GTW Gear Online Store Privacy Policy
This Privacy Policy is intended for visitors to https://gtwgear.com (the “Website”), the GTW Gear online store (the “Store”).
The controller of your personal data in connection with use of the Store is Krzysztof Gluch, trading as EMKA-GTW Krzysztof Gluch, with its registered address at Gajków, ul. Młyńska 13, 55-002, Poland, entered in the Polish Central Register and Information on Economic Activity, Tax ID (NIP): 9121004361, National Business Registry Number (REGON): 932369560 (the “Controller,” “we,” or “us”).
For all matters concerning personal-data processing, contact us at info@gtwgear.com or write to the registered address above.
1. Cookies and similar technologies
We use cookies and similar technologies to understand how visitors use the Website and, subject to consent, for analytics and marketing, including displaying advertisements elsewhere on the Internet.
What are cookies?
A cookie is a small text file saved by a website on the computer, phone, or other device used to browse it. It contains information relating to the use of that website.
Some cookies are strictly necessary for the Store and cannot be disabled through our consent panel. All other cookies, including analytics and advertising cookies, are used only after you give consent when first visiting the Website. You can change or withdraw your consent through the cookie-preference panel.
Types of cookies we use
Strictly necessary cookies. These cookies are required for the Store to operate, remain secure, remember privacy settings, administer the Website, and activate only those tracking tools to which you have consented.
Analytics cookies. Analytics tools help us understand how visitors use the Website. The information available to us does not directly identify a named individual, but it allows us to measure visits, viewed pages, interaction patterns, traffic sources, device and browser information, and similar usage statistics. We aggregate and analyze these data to improve the Store and our advertising and marketing communications.
Advertising cookies. Subject to consent, advertising tools allow us to display targeted advertisements on other websites and social-media services, measure campaign effectiveness, and tailor messages to information about audience segments. Cookies may also be used to embed newsletter-subscription forms and measure their effectiveness. Email-marketing analytics may be combined with Store analytics to improve messages sent to subscribers.
Functional cookies. These cookies enable optional Store functions such as chat, product reviews or ratings, product sharing, and recently viewed products. The current list and purposes are shown in the cookie-preference panel.
Social-media links
The Website contains links to our Facebook and Instagram profiles. When you follow such a link, the operator of that service may receive information that you arrived from the Store, in the same way as when moving between other websites. Details are available from Meta's Privacy Center.
Legal basis for cookies and profiling
The legal basis for strictly necessary cookies is our legitimate interest in operating and securing a Website that supports our business. The legal basis for all non-essential cookies is your consent. Where information obtained through cookies constitutes personal data, you have the rights described below.
Advertising and analytics may involve profiling. This means that we or our marketing providers may create a user profile from information such as an email address, order history, device type, technologies used, and frequency of visits, and use it to predict interests or likely purchasing behavior. This helps determine which content and advertisements are shown on our Website and elsewhere. Profiling is not used to make decisions that produce legal or similarly significant effects for you.
How long cookies remain on your device
Session cookies expire when the browser session ends. Persistent cookies remain until their stated expiry date unless you delete them earlier through browser settings. Third-party analytics, advertising, functional, and social-media cookies are also subject to the respective provider's policies.
2. Other purposes for which we process personal data
| Purpose | Categories of data | Legal basis |
|---|---|---|
| Processing orders and providing customer Accounts | Identification and contact details required for fulfillment; order details and history | Performance of a contract — Article 6(1)(b) GDPR |
| Responding to inquiries and correspondence | Identification details and information supplied in a contact form or correspondence; correspondence history | Our legitimate interest in communicating with persons who contact us — Article 6(1)(f) GDPR |
| Complaints, returns, withdrawal, and other after-sales service | Identification and contact details; order details and history; correspondence history | Our legitimate interest in handling complaints and statutory withdrawal procedures — Article 6(1)(f) GDPR |
| Publishing product reviews and comments | Review or comment content and identifying details of the person submitting it | Your consent, expressed by submitting or publishing the review or comment — Article 6(1)(a) GDPR |
| Claims, records, and compliance evidence | Data received from customers and Store users for the purposes described in this Policy | Our legitimate interest in establishing, exercising, or defending legal claims and demonstrating GDPR compliance — Article 6(1)(f) GDPR |
| Accounting and tax compliance | Customer identification and contact details; invoice details | Compliance with legal obligations — Article 6(1)(c) GDPR |
| Newsletter | Email address and message statistics, including opening history | Our legitimate interest arising from your marketing consent — Article 6(1)(f) GDPR; electronic marketing is sent only with the required consent |
| Sales and traffic analytics | Store sales statistics and Website usage statistics | Our legitimate interest in business analysis and optimization; Website traffic analytics are used subject to cookie consent — Article 6(1)(f) GDPR |
| Marketing our own products and services | Browsing history, purchase history, demographic or audience-segment characteristics, and similar marketing attributes | Our legitimate interest in marketing our own products and services — Article 6(1)(f) GDPR. Cookie-based marketing and direct electronic marketing require prior consent where required by law |
Providing personal data is voluntary, but certain data are necessary to process an order, issue an invoice, notify you about order status, answer an inquiry, handle a complaint, or provide another service you request.
3. Retention periods
Order-related data are processed for as long as necessary to fulfill the order and thereafter for the periods required by accounting and tax law. Other data are kept for as long as necessary for the purposes described above: until our applicable legitimate interest ends, you successfully object, or you withdraw consent where consent is the basis for processing.
Further retention may occur where required by law, particularly for tax purposes, and for archiving necessary to establish, exercise, or defend claims until the relevant limitation periods expire.
4. Recipients of personal data
We use service providers in operating the Store. Data may be entrusted to the Store-software provider, hosting providers for the Website and email, accounting providers, and providers of marketing and analytics tools. For order fulfillment, data may be disclosed to delivery companies and payment intermediaries; these entities may act as independent controllers for their own services.
5. International transfers
For the marketing and analytics activities described under Cookies, we may use providers based in the United States, including Google and Meta. Personal data may therefore be transferred outside the European Economic Area. Where applicable, an adequate level of protection is provided through the EU–US Data Privacy Framework or another lawful transfer mechanism. More information is available at dataprivacyframework.gov.
6. Your rights
We protect the confidentiality of your personal data and enable you to exercise your rights free of charge by emailing info@gtwgear.com or contacting us using the details above.
Subject to the conditions set by the GDPR, you have the right to:
- request access to the personal data we hold about you;
- request correction of inaccurate or incomplete data;
- request erasure where the data are no longer necessary or no other legal basis applies;
- withdraw consent at any time, without affecting the lawfulness of processing before withdrawal;
- object to processing based on legitimate interests, including direct marketing;
- request restriction of processing;
- receive data you provided in a structured, commonly used, machine-readable format and, where technically feasible, have those data transmitted to another controller when the right to portability applies;
- lodge a complaint with the President of the Polish Personal Data Protection Office if you believe that processing violates data-protection law.
7. Additional information for Newsletter subscribers
If you subscribe, we will send marketing information about our products and services, including product launches, promotions, and special offers. You may unsubscribe at any time by using the link included in every Newsletter or by contacting us.
Our email-marketing system provides statistics such as whether a message was opened. We analyze these data to tailor Newsletter and notification content to subscriber interests, which may constitute profiling. You may object to this processing at any time. If a subscriber remains inactive for two years, we may stop sending the Newsletter and remove the subscriber from the list after giving additional notice.
We do not use personal data to make decisions based solely on automated processing that produce legal effects or similarly significantly affect you. The contractual rules for the Newsletter are included in the Newsletter Terms.
Appendix 1 — Analytics and advertising tools using cookies
Google Analytics
Subject to consent, Google Analytics may collect information such as the number of visits, pages viewed, dates of first and last visits, visit duration, traffic source, browser, clicked links, approximate geographic area, and a shortened/anonymized IP address. Google assigns its own identifier and processes cookie-derived data on its servers. We receive aggregated Website traffic reports only for users who consented to analytics cookies.
Further information is available at Google's partner-site policy and Google Analytics security and privacy information. The Google Analytics opt-out browser add-on is available at tools.google.com/dlpage/gaoptout.
Shoper platform cookies
The provider of the Shoper platform places cookies to collect aggregate information about use of online stores, such as viewed pages and products, time spent, clicks, and purchase analytics including conversion rates. These data are used to create aggregated reports without directly identifying individuals, helping store owners improve their stores and sales processes.
Google Ads and other Google advertising tools
Subject to consent, Google may process data from advertising cookies across websites on which you permitted such use and from advertisements you clicked. Google uses these data to display advertisements on other websites. Google advertising cookies generally expire after approximately three months. We do not receive the raw cookie data stored on your device; we select audience groups using aggregate criteria, such as visitors to the Website or a particular page during a defined period, and may measure campaign effectiveness.
More information and advertising controls are available at Google Advertising Technologies.
Email marketing
We use a third-party email-marketing platform. Subject to the applicable consent settings, it may place cookies used to display subscription forms and measure their conversion performance. The platform also processes subscription and campaign statistics as described in this Policy.
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