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PRIVACY POLICY

frostbox.pl
Version: 14 January 2026

This Privacy Policy is informational in nature and constitutes the fulfilment of obligations under Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR). This document does not constitute an offer or contract within the meaning of the Polish Civil Code and does not create any additional obligations on the part of the Controller beyond those arising from mandatory legal provisions.

1. Data Controller

The controller of your personal data is:

FIFO Prosta Spolka Akcyjna

ul. Kanonia 9, 50-328 Wroclaw, Poland

Tax ID (NIP): 8982295483

Statistical Number (REGON): 525881729

National Court Register (KRS): 0001047768

Registration Court: District Court for Wroclaw-Fabryczna in Wroclaw, VI Commercial Division of the National Court Register

Contact for data protection matters: [email protected]

2. Purposes and Legal Bases for Processing

We process your personal data for the following purposes:

2.1. Order fulfilment and contract performance

Legal basis: GDPR Art. 6(1)(b) — performance of a contract to which you are a party, or taking steps prior to entering into a contract.

Scope of data: name, surname, delivery address, email address, phone number, invoice details (Tax ID, company name, address).

2.2. Payment processing

Legal basis: GDPR Art. 6(1)(b) — contract performance.

Payment operators: Stripe, Przelewy24, credit card operators, leasing companies. Payment data (card numbers) is not stored on our servers — we transmit it directly to payment operators in accordance with PCI DSS standards.

2.3. User account management

Legal basis: GDPR Art. 6(1)(b) — provision of account management service.

Scope of data: email address, password (encrypted), order history, saved addresses.

2.4. Contact form and inquiry handling

Legal basis: GDPR Art. 6(1)(f) — legitimate interest of the controller in servicing customers and potential customers.

Scope of data: name, email address, phone number (optional), message content.

2.5. Newsletter and direct marketing

Legal basis: GDPR Art. 6(1)(a) — your voluntary consent.

Scope of data: email address. You may withdraw consent at any time via the unsubscribe link in any message or by contacting us.

2.6. Analytics and website optimization

Legal basis: GDPR Art. 6(1)(a) — consent given by accepting analytical cookies.

Tools: Google Analytics. Data is anonymized (truncated IP addresses).

2.7. Remarketing and advertising

Legal basis: GDPR Art. 6(1)(a) — consent given by accepting marketing cookies.

Tools: Meta Pixel (Facebook/Instagram), Google Ads.

2.8. Legal and tax obligations

Legal basis: GDPR Art. 6(1)(c) — compliance with legal obligations (maintaining accounting records, issuing invoices).

2.9. Establishment, exercise or defence of legal claims

Legal basis: GDPR Art. 6(1)(f) — legitimate interest of the controller.

2.10. AI chat assistant

Our website offers a chat with an AI assistant. The assistant is a computer program, not a person. It answers questions about our offer and takes enquiries, including service requests.

Legal basis: GDPR Art. 6(1)(b) – steps taken at your request before entering into a contract – and Art. 6(1)(f) – our legitimate interest in handling enquiries. Scope of data: the content of the conversation and any data you provide in it (name, phone number, e-mail address). The conversations are handled on our behalf by ElevenLabs Inc. (USA). Enquiries from the chat are forwarded to our team by e-mail and via the Telegram messenger.

Data may be transferred to the USA on the basis of the safeguards provided in Chapter V GDPR (the European Commission's adequacy decision for the EU-US Data Privacy Framework or standard contractual clauses). Chat transcripts are stored for 90 days and then deleted. Please do not share sensitive data or payment card details in the chat.

3. Requirement to Provide Data

Providing personal data is voluntary, but in some cases necessary to use certain website features or enter into a contract:

PurposeRequirementConsequence of Not Providing
Placing an orderContractual requirementUnable to process order and delivery
Account registrationVoluntaryNo access to account features (order history, quick checkout)
Contact formVoluntaryUnable to respond to inquiry
NewsletterVoluntaryNo marketing communications received

4. Data Recipients

Your personal data may be transferred to the following categories of recipients:

— Payment operators: Stripe, Przelewy24, credit card operators, leasing companies

— Courier and transport companies handling delivery

— IT service providers: hosting, servers, e-commerce systems

— Accounting firm handling bookkeeping

— Providers of analytical and marketing tools: Google, Meta

— AI solution providers supporting customer service

— Public authorities, where required by law

The Controller is not responsible for the privacy policies and data processing practices of third parties. We recommend reviewing their privacy policies.

5. Transfers Outside the European Economic Area

Some of our service providers are located outside the European Economic Area, including in the United States. This includes in particular:

— Google LLC (Google Analytics, Google Ads)

— Meta Platforms, Inc. (Facebook Pixel, WhatsApp)

— Stripe, Inc. (payment processing)

— AI solution providers

Data transfers to the USA are made on the basis of:

— European Commission implementing decision on the EU-US Data Privacy Framework (for certified entities)

— Standard contractual clauses adopted by the European Commission

6. Data Retention Periods

We retain your data for the period necessary to achieve the purposes for which it was collected:

Data CategoryRetention PeriodLegal Basis
Transaction data (invoices, orders)5 years from the end of fiscal yearPolish Tax Code, Accounting Act
Warranty and complaint data6 years from purchase dateLimitation period (Polish Civil Code)
Contact form dataUntil matter resolved + 3 yearsLimitation of claims
User account dataUntil account deletion + 5 years for transaction dataGDPR + tax regulations
Newsletter and marketingUntil consent withdrawalGDPR Art. 6(1)(a)
Analytical cookiesAccording to cookie settingsUser consent

7. Automated Decision-Making

We do not make decisions about you based solely on automated processing, including profiling, that would produce legal effects or similarly significantly affect you within the meaning of GDPR Art. 22.

Analytical and marketing tools may create behavioral profiles for ad personalization purposes, but these do not affect your rights or obligations towards us.

8. Your Rights

You have the following rights in relation to the processing of your personal data:

Right of access

You can obtain information about whether we process your data and, if so, obtain a copy.

Right to rectification

You can request correction of inaccurate data or completion of incomplete data.

Right to erasure ("right to be forgotten")

In certain circumstances, you can request deletion of your data. This right does not apply where processing is necessary for the establishment, exercise or defence of legal claims or compliance with a legal obligation.

Right to restriction of processing

You can request restriction of processing in certain cases.

Right to data portability

You can receive your data in a machine-readable format.

Right to object

You can object to processing based on legitimate interest, including direct marketing.

Right to withdraw consent

If processing is based on consent, you can withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing before its withdrawal.

Right to lodge a complaint

You have the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw, Poland, www.uodo.gov.pl).

Requests are fulfilled within one month of receipt. In case of complex requests, the deadline may be extended by another two months, of which you will be informed.

9. Cookies

The frostbox.pl website uses cookies — small text files stored on your device by your web browser.

9.1. Types of cookies

Cookie TypePurposeLegal Basis
Strictly NecessaryWebsite functionality, shopping cart, user session, securityLegitimate interest (GDPR Art. 6(1)(f))
FunctionalRemembering preferences, language, regionUser consent (GDPR Art. 6(1)(a))
AnalyticalGoogle Analytics — statistics, website optimizationUser consent (GDPR Art. 6(1)(a))
MarketingMeta Pixel, Google Ads — remarketing, ad personalizationUser consent (GDPR Art. 6(1)(a))

9.2. Managing cookies

On your first visit to the website, we display a banner allowing you to consent or decline to individual categories of cookies. You can change your preferences at any time via the "Cookie settings" link in the footer.

You can also manage cookies in your browser settings. Disabling all cookies may limit website functionality.

9.3. Third-party cookies

Some cookies are set by third parties (Google, Meta). These parties may use them for their own purposes in accordance with their privacy policies:

— Google: https://policies.google.com/privacy

— Meta: https://www.facebook.com/privacy/policy/

The Controller is not responsible for the content and practices of third parties. Use of their services is subject to their own terms and policies.

10. Data Security

We implement appropriate technical and organizational measures to protect your data against unauthorized access, loss or destruction. In particular:

— Connection to the website is encrypted (SSL/TLS)

— Passwords are stored in encrypted form

— Payment data is processed by certified operators (PCI DSS)

— We regularly update software and security systems

— Access to data is limited to authorized personnel only

Despite implementing appropriate safeguards, no system of data transmission over the Internet or data storage system is completely secure. The Controller cannot guarantee absolute security of data transmitted over the Internet.

11. Links to External Websites

The frostbox.pl website may contain links to third-party websites. The Controller is not responsible for the privacy policies, data processing practices or content of external websites. We recommend reviewing the privacy policies of websites you visit.

12. Governing Law and Jurisdiction

This Privacy Policy is governed by Polish law.

Any disputes relating to the processing of personal data shall be resolved by the competent Polish courts, subject to mandatory consumer protection provisions that may grant the right to bring proceedings before courts of the consumer's place of residence.

13. Changes to the Privacy Policy

The Controller reserves the right to amend this Privacy Policy. Changes may result from technological developments, changes in legislation or development of the service offering.

We will inform you of significant changes via a notice on the website or an email (if we have your address). Continued use of the website after publication of changes constitutes acceptance thereof.

We encourage you to periodically review this page. The date of the last update is always visible at the beginning of the document.

14. Contact

For matters related to the protection of personal data, you can contact us:

Email: [email protected]

Phone: +48 71 707 90 25

Address: FIFO Prosta Spolka Akcyjna, ul. Kanonia 9, 50-328 Wroclaw, Poland

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