Date: [Sep. 25th, 2024]

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from https://www.sqpolska.com (the “Site”).

1、PERSONAL INFORMATION WE COLLECT

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as “Device Information”.

We collect Device Information using the following technologies:

1.1 “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.

1.2 “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.

1.3 “Web beacons”, “tags”, and “pixels” are electronic files used to record information about how you browse the Site.

[[INSERT DESCRIPTIONS OF OTHER TYPES OF TRACKING TECHNOLOGIES USED]]

When you contact us by e-mail or via a contact form, the data you provide (your e-mail address, name and telephone number, company name, resident country, if applicable) will be stored by us in order to answer your questions. When you register a customer account with us, we only collect the information that you voluntarily share with us. This data may include, for example : your email address and a password you choose yourself；Your name, telephone numbers，your resident country；Your facebook account and google account；Any further information on your person and your interests that you might share with us.

Additionally when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, purchased item details (name, price, model, etc.), order number, billing address, shipping address, payment information (including [credit card] [PayPal] [[INSERT ANY OTHER PAYMENT TYPES ACCEPTED]]),Delivery and payment status, e.g. “completed” or “dispatched” , After sales status, Information regarding service providers involved (e.g. shipment numbers of parcel services), email address, and phone number. We refer to this information as “Order Information”.

[[INSERT ANY OTHER INFORMATION YOU COLLECT: OFFLINE DATA, PURCHASED MARKETING DATA/LISTS]]

When we talk about “Personal Information” in this Privacy Policy, we are talking both about Device Information and Order Information.

2、HOW DO WE USE YOUR PERSONAL INFORMATION?

We use the Order Information that we collect generally to fulfill any orders placed through the Site (including processing your payment information, arranging for shipping, and providing you with invoices and/or order confirmations). Additionally, we use this Order Information to:

2.1 Communicate with you.

2.2 Screen our orders for potential risk or fraud.

2.3 When in line with the preferences you have shared with us, provide you with information or advertising relating to our products or services.

2.4 We collect the payment details shared by you in order to execute the payment. We receive further payment details from external payment service providers and credit agencies which we work with in executing payments and carrying out credit checks. We only forward information to our payment service providers which is necessary for processing payment. Payment details include: Billing addresses、Preferred payment method、IBAN and BIC or account number and sort code、Credit card details.

The payment details also include other information directly connected to payment processing and credit checking. This applies, for example, to information which external payment service providers use for identification such as your PayPal ID if you are paying with PayPal.

2.5 Transfer of data on outstanding debts to collection service providers

In the event that outstanding invoices are not settled despite repeated reminders, we may transfer the data required to commission a collection service provider to a collection service provider for the purpose of collecting the debt. Alternatively, we may sell the debt to a collection service provider which is then able to file a claim in its own name. The agencies we charge with collection services are the following [Please fill in the information of the debt collection service provider you cooperate with, if not, delete this paragraph]

Legal basis: The legal basis for transferring data within the framework of fiduciary collection services is Article 6 (1) b GDPR; data is transferred within the framework of selling debt on the basis of Article 6 (1) f GDPR.

[[INSERT OTHER USES OF ORDER INFORMATION]]

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

[[INSERT OTHER USES OF DEVICE INFORMATION, INCLUDING: ADVERTISING/RETARGETING]]

3、SHARING YOUR PERSONAL INFORMATION

We share your Personal Information with third parties to help us use your Personal Information, as described above.

we may pass on your personal data to third parties not already mentioned in this privacy policy if we offer participation in promotions, competitions, conclusion of contracts or similar services together with partners. Depending on the service, your data may also be collected by the partners on their own responsibility. You will receive more detailed information when you provide your data or in the description of the respective offers.

3.1 Transfer only where allowed by law

We only forward your data if this is allowed by German or European law. We work particularly closely with certain service providers, for example in the area of customer service providers , with technical service providers or with logistics companies . These service providers may generally only process your data on our behalf under special conditions. Where we use them to process orders, the service providers only receive access to your data in the scope and for the time period required for provision of the relevant service. If you shop with one of our partners, we forward particular shopping data regarding you to the partner (e.g. your name and your delivery address), so that the partner can send you the goods ordered.

3.2 Technical service providers

We work with technical service providers in order to be able to provide our services. These service providers include, for example, [2Cshop]. If they process your data outside the European Union, this may mean that your data is transmitted to a country with a lower data protection standard than the European Union. In such cases we will ensure that the relevant service providers contractually or otherwise guarantee an equivalent data protection level.

3.3 Payment service providers and credit agencies

We offer different payment options, such as advance payment, payment by credit card, payment by PayPal and payment on invoice. For this purpose, payment data can be transferred to payment service providers with whom we work with. You can find more details about processing of personal data by payment service providers in their privacy policies:

(e.g："We use PayPal for payments and other services. If you wish to use one of these services and pay on our website, PayPal may collect the personal data you provide, such as payment and other identifying information. PayPal uses this information to operate and improve the services it provides to us and others, including for fraud detection, harm and loss prevention, authentication, analytics related to the performance of its services, and to comply with applicable legal requirements. The processing of this information will be subject to the PayPal Privacy Statement available: https://www.paypal.com/c2/legalhub/privacy-full at PayPal.com."

[Please fill in the other partner payment service provider and attach a link to its privacy policy]

The service provider we use for credit checks is [Please fill in the name of the cooperative credit reporting agency, if not, delete this paragraph.] Its privacy policy can be found here [The link to the privacy policy of the credit reporting agency, if not, this paragraph will be deleted].

3.4 Shipping companies

We work with external shipping companies (e.g. [Please enter the cooperative logistics service provider and attach a link to its privacy policy] to deliver orders.

3.5 We also use Google Analytics to help us understand how our customers use the Site -- you can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Finally, we may also share your Personal Information to comply with applicable laws and regulations, to respond to a subpoena, search warrant or other lawful request for information we receive, or to otherwise protect our rights.

3.6 Authorities and other third parties

If we are obliged by an official or court decision or it is for prosecution purposes, we will if necessary forward your data to prosecution authorities or other third parties.

4、BEHAVIOURAL ADVERTISING

As described above, we use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page at http://www.networkadvertising.org/understanding-online-advertising/how-does-it-work.

You can opt out of targeted advertising by using the links below:

4.1 Facebook: https://www.facebook.com/settings/?tab=ads

4.2 Google: https://www.google.com/settings/ads/anonymous

4.3 Bing: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

[[INCLUDE OPT-OUT LINKS FROM WHICHEVER SERVICES BEING USED]]

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal at: http://optout.aboutads.info/.

5、OTHER TRACKING TECHNOLOGIES

We may also use Tracking Technologies to collect "clickstream" data, such as the domain name of the service providing you with Internet access, your device type, IP address used to connect your computer to the Internet, your browser type and version, operating system and platform, the average time spent on our Site, webpages viewed, content searched for, access times and other relevant statistics, and assign unique identifiers to the device or other credentials you use to access the Site for the same purposes.

Pages of our Site may also use Java scripts, which are code snippets embedded in various parts of websites and applications that facilitate a variety of operations including accelerating the refresh speed of certain functionality or monitoring usage of various online components; entity tags, which are HTTP code mechanisms that allow portions of websites to be stored or “cached” within your browser to accelerate website performance; and HTML5 local storage, which allows data from websites to be stored or “cached” within your browser to store and retrieve data in HTML5 pages when the website is revisited.

6、DO NOT TRACK

Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Site does not currently process or respond to “DNT” signals.

7、LOCATION INFORMATION

You may be able to adjust the settings of your device so that information about your physical location is not sent to us or third-parties by (a) disabling location services within the device settings; or (b) denying certain websites or mobile applications permission to access location information by changing the relevant preferences and permissions in your mobile device or browser settings.

8、PERSONAL DATA PROTECTION

We use technical and organisational measures to secure our systems. With regard to your order and your customer login, we transmit your personal data securely using SSL encryption (Secure Socket Layer).

9、YOUR RIGHTS

You have the following rights against us as a data controller in respect of personal data relating to you:

right to information,right of rectification or erasure,right to restriction of processing,right to object to processing,right to data portability.right to withdraw consent (in case consent is the basis for data processing).

9.1 Information requests

In order to ensure that your data is not disclosed to third parties in the course of requests for information, please attach sufficient proof of identity to your request.

9.2 Withdrawal of consent.

If you have given your consent to the processing of your data, you may revoke this consent at any time. Such revocation affects the permissibility of the processing of your personal data after you have expressed it to us. The permissibility of the processing of your data up to the time of your revocation remains unaffected.

9.3 Objection in case of processing on the basis of balancing of interests

Insofar as we base the processing of your personal data on a balancing of interests, you may object to the processing. This is the case if the processing is not necessary, in particular, for the fulfilment of a contract with you, which is shown by us in each case in the following description of the functions. When exercising such an objection, we ask you to explain the reasons why we should not process your personal data in the way we have done. In the event of your objection, we will review the situation and either cease or adjust the data processing or show you our compelling legitimate grounds for continuing the processing.

Of course, you can object to the processing of your personal data for advertising and data analysis purposes at any time. The best way to exercise your advertising objection is to contact us using the contact details provided above.

You also have the right to complain to a data protection supervisory authority about our processing of your personal data. The competencies of the supervisory authorities depend on the seat of the data controller. You may, however, contact any data protection authority in any member state of the European Union, in particular at your place of residence, which will forward your complaint to the competent authority.

10、RETENTION AND ERASURE OF DATA

We will store your personal data as long as is necessary for the purposes named in this Privacy Notice, especially for the fulfilment of our contractual and legal obligations. We may also store your personal data for other purposes if or as long as the law allows us store it for particular purposes, including for defence against legal claims.

If you close your customer account, we will delete all the data we have stored regarding you. If it is not possible or necessary to completely delete your data for legal reasons, the relevant data will be blocked for further processing. If data is blocked, technical and organisational measures are used to ensure that only a few employees can access the relevant data, based on need to know and only for select purposes (e.g. in the event of a tax audit).Blocking will occur, for example, in the following cases:

10.1 Your order and payment details and perhaps other details are generally subject to various legal retention obligations, such as those in the Handelsgesetzbuch (HGB - Commercial Code) and the Abgabenordnung (AO - Tax Code). The law obliges us to retain this data for tax audits and financial audits for up to ten years. Only then can we finally delete the relevant data.

10.2 Even if your data is not subject to any legal retention obligation, we may refrain in the cases allowed by the law from immediate deletion and instead carry out initial blocking. This applies especially in cases where we may need the relevant data for further contractual processing or prosecution or legal defence (e.g. in the event of complaints). The decisive criterion for the duration of the blocking is then the legal limitation periods. After the relevant limitation periods expire, the relevant data will finally be deleted.

Deletion may be waived in the cases allowed by law if the data is anonymous or pseudonymous and deletion would rule out or seriously hinder processing for scientific research or statistical purposes.

11、CHANGES

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons.

12、MINORS

The Site is not intended for individuals under the age of ${age} .

13、CONTACT US

For more information about our privacy practices, if you have questions, or if you would like to make a complaint, please contact us by e-mail at shengqiangc2@gmail.com or by mail using the details provided below:

SQ POLSKA 688 SP.Z O.O.

[Re: Privacy Compliance Officer]

ul. NADRZECZNA, nr 16, lok. H4B22, miejsc. WÓLKA KOSOWSKA, kod 05-552, poczta POLSKA