PRIVACY POLICY

1. This Privacy Policy defines principles of gathering, processing and using
personal data obtained by website www.fokuspokus.lt (hereinafter
referred as “the Website”).
2. The Website is owned by Fokuspokus who runs economic
activity under name Fokuspokus Studio Fokuspokus seated in
Vilnius , entered into the
Business Activity Central Register and Information Record kept by the
Minister of Economy,hereinafter
referred to as Fokuspokus Studio Fokuspokus. Fokuspokus
is also the Personal Information Administrator.
3. Personal data collected by Fokuspokus Studio Fokuspokus via the
Website are processed in compliance with Regulation (EU) 2016/679 of
the European Parliament and of the Council of 27 April 2016 on the
protection of natural persons with regard to the processing of personal
data and on the free movement of such data, and repealing Directive
95/46/EC (General Data Protection Regulation), hereinafter also referred
to as GDPR.
4. Fokuspokus Studio Fokuspokus acts with utmost care in order to
ensure privacy of Users who visit the Website.

Article 2 - Type of processed data, objectives and legal

ground

1. Fokuspokus Studio Fokuspokus collects data on individuals who run

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economic or professional activity on their own behalf (hereinafter
referred to as the Entrepreneurs), and data on individuals who perform
legal actions that are not directly related to their activity, hereinafter
referred to as Customers.
2. Customer personal data are collected for:
a) registration of an account in the Website for the purpose of
establishment and management of an individual account. Legal
grounds: processing is necessary for the performance of a contract
on establishment and management of an Account service (article 6
sec. 1 letter b of GDPR);
b) placement of an order in the Website for the purpose of the
performance of a sales contract. Legal grounds: processing is
necessary for the performance of a sales contract (article 6 sec. 1
letter b of GDPR);
c) use of the contact form service for the purpose of the performance of
a contract executed by electronic means. Legal grounds: processing
is necessary for the performance of a contract on contact form
services (article 6 sec. 1 letter b of GDPR).

3. In case of a registration of an Account in the Website, a User shall provide
following data:
a) e-mail;
b) name and surname;
c) phone number;
4. During registration of an account in the Website, the Customer defines an
individual access password to their account. The Customer may change
an account later in compliance with principles defined in Article 6.
5. In the case of ordering in the Website, Customer provides the following
information:
a) e-mail;
b) address data:
a. postal code and place of residence;
b. country;
c. street and house/flat number.
c) name and surname;
d) phone number;
6. In the case of Entrepreneurs above the data range is further extended by:
a) the company name;
b) Business Tax Number;

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c) national business registry number (REGON).
7. When using the contact form service, the Customer shall provide the
following data:
a) e-mail;
b) name and surname;
c) phone number;
8. During the Website browsing additional information may be collected such
as IP address assigned to User's computer or external IP address of your
ISP's, domain name, browser type, time of access, the type of operating
system.
9. Also navigation data may be collected from the Customers, including
information on links and references they click or other activities
undertaken by them in our Website. Legal grounds- legitimate interests
(article 6 sec. 1 letter f of GDPR) in form of facilitation of use of services
rendered by electronic means and improvement of functionality of such
services.
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.
To determine, exercise and enforce claims, come personal data provided
by the Customer when using functionalities of the Website may be
provided, such as: name, surname, information about use of services, if
claims result from the manner of user of services by the Customer, other
data necessary to prove existence of claim, including the volume of
suffered losses. Legal grounds- legitimate interests (article 6 sec. 1 letter
f of GDPR) in form of determination, exercising and enforcement of claims
and defence against claims in litigation and proceeding in front of other
public authorities.
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.
Personal data are provided to Fokuspokus Studio Fokuspokus on
voluntary basis in relation to concluded sales contracts or services
rendered via the Website Website, provided that, however, without data
specified in the data forms in the Registration process, Registration and
establishment of a Customer Account is not possible, and if orders are
placed without Registration of Customer Account, placement and
fulfilment of Customer order will be impossible.

Article 3 - To whom are data disclosed or provided and how

long are they stored?

1. Customer’s personal data are provided to providers of services used by
Fokuspokus Studio Fokuspokus when operating the Website
depending on contractual arrangements and circumstances, they are
either subject to Fokuspokus Studio Fokuspokus’s instructions about
manners and ways of data processing (processors) or they define purposes
and manners of processing on their own (data controllers).

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a) Processors. Fokuspokus Studio Fokuspokus uses services of
providers processing data on Fokuspokus Studio Fokuspokus’s
request only. They include for instance hosting providers, accounting
services, providers of marketing systems, systems of traffic analysis in
the Website, systems for analysis of marketing campaign efficiency;
b) Controllers. Fokuspokus Studio Fokuspokus uses services of
providers that do not act on request only, but they define the
objectives and manners of use of Customers’ personal data. They
render electronic payment and banking services.

2. Location. Providers of services have their registered offices mainly in
Poland and other countries of the European Economic Area (EEA).
3. Customers’ personal data are stored:
a) If Customer’s personal data are processed on the basis of a consent,
they shall be processed by Fokuspokus Studio Fokuspokus until
the consent is not cancelled, and after cancellation of the consent – for
a period of time corresponding to the period of limitation of claims
that may be raised by or against Fokuspokus Studio Fokuspokus.
If it is not provided otherwise in a specific provision, period of
limitation amounts to six years, and in case of claims concerning
periodical services or claims related to business activity – three years;
b) If personal data are processed on the basis of execution of the
contract, then the Customers’ personal data shall be processed by
Fokuspokus Studio Fokuspokus as long, as it is necessary for
execution of the contract, and afterwards – for a period of time
corresponding to the period of limitation of claims. If it is not provided
otherwise in a specific provision, period of limitation amounts to six
years, and in case of claims concerning periodical services or claims
related to business activity – three years.

4. In case of purchase in the Website personal data may be transferred,
depending on customer choice, to the following entities in order to deliver
the ordered goods:
a) a courier company;


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7. In case of a respective request, Fokuspokus Studio Fokuspokus
discloses personal data to authorised state authorities, in particular to
organisational units of the prosecutor’s office, the Police, the Chairperson
of the Personal Data Protection Office, the Chairperson of the Office of
Competition and Consumer Protection or the Chairperson of the Office of
Electronic Communications.

Article 4 - Cookies mechanism, IP address

1. The Website uses small files called cookies. They are recorded by Fokuspokus
Studio Fokuspokus Website on a computer of a visitor to the
Website, if a web browser allows so. Cookie file usually contains a name of
domain, where it comes from, its expiry time and an individual random
number that identifies such file. Information collected by means of such
type of files allow to adjust services offered by Fokuspokus Studio Agnieszka
Tymińska to individual preferences and actual needs of visitors at the
Website. It gives also an opportunity to work out general statistics of hits
into information presented at the Website.
2. Fokuspokus Studio Fokuspokus uses two types of cookie files:
a) Session cookie: recorded information is deleted from memory of
a device after an end of a session of a given web browser or after
a computer is turned off. Session cookie mechanism does not allow for
collection of any personal data and other confidential information from
User’s computer.
b) Persistent cookie: they are kept on User’s hard disk drive until they
are deleted. Persistent cookie mechanism does not allow to collect any
personal information or any confidential information from users
computer.

3. Fokuspokus Studio Fokuspokus uses its own cookies for:
a) authentication in the Website and to ensure the User session in the
Website (after logging in), through which the user does not have on
every page to retype your login and password;
b) analyzes and surveys and audits audience, and in particular to create
anonymous statistics that help to understand how customers use the
Website, which allows improvement of its structure and content.
4. Fokuspokus Studio Fokuspokus uses external cookies to:
a) to present the Certificate Trusted Regulations through the Service
rzetelnyregulamin.pl (external cookies administrator Rzetelna Grupa
Sp. z o.o. with its registered office Warsaw, Poland).

5. The cookie mechanism is safe for computers of the Website’s Users. In
particular this way does not give a possibility for viruses or other
unwanted or malicious software to enter your computers. Still, Users have

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an option in their web browsers to limit or switch off the access of cookie
files to their computers. If you use this option, you may still use the
Website except functions that due to their nature require cookies.
6. Below you can find how to change the settings for web browsers on the
use of cookies:
a) Chrome;
b) Facebook in-app Browser;
c) Internet Explorer;
d) Microsoft EDGE;
e) Mozilla Firefox;
f) Opera;
g) Safari;
h) Samsung Browser.
7. Fokuspokus Studio Fokuspokus may collect your IP address. IP
address is a number assigned to the computer of a website visitor by your
ISP. IP number allows you to access the Internet. In most cases, the
computer is assigned dynamically, ie it changes every time you connect to
the Internet and therefore is widely regarded as a non-personally
identifying information. The IP address is used by Fokuspokus Studio
Fokuspokus in diagnosing technical problems with the server,
creating a statistical analysis (eg determining regions from which we note
the most visits), as information useful in administering and improving the
Website, as well as for security purposes and the possible identification of
aggravating server unwanted automatic programs for viewing Website
content.
8. The Website contains links and hyperlinks to other web pages. Fokuspokus
Studio Fokuspokus shall not be responsible for privacy policies in
force therein.

Article 5 - Rights of data subjects

1. The right to withdraw consent – legal ground: article 7 sec. 3 of GDPR.
a) The Customer has a right to withdraw consent granted to Fokuspokus
Studio Fokuspokus.
b) Withdrawal of consent shall be effective as the time of withdrawal.
c) Withdrawal of consent shall not affect the lawfulness of processing
before its withdrawal.
d) Withdrawal of consent shall not entail any negative consequences for
the Customer, but may prevent them from further use of services of

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functionalities, which may be lawfully provided by Fokuspokus Studio
Fokuspokus only upon consent of the Customer.
2. Right to object to personal data processing - legal ground: article 21 of
GDPR.
a) The Customer shall have the right to object, on grounds relating to
their particular situation, at any time to processing of personal data
concerning them, including profiling, if Fokuspokus Studio Agnieszka
Tymińska processes their data on the basis of a legitimate interest,
such e.g. marketing of Fokuspokus Studio Fokuspokus’s products
and services, statistic concerning use of individual functionalities of
the Website and facilitation of use of the Website, and Customer
satisfaction surveys;
b) An e-mail resignation from marketing communications on products or
services will mean the Customer’s objection to processing of their
personal data, including profiling for those purposes;
c) If the Customer’s objection is reasonable and Fokuspokus Studio
Fokuspokus has no other legal grounds to process personal
data, the Customer’s personal data, whose processing has been
objected by the Customer, will be deleted.

3. Right to erasure (“right to be forgotten” ) - legal ground: article 17 of
GDPR.
a) The Customer has the right to demand erasure of all or some personal
data;
b) The Customer has the right to demand the erasure of some personal
data, if:
a. the personal data are no longer necessary in relation to the
purposes for which they were collected or processed;
b. the Customer has withdrawn consent in the scope in which
personal data have been processed on the basis of their consent;
c. the Customer has objected to use of their data for marketing
purposes;
d. the personal data are unlawfully processed;
e. the personal data have to be erased for compliance with a legal
obligation in Union or Member State law to which Fokuspokus Studio
Fokuspokus is subject;
f. the personal data have been collected in relation to the offer of
information society services.

c) Despite of demand of erasure of personal data in relation to an
objection or withdrawal of consent, Fokuspokus Studio Agnieszka
Tymińska may retain some full personal data in the scope, in which
processing is necessary for determination, claiming or defence against

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claims, and for fulfilment of the legal obligation requiring data
processing under the legislation of the European Union or a Member
State to which Fokuspokus Studio Fokuspokus is subject. It refers
in particular to: name, surname, e-mail address, which are retained for
the purpose of examination of complaints and claims related to use of
Fokuspokus Studio Fokuspokus services, or additionally an
address of residence/ correspondences, order number, which are
retained for the purpose of examination of complaints and claims
related to concluded sales agreements or service agreements.
4. Right to restriction of processing- legal ground: article 18 of GDPR.
a) The Customer shall have the right to obtain from the controller
restriction of their personal data processing. Submission of such
demand, until its examination, prevents the use of specified
functionalities or services, the use of which would be related with
processing of personal data subject to such demand. Moreover,
Fokuspokus Studio Fokuspokus will not send any message,
including marketing communications.
b) The Customer shall have the right to demand restriction of their
personal data processing in the following cases:
a. When they contest the acccuracy of their personal data; then
Fokuspokus Studio Fokuspokus shall restrict their use for
a period enabling verification of the accuracy of the personal data,
but no longer than for 7 days;
b. When data processing is unlawful and the Customer demands
restriction of their use instead of their erasure;
c. When personal data are no longer necessary for the purposes of
their collection or use, but they are needed by the Customer in
order to determine, exercise or defend claims;
d. When the Customer objected to proceeding of their data- then the
restriction is introduced for a period necessary to consider
whether, due to exceptional circumstances – protection of the
Customer’s interests, rights and freedoms prevails over the
interests, which are exercise by the Controller when proceeding
Customer’s personal data.

5. Right of access to data - legal ground: article 15 of GDPR.
a) The Customer shall have the right to obtain a confirmation from the
Controller, whether or not it processes personal data, and if yes, the
Customer shall have the right to:
a. obtain access to their personal data;
b. obtain information on the purposes of the processing, the
categories of processes personal data, the recipients or categories
of recipients of such data, the envisaged period for which the

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personal data will be stored or the criteria used to determine that
period (if determination of the planned period of data processing
is not possible), on Customer’s rights under the GDPR and the
right to lodge a complaint with a supervisory authority, on the
source of such data, automated decision-making, including
profiling and security devices applied due to the transfer of such
data outside the European Union;
c. obtain copies of their personal data.

6. Right to rectification - legal ground: article 16 of GDPR
a) The Customer shall have the right to obtain from the Controller
without undue delay the rectification of inaccurate personal data
concerning the Customer. Taking into account the purposes of the
processing, the Customer shall have the right to have incomplete
personal data completed, including by means of providing

a supplementary statement, sending the respective request to the e-
mail address in compliance with of the Privacy Policy.

7. Right to data portability- legal ground: article 20 of GDPR.
a) The Customer shall have the right to obtain their personal data, which
were provided to the Controller, and then to send them to another
data controller selected by the Customer. The Customer shall have the
right to demand that such personal data are sent directly by us to
another data controller, if this is technically feasible. In such case the
Controller shall sent the Customer’s personal data in a csv file, which
is a commonly used machine-readable format, allowing transfer of
processed data to another data controller.

8. If the Customer wishes to exercise any of the foregoing rights, Fokuspokus
Studio Fokuspokus fulfils a request or refuses to fulfil it promptly,
but no later than within a month of its receipt. If, however, due to
a complex nature of a demand or a number of demands Fokuspokus Studio
Fokuspokus is not able to fulfil demand within one month, it shall
fulfil it during the following two month, notifying the Customer earlier
within a month from receipt of the demand on the intended prolongation
of the period and about own activities.
9. The Customer may file complaints, questions or requests concerning
processing of their personal data and execution of this rights.
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The Customer has the right to demand that Fokuspokus Studio Agnieszka
Tymińska provides copies of standard contractual clauses, sending
a request in the was define in of the Privacy Policy.
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The Customer shall have the right to file a complaint to the Chairperson of
the Office of Personal Data Protection in respect to violation of their rights
for personal data processing or other rights granted under the GDPR.
Article 6 - Security management – the password

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1. Fokuspokus Studio Fokuspokus ensures safe and encrypted
connection to the Customers during transfer of personal data and logging
to the Customer Account on the Portal. Fokuspokus Studio Agnieszka
Tymińska uses SSL certificate issued by one of the world leaders in respect
to security and encryption of data sent via the Internet.
2. In any case of loss of the password to the Customer’s account in the
Website, generating a new password shall be available. The Fokuspokus
Studio Fokuspokus shall not send any password reminder. The
Customer’s encrypted password is stored in database in non-readable
form. In order to generate a new password, e-mail address shall be
entered to the form available at „Forget your password?”, given in log-in

form in the Website. Fokuspokus Studio Fokuspokus will be sent an e-
mail with a unique redirecting to the Website, after selecting the user will

be able to choose a new password.
3. Fokuspokus Studio Fokuspokus shall never ask the Customer to
provide him with access to the login or password in any form.

Article 7 - Amendments to the Privacy Policy
1. Privacy Policy may change as Fokuspokus Studio Fokuspokus inform
users in advance of 7 days.
2. Please send all additional questions related to the Privacy Policy to:
info@Fokuspokus.pl.
3. Date of the last amendment: 16.04.2021.