Privacy policy
Privacy policy of 12.06.2026.
Dear User!
We care about your privacy and want you to feel comfortable while using our services. Therefore, below we present the most important information on the policy for the processing of your personal data and on cookies which are used by our Shop. This Privacy Policy has been prepared in accordance with the UK General Data Protection Regulation (UK GDPR), and, where applicable, the EU GDPR. Nothing in this document limits your rights under applicable local data protection law. For the sake of clarity and due to the fact that the relevant provisions of both the UK GDPR and the EU GDPR have essentially identical wording, this document will hereinafter refer to both collectively as the “GDPR”. Any differences in interpretation or applicability between the two frameworks will be explicitly noted where relevant.
PERSONAL DATA CONTROLLER
HUGUP SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with its registered seat at ul. Smoluchowskiego 3c/3, 60-179, Poland, entered in the National Court Register - Register of Entrepreneurs by SĄD REJONOWY POZNAŃ - NOWE MIASTO I WILDA W POZNANIU, VIII WYDZIAŁ GOSPODARCZY KRAJOWEGO REJESTRU SĄDOWEGO, under KRS (National Court Register) number 0000880047, NIP (Tax Identification Number) 7812017081, REGON (National Official Business Register number) 388015044, initial capital PLN 5700,00.
If you wish to contact us in relation to our processing of your personal data, please email us at: support@hugup.com.
YOUR RIGHTS
You have the right to request:
- access to your personal data, including obtaining a copy of your data (Article 15 of the GDPR or, if applicable, Article 13 sec. 1(f) of the GDPR),
- their rectification (Article 16 of the GDPR),
- erasure (Article 17 of the GDPR),
- restriction of their processing (Article 18 of the GDPR),
- the transfer of data to another controller (Article 20 of the GDPR),
and the right to:
- object to the processing of your personal data at any time:
on grounds relating to your particular situation - with regard to the processing of your personal data based on Article 6 sec. 1(f) of the GDPR (i.e. the legitimate interests pursued by us), including profiling; if your personal data is processed for the purposes of direct marketing, including profiling, to the extent that such processing is related to such direct marketing (Art. 21 sec. 2 of the GDPR).
Contact us if you wish to exercise your rights. You can object to our use of cookies (which you will read about below) in particular by using the appropriate settings on your browser.
If you consider that your data is being processed unlawfully, you can lodge a complaint with the competent data protection authority:
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In the UK: Information Commissioner’s Office (ICO), www.ico.org.uk;
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In the EU: with the competent supervisory authority in the Member State of your habitual residence, place of work or place of the alleged infringement. A list of authorities is available at: https://edpb.europa.eu/about-edpb/about-edpb/members_en.
PERSONAL DATA AND PRIVACY
Your data is processed by us for purposes related to the operation of the Shop and the provision of the services offered therein. Below you will find detailed information on the processing of your data depending on your activities.
1. Placing an order in the Shop
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For what purpose do we process your data? |
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to process your order |
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On what basis do we process your data? |
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a sales contract (Article 6 sec. 1(b) of the GDPR) |
a legal obligation, particularly related to accounting, safety and regulatory compliance of products, requiring us to process your personal data (Article 6(1)(c) of the GDPR) |
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For how long will we process your data? |
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for the duration of the aforementioned contract |
until the expiry of our legal obligations |
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in addition, your data will be processed until the expiry of the period during which claims may be asserted - either by you or by us (see the last table of this part for more information) |
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What happens if you do not provide the data? |
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you will not be able to place an order |
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2. Creating an account in the Shop
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For what purpose do we process your data? |
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to execute a contract for the provision of an account in the Shop |
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On what basis do we process your data? |
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a contract for provision of services (Article 6 sec. 1(b) of the GDPR) |
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For how long will we process your data? |
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for the duration of the aforementioned contract |
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in addition, your data will be processed until the expiry of the period during which claims may be asserted - either by you or by us (see the last table of this part for more information) |
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What happens if you do not provide the data? |
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you will not be able to create an account and use its features, such as viewing your order history or checking your order status |
3. Contacting us (e.g. to ask a question)
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For what purpose do we process your data? |
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to respond to your inquiries or requests |
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On what basis do we process your data? |
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a contract or actions taken at your request prior to entering into a contract (Article 6 sec. 1(b) of the GDPR) - if your enquiry or request relates to a contract to which we are or may be a party |
our legitimate interest in processing your data for the purpose of communicating with you (Article 6 sec. 1(f) of the GDPR) - if your enquiry or request is not related to a contract |
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For how long will we process your data? |
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for the duration of the contract binding us or, if no contract is concluded - until the expiry of the claim period - see the last table of this part |
until the expiry of the claim period - see the last table in this part or until we have taken account of your objection to the processing* |
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in addition, your data will be processed until the expiry of the period during which claims may be asserted - either by you or by us (see the last table of this part for more information) |
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What happens if you do not provide the data? |
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we will not be able to respond to your enquiry or request |
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*whichever is applicable in a particular case
4. Browser settings or other similar action allowing marketing activities
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For what purpose do we process your data? |
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for the purposes of direct marketing through the display of personalised advertising (read more in the "Profiling" and "Cookies" parts of the Privacy Policy) |
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On what basis do we process your data? |
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our legitimate interest in processing the data for the purpose stated above (Article 6 sec. 1(f) of the GDPR) |
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For how long will we process your data? |
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until the cookies used for marketing purposes expire or are deleted by you* |
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What happens if you do not provide the data? |
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you will not receive suggestions for products or services in which you may be interested |
*whichever is applicable in a particular case
5. Browser settings or other similar action allowing analytical activities
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For what purpose do we process your data? |
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to analyse how you use and navigate through the Shop in order to improve its functionality (read more in the "Analytics" and "Cookies" parts of our Privacy Policy) |
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On what basis do we process your data? |
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our legitimate interest in processing the data for the purpose stated above (Article 6 sec. 1(f) of the GDPR) |
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For how long will we process your data? |
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until the cookies used for analytical purposes expire or are deleted by you* |
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What happens if you do not provide the data? |
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we will not take into account the way you use and navigate through the Shop when working on its development |
*whichever is applicable in a particular case
6. Your consent to receive marketing content from us (e.g. information on special offers)
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For what purpose do we process your data? |
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to send marketing information, especially special offers |
to analyse the effectiveness of the messages we send, in order to establish general principles for effective messaging in our business activity (read more in the "Analytical activities" part of the Privacy Policy) |
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On what basis do we process your data? |
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your consent to our marketing activities (Article 6 sec. 1(a) of the GDPR) |
our legitimate interest in processing the data for the purpose stated above (Article 6 sec. 1(f) of the GDPR) |
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For how long will we process your data? |
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until you withdraw your consent - remember, you can withdraw your consent at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. |
until we have taken account of your objection to the processing |
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in addition, your data will be processed until the expiry of the period during which claims may be asserted - either by you or by us (see the last table of this part for more information) |
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What happens if you do not provide the data? |
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you will not receive our marketing materials, including information about our special offers |
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7. Signing up for the newsletter
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For what purpose do we process your data? |
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to send you our newsletter |
to analyse the effectiveness of the messages we send, in order to establish general principles for effective messaging in our business activity (read more in the "Analytical activities" part of the Privacy Policy) |
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On what basis do we process your data? |
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a contract for services of sending a newsletter (Article 6 sec. 1(b) of the GDPR) |
our legitimate interest in processing the data for the purpose stated above (Article 6 sec. 1(f) of the GDPR) |
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For how long will we process your data? |
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until you unsubscribe from our newsletter |
until we have taken account of your objection to the processing |
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in addition, your data will be processed until the expiry of the period during which claims may be asserted - either by you or by us (see the last table of this part for more information) |
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What happens if you do not provide the data? |
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you will not be able to receive information regarding the Shop and our services |
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8. Using services (other than those mentioned above), such as browsing our website or using other features available on it – if they require data processing
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For what purpose do we process your data? |
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execution of the contract concluded between us |
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On what basis do we process your data? |
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a contract for provision of services (Article 6 sec. 1(b) of the GDPR) |
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For how long will we process your data? |
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for the contract period |
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in addition, your data will be processed until the expiry of the period during which claims may be asserted - either by you or by us (see the last table of this part for more information) |
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What happens if you do not provide the data? |
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you will not be able to use those functions for which the processing of data is necessary |
9. Any act or omission which may give rise to a claim relating to the Shop or our services
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For what purpose do we process your data? |
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to establish, assert or defend possible claims relating to the contract concluded or the services provided |
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On what basis do we process your data? |
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our legitimate interest to process your personal data for the purpose stated above (Article 6 sec. 1(f) of the GDPR) |
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For how long will we process your data? |
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until the expiry of the claim period or until we take account of your objection to the data processing* |
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What happens if you do not provide the data? |
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inability to establish, assert or defend claims |
*whichever is applicable in a particular case
RECEIVING DATA FROM THIRD PARTIES
In some cases, we may receive your personal data from third-party sources, such as payment platforms, social media platforms or partner services you use to access our Shop. This includes cases where you log in through social media accounts or interact with embedded content (e.g. comments, shares, likes). The data received from such third parties will only be processed where lawful and under the same conditions as if it had been provided directly by you.
PROFILING
In the Shop, we carry out profiling - we will profile you if you allow such activities. This profiling involves automatically assessing what products or services you may be interested in, using information about the content you view. In this way, advertisements for products or services displayed as part of the online services used by you will be more tailored to you and your needs.
The profiling we perform does not result in decisions that produce legal effects for you or affect you in a similarly significant way.
You have the right to object to profiling at any time and to request human intervention, express your point of view, or contest a decision based solely on automated processing, including profiling, where such decision produces legal effects or similarly significantly affects you (Article 22 of the GDPR).
ANALYTICAL ACTIVITIES
As part of the the Shop's website, we perform analytical activities to make it more intuitive and accessible - we will do so if you allow such activities. As part of the analysis, we will take into account the way in which you navigate the Shop, for example, how much time you spend on a particular subpage, or where in the Shop you click. This allows us to optimize the layout, appearance and content of the Shop as we work on its development, in order to improve its functionality.
In addition, if you wish to receive marketing messages or newsletter from us, we may analyze the effectiveness of the mailing we have conducted. For example, we can check whether and how it affected activity in our Shop. Such activities will help us establish general rules for sending such messages - for example, in terms of optimal sending hours or determining how to formulate effective content.
DATA SECURITY
When processing your personal data, we use organisational and technical means in accordance with applicable law, including the encryption of the connection using the SSL/TLS protocol.
COOKIES
Our Shop, like most websites, uses the so-called cookies. These cookies:
- are saved in the memory of your device (computer, telephone, etc.);
- do not change the settings of your device.
In our Shop, cookies are used for:
- saving your session,
- statistical purposes,
- marketing purposes,
- making the Shop functions available.
To learn how to manage cookies, including how to turn them off in your browser, you can use the help file of your browser. You can find out more about this by pressing F1 in your browser. In addition, appropriate tips can be found on the following pages, depending on the browser you are using:
- Google Chrome
- Opera
- Safari
- Mozilla Firefox
- Microsoft Edge
Cookies will not be processed by us for more than 2 years.
Using appropriate options of your browser, you can at any time:
- delete cookies,
- block the use of cookies in the future.
In such cases, we will no longer process them.
EXTERNAL SERVICES / DATA RECIPIENTS
We use external services to help us in our business. We entrust them with the processing of your data - these processors only process data upon our documented request.
Below you will find a list of the recipients of your data:
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ACTION |
DATA RECIPIENTS |
TRANSFERS OF PERSONAL DATA TO COUNTRIES OUTSIDE THE EUROPEAN UNION |
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any action connected with the Shop |
entity providing us with technical/IT support |
does not take place |
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persons cooperating with us on the basis of civil law contracts, supporting our current activities |
does not take place |
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sales software provider |
yes – the USA, Singapore, the United Kingdom, Switzerland, Canada, Argentina, Israel, New Zealand ** |
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visiting the Shop with settings that allow marketing activities to be carried out |
provider of marketing services |
yes – the USA, China ** |
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visiting the Shop with settings that allow analytical activities to be carried out |
entity enabling analytical activities in the Shop |
yes – the USA ** |
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placing an order in the Shop* |
payment processor |
yes – the USA, the United Kingdom ** |
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provider of the standard office software (including email boxes) |
yes – the USA, Singapore, the United Kingdom, Switzerland, Canada, Argentina, Israel, New Zealand ** |
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instalment service provider |
yes – the United Kingdom ** |
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SALESUPPLY POLAND SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ |
does not take place |
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subscribing to the newsletter or consent to marketing |
entity providing newsletter or marketing messaging services |
yes – the USA ** |
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use of the online chat available in the Shop |
provider of the online chat available in the Shop |
yes – the USA ** |
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SALESUPPLY POLAND SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ |
does not take place |
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your use of services provided to us in connection with the Shop via social media platforms |
social media platforms |
yes – the USA, China ** |
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contacting us (e.g. to ask a question) |
provider of the standard office software (including email boxes) |
yes – the USA, Singapore, the United Kingdom, Switzerland, Canada, Argentina, Israel, New Zealand ** |
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SALESUPPLY POLAND SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ |
does not take place |
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analysis of Users’ behavior on the Store’s website and improvement of the User experience |
Microsoft – the entity providing the Microsoft Clarity tool |
yes – the USA ** |
Additionally:
relevant public authorities to the extent that we are required to provide them with the data.
Our website is hosted by Shopify International Ltd., a company based in Ireland, with offices at 2nd Floor, 1-2 Victoria Buildings, Haddington Road, Dublin 4, D04 XN32. We have entered into a data processing agreement with this provider to ensure that your data is processed securely and in compliance with the GDPR.
TRANSFER OF DATA OUTSIDE THE EUROPEAN UNION
** As such, your personal data may also be processed by entities outside the European Union. An adequate level of protection of your data, including through the application of appropriate safeguards, is ensured by:
the participation of these entities in the Data Privacy Framework, a program established by the implementing decision of the European Commission as a set of principles that guarantee adequate privacy protection - in the case of entities from the United States
the standard data protection clauses adopted by the European Commission as referred to in Article 46 sec. 2(c) of the GDPR - in the case of China and Singapore
Commission Implementing Decision of 28.6.2021 pursuant to Regulation (EU) 2016/679 of the European Parliament and of the Council on the adequate protection of personal data by the United Kingdom Commission Decision No 2000/518/EC on the adequate protection of personal data in Switzerland Commission Decision No 2002/2/EC on the adequate protection of personal data provided by the Canadian Personal Information Protection and Electronic Documents Act
Commission Decision No 2003/490/EC on the adequate protection of personal data in Argentina Commission Decision No 2011/61/EU on the adequate protection of personal data by the State of Israel with regard to automated processing of personal data
Commission Implementing Decision No 2013/65/EU on the adequate protection of personal data in New Zealand.