Cookies & Privacy

Last updated: 03/09/2021

This Privacy Policy sets out how ZOJO. The Gorgeousness Company Sp. z o.o. collects, uses and protects any personal information, our privacy practices and your privacy rights. Providing your personal data is necessary for the proper provision of Electronic Services within the Online Store and for the conducting of the Products Sale Agreement.

Personal Data Collected

Personal data means any information relating to identified or identifiable natural person. This may include, but not be limited to, name, surname, address, date of birth, telephone number, email address, bank account number, tax identification number, encrypted password to the customer account, data on your orders placed or services purchased, payment information, your product preferences, data we collect during your visit on our websites or social media accounts, including the data on your behaviour in relation to cruising our websites or being the addressee of our newsletter, login information, IP address, or any other information provided voluntarily either via our website, personally at our stores, by sending us an email, via social media, during the account registration or while submitting an order or by signing up to our newsletter or loyalty programme. If you submit your personal data to us by doing so you accept the use of such data in accordance with this Privacy Policy.

Administrator of Personal Data

Websites www.zojoelixirs.com and www.moonholi.com, as well as social media accounts of our brands : ZOJO Beauty Elixirs (@zojoelixirs, @zojoelixirs_pl, @zojoelixirs_influencers) and Moonholi (@moonholi i @moonholi_contact)  and any personal data provided to us is administered by ZOJO. The Gorgeousness Company Sp. z o.o. with its registered seat at Złota 59, 00-120 Warsaw, Poland, registered with the District Court in Warsaw, XII Commercial Department of the National Court Register, under the KRS number 0000633933 (“ZOJO”).

For further information or if you wish to access, modify or erase your personal data please contact ZOJO at the below:

ZOJO. The Gorgeousness Company Sp. z o.o.
Złota 59

00-120 Warsaw, Poland

T: +48 790 522 970

E: store@zojoelixirs.com

Purpose of processing

We process your data only with your consent (Article 6 (1) (a) of the GDPR), if we have a legitimate interest in their processing (Article 6 (1) (f) of the GDPR), if we need this data to implement contracts with you in accordance with Art. 6 sec. 1 lit. b) GDPR, or if it is necessary to fulfill a legal obligation (Article 6 (1) (c) of the GDPR).

We process your personal data in the following cases:

  1. if you contact us using the contact form on the website (clause A)
  2. when you place an order, when you create a user account or when you sign up to our Beauty Club loyalty program (clause B)
  3. when you contact us in any other way (e.g. by e-mail, telephone) (clause C)
  4. if you are a job candidate and you participate in the recruitment process (clause D)
  5. data collected via social media (followers, customers, influencers, participants of competitions and promotional campaigns) (clause E)
  6. when subscribing to the newsletter (clause F)
  7. if you are our contractor or a contact person in the contractor’s company (clause G)

CLAUSE A

Processing of personal data as part of the contact form

The administrator of your personal data is ZOJO. The Gorgeousness Company Sp. z o.o. with headquarters in Warsaw (00-120) at ul. Zlota 59.

Contact with ZOJO. The Gorgeousness Company Sp. z o.o. is possible via the e-mail address store@zojoelixirs.com or in writing to the above address.

  1. Your data will be processed:
  • in order to reply to a message sent via the contact form – the basis for processing is the necessity to perform the contract to which the data subject is a party, or to take action at the request of the data subject, before concluding the contract (Article 6 section 1 letter b of the GDPR);
  • in order to consider a complaint submitted by the customer – the basis for processing is the implementation of the legitimate interest of ZOJO. The Gorgeousness Company Sp. z o.o. (Article 6 (1) (f) of the GDPR);
  • in order to establish or pursue possible claims or defend against claims – the basis for processing is the implementation of the legitimate interests of ZOJO. The Gorgeousness Company Sp. z o.o. (Article 6 (1) (f) of the GDPR);
  • in order to conduct marketing activities – the basis for processing is the implementation of the legitimate interest of ZOJO. The Gorgeousness Company Sp. z o.o. (Article 6 (1) (f) of the GDPR).
  1. Personal data will be kept for the time necessary to answer (consider the complaint) and the time necessary to pursue any claims. For marketing purposes, personal data will be processed until the consent is withdrawn.
  2. You have the right to: access the data and request rectification, deletion, processing restrictions, the right to transfer data, the right to object to data processing and the right to lodge a complaint with the President of the Personal Data Protection Office on the terms set out in the GDPR.
  3. If the basis for the processing of your personal data is the consent in accordance with art. 6 sec. 1 lit. a GDPR, you have the right to withdraw your consent to the processing of personal data at any time. Withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal.
  4. You have the right to object to the processing of personal data on the basis of the legitimate interest of the administrator for reasons related to your particular situation.
  5. Data processing is necessary to respond to a query (including considering the complaint). The processing of personal data for marketing purposes is optional.

CLAUSE B

Processing of personal data collected during the placement of the customer order or during additional account registration or signing up to the Beauty Club loyalty program

The administrator of your personal data is ZOJO. The Gorgeousness Company Sp. z o.o. with headquarters in Warsaw (00-120), at ul. Zlota 59.

Contact with ZOJO. The Gorgeousness Company Sp. z o.o. is possible via the e-mail address store@zojoelixirs.com or in writing to the above-mentioned address.

Your data will be processed for the purpose of:

  • enabling the provision of electronic services ·
  • in order to conclude and perform a contract between your company and ZOJO. The Gorgeousness Company Sp. z o.o. – the basis for processing is the necessity to perform the contract to which you are a party, or to take action at your request (Article 6 (1) (b) of the GDPR);
  • in the case of creating an account by the user in order to conclude and perform the contract between your company and ZOJO. The Gorgeousness Company Sp. z o.o. – the basis for processing is the necessity to perform the contract to which you are a party or to take action at your request (Article 6 (1) (b) of the GDPR) and consent (Article 6 (1) (a)) GDPR);
  • in the case of creating an account in the Beauty Club loyalty program by the user in order to conclude and perform the contract between your company and ZOJO. The Gorgeousness Company Sp. z o.o. – the basis for processing is the necessity to perform the contract to which you are a party or to take action at your request (Article 6 (1) (b) of the GDPR) and consent (Article 6 (1) (a)) GDPR);
  • for the purpose of fulfilling the legal obligations incumbent on ZOJO. The Gorgeousness Company Sp. z o.o. on the basis of generally applicable law, including tax and accounting regulations – the basis for processing is the necessity to fulfill the legal obligation incumbent on the administrator (Article 6 (1) (c) of the GDPR);
  • in order to establish or pursue possible claims or defend against claims – the basis for processing is the implementation of the legitimate interests of ZOJO. The Gorgeousness Company Sp. z o.o. (Article 6 (1) (f) of the GDPR).
  • solving problems related to the service provided (Article 6 (1) (f) of the GDPR);
  • handling complaints in the event that you make such a complaint (Article 6 (1) (f) of the GDPR);
  • In the event of a complaint, the data will be processed for the purpose of accepting and handling complaints and pursuing claims (legal basis: legitimate interest of the administrator – Article 6 (1) (f) of the GDPR). Where applicable, the recipients of the data may be the producers of the advertised goods, couriers and mail, and payment processing companies. The data will be stored for the period required by applicable law and until any claims are time-barred. Each person has the right to request access to their data, rectification, deletion, transfer, limitation of processing, objecting to processing and the right to lodge a complaint to the President of the Office for Personal Data Protection. The right to object to the processing of data is granted in the case of data processing based on the legitimate interest of the data controller.
  • handling requests that you send to us (e.g. via the contact form (Article 6 (1) (b) of the GDPR);
  • contacting you, including for purposes related to the provision of services (Article 6 (1) (b) of the GDPR);
  • conducting marketing activities towards you, including direct marketing of your own services (Article 6 (1) (f) of the GDPR);
  • performance of the contract (Article 6 (1) (b) of the GDPR);
  • providing support for payment and delivery services (Article 6 (1) (b) of the GDPR);
  • handling your requests, in particular sent to the customer service department and via the contact form, in a situation where they are not directly related to the performance of the contract (Article 6 (1) (b) of the GDPR);
  • organization of loyalty programs, competitions and promotional campaigns in which you can take part (art. 6 ust. 1 lit. f RODO);
  • pursuing claims and defending against claims (Article 6 (1) (f) of the GDPR);
  • conducting statistical analyzes (Article 6 (1) (f) of the GDPR);
  • storing data for archiving purposes and ensuring accountability (demonstrating compliance with our obligations under the law) (Article 6 (1) (f) of the GDPR);
  • statistical data profiling for marketing purposes for management statistics and, inter alia, sending personalized offers and better matching of the offer – legal basis (Article 6 (1) (f) of the GDPR).

Data recipients:

Your personal data will be transferred to entities providing services to ZOJO. The Gorgeousness Company Sp. z o.o. i.e. law firms, banks, consulting companies, IT service providers and IT system suppliers, courier companies, payment service companies, and other authorized entities – the recipient of your personal data will be entities authorized to obtain personal data on the basis of legal provisions.

Retention period:

Your personal data is stored:

  • in the case of data processing necessary for us to fulfill a legal obligation – for the period of limitation of tax obligations resulting from the relevant provisions of tax law;
  • in the case of data processing in order to implement our legitimate interest, for the period until you submit an objection, subject to the need to process data until the end of the period necessary to establish, assert or defend claims;
  • in the case of data processing for direct marketing purposes – for the period until you submit an objection, subject to the necessity of data processing until the end of the period necessary to establish, assert or defend claims.

Letter of Rights:

You have the right to access your data and the right to rectify, delete, limit processing, the right to transfer data, the right to object to data processing, the right to withdraw any consent at any time; in the case of data processing for direct marketing purposes, including profiling, you have the right to object at any time. If you exercise this right, we will stop processing your data for this purpose.

Right to lodge a complaint:

You have the right to lodge a complaint with the President of the Personal Data Protection Office, if you feel that the processing of your personal data violates the provisions on the protection of personal data.

Right to object:

At any time, you have the right to object to the processing of your data on the basis of a legitimate interest, as described above, for reasons related to your particular situation.

Withdrawal of consent to the processing of your personal data:

You have the right to withdraw your consents granted for the processing of personal data at any time, without affecting the lawfulness of the processing, which was carried out on the basis of consent before its withdrawal. The consent may be withdrawn by sending an e-mail, and if it is difficult for you, also in the form of a regular letter to the following addresses: in the case of e-mail: store@zojoelixirs.com, in the case of a regular letter: ZOJO. The Gorgeousness Company Sp. z o.o. with headquarters in Warsaw, at ul. Złota 59, 00-120 Warsaw. Data processing is voluntary, however, it is necessary to provide an answer.

CLAUSE C

When you contact us or provide your data in any other way (e.g. by e-mail, telephone)

The administrator of your personal data is ZOJO. The Gorgeousness Company Sp. z o.o. with headquarters in Warsaw (00-120), at ul. Zlota 59.

Contact with ZOJO. The Gorgeousness Company Sp. z o.o. is possible via the e-mail address store@zojoelixirs.com or in writing to the above-mentioned address.

Your data will be processed for the purpose of:

  • enabling the provision of electronic services ·
  • solving problems related to the service provided (Article 6 (1) (f) of the GDPR);
  • handling complaints in the event that you make such a complaint (Article 6 (1) (f) of the GDPR);
  • In the event of a complaint, the data will be processed for the purpose of accepting and handling complaints and pursuing claims (legal basis: legitimate interest of the administrator – Article 6 (1) (f) of the GDPR). Where applicable, the recipients of the data may be the producers of the advertised goods, couriers and mail, and payment processing companies. The data will be stored for the period required by applicable law and until any claims are time-barred. Each person has the right to request access to their data, rectification, deletion, transfer, limitation of processing, objecting to processing and the right to lodge a complaint to the President of the Office for Personal Data Protection. The right to object to the processing of data is granted in the case of data processing based on the legitimate interest of the data controller.
  • handling requests that you send to us (e.g. via the contact form (Article 6 (1) (b) of the GDPR);
  • contacting you, including for purposes related to the provision of services (Article 6 (1) (b) of the GDPR);
  • conducting marketing activities towards you, including direct marketing of your own services (Article 6 (1) (f) of the GDPR);
  • performance of the contract (Article 6 (1) (b) of the GDPR);
  • providing support for payment and delivery services (Article 6 (1) (b) of the GDPR);
  • handling your requests, in particular sent to the customer service department and via the contact form, in a situation where they are not directly related to the performance of the contract (Article 6 (1) (b) of the GDPR);
  • organization of loyalty programs, competitions and promotional campaigns in which you can take part (Article 6 (1) (f) of the GDPR);
  • pursuing claims and defending against claims (Article 6 (1) (f) of the GDPR);
  • conducting statistical analyzes (Article 6 (1) (f) of the GDPR);
  • storing data for archiving purposes and ensuring accountability (demonstrating compliance with our obligations under the law) (Article 6 (1) (f) of the GDPR);
  • recruitment (Article 6 (1) (b) of the GDPR)
  • future recruitments (provided you have consented to it) (Article 6 (1) (a) of the GDPR).

 Data recipients:

Your personal data will be transferred to entities providing services to ZOJO. The Gorgeousness Company Sp. z o.o. i.e. law firms, banks, consulting companies, IT service providers and IT system suppliers, shipping companies, payment providers and other authorized entities – the recipient of your personal data will be entities authorized to obtain personal data on the basis of legal provisions.

Retention period:

Your personal data is stored:

  • in the case of data processing necessary for us to fulfill a legal obligation – for the period of limitation of tax obligations resulting from the relevant provisions of tax law;
  • in the case of data processing in order to implement our legitimate interest, for the period until you submit an objection, subject to the need to process data until the end of the period necessary to establish, assert or defend claims;
  • in the case of data processing for direct marketing purposes – for the period until you submit an objection, subject to the necessity of data processing until the end of the period necessary to establish, assert or defend claims.

Letter of Rights:

You have the right to access your data and the right to rectify, delete, limit processing, the right to transfer data, the right to object to data processing, the right to withdraw any consent at any time; in the case of data processing for direct marketing purposes, including profiling, you have the right to object at any time. If you exercise this right, we will stop processing your data for this purpose.

Right to lodge a complaint:

You have the right to lodge a complaint with the President of the Personal Data Protection Office, if you feel that the processing of your personal data violates the provisions on the protection of personal data.

Right to object:

At any time, you have the right to object to the processing of your data on the basis of a legitimate interest, as described above, for reasons related to your particular situation.

Withdrawal of consent to the processing of your personal data:

You have the right to withdraw your consents granted for the processing of personal data at any time, without affecting the lawfulness of the processing, which was carried out on the basis of consent before its withdrawal. The consent may be withdrawn by sending an e-mail, and if it would be difficult for you, also in the form of a regular letter to the following addresses: in the case of e-mail: store@zojoelixirs.com. In the case of a regular letter: ZOJO. The Gorgeousness Company Sp. z o.o. with headquarters in Warsaw, at ul. Złota 59, 00-120 Warsaw. Data processing is voluntary, however, it is necessary to provide an answer.

CLAUSE D

Processing of personal data if you are a job candidate and you take part in the recruitment process

1) The administrator of your personal data is ZOJO. The Gorgeousness Company Sp. z o.o. with headquarters in Warsaw (00-120) at ul. Zlota 59

2) Contact with ZOJO. The Gorgeousness Company Sp. z o.o. is possible via the e-mail address: rekrutacja@zojoelixirs.com or in writing to the above-mentioned address

3) Your personal data contained in the application documents will be processed:

  1. a) in the case of recruitment, under which employment is to take place on the basis of an employment contract – your personal data will be processed in order to perform the obligations arising from legal provisions, including in particular the Labor Code – the legal basis for processing is the legal obligation on ZOJO. The Gorgeousness Company Sp. z o.o. as a potential employer (Article 6 (1) (c) of the GDPR);
  2. b) in the case of recruitment, under which it is sufficient for employment on the basis of a civil law contract – your personal data will be processed in order to carry out the recruitment process – the legal basis for processing is taking action before a possible conclusion of a civil law contract (Article 6 (1) letter b GDPR);
  3. c) for the purposes of conducting future recruitment processes – the legal basis for the processing of your personal data is consent (Article 6 (1) (a) of the GDPR);
  4. d) in order to establish or pursue possible claims or defend against such claims by ZOJO. The Gorgeousness Company Sp. z o.o. – the legal basis for data processing is the legitimate interest of ZOJO. The Gorgeousness Company Sp. z o.o. (Article 6 (1) (f) of the GDPR).

4) Your personal data may be transferred to entities providing services to ZOJO. The Gorgeousness Company Sp. z o.o. in connection with conducting recruitment processes, such as recruitment agencies, as well as suppliers of IT systems and IT services or accounting companies for the needs of payroll and human resources.

5) Personal data will be processed until the recruitment process is completed, and in the case of separate consent to the processing of data for the purposes of future recruitment – no longer than 6 months from the moment of consent or until its withdrawal.

6) You have the right to: access the content of the data and request their rectification, deletion, processing restrictions, the right to transfer personal data, the right to object to data processing and the right to lodge a complaint with the President of the Personal Data Protection Office on the terms set out in the GDPR.

7) The consent may be withdrawn at any time. Withdrawal of consent does not affect the lawfulness of the processing carried out before its withdrawal.

8) You have the right to object to the processing of personal data on the basis of the legitimate interest of the administrator for reasons related to your particular situation.

9) Providing data is a condition for participation in the recruitment process, and failure to do so will make it impossible to apply for the indicated position.

CLAUSE E

Data collected via social media (followers, customers, influencers, participants of competitions and promotional campaigns)

ZOJO The Gorgeousness Company Sp. z o.o. with headquarters in Warsaw (00-120), at ul. Zlota 59 is the administrator of the data of persons visiting the administrator’s profiles on social media (Facebook, Instagram, YouTube, TikTok, Pinterest).

  1. These data are processed only in connection with keeping the administrator’s profile in social media, including for the purpose of informing and promoting the administrator’s activity, communicating with people visiting the administrator’s profiles and for analytical purposes. The legal basis for the processing of personal data by the administrator for this purpose is its legitimate interest (Article 6 (1) (f) of the GDPR), consisting in promoting its activity.
  2. If you participate in competitions organized on our social networks, the legal basis for the processing of your personal data is consent (Article 6 (1) (a) of the GDPR). In this case, we only process the data necessary for their implementation.
  3. Providing personal data is voluntary. The data will be processed for the duration of the Administrator’s profile or until an objection to data processing or a request to delete data is submitted.
  4. Personal data may be transferred to external entities supporting our organization in the provision of services, i.e. those that provide IT technical, marketing or analytical support services.
  5. Each person has the right to access, rectify, delete, limit processing, transfer their personal data, object to the processing of their personal data, submit a complaint to the President of the Personal Data Protection Office.
  6. In matters relating to the processing of personal data, you can contact us by correspondence or by e-mail to the address store@zojoelixirs.com.

CLAUSE F

When subscribing to the newsletter

The legal basis for sending our newsletter is your consent (Article 6 (1) (a) of the GDPR).

The administrator of your personal data is ZOJO. The Gorgeousness Company Sp. z o.o. with headquarters in Warsaw (00-120), at ul. Zlota 59.

Contact with ZOJO. The Gorgeousness Company Sp. z o.o. is possible via the e-mail address store@zojoelixirs.com or in writing to the above-mentioned address.

Your data will be processed in order to conduct marketing activities towards you, including direct marketing of your own products and services (Article 6 (1) (f) of the GDPR).

When sending the newsletter, we also use the technologies made available by our newsletter platform provider to monitor the behavior of newsletter recipients (e.g. clicking a link), which we use to optimize our content and shipping statistics. The legal basis is our legitimate interest (Article 6 (1) (f) of the GDPR). You can unsubscribe from the newsletter at any time.

CLAUSE G

Information clause of the information obligation for contact persons / persons representing clients or contractors

  1. The administrator of your personal data is ZOJO. The Gorgeousness Company Sp. z o.o. with headquarters in Warsaw (00-120) at ul. Zlota 59.
  2. Contact with ZOJO. The Gorgeousness Company Sp. z o.o. is possible via e-mail at store@zojoelixirs.com or in writing to the above-mentioned address.
  3. The data controller processes your business personal data, such as: name, surname, e-mail address, telephone number.
  4. The data controller obtained your personal data from the company with which you cooperate, or which you represent in the contract with ZOJO. The Gorgeousness Company Sp. z o.o.
  5. Your data will be processed:
  • for the purpose of commercial contacts for the purposes of the implementation of a commercial agreement between the client or contractor of ZOJO. The Gorgeousness Company Sp. z o.o. – the basis for processing is the implementation of the legitimate interest of ZOJO. The Gorgeousness Company Sp. z o.o. (Article 6 (1) (f) of the GDPR). The legitimate interest lies in the efficient and ongoing performance of the commercial contract;
  • in order to establish or pursue possible claims or defend against claims – the basis for processing is the implementation of the legitimate interests of ZOJO. The Gorgeousness Company Sp. z o.o. (Article 6 (1) (f) of the GDPR).
  1. Your personal data will be transferred to entities providing services to ZOJO. The Gorgeousness Company Sp. z o.o. i.e. law firms, banks, IT service providers and IT system suppliers as well as other entities authorized under the law.
  2. Personal data will be kept for the duration of the commercial agreement between ZOJO. The Gorgeousness Company Sp. z o.o. and the client / contractor and the time necessary to pursue any claims.
  3. You have the right to: access the content of the data and request rectification, deletion, processing restrictions, the right to transfer data, the right to object to data processing and the right to lodge a complaint with the President of the Personal Data Protection Office on the terms set out in the GDPR.
  4. You have the right to object to the processing of personal data on the basis of the legitimate interest of the administrator for reasons related to your particular situation.

Security

ZOJO is committed to ensuring that any personal data gathered is secure. We have implemented adequate technical and organisational measures in order to protect the personal information against any unauthorised access, disclosure, falsification, misuse or accidental loss.

Please note we have no control and take no responsibility for any third parties sites referred in our website.

Use & Sharing of Personal Data

It is our policy not to share your personal data with any third parties unless you have expressed your prior consent or it is required by law or necessary in order to fulfil the required services.

Personal information is stored in a secure database for exclusive access by ZOJO staff. We have undertaken all appropriate means, whether technical or organisational, to ensure a proper level of protection of any personal information that is transferred to any third party such as our clients, affiliates, service providers, agents etc which are processing such personal data on our behalf.

In the case of Clients using electronic payments via Przelewy24.pl or PayPal, ZOJO transfers the personal data to the relevant financial agent within the scope necessary to execute the transaction.

In the case of Clients using the courier delivery option, ZOJO transfers the personal data of the Clients to the courier company, within the scope necessary to assure the proper delivery of the goods.

Cookies

Cookies are small files that are being saved by the Internet browser on the user’s hard drive which allows the browser to tailor its performance to the user’s individual needs and preferences. We use cookies in the following ways:

  • To monitor which pages are being visited
  • For statistical analysis purposes
  • To improve our website
  • To personalise i.e. adjust the content to the user’s preferences/needs
  • To measure the efficiency of our marketing activities
  • To ensure security of the data provided
  • To save the contents of the shopping basket
  • To verify the user

Most web browsers automatically accept cookies, however you may choose to decline them by changing your web browser settings. Changes like that may prevent you from using the full functionality of our website.

Changes to Privacy Policy

This Privacy Policy may change from time to time without prior notice.

For further information or if you wish to access or modify your personal data please contact ZOJO at the below:

ZOJO. The Gorgeousness Company Sp. z o.o.
Złota 59

00-120 Warsaw, Poland

T: +48 790 522 970

E: store@zojoelixirs.com