Privacy Policy


The protection of personal data has always been considered one of the key aspects of Clochee Sp. z o.o.'s (hereinafter: "Clochee") operations. As a manufacturer and provider of what we believe are the best cosmetic products for our loyal customers, we also take responsibility for the security of personal data processed in connection with our business. Our goal is to inform you properly about matters related to the processing of personal data, especially in light of the new data protection regulations, including the General Data Protection Regulation (GDPR) (EU) 2016/679 of April 27, 2016. Therefore, in this document, we provide information on the legal basis for processing personal data, methods of collection and use, as well as the rights of data subjects related to these processes.

What are personal data and what does their processing mean?

Personal data refers to information about an identified or identifiable natural person. Processing of personal data essentially includes any activity involving personal data, whether carried out in an automated manner or not, such as collecting, storing, organizing, modifying, reviewing, using, disclosing, restricting, deleting, or destroying. Clochee processes personal data for various purposes, and depending on the purpose, different methods of collection, legal bases for processing, use, disclosure, and retention periods may apply.

When does this Privacy Policy apply?

This privacy policy applies to all cases in which Clochee is the data controller for personal data and processes such data. This includes cases where Clochee processes personal data obtained directly from the data subject, as well as cases where personal data is obtained from other sources. Clochee fulfills its information obligations in both cases, as defined in Articles 13 and 14 of the GDPR, respectively. Below, we provide the full details of Clochee as the data controller:

Clochee Spółka z ograniczoną odpowiedzialnością with its registered office in Szczecin (Clochee), Al. Wojska Polskiego 14/U1, 70-471 Szczecin, registered in the National Court Register, kept by the District Court Szczecin-Centrum Szczecin, XIII Economic Department of the National Court Register, under the KRS number 0000470899, with Tax Identification Number (NIP) 8522603457, REGON 321395694, and share capital of PLN 1,601,000.00 (one million six hundred one thousand zlotys, 00/100), fully paid.

How, based on what legal grounds, and what types of personal data does Clochee process?

We aim to maintain transparency regarding the methods and legal bases for processing personal data, as well as the purposes for which Clochee processes personal data. We make sure to provide necessary information on these matters to each individual whose personal data we process as the data controller. To ensure clarity in our explanations, we present a summary of personal data processing operations below. Additionally, whenever we process personal data based on the legitimate interests of the data controller, we strive to analyze and balance our interests against the potential impact on the data subject (both positive and negative) and the rights of the data subject under data protection laws. We do not process personal data based on our legitimate interests if we conclude that the impact on the data subject outweighs our interests (in such cases, we may process personal data if we have appropriate consent or if required or permitted by law).

Processing personal data of individuals visiting Clochee's website or using electronic services (e.g., online stores)

General Information

Individuals visiting Clochee's websites or using electronic services provided by Clochee, collectively referred to as "Services," have control over the personal data they provide to us. The Services limit the collection and use of information about their users to the necessary minimum required to provide services at the desired level, in accordance with Article 18 of the Act of July 18, 2002, on the provision of electronic services.


To a limited extent, we may collect personal data automatically through cookies on our websites. Cookies are small text files stored on a user's computer or other mobile device while using websites. These files serve various functions on a specific website, such as utilizing different features provided on the website or confirming that a user has seen specific content on the website. Among cookies, we can distinguish those necessary for the operation of the Clochee service. Cookies in this category are used to:

  • maintain user sessions,
  • save user session state,
  • enable authorization using the login service,
  • save information allowing anonymous user login,
  • save information necessary for the operation of the online shopping cart on websites,
  • monitor the availability of services.

Another category of cookies consists of files that, while not essential for using the Services, facilitate their use. These cookies are used to:

  • restore the last viewed state upon the next login to the product,
  • remember the user's choice regarding stopping the display of a selected message or displaying it a specific number of times,
  • restore the user session,
  • save the last-selected category in the product,
  • Verify if the cookie file storage functions correctly,
  • Enable automatic login to the product (the "Remember me" option),
  • Adjust product content to user preferences,
  • Set preferred language, currency, font size, and other properties to facilitate interaction with the application,
  • Restore the last search result in the product,
  • Display recently viewed products in the online store,
  • Display the last selected sorting parameter.

Among the entities listed in this document as of its preparation date are:

  • Google Analytics (more information and Google Analytics blocking add-on:,
  • Facebook (more information on the website:,
  • Instagram (more information on the website:,
  • DotPay (more information on the website:

We also inform that some elements of Clochee services are handled by external advertisers placing behavioral ads on Clochee websites. Content from external providers may contain cookies from other entities, so users are advised to familiarize themselves with the rules for using these cookies on websites by these external providers. Users can manage cookies used by Clochee or any other external providers by changing their web browser settings. Clochee also notes that rejecting cookies may result in some features offered by our services not working correctly, and in some cases, it may even prevent the use of the selected product.

Access Logs

We collect information about the use of services by users and their IP addresses based on access log analysis. We use this information to diagnose server-related issues, analyze potential security breaches, and manage the website. The IP address is also used for statistical purposes, such as collecting and analyzing demographic data of website visitors (e.g., information about the region from which the connection was made). Based on the information obtained in the manner described above, aggregate general statistical summaries are created in specific cases, disclosed to third parties cooperating with us. These summaries usually include information about website viewership. However, these summaries do not contain any data allowing the identification (determination of identity) of a specific user of the service. We also inform that we may be obliged to disclose information about the IP address of a specific user of the service at the request of authorized state authorities - based on applicable legal regulations - in connection with proceedings conducted by them.

Other Data

As a rule, only when it is really necessary to provide a given service, in some cases, such as subscribing to free newsletters, ordering e-books, conducting surveys, or in order forms, we collect more detailed information about users, such as email addresses or other personal data.

Automatic Processing of Personal Data

Information collected in connection with the use of our services may be processed automatically (including profiling), but this will not have any legal effects on an individual or significantly affect their situation. We attach particular importance to the issue of profiling and emphasize that:

We do not process any sensitive data for profiling purposes,

  • For profiling purposes, we usually process data that has been pseudonymized or aggregated by us,
  • If we cannot achieve the goal other than by profiling non-pseudonymized or non-aggregated personal data, we use typical data for this purpose: email address, IP, or cookies,
  • We profile to analyze or forecast personal preferences and interests of people using our services, products, or services and to tailor the content in our services or products to those preferences,
  • We profile for marketing purposes, i.e., matching the marketing offer to the above preferences.

Legal Bases for Processing

In the case of processing personal data in connection with the use of Clochee services by users, we may have various legal bases for processing, depending on the category of personal data we process and the purpose of processing. For example:

  • We process the personal data of people visiting our websites based on the legitimate interest of the data controller, e.g., by adjusting displayed ads or based on consent when we ask the data subject for their consent,
  • We process the personal data of people using our online stores and filling out an online form for this purpose because it is necessary for the purpose of performing the contract,
  • Sometimes legal regulations require us to process certain personal data for tax and accounting purposes.
  • Processing personal data of individuals contacting Clochee to obtain information about the offer or share comments about Clochee's services or products, as well as contacting to conclude an agreement with Clochee

In addition to the data mentioned in the previous section, from individuals who contact Clochee to obtain information about the offer or share comments about Clochee's services or products, as well as contacting to conclude an agreement with Clochee, we collect the following personal data: first and last name, position, company address, email address, and telephone/fax number. In particular, these individuals may send us an email through the website. Such messages contain a set username and email address, and additional information that the user wants to include in the message. We kindly ask not to provide information about special categories of personal data (such as information about race or ethnic origin, political opinions, religious or philosophical beliefs, union membership, information about physical or mental health, genetic data, biometric data, information about sexual life or sexual orientation, and criminal record) through websites. In case of providing such information for any reason, it will mean explicit consent to the collection and use of such information as specified in this document or as specified where such information was disclosed.

Legal Bases for Processing

We collect the above data based on consent given by the user making the above request to Clochee or for the purpose of performing a contract (fulfilling the request) submitted by the individual. The provided data may also be processed based on the legitimate interest of the data controller.

Processing of Personal Data of Clochee Customers and Potential Customers

Clochee processes personal data of its customers and potential customers. Among these data may be personal data of individuals associated with Clochee's customers who are not individuals (e.g., contacts). Personal data of this type is processed in IT systems used by Clochee (including both the CRM system and systems for electronic recording of conversations when concluding agreements and contacts with customers by phone, with each case informing the data subject about recording such a call and the possibility of disconnecting if consent to recording is not given). Personal data processed for these purposes include, among others: first and last name, position of the contact person, phone number, email address, or other business contact details. In addition, for customers who have entered into paid agreements with Clochee, we also process payment-related data, including credit card numbers and bank account numbers. Personal data of business contacts may be disclosed to Clochee's permanent commercial employees and used by them to conduct Clochee's commercial activities.

Legal Basis for Processing

The processing of personal data of individuals who are our customers is based on:

  • Clochee's legitimate interest as a data controller (e.g., in creating a database, analytical and profiling activities, including analysis of product usage, direct marketing of own products, securing documentation for defense against potential claims or for claim enforcement),
  • Consent (especially consent for email marketing or telemarketing),
  • Performance of a concluded contract,
  • Obligations arising from the law (e.g., tax law or accounting regulations).

The processing of personal data of individuals who are potential customers is based on:

  • Clochee's legitimate interest as a data controller (e.g., in creating a database, direct marketing of own products),
  • Consent (especially consent for email marketing or telemarketing).
  • Duration of Personal Data Processing

The duration for which we can process personal data depends on the legal basis that constitutes the lawful grounds for Clochee to process personal data. In the Clochee policies, including data retention policies, we specify that we may never process personal data beyond the period stipulated by the aforementioned legal bases. Accordingly, we inform you that:

  • In the case of processing personal data based on consent, the processing period lasts until the user withdraws this consent.
  • In the case of processing personal data based on the legitimate interest of the data controller, the processing period lasts until the cessation of the aforementioned interest (e.g., the limitation period for civil claims) or until the data subject objects to further processing – in situations where such objection is permitted by law.
  • In the case of processing personal data because it is necessary due to applicable legal provisions, the processing periods for this purpose are determined by these provisions (for example, the mandatory legal obligation to retain the user's personal data for a longer period, or if the user's personal data is needed to assert legal claims or defend against legal claims, the user's personal data will be retained until the end of the relevant retention period or until the resolution of these claims).
  • In the absence of specific legal or contractual requirements, the basic data retention period for records and other documentary evidence drawn up during the performance of the contract is a maximum of 10 years.

When and How Do We Disclose Personal Data to Third Parties? Do We Transfer Data to Third Countries?

We disclose personal data to others only when permitted by law. In such cases, in the relevant agreement concluded with a third party, we include provisions and security mechanisms to protect data and maintain our standards regarding data protection, confidentiality, and security. Agreements of this kind are called personal data processing agreements, and Clochee has control over how and to what extent the entity to which Clochee has entrusted the processing of specific categories of personal data processes that data. Accordingly, we indicate that the recipients of personal data processed by Clochee as a data controller may include:

  • Entities processing personal data under personal data processing agreements (so-called processors),
  • Entities conducting marketing or sales campaigns on behalf of Clochee,
  • Other subcontractors of Clochee providing software delivery services, software or hardware maintenance services used by Clochee, as well as suppliers of goods we use,
  • Entities providing survey research services, including NPS (customer satisfaction) surveys,
  • Debt collection companies (with personal data transferred only to the extent necessary to achieve the specific purpose),
  • Auditors and certified auditors, legal advisors, tax advisors,
  • Authorities supervising compliance with the law, regulatory authorities, and other public administration bodies.
  • (In the last two cases, we transfer data only when and to the extent necessary, and only in accordance with absolutely applicable legal requirements and in a manner consistent with these regulations).

In the case of personal data subject to EU regulations, it should be noted that cross-border transfers may involve countries not belonging to the European Economic Area ("EEA") and countries where regulations specifying special protection of personal data do not apply. We have taken measures to ensure adequate protection of all personal data and compliance with the law for the transfer of personal data outside the EEA. When transferring personal data outside the EEA to a country where, according to the European Commission, there is no adequate level of protection of personal data, the transfer takes place only on the basis of an agreement that takes into account the EU requirements for transferring personal data outside the EEA.

What Rights Do Data Subjects Have, and How Are They Exercised?

Individuals have specific rights regarding their personal data, and Clochee, as a data controller, is responsible for exercising these rights in accordance with applicable legal regulations. For any questions and requests regarding the scope and implementation of rights, as well as to contact us for the purpose of exercising a specific right related to the protection of personal data, please contact us at the email address:

We reserve the right to exercise the following rights after positively verifying the identity of the person applying for a specific action.

Access to Personal Data

Individuals have the right to access the data we store as a data controller. This right can be exercised by sending an email to:

Changing Personal Data

Changes, including updates to personal data processed by Clochee, can be made by sending an email to: or, in relevant cases, by contacting us through the appropriate registration page or changing personal data stored in relevant applications in which registration was made.

Withdrawal of Consent

In the case of processing personal data based on consent, individuals have the right to withdraw this consent at any time. We inform about this right at any time we collect consents and enable the withdrawal of consent as easily as it was given. In the absence of different information, i.e., if we have not provided another address or contact number for withdrawing consent, please send us an email at

Right to Restrict Processing or Object to Personal Data Processing

Individuals have the right to restrict processing or object to the processing of their personal data at any time, due to their particular situation, unless processing is required by law. A person may object to the processing of their personal data when:

Right to Lodge a Complaint and Contact Information

Individuals whose personal data Clochee processes also have the right to lodge a complaint with the supervisory authority, which is the President of the Office for Personal Data Protection (address: ul. Stawki 2, 00-193 Warsaw).

Of course, we do not limit contact with us and enable direct contact at the headquarters of Clochee. Additionally, contact can be made by mail or phone, and for this purpose, we provide the following contact details: Clochee Sp. z o.o., al. Wojska Polskiego 14/U1, Szczecin, tel. 790 322 322.

Can Changes to this Privacy Policy Occur, and When?

We commit to regularly reviewing this Privacy Policy and making changes when necessary or desirable due to: new legal regulations, new guidelines from authorities responsible for supervising processes related to personal data protection, best practices in the field of personal data protection (Codes of Conduct if Clochee is bound by such Codes, in which case we will inform you). We also reserve the right to change this Privacy Policy in the event of changes in the technologies we use to process personal data (provided that such changes affect the content of this document) and in the event of changes to the methods, purposes, or legal bases for processing our personal data.

The last update of this document took place on July 1, 2023.