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PRIVACY AND COOKIES POLICY OF BROYX.COM

Last updated: September 2026

§ 1. GENERAL PROVISIONS

  • This Privacy Policy sets out the rules for the processing and protection of personal data of Users using the website available at broyx.com, hereinafter referred to as the “Website”, as well as the rules governing the use of cookies and artificial intelligence technologies.

  • The Website is informational, marketing and product-oriented in nature. No products are sold through the Website and it is not possible to place orders or conclude sales agreements through the Website.

  • The controller of the personal data of Website Users within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (“GDPR”) is Alterson Polska Sp. z o.o., with its registered office at ul. Jagiellońska 55, 03-301 Warsaw, Poland, entered in the Register of Entrepreneurs of the National Court Register under KRS number 00004031529, NIP 5213622538, REGON 145894500, hereinafter referred to as the “Controller”.

  • Personal data is protected in accordance with generally applicable laws, including the GDPR, the Polish Act of 10 May 2018 on the Protection of Personal Data and, where applicable, Regulation (EU) 2024/1689 of the European Parliament and of the Council laying down harmonised rules on artificial intelligence (“AI Act”).

  • The Controller may be contacted in matters relating to personal data protection by e-mail at: contact@broyx.com or in writing at the address of the Controller’s registered office.

§ 2. PURPOSES, LEGAL BASES AND RETENTION PERIODS

The Controller may process Users’ personal data for the following purposes:

1. Communication and handling enquiries

  • Scope of data: in particular, name, e-mail address, telephone number, content of correspondence and other information voluntarily provided by the User.
  • Purpose: responding to enquiries concerning products, the BROYX brand, cooperation, product availability from distributors or other matters related to the Controller’s activities.
  • Legal basis: Article 6(1)(f) GDPR – the Controller’s legitimate interest in maintaining communication with Users and handling enquiries addressed to it.
  • Retention period: for the period necessary to handle the matter and thereafter, where justified, until the expiry of the limitation period for possible claims or until an effective objection is submitted.

2. Marketing of the Controller’s own products and the BROYX brand

  • Scope of data: depending on the functionalities used on the Website, this may include an e-mail address, data relating to activity on the Website, and statistical and analytical information.
  • Legal basis: Article 6(1)(a) GDPR – the User’s consent, where required, and Article 6(1)(f) GDPR – the Controller’s legitimate interest in promoting its business, products and brand.
  • Retention period: until consent is withdrawn, an effective objection is submitted, or the purpose of processing ceases to apply.

3. Analysis of Website use and development of the Website

  • Scope of data: in particular, technical information concerning the device and browser, IP address, information about the manner in which the Website is used, and statistical data.
  • Purpose: compiling statistics, analysing Website traffic, and improving its functionality, security and quality of content.
  • Legal basis: Article 6(1)(a) GDPR – the User’s consent to the extent required by applicable law concerning cookies or similar technologies, and Article 6(1)(f) GDPR – the Controller’s legitimate interest to the extent permitted by law.
  • Retention period: for the period resulting from the settings of the relevant analytical tool or until consent is withdrawn or an effective objection is submitted.

§ 3. USE OF ARTIFICIAL INTELLIGENCE TECHNOLOGIES

1. AI Virtual Assistant

  • In order to improve the use of the Website, facilitate navigation, provide information about BROYX products and help Users find relevant content on the Website, an automated AI Assistant may be made available.

  • A User interacting with the AI Assistant is communicating with an artificial intelligence system and not with a human being.

  • The content of queries entered in the chat window, together with necessary technical data, may be processed for the purpose of generating responses and improving the quality of the Website.

  • The legal basis for such processing is Article 6(1)(f) GDPR – the Controller’s legitimate interest in providing Users with an informational and support function and improving the quality of service.

  • The AI Assistant service may be provided using a solution supplied by Chatbase Inc., based in the United States. Where personal data is transferred outside the European Economic Area, appropriate legal mechanisms required under the GDPR are applied, in particular Standard Contractual Clauses or European Commission adequacy decisions.

  • The Controller does not use data entered by Users in the AI Assistant window to independently train publicly available artificial intelligence models, unless otherwise resulting from the terms and operation of the technology provider used.

  • Users should not enter special categories of personal data, health information, confidential financial information, passwords or other information that is not necessary to obtain a response in the chat window.

  • Responses generated by the AI Assistant are for informational and support purposes only. They do not constitute a commercial offer within the meaning of Article 66 of the Polish Civil Code and do not constitute confirmation of product availability from any particular seller.

  • Current information concerning BROYX products, their characteristics and technical specifications is available on the relevant product pages on the Website. Information concerning prices, availability and purchase conditions should always be verified directly with the relevant seller or distributor.

  • The User may stop using the AI Assistant at any time and contact the Controller at: contact@broyx.com.

2. Graphic and visual materials generated or modified using AI

  • Selected illustrations, visual elements and promotional materials published on broyx.com and on official BROYX social media profiles may be created or modified using artificial intelligence tools.

  • Materials generated or modified using AI may depict, among other things, outdoor environments, people or example situations related to sport and physical activity.

  • Such materials may be promotional, decorative or illustrative in nature.

  • The actual appearance of products, their parameters and technical characteristics should be verified on the official product pages on the Website and, with regard to purchase conditions, directly with sellers and distributors offering the relevant products.

§ 4. RECIPIENTS OF PERSONAL DATA AND TRANSFERS OUTSIDE THE EEA

  • Users’ personal data may be disclosed to entities cooperating with the Controller only to the extent necessary to achieve the purposes set out in this Policy, in particular to:
    • entities affiliated with the Controller and subcontractors,
    • hosting and IT service providers,
    • providers of analytical, marketing and advertising tools,
    • providers of communication and User support solutions,
    • providers of artificial intelligence systems and tools, including Chatbase Inc.,
    • legal, accounting, auditing and advisory service providers,
    • Google LLC, Meta Platforms Ireland Ltd. and other technology providers used on the Website, to the extent resulting from the tools actually used.

  • Due to the use of services supplied by technology providers based or operating infrastructure outside the European Economic Area, Users’ data may be transferred outside the EEA.

  • Transfers of personal data outside the EEA are carried out using mechanisms provided for under the GDPR, in particular Standard Contractual Clauses or European Commission adequacy decisions.

§ 5. USERS’ RIGHTS

Each User, where provided for under the GDPR, has the following rights:

  • the right to access their personal data and obtain a copy thereof,
  • the right to rectify inaccurate personal data,
  • the right to erasure of personal data,
  • the right to restriction of processing,
  • the right to data portability, where applicable,
  • the right to object to processing based on the Controller’s legitimate interests, including direct marketing,
  • the right to withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before consent was withdrawn.

Requests concerning the exercise of the above rights should be sent to: contact@broyx.com.

The Controller handles requests within the time limits provided for under the GDPR.

Users also have the right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw, Poland – if they believe that the processing of their personal data infringes the GDPR.

§ 6. COOKIES, PROFILING AND TRACKING TECHNOLOGIES

  • The Website may use cookies and similar technologies, both its own and those provided by third parties.

  • Cookies are small text files stored on the User’s device while using the Website.

  • Cookies may be used in particular for the following purposes:

    • ensuring the proper and secure operation of the Website,
    • remembering User preferences,
    • compiling statistical analyses,
    • measuring Website traffic and the effectiveness of marketing activities,
    • personalising content,
    • carrying out advertising and remarketing activities, subject to obtaining the required consent.

  • To the extent required by law, cookies other than those strictly necessary are used only after the User has given consent.

  • Data concerning User activity may be used for profiling, in particular for adapting marketing and advertising content, where the User has given the required consent.

  • Profiling carried out on the Website is not used to make decisions concerning Users that produce legal effects or similarly significantly affect them.

  • Users may change their cookie preferences at any time using the consent management panel available on the Website and through the relevant settings in their web browser.

  • Withdrawal of consent does not affect the lawfulness of activities carried out before consent was withdrawn.

§ 7. FINAL PROVISIONS

  • The Controller applies appropriate technical and organisational measures intended to ensure the security of processed personal data, taking into account the nature of the data, the scope of processing and the related risks.

  • The Controller may update this Privacy Policy in particular in the event of changes in applicable law, the functionality of the Website, technologies used or methods of processing personal data.

  • The current version of the Privacy Policy is published on the Website together with the date of its most recent update.

  • Matters not regulated by this Policy are governed by applicable law, in particular the GDPR, the Polish Act of 10 May 2018 on the Protection of Personal Data and, where applicable, the AI Act.

  • This version of the Privacy Policy becomes effective on the date of its publication on the Website.

 

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