Privacy Policy

1. What data we collect and why

Orders

When you buy something we process your name, email address, phone number, shipping address, tax ID (only if you enter one at checkout), the products you ordered and the amount paid. We use this to process, ship and support your order, to email you an order confirmation, and to keep the accounting records required by law.

Legal basis: performance of a contract (art. 6(1)(b) GDPR) and our legal obligations under tax and accounting law (art. 6(1)(c) GDPR).

Payments

Payments are handled by Stripe on its own secure checkout page. We never see or store your full card or bank details — we only receive the payment status and the contact and shipping details you enter at checkout.

Your account

If you create an account we store your email address, your password (only as a secure one-way hash, never in plain text) and your order history, so you can log in and see your orders.

Legal basis: performance of a contract (art. 6(1)(b) GDPR).

Contact form

When you send us a message we store your name, email address, phone number (if you give one), your message and the IP address it was sent from. We use it to reply to you and to protect the form against spam and abuse.

Legal basis: our legitimate interest in answering enquiries and preventing abuse (art. 6(1)(f) GDPR).

Technical data

Like any website, our server processes your IP address and basic request information (for example browser type) to deliver the site, keep it secure and limit abusive traffic.

Legal basis: our legitimate interest in running a secure website (art. 6(1)(f) GDPR).

Website analytics

We use PostHog to understand how visitors use the shop — which pages are viewed, what is clicked, where visitors come from, device and browser type, page loading speed, technical errors, and approximate location (country and city) derived from the IP address — so we can fix problems and improve the site.

• Without your consent (before you choose, or if you click “Reject”) we collect this information without identifying your device: nothing is stored on your device, there are no session recordings, and PostHog combines your IP address and browser details with a random value that changes every day into a one-way code. The daily value is deleted after that day's data is processed, so your visits can't be linked across days, and the code can't be turned back into your IP address.
• If you click “Accept”, PostHog also stores an identifier on your device (see section 5) to recognise your device on later visits, records how you use our pages (session replay: what is shown on the page, clicks, scrolling and mouse movement — text you type into forms and your email address in the account menu are hidden and not recorded) and, if you are logged in, links this to your account number (not your email address).

Legal basis: statistics without identifying your device — our legitimate interest in understanding and improving our website (art. 6(1)(f) GDPR); everything else — your consent (art. 6(1)(a) GDPR). You can withdraw consent at any time with “Cookie settings” at the bottom of every page; this doesn't affect processing before the withdrawal.

We do not use advertising or cross-site tracking tools, and we do not sell your data.

2. Who we share your data with

We only share data with service providers that help us run the shop, and only what they need:

• Stripe — payment processing. See Stripe's privacy policy.
• CJ Dropshipping — our fulfilment partner, which packs and ships your order. It receives only what's needed for delivery: your name, phone number, shipping address (street, city, region, postcode and country), our order number, the products and quantities you ordered, their prices, and the chosen shipping method. We do not share your email address, tax ID or account details with CJ Dropshipping.
• Brevo (Sendinblue SAS, France) — sends our transactional emails, such as order confirmations. It receives your email address and the content of the email: your order number, the products you ordered and the amount paid. We don't use Brevo for marketing. See Brevo's privacy policy.
• Shipping carriers — the courier chosen for your parcel receives the details needed to deliver it.
• PostHog (PostHog Inc.) — website analytics described in section 1. Analytics data is stored in PostHog's EU cloud (Frankfurt, Germany) and is sent through our own domain. See PostHog's privacy policy.
• OVHcloud — our hosting provider, which stores the website and its database on our behalf. See OVHcloud's data protection information.

Some icons on the site are loaded from simpleicons.org, which means your browser sends your IP address to that service when it loads them.

We may also disclose data where we are legally required to, for example to tax authorities.

3. Transfers outside the EEA

Some of our service providers, including CJ Dropshipping, may process personal data outside the European Economic Area (EEA), including in China, in connection with fulfilling and delivering your order.

Where personal data is transferred outside the EEA, we take the measures required by applicable data protection law to ensure that the transfer is carried out lawfully and that your personal data receives an appropriate level of protection.

PostHog Inc. is based in the United States. Analytics data is stored in the EU, but PostHog staff and some of its sub-processors may access it from outside the EU, for example for support. Such transfers rely on the EU-U.S. Data Privacy Framework, under which PostHog is certified, or on the EU Standard Contractual Clauses in PostHog's data processing agreement.

For more information about the safeguards applicable to a particular transfer, you may contact us using the contact details provided in this Privacy Policy.

4. How long we keep your data

• Orders, invoices and other tax records — for as long as required by applicable tax and accounting laws.
• Your account — until you ask us to delete it, unless we are required to retain certain data by law.
• Contact form messages — up to 12 months after we've finished handling your enquiry.
• Website analytics — about 12 months; session recordings — up to 30 days.
• Technical logs — kept for a short period for security purposes, then deleted.

5. Cookies and local storage

Strictly necessary — always on, because the site can't work without them:

• BEARER (cookie) — keeps you logged in after you sign in. It can't be read by scripts and expires after 24 hours or when you log out.
• authEmail, authExp and authUserId (local storage in your browser) — remember your email, your account number and when your login expires, so the account menu can show it. Removed when you log out or when your login expires.
• analyticsConsent and __ph_opt_in_out_… (local storage) — remember whether you accepted or rejected analytics, so we don't ask again on every page.

Analytics — only if you click “Accept” on the cookie banner:

• ph_… (cookie, local storage and session storage, PostHog) — a random identifier of your device and current visit, used for the analytics and session recordings described in section 1. The cookie expires after 12 months; all of them are deleted when you click “Reject” in Cookie settings.

You can change your choice at any time with “Cookie settings” at the bottom of every page.

Stripe sets its own cookies on its checkout page to process payments and prevent fraud. These are covered by Stripe's privacy policy.

6. Your rights

You have the right to:

• withdraw your consent to analytics at any time (“Cookie settings” at the bottom of every page),
• access your data and get a copy of it,
• have inaccurate data corrected,
• have your data deleted (unless we must keep it, for example for accounting),
• restrict processing of your data in certain cases,
• object to processing where applicable under the GDPR, including processing based on our legitimate interests,
• receive your personal data in a structured, commonly used and machine-readable format where the right to data portability applies,
• lodge a complaint with a supervisory authority — in Poland this is the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw.

To use any of these rights, email us at support@frostfaces.com. We'll respond within one month.

7. Security

The whole site uses an encrypted HTTPS connection, passwords are stored only as secure hashes, and payments are processed entirely by Stripe. Access to customer data is limited to what's needed to fulfil orders.

8. Changes to this policy

We may update this policy when our services or the law change. The date at the top shows the latest version.

9. Data controller and contact

The controller of your personal data is:

Aleje Jerozolimskie 109/70, 02-011 Warsaw, Poland
Email: support@frostfaces.com

For any question about your data, or to exercise your rights, email us at the address above.