Legal document

Newsletter Terms

Operator: FIRSTSTONE TRADING sp. z o.o.
Version: 2.0
Effective date: 2026-06-06
Last updated: 2026-08-09
Language: Polish
Legal contact: compliance@purepoint.pl

Operator: FIRSTSTONE TRADING spółka z ograniczoną odpowiedzialnością (FIRSTSTONE TRADING sp. z o.o.) KRS: 0001254766 | NIP: 7831958614 Registry court: District Court Poznań – Nowe Miasto i Wilda in Poznań, 8th Commercial Division of the National Court Register Registered office: ul. Wierzbięcice 44A/40A, 61-568 Poznań, województwo wielkopolskie Voivodeship Correspondence / Shop service address: ul. Wierzbięcice 44A/40A, 61-568 Poznań Representation: Krystian Dawidowski — Member of the Management Board (sole-member management board, independent representation) Newsletter contact: contact@purepoint.pl Legal / GDPR (RODO) contact: compliance@purepoint.pl Electronic Delivery Address (ADE): AE:PL-21312-60691-FGBFV-19

Version: 2.0 Effective date: 6 June 2026 Review: quarterly

§ 1. General provisions and definitions
§ 2. Purpose of the Newsletter (research-only)
§ 3. Operator and processor — Sendinblue SAS / Brevo
§ 4. Subscription procedure — double opt-in
§ 5. Sending frequency
§ 6. Newsletter content
§ 7. Unsubscribe (1-click unsubscribe)
§ 8. Protection of personal data (GDPR (RODO))
§ 9. Final provisions
Bibliography
Change history
Closing clause

§ 1. General provisions and definitions

These Newsletter Terms (hereinafter: the Terms) set out the rules for the provision by electronic means of the free Newsletter service of the purepoint.pl Shop by FIRSTSTONE TRADING spółka z ograniczoną odpowiedzialnością, with its registered office in Poznań (hereinafter: the Operator).
The Operator provides the Newsletter service within the meaning of Art. 2(4) of the Act of 18 July 2002 on the provision of services by electronic means (consolidated text: Journal of Laws 2024, item 1513, as amended) [VERIFY — the publication reference for the Act on the Provision of Services by Electronic Means is inconsistent across the document cluster: the privacy policy cites Journal of Laws 2024, item 1513, the cookies policy Journal of Laws 2024, item 1067, and this document originally Journal of Laws 2025, item 200; harmonised to Journal of Laws 2024, item 1513 — the correct current consolidated text to be confirmed by legal counsel] and conducts direct marketing using electronic communication in accordance with Art. 398 para. 1 of the Act of 12 July 2024 — Electronic Communications Law (Journal of Laws 2024, item 1221, hereinafter: PKE).
For the purposes of the Terms, the following definitions are introduced:
Newsletter — a recurring communication of commercial and substantive information sent by the Operator by electronic means to the Subscriber’s email address after consent has been given and confirmed in accordance with the double opt-in procedure.
Subscriber — a natural person, legal person or organisational unit without legal personality to which the law grants legal capacity, who has subscribed to the Newsletter; as a rule, the Subscriber is a Qualified Buyer within the meaning of the Shop Terms.
Qualified Buyer — a natural person conducting business activity, a legal person or an organisational unit purchasing or interested in purchasing the Products for a purpose connected with business, professional, research or academic activity (Art. 43(1) of the Civil Code), excluding a consumer within the meaning of Art. 22(1) of the Civil Code.
Products / Research Material — peptides and reference reagents offered in the Shop exclusively for research and development purposes (Research Use Only), not intended for use in humans or animals.
Shop — the purepoint.pl website operated by the Operator.
Brevo — the commercial name of the marketing platform operated by Sendinblue SAS (Paris, France), used as the processor for sending the Newsletter.
GDPR (RODO) — Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (OJ EU L 119 of 4 May 2016, p. 1).
Use of the Newsletter is voluntary, free of charge and does not require the creation of an account in the Shop. The Subscriber may unsubscribe from receiving the Newsletter at any time in the manner described in § 7.

§ 2. Purpose of the Newsletter (research-only)

The Newsletter serves to inform Subscribers exclusively within the scope consistent with the Operator’s business profile described in the Shop Terms, i.e. the distribution of Research Materials on a Research Use Only basis.
The Newsletter covers in particular:
information about new SKUs (catalogue products) introduced into the offer, including availability, HPLC purity, molecular weight, lyophilisate form;
publication of new Certificates of Analysis (COA) and updates to already published COAs;
technical and educational information concerning research methodology, in vitro binding assays, reagent reconstitution techniques, peptide stability under laboratory conditions;
announcements of industry events (conferences, training, educational webinars, R&D trade fairs);
the Operator’s organisational information (changes to terms, technical breaks of the Shop, price list changes, new logistics partners).
The Newsletter does NOT contain and will not contain:
any statements suggesting that the Products are intended for use in humans or animals (human-use marketing);
dosing instructions, administration protocols, descriptions of pharmacological effects in humans;
content misleading as to the legal status of the Products or suggesting their medicinal properties;
advertising of medicinal products within the meaning of Chapter 4 of the Act of 6 September 2001 — Pharmaceutical Law (consolidated text: Journal of Laws 2025, item 750, previously Journal of Laws 2024, item 686, as amended, hereinafter: PF);
content infringing Art. 124 of the PF, pursuant to which anyone who, without the required authorisation, places a medicinal product on the market is subject to a fine, restriction of liberty or imprisonment for up to 2 years.
The Operator applies a zero medical claims policy — every item of Newsletter content is subject to internal compliance verification before sending.

§ 3. Operator and processor — Sendinblue SAS / Brevo

The processor within the meaning of Art. 4(8) of the GDPR (RODO), providing the technical infrastructure for sending the Newsletter, is Sendinblue SAS with its registered office in Paris (France), operating under the commercial brand Brevo, on the basis of a personal data processing entrustment agreement compliant with Art. 28 of the GDPR (RODO).
Sendinblue SAS processes the data solely to the extent of:
technical handling of mailing lists;
carrying out the double opt-in procedure (recording consent, sending the confirmation email);
delivering subsequent Newsletter messages;
handling unsubscribe links;
reporting aggregate open and click statistics (engagement metrics).
Sendinblue SAS has its registered office within the European Economic Area (EEA), and therefore no transfer of data to a third country within the meaning of Chapter V of the GDPR (RODO) occurs, and the judgment of the CJEU of 16 July 2020 in Case C-311/18 (Schrems II) does not apply.
Brevo’s privacy policy is available at: https://www.brevo.com/legal/privacypolicy/

§ 4. Subscription procedure — double opt-in

Subscription to the Newsletter takes place in three steps in accordance with the double opt-in procedure required by the President of the Personal Data Protection Office and Art. 398 of the PKE:
Step 1 — sign-up: the Subscriber enters their email address in the sign-up form on the purepoint.pl website, ticks the checkbox of consent to receive the Newsletter, and accepts these Terms and the Privacy Policy;
Step 2 — confirmation email: within a few minutes a message entitled “Confirm your subscription to the PUREPOINT Newsletter” is sent to the address provided, containing a unique activation link valid for 48 hours;
Step 3 — activation: the Subscriber clicks the activation link — only this moment completes the subscription procedure and results in the address being placed on the active distribution list.
If the Subscriber does not click the activation link within 48 hours, the email address is automatically deleted from the Operator’s system without further processing.
The Operator records proof of consent in accordance with Art. 7 para. 1 of the GDPR (RODO) — in particular: the sign-up timestamp, IP address, browser agent, the wording of the consent clause in the version in force at the time of sign-up, and the timestamp of the activation link click.
Consent to the Newsletter is separate from the marketing consent given when creating a Qualified Buyer Account and is not a necessary condition for making a purchase in the Shop.

§ 5. Sending frequency

The Operator undertakes to send the Newsletter no more frequently than twice per month (a maximum of 24 messages per calendar year), subject to para. 2.
In particularly justified cases, the Operator reserves the right to send an additional message (beyond the limit) solely for the purpose of:
informing about the withdrawal of a specific Product batch from the market (recall) for quality reasons;
announcing a material change to the terms (Shop Terms, Privacy Policy) required by law;
notifying of a personal data breach (Art. 34 of the GDPR (RODO)), where the incident concerns the Newsletter database.
The Operator does not send bulk promotional messages of an impulse nature or communications multiple times in the same week.

§ 6. Newsletter content

Each Newsletter message permanently contains:
the name and identification details of the Operator (KRS, NIP, correspondence address);
a clear marking “Material for research purposes only — Research Use Only / Not for Human Consumption”;
an unsubscribe link in the footer, in accordance with § 7;
a link to the Privacy Policy and these Terms;
indication of the email address for GDPR (RODO) matters: compliance@purepoint.pl.
The Newsletter may contain only content compliant with § 2 para. 2. In the event of interpretive doubts as to the compliance of a specific communication, the decision is made by the Operator following internal consultation, guided by the principle of in dubio pro compliance (in case of doubt — in favour of compliance, i.e. the content is NOT sent).
The Operator does not make the list of Subscribers available to third parties for marketing purposes, does not sell the database and does not use it to carry out affiliate campaigns for the benefit of third parties.

§ 7. Unsubscribe (1-click unsubscribe)

The Subscriber may unsubscribe from the Newsletter at any time without giving a reason and without incurring any costs.
Unsubscription takes place by:
clicking the “Unsubscribe” link placed in the footer of every Newsletter message — the 1-click unsubscribe mechanism compliant with the List-Unsubscribe-Post defined in RFC 8058;
sending an email to compliance@purepoint.pl requesting removal from the Newsletter database;
withdrawing consent in the Qualified Buyer panel — if the Subscriber holds an Account in the Shop.
The Operator undertakes to remove the Subscriber’s email address from the active distribution database without undue delay, no later than within 7 days from the moment of unsubscription.
After removing the address from the active database, the Operator may retain the proof of consent and the fact of unsubscription in the form of a sign-up log and an unsubscribe log for the period necessary to demonstrate compliance with the GDPR (RODO) (Art. 5 para. 2 — the accountability principle), but no longer than 3 years from the date of unsubscription. [VERIFY — retention inconsistency in the cluster: Privacy Policy § 7 para. 7 provides for the retention of consent-withdrawal logs for 5 years, this document — 3 years; a single period for the same data category should be harmonised — decision to be confirmed by legal counsel]
Withdrawal of consent does not affect the lawfulness of the processing of data carried out before its withdrawal (Art. 7 para. 3, second sentence, of the GDPR (RODO)).

§ 8. Protection of personal data (GDPR (RODO))

Data controller: FIRSTSTONE TRADING sp. z o.o., details as in the header.
Categories of data: email address, sign-up timestamp, IP address, the wording of the consent clause, Qualified Buyer category (if provided), open and click statistics (engagement metrics).
Legal basis: (i) Art. 6 para. 1(a) of the GDPR (RODO) — the consent of the data subject to the processing of personal data for the purpose of sending the Newsletter; (ii) Art. 10 para. 2 of the Act on the provision of services by electronic means — consent to receive commercial information by electronic means; (iii) Art. 398 para. 1 of the Act of 12 July 2024 — Electronic Communications Law (PKE) — consent to the use of an electronic communication channel (email) for direct marketing purposes. The consents are voluntary, informed and unambiguous and may be withdrawn at any time, independently of one another.
Purposes of processing: sending the Newsletter, handling the double opt-in procedure, handling unsubscriptions, aggregate reporting, demonstrating compliance with the GDPR (RODO) (accountability).
Retention period: until consent is withdrawn (unsubscription); proof of consent and the unsubscribe log — for a period of 3 years in accordance with § 7 para. 4.
Data recipients: Sendinblue SAS (Brevo) — processor in accordance with § 3; cyber_Folks S.A. — hosting of the Shop infrastructure; entities servicing the Operator in the field of accounting and compliance — solely where it is necessary to prove compliance.
Subscriber’s rights (Art. 12–22 of the GDPR (RODO)): access to data, rectification, erasure, restriction of processing, data portability, objection, withdrawal of consent at any time, lodging a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw).
Data Protection Officer (DPO): the Operator has not appointed a DPO, as the conditions for mandatory appointment set out in Art. 37 para. 1 of the GDPR (RODO) are not met. In all GDPR (RODO) matters, the Subscriber contacts: compliance@purepoint.pl.
Profiling / automated decisions: the Operator does not take automated decisions regarding Subscribers within the meaning of Art. 22 of the GDPR (RODO) and does not carry out profiling with legal significance.

§ 9. Final provisions

The Operator reserves the right to amend the Terms in the event of changes to legal provisions, a change of the sending processor, a change in the scope of the Newsletter, or a modification of the subscription and unsubscription procedure. The Subscriber will be notified of changes by a Newsletter message or a direct email with 14 days’ advance notice.
Failure to accept the amended Terms entitles the Subscriber to unsubscribe from the Newsletter under § 7 — without negative consequences.
The law applicable to the Terms is Polish law. The resolution of disputes takes place in accordance with Regulation (EU) No 1215/2012 of the European Parliament and of the Council of 12 December 2012 (Brussels I bis) and Regulation (EC) No 593/2008 (Rome I).
The Terms enter into force on 6 June 2026 and apply from the moment of publication on the purepoint.pl/regulamin-newslettera/ website.

Bibliography

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR (RODO)) — OJ EU L 119 of 4 May 2016, p. 1.
Act of 23 April 1964 — Civil Code (consolidated text: Journal of Laws 2024, item 1061, as amended).
Act of 18 July 2002 on the provision of services by electronic means (consolidated text: Journal of Laws 2024, item 1513, as amended). [VERIFY — publication reference harmonised across the cluster; to be confirmed by legal counsel]
Act of 12 July 2024 — Electronic Communications Law (Journal of Laws 2024, item 1221).
Act of 6 September 2001 — Pharmaceutical Law (consolidated text: Journal of Laws 2025, item 750, previously Journal of Laws 2024, item 686, as amended), in particular Art. 124 para. 1.
Act of 10 May 2018 on the protection of personal data (consolidated text: Journal of Laws 2019, item 1781, as amended).
Judgment of the Court of Justice of the EU of 16 July 2020 in Case C-311/18 Data Protection Commissioner v. Facebook Ireland Ltd, Maximillian Schrems (Schrems II).
RFC 8058 (IETF, 2017) — Signaling One-Click Functionality for List Email Headers.
Sendinblue / Brevo Privacy Policy: https://www.brevo.com/legal/privacypolicy/
European Data Protection Board (EDPB) Guidelines 05/2020 on consent under Regulation 2016/679, adopted on 4 May 2020.

Change history

Version	Date	Scope of changes	Author
1.0	2026-05-22 / 2026-05-24	First version of the Newsletter Terms — single opt-in, no specification of frequency, incorrect citation of Art. 124 of the PF.	FIRSTSTONE Compliance
2.0	2026-06-06	Introduction of a double opt-in procedure compliant with RFC 8058; specification of the limit of 2×/month; designation of Sendinblue SAS / Brevo as the processor; correction of the citation of Art. 124 of the PF (fine, restriction of liberty or imprisonment for up to 2 years); full GDPR (RODO) clause; 1-click unsubscribe mechanism; harmonisation of the terminology “Qualified Buyer” and “Research Material”.	FIRSTSTONE Compliance

Closing clause

In matters not regulated by this document, the mandatorily applicable provisions of Polish and European Union law shall apply. In the event of interpretive doubts, contact compliance@purepoint.pl.