PRIVACY POLICY

§ 1 Type of processed data, purposes, and legal basis

• email address
• first name
• phone number

§ 2 Recipients of data

• 1.1. Processors. The Controller uses suppliers who process personal data solely on the Controller’s instructions. These include, among others, providers of hosting services, accounting services, marketing systems, systems for analyzing traffic on the Website, and systems for analyzing the effectiveness of marketing campaigns.
• 1.2. Controllers. The Controller uses suppliers who do not act solely on instructions and independently determine the purposes and methods of using Clients’ personal data. These provide electronic payment and banking services.

§ 3 Data retention period

• 1.1. Where the basis for processing personal data is consent, the Client’s personal data is processed by the Controller until the consent is withdrawn, and after withdrawal of consent, for a period corresponding to the limitation period for claims that the Controller may raise or that may be raised against them. Unless a specific provision states otherwise, the limitation period is six years, and for claims concerning periodic benefits and claims related to business activities – three years.
• 1.2. Where the basis for processing data is the performance of a contract, the Client’s personal data is processed by the Controller as long as it is necessary for the performance of the contract, and after that time, for a period corresponding to the limitation period for claims. Unless a specific provision states otherwise, the limitation period is six years, and for claims concerning periodic benefits and claims related to business activities – three years.

§ 4 Cookie mechanism, IP address

• 2.1. Session cookies: After the browser session ends or the computer is turned off, the stored information is deleted from the device’s memory. The session cookie mechanism does not allow the collection of any personal data or any confidential information from Clients’ computers.
• 2.2. Persistent cookies: These are stored in the memory of the Client’s end device and remain there until they are deleted or expire. The persistent cookie mechanism does not allow the collection of any personal data or any confidential information from Clients’ computers.

• 3.1. analysis and research as well as audience auditing, in particular to create anonymous statistics that help understand how Clients use the Website, enabling improvements to its structure and content.

• 4.1. presenting a map indicating the location of the Controller’s office on the Website’s information pages, using the maps.google.com service (external cookie administrator: Google Inc., based in the USA).

§ 5 Rights of data subjects

• 1.1. The Client has the right to withdraw any consent given.
• 1.2. Withdrawal of consent takes effect from the moment of withdrawal.
• 1.3. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
• 1.4. Withdrawal of consent does not entail any negative consequences for the Client; however, it may prevent further use of services or functionalities that the Controller may lawfully provide only with consent.

• 2.1. The Client has the right to object at any time – for reasons related to their particular situation – to the processing of their personal data based on Article 6(1)(e) or (f) of the GDPR, including profiling based on these provisions. The Controller may no longer process such personal data unless they demonstrate compelling legitimate grounds for processing that override the interests, rights, and freedoms of the data subject, or grounds for establishing, pursuing, or defending claims.
• 2.2. Opting out via email from receiving marketing communications regarding products or services will constitute the Client’s objection to the processing of their personal data, including profiling for these purposes.

• 3.1. The Client has the right to request the erasure of all or some of their personal data.
• 3.2. The Client has the right to request the erasure of personal data if:
  • 3.2.1. the personal data is no longer necessary for the purposes for which it was collected or processed;
  • 3.2.2. they have withdrawn specific consent, to the extent that the personal data was processed based on their consent;
  • 3.2.3. they have objected under Article 21(1) of the GDPR to the processing and there are no overriding legitimate grounds for processing, or they have objected under Article 21(2) of the GDPR to the processing;
  • 3.2.4. the personal data is processed unlawfully;
  • 3.2.5. the personal data must be erased to comply with a legal obligation under Union law or the law of the Member State to which the Controller is subject;
  • 3.2.6. the personal data was collected in connection with the offering of information society services.
• 3.3. Despite a request for erasure of personal data due to an objection or withdrawal of consent, the Controller may retain certain personal data to the extent that processing is necessary for establishing, pursuing, or defending claims, as well as for complying with a legal obligation requiring processing under Union law or the law of the Member State to which the Controller is subject. This applies in particular to personal data including: first name, last name, email address, which are retained for the purpose of handling complaints and claims related to the use of the Controller’s services, as well as residential/correspondence address and order number, which are retained for the purpose of handling complaints and claims related to concluded sales contracts or service provision.

• 4.1. The Client has the right to request the restriction of the processing of their personal data. Submitting such a request prevents the use of certain functionalities or services that involve the processing of the data subject to the request until the request is processed. The Controller will also refrain from sending any communications, including marketing ones.
• 4.2. The Client has the right to request the restriction of the use of their personal data in the following cases:
  • 4.2.1. when they contest the accuracy of their personal data – in which case the Controller restricts its use for the time needed to verify the accuracy of the data, but no longer than 7 days;
  • 4.2.2. when the processing of the data is unlawful, and instead of erasure, the Client requests the restriction of its use;
  • 4.2.3. when the personal data is no longer necessary for the purposes for which it was collected or used but is needed by the Client to establish, pursue, or defend claims;
  • 4.2.4. when the data subject has objected to the processing of their data – until it is determined whether the legitimate grounds on the Controller’s side override the grounds for the objection of the data subject.

• 5.1. The Client has the right to obtain confirmation from the Controller as to whether their personal data is being processed, and if so, the Client has the right to:
  • 5.1.1. access their personal data;
  • 5.1.2. obtain information about the purposes of processing, the categories of personal data processed, the recipients or categories of recipients of this data, the planned retention period of the Client’s data or the criteria for determining this period (if specifying the planned retention period is not possible), the rights the Client has under the GDPR, the right to lodge a complaint with a supervisory authority, and if the personal data was not collected from the data subject – any available information about its source, as well as information about automated decision-making, including profiling as referred to in Article 22(1) and (4) of the GDPR, and – at least in those cases – meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject, and the safeguards applied in connection with the transfer of personal data outside the European Union;
  • 5.1.3. obtain a copy of their personal data. The right to obtain a copy must not adversely affect the rights and freedoms of others.

• 6.1. The Client has the right to request the Controller to promptly rectify their personal data that is inaccurate. Taking into account the purposes of processing, the Client whose data is concerned has the right to request the completion of incomplete personal data, including by providing an additional statement, by sending the request to the email address in accordance with §6 of the Privacy Policy.

• 7.1. The Client has the right to receive their personal data provided to the Controller and then transfer it to another controller of their choice. The Client also has the right to request that the personal data be transferred directly by the Controller to such a controller, provided it is technically feasible. In such a case, the Controller will provide the Client’s personal data in a CSV file format, which is a commonly used, machine-readable format that allows the received data to be transferred to another data controller.

• 8.1. The Client has the right to lodge a complaint with the President of the Personal Data Protection Office regarding a violation of their rights to the protection of personal data or other rights granted under the GDPR.

§ 6 Changes to the Privacy Policy