This document specifies the conditions for the processing of personal data (hereinafter also referred to as “data”) and cookies in the area of the website topmovers.pl, conducted via the website, made available at URL: topmovers.pl, hereinafter referred to as the “Website”.
TABLE OF CONTENTS
§1. HOW TO CONTACT THE DATA ADMINISTRATOR.. 1
§2. ON WHAT BASIS WE PROCESS YOUR DATA.. 1
§3. INFORMATION ON THE PROCESSING OF DATA FOR THE CONCLUSION AND IMPLEMENTATION OF CONTRACTS, POSSIBLE PURSUING CLAIMS AND DEFENSE AGAINST THEM..1
§4. INFORMATION ON THE PROCESSING OF DATA FOR DIRECT MARKETING.. 1
§5. INFORMATION ON DATA PROCESSING TO ENSURE SECURITY.. 1
§6. INFORMATION ON DATA RECIPIENTS.. 1
§7. INFORMATION ON TRANSMISSION OF DATA TO THIRD COUNTRIES.. 1
§8. ABSOLUTE RIGHTS OF PERSONS WHOSE DATA ARE PROCESSED.. 1
§9. RELATIVE RIGHTS OF PERSONS WHOSE DATA ARE PROCESSED.. 1
§10. COOKIES – INTRODUCTION.. 1
§11. DATA ADMINISTRATOR COOKIES.. 1
§12. THIRD PARTY COOKIES.. 1
§13. CONSENT TO THE USE AND MANAGEMENT OF COOKIES.. 1
§14. CACHE.. 1
§15. LINKS TO OTHER WEBSITES OR SOFTWARE.. 1
§1. HOW TO CONTACT THE DATA ADMINISTRATOR
The administrator of personal data processed as part of the Website is TMR COMPLETE SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ SPÓŁKA KOMANDYTOWA with its seat in Warsaw (02-013) street Williama Heerleina lindleya 16, entered into the Register of Entrepreneurs of the National Court Register under the number KRS: 0000853980, NIP: 7010807133 oraz REGON: 369646727.
You can contact the data administrator by phone: 888 888 436 and using an e-mail address: email@example.com.
§2. ON WHAT BASIS WE PROCESS YOUR DATA
When collecting personal data, we always inform about the legal basis of their processing. It results from the provisions of the GDPR (Regulations of the European Parliament and of the Council (UE) 2016/679 of April 27 2016 r. on the protection of individuals with regard to the processing of personal data, on the free movement of such data, and repealing the Directive 95/46/WE – general data protection regulation). When we inform about:
- art.6 pkt 1 lit. a) RODO – this means that we process personal data on the basis of the consent received,
- art.6 pkt 1 lit. b) RODO – this means that we process personal data because they are necessary to perform the contract or to take action before its conclusion, at the request received,
- art.6 pkt 1 lit. c) RODO – it means that we process personal data in order to fulfill a legal obligation,
- art.6 pkt 1 lit. f) RODO – it means that we process personal data in order to perform legitimate interests.
§3. INFORMATION ON THE PROCESSING OF DATA FOR THE CONCLUSION AND IMPLEMENTATION OF CONTRACTS, Possible CLAIMS AND DEFENSE AGAINST THEM
- We can process personal data necessary to perform the contract concluded with you. However, even before its conclusion, we may process personal data necessary to take action at your request. The processing of this data is based on Art.) GDPR.
- During the performance of the contract and after its performance, we process the personal data of its party for the purpose of considering claims, and their investigations. Our legitimate interest is, for example, the possibility of responding to a possible complaint, what we are obliged to do under separate provisions of civil law. In this case, we will process personal data based on a legitimate interest, which is the defense against possible claims or their pursuit. The processing of this data is based on Art. 6 point 1 lit. f) GDPR.
- We will store this data for the period necessary to achieve the designated purposes, no later than until the claims under separate legal provisions are time-barred.
- You have the right to access your data, rectification, deletion, processing restrictions, the right to transfer data, as well as the right to lodge a complaint to the supervisory body. In the event of data processing for the purpose set out in point 3, you also have the right to object to their processing.
- Providing this data is voluntary, however, failure to provide this data will prevent the conclusion of the contract or its implementation.
- The recipients of this data are: e-mail service provider, IT service provider, messenger provider, advertising service provider, legal, advisory and debt collection service provider and other service providers that we use for the designated purpose.
§4. INFORMATION ON THE PROCESSING OF DATA FOR DIRECT MARKETING
- We may process your personal data for the purpose of direct marketing. This happens, for example, when we reply to your message by providing details of our offer.
- The processing of this data is based on (Article 6 (1) (f) of the GDPR.
- We will store your data until it is necessary for the purpose of its implementation.
- You have the right to access your data, rectify it, delete it, limit processing, the right to transfer data, the right to object to data processing, as well as the right to lodge a complaint with the supervisory authority.
- Providing this data is voluntary, and failure to provide this data will prevent direct marketing activities.
- The recipients of this data are: IT service provider, e-mail service provider and advertiser.
§5. INFORMATION ON DATA PROCESSING TO ENSURE SECURITY
- From the moment you launch our website, we process data such as:
- public IP address of the device from which the request came,
- browser type and language,
- date and time of the inquiry,
- the number of bytes sent by the server,
- URL of the previously visited page, in case the visit was made using this link,
- information about errors that occurred while processing the inquiry.
- Our legitimate interest in this processing is keeping logs of server events and securing the Website against potential hacking attacks and other abuses. Including the possibility of determining the IP address of a person performing an illegal activity in the area of the Website, such as attempting to breach security, or publish prohibited content, or attempting illegal activities using our servers.
- The processing of this data is based on Art. 6 point 1 lit. f) GDPR.
- We will store this data for the period necessary to achieve the designated purposes, no later than until the claims under separate legal provisions are time-barred.
- You have the right to access your data, rectify it, delete it, limit processing, and object to its processing, as well as the right to lodge a complaint with the supervisory authority.
- Providing this data is a condition for using the Website. Failure to provide this data will prevent the use of the Website.
- The recipient of this data is the IT service provider.
§6. INFORMATION ON DATA RECIPIENTS
When processing personal data, we use external services. Therefore, third parties may be recipients of your personal data. When collecting personal data, we always inform about these recipients, but due to the primacy of legibility of the message, we do it briefly. Therefore, we hereby explain that when we inform about individual categories of recipients, they are the following entities:
- IT service provider: JACKVISION, ul. Gierdziejewskiego 7 lok.20A, 02-495 Warszawa.
- Email service provider: Google Inc. 1600 Amphitheatre Pkwy, Mountain View, CA 94043, Stany Zjednoczone;
- Messenger provider: Facebook Inc. 1 Hacker Way, Menlo Park, CA 94025, Stany Zjednoczone.
- Advertising service provider: JACKVISION, ul. Gierdziejewskiego 7 lok.20A, 02-495 Warszawa.
- Provider of legal / advisory / debt collection services – these service providers are appointed individually, in the event of a specific need.
§7. INFORMATION ON TRANSMISSION OF DATA TO THIRD COUNTRIES
- Due to the fact that we use the services of other suppliers, your personal data may be transferred outside the European Economic Area, namely to the country: United States of America (USA).
- The European Commission has determined that some countries outside the European Economic Area (EEA) protect personal data adequately.
- Since the country to which we transfer personal data has not been recognized as a safe country, the transfer of data takes place on the basis of an agreement containing standard data protection clauses adopted by the European Commission.
§8. ABSOLUTE RIGHTS OF PERSONS WHOSE DATA ARE PROCESSED
When we write about the rights related to the processing of your personal data, we refer to the rights described below. The possibility of exercising the following rights is independent of the legal basis for the processing of personal data.
The right to access data
You have the right to obtain confirmation from us as to whether we process personal data concerning you. If this is the case, you have the right to access this data, as well as receive additional information about:
- the purposes of the processing,
- categories of data concerned,
- recipients or categories of recipients to whom the data has been or will be disclosed, in particular about recipients in third countries or international organizations,
- if possible, the planned period of data storage, and if this is not possible, the criteria for determining this period,
- the right to request us to rectify, delete or limit data processing, to object to such processing, as well as the right to lodge a complaint with the supervisory authority,
- the data source, if your data has not been collected from you,
- automated decision making, including profiling and the rules for making them, as well as the importance and expected consequences of such processing for you.
Upon receipt of such a request, we are required to provide a copy of the personal data undergoing processing. If such a request is submitted electronically and if we do not receive any other objection, we will also provide information electronically.
The right to rectify data
You have the right to request us to immediately rectify your personal data that is incorrect. Taking into account the purposes of processing, you have the right to request that incomplete personal data be supplemented, including by providing an additional statement.
The right to delete data (to be forgotten)
You have the right to request us to delete your personal data immediately. We are then obliged to delete personal data without undue delay if one of the following circumstances applies:
- you have withdrawn your consent to the processing of your personal data and we have no other basis for their processing,
- you have lodged an effective objection to the processing of your data,
- Your personal data has been processed unlawfully,
- Your personal data must be deleted in order to comply with the legal obligation,
- Your data was collected in connection with the offering of information society services.
Right to restriction of processing
You have the right to request us to restrict processing in the following cases:
- when you question the correctness of the data – for a period allowing us to check their correctness,
- the processing is unlawful and you oppose the deletion of the data and request the restriction of their use instead,
- we no longer need personal data for processing purposes, but you need them to establish, exercise or defend claims,
- you have objected to the processing of your data – until it is determined whether the legitimate grounds on our part override the grounds of your objection.
Automated decisions, including profiling
You have the right not to be subject to a decision which is based solely on automated processing, including profiling, and produces legal effects on you or similarly significantly affects you.
The law does not apply if this decision:
- it is necessary for the conclusion or performance of a contract between you and us,
- is permitted by EU law or the law of the Republic of Poland and which provides for appropriate measures to protect your rights, freedoms and legitimate interests,
- or is based on your explicit consent.
Right to lodge a complaint
You have the right to lodge a complaint regarding the processing of your personal data with the supervisory authority: President of the Personal Data Protection Office, street Stawki 2, 00-193 Warsaw, tel. 22 531 03 00, fax. 22 531 03 01, e-mail: firstname.lastname@example.org.
§9. RELATIVE RIGHTS OF PERSONS WHOSE DATA ARE PROCESSED
When we write about the rights related to the processing of your personal data, we refer to the powers described below. The possibility of using them depends each time on the legal basis for the processing of personal data.
The right to withdraw consent to processing
In the event that we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time. Naturally, the withdrawal of the consent granted does not affect the lawfulness of the prior processing of personal data.
Right to data portability
You have the right to receive your personal data provided to us in a structured and commonly used machine-readable format. You also have the right to send this personal data to another administrator without obstruction on our part, if the processing takes place :
- on the basis of consent or on the basis of a contract, and in an automated manner.
When exercising the right to data portability, you have the right to request that personal data be sent by us directly to another administrator, if technically possible. This right may not adversely affect the rights and freedoms of others.
Right to object
In the event that we process your personal data pursuant to art. 6 point 1 lit. f) GDPR, you have the right to object to the processing of this data, for reasons related to your particular situation.
Then we are no longer allowed to process this personal data, unless we can prove existence :
- valid, legitimate grounds for processing, where these grounds must override the interests, rights and freedoms of your person, or the grounds for establishing, investigating or defending claims.
Also, if you object to the processing of your personal data for direct marketing purposes, then we will not be able to process it for such purposes .
§10. COOKIES – INTRODUCTION
In terms of the purposes of using cookies, we distinguish between three categories :
- Necessary files – these files enable the proper operation of the website and its functionality, e.g. authentication or security cookies. Without saving them on your device, it will be impossible to use the website.
- Analytical files – these files make it possible to monitor opened websites, traffic sources, time spent on the website. Without saving them, the use of the website functionality will not be limited.
- Advertising files – these files enable the display of personalized advertisements within or outside the website.Without saving them, the use of the website functionality will not be limited.
In terms of their validity, we distinguish between two categories of cookies:
- session files – existing until the end of the session,
- persistent files – existing after the session ends.
In terms of distinguishing the entity administering cookies, we distinguish:
- our cookies,
- third party cookies.
§11. DATA ADMINISTRATOR COOKIES
The cookies we administer allow us to protect the Website against hacker attacks.
§12. THIRD PARTY COOKIES
- Google Ads – advertising files, used to conduct and evaluate the quality of advertising campaigns carried out with the use of the service Google Ads,
- Google Analytics – analytical files used to study the behavior and traffic of users and to compile traffic statistics.
Collected by Google Inc are anonymous and collective. In particular, they do not contain identifying features (understood as personal data) Website users. By using the above-mentioned services, we collect data such as the sources of acquiring users visiting the Website, as well as the manner of their behavior on the Website, information about the devices and browsers used by them, IP address, domain, demographic data (age, gender), interests and geographic data.
More information in this regard can be found here: https://policies.google.com/technologies/cookies?hl=pl
We use files administered by Facebook Inc. 1 Hacker Way, Menlo Park, CA 94025, United States :
- Pixel advertising tags, used by Facebook Inc. 1 Hacker Way, Menlo Park, CA 94025, United States. These are elements published in digital content and make it possible to record information, e.g. about the activity carried out on the website, as well as to evaluate the effectiveness of advertisements. Facebook Inc. pixel tag management is possible via Facebook in its user panel
More information in this regard can be found here: https://www.facebook.com/policies/cookies/
§13. CONSENT TO THE USE AND MANAGEMENT OF COOKIES
With the exception of the necessary cookies, their processing is based on the user’s consent.
The consent to the processing of cookies is voluntary and may be withdrawn at any time. However, it should be remembered that the lack of consent to the use of certain cookies may limit the use of the Website and its functionality, and even prevent it from being used.
Consent to the processing of cookies may take place :
- by means of the software settings installed on the telecommunications end device used by the user,
- by using a button containing a declaration of consent to the processing of cookies or confirmation of reading its terms,
- using the settings available in the website area.
When you use the Website, we may automatically use the cache installed on your device. As part of the local memory, it is possible to store data intersessionally, i.e. between subsequent visits to the Website. The purpose of using the cache is to accelerate the use of the Website by eliminating the situation in which the same data would be repeatedly downloaded from the Website, thus burdening the User’s Internet connection. The cache can also store data such as login password.
§15. LINKS TO OTHER WEBSITES OR SOFTWARENIA
- The change of the privacy and cookies policy takes place by publishing its new content on the website.
- We publish information on changes to the Privacy and Cookies Policy in the area of the Website, no later than 3 days before the effective date of its new wording..