- WHO PROCESSES YOUR DATA?
The admistrator of your personal data is Intrex Spółka z ograniczonąodpowiedzialnością located in Sady 62-080, Za Motelem 7 street, registered into National Court Register by District Court Poznań – Nowe Miasto i Wilda in Poznań, VIII NCR Commercial Division No KRS 0000657643, NIP: 7811941102, REGON: 36646806, hereinafter referred to as ‘We’.
You can contact us by post at : Intrex sp. z o.o., ul. Za Motelem 7, 62-080 Sady or by mail: email@example.com.
- WHAT KIND OF DATA DO WE GATHER?
As part of running the Site, we may ask you to provide us with data, including personal information
The data we gather include:
– a unique advertiser identifier
– website activity data, incl. click stream analysis
– device identifier
– browser type, domain and communication language and its settings,
– time zone,
– visited websites,
– personal and marketing preferences,
– cookies and pixel tags,
– IP addresses,
– Internet provider.
Through the Site, other data may also be collected, including personal data in connection with the provision of forms on the Site (contact form and newsletter sign-up form). We provide each time a dedicated separate information on the processing of personal data in the link under the form. We recommend that you get acquainted with their content when using the forms.
In addition, we collect, use and share aggregated data, such as statistical or demographic data. For example, we may aggregate our Site usage data to calculate the percentage of users accessing a particular feature of the Site. However, if we combine aggregated data with your personal information, this may directly or indirectly identify you.
We do not collect special categories of personal data (including data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, sexuality or sexual orientation). We also do not collect any information regarding criminal convictions and criminal acts.
Our Site is not intended for use by children, we do not consciously collect data on children.
Your provision of data is voluntary, but failure to do so may entail the inability to use some of the services of our Site.
- LOGI SERWERA
Each use of the Website is associated with sending an inquiry to our server. These inquiries are saved in the server’s logs and stored there. The data stored in the logs comprise: your IP address, time of the inquiry, time of sending the answer, browser’s and user’s operating system details. These data are not associated with a specific user of the Website nor are used to identify the users, but used only to manage the server and, as a rule, are kept for a period of 30 days.
- DISTRIBUTOR’S AREA
- COOKIE TYPES
Depending on the storage time on terminal device, cookies we use can be divided into:
session cookies: stored on the user’s device until the end of browser’s session. The data gathered until are then deleted permanently.
persistent cookies: stored on the user’s device for a given in file parameters’ time or until deleted by the user.
We use the following cookie types:
‘necessary’ cookies – these enable the use of our Website, i.e. cookies that are used to ensure our security, to identify misuse of the Website. That type of files ensures basic functionality of the Website and the use of the Website is dependent on their download, so they are always activated
Preference cookies allow the site to remember information that changes the look or function of the site, such as your preferred language or the region where you are located.
Statistical cookies help website owners understand how different users use the site.
Marketing cookies are used to track users on websites. The goal is to display ads that are relevant and interesting to individual users and thus more valuable to publishers and advertisers.
- MANAGING COOKIE TYPES IN THE BROWSERE
In many cases, the software used to browse websites allows storing cookies in the user’s device, giving the possiblity to manage and/or delete them according to one’s own preferences. The scope of automatically gathered information depends, among others, on your browser’s settings. You can always check these to learn what kind of data is shared through the browser automatically or to change these settings. At any time, you have the option of disabling or restoring the function of gathering cookies by changing the settings in your browser. In order to delete or block cookies on your computer, follow the instructions given by the browser’s producer on the help page.
You can find a link to the tool used on the Site to manage your preferences regarding the installation of cookies in the footer of our Site under the heading “Cookie Management”.
To delete cookies stored on your computer, follow the instructions that your browser’s manufacturer provides on its products’ cookie management help page.
- WHY DO WE GATHER YOUR PERSONAL DATA, LEGAL BASIS.
In the course of running the Site, we process your data (depending on the service/circumstances/contract) for the following purposes:
- to enable our distributors to download files form the distributors’ area – based on their consent [art. 6, sec. 1(a) GDPR]
- carry out activities related to marketing of our products and services – based on your consent [Article 6 (1) (a) RODO], taking into account consents given for the use of particular types of cookies
- sending commercial information within the meaning of the Law on Provision of Electronic Services, if you have agreed to receive it – based on your consent [Article 6 (1) (a) RODO],
- analyze your activity (including profiling) on the Site in order to tailor (including automated) services and content to your individual preferences, including targeted advertising – based on your consent [Article 6 (1) (a) RODO], taking into account consents given for the use of particular types of cookies,
- measure advertising effectiveness and conversions within relevant advertising networks – based on your consent [Article 6 (1) (a) RODO], taking into account consents given for the use of particular types of cookies,
- to collect information about your shopping experience on our Site – on the basis of our legitimate interest [Article 6 (1) (a) RODO] taking into account the consents given for the use of particular types of cookies
- to prepare general statistics reacted to the use of the Website by you and other users, incl. demographic data (i.e. about a region the connection comes from) – on the basis of our legitimate interest [art. 6, sec. 1(f) GDPR]
- to allow users of the Site to manage their consent to the installation of cookies and, where applicable, the related processing of personal data – on the basis of our legitimate interest [Article 6 (1) (f) RODO],
- processing and handling of complaints submitted by you regarding our goods and services and the performance of warranty services – as applicable, based on the agreement concluded with you [Article 6 (1) (b) RODO] or based on our legitimate interest [Article 6 (1) (f) RODO],
- handling inquiries and requests you send to us – on the basis of our legitimate interest [Article 6 (1) (f) RODO],
- to contact you, in particular for purposes related to the provision of services – if applicable, in connection with the necessity to perform the contract concluded with you [Article 6 (1) (b) RODO] or on the basis of our legitimate interest [Article 6 (1) (f) RODO],
- to perform technical activities and troubleshooting related to managing the website on the basis of our legitimate interest [art. 6, sec. 1(a) GDPR]
- to store data in order to ensure accountability (including demonstrating compliance with our obligations under the law) – on the basis of our legitimate interest [art. 6, sec. 1(f) GDPR]
- to store data for archival purposes – based on our legitimate interest [art. 6, sec. 1(f) GDPR]
- storage of data for archival purposes – on the basis of our legitimate interest [Article 6 (1) (f) RODO],
- conduct court, arbitration and mediation proceedings – based on our legitimate interest [Article 6 (1) (f) of the RODO],
- to ensure the security and integrity of the services we provide electronically, including preventing fraud and abuse, combating SPAM, and ensuring the security of traffic on the Site – based on our legitimate interest [Article 6 (1) (f) RODO].
If until now you were interested in our marketing messages sent by electronic means, you will continue receiving them, unless you unsubscribe from our Newsletter. Remember that you can unsubscribe at any time, by clicking in a link attached to our marketing messages. We respect you decisions, so you can always change your mind.
Profiling based on your personal data for the purpose of automated presentation of content tailored to your preferences is carried out only on the basis of your express consent, which you can withdraw/change at any time in the tool for managing consent to the installation of cookies, a link to which can be found in the footer of our Site.
- TOOLS WE USE
In order to make optimized use of the information contained in cookies, among other things, we use analytical tools and tools that enable us to manage advertising and marketing of our products, including by displaying targeted advertising based on recognition of your device.
These tools also allow us to process the collected information in such a way that it supports our research and development work and supports our marketing activities.
Pursuant to the consents you have given us, your personal data (collected, among other things, through cookies) may be processed by automated means (including profiling), and based on the collected information (e.g. data on your preferences), we may customize the content presented on and off our Site, including advertising content.
Within the limits of the consents you have given us, through the tools we use, we may also share information about your use of our Site with our social, advertising and analytics partners, who may combine it with other information you have provided to them or that they have collected as a result of your use of their services.
4.1 GOOGLE reCAPTCHA
The reCAPTCHA collects hardware and software information, such as your IP address, browser properties (including browser type and version, screen resolution, language, time and date of access), your Google account information (if you are logged in), your browsing behavior, your accessing behavior (such as mouse movements across the reCAPTCHA surface), tasks including image identification if necessary, and sends it to Google for analysis. In accordance with the reCAPTCHA Terms of Service, the information collected from your use of the reCAPTCHA service will be used to improve the service and improve security in general. However, it will not be used by Google to personalize the ads displayed. Our legal basis for the processing in question is our legitimate interest in protecting our Site from abuse and spam.
- THE COOKIE MANAGEMENT PLATFORM
In order to legally enable our Website users to consent to the installation of applicable cookies and, where applicable, the related processing and also the sharing of personal data, we use a dedicated platform for this purpose.
User consent is recorded and documented by logging the user’s anonymous IP number, browser user client, website URL, date and time of consent, and a unique encrypted key. After 14 days, consent is automatically deleted from the log.
The legal basis for the data processing in question is our legitimate interest related to the implementation of the principle of accountability under the provisions of the RODO.
- GOOGLE ANALYTICS, GOOGLE ADS, YOUTUBE
Using Google Ads marketing tools, and Google Analytics analytics tools, we process data related to your activity on our Site, including web identifiers in order to provide you with personalized based on profiling ads or to monitor your choices using statistical and marketing cookies. We only undertake our activities using the tools in question within the limits of the consents you have given for the use of particular types of cookies, including consents for automated decision-making and data transfer to advertising partners. You can check/change your consent settings at any time in the cookie consent management tool linked in the footer of our Site. To delete cookies already stored on your computer, follow the instructions that your browser manufacturer provides on the help page for managing cookies in its products.
4.3.1 GOOGLE ANALYTICS enables us to generate detailed statistics on how users use our Website. This tool collects data in the form of web identifiers, including cookie IDs, IP address, device IDs and user IDs. With the tools provided by Google, your IP address is anonymized.
In accordance with Google Analytics terms of service, Google states that it will not associate the IP address of the data subject with other data held by Google.
To opt out of Google Analytics cookies, you can also download and install the Opt-out Browser Add-on: a browser add-on that blocks Google Analytics.
4.3.2GOOGLE ADS is Google’s advertising system that enables, where applicable, the display of ads on Google’s advertising network and YouTube.
In connection with the use of Google Ads tools, other companies, where appropriate and subject to users’ consents, may place cookies on users’ browsers and read them, or use web beacon images (beacon – a technique used on websites to verify whether a user has accessed certain content) to collect information as a result of displaying ads on the sites.
Google uses the information provided on the Sites (including, where applicable, our Sites) and applications to provide and improve services, manage services, develop new services, measure advertising effectiveness, protect against fraud and abuse, and personalize content and ads displayed on Google and Google’s partner sites and applications. You can find detailed information about Google’s use of data in the link below: How Google uses data from sites and apps that use our services.
Any user with a Google account can disable personalization of ads on the web in Google Ads Settings.
Users signed in to Google can also export all records from the Google website, in the “My Activity” section (including those related to ads) using the Get Your Data function provided by Google.
In connection with our use of tools provided by Google, your personal data may be transferred to the United States. The U.S. is not subject to a decision by the European Commission finding an adequate level of protection under European data protection legislation. Transfers to the U.S. involve the risk of possible access to entrusted data due to programs allowing U.S. public authorities to access personal data transferred from the European Union to the U.S. for national security purposes, resulting in restrictions on the protection of personal data. These restrictions are not implemented in a manner that meets substantively equivalent requirements to those of EU law. These laws do not grant data subjects rights that are enforceable against U.S. authorities before the courts. The legal basis for the transfer of personal data to the U.S. in this case is the consent you gave when you entered our Site. You can withdraw your consent at any time in the tool that allows you to manage your consent to the installation of cookies, a link to which can be found in the footer of our Site.
When transferring personal data acquired in connection with online advertising and measurement outside Europe – Google uses standard contractual clauses (SKUs). The Google Advertising Services Data Processing Rules for services for which Google is a processor include both the relevant SKUs prepared by the European Commission (legitimizing data transfer in compliance with RODO) and the UK SKUs (legitimizing data transfer in compliance with the provisions of RODO adopted in UK law), according to the needs of the respective data transfer processes. Similarly, the Terms of Cooperation between controllers on data protection for services for which Google is the controller include both the relevant SKUs of the European Commission and the UK SKUs, according to the needs of the respective data transfer processes.
4.4 HOTJAR ANALYTICS
We undertake our activities using the tools in question only within the limits of the consents you have given for the use of statistical cookies. You can check/change the settings of your consents at any time in the tool that allows you to manage your consent to the installation of cookies, a link to which can be found in the footer of our Site. To delete cookies already stored on your computer, follow the instructions that your browser manufacturer provides on the help page for managing cookies in its products.
In the event that data is transferred outside the EEA as part of the services Hotjar provides, Hotjar ensures that the transfer will occur within the legal instruments accepted by the RODO, such as the use of standard data protection clauses or other appropriate safeguards. As with tools provided by Google, your personal data may be transferred to the United States. The U.S. is not subject to a decision by the European Commission finding an adequate level of protection under European data protection legislation. The legal basis for the transfer of personal data to the USA in this case is the consent you gave when you entered our Site. You can withdraw your consent at any time by clicking on the tool to manage your consent to the installation of cookies, a link to which can be found in the footer of our Site.
For more information, see the “About Hotjar” section of the Hotjar support page.
- YOUTUBE VIDEOS ON OUR SITE
We place YouTube videos on our Site in enhanced privacy mode – without using cookies that track data about user behavior. This means that activity information will not be collected by YouTube to personalize your viewing experience and the content you view with extended privacy mode enabled will not affect your browsing experience on YouTube.
- TECHNICAL MEASURES
We make every effort to secure your data and protect it from the actions of third parties. We use all necessary security measures for servers, connections and the Site. In particular, the communication between your computer and our server, when we collect your personal data, is encrypted using SSL (Secure Socket Layer). In addition, our databases are protected from third-party access. If we use subcontractors – we carefully verify their reliability and the security measures they use to protect the data of our Website users.
- RECIPIENTS OF YOUR DATA
Where appropriate, we may transfer data:
- persons authorized by us, our employees and associates who must have access to the data to perform their duties,
- processing entities to whom we commission this task, e.g. companies dealing with the operation of our IT systems or providing us with IT tools, companies providing consulting and marketing services to us, suppliers of analytical and remarketing tools used by us (Google Analytics, Google Ads).
- public entities, if it results from an obligation imposed by law.
- other entities that will process personal data as an independent data controller: e.g. business partners as part of the marketing tools used on the Website (Google). The sharing of anonymized data from Google Analytics takes place only on the basis of your explicit consent expressed by accepting the relevant cookies
- THE STORAGE PERIOD OF YOUR DATA
Your personal data will be processed by us for the period necessary for the performance of the contract for the provision of customer account services (if entered into) and the performance of the contract for the sale of goods (if entered into), as well as for the period provided for by applicable laws, primarily taking into account the statute of limitations for claims arising from civil law relations between you and us.
We are entitled to process personal data that we process based on your consent until you revoke your consent or until the processing of your personal data is no longer necessary to achieve the purpose for which the data is processed, and when the respective purpose of the processing has been achieved and completed.
When responding to your inquiries, your personal data will be processed by us until we have answered your question. After answering your question, your data may be stored by us, but only for a period of time corresponding to the statute of limitations for claims that may be raised against us and that we may have against you.
We will process data that we process on the basis of our legitimate interest until you raise any objection, or until the processing of your personal data is no longer necessary to achieve the purpose for which the data is processed, and when the relevant purpose of the processing has been achieved and completed.
- YOUR RIGHTS
In connection with the processing of your personal data, you have the following rights, within the limits of the law and as applicable:
- access to the content of your data and rectification, deletion or limitation of processing and transfer of your data,
- in situations where we process your data on the basis of your consent, you have the right to withdraw it at any time, but this will not affect the lawfulness of processing based on your consent before its withdrawal,
- In such a situation, we will no longer process this personal data for the relevant purpose unless we demonstrate the existence of valid legitimate grounds for processing that override your interests, rights and freedoms, or grounds for establishing, asserting or defending claims,
- to lodge a complaint with the supervisory authority having jurisdiction, in particular, over the place of your habitual residence, place of work or place where the alleged violation was committed, if you consider that the processing of your personal data violates the provisions of the RODO. In Poland, the supervisory authority is the President of the Office for Personal Data Protection (ul. Stawki 2, 00-193 Warszawa).
You can exercise some of the above rights yourself:
-Unsubscribing from the newsletter by using the unsubscribe function available in the footer of each newsletter will be equivalent to revoking your consent to the processing of personal data for the purpose of sending the newsletter.
– Consent to the installation of cookies in conjunction with the processing of personal data for the purposes specified by the function of such cookies – you can withdraw in the tool for managing consent to the installation of cookies, a link to which can be found in the footer of our Site.
You can exercise your other rights by sending an email to: firstname.lastname@example.org.
We will make every effort to promptly handle your request and provide you with answers to questions about the processing of your data. We will respond no later than 30 days after receiving your request. If this deadline were to be extended, where appropriate, due to the complex nature of the request or the number of requests we have received – we will inform you of the extension, along with an indication of the reasons for such extension.
In case of reasonable doubt about the identity of the person making the request – we will be able to request additional information necessary to confirm the identity of the person making the request. It is not mandatory to provide such data, but failure to do so will result in the refusal of the request.
We store information regarding requests received, in order to demonstrate compliance in accordance with the principle of accountability under the RODO, and to establish, protect and pursue claims.
- QUESTIONS AND RESERVATIONS