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Privacy and cookie files policy

This document regulates the Privacy and Cookie Files Policy of the on-line service, conducted with the intermediary of the web site, made available at the following URL address:, hereinafter referred to as “Service”. The Service is manager by Hubert Owerczuk, who conducts its economic activity under the firm WebWise Hubert Owerczuk, with a registered office in Warsaw (03-324) at 14 Krzywińska Street, Suite 4, Poland registered in the Central Registration and Information on Business, kept by the Minister of Economic Development, under the Tax Identification Number (NIP): 5423037817 and the National Business Registry Number (REGON): 200842030, that is a service provider, administrator and owner of the Service. You can contact with the Service Provider by submitting an e-mail to the following address:

1. Introduction

In the part describing the privacy policy we inform we inform about the conditions of collecting, using and protecting personal data of the Service Users, hereinafter referred to as the “Users”. For personal data we consider any and all information related to an identified or possible to be identified natural person. The person possible to be identified is a person, whose identity can be determined directly or indirectly, in particular by referring to an ID number or one or a few specific factors, which determine his/her features. The information is not considered as enabling to a determination an identity of the concerned person, if it would require excessive costs, time or efforts. Providing personal data is voluntary, but necessary in order to use the marked functionalities, for example to place an order and settle / register an account on the website or use forms. These goals are always clearly marked. Failure to provide this data may prevent you from using these features.

In this document we also list the applied technologies, which are connected with processing data. For instance: web browser memory handling, geolocation or pixel tags.

Within a scope of the Cookie File Policy we inform about the conditions of storing the data or getting access to information, which are already stored on the telecommunication device of the end users. As the end user we recognise a natural person or an entity, that uses a publicly available telecommunication service or, which requires rendering such a service, for satisfying their/its own needs.

2. Declaration

While realising an overarching objective, which consists in respecting privacy, we make attempts to exercise due care. In order to fulfil this assumption, we realise standards and rules resulting from the generally applicable law provisions. These include in particular: GDPR (Regulation of the European Parliament and of the European Council) 2016/679 of 27th April 2016 on the protection of individuals with regard to the processing and free movement of personal data and repealing of the directive 95/46/EC (general regulation on data protection), the Act of 10th May 2018 on the protection of personal data, the Act of 18th July 2002 on the provision of electronic services, and the Act of 16th July 2004 Telecommunication Law. In particular we exercise due care in order to ensure that the personal data is:

  • processed according to the law provisions, reliably and in a transparent manner,

  • collected for the objectives compliant with the law provisions, which we inform about when collecting this data,

  • not a subject of further processing non-compliant with the purposes given in the information obligation,

  • correct and updated as necessary

  • substantially correct and adequate with regard to the objectives, for which it is processed,

  • appropriately secured against an access of the unauthorised persons, damaging, disclosing and unlawful use,

  • stored in a form that enables to identify the persons, to whom it refers no longer that it is necessary to achieve an objective of its processing, which we inform about before collecting personal data or during the process.

The data processed by the Service provider is stored on the external, secure servers, on the basis of the agreements concluded by the Service Provider. The agreements consider a proper level of securing data.

3. Controller of personal data

The controller of the personal data processed within a frame of the Service is the Service Provider.

4. Basis and time of processing personal data

When collecting personal data, we always inform about the legal basis of their processing. When we inform about:

  • Article 6 paragraph 1 point a) GDPR - this means that we process personal data based on the consent received,

  • Article 6 paragraph 1 point b) GDPR - this means that we process personal data because they are necessary to perform the contract or to take actions before its conclusion, upon the request received,

  • Article 6 paragraph 1 point c) GDPR - this means that we process personal data in order to fulfill the legal obligation,

  • Article 6 paragraph 1 point f) GDPR - this means that we process personal data for the performance of legitimate interests about which we always inform.

We may also process personal data based on other specific provisions, such as the Electronic Services Provision Act.

The processing time of personal data depends on the basis and purpose of their processing. We always inform you about it before collecting personal data or during this process. Examples of storage periods for personal data:

  • Personal data processed in connection with marketing activities will be processed until objections to the processing of this data are received.

  • Personal data processed on the basis of consent to the processing of these data, will be processed until it is withdrawn.

  • Personal data processed using cookies and similar technologies, will be processed until these files are deleted using the browser or device settings and objection to their processing.

  • Personal data processed in connection with the implementation of applicable legal provisions (eg. for the purpose of issuing an invoice) will be processed within the time required by the generally applicable provisions of accounting and tax law.

  • Personal data related to the provision of services, including sales, will be kept until possible claims from us or by us, i.e. in accordance with the generally applicable limitation periods for claims.

5. Scopes and objectives of processing personal data

We process Users’ personal data in the systematised collections, which are defined according to their objective of processing. This data is processed in the necessary scope for a realisation of the determined objective. The list below includes the collections, scopes, and the objectives of processing personal data, too.

In addition, the possible purposes of personal data processing are:

  • assessment and analysis of activities, including profiling (automated processing of personal data for the purpose of presenting tailored advertising or market and statistical analyzes),

  • fulfilling legal obligations resulting from the provisions of generally applicable law, eg accounting or tax law, pursuing claims and responding to them.

We always inform you about the purposes of personal data processing before collecting these data or when collecting them.

6. Disclosure of personal data

We may entrust the processing of personal data on our behalf to other entities. These may be, for example, a webmaster, accounting or legal service, a payment operator or other entity with whom we cooperate in order to provide services properly. We always inform the recipients of personal data before collecting these data or when collecting them.

Entrusting personal data always takes place on the basis of a data entrustment agreement or another legal instrument, ensuring an adequate level of security of processing of entrusted personal data.

The current list of entities entrusted with data processing is permanently available. In order to get access to it, just ask us with such a request. This can be done, e.g. by sending an e-mail. The legal basis for entrusting personal data is art. 28 GDPR.

In the case of transfering of data outside the European Economic Area, we will always inform you about this fact before collecting this data or when collecting it.

In the remaining scope, we do not disclose the collected data to third parties, except for situations in which it is required by generally applicable law, i.e. on the basis of a request of an authority or court authorized to do so.

7. The rights of persons whose personal data is processed

In relation to the processing of personal data, the persons whose personal data we process are entitled to the rights related to this processing. The ability to exercise the following rights depends on the legal basis for the processing of personal data.

The right to access data

The data subject is entitled to obtain confirmation from us whether personal data concerning them are being processed. If this is the case, they are entitled to access to them and additional information (among others goals, categories, recipients, retention, rights, source).

After receiving such a request, we are required to provide a copy of the personal data to be processed. If such request is received electronically and if we do not receive an exception, we will also provide information electronically.

The right to rectify data

The data subject has the right to request us to rectify immediately any personal data that is incorrect about them. Taking into account the purposes of processing, they have the right to request supplementing incomplete personal data, including by providing an additional statement.

The right to be forgotten

The data subject has the right to request us to delete their personal data immediately. We then have an obligation to delete personal data without undue delay if one of the following circumstances applies:

  • the consent to the processing of personal data has been withdrawn and there is no other basis for processing,

  • has submitted effective opposition to the processing,

  • personal data were processed unlawfully,

  • personal data must be removed in order to comply with the legal obligation,

  • data were collected in connection with offering information society services.

The right to limit processing

The data subject has the right to request a processing restriction from us in the following cases:

  • the data subject questions the correctness of personal data - for a period allowing us to check the correctness of this data;

  • the processing is unlawful and the data subject opposes the removal of personal data, requesting to limit their use instead;

  • we no longer need personal data for processing, but they are needed by the data subject to determine, assert or defend claims;

  • the data subject has lodged an objection under Article 21 par. 1 GDPR regarding processing - until it is determined whether the legitimate grounds on our part of the administrator override the grounds for objection of the data subject.

The right to transfer data

The data subject has the right to receive, in a structured, commonly used, machine-readable format, personal data that they provided to us, and they have the right to forward this personal data to another administrator without hindrance from us, if the processing takes place:

  • on the basis of consent or on the basis of a contract; and

  • in an automated way.

By exercising the right to transfer data, the data subject has the right to request that personal data is sent by us directly to another administrator, if it is technically possible. This right can not adversely affect the rights and freedoms of others.

The right to object

The data subject has the right to object at any time - for reasons related to their particular situation - to the processing of their personal data based on art. 6 par. 1 point f) (legitimate interest of the administrator), including profiling. We may no longer process such personal data unless we prove that there are legally valid grounds for processing that override the interests, rights and freedoms of the data subject, or the grounds for determining, investigating or defending claims.

Also if the data subject complains against processing for direct marketing purposes (including profiling for marketing purposes), personal data may no longer be processed for such purposes.

Automated decisions, including profiling

The data subject has the right not to be subject to a decision which is based solely on automated processing, including profiling, and has legal effects or substantially affects the person.

The law does not apply if this decision:

  • it is necessary to conclude or perform the contract between the data subject and us;

  • it is authorized by Union law or the law of the Republic of Poland and provides for appropriate measures to protect the rights, freedoms and legitimate interests of the data subject; or

  • is based on the explicit consent of the data subject.

8. Server logs

The internal logs of the Service server events that automatically record the requests of the parties submitted, when the Customers use the Service. internal logs of the Service server events contain a party’s request submitted by the user, IP address, web browser type, language of web browser, date and time of the request, and at least one “cookie” file, which can unambiguously identify the User’s web browser.

The data collected in the system logs is used by us in order to administer the Service. The data is not given to the benefit of the third-party entities, excluding the circumstances described in this document.

With regard to using the Service by the Users, we can automatically collect and record in the server logs the technical details in respect of a manner of using the services, requests related to rendering electronic services submitted by the User, IP address and technical data about operating of the Service with regard to the acts performed by the User. In particular it refers to the information about beginning, finishing and a scope of each use of the service rendered by electronic means. We may also collect information, in order to store them locally on the User’s device, using a memory mechanism of the web browser.

9. Cache memory

While rendering the services to the benefit of the Users, we may automatically use the cache memory of the web browser, application or the User’s device. This usage consists in storing data in the web browser memory installed in the User’s device. Within a frame of a local memory, it is possible to store data on an intersessional basis, i.e. between the subsequent User’s sessions. The purpose to use the cache memory is accelerating the usage of the Service, by eliminating a situation, in which the same data is many times taken from the Service, what loads the User’s Internet connection.

10. Geolocation

We or the third-party entities with the intermediary of the cookie files administered by them, may use a geolocation functionality, which consists in collecting and processing information about the User’s place of residence. For this purpose, it may be processed the following data: IP number, from a GPS sensor, from a Wi-Fi point or from the base transceiver station of the mobile network.

11. Pixel tag

We or the third-party entities with the intermediary of the cookie files administered by them, may use a pixel tag functionality. These are the elements published in the digital contents and they enable to register information, for example about the User’s activity on the web site.

12. Cookie files and profiling - introduction

While rendering services to the benefit of the Users, we use professional technologies in order to collect and record information, such as cookie files. These are the commonly used, small files that contain a character string, which are submitted and recorded on the end device (for example, on a PC, laptop, tablet, smartphone) used by the User while visiting the Service by him/her. This information is submitted to a storage of web browser, which sends it back during the subsequent visits of the concerned web site. The cookie files contain information necessary to use properly the Service. The most often they contain a name of the web site, from which they origin, duration of storing them on the end device and a unique number. The external entities, mentioned in par. 6 of the the Privacy and Cookie Files Policy may also have an access to data from the cookie files.

We may use cookies to learn about the preferences of people using our website. For example, we can analyze the frequency of their visits. Thanks to this, we can better adapt to expectations, eg by displaying ads tailored to the needs and preferences of specific recipients or those who have previously visited our website. No consent to the use of these cookies will result in excluding the use of such ads.

13. A basis for processing cookie files

The consent to the processing of cookies may take place:

  • by using a button containing a statement of consent to the processing of cookies or confirmation of familiarization with its terms,

  • by means of software settings installed in the telecommunications User's use the end device,

  • using the configuration of the service used by the User.

This consent may be withdrawn at any time, in a free of charge manner and described in the section on cookie management.

14. Which cookie files are used by us?

We may categorise the cookie files considering three methods of their breakdown.

In terms of the objectives of using the cookie files, we distinguish three categories of them:

  • necessary cookie files – these files allow for a correct operation of the Service and its functionalities, which the User wants to use, e.g. authorisation cookie files. It is impossible to use the Service without recording them on the user’s device,

  • functional cookie files – the files that enable to memorise the settings chosen by the User and adjusting them to his/her needs and preferences, e.g. within a scope of the selected language, font size, outline of the web site. They enable the Service Provider to improve the functionality and performance of the web site. Without recording them on the user’s device, using the Service may be restricted,

  • business cookie files – this category includes, e.g. advertising cookie files. They enable to adapt the advertisements displayed in the Service or outside it to the User’s preferences. Without recording them on the user’s device, using the concerned functionalities of the Service may be restricted.

In terms of a duration of their validity, we distinguish two categories of cookie files:

  • session cookie files – that exist to an end of the concerned User’s session,

  • persistent cookie files – that exist after an end of the User’s session.

In terms of the entity, which administers cookie files, we distinguish:

  • cookie files of the Service Provider,

  • cookie files of the third-party entities.

15. Cookie files of the Service Provider

The cookie files of the Service Provider enable to recognise the User’s device and display the Service web site adapted to his/her individual expectations therefore using its functionalities becomes easier and more pleasant. Thanks to recording these files on the User’s device it is possible, for instance to remember the data for signing in, maintaining a session after signing in, remembering the chosen goods or services or adapting to the User’s preferences with regard to, e.g. content outline, language or its colour.

16. Cookie files of third-party entities

The Service provider may use the cookie files used by Google Inc. 1600 Amphitheatre Pkwy, Mountain View, CA 94043, U.S.A. within a frame of the following services:

  • Google AdWords – enable to conduct and evaluate quality of the advertising companies, realised using the Google Adwords service.

  • Google Analytics – enable to evaluate quality of the advertising companies, realised using the Google Adwords service, as well as to research behaviours and traffic of the Users and draw up traffic statistics.

  • Google Maps – enable to store data about the Customer, which allow for using the map functionalities available within a frame of the Google Maps service. Google Inc. may trace a location of the User.

  • Google+ – enable to join a User’s account in the Google + service with the Service account, if only the Service Provider makes available this functionality. These files can be also used to process the User’s activities in the external social media services. Processing of these activities may be of public nature.

  • YouTube – enable to store data about the Customer, which allow for using the YouTube service. Google Inc. may trace playing movies by the User.

The Service Provider may use the cookie files, used by:

  • Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA,

  • Twitter Inc., 1355 Market Street, Suite 900, USA.

These files may be used in order to join the User’s accounts: in the external social media services with the Service account if only the Service Provider makes available this functionality. These files can be also used to process the User’s activities in the external social media services. Processing of these activities may be of public nature.

Using the cookie files of the third-party entities is a subject of the privacy policy or the cookie files policy, applied by these entities.

17. Managing cookie files and the other information

The most often the default settings of the web browser permit for placing the cookie files and the other information in the end device. If the User does not agree to record these files, it is necessary to modify appropriately the web browser settings. It is possible to disable recording for all connections from the concerned web browser or the specified web site, and also to remove them. A manner of managing the files depends on the used software. The valid rules of managing the files can be found in the settings of the used web browser.

The consent to process cookie files is voluntary. Nevertheless, you should remember that the restrictions within a scope of using them may hinder or make impossible to use a part of the Service functionalities.

18. Referrals to the other web sites or software

The Service may include the referrals to the other web sites or software. We disclaim any responsibility and liability for the applicable rules of adhering to the privacy and cookie files policy applicable on these web sites or in this software. We recommend to read the privacy policy and cookie files policy of these web sites or software after visiting them or prior to their installation.

19. Amendments to the Privacy and Cookie Files Policy

We reserve a right to amend this Privacy and Cookie Files Policy. In such a case, we will publish its updated version in this location.

20. Contact and reports

We continuously make every effort to process the User’s personal data and cookie files while observing the highest standards. Therefore, we maintain an implemented immediate reaction system in respect of the situations when these standards are in danger. In the case of identifying hazards, to which they are exposed or when they are violated, please contact us without undue delay using our contact data provided below:

  • 14 Krzywińska Street, Suite 4
  • 03-324 Warsaw, Poland

We are willing to familiarise with all feedback. Therefore, in the case of any inquires, requests or doubts connected with processing the personal data or cookie files, please do not hesitate to contact us.