Privacy Policy

The following Privacy Policy sets out the rules for storing and accessing data on Users’ Devices using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users’ personal data provided by them personally and voluntarily through the tools available in the Service.

§1 Definitions

1. Service - the website operating at https://bratpol.pl/
2. External Service - websites of partners, service providers or service recipients cooperating with the Administrator
3. Service / Data Administrator - The Administrator of the Service and the Data Administrator (hereinafter: the Administrator) is PH BRATPOL, conducting business at: Partyzantów 46/203, 81-423 Gdynia, providing electronic services through the Service
4. User - a natural person for whom the Administrator provides electronic services through the Service.
5. Device - an electronic device together with software, through which the User accesses the Service
6. Cookies - text data collected in the form of files placed on the User’s Device
7. GDPR - 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 (General Data Protection Regulation)
8. Personal data - means information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified directly or indirectly, in particular by reference to an identifier such as a name and surname, identification number, location data, online identifier or one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
9. Processing - means an operation or set of operations performed on personal data or sets of personal data, whether by automated or non-automated means, such as collecting, recording, organizing, structuring, storing, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making available, aligning or combining, restricting, erasing or destroying;
10. Restriction of processing - means marking stored personal data with the aim of limiting their processing in the future
11. Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements
12. Consent - the consent of the data subject means a freely given, specific, informed and unambiguous indication of the data subject’s wishes by which, by a statement or clear affirmative action, the data subject agrees to the processing of personal data concerning them
13. Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to personal data transmitted, stored or otherwise processed
14. Pseudonymization - means the processing of personal data in such a manner that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures preventing it from being attributed to an identified or identifiable natural person
15. Anonymization - Data anonymization is an irreversible process of operations on data that destroys / overwrites "personal data", preventing the identification of, or linking of, a given record to a specific user or natural person.

§2 Data Protection Officer

1. Pursuant to Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.
2. In matters concerning data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

1. Internal cookies - files placed and read from the User’s Device by the Service’s ICT system
2. External cookies - files placed and read from the User’s Device by ICT systems of External Services. Scripts of External Services that may place Cookies on Users’ Devices have been knowingly placed in the Service through scripts and services made available and installed in the Service
3. Session cookies - files placed and read from the User’s Device by the Service during a single session of a given Device. After the session ends, the files are deleted from the User’s Device.
4. Persistent cookies - files placed and read from the User’s Device by the Service until they are manually deleted. The files are not deleted automatically after the Device session ends unless the User’s Device configuration is set to delete Cookies after the Device session ends.

§4 Data Storage Security

1. Cookie storage and reading mechanisms - The mechanisms for storing, reading and exchanging data between Cookies saved on the User’s Device and the Service are carried out through the built-in mechanisms of web browsers and do not allow the retrieval of other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, Trojan horses and other worms to the User’s Device is also practically impossible.
2. Internal cookies - the Cookies used by the Administrator are safe for Users’ Devices and do not contain scripts, content or information that could threaten the security of personal data or the security of the Device used by the User.
3. External cookies - The Administrator takes all possible actions to verify and select service partners in terms of Users’ security. The Administrator selects well-known, large partners with global public trust for cooperation. However, the Administrator does not have full control over the content of Cookies originating from external partners. To the extent permitted by law, the Administrator is not responsible for the security of Cookies, their content or their lawful use under the license by Scripts installed in the Service and originating from External Services. The list of partners is provided later in this Privacy Policy.
4. Cookie control
   1. The User may at any time independently change settings concerning the saving, deleting and access to data stored in Cookies by this website using the built-in cookie management module.
   2. At the same time, the user may use the global disabling of cookies in the most popular browsers:
      • Managing cookies in the Chrome browser
      • Managing cookies in the Opera browser
      • Managing cookies in the FireFox browser
      • Managing cookies in the Edge browser
      • Managing cookies in the Safari browser
      • Managing cookies in the Internet Explorer 11 browser
   3. The User may at any time delete all Cookies saved so far using the tools of the User’s Device through which the User uses the Service.
5. User-side risks - The Administrator applies all possible technical measures to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Administrator is not responsible for the interception of this data, impersonation of the User’s session or deletion of such data as a result of the User’s conscious or unconscious activity, viruses, Trojan horses and other spyware with which the User’s Device may be or may have been infected. In order to protect themselves against these threats, Users should follow the recommendations for safe use of the Internet.
6. Storage of personal data - The Administrator ensures that every effort is made to ensure that personal data voluntarily entered by Users is secure, that access to it is limited and carried out in accordance with its purpose and processing objectives. The Administrator also ensures that every effort is made to protect the data held against loss by applying appropriate physical and organizational safeguards.

§5 Purposes for Which Cookies Are Used

1. Improving and facilitating access to the Service
2. Personalizing the Service for Users
3. Marketing, remarketing on external services
4. Keeping statistics (users, number of visits, types of devices, connection, etc.)
5. Providing multimedia services
6. Providing social media services

§6 Purposes of Personal Data Processing

1. Personal data voluntarily provided by Users is processed for one of the following purposes:
   1. Provision of electronic services:
      • Newsletter service (including sending advertising content with consent)
      • Services for sharing information about content placed in the Service on social media services or other websites.
   2. Communication between the Administrator and Users in matters related to the Service and data protection
   3. Ensuring the legitimate interest of the Administrator
2. Data about Users collected anonymously and automatically is processed for one of the following purposes:
   1. Keeping statistics
   2. Remarketing
   3. Ensuring the legitimate interest of the Administrator

§7 Cookies of External Services

1. The Administrator uses JavaScript scripts and web components of partners in the Service, which may place their own cookies on the User’s Device. Please remember that in your browser settings you can decide which cookies may be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

   1. Multimedia services:
      • YouTube
      • Vimeo
   2. Social / combined services:
      (Registration, Login, content sharing, communication, etc.)
      • Twitter
      • Facebook
      • Google+
      • LinkedIn
   3. Newsletter services:
      • GetResponse
   4. Statistics:
      • Google Analytics
      • Ahrefs
   5. Other services:
      • Google Maps
2. Services provided by third parties are beyond the Administrator’s control. These entities may change their terms of service, privacy policies, purpose of data processing and methods of using cookies at any time.

§8 Types of Data Collected

1. The Service collects data about Users. Some data is collected automatically and anonymously, and some data is personal data provided voluntarily by Users when signing up for individual services offered by the Service.
   1. Anonymous data collected automatically:
      • IP address
      • Browser type
      • Screen resolution
      • Approximate location
      • Subpages of the service opened
      • Time spent on the relevant subpage of the service
      • Type of operating system
      • Address of the previous subpage
      • Referring page address
      • Browser language
      • Internet connection speed
      • Internet service provider
   2. Data collected during registration:
      • First name / surname / nickname
      • E-mail address
      • Phone number
      • IP address (collected automatically)
      • Tax Identification Number (NIP)
      • National Court Register Number (KRS)
      • REGON number
   3. Data collected when subscribing to the Newsletter service
      • First name / surname / nickname
      • E-mail address
      • IP address (collected automatically)
2. Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to the provider of statistical services.

§9 Access to Personal Data by Third Parties

1. As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided is not transferred or resold to third parties.
2. Access to data (most often on the basis of a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to operate the service, i.e.:
   1. Hosting companies providing hosting or related services to the Administrator
   2. Companies through which the Newsletter service is provided
   3. IT service and support companies performing maintenance or responsible for maintaining IT infrastructure
   4. Companies responsible for the Administrator’s accounting (in the case of using paid Administrator Services)
   5. Companies responsible for delivering physical products to the User (postal / courier services if information needs to be sent in writing)
3. Entrusting the processing of personal data:
   1. Newsletter - In order to provide the Newsletter service, the Administrator uses the services of a third party - the GetResponse service. Data entered in the newsletter subscription form is transferred to, stored and processed in the external service of this provider.
      Please note that the indicated partner may modify the indicated privacy policy without the Administrator’s consent.
   2. Hosting, VPS or Dedicated Server Services - In order to operate the service, the Administrator uses the services of an external hosting, VPS or Dedicated Server provider - ABHOST Sp. z o.o. All data collected and processed in the service is stored and processed in the provider’s infrastructure located within the borders of the European Union. Data may be accessed as a result of maintenance work carried out by the provider’s personnel. Access to this data is regulated by the agreement concluded between the Administrator and the Service Provider.
   3. Website maintenance services - In order to maintain the service, the Administrator uses the services of an external service provider - ABHOST Sp. z o.o. . The personnel of the indicated entity have access to data entered by users during registration and editing of the user account and/or data concerning the Newsletter service. Access to this data is regulated by the agreement concluded between the Administrator and the Service Provider.
4. Transfer of personal data:
   1. Accounting Services - In the event of a transaction, some personal data of natural persons or data of natural persons conducting business activity is transferred to the entity providing accounting services to the Administrator. The transfer of this data is regulated by the Act and the agreement concluded between the Administrator and the Service Provider.
   2. Courier Services - In the event of a transaction that requires the transfer of the item to which the transaction relates by post or courier, some personal data of natural persons or data of natural persons conducting business activity is transferred to the entity providing postal / courier services to the Administrator, selected by the User. The transfer of this data is regulated by the agreement concluded between the Administrator and the Service Provider.

§10 Method of Processing Personal Data

1. Personal data voluntarily provided by Users:
   1. Personal data will not be transferred outside the European Union unless it has been published as a result of the User’s individual action (e.g. entering a comment or post), which will make the data available to every person visiting the service.
   2. Personal data will not be used for automated decision-making (profiling).
   3. Personal data will not be resold to third parties.
2. Anonymous data (without personal data) collected automatically:
   1. Anonymous data (without personal data) will be transferred outside the European Union.
   2. Anonymous data (without personal data) will not be used for automated decision-making (profiling).
   3. Anonymous data (without personal data) will not be resold to third parties.

§11 Legal Bases for Personal Data Processing

1. The Service collects and processes Users’ data on the basis of:
   1. 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 (General Data Protection Regulation)
      • Art. 6 sec. 1 lit. a 
        the data subject has given consent to the processing of their personal data for one or more specific purposes
      • Art. 6 sec. 1 lit. b
        processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract
      • Art. 6 sec. 1 lit. f
        processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
   2. Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
   3. Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)
   4. Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24, item 83)

§12 Period of Personal Data Processing

1. Personal data voluntarily provided by Users:

   As a rule, the indicated personal data is stored only for the period during which the Administrator provides the Service within the Service. It is deleted or anonymized within 30 days from the end of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

   An exception is a situation that requires securing legally justified purposes for further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time the User requests its deletion, for no longer than 3 years in the event of a breach or suspected breach of the service regulations by the User

2. Anonymous data (without personal data) collected automatically:

   Anonymous statistical data, which does not constitute personal data, is stored by the Administrator for the purpose of keeping service statistics for an indefinite period

§13 Users’ Rights Related to Personal Data Processing

1. The Service collects and processes Users’ data on the basis of:
   1. Right of access to personal data - Users have the right to obtain access to their personal data, exercised upon a request submitted to the Administrator
   2. Right to rectify personal data - Users have the right to request that the Administrator immediately rectify personal data that is incorrect and/or complete incomplete personal data, exercised upon a request submitted to the Administrator
   3. Right to erase personal data - Users have the right to request that the Administrator immediately erase personal data, exercised upon a request submitted to the Administrator. In the case of user accounts, data deletion consists of anonymizing data enabling the identification of the User. The Administrator reserves the right to suspend the execution of a data deletion request in order to protect the Administrator’s legitimate interest (e.g. when the User has violated the Terms and Conditions or the data has been obtained as a result of correspondence).
      In the case of the Newsletter service, the User may independently delete their personal data using the link included in each e-mail message sent.
   4. Right to restrict the processing of personal data - Users have the right to restrict the processing of personal data in the cases specified in Art. 18 of the GDPR, including questioning the accuracy of personal data, exercised upon a request submitted to the Administrator
   5. Right to data portability - Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used and machine-readable format, exercised upon a request submitted to the Administrator
   6. Right to object to the processing of personal data - Users have the right to object to the processing of their personal data in the cases specified in Art. 21 of the GDPR, exercised upon a request submitted to the Administrator
   7. Right to lodge a complaint - Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.

§14 Contact with the Administrator

1. The Administrator can be contacted in one of the following ways
   1. Postal address - Partyzantów 46/203, 81-423 Gdynia
   2. E-mail address - [email protected]
   3. Phone call - +48 721 318 500
   4. Contact details - available at: https://bratpol.pl/en/contact

§15 Service Requirements

1. Restricting the saving of and access to Cookies on the User’s Device may cause some functions of the Service to operate incorrectly.
2. The Administrator bears no responsibility for improperly functioning Service features if the User restricts in any way the possibility of saving and reading Cookies.

§16 External Links

1. The Service - articles, posts, entries or Users’ comments - may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated by them may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for content located outside the Service.

§17 Changes to the Privacy Policy

1. The Administrator reserves the right to make any changes to this Privacy Policy without the need to inform Users in the scope of the application and use of anonymous data or the use of Cookies.
2. The Administrator reserves the right to make any changes to this Privacy Policy in the scope of Personal Data processing, about which Users who have user accounts or are subscribed to the newsletter service will be informed by e-mail within 7 days of the change to the provisions. Continued use of the services means that the User has read and accepted the introduced changes to the Privacy Policy. If the User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
3. Changes introduced to the Privacy Policy will be published on this subpage of the Service.
4. Introduced changes enter into force upon their publication.