WEB SITE https://mogilskamlyny.com
I. GENERAL PROVISIONS
1. The Administrator of personal data collected via the Website or other communication with Website User (e.g. related social media) is NOHO INVESTMENT Spółka z ograniczoną odpowiedzialnością Spółka komandytowa with its registered office in Kraków at 25 Armii Krajowej street, 30-150 Kraków, KRS: 0000796143, TIN: 6772445633, REGON number: 383953039
2. Regarding the processing of personal data you can contact the Administrator: email: email@example.com
II. SCOPE OF PERSONAL DATA PROCESSING
1. The following personal data is processed as part of the functioning of the website:
a) Data recorded in form of cookies and server logs.
b) Data obtained by the Administrator through social media
III. PURPOSE AND LEGAL BASIS OF PERSONAL DATA PROCESSING
1. The purposes of data processing include:
a) Enabling Users to use the Website,
b) To enable browsing the information made available on the Website,
c) To create registers and records connected with the obligations under the RODO,
d) To administer the proper operation of the Website,
e) For analytical and statistical purposes – in order to improve the operation of the website and its individual elements,
f) Conducting permitted marketing activities towards Users,
g) To enable Users to contact the Administrator of personal data through social media and to interact with the Administrator’s profiles on portals such as Facebook, Instagram and Linkedin.
2. The base for processing include:
a) Consent of the person to whom theses data concern – Article 6 section 1 let. a RODO,
b) The legitimate interest of the Administrator consisting of:
IV. DATA COLLECTION
V. RECIPIENTS OF PERSONAL DATA
1. Recipients of personal data processed within the website and related social media may be:
a) Entities related to the Administrator by capital or personal relationship,
b) Entities rendering services to the Administrator in the field of hosting, website maintenance, provision of additional software for the website or similar services,
c) Entities providing legal and accounting services to the Administrator.
2. If such an obligation arises from universally applicable law or from the decision of a competent authority, and if person of these data submits such a request, the Administrator may make his/her personal data available to competent public authorities.
VI. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
a.i.1. In connection with the operation of the Website the Administrator may use technology
and popular services offered, among others, by Facebook Inc. company which is based outside the European Union – and under the provisions of the RODO it is treated as a third country entity.
a.i.2. RODO limits the possibility of transferring personal data to third countries, due to the fact that in this country there may not be provisions guaranteeing a sufficient level of protection of personal data of European Union citizens due to the lack of European law application. In this case, each administrator is required to determine the legal basis for such transfer.
a.i.3. Facebook Inc. company declares to apply an adequate level of personal data security (compliance of the processing of personal data with RODO).
a.i.4. The Administrator shall at all times give you further information concerning the transfer of data outside the European Economic Area. The User has the right to obtain a copy of data transferred to a third country.
VII. DURATION OF DATA STORAGE
1. Personal Data shall be stored for the following periods:
a) For personal data processed on the basis of consent, until the consent is withdrawn or the purpose of the processing is achieved.
b) Data processed on the basis of the Administrator’s legitimate interest – until effective lodging of an objection or achievement of the purpose of processing, however, no longer than 5 years, counted from the end of the year in which the Administrator started processing the personal data.
c) Data processed for analytical purposes and administration of the website – until the expiry of the usefulness or validity of the data.
2. If the data subject requests the exercise of the right to be forgotten, such request shall be considered individually by the Administrator.
VIII. RIGHTS OF PEOPLE TO WHOM THESE DATA CONCERN
1. Users are authorized to exercise their rights under the RODO in relation to the processing of personal data concerning the User, in particular:
a) The right to access and obtain a copy of data,
b) The right to request rectification or completion of personal data,
c) The right to demand erasure – the data subject may demand erasure of his/her personal data if he/she considers that there are no legal basis for the Administrator to process his/her personal data,
d) The right to restrict the processing of personal data – the data subject may demand that the Administrator restrict the processing of his/her personal data only to the storage thereof or to the performance of activities on them as agreed upon with him/her, if the data are incorrect or processed without a legal basis, or the data subject does not want them erased because of the necessity to retain the data to establish, assert or defend claims, or for the duration of the determination of the objection to the processing of personal data.
e) The right to object to the processing of personal data:
Processing of personal data for direct marketing purposes: The person to whom these data concern, shall have the right to object to the processing of personal data for direct marketing purposes. The use of this right shall result in the situation where the Administrator ceasing to process the personal data for such purposes.
Objection on grounds of special situation: The person to whom these data concern has the right to object to the processing of his or her personal data on the basis of a legitimate interest for purposes other than direct marketing. The objection shall then specify the specific situation of the data subject which justifies the request to cease processing of personal data. The Administrator shall cease processing personal data for these purposes, unless the administrator demonstrates that the basis for further processing override the rights of the data subject, or that the data are necessary for the establishment, exercise or defence of claims.
(f) Right to data portability – The data subject shall have the right to obtain
a structured, commonly used and machine-readable format the personal data concerning him or her which were provided to the Administrator on the basis of the consent granted. The data subject may instruct the Administrator to send the data directly to another entity.
The User may exercise his/her right by sending a message to the following email address: firstname.lastname@example.org
IX. RIGHT TO LODGE A COMPLAINT TO THE SUPERVISORY AUTHORITY
A user who believes that his or her personal data is being processed unlawfully may lodge a complaint to the President of the Office for Personal Data Protection (address: 2 Stawki street, 00-193 Warszawa).
X. CONSENT TO PERSONAL DATA PROCESSING AND ITS WITHDRAWAL
Where personal data is processed on the basis of consent given, the person to whom these data concern may withdraw his or her consent to the processing of personal data at any time. The withdrawal of consent shall not affect the lawfulness of data processing carried out before its withdrawal.
The User may exercise his/her right by sending a message to the following email address: email@example.com
XI. NECESSITY OF PROVIDING PERSONAL DATA
Providing personal data is voluntary, however, it is necessary if the data subject wishes to use or obtain information on the services offered within the enterprise run by the Administrator via social media.
XII. COOKIES AND SERVER LOGS
2. When you reconnect to the Website, the website recognizes the device on which the page is opened. The files can be read by the system used by the Administrator, as well as by the service providers used in the creation of the Website.
3. Some cookies are anonymous, which makes it impossible to identify the user without additional information.
5. Cookies used in the operation of the Website have the following functions:
a.i.1 .a) session status – cookies carry, among other things, information about how visitors use the Website, such as which subpages they view most often. They also make it possible to identify any errors that are displayed. Cookies used to save the so-called “session status” – so they support the improvement of services and they increase sites browsing comfort;
a.i.1.b) creation of statistics – cookies are used to analyze how users use the Website (how many open the website, how long they stay on it, which content arouses most interest, etc.). This allows us to continuously improve the Website and adapt its operation to the preferences of users.
6. If you do not wish cookies to be used when viewing the Website, please change the settings in your Internet browser as follows:
a) completely block the automatic handling of cookies, or
b) request notification each time cookies are placed on your device. The settings can be changed at any time.
8. Some events triggered by persons using the Website and information about them are recorded in the form of server logs. Data saved in this way are used only for proper administration of the Website, ensuring its proper operation and uninterrupted performance of its various functionalities.
9. The following information may be saved as server logs:
a) brand and model of the device on which the Website is opened;
b) hardware identifier;
c) type and version of the operating system
d) date and time of login,
e) IP address of the device.
10. Logs of individual user actions may also be stored in form of logins. In this case, the logs are available in tools designed to handle individual functionalities of the Application.
11. The data indicated in paragraph 9 above are not associated with specific users, and their use only covers the activities indicated in paragraph 8 above.
XIII. AUTOMATED DECISION-MAKING AND PROFILING
As part of the operation of the Website, the Administrator does not use mechanisms in the field of automated decision-making, as well as profiling.
XIV. PROCESSING OF DATA IN SOCIAL MEDIA
1. The Administrator uses social media to promote the services provided, including portals such as Facebook, Instagram and Linkedin.
2. The Administrators indicated in item 1 of social networking sites record the behavior of their users using, among others, cookies and other related technologies, including behavior involving interaction with fan pages / profiles of the Administrator of personal data.
3. The Administrator informs that the data collected through facebook.com and instagram.com are subject to co-management by the Administrator and the company Facebook Ireland Ltd. – as European branch of Facebook Inc. responsible for Facebook.com operations in the European Union.
4. The Administrator informs that the data collected via linkedin.com are subject to co-management by the Administrator and the LinkedIn Ireland Unlimited Company.
5. The scope of processing personal data by Facebook.com, a platform on which the Administrator has its fanpage, has been described
6. The scope of processing of personal data by instagram.com, the platform on which the Personal Data Administrator has its fanpage can be found at: https://www.facebook.com/help/instagram/155833707900388
7. The scope of processing of personal data by instagram.com, the platform on which the Personal Data Administrator has its profile can be found at: https://pl.linkedin.com/legal/privacy-policy
8. As part of the use of the aforementioned portals, the Personal Data Administrator has access to the following Users’ personal data:
a) The User’s name or surname,
b) User’s profile photo,
c) Content of the Administrator’s correspondence with the User,
d) Information about liking the fanpage/profile,
e) Information about User activity on the fanpage/interactions with the Administrator’s profile,
f) Content of comments and posts posted on the fanpage/profile by the User,
g) Statistical data (general) generated by the operator of the aforementioned services concerning interests, demographic data (age, gender), general data on user location (region).
9. The personal data Administrator processes personal data of the users of the above mentioned portals
for the following purposes:
a) To enable User to use the fanpage/view the profile,
b) To share posts and conversations in the comments published on the fanpage/profile,
c) To allow the User to contact the Administrator of the personal data,
d) To conduct investigations, to establish, assert and defend potential claims,
e) To use statistics provided by the above-mentioned portals concerning the display of posts, their range, the number of interactions, demographic data concerning the persons observing the fanpage/profile, which data is collected on the basis of User activity on the fanpage/interaction with the Administrator’s profile.
f) To enable the Administrator to gain contacts to people interested in the Administrator’s offer and activity, using the Facebook Lead Ads tool,
g) To carry out marketing activities via fanpage, including informing
about the Administrator’s activities and products offered, displaying posts, as well as using Facebook Lead Ads.
10. Personal data of users of the above mentioned portals are processed on the following bases
•a) In terms of enabling Users to use the fanpage/interact with the profile – on the basis of Article 6 section 1(f) RODO – in the Administrator’s legitimate interest consisting in facilitating the use of the services offered,
In the scope of sharing posts, discussion in comments and contact with the Users who have liked the fanpage/profile – on the basis of Article 6 section 1(f) RODO i.e. on the basis of the Administrator’s legitimate interest which is the need to ensure contact with the Administrator and the exchange of information between them and the users,
c) Within the scope of obtaining by the Administrator of contacts’ personal data by means of Facebook Lead Ads – on the basis of Article 6 section 1(f) RODO i.e. on the basis of a legitimate interest of the Administrator of personal data, which constitutes the right to contact the persons interested in the offer and to conduct marketing activities towards them,
d) Within the scope of investigation, establishment, investigation and defence of potential claims – on the basis of Article 6 section 1(c) and (f) of the RODO, i.e. in the performance of the obligation arising from Article 8 of the Act on Provision of Electronic Services and on the basis of a legitimate interest of the Personal Data Administrator consisting in the establishment, investigation and defence of claims in connection with the fanpage/profile.
e) With regard to the use of statistical data – on the basis of Article 6 section 1(f) RODO i.e. on the basis of a legitimate interest of the Administrator of personal data, which is to facilitate the use of services, improve their quality and functionality. In connection with the principles of running the aforementioned portals, the User is aware of the statistical activities conducted towards him or her and the disclosure of their results to the Personal Data Administrator.
f) In the scope of marketing activities carried out by means of the fanpage/profile – on the basis of Article 6 section 1(f) RODO i.e. on the basis of a legitimate interest of the Personal Data Administrator, which is the marketing relating to the Administrator’s enterprise.
11. Personal data collected and processed within the operation of the fanpage/profile are stored by the Personal Data Administrator no longer than necessary to carry out the various purposes of processing, whereby:
a) Data concerning likes, published posts and persons observing the fanpage/profile – until the User revokes the liking or deletes the post,
b) Data related to the contact with the User – until the expiration of the period of limitation of possible claims related to the content of the correspondence, but no longer than 3 years.
c) Data processed in connection with service usage statistics – until the purposes of personal data processing are fulfilled, however, no longer than 3 years.
d) Data processed in the establishment, investigation or defence of claims – until the completion of proceedings concerning these claims.
12. Using the fanpage / interacting with the profile of the Administrator, the User does not remain anonymous. In particular, information about likes the content of posts, comments and other information published by Users, as well as information about persons observing the fanpage (for facebook and instagram portals) are open to other users of the above mentioned portals,
XV. FINAL PROVISIONS
1. To the extent not covered by this Policy shall be applicable the relevant generally applicable provisions, in particular concerning the personal data scope.
2. The User shall be informed of any amendments to this Policy by publication of the new text of the Policy on the Website and by displaying a message upon entering the Website.
3. This Policy is effective from the 1st of December 2021.