PRIVACY POLICY
1. This Privacy Policy outlines the rules for processing personal data collected via the website https://gobagz.net (hereinafter referred to as the „Website„).
2. The owner of the Website and the Data Controller is PROMOTORZY TRADING SP. Z O.O. with its registered office in Warsaw (03-310), ul. Św. Jacka Odrowąża 15, registered in the National Court Register under the number KRS 0000422037, NIP: 524-27-51-528, REGON: 146139035, hereinafter referred to as PROMOTORZY TRADING SP. Z O.O.
3. The personal data collected by PROMOTORZY TRADING SP. Z O.O. via the Website are processed in accordance with the European Parliament and Council Regulation (EU) 2016/679 of 27 April 2016 on the protection of natural persons in relation to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as GDPR.
4. PROMOTORZY TRADING SP. Z O.O. makes every effort to respect the privacy of its customers visiting the Website.
1. Type of data processed, purpose, and legal basis
1. PROMOTORZY TRADING SP. Z O.O. collects information about individuals performing legal acts unrelated to their business activities, individuals conducting business or professional activities on their own behalf, and individuals representing legal entities or organizational units without legal personality that are granted legal capacity by law, hereinafter collectively referred to as „Customers.”
2. Personal data of Customers is collected in the following cases:
a) Newsletter subscription, for the performance of a contract for the provision of electronic services. Legal basis – consent of the data subject to the execution of a contract for the Newsletter service (Art. 6(1)(a) GDPR);
b) Use of the contact form service on the Website, for the performance of a contract for the provision of electronic services. Legal basis – necessity for the performance of a contract for the contact form service (Art. 6(1)(b) GDPR).
3. In the case of subscribing to the Newsletter, the Customer provides only their email address.
4. In the case of using the contact form service, the Customer provides the following data:
a) Email address;
b) Name.
5. When using the Website, additional information may be collected, including: the IP address assigned to the Customer’s computer or the external IP address of the Internet service provider, domain name, browser type, access time, and type of operating system.
6. Navigational data may also be collected from Customers, including information about links and references they click on or other activities performed on the Website. Legal basis – legitimate interest (Art. 6(1)(f) GDPR), aimed at facilitating the use of electronic services and improving their functionality.
7. In order to determine, pursue, and enforce claims, certain personal data provided by the Customer during the use of the Website’s functionality may be processed, such as: name, surname, data related to the use of services, if the claims arise from the way the Customer uses the services, and other data necessary to prove the existence of a claim, including the extent of damage incurred. Legal basis – legitimate interest (Art. 6(1)(f) GDPR), aimed at determining, pursuing, and enforcing claims and defending against claims in proceedings before courts and other public authorities.
8. PROMOTORZY TRADING SP. Z O.O. processes personal data, including name, surname, email address, as well as responses to survey questions and satisfaction surveys. Participation in such actions is voluntary. If the Customer does not wish to participate, they may inform PROMOTORZY TRADING SP. Z O.O. at any time as per Section 7, and PROMOTORZY TRADING SP. Z O.O. will block the relevant data. Legal basis – legitimate interest (Art. 6(1)(f) GDPR), aimed at improving the functionality of electronic services and evaluating customer satisfaction with the services provided.
2. Who will have access to the data and how long will it be stored
1. The Customer’s personal data is provided to service providers that PROMOTORZY TRADING SP. Z O.O. uses in relation to the operation of the Website. Depending on the contractual arrangements and circumstances, service providers either follow the instructions of PROMOTORZY TRADING SP. Z O.O. regarding the purposes and means of data processing (data processors) or determine the purposes and means of data processing themselves (data controllers).
a) Data processors: PROMOTORZY TRADING SP. Z O.O. uses providers that process personal data only on the instruction of PROMOTORZY TRADING SP. Z O.O. including those providing hosting services, accounting services, marketing systems, website traffic analysis systems, and systems for analyzing the effectiveness of marketing campaigns;
b) Data controllers: PROMOTORZY TRADING SP. Z O.O. uses providers that do not act solely on instructions and determine the purposes and means of using personal data themselves. These include electronic payment providers and banks.
2. Location: Service providers are based in Poland and other countries within the European Economic Area (EEA).
3. Personal data of Customers is stored:
a) If the basis for data processing is consent, the data will be processed by PROMOTORZY TRADING SP. Z O.O. as long as the consent is not withdrawn, and after withdrawal for a period corresponding to the limitation period for claims that PROMOTORZY TRADING SP. Z O.O. may raise and that may be raised against it. Unless otherwise specified by law, the limitation period is six years, and for claims related to periodic benefits or business activities – three years.
b) If the basis for data processing is the performance of a contract, the data will be processed by PROMOTORZY TRADING SP. Z O.O. for as long as necessary to perform the contract, and after that period for a time corresponding to the limitation period for claims. Unless otherwise specified by law, the limitation period is six years, and for claims related to periodic benefits or business activities – three years.
4. Navigational data may be used to provide better service to Customers, analyze statistical data, adapt the Website to Customer preferences, and administer the Website.
5. If the Customer subscribes to the Newsletter, PROMOTORZY TRADING SP. Z O.O. will send electronic messages to their email address with commercial information about promotions and new products available on the Website.
6. Upon request, PROMOTORZY TRADING SP. Z O.O. may disclose personal data to authorized state authorities, including organizational units of the Prosecutor’s Office, Police, the President of the Personal Data Protection Office, the President of the Office for Competition and Consumer Protection, or the President of the Office of Electronic Communications.
3. Cookies mechanism and IP address
1. The website gobagz.net uses small files known as cookies, which are stored on the device of the person visiting the website, provided that the browser allows it. A cookie typically contains the domain name it came from, its „expiry time”, and a randomly selected unique number identifying the cookie. The information collected via cookies helps to tailor the products offered by PROMOTORZY TRADING SP. Z O.O. to the individual preferences and real needs of the website visitors. It also enables the creation of general statistics regarding visits to the presented products on the website.
2. PROMOTORZY TRADING SP. Z O.O. uses two types of cookies:
a) Session cookies: These are deleted from the device’s memory when the browser session ends or when the computer is turned off. The session cookie mechanism does not allow the retrieval of any personal or confidential data from the customers’ computers.
b) Persistent cookies: These are stored in the device’s memory and remain there until they are deleted or they expire. The persistent cookie mechanism does not allow the retrieval of any personal or confidential data from customers’ computers.
3. PROMOTORZY TRADING SP. Z O.O. uses own cookies for the following purposes:
a) Authentication of the customer on the website and maintaining the session of the customer on the website,
b) Analysis, research, and audit of the website’s viewership, particularly to create anonymous statistics that help to understand how customers use the website, which enables improvements in its structure and content.
4. PROMOTORZY TRADING SP. Z O.O. uses third-party cookies for the following purposes:
a) To display a map showing the location of the PROMOTORZY TRADING SP. Z O.O. office via the maps.google.com service (administrator of third-party cookies: Google Inc., USA),
b) To collect general and anonymous statistical data via Google Analytics tools (administrator of third-party cookies: Google Inc., USA).
5. The cookie mechanism is secure for customers’ computers. Specifically, it is not possible for viruses or other unwanted or malicious software to enter customers’ computers through this mechanism. However, customers can limit or disable cookies in their browsers. If this option is used, access to the website will still be possible, except for functions that inherently require cookies.
6. Below is how customers can change the cookie settings in popular internet browsers:
a) Google Chrome and Chrome Mobile;
b) Facebook in-app Browser;
c) Internet Explorer;
d) Microsoft EDGE;
e) Mozilla Firefox;
f) Opera;
g) Safari and Safari Mobile;
h) Samsung Browser.
7. PROMOTORZY TRADING SP. Z O.O. may collect IP addresses of customers. An IP address is a number assigned to the customer’s computer by their internet service provider. The IP address allows access to the internet. In most cases, it is assigned dynamically, meaning it changes with each internet connection. The IP address is used by PROMOTORZY TRADING SP. Z O.O. for diagnosing technical problems with the server, creating statistical analyses (e.g., determining which regions have the most visits), for server administration and improvement, as well as for security purposes and potential identification of unauthorized automated browsing programs.
8. The website contains links to other websites. PROMOTORZY TRADING SP. Z O.O. is not responsible for the privacy policies applied on those websites.
4. Rights of data subjects
1. Right to Withdraw Consent – Legal basis: Article 7(3) GDPR
a) The customer has the right to withdraw any consent previously given to PROMOTORZY TRADING SP. Z O.O.
b) The withdrawal of consent takes effect from the moment it is withdrawn.
c) Withdrawing consent does not affect the legality of any processing that took place before the withdrawal.
d) Withdrawing consent does not entail any negative consequences for the customer, although it may prevent continued access to services or functionalities that PROMOTORZY TRADING SP. Z O.O. may provide only on the basis of consent.
2. Right to Object to Processing of Data – Legal basis: Article 21 GDPR
a) The customer has the right to object at any time to the processing of their personal data, including profiling, when PROMOTORZY TRADING SP. Z O.O. processes their data based on a legitimate interest, e.g., marketing of products and services, website usage statistics, and facilitating website navigation.
b) Opting out of marketing communications via email is considered an objection to the processing of personal data, including profiling, for marketing purposes.
c) If the objection is justified and PROMOTORZY TRADING SP. Z O.O. no longer has another legal basis to process the data, the customer’s personal data will be deleted.
3. Right to Erasure („Right to Be Forgotten”) – Legal basis: Article 17 GDPR
a) The customer has the right to request the deletion of all or some of their personal data.
b) The customer may request the deletion of personal data if:
– The data is no longer necessary for the purposes for which it was collected or processed.
– The customer has withdrawn their consent for processing based on consent.
– The customer has objected to processing for marketing purposes.
– The data is being processed unlawfully.
– The data must be deleted to comply with a legal obligation under EU or Member State law.
– The data was collected in connection with offering information society services.
c) Even if the customer requests the deletion of personal data, PROMOTORZY TRADING SP. Z O.O. may retain certain data as necessary for establishing, exercising, or defending legal claims, or to fulfill a legal obligation under EU or Member State law, such as customer name, email address, or mailing address for resolving complaints or claims regarding services or contracts.
4. Right to Restrict Processing of Data – Legal basis: Article 18 GDPR
a) The customer has the right to request the restriction of processing of their personal data. This restriction may prevent the use of certain functionalities or services that depend on the processing of the data in question.
b) The customer has the right to request a restriction of processing in the following cases:
– When the accuracy of the personal data is contested – the restriction applies until the accuracy is verified, not exceeding 7 days.
– When processing is unlawful, but the customer opts for restriction instead of deletion.
– When the personal data is no longer necessary for the purposes for which it was collected but is needed by the customer for the establishment, exercise, or defense of legal claims.
– When the customer has objected to the use of their data – the restriction applies while it is determined whether the legitimate interests of PROMOTORZY TRADING SP. Z O.O. override the customer’s rights.
5. Right of Access to Data – Legal basis: Article 15 GDPR
a) The customer has the right to obtain confirmation from the Administrator as to whether their personal data is being processed.
b) If personal data is being processed, the customer has the right to:
– Access their personal data.
– Obtain information on the purposes of processing, categories of processed data, recipients of the data, the planned retention period, or criteria used to determine the retention period.
– Know their rights under GDPR, the right to lodge a complaint with a supervisory authority, the source of the data, any automated decision-making, including profiling, and the safeguards in place regarding transfers outside the EU.
– Receive a copy of the personal data being processed.
6. Right to Rectify Data – Legal basis: Article 16 GDPR
a) The customer has the right to request the immediate correction of inaccurate personal data.
b) The customer also has the right to request the completion of incomplete personal data.
7. Right to Data Portability – Legal basis: Article 20 GDPR
a) The customer has the right to receive their personal data in a structured, commonly used, and machine-readable format and to transfer it to another data controller.
b) The customer may also request that their data be sent directly to another data controller if technically feasible.
8. Timeframe for Exercising Rights
– PROMOTORZY TRADING SP. Z O.O. will respond to any requests to exercise the above rights promptly, within one month of receiving the request. If the request is complex or if there are numerous requests, PROMOTORZY TRADING SP. Z O.O. may extend the response period by two additional months, informing the customer of the extension within one month from receiving the request.
9. Complaints and Inquiries
– The customer may lodge complaints, inquiries, or requests regarding the processing of their personal data directly with the Administrator.
– The customer also has the right to file a complaint with the President of the Personal Data Protection Office if they believe their rights under GDPR or other related laws have been violated.
5. Services tailored to preferences and interests (Profiling)
1. Profiling means any form of automated processing of Personal Data, which involves using Personal Data to evaluate certain personal aspects of an individual, in particular to analyze or predict aspects related to the effects of that individual’s work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movement.
2. Personal data of Clients may be processed in an automated manner (profiling), but this will not result in any legal consequences for them or otherwise significantly affect their situation.
3. The profiling of Personal Data by PROMOTORZY TRADING SP. Z O.O. involves processing Client data in both automated and manual ways, by using it to assess certain information about the Client, particularly to analyze or predict their personal preferences and interests.
4. In order to reach the Client with marketing communications outside the website, PROMOTORZY TRADING SP. Z O.O. uses services provided by external suppliers. These services involve displaying marketing messages on websites other than the gobagz.net website. For this purpose, external suppliers may install a relevant code or pixel to collect information about the Client’s activity on the website. Details regarding the use of cookies are provided in §3. The legal basis for processing is a legitimate interest (Article 6(1)(f) GDPR), which involves tailoring marketing messages to the Client’s preferences and interests.
5. To reach the Client with marketing communications via the website, PROMOTORZY TRADING SP. Z O.O. uses services provided by external suppliers. These services involve displaying marketing messages on the website. For this purpose, external suppliers may install a relevant code or pixel to collect information about the Client’s activity on the website. Details regarding the use of cookies are provided in §3. The legal basis for processing is a legitimate interest (Article 6(1)(f) GDPR), which involves tailoring marketing messages to the Client’s preferences and interests.
6. To reach the Client with marketing communications via the website, PROMOTORZY TRADING SP. Z O.O. uses its own cookies mechanisms to collect information about the Client’s activity on the website. Details regarding the use of cookies are provided in §3. The legal basis for processing is a legitimate interest (Article 6(1)(f) GDPR), which involves tailoring marketing messages to the Client’s preferences and interests.
6. Security management – passwords
1. PROMOTORZY TRADING SP. Z O.O. ensures secure and encrypted transmission of personal data within the Service. PROMOTORZY TRADING SP. Z O.O. uses an SSL certificate issued by one of the leading global companies specializing in data security and encryption of data transmitted over the Internet.
7. Changes to the Privacy Policy
1. The Privacy Policy may be subject to change, and PROMOTORZY TRADING SP. Z O.O. will notify Clients in advance, at least 7 days before the changes take effect.
2. Any questions regarding the Privacy Policy should be directed to: world@promotorzy.pl
