PRIVACY POLICY
1. This Privacy Policy outlines the principles for the processing of personal data collected through the website https://us.gobagz.net (hereinafter referred to as “the Website“).
2. The owner of the website us.gobagz.net and the Data Controller is PROMOTORZY TRADING SP. Z O.O. located in Warsaw (03-310), at ul. Św. Jacka Odrowąża 15, entered into the National Court Register (KRS) 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 us.gobagz.net website are processed in accordance with the European Parliament and Council Regulation (EU) 2016/679 of April 27, 2016, on the protection of individuals with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, GDPR).
4. PROMOTORZY TRADING SP. Z O.O. is committed to respecting the privacy of Customers visiting the us.gobagz.net website.
1. Types of data processed, purposes, and legal basis
1. PROMOTORZY TRADING SP. Z O.O. collects information about individuals who are performing legal actions unrelated to their business activity, individuals conducting business or professional activity on their own behalf, as well as individuals representing legal entities or organizational units without legal personality that are granted legal capacity by law, collectively referred to as “Clients.”
2. Personal data of Clients are collected in the following cases:
a) Newsletter subscription – for the performance of the contract, which involves providing an electronic service. Legal basis: consent of the data subject for the performance of the newsletter service contract (Art. 6(1)(a) GDPR);
b) Use of the contact form on the website us.gobagz.net – for the performance of an electronic service contract. Legal basis: necessity for the performance of the contact form service contract (Art. 6(1)(b) GDPR).
3. For the newsletter service, the Client only provides their email address.
4. For the contact form service, the Client provides the following data:
a) Email address;
b) Name.
5. While using the us.gobagz.net website, additional information may be collected, including: the IP address assigned to the Client’s computer or the external IP address of the Internet service provider, domain name, browser type, access time, and operating system type.
6. Navigation data may also be collected, including information about links and references the Client clicks on, or other actions taken on the us.gobagz.net website. Legal basis: legitimate interest (Art. 6(1)(f) GDPR), aiming to facilitate the use of the services provided electronically and to improve the functionality of those services.
7. In order to determine, pursue, and enforce claims, certain personal data provided by the Client during the use of functionalities on the us.gobagz.net website, such as: first name, last name, service usage data (if the claim arises from the way the Client uses the services), and other necessary data to prove the existence of the claim, including the extent of the damage, may be processed. Legal basis: legitimate interest (Art. 6(1)(f) GDPR), aimed at establishing, pursuing, and enforcing claims, as well as defending against claims in legal proceedings before courts and other public authorities.
8. PROMOTORZY TRADING SP. Z O.O. processes personal data including: first name, last name, email address, as well as responses to satisfaction survey questions and forms used for satisfaction research. Participation in such actions is voluntary. If the Client does not agree to participate, they may inform PROMOTORZY TRADING SP. Z O.O. at the address provided in §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 the electronic services provided and assessing customer satisfaction with the services provided.
2. Data sharing, retention period
1. Client personal data is shared with service providers that PROMOTORZY TRADING SP. Z O.O. uses in connection with the operation of the us.gobagz.net website. Service providers to whom personal data may be transferred either follow the instructions of PROMOTORZY TRADING SP. Z O.O. regarding the purposes and methods of processing the data (data processors), or independently determine the purposes and methods of processing (data controllers).
a) Data processors: PROMOTORZY TRADING SP. Z O.O. uses service providers who process personal data solely on the instructions of PROMOTORZY TRADING SP. Z O.O. These include, among others, hosting service providers, accounting services, marketing system providers, website traffic analysis systems, and campaign effectiveness analysis systems.
b) Data controllers: PROMOTORZY TRADING SP. Z O.O. uses service providers who do not act solely on the instructions and determine the purposes and methods of using Clients’ personal data. These service providers offer electronic payment and banking services.
2. Location: Service providers are located in Poland and other countries within the European Economic Area (EEA).
3. Client personal data is retained:
a) If the processing is based on consent, personal data will be processed by PROMOTORZY TRADING SP. Z O.O. as long as the consent is not withdrawn, and after withdrawal, for the period corresponding to the statute of limitations for claims that PROMOTORZY TRADING SP. Z O.O. may raise and those that may be raised against it. Unless specified otherwise by special provisions, the limitation period is six years, and for claims related to periodic benefits or business activity – three years.
b) If the processing is based on the performance of a contract, personal data will be processed by PROMOTORZY TRADING SP. Z O.O. as long as necessary to perform the contract, and after that, for the period corresponding to the statute of limitations for claims.
4. Navigation data may be used to provide better customer service, analyze statistical data, tailor the website to customer preferences, and administer the website.
5. If the Client subscribes to the Newsletter, PROMOTORZY TRADING SP. Z O.O. will send electronic messages containing commercial information about promotions and new products available on the website.
6. In the event of a request, PROMOTORZY TRADING SP. Z O.O. may provide personal data to authorized public authorities, particularly to the Prosecutor’s Office, Police, President of the Personal Data Protection Office, President of the Office for Competition and Consumer Protection, or the President of the Office of Electronic Communications.
3. Cookie mechanism and IP address
1. The website us.gobagz.net uses small files called cookies. These are stored on the device of the user visiting the website by PROMOTORZY TRADING SP. Z O.O. provided that the browser allows it. A cookie typically contains the name of the domain from which it originates, its expiration time, and a randomly assigned identifier. The information collected through cookies helps tailor the products offered by PROMOTORZY TRADING SP. Z O.O. to the individual preferences and needs of website visitors. It also enables the development of general statistics about the viewership of 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 once the session ends or the browser is closed. Session cookies do not collect any personal data or confidential information from users’ devices.
b) Persistent cookies: These remain stored on the device until they are deleted or expire. Persistent cookies do not collect any personal or confidential information from users’ devices.
3. PROMOTORZY TRADING SP. Z O.O. uses its own cookies for the following purposes:
a) To authenticate the user on the website and maintain the user’s session.
b) For analytics, research, and auditing of viewership, including the creation of anonymous statistics to understand how users interact with the website, enabling the improvement of its structure and content.
4. PROMOTORZY TRADING SP. Z O.O. uses third-party cookies for the following purposes:
a) To display a map on informational pages showing the location of PROMOTORZY TRADING SP. Z O.O. office via the Google Maps service (third-party cookie provider: Google Inc., USA).
b) To collect general, anonymous statistical data through Google Analytics (third-party cookie provider: Google Inc., USA).
5. The cookie mechanism is safe for users’ computers. In particular, this mechanism does not allow viruses or other unwanted or malicious software to infiltrate users’ computers. However, users have the option to limit or block access to cookies through their browser settings. If users choose to do so, they may still be able to use the website, though certain features that rely on cookies may not function.
6. Below are instructions on how to change cookie settings in popular web browsers:
a) 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 the IP addresses of users. An IP address is a number assigned to a user’s device by their Internet Service Provider (ISP) for accessing the Internet. In most cases, the IP address is assigned dynamically, meaning it changes with each connection. The IP address is used by PROMOTORZY TRADING SP. Z O.O. to diagnose technical issues with the server, generate statistical analyses (e.g., identifying which regions generate the most traffic), and for server administration and security purposes. It may also be used to identify and block unwanted automated programs that may be accessing the website.
8. The website may contain links to other websites. PROMOTORZY TRADING SP. Z O.O. is not responsible for the privacy practices or policies of those websites.
4. Rights of data subjects
1. Right to Withdraw Consent – Legal basis: Article 7(3) GDPR.
a) The user has the right to withdraw any consent they have provided to PROMOTORZY TRADING SP. Z O.O.
b) The withdrawal of consent will take effect from the moment it is withdrawn. c) The withdrawal of consent will not affect the processing of data carried out by PROMOTORZY TRADING SP. Z O.O. based on consent prior to its withdrawal.
d) The withdrawal of consent will not result in any negative consequences for the user; however, it may prevent the user from continuing to use services or features that can only be provided with the user’s consent.
2. Right to Object to Data Processing – Legal basis: Article 21 GDPR.
a) The user has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data, including profiling, if PROMOTORZY TRADING SP. Z O.O. processes their data based on legitimate interests (e.g., marketing, statistical purposes, or facilitating the use of the website).
b) An objection to receiving marketing communications will be considered an objection to the processing of personal data for marketing purposes, including profiling.
c) If the objection is justified, and PROMOTORZY TRADING SP. Z O.O. has no legal basis for processing the personal data, the data will be deleted.
3. Right to Erasure (“Right to be Forgotten”) – Legal basis: Article 17 GDPR.
a) The user has the right to request the deletion of all or some of their personal data.
b) The user can request erasure if:
– The data is no longer necessary for the purposes for which it was collected or processed.
– The user has withdrawn consent for processing based on consent.
– The user objects to processing for marketing purposes.
– The data was processed unlawfully.
– The data must be deleted to comply with a legal obligation under EU or national law.
– The data was collected in connection with the provision of information society services.
c) Even if the user requests the deletion of their data, PROMOTORZY TRADING SP. Z O.O. may retain certain data if necessary for the establishment, exercise, or defense of legal claims or to comply with legal obligations.
4. Right to Restrict Processing – Legal basis: Article 18 GDPR.
a) The user has the right to request the restriction of the processing of their personal data. This restriction may limit access to certain services or features of the website that require processing.
b) The user can request the restriction of processing in the following cases:
– The accuracy of the data is disputed, and processing is restricted until the accuracy is verified.
– The processing is unlawful, and the user requests restriction instead of erasure.
– The data is no longer needed but is necessary for the user to establish, exercise, or defend legal claims.
– The user has objected to processing, and the restriction is necessary while assessing whether the legitimate grounds of PROMOTORZY TRADING SP. Z O.O. override the user’s rights.
5. Right of Access to Data – Legal basis: Article 15 GDPR.
a) The user has the right to obtain confirmation from PROMOTORZY TRADING SP. Z O.O. as to whether their personal data is being processed. If data is being processed, the user has the right to access their data and receive information about:
– The purposes of processing.
– The categories of personal data being processed.
– The recipients of the data.
– The retention period or criteria for determining it.
– The rights available to the user under GDPR.
– The source of the data (if not provided directly by the user).
– The existence of automated decision-making, including profiling. b) The user may request a copy of their personal data.
6. Right to Rectification – Legal basis: Article 16 GDPR.
a) The user has the right to request the correction of inaccurate personal data or the completion of incomplete data.
7. Right to Data Portability – Legal basis: Article 20 GDPR.
a) The user has the right to receive their personal data in a structured, commonly used, and machine-readable format and to transmit it to another data controller, if technically feasible.
8. In case of requests under the rights listed above, PROMOTORZY TRADING SP. Z O.O. will respond within one month of receiving the request. If the request is complex, the deadline may be extended by two additional months.
9. The user may contact PROMOTORZY TRADING SP. Z O.O. to inquire about their data processing practices or to exercise their rights.
10. The user has the right to file a complaint with the U.S. Federal Trade Commission (FTC) or another appropriate authority in case of data protection violations.
5. Services tailored to preferences and interests (Profiling)
1. Profiling means any form of automated processing of personal data that involves using personal data to assess certain personal aspects of an individual, particularly to analyze or predict aspects related to the individual’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
2. Personal data of clients may be processed automatically (profiling), but this will not result in any legal consequences or significantly affect the client’s situation.
3. The profiling of personal data by PROMOTORZY TRADING SP. Z O.O. involves the automated and manual processing of clients’ data, which is used to assess certain information about the client, particularly to analyze or predict their personal preferences and interests.
4. To reach clients with marketing messages outside of the website, PROMOTORZY TRADING SP. Z O.O. uses external service providers. These services involve displaying marketing messages on websites other than the us.gobagz.net website. In this process, external providers may install appropriate code or pixels to collect information about the client’s activity on the website. For details regarding the cookies used, please refer to Section 3. Legal basis: Legitimate interest (Art. 6(1)(f) GDPR), which involves tailoring marketing messages to the client’s preferences and interests.
5. To reach clients with marketing messages through the website, PROMOTORZY TRADING SP. Z O.O. uses external service providers. These services involve displaying marketing messages on the us.gobagz.net website. In this process, external providers may install appropriate code or pixels to collect information about the client’s activity on the website. For details regarding the cookies used, please refer to Section 3. Legal basis: Legitimate interest (Art. 6(1)(f) GDPR), which involves tailoring marketing messages to the client’s preferences and interests.
6. To reach clients with marketing messages through the website, PROMOTORZY TRADING SP. Z O.O. uses its own cookie mechanisms to collect information about the client’s activity on the website. For details regarding the cookies used, please refer to Section 3. Legal basis: Legitimate interest (Art. 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 a secure and encrypted connection for clients when transmitting personal data through the Service. PROMOTORZY TRADING SP. Z O.O. uses an SSL certificate issued by one of the leading global security and data encryption companies for transmitting data over the internet.
7. Changes to the Privacy Policy
1. The Privacy Policy may be updated, and PROMOTORZY TRADING SP. Z O.O. will inform clients of any changes at least 7 days in advance.
2. Any questions regarding the Privacy Policy should be directed to: world@promotorzy.pl
