Privacy Policy

1 DATA PROTECTION AT A GLANCE

1.1 GENERAL INFORMATION

The following notes provide a simple overview of what happens to your personal data when you visit this website. Personal data is any data that can be used to identify you personally. For detailed information on data protection, please refer to our privacy policy listed below this text.

1.1.1 DATA COLLECTION ON THIS WEBSITE

Who is responsible for data collection on this website?

Data processing on this website is carried out by the website operator. You can find his contact details in the section “Note on the responsible party” in this privacy policy.

How do we collect your data?

On the one hand, your data is collected by you providing it to us. This may, for example, be data that you enter in a contact form.

Other data is collected automatically or after your consent when you visit the website by our IT systems. This is mainly technical data (e.g. Internet browser, operating system or time of page view). This data is collected automatically as soon as you enter this website.

What do we use your data for?

Some of the data is collected to ensure error-free provision of the website. Other data may be used to analyze your user behavior.

What rights do you have regarding your data?

You have the right at any time to receive information free of charge about the origin, recipient and purpose of your stored personal data. You also have a right to request the correction or deletion of this data. If you have given your consent to data processing, you can revoke this consent at any time for the future. You also have the right to request the restriction of the processing of your personal data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

You can contact us at any time for this purpose as well as for further questions on the subject of data protection.

1.1.2 ANALYSIS TOOLS AND TOOLS FROM THIRD-PARTY PROVIDERS

When visiting this website, your surfing behavior may be statistically analyzed. This is done primarily with so-called analysis programs. Detailed information on these analysis programs can be found in the following privacy policy.

2 GENERAL NOTES AND OBLIGATORY INFORMATION

2.1 DATA PROTECTION

The operators of these pages take the protection of your personal data very seriously. We treat your personal data confidentially and in accordance with the statutory data protection regulations and this data protection declaration.

When you use this website, various personal data are collected.

Personal data is data with which you can be personally identified. This privacy policy explains what data we collect and what we use it for. It also explains how and for what purpose this is done.

We would like to point out that data transmission on the Internet (e.g. when communicating by e-mail) can have security gaps. Complete protection of data against access by third parties is not possible.

2.2 NOTE ON THE RESPONSIBLE PARTY

The responsible party for data processing on this website is:

Netzlink Polska Sp. z o.o.

Mr. Sławomir Lewandowski
ul. Kasztanowa 33

83-010 Rotmanka (Poland)
Tel: +48 58 77 37 910
Email: info@netzlink.pl

The controller is the natural or legal person who alone or jointly with others determines the purposes and means of the processing of personal data (e.g. names, e-mail addresses or similar).

2.3 STORAGE PERIOD

Unless a more specific storage period has been stated within this Privacy Policy, your personal data will remain with us until the purpose for processing the data no longer applies. If you assert a legitimate request for deletion or revoke your consent to data processing, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g. retention periods under tax or commercial law); in the latter case, the data will be deleted once these reasons no longer apply.

2.4 NOTICE ON THE TRANSFER OF DATA TO THE USA AND OTHER THIRD COUNTRIES

Among other things, we use tools from companies based in the USA or other third countries that are not secure under data protection law. If these tools are active, your personal data may be transferred to these third countries and processed there. We would like to point out that no level of data protection comparable to that in the EU can be guaranteed in these countries. For example, US companies are obliged to hand over personal data to security authorities without you as a data subject being able to take legal action against this. It can therefore not be ruled out that US authorities (e.g. intelligence services) process, evaluate and permanently store your data located on US servers for monitoring purposes. We have no influence on these processing activities.

2.5 REVOCATION OF CONSENT TO YOUR DATA PROCESSING

Many data processing operations are only possible with your express consent. You can revoke consent you have already given at any time. The legality of the data processing carried out until the revocation remains unaffected by the revocation.

2.6 RIGHT TO OBJECT TO DATA COLLECTION IN SPECIAL CASES AND TO DIRECT ADVERTISING (ART. 21 DSGVO)

IF DATA PROCESSING IS CARRIED OUT ON THE BASIS OF ART. 6 ABS. 1 LIT. E OR F DSGVO, YOU HAVE THE RIGHT TO OBJECT TO THE PROCESSING OF YOUR PERSONAL DATA AT ANY TIME FOR REASONS ARISING FROM YOUR PARTICULAR SITUATION; THIS ALSO APPLIES TO PROFILING BASED ON THESE PROVISIONS. THE RESPECTIVE LEGAL BASIS ON WHICH PROCESSING IS BASED CAN BE FOUND IN THIS PRIVACY POLICY. IF YOU OBJECT, WE WILL NO LONGER PROCESS YOUR PERSONAL DATA CONCERNED UNLESS WE CAN DEMONSTRATE COMPELLING LEGITIMATE GROUNDS FOR THE PROCESSING WHICH OVERRIDE YOUR INTERESTS, RIGHTS AND FREEDOMS, OR THE PROCESSING IS FOR THE PURPOSE OF ASSERTING, EXERCISING OR DEFENDING LEGAL CLAIMS (OBJECTION UNDER ARTICLE 21(1) DSGVO).

IF YOUR PERSONAL DATA ARE PROCESSED FOR THE PURPOSE OF DIRECT MARKETING, YOU HAVE THE RIGHT TO OBJECT AT ANY TIME TO THE PROCESSING OF PERSONAL DATA CONCERNING YOU FOR THE PURPOSE OF SUCH MARKETING; THIS ALSO APPLIES TO PROFILING INSOFAR AS IT IS RELATED TO SUCH DIRECT MARKETING. IF YOU OBJECT, YOUR PERSONAL DATA WILL SUBSEQUENTLY NO LONGER BE USED FOR THE PURPOSE OF DIRECT MARKETING (OBJECTION PURSUANT TO ART. 21 PARA. 2 DSGVO).

2.7 RIGHT OF COMPLAINT TO THE COMPETENT SUPERVISORY AUTHORITY

In the event of violations of the GDPR, data subjects shall have a right of appeal to a supervisory authority, in particular in the Member State of their habitual residence, their place of work or the place of the alleged violation. The right of appeal is without prejudice to other administrative or judicial remedies.

The competent supervisory authority is the

Prezes Urzędu Ochrony Danych Osobowych (PUODO) (Personal Data Protection Office)
Stawki 2
00-193 Warsaw
Poland

Contact:
Email: kancelaria@uodo.gov.pl
Website: https://www.uodo.gov.pl/

2.8 RIGHT TO DATA PORTABILITY

You have the right to have data that we process automatically on the basis of your consent or in performance of a contract handed over to you or to a third party in a common, machine-readable format. If you request the direct transfer of the data to another responsible party, this will only be done insofar as it is technically feasible.

2.9 SSL OR TLS ENCRYPTION

For security reasons and to protect the transmission of confidential content, such as orders or requests that you send to us as the site operator, this site uses SSL or TLS encryption. You can recognize an encrypted connection by the fact that the address line of the browser changes from “http://” to “https://” and by the lock symbol in your browser line.

If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

2.10 INFORMATION, DELETION AND CORRECTION

Within the framework of the applicable legal provisions, you have the right at any time to free information about your stored personal data, its origin and recipient and the purpose of data processing and, if applicable, a right to correction or deletion of this data. For this purpose, as well as for further questions on the subject of personal data, you can contact us at any time.

2.11 RIGHT TO RESTRICTION OF PROCESSING

You have the right to request the restriction of the processing of your personal data. For this purpose, you can contact us at any time. The right to restriction of processing exists in the following cases:

If you dispute the accuracy of your personal data stored by us, we usually need time to verify this. For the duration of the review, you have the right to request the restriction of the processing of your personal data.
If the processing of your personal data happened/is happening unlawfully, you can request the restriction of data processing instead of deletion.
If we no longer need your personal data, but you need it to exercise, defend or assert legal claims, you have the right to request restriction of the processing of your personal data instead of erasure.
If you have lodged an objection pursuant to Art. 21 (1) DSGVO, a balancing of your and our interests must be carried out. As long as it has not yet been determined whose interests prevail, you have the right to request the restriction of the processing of your personal data.

If you have restricted the processing of your personal data, this data – apart from its storage – may only be processed with your consent or for the assertion, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of an important public interest of the European Union or a Member State.

2.12 OBJECTION TO ADVERTISING EMAILS

The use of contact data published within the framework of the imprint obligation for the transmission of advertising and information material not expressly requested is hereby objected to. The operators of the pages expressly reserve the right to take legal action in the event of the unsolicited sending of advertising information, such as spam e-mails.

3 DATA COLLECTION ON THIS WEBSITE

3.1 COOKIES

Our Internet pages use so-called “cookies”. Cookies are small text files and do not cause any damage to your terminal device. They are stored either temporarily for the duration of a session (session cookies) or permanently (permanent cookies) on your end device. Session cookies are automatically deleted at the end of your visit. Permanent cookies remain stored on your end device until you delete them yourself or until they are automatically deleted by your web browser.

In some cases, cookies from third-party companies may also be stored on your terminal device when you enter our site (third-party cookies). These enable us or you to use certain services of the third-party company (e.g. cookies for processing payment services).

Cookies have various functions. Many cookies are technically necessary, as certain website functions would not work without them (e.g. the shopping cart function or the display of videos). Other cookies are used to evaluate user behavior or display advertising. Cookies that are necessary to carry out the electronic communication process (necessary cookies) or to provide certain functions that you have requested (functional cookies, e.g. for the shopping cart function) or to optimize the website (e.g. cookies to measure the web audience) are stored on the basis of Art. 6 (1) lit. f DSGVO, unless another legal basis is specified. The website operator has a legitimate interest in storing cookies for the technically error-free and optimized provision of its services. If consent to the storage of cookies has been requested, the storage of the cookies in question is based exclusively on this consent (Art. 6 para. 1 lit. a DSGVO); consent can be revoked at any time.

You can set your browser so that you are informed about the setting of cookies and only allow cookies in individual cases, exclude the acceptance of cookies for certain cases or in general and activate the automatic deletion of cookies when closing the browser. If cookies are deactivated, the functionality of this website may be limited.

Insofar as cookies are used by third-party companies or for analysis purposes, we will inform you separately about this within the framework of this data protection declaration and, if necessary, request your consent.

3.2 CONSENT WITH BORLABS COOKIE

Our website uses Borlabs Cookie consent technology to obtain your consent to the storage of certain cookies in your browser or to the use of certain technologies and to document this in compliance with data protection regulations. The provider of this technology is Borlabs – Benjamin A. Bornschein, Rübenkamp 32, 22305 Hamburg (hereinafter referred to as Borlabs).
When you enter our website, a Borlabs cookie is stored in your browser, which stores the consent you have given or the withdrawal of this consent. This data is not passed on to the provider of Borlabs Cookie.

The collected data is stored until you ask us to delete it or delete the Borlabs cookie yourself or the purpose for storing the data no longer applies. Mandatory statutory retention periods remain unaffected. Details on data processing by Borlabs Cookie can be found at https://de.borlabs.io/kb/which-data-stores-borlabs-cookie/.
Borlabs cookie consent technology is used to obtain the legally required consent for the use of cookies. The legal basis for this is Art. 6 Para. 1 lit. C GDPR

3.3 SERVER LOG FILES

The provider of the pages automatically collects and stores information in so-called server log files, which your browser automatically transmits to us. These are:

browser type and browser version
Operating system used
referrer URL
Host name of the accessing computer
Time of the server request
IP address

This data is not merged with other data sources.

The collection of this data is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in the technically error-free presentation and optimization of its website – for this purpose, the server log files must be collected.

3.4 CONTACT FORM

If you send us inquiries via the contact form, your data from the inquiry form, including the contact data you provided there, will be stored by us for the purpose of processing the inquiry and in case of follow-up questions. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 (1) lit. b DSGVO, if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 (1) (f) DSGVO) or on your consent (Art. 6 (1) (a) DSGVO) if this has been requested.

The data you enter in the contact form will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after we have completed processing your request). Mandatory legal provisions – in particular retention periods – remain unaffected.

3.5 INQUIRY BY E-MAIL, TELEPHONE OR FAX

If you contact us by e-mail, telephone or fax, your inquiry including all resulting personal data (name, inquiry) will be stored and processed by us for the purpose of processing your request. We do not pass on this data without your consent.

The processing of this data is based on Art. 6 (1) lit. b DSGVO, if your request is related to the performance of a contract or is necessary for the implementation of pre-contractual measures. In all other cases, the processing is based on our legitimate interest in the effective processing of the requests sent to us (Art. 6 (1) (f) DSGVO) or on your consent (Art. 6 (1) (a) DSGVO) if this has been requested.

The data you send to us via contact requests will remain with us until you request us to delete it, revoke your consent to store it, or the purpose for storing the data no longer applies (e.g. after your request has been processed). Mandatory legal provisions – in particular legal retention periods – remain unaffected.

4 ANALYSIS TOOLS AND ADVERTISING

4.1 GOOGLE TAG MANAGER

(is integrated in particular for additional manual IP anonymization)

We use the Google Tag Manager. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland.

The Google Tag Manager is a tool that allows us to integrate tracking or statistical tools and other technologies on our website. The Google Tag Manager itself does not create user profiles, does not store cookies and does not perform any independent analyses. It only serves to manage and play out the tools integrated via it. However, the Google Tag Manager records your IP address, which may also be transmitted to Google’s parent company in the United States.

The use of the Google Tag Manager is based on Art. 6 (1) lit. f DSGVO. The website operator has a legitimate interest in a quick and uncomplicated integration and management of various tools on his website. Insofar as a corresponding consent was requested, the processing is carried out exclusively on the basis of Art. 6 para. 1 lit. a DSGVO; the consent can be revoked at any time.

4.2 GOOGLE ANALYTICS

This website uses functions of the web analytics service Google Analytics. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland.

Google Analytics enables the website operator to analyze the behavior of website visitors. In doing so, the website operator receives various usage data, such as page views, length of stay, operating systems used and the origin of the user. This data may be summarized by Google in a profile that is assigned to the respective user or their end device.

Furthermore, Google Analytics may record your mouse and scroll movements and clicks, among other things. Furthermore, Google Analytics uses various modeling approaches to supplement the collected data sets and uses machine learning technologies in the data analysis.

Google Analytics uses technologies that enable the recognition of the user for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transferred to a Google server in the USA and stored there.

The use of this analysis tool is based on Art. 6 para. 1 lit. f DSGVO. The website operator has a legitimate interest in analyzing user behavior in order to optimize both its website and its advertising. If a corresponding consent has been requested (e.g. consent to store cookies), the processing is based exclusively on Art. 6 para. 1 lit. a DSGVO; the consent can be revoked at any time.

Data transfer to the USA is based on the standard contractual clauses of the EU Commission.

Details can be found here:

https://privacy.google.com/businesses/controllerterms/mccs/.

4.2.1 IP ANONYMIZATION

We have activated the IP anonymization function on this website. This means that your IP address will be truncated by Google within member states of the European Union or in other states party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On behalf of the operator of this website, Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity and providing other services relating to website activity and internet usage to the website operator. The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google.

4.2.2 BROWSER PLUGIN

You can prevent the collection and processing of your data by Google by downloading and installing the browser plugin available at the following link:

https://tools.google.com/dlpage/gaoptout?hl=de.

You can find more information on how Google Analytics handles user data in the

https://support.google.com/analytics/answer/6004245?hl=de.

4.2.3 ORDER PROCESSING

We have concluded an order processing agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

4.2.4 DEMOGRAPHIC FEATURES ON GOOGLE ANALYTICS

This website uses the “demographic characteristics” function of Google Analytics to display suitable advertisements to website visitors within the Google advertising network. This allows reports to be generated that include statements about the age, gender, and interests of site visitors. This data comes from interest-based advertising from Google as well as from visitor data from third-party providers. This data cannot be assigned to a specific person. You can deactivate this function at any time via the ad settings in your Google account or generally prohibit the collection of your data by Google Analytics as shown in the item “Objection to data collection”.

4.2.5 STORAGE PERIOD

Data stored by Google at user and event level that is linked to cookies, user identifiers (e.g. User ID) or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) is anonymized and deleted after 14 months. For details, please see the following link:

https://support.google.com/analytics/answer/7667196?hl=de

5 NEWSLETTER AND POSTAL ADVERTISING

POSTAL ADVERTISING

We use your address in compliance with all legal provisions for sending postal advertising (postal advertising).

The legal basis for this is our legitimate interest in direct advertising pursuant to Art. 6 (1) f in conjunction with Recital 47 DSGVO. Insofar as a corresponding consent has been requested, the processing is carried out exclusively on the basis of Art. 6 (1) lit. a DSGVO; the consent can be revoked at any time. More specific regulations may be communicated to them, if necessary, in the course of data collection and take precedence over the present regulation.

Your address will remain with us until the purpose for data processing ceases to apply. If you assert a legitimate request for deletion or revoke your consent to postal advertising, your data will be deleted unless we have other legally permissible reasons for storing your personal data (e.g., retention periods under tax or commercial law); in the latter case, the data will be deleted after these reasons no longer apply.

We use the following service provider to send our postal mailings:

Netzlink Polska Sp. z o.o.

Mr. Sławomir Lewandowski
up. Kasztanowa 33
83-010 Rotmanka (Poland)
Phone: +48 58 77 37 910
Email: info@netzlink.pl

6 PLUGINS AND TOOLS

6.1 GOOGLE WEB FONTS (LOCAL HOSTING)

This site uses so-called web fonts provided by Google for the uniform display of fonts. The Google Fonts are installed locally. There is no connection to Google servers.

Further information on Google Web Fonts can be found at

https://developers.google.com/fonts/faq and in Google’s privacy policy:

https://policies.google.com/privacy?hl=de.

22. June 2022