Privacy Policy

The following Privacy Policy outlines the rules for storing and accessing data on the Users’ Devices using the Service for the purpose of electronic service provision by the Administrator, as well as the principles for collecting and processing personal data provided by Users voluntarily via tools available in the Service.

This Privacy Policy is an integral part of the Service’s Terms and Conditions, which define the rules, rights, and obligations of the Users utilizing the Service.

§1 Definitions

• Service – the “Transgabaryt” website operating at www.transgabaryt.pl
• External Service – partner websites, service providers, or clients cooperating with the Administrator
• Administrator – the operator of the Service and Data Controller, is the company “Adam Nosewicz,” based at al. Wojska Polskiego 31, 62-800 Kalisz, with the Tax Identification Number (NIP): 9680867109, providing electronic services through the Service.
• User – an individual for whom the Administrator provides services electronically through the Service.
• Device – an electronic device with software that the User uses to access the Service.
• Cookies – text data collected in the form of files placed on the User’s Device.
• GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation).
• Personal Data – information about an identified or identifiable individual (“data subject”). An identifiable person is someone who can be directly or indirectly identified, especially by an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to physical, physiological, genetic, mental, economic, cultural, or social identity.
• Processing – any operation performed on personal data, such as collection, recording, organization, structuring, storage, adaptation, retrieval, consultation, use, disclosure, dissemination, or destruction.
• Restriction of processing – marking stored personal data to limit their processing in the future.
• Profiling – any form of automated processing of personal data to evaluate certain personal aspects, particularly to analyze or predict aspects regarding work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
• Consent – a voluntary, specific, informed, and unambiguous indication of the data subject’s agreement to the processing of personal data.
• Data breach – a security breach leading to accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.

§2 Data Protection Officer

Based on Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

For matters related to data processing, including personal data, you should contact the Administrator directly.

§3 Types of Cookies

• Internal Cookies – files placed and read from the User’s Device by the Service’s ICT system.
• External Cookies – files placed and read from the User’s Device by ICT systems of external services. External services that may place cookies on the User’s Device are consciously integrated into the Service through scripts and services provided and installed in the Service.
• Session Cookies – files placed and read from the User’s Device by the Service during one session of a given Device. After the session ends, the files are deleted from the User’s Device.
• Persistent Cookies – files placed and read from the User’s Device by the Service until they are manually deleted. The files are not automatically deleted after the session ends unless the User’s Device settings are configured to automatically delete cookies at the end of the session.

§4 Data Storage Security

• Mechanisms for storing and reading cookies – The mechanisms for storing, reading, and exchanging data between cookies saved on the User’s Device and the Service are carried out by the built-in mechanisms of web browsers and do not allow the collection of other data from the User’s Device or data from other websites visited by the User, including personal or confidential information. It is practically impossible to transfer viruses, trojans, or other worms to the User’s Device.

• Internal Cookies – The cookies used by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that may threaten the security of personal data or the security of the User’s Device.

• External Cookies – The Administrator makes every effort to verify and select service partners in terms of User safety. The Administrator selects well-known, large partners with global social trust. However, the Administrator does not have full control over the content of cookies from external partners. The Administrator is not responsible for the security of external cookies or their use by external service scripts installed in the Service, to the extent permitted by law.

Control of Cookies

• The User can change the settings for saving, deleting, and accessing cookies by any website at any time.

• Information on how to disable cookies in the most popular web browsers is available at the following pages:

  • Managing cookies in Chrome
  • Managing cookies in Opera
  • Managing cookies in Firefox
  • Managing cookies in Edge
  • Managing cookies in Safari
  • Managing cookies in Internet Explorer 11

• The User can delete all saved cookies at any time using the tools of the User’s Device through which the User accesses the Service.

§5 Purposes of Using Cookies

• Improving and facilitating access to the Service
• Personalizing the Service for Users
• Enabling login to the Service
• Marketing and remarketing on external services
• Serving ads
• Affiliate services
• Running statistics (number of users, number of visits, device types, connection, etc.)
• Providing multimedia services
• Offering social media services

§6 Purposes of Processing Personal Data

Personal data voluntarily provided by Users are processed for one of the following purposes:

• Provision of electronic services:

  • User registration and account maintenance services within the Service and functionalities related to it
  • Newsletter services (including sending advertising content with consent)
  • Services for commenting/liking posts in the Service without the need to register
  • Services for sharing content from the Service on social media or other websites

• Communication between the Administrator and Users regarding the Service and data protection

• Ensuring the legitimate interest of the Administrator

Anonymous and automatically collected User data are processed for one of the following purposes:

• Running statistics
• Remarketing
• Serving ads tailored to Users’ preferences
• Managing affiliate programs
• Ensuring the legitimate interest of the Administrator

§7 External Service Cookies

The Administrator uses JavaScript scripts and web components from partners in the Service, which may place their cookies on the User’s Device. Please note that you can control the use of cookies from individual websites through the settings of your web browser. Below is a list of partners or their services implemented in the Service that may place cookies:

• Multimedia services:

  • YouTube

• Social media/linked services:

  • Facebook
  • Google+

• Newsletter services:

  • Mailerlite

• Statistics:

  • Google Analytics

• Other services:

  • Google Maps

§8 Types of Data Collected

The Service collects data about Users. Some data is collected automatically and anonymously, while some is personal data provided voluntarily by Users when subscribing to specific services offered by the Service.

Automatically collected anonymous data includes:

• IP address
• Browser type
• Screen resolution
• Approximate location
• Pages viewed in the Service
• Time spent on a given page
• Operating system type
• Previous page URL
• Referral page URL
• Browser language
• Internet connection speed
• Internet service provider

Data Collected During Registration:

• First Name / Last Name / Username
• Login
• Email address
• Phone number
• IP address (collected automatically)

Data Collected for Newsletter Subscription:

• First Name / Last Name / Username
• Email address
• IP address (collected automatically)

Data Collected When Adding Comments:

• First Name / Last Name / Username
• Email address
• Website URL
• IP address (collected automatically)

Some data (without personally identifiable information) may be stored in cookies. Some data (without personally identifiable information) may be shared with providers of statistical services.

§9 Access to Personal Data by Third Parties

As a general rule, the only recipient of personal data provided by Users is the Administrator. The data collected within the services provided are not transferred or resold to third parties.

Access to data (most often based on a data processing agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the Service, such as:

• Hosting companies providing hosting or related services to the Administrator
• Companies through which the Newsletter service is provided

Delegation of Personal Data Processing – Newsletter

The Administrator, to provide the Newsletter service, uses a third-party service – Mailerlite. Data entered in the subscription form for the Newsletter is transferred, stored, and processed through this external provider.

Please note that the mentioned partner may modify its privacy policy without the Administrator’s consent.

Delegation of Personal Data Processing – Hosting, VPS, or Dedicated Server Services

The Administrator, to run the Service, uses external hosting providers, VPS, or dedicated server services – www.zenbox.pl. All data collected and processed by the Service is stored and processed within the infrastructure of the provider, located in Poland. Access to this data may occur as a result of maintenance work conducted by the provider’s staff. Access to this data is regulated by an agreement between the Administrator and the provider.

§10 How Personal Data is Processed

Personal data voluntarily provided by Users:

• Personal data will not be transferred outside the European Union unless it is published due to individual action by the User (e.g., posting a comment or entry), which will make the data available to anyone visiting the Service.
• Personal data will not be used for automated decision-making (profiling).
• Personal data will not be resold to third parties.

Automatically collected anonymous data:

• Anonymous data (without personal information) may be transferred outside the European Union.
• Anonymous data (without personal information) will not be used for automated decision-making (profiling).
• Anonymous data (without personal information) will not be resold to third parties.

§11 Legal Basis for Processing Personal Data

The Service collects and processes Users’ data based on:

• Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (General Data Protection Regulation):

  • Article 6(1)(a) – the data subject has given consent to the processing of their personal data for one or more specific purposes.

  • Article 6(1)(b) – processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject before entering into a contract.

  • Article 6(1)(f) – processing is necessary for the purposes of the legitimate interests pursued by the Administrator or a third party.

• The Act of May 10, 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)

• The Act of July 16, 2004 Telecommunications Law (Journal of Laws 2004, No. 171, item 1800)

• The Act of February 4, 1994 on Copyright and Related Rights (Journal of Laws 1994, No. 24, item 83)

§12 Retention Period for Personal Data

Personal data voluntarily provided by Users:

• As a rule, personal data is stored only for the period during which the service is provided in the Service by the Administrator. They are deleted or anonymized within 30 days after the service is terminated (e.g., user account deletion, unsubscribing from the Newsletter, etc.).

• An exception is a situation where it is necessary to secure legally justified interests for further data processing by the Administrator. In such a case, the Administrator will retain the specified data, from the time of the deletion request by the User, for no longer than 3 years if the User violates or is suspected of violating the Service’s regulations.

Automatically collected anonymous data:

• Anonymous statistical data, which does not constitute personal data, is stored by the Administrator indefinitely for the purpose of maintaining the Service’s statistics.

§13 User Rights Regarding Personal Data Processing

The Service collects and processes Users’ data based on:

• Right of access to personal data
  Users have the right to access their personal data, which can be exercised by submitting a request to the Administrator.

• Right to rectify personal data
  Users have the right to request the immediate correction of their personal data if it is inaccurate or incomplete. This can be requested from the Administrator.

• Right to delete personal data
  Users have the right to request the immediate deletion of their personal data. This can be requested from the Administrator. In the case of user accounts, data deletion is carried out by anonymizing data that allows User identification. The Administrator reserves the right to suspend the data deletion request to protect the Administrator’s legitimate interests (e.g., if the User has violated the Service’s regulations, or data was obtained through correspondence).

  In the case of the Newsletter service, the User can delete their personal data independently using the link included in every email sent.

• Right to restrict the processing of personal data
  Users have the right to restrict the processing of personal data in cases specified in Article 18 of the GDPR, e.g., disputing the accuracy of personal data. This can be requested from the Administrator.

• Right to data portability
  Users have the right to obtain their personal data from the Administrator in a structured, commonly used, machine-readable format. This can be requested from the Administrator.

• Right to object to the processing of personal data
  Users have the right to object to the processing of their personal data in cases specified in Article 21 of the GDPR. This can be requested from the Administrator.

• Right to file a complaint
  Users have the right to file a complaint with a supervisory authority responsible for data protection.

§14 Contact with the Administrator

The Administrator can be contacted in one of the following ways:

• Postal address: Adam Nosewicz, al. Wojska Polskiego 31, 62-800 Kalisz
• Email: kontakt@transgabaryt.pl
• Phone: +48 508 371 775
• Contact form: available at www.transgabaryt.pl/kontakt

§15 Service Requirements

Restricting the ability to store and access cookies on the User’s Device may cause some functions of the Service to malfunction.

The Administrator is not responsible for improperly functioning Service features if the User restricts the ability to store and access cookies.

§16 External Links

The Service, articles, posts, or user comments may contain links to external websites not cooperating with the Service Administrator. These links and the content or files found under them may be unsafe for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content found outside the Service.

§17 Changes to the Privacy Policy

The Administrator reserves the right to make any changes to this Privacy Policy without informing Users, in terms of using and handling anonymous data or cookies.

The Administrator reserves the right to change the Privacy Policy regarding the processing of Personal Data. Users who have an account or are subscribed to the Newsletter will be informed via email within 7 days of the changes. Continued use of the services implies acknowledgment and acceptance of the changes to the Privacy Policy. If a User does not agree with the changes, they are required to delete their account or unsubscribe from the Newsletter.

Changes made to the Privacy Policy will be published on this page of the Service.

Changes take effect upon their publication.