Content of the regulations

Definitions

1. Administrator (We) – NEOVITRE Sp. z o.o., based in Katowice. Plac Wolności 4, 40-078 Katowice, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court of Katowice-Wschód in Katowice, VIII Economic Department of the National Court Register under the KRS number 0000953715, NIP 6343006850, REGON 521247800
2. Personal data – all information about a natural person identified or identifiable by one or more specific factors that determine physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, Internet ID and information collected through cookies and other similar technology.
3. Policy – this Privacy Policy.
4. RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC.
5. Service – the website operated by us at www.neovitre.pl
6. User (You) – any natural person visiting the Website or using one or more of the services or functionalities described in the Policy

Processing of data in connection with the use of the site

• In connection with your use of the Website, we collect your data to the extent necessary to provide the various services offered, as well as information about your activity on the Website. The detailed rules and purposes of the processing of personal data collected during your use of the Service are described below.

Purposes and legal basis of data processing on the site

Use of the service

1. We process personal data of all persons who use the Service (including: ) , IP address or other identifiers and information collected through cookies or other similar technologies) and who are not registered Users (i.e., persons who do not have a profile on the Service) for the following purposes:
   1. in order to provide services electronically in the scope of providing Users with access to the content collected on the Website – then the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) RODO);
   2. for analytical and statistical purposes, in which case the legal basis for the processing is our legitimate interest (Article 6(1)(f) RODO) consisting in conducting analyses of Users’ activities, as well as their preferences in order to improve the functionalities used and services provided;
   3. for the purpose of possible establishment, investigation or defense of claims – the legal basis for the processing is our legitimate interest (Article 6(1)(f) RODO) in protecting our rights;
   4. for marketing purposes (ours and those of our partners), in particular related to the presentation of behavioral advertising – the principles of processing personal data for marketing purposes are described in the “MARKETING” section.
2. Your Activity on the Service, including your personal information, is recorded in system logs. The information collected in the logs is processed primarily for purposes related to the provision of services. We also process them for technical, administrative purposes, for the purpose of ensuring the security of the IT system and the management of this system, as well as for analytical and statistical purposes – in this regard, the legal basis for processing is our legitimate interest (Article 6(1)(f) RODO).

Use of paid services on the site

1. If you place an order (to purchase goods or services) on the Website, we will process your personal data for the following purposes:
   1. for the purpose of fulfilling a submitted order – the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) RODO); for data provided optionally, the legal basis for processing is consent (Article 6(1)(a) RODO);
   2. in order to comply with statutory obligations incumbent on us, and arising in particular from tax and accounting regulations – the legal basis for processing is a legal obligation (Article 6(1)(c) RODO);
   3. for analytical and statistical purposes – the legal basis for the processing is our legitimate interest (Article 6.1.f RODO) consisting in conducting analyses of your activity on the Website, as well as your shopping preferences in order to improve the functionalities used;
   4. for the purpose of possible establishment, investigation or defense of claims – the legal basis for the processing is our legitimate interest (Article 6(1)(f) RODO) in protecting our rights.

Contact forms

1. In the Service we provide the possibility to contact us using electronic contact forms. Using the form requires you to provide your personal information necessary for us to contact you and answer your question. You can also provide other data in the form to facilitate our contact or service your request. Provision of data marked as mandatory is required in order to receive and handle your inquiry, and failure to provide such data will result in our inability to handle your inquiry. Provision of other data is voluntary.
2. The personal data you send us via the contact form are processed:
   1. in order to identify you as a sender and to handle your inquiry sent via the form provided – the legal basis for the processing is the necessity of the processing for the performance of the service contract (Article 6(1)(b) RODO);
   2. for analytical and statistical purposes – the legal basis for the processing is our legitimate interest (Article 6(1)(f) of the RODO) consisting in keeping statistics on queries submitted by Users via the Service in order to improve its functionality.

Marketing

1. We process your personal data to carry out marketing activities, which may consist of:
   1. displaying marketing content that is not tailored to your preferences (contextual advertising);
   2. displaying marketing content that matches your interests (behavioral advertising);
   3. targeting e-mail notifications of interesting offers or content, which in some cases contain commercial information (newsletter service)
   4. conducting other activities related to direct marketing of goods and services (sending commercial information by electronic means and telemarketing activities)
2. In order to carry out marketing activities, in some cases we use profiling (if you agree). This means that through automated data processing we evaluate selected factors about individuals in order to analyze their behavior or make predictions for the future.

Direct marketing

1. Your Personal Information may also be used by us so that we can target marketing content to you through various channels, i.e. via e-mail, via MMS / SMS or by phone. We only take such actions if you have given your consent, which you may withdraw at any time.

Social networks

1. We process your personal data when you visit our profiles maintained on social media (Facebook, YouTube, Instagram, Twitter). This data is processed exclusively in connection with the operation of the profile, including to keep you informed about our activities and to promote various events, services and products. The legal basis for processing personal data for this purpose is our legitimate interest (Article 6(1)(f) RODO) in promoting our own brand.

Cookies and similar technology

1. Cookies are small text files installed on your device when you browse the Service. Cookies collect information to facilitate your use of the website – for example, by remembering your visits to the Website and the activities you perform. We may use the following types of cookies on the Site:

‘Service’ cookies

1. We are using the so-called. Service cookies primarily for the purpose of providing you with electronic services and improving the quality of these services. Accordingly, we and other entities providing analytical and statistical services to us use cookies to store information or access information already stored on your telecommunications end device (computer, phone, tablet, etc.). Cookies used for this purpose include:
   1. cookies with data you input (session ID) for the duration of the session (user input cookies);
   2. authentication cookies used for services that require authentication for the duration of the session (authentication cookies);
   3. Security cookies, such as those used to detect authentication abuse (user centric security cookies);
   4. multimedia player session cookies (e.g. flash player cookies), for the duration of the session (multimedia player session cookies);
   5. Persistent cookies used to personalize the user interface for the duration of the session or slightly longer (user interface customization cookies),
   6. cookies used to monitor website traffic, i.e. Data analytics, including Google Analytics cookies (these are cookies used by Google to analyze how you use the Site, to create statistics and reports on the operation of the Site). Google does not use the collected data to identify you, nor does it combine this information to enable identification. Detailed information on the scope and principles of data collection in connection with this service can be found at the following link: https://www.google.com/intl/pl/policies/privacy/partners.

‘Marketing’ cookies

1. We and our trusted partners also use cookies for marketing purposes, including. in connection with targeting you with behavioral advertising. For this purpose, we and our trusted partners store information or access information already stored on your telecommunications end device (computer, phone, tablet, etc.). The use of cookies and personal data collected through them for marketing purposes, in particular to promote the services and goods of third parties, requires your consent, which can be withdrawn at any time.

Cookie management

1. If you do not want to receive cookies, you can change your browser settings. We stipulate that disabling cookies necessary for authentication processes, security, maintaining user preferences may hinder the use of the Website.
2. To manage your cookie settings, select the web browser you are using from the list below and follow the instructions:
   1. Edge
   2. Internet Explorer
   3. Chrome
   4. Safari
   5. Firefox
   6. Opera
   7. Mobile devices:
   8. Android
   9. Safari (iOS)
   10. Windows Phone

Relevant marketing techniques

1. The purpose and scope of data collection and its further processing and use by service providers, as well as the possibility of contact and the User’s rights in this regard are described in the service providers’ privacy policies.
2. We may use remarketing techniques that allow us to tailor advertising messages to your behavior on the Service, which may give the illusion that your personal information is being used for tracking, but in practice we do not provide any of your personal information to advertising operators. A technological prerequisite for such activities is that cookies are enabled.
3. We can apply a solution to study user behavior by creating heat maps and recording behavior on the Service. This information is anonymized before it is sent to the service provider so that it does not know which individual it relates to. In particular, typed passwords and other personal data are not recorded.

Period of personal data processing

1. The period for which we process your data depends on the type of service provided and the purpose of the processing. As a general rule, data are processed for the duration of the service or order processing, until you withdraw your consent or make an effective objection to data processing (in cases where the legal basis for data processing is our legitimate interest).
2. The period of data processing may be extended if the processing is necessary for the establishment, investigation or defense of possible claims, and thereafter only if and to the extent required by law.
3. After the end of the processing period, your data is irreversibly deleted or anonymized.

Your powers

1. As we process your personal data, you have the following rights:
   1. The right to information about the processing of personal data – on this basis, at your request, we will provide you with information about the processing of your data, including, in particular, the purposes and legal grounds for processing, the scope of the data held, the entities to which they are disclosed, and the planned date of deletion;
   2. The right to obtain a copy of the data – on this basis, at your request, we will provide you with a copy of the processed data concerning the person making the request;
   3. The right to rectification – at your request, we are obliged to remove any inconsistencies or errors in the processed personal data and complete it if it is incomplete;
   4. The right to erasure – on this basis you can request the erasure of data, the processing of which is no longer necessary to carry out any of the purposes for which they were collected;
   5. The right to restrict processing – on this basis, at your request, we will stop performing operations on your personal data – except for operations to which you have consented – and their storage, in accordance with established retention policies or until the reasons for restricting processing cease to exist;
   6. The right to data portability – on this basis – to the extent that your data is processed in connection with a contract or consent given – we will release the data you provide in a computer-readable format. You may also request that we send this data to another entity – provided, however, that we have the technical capabilities to do so.
   7. The right to object to the processing of data for marketing purposes – you can object to the processing of personal data for marketing purposes at any time, without having to justify such objection;
   8. The right to object to other purposes of processing – You may object at any time to the processing of personal data that is carried out on the basis of our legitimate interest (e.g., for analytical or statistical purposes or for reasons related to property protection); an objection in this regard should contain a justification;
   9. The right to withdraw consent – if the data is processed on the basis of your consent, you have the right to withdraw it at any time, which, however, does not affect the legality of the processing carried out before the withdrawal of consent.
   10. The right to complain – if you believe that the way we process your personal data violates the provisions of the RODO or other data protection laws, you may file a complaint with the President of the Office for Personal Data Protection.

Recipients of data

1. As we want to perform the best possible services for you, we will disclose your personal data to our trusted partners, including in particular suppliers responsible for operating information systems, entities such as banks and payment operators, accounting service providers, couriers (in connection with order processing), marketing agencies (for marketing services) and our affiliates.
2. Your personal data will be shared with other entities for their own purposes, including marketing purposes only if you consent.

Transfers of data outside the EEA

1. The level of protection of personal data outside the European Economic Area (EEA) may differ from that provided by European law. For this reason, we will transfer your personal data outside the EEA only when necessary, and with an appropriate degree of protection. You will be notified each time.

Security of personal data

1. Know that we take all steps to ensure that your personal data is processed by us in a secure manner – ensuring, above all, that only authorized persons have access to your data and only to the extent necessary for their tasks.
2. We take all necessary measures to ensure that our subcontractors and other cooperating entities provide guarantees to apply appropriate security measures whenever they process your personal data on our behalf.

Contact information

1. For all matters referred to in this policy, in particular related to the processing of your personal data, you can contact us through:
   1. e-mail: biuro@neovitre.pl
   2. phone: +48 32 739 90 99