Privacy Policy

Privacy Policy

The following Privacy Policy sets out the principles for storing and accessing data on the Devices of Users using the Service for the purposes of providing electronic services by the Administrator, and the principles for collecting and processing the personal data of Users that have been provided by them personally and voluntarily through the tools available on the Service.

The following Privacy Policy is an integral part of the Terms of Service, which sets out the principles, rights and obligations of Users using the Service.

§1 Definitions

  • Service – the website of “REAL KALISZ” operating at https://www.real.kalisz.pl.
  • External Website – websites of partners, service providers or customers cooperating with the Administrator
  • Administrator of the Website / Data – the Administrator of the Website and Data Administrator (hereinafter referred to as Administrator) is the company “PRZEDSIĘBIORSTWO HANDLOWO PRODUKCYJNE “REAL” CEZARY WOJTKOWIAK”, operating at the address: Zachodnia 5, 62-800 Kalisz, with assigned tax identification number (NIP): 6180060141, providing services electronically through the Website
  • User – a natural person for whom the Administrator provides services electronically through the Website.
  • Device – an electronic device with software, through which the User accesses the Website.
  • Cookies – text data collected in the form of files placed on the User’s Device.
  • RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
  • Personal data – means information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.
  • Processing – means an operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, organisation, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • Restriction of processing – means the marking of stored personal data for the purpose of restricting its future processing.
  • Profiling – means any form of automated processing of personal data which involves the use of personal data to evaluate certain personal factors relating to an individual, in particular to analyse or predict aspects relating to that individual’s performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
  • Consent – consent of the data subject means a freely given, specific, informed and unambiguous indication of intent by which the data subject, either by a statement or by a clear affirmative action, gives his or her consent to the processing of personal data concerning him or her.
  • Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to, personal data transmitted, stored or otherwise processed.
  • Pseudonymisation – means the processing of personal data in such a way that they can no longer be attributed to a specific data subject, without the use of additional information, provided that such additional information is kept separately and is covered by technical and organisational measures to prevent its attribution to an identified or identifiable natural person.
  • Anonymisation – Data anonymisation is an irreversible process of data operations that destroys / overwrites “personal data” making it impossible to identify, or link, a particular record to a specific user or individual.

§2 Data Protection Officer

Pursuant to Article 37 RODO, the Controller has not appointed a Data Protection Officer.

For matters concerning data processing, including personal data, please contact the Controller directly.

§3 Types of Cookies

  • Internal cookies – files placed and read from the User’s Device by the Service’s data communications system.
  • External Cookies – files placed and read from the User Device by tele-information systems of external Services. The scripts of external Services that may place Cookies on User Devices have been deliberately placed on the Website through scripts and services made available and installed on the Website.
  • Session Cookies – files placed and read from the User’s Device by the Service during a single session of a given Device. At the end of the session, the files are deleted from the User Device.
  • Persistent cookies – files placed and read from the User Device by the Website until they are manually deleted. The files are not deleted automatically after the end of a session of the Device, unless the configuration of the User Device is set to delete cookies after the end of a session of the Device.

§4 Data storage security

  • Mechanisms for storing and reading Cookies – The mechanisms for storing, reading and exchanging data between Cookies stored on the User’s Device and the Website are implemented through the built-in mechanisms of web browsers and do not allow other data to be retrieved from the User’s Device or from other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojan horses and other worms to the User Device is also practically impossible.
  • Internal cookies – the cookies used by the Administrator are safe for the User’s Device and do not contain scripts, content or information which may threaten the security of personal data or the security of the Device used by the User.
  • External cookies – The Administrator makes all possible efforts to verify and select service partners in the context of User security. The Administrator selects well-known, large partners with global public trust for cooperation. 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 cookies, their content and their use by the Scripts installed in the service, coming from external services in compliance with the licence, as far as the law allows. The list of partners is provided later in the Privacy Policy.
  • Cookie control
  • Threats on the part of the User – The Administrator uses all possible technical measures to ensure the security of the data placed in cookies. However, it should be noted that ensuring the security of this data depends on both parties including the User’s activity. The Administrator is not responsible for interception of this data, impersonation of the User’s session or its deletion, as a result of the User’s conscious or unconscious activity, viruses, Trojan horses and other spyware with which the User’s Device may be or has been infected. Users, in order to protect themselves from these threats, should follow the recommendations for use of the Internet.
  • Storage of personal data – The Administrator ensures that it makes every effort to ensure that the processed personal data entered voluntarily by the Users is secure, that access to it is limited and that it is carried out in accordance with its purpose and the purposes of processing. The Administrator also ensures that it makes every effort to secure the data it holds against loss, through the use of appropriate physical and organisational safeguards.

§5 Purposes for which cookies are used

  • To improve and facilitate access to the Website
  • Personalisation of the Website for Users
  • Keeping statistics (users, number of visits, types of device, link, etc.).

§6 Purposes of personal data processing

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

  • Implementation of electronic services:
    • Newsletter service (including sending advertising content with consent)
  • Communication of the Administrator with Users on matters related to the Service and data protection
  • Ensuring the legitimate interest of the Administrator

Data on Users collected anonymously and automatically is processed for one of the following purposes:

  • Conducting statistics
  • Ensuring the legitimate interest of the Administrator

§7 Cookies of External Services

The Administrator uses javascript and web components of partners on the Website, who may place their own cookies on the User’s Device. Please note that you can decide for yourself in your browser settings what cookies are allowed to be used by individual websites. Below is a list of the partners or their services implemented on the Website that may place cookies:

Maintenance of statistics:

The services provided by third parties are beyond the control of the Administrator. These entities may change their terms and conditions of service, privacy policies, purpose of data processing and ways of using cookies at any time.

§8 Types of data collected

The Website collects data about Users. Part of the data is collected automatically and anonymously, and part of the data is personal data voluntarily provided by Users when signing up for particular services offered by the Website.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Sub-pages accessed
  • Time spent on relevant sub-page
  • Operating system type
  • Previous Subpage Address
  • Referring website address
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected during registration:

  • Email address
  • IP address (automatically collected)

Data collected when subscribing to the Newsletter service

  • E-mail address
  • IP address (collected automatically)

Some data (without identifying information) may be stored in cookies. Part of the data (without identifying information) may be transmitted to a statistical service provider.

§9 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided is not transferred or resold to third parties.

Access to the data (usually on the basis of the Contract for entrustment of data processing) may have entities responsible for maintenance of infrastructure and services necessary for running the service, i.e:

  • Hosting companies, providing hosting or related services to the Administrator

Entrustment of personal data processing – Hosting, VPS or Dedicated Servers services

In order to run the website, the Administrator uses the services of an external provider of hosting, VPS or Dedicated Servers – HOME.PL. All data collected and processed on the website are stored and processed in the service provider’s infrastructure located in Poland. There is a possibility of access to the data as a result of maintenance works performed by the service provider’s personnel. Access to these data is regulated by the agreement concluded between the Administrator and the service provider.

§10 Processing of personal data

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless they have been published as a result of an individual action by the User (e.g. entering a comment or a post), which will make the data available to any visitor to the website.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

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

§11 Legal bases for processing personal data

The Service collects and processes Users’ data on the basis of:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation)
    • Article 6(1)(a)
      the data subject has given his or her consent to the processing of his or her personal data for one or more specified purposes
    • Article 6(1)(b)
      processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
    • Article 6(1)(f)
      processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
  • Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)
  • Act of 16 July 2004. Telecommunications law (Journal of Laws 2004 no. 171 item 1800)
  • Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24 item 83)

§12 Processing period for personal data

Personal data provided voluntarily by Users:

As a rule, the personal data indicated are stored exclusively for the duration of the provision of the Service within the Service by the Administrator. They are deleted or anonymised up to 30 days after the termination of the service (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.).

The exception to this is when it is necessary to safeguard the legitimate purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data from the time of the User’s request for deletion, no longer than for a period of 3 years in case of violation or suspected violation of the provisions of the regulations of the service by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, is stored by the Administrator for the purpose of keeping service statistics for an indefinite period of time.