1.
DEFINITIONS
1.1 Administrator - eTOP Sp. z o.o. with its registered office at Al. Jerozolimskie 200, 02-222 Warsaw
1.2 Personal Data - information about a natural person identified or identifiable by one or more factors specific to 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.
1.3 Policy - this Privacy Policy.
1.4. 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.
1.5 Service - the website operated by the Administrator at https://www.etop.pl, https://datahouse.pl, https://hostilla.pl, https://datahouse.net.
1.6 User - any natural person visiting the Website or using one or more services or functionalities described in the Policy.
2.
PROCESSING OF DATA IN CONNECTION OF USING THE SERVICE
2.1 In connection with the User's use of the Website, the Administrator collects data to the extent necessary to provide the individual services offered, as well as information about the User's activity on the Website. The detailed principles and purposes of the processing of Personal Data collected during the use of the Website by the User are described below.
3.
PURPOSES AND REGULAR GROUNDS FOR PROCESSING DATA ON THE SERVICE USE OF THE SERVICE
3.1. Personal data of all persons using the Service (including IP address or other identifiers and information collected through cookies or other similar technologies), and not being registered Users (i.e. persons who do not have a profile on the Service), are processed by the Administrator:
3.1.1. For the purpose of providing services electronically in the scope of providing Users with access to the content collected on the Website - in which case the legal basis for processing is the necessity of processing for the performance of the agreement (legal basis for processing: Article 6(1)(b) RODO);
3.1.2. For analytical and statistical purposes - then the legal basis for processing is the Administrator's legitimate interest (legal basis for processing: Article 6(1)(f) RODO), consisting of conducting analyses of Users' activities, as well as their preferences in order to improve the applied functionalities and provided services;
3.1.3. For the purpose of possible establishment and investigation of claims or defence against claims - the legal basis of the processing is the legitimate interest of the Administrator (legal basis for processing: Article 6(1)(f) RODO), consisting of the protection of your rights;
3.2 The User's activity on the Website, including his/her Personal Data, is recorded in system logs (a special computer program used to store a chronological record containing information about events and activities that concern the IT system used to provide services by the Administrator). The information collected in the logs is processed primarily for purposes related to the provision of services. The Administrator also processes them for technical, administrative purposes, for the purposes 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 the Administrator's legitimate interest (legal basis for processing: Article 6(1)(f) RODO).
4.
MECHANISMS AND METHODS OF DATA PROCESSING REGISTRATION IN THE SERVICE
4.1 When you register with the Website, you will be asked to provide the data necessary to create and operate your account. In order to facilitate operation, the User may, by using the functionalities made available to him/her within his/her account, provide additional data. Such data can be deleted at any time. The provision of data marked as mandatory is required in order to set up and operate an account, and their failure to do so shall result in the impossibility to set up an account. The provision of other data is voluntary.
4.2 Personal data is processed:
4.2.1. For the purpose of providing services related to the maintenance and operation of an account on the Website - the legal basis for processing is the necessity of processing for the performance of the contract (legal basis for processing: Article 6(1)(b) RODO);
4.2.2. For analytical and statistical purposes - the legal basis of processing is the Administrator's legitimate interest (legal basis for processing: Article 6(1)(f) RODO), consisting of conducting analyses of Users' activity on the Website and the manner of using the account, as well as Users' preferences in order to improve the applied functionalities;
4.2.3. For the purposes of possible establishment and investigation of claims or defence against claims - the legal basis of the processing is the legitimate interest of the Administrator (legal basis for processing: Article 6(1)(f) RODO), consisting in the protection of his/her rights;
4.2.4. For marketing purposes of the Administrator and other entities - the principles of processing Personal Data for marketing purposes are described in the MARKETING section.
4.3 If the User posts any Personal Data of other persons (including their name, address, telephone number or e-mail address) on the Service, he/she may do so only on condition that he/she does not violate the provisions of the law and personal rights of such persons.
PLACING AN ORDER
4.4 The placing of an order (e.g. purchase of goods or services) by a Service User involves the processing of his/her Personal Data. Provision of data marked as mandatory is required in order to accept and handle the order, and their failure to do so results in the order not being processed. Provision of the remaining data is optional.
4.5 Personal Data shall be processed:
4.5.1. For the purpose of processing the order placed - the legal basis for processing is the necessity of processing for the performance of the contract (legal basis for processing: Article 6(1)(b) of the RODO);
4.5.2. In order to comply with statutory obligations incumbent on the Administrator, arising in particular from tax and accounting regulations - the legal basis for processing is a legal obligation (legal basis for processing: Article 6(1)(c) RODO);
4.5.3. For analytical and statistical purposes - the legal basis for processing is the Administrator's legitimate interest (legal basis for processing: Article 6(1)(f) RODO), consisting of conducting analyses of Users' activity on the Website, as well as Users' shopping preferences in order to improve the applied functionalities;
4.5.4. For the purposes of possible establishment and investigation of claims or defence against claims - the legal basis of the processing is the legitimate interest of the Administrator (legal basis of processing: Article 6(1)(f) RODO), consisting in the protection of its rights.
CONTACT FORMS
4.6 The Administrator provides the possibility to contact the Administrator using electronic contact forms or chat. The use of the form requires the User to provide the Personal Data necessary to contact the User and respond to the request. The User may also provide other data in order to facilitate the contact or handling of the enquiry. The provision of data marked as mandatory is required in order to receive and handle the enquiry, and failure to provide such data will result in the impossibility of service. The provision of other data is voluntary.
4.7. Personal data is processed in order to identify the sender and to handle their enquiry sent via the form provided - the legal basis for the processing is the necessity of the processing for the performance of the service contract (legal basis for the processing: Article 6(1)(b) RODO).
5.
MARKETING
5.1 The Administrator processes the Users' Personal Data in order to carry out marketing activities, which may consist in:
5.1.1. Displaying marketing content to the User that is not tailored to the User's preferences (contextual advertising);
5.1.2. Sending e-mail notifications of interesting offers or content, which in some cases contain commercial information (newsletter service);
5.1.3. To carry out other activities related to direct marketing of goods and services (sending commercial information by e-mail and telemarketing activities).
5.2 In order to carry out marketing activities, the Administrator uses profiling in some cases. This means that the Administrator, through automated data processing, creates a profile of the User and on the basis of the collected information evaluates selected factors concerning the Users (e.g. e-mail address, order history, type of device, technology used, frequency of visits, vehicle model) in order to analyse their behaviour as buyers or to create a purchase forecast for the future. This allows the content displayed to be better tailored to the individual preferences
and interests of the user.
CONTEXTUAL ADVERTISING
5.3 The Administrator processes the Users' Personal Data for marketing purposes in connection with directing contextual advertising (i.e. advertising that is not tailored to the User's preferences) to the Users. The processing of Personal Data is then carried out in connection with the fulfilment of the Administrator's legitimate interest (legal basis for processing: Article 6(1)(f) RODO).
NEWSLETTER
5.4 The Administrator provides a newsletter service under the terms and conditions set out in the Terms and Conditions to persons who have provided their e-mail address for this purpose. The provision of data is required in order to provide the newsletter service and failure to do so will result in the newsletter not being sent. This form of communication with the User may include profiling. This means that, through automated data processing, the Administrator, creates a profile of the User and, on the basis of the collected information, evaluates selected factors concerning the Users (e.g. e-mail address, order history, type of device, technology used, frequency of visits) in order to analyse their behaviour as buyers or to create a purchase forecast for the future. This allows the content sent to be better tailored to the User's individual preferences and interests.
5.4 Personal data is processed:
5.4.1. For the provision of the newsletter dispatch service - the legal basis of the processing is the necessity of the processing for the performance of the contract (legal basis for processing: Article 6(1)(b) RODO);
5.4.2. For the purpose of directing marketing content to the User as part of the newsletter - the legal basis for processing, including using profiling, is the legitimate interest of the Administrator (legal basis for processing: Article 6(1)(f) RODO) in relation to the consent to receive the newsletter;
5.4.3. For analytical and statistical purposes - the legal basis of the processing is the legitimate interest of the Administrator, (legal basis for processing: Article 6 (1) (f) RODO), consisting of conducting analyses of Users' activity on the Website in order to improve the applied functionalities;
5.4.4. For the purposes of possible establishment and investigation of claims or defence against claims - the legal basis of the processing is the Administrator's legitimate interest (legal basis of processing: Article 6 (1) (f) RODO), consisting in the protection of its rights.
DIRECT MARKETING
5.5 The User's personal data may also be used by the Administrator to direct marketing content to the User through various channels, i.e. by email, MMS / SMS or telephone. Such activities are undertaken by the Administrator only if the User has given his/her consent, which he/she may withdraw at any time.
5.6 The Administrator may, in certain cases, also carry out direct marketing by post. The User has the right to object to this type of marketing.
6.
SOCIAL NETWORKS
6.1 The Administrator processes the Personal Data of Users visiting the Administrator's profiles conducted on social media (Facebook, YouTube). This data is processed exclusively in connection with
with the running of the profile, including for the purpose of informing Users about the Administrator's activities and promoting various events, services and products. The legal basis for the Administrator's processing of Personal Data for this purpose is its legitimate interest (legal basis for processing: Article 6(1)(f) RODO), consisting of promoting its own brand.
7.
POSTING COMMENTS
7.1 The Administrator provides the possibility of posting comments on the Website. Providing data in the fields marked as "required field" is voluntary, but failure to do so will result in the inability to post a comment. Data publicly visible to all Users are: the pseudonym of the User.
7.2 Personal data is processed for the purpose of publishing a comment within the functionalities provided by the Administrator - the legal basis for processing is the necessity of processing to provide the service (legal basis for processing: Article 6.1.b) RODO).
8.
COOKIES AND SIMILAR TECHNOLOGY
8.1 Cookies are small text files installed on the User's device when browsing the Website.
Cookies collect information to facilitate the use of the Website - for example, by remembering the User's visits to the Website and the actions performed by him.
SERVICE" COOKIES
8.2 The Administrator uses so-called "service cookies" primarily to provide the User with services provided electronically and to improve the quality of such services. In this regard, the Administrator and other entities providing analytical and statistical services to the Administrator use cookies, storing information or accessing information already stored in the User's telecommunications end device (computer, phone, tablet, etc.). Cookies used for this purpose include:
8.2.1. User input cookies (session ID) for the duration of the session;
8.2.2. Authentication cookies used for services requiring authentication for the duration of the session (authentication cookies);
8.2.3. Security cookies, such as those used to detect authentication abuse (user centric security cookies);
8.2.4. Multimedia player session cookies (e.g. flash player cookies), for the duration of the session (multimedia player session cookies);
8.2.5. Persistent cookies used to personalize the User interface for the duration of the session or slightly longer (user interface customization cookies).
9.
ANALYTICAL AND MARKETING TOOLS USED BY THE ADMINISTRATOR'S PARTNERS
9.1 The Administrator and its Partners apply various solutions and tools used for analytical and marketing purposes. Below you will find basic information about these tools. In contrast, detailed information in this regard can be found in the privacy policy of the respective Partner.
GOOGLE ANALYTICS
9.2 Google Analytics cookies are cookies used by Google to analyze your use of the Website, to create statistics and reports on the functioning of the Website. Google does not use the collected data to identify the User, nor does it combine this information to enable identification. Detailed information about 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.
GOOGLE ADS
9.3 Google Ads is a tool that makes it possible to measure the effectiveness of advertising campaigns implemented by the Administrator, allowing analytics of such data as keywords or the number of unique users, for example. The Google Ads platform also allows us to display our ads to people who have visited the Service in the past. Information on Google's data processing for the above service is available at the following link: https://policies.google.com/technologies/ads?hl=pl
FACEBOOK PIXELS
9.4 Facebook Pixels is a tool that allows measuring the effectiveness of advertising campaigns implemented by the Administrator on Facebook. The tool allows advanced data analytics to optimize the Administrator's activities also using other tools offered by Facebook. Detailed information on data processing by Facebook can be found at this link: https://pl-pl.facebook.com/help/443357099140264?helpref=about_content
HOTJAR
9.5 HotJar is a tool that allows the Administrator to conduct analysis of User activity on the Service, such as through surveys or satisfaction surveys, and by anonymously collecting information about clicks on particular areas of the Service. The tool does not allow for User identification. Detailed information about the data collected through HotJar and how to deactivate User monitoring is available at the following link: https://www.hotjar.com/privacy DOUBLECLICK
9.6 DoubleClick is a tool that allows to measure the effectiveness of advertising campaigns implemented by the Administrator (Google Ads campaigns) and to analyze its results.
YOULEAD
9.7. YouLead is a marketing automation tool.
GOOGLE TAG MANAGER
9.8. Google Tag Manager is a tool that allows the Administrator to conduct analysis of Users' activities by enabling management of other analytical or marketing tools used by the Administrator.
10.
11.
PERIOD OF PERSONAL DATA PROCESSING
11.1 The period of data processing by the Administrator depends on the type of service provided and the purpose of processing. As a rule, data shall be processed for the duration of the service provided or the execution of the order, until the withdrawal of the consent given or the filing of an effective objection to data processing in cases where the legal basis for data processing is the legitimate interest of the Administrator.
11.2 The period of data processing may be extended in cases where the processing is necessary for the establishment and assertion of possible claims or defense against claims, and thereafter only in the case and to the extent required by law. After the expiration of the processing period, the data shall be irreversibly deleted or anonymized.
12.
USER PERMISSIONS
12.1 The User shall have the right to access the content of the data and to request rectification, erasure, restriction of processing, the right to data portability and the right to object to the processing of the data, as well as the right to lodge a complaint with the supervisory authority dealing with the protection of Personal Data.
12.2 To the extent that User Data is processed on the basis of consent, this consent may be withdrawn at any time by contacting the Administrator or using the functionalities provided on the Website.
12.3 The User has the right to object to the processing of data for marketing purposes, if the processing is carried out in connection with the legitimate interest of the Administrator, as well as - for reasons related to the User's particular situation - in other cases where the legal basis for data processing is the Administrator's legitimate interest (e.g. in connection with the implementation of analytical and statistical purposes). In order to withdraw your consent, you can contact us by sending an emailto: iod@etop.pl.
13.
DATA RECIPIENTS
13.1 In connection with the performance of services, Personal Data will be disclosed to external entities, including, in particular, suppliers responsible for the operation of IT systems, entities such as banks and payment operators, entities providing accounting services, couriers (in connection with the execution of the order) and entities related to the Administrator.
13.2 If a comment is added to the Service, the User's nickname will be made public along with the content of the comment.
14.
DATA TRANSFER OUTSIDE THE EOG
14.1 The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Administrator transfers Personal Data outside the EEA only when necessary and with an adequate level of protection, primarily by:
14.1.1. Cooperating with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the determination of an adequate level of protection for Personal Data;
14.1.2. Applying standard contractual clauses issued by the European Commission;
14.1.3. Application of binding corporate rules approved by the relevant supervisory authority;
14.1.4. In the case of transfer of data to the U.S., cooperation with entities participating in the Privacy Shield program (Privacy Shield), approved by a decision of the European Commission.
14.2 The Administrator shall always inform of its intention to transfer Personal Data outside the EEA at the stage of collection.
15.
PERSONAL DATA SECURITY
15.1 The Administrator shall, on an ongoing basis, conduct a risk analysis to ensure that the Personal Data is processed by the Administrator in a secure manner - ensuring, first and foremost, that only authorized persons have access to the data and only to the extent necessary for the tasks they perform. The Administrator shall ensure that all operations on Personal Data are recorded and performed only by authorized employees and associates.
15.2 The Administrator shall take all necessary measures to ensure that also its subcontractors and other cooperating entities provide a guarantee of the application of appropriate security measures whenever they process Personal Data on behalf of the Administrator.
16.
CONTACT DETAILS
16.1 Contact with the Administrator is possible by e-mail address etop@etop.pl or mailing address Etop sp. z o.o. , 200 Jerozolimskie Avenue, 02-222 Warsaw.
16.2 The Administrator has appointed a Personal Data Protection Supervisor, who can be contacted via e-mail iod@etop.pl or by correspondence to the Administrator's address marked "Personal Data Protection Supervisor" in any matter concerning the processing of Personal Data.
16.3 You have the right of access to the content of your data and the right to rectification, erasure, restriction of processing, the right to data portability, the right to object (e.g. if your data is processed on the basis of your consent, or for marketing purposes or sharing your data); you have the right to withdraw your consent at any time. To revoke your consent, you may contact the customer service desk at eTOP Ltd. or by sending an email to: iod@etop.pl. Your provision of personal data is fully voluntary. Failure to provide personal data will result in the inability to fully perform the obligations assumed by eTOP sp. z o.o. under the agreements concluded with you.
17.
PRIVACY POLICY CHANGES
17.1 The Policy shall be reviewed on an ongoing basis and updated as necessary.
17.2 The current version of the Policy has been adopted and is effective as of 01.01.2020.
18.
RECRUITMENT INFORMATION CLAUSE
18.1 Information about personal data processing
eTOP sp. z o.o. is headquartered at 200 Jerozolimskie Avenue, 02-222 Warsaw, Poland. eTOP sp. z o.o. pays significant attention to the protection of personal data, therefore it has decided to appoint a Data Protection Officer, who can be contacted by traditional mail (address above), e-mail at: "iod@etop.pl". eTOP sp. z o.o. encourages contact via e-mail.
18.2 Data Administrator
In connection with the recruitment, the controller of your data is eTOP sp. z o.o., which will process your personal data for the purpose of the recruitment process.
18.3 Acquisition of data and the purpose of their processing
The processing of your data for the purpose of conducting the recruitment process is carried out on the basis of:
- On the basis of Article 6(1)(b) of the 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), hereinafter referred to as "RODO", i.e. for the purposes of concluding a contract of employment or cooperation;
- On the basis of Article 6(1)(a) of the RODO, i.e. the expressed consent to process personal data to the extent not required by the provisions of the Labor Code and in the case of consent to participate in future recruitments;
- Based on Article 9(2)(b) of the RODO in the scope of data processing for the purpose of determining the employee's fitness for work
Provision of data to the extent required by the Labor Code is mandatory, and to the remaining extent voluntary.
Your data, in the case of failure to conclude a contract, should be deleted at the end of the recruitment process. The administrator, without additional consent of the data subject, may keep the data of candidates who have not been hired for up to 6 months after the end of the recruitment process as a legitimate purpose of the administrator due to the fact that the hired person may not prove himself in the job or may resign. In the case of consent for further recruitment processes, no longer than one year.
The data may also be processed by automated means, including being used for profiling, but such processing will not have any legal effect or materially affect you.
18.4 Recipients of data
The data may be accessed on the basis of concluded agreements and for strictly defined purposes by entities providing ICT solutions, auditing entities, state authorities or other entities authorized under the law, in order to fulfill the obligations incumbent on eTOP sp. z o.o.. Data will be processed in Poland, possibly in the European Economic Area.
18.5 Rights with respect to the processed data
A person whose data is processed by the controller has the right to request access to the data, rectification, i.e. correction, deletion or restriction of processing, and to object to processing, as well as the right to data portability. More information on data subjects' rights is available in Articles 12-23 of the General Data Protection Regulation (RODO/GDPR), the text of which can be found at: https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679
In addition, you have the right to lodge a complaint to the supervisory authority, Prezesa Urzędu Ochrony Danych Osobowych, , more information at: https://uodo.gov.pl/pl/p/skargi