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Privacy policy and cookies

  1. GENERAL PROVISIONS

    1. The controller of personal data collected via the website polwingo.com is POLWINGO sp. z o.o., NIP: 6463022780, REGON: 542403540, email: office@polwingo.com (the “Controller”), who is also the Service Provider.

    2. Personal data collected through the website are processed in accordance with Regulation (EU) 2016/679 (GDPR) and the Polish Personal Data Protection Act of 10 May 2018.

    TYPES OF DATA, PURPOSES AND SCOPE OF PROCESSING

    A. Purposes and legal bases

    1. Contact form
      Processed under Art. 6(1)(f) GDPR (legitimate interest of the Controller).

    2. Newsletter subscription / commercial information by email
      Processed on the basis of consent, Art. 6(1)(a) GDPR.

    B. Categories of personal data

    1. First name and last name

    2. Address (residential)

    3. Email address

    4. Phone number

    C. Retention periods

    1. Contract performance as legal basis
      Stored for the time necessary to perform the contract, then for the limitation period for claims. Unless a special provision states otherwise: 6 years, and for periodic claims and claims related to business activity: 3 years.

    2. Consent as legal basis
      Stored until consent is withdrawn, then for the limitation period for claims that may be pursued by or against the Controller. Unless a special provision states otherwise: 6 years, and for periodic claims and claims related to business activity: 3 years.

    D. Additional data collected during website use

    1. Technical information: user IP address or external IP of the ISP, domain name, browser type, access time, operating system type.

    2. Navigation data: links and references clicked and other actions taken on the website, processed under Art. 6(1)(f) GDPR (facilitating electronic services and improving their functionality).

    3. Providing personal data by the user is voluntary.

    4. Data may be processed automatically, including profiling, if the user gives consent under Art. 6(1)(a) GDPR. Profiling may result in assigning a profile to a person to make decisions concerning them or to analyze or predict their preferences, behaviors, and attitudes.

    E. Data protection principles ensured by the Controller

    1. Processing is lawful.

    2. Data are collected for specified, lawful purposes and not further processed in a way incompatible with those purposes.

    3. Data are factually correct, adequate, and kept in a form permitting identification of data subjects no longer than necessary for the purposes of processing.

    DISCLOSURE OF PERSONAL DATA

    1. Data may be disclosed to service providers used by the Controller to operate the website. Depending on contractual arrangements, such providers either act on the Controller’s instructions as processors or determine purposes and means of processing as independent controllers.

    2. Users’ personal data are stored exclusively within the European Economic Area (EEA).

    RIGHTS OF THE DATA SUBJECT

    1. The data subject has the right of access, rectification, erasure, restriction of processing, data portability, objection, and the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.

    2. Legal bases:

      • Access – Art. 15 GDPR

      • Rectification – Art. 16 GDPR

      • Erasure (“right to be forgotten”) – Art. 17 GDPR

      • Restriction – Art. 18 GDPR

      • Portability – Art. 20 GDPR

      • Objection – Art. 21 GDPR

      • Withdrawal of consent – Art. 7(3) GDPR

    3. To exercise these rights, send an email to: office@polwingo.com.

    4. The Controller will fulfill or refuse the request without undue delay and no later than one month after receipt. Due to the complexity or number of requests, this period may be extended by two further months; the user will be informed within one month of receipt about the extension and its reasons.

    5. If processing violates GDPR, the data subject has the right to lodge a complaint with the President of the Personal Data Protection Office (PUODO).

    COOKIES

    1. The website uses cookies.

    2. Installing cookies is necessary for the proper provision of services on the website. Cookies contain information required for correct operation and enable general visit statistics.

    3. Types used: session cookies. Session cookies are temporary and stored on the user’s device until logout (leaving the site).

    4. The Controller uses first-party cookies to better understand user interactions with site content. These cookies collect information on how the site is used, the referring site type, number of visits, and visit duration. This information does not record specific personal data and is used to compile site usage statistics.

    5. Users can manage cookie access via their browser settings. Detailed information on handling cookies is available in the software (browser) settings.

    FINAL PROVISIONS

    1. The Controller applies technical and organizational measures appropriate to the risks and categories of data, protecting data against access by unauthorized persons, removal by unauthorized persons, processing contrary to applicable regulations, and against alteration, loss, damage, or destruction.

    2. The Controller provides appropriate technical measures preventing unauthorized acquisition and modification of personal data transmitted electronically.

    3. In matters not regulated by this Privacy Policy, the provisions of the GDPR and other applicable Polish law shall apply accordingly.