Privacy and cookies policy

1. DEFINITIONS

1.1 Administrator – Umbrella NetCon Sp. z o.o. with its registered office in Warsaw, 36/112 B Ken Avenue, 02-797 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 identifier and information collected through cookies and other similar technology.
1 1.3 Policy – this Privacy Policy..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 www.ProfiFold.pl.
1.6. User – any natural person visiting the Service or using one or more of the services or functionalities described in the Policy.

2. PROCESSING OF DATA IN CONNECTION WITH THE USE OF THE SITE

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. Detailed rules and purposes of processing of Personal Data collected during the User’s use of the Website are described below.

3. PURPOSES AND LEGAL BASIS OF DATA PROCESSING ON THE SITE

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 who are not registered Users (i.e. persons who do not have a profile on the Service), are processed by our administrator.
3.1.1. for the purpose of providing services electronically in the scope of providing Users with access to content collected on the Website – in which case the legal basis for processing is the necessity of processing for the performance of the agreement (Article 6(1)(b) RODO);
3.1.2. for analytical and statistical purposes, in which case the legal basis for processing is the Administrator’s legitimate interest (Article 6(1)(f) RODO), consisting of conducting analyses of Users’ activities, as well as their preferences in order to improve the functionalities used and services provided;
3.1.3. for the purpose of possible establishment and assertion of claims or defense against claims – the legal basis of processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO), consisting in the protection of its rights;
3.1.4. for the marketing purposes of the Administrator and other entities, in particular related to the presentation of behavioral advertising – the principles of processing Personal Data for marketing purposes are described in the MARKETING section

3.2 The User’s activity on the Service, 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 relate to the computer 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 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 the Administrator’s legitimate interest (Article 6(1)(f) RODO).

SITE REGISTRATION

3.3 Those who register on the Website are asked to provide the data necessary to create and operate an account. In order to facilitate the service, the User may provide additional data, thereby consenting to its processing. Such data can be deleted at any time. Provision of data marked as mandatory is required to create and operate an account, and failure to provide such data will result in the inability to create an account. Provision of other data is voluntary.
3.4 Personal data is processed:
3.4.1. 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 (Article 6.1.b RODO);
3.4.2. for analytical and statistical purposes – the legal basis of processing is the Administrator’s legitimate interest (Article 6.1.f RODO), consisting of conducting analyses of Users’ activity on the Website and the way they use their account, as well as Users’ preferences in order to improve the applied functionalities;
3.4.3. for the purpose of possible establishment and investigation of claims or defense against claims – the legal basis of processing is the legitimate interest of the Administrator (Article 6.1.f RODO), consisting in the protection of the User’s rights;
3.4.4. for marketing purposes of the Administrator and other entities – the principles of processing Personal Data for marketing purposes are described in the MARKETING section.
3..5. if the User posts any Personal Data of other persons (including their name, address, telephone number or e-mail address) on the Website, he/she may do so only on condition that he/she does not violate the laws and personal rights of such persons.

ORDERING

3.6 Placing an order (purchase of goods) by a Service User involves the processing of his Personal Data. Provision of data marked as mandatory is required in order to accept and process the order, and failure to provide such data will result in failure to process the order. Provision of other data is optional.
3.7. personal data are processed:
3.7.1. for the purpose of fulfilling the order placed – the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) RODO);
3.7.2. for the purpose of fulfilling statutory obligations incumbent on the Administrator, resulting in particular from tax and accounting regulations – the legal basis for processing is a legal obligation (Article 6(1)(c) RODO);
3.7.3. for analytical and statistical purposes – the legal basis of processing is the legitimate interest of the Administrator (Article 6.1.f RODO), consisting of conducting analysis of Users’ activity on the Website, as well as Users’ shopping preferences in order to improve the applied functionalities;
3.7.4. for the purpose of possible establishment and investigation of claims or defense against claims – the legal basis of processing is the legitimate interest of the Administrator (Article 6.1.f RODO), consisting of protecting its rights.

CONTACT FORMS

3.8 The Administrator shall provide the possibility of contacting him using electronic contact forms. Using the form requires providing Personal Data necessary to contact the User and respond to the inquiry. The User may also provide other data in order to facilitate contact or service the inquiry. Provision of data marked as mandatory is required in order to accept and service the inquiry, and failure to provide such data will result in the impossibility of service. Provision of other data is voluntary.
3.9. Personal data is processed:
3.9.1. for the purpose of identifying the sender and handling his/her inquiry sent via the form provided – the legal basis for processing is the necessity of processing for the performance of the service contract (Article 6.1.b RODO);
for data provided optionally, the legal basis for processing is consent (Article 6.1.a RODO).

4. MARKETING

4.1 The Administrator processes the Users’ Personal Data in order to carry out marketing activities, which may consist of:
4.1.1. displaying to the User marketing content that is not tailored to the User’s preferences (contextual advertising);
4.1.2. displaying to the User marketing content that corresponds to the User’s interests (behavioral advertising);
4.1.3. Directing e-mail notifications about interesting offers or content, which in some cases contain commercial information (newsletter service);
4.1.4. Conducting other types of activities related to direct marketing of goods and services (sending commercial information by e-mail and telemarketing activities).
4.2 In order to carry out marketing activities, the Administrator uses profiling in some cases. This means that through automatic data processing, the Administrator evaluates selected factors concerning Users in order to analyze their behavior or create a forecast for the future. This allows the content displayed to be better tailored to the individual preferences and interests of the User.

CONTEXTUAL ADVERTISING

4.3 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 realization of the Administrator’s legitimate interest (Article 6.1.f RODO).

BEHAVIORAL ADVERTISING

4.4 The Administrator and its trusted partners process Users’ Personal Data, including Personal Data collected through cookies and other similar technologies, for marketing purposes in connection with targeting Users with behavioral advertising (i.e., advertising that is tailored to the User’s preferences).
4.5 The processing of Personal Data also includes profiling of Users.

NEWSLETTER

4.6 The Administrator provides the newsletter service under the terms and conditions of the Regulations to those who have provided their e-mail address for this purpose. Provision of data is required in order to provide the newsletter service, and failure to do so results in the inability to send the newsletter.
This form of communication with the User may include profiling.
4.7 Personal data are processed:
4.7.1. for the purpose of providing the newsletter mailing service – the legal basis for the processing of
is the necessity of processing for the performance of the contract (Article 6(1)(b) RODO); 4.7.2. in the case of directing marketing content to the User as part of the newsletter – the legal basis for processing, including with the use of profiling, is the legitimate interest of the Administrator (Article 6(1)(f)
RODO) in connection with the consent to receive the newsletter;
4.7.3. for analytical and statistical purposes – the legal basis of processing is the legitimate interest of the Administrator, (Article 6(1)(f) RODO), consisting of conducting analyses of Users’ activity on the Website in order to improve the applied functionalities;
4.7.4. for the purpose of possible establishment and investigation of claims or defense against claims – the legal basis of processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO), consisting of protecting its rights.

5. SOCIAL NETWORKS

5.1 The Administrator processes Personal Data of Users visiting the Administrator’s profiles maintained on social media (Facebook, YouTube, Twitter, Google+). The Data is processed in connection 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 (Article 6(1)(f) of the DPA) in promoting its own brand. For more information, please visit our social media profiles.

6. POSTING OPINIONS AND COMMENTS

6.1 The Administrator provides the possibility of posting opinions and comments on the Website. Providing data in the fields marked as “required field” is voluntary, but their absence will result in the inability to post opinions or comments. The User can decide on the scope of Data, which is publicly visible to all Users.
6.2. Personal Data is processed:
6.2.1. for the purpose of publishing an opinion or comment within the functionalities provided by the Administrator – the legal basis for processing is the necessity of processing to provide the service (Article 6.1(b) RODO);
6.2.2. for the purpose of moderation of an opinion or comment (including elimination of spam) – then the legal basis for processing is the Administrator’s legitimate interest (Article 6.1(f) RODO), consisting of approving comments added by Users and making them public.

7. COOKIES AND SIMILAR TECHNOLOGY

The Administrator uses cookies mainly to provide the User with services provided electronically. 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.).

ESSENTIAL COOKIES

7.1 The Administrator uses necessary cookies primarily to provide Users with the services and functionalities of the Website that the User wants to use. Necessary cookies may only be installed by the Administrator through the Service.
7.2 The legal basis for data processing in connection with the use of necessary cookies is the necessity of processing for the performance of the contract (Article 6(1)(b) of the RODO)

FUNCTIONAL AND ANALYTICAL COOKIES

7.3 Functional cookies are used to remember and customize the Site according to the User’s choices, and may be installed by the Administrator and its partners through the Site.
7.4 Analytical cookies enable the acquisition of information such as the number of visits and traffic sources on the Site. They are used to determine which pages are more and which are less popular, and to understand how Users navigate the Site by keeping statistics on traffic on the Site. The processing is done to improve the performance of the Website and may be installed by the Administrator and its partners through the Website.
7.5 The legal basis for the processing of Personal Data in connection with the use of necessary and analytical cookies by the Administrator, for this purpose, is its legitimate interest (Article 6(1)(f) RODO), which is to ensure the highest quality of services provided on the
Service 7.6 The processing of Personal Data in connection with the use of functional and analytical cookies is subject to the User’s consent to the use (separately) of functional and analytical cookies. This consent can be withdrawn at any time through this platform

ADVERTISING COOKIES

7.7 Advertising (Marketing) cookies allow to adjust the displayed advertising content of the Users’ interests within the Service and outside the Service. Based on the information from these cookies and the User’s activity, the User is profiled. Advertising cookies may be installed by the Administrator and its partners through our website.
7.8. The legal basis for the processing of Personal Data in connection with the use of advertising cookies by the Administrator, for this purpose, is its legitimate interest (Article 6(1)(f) RODO).
7.9. The processing of Personal Data using cookies is possible after obtaining consent which can be withdrawn at any time.

8. ANALYTICAL AND MARKETING TOOLS USED BY THE ADMINISTRATOR’S PARTNERS

8.1 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 turn, detailed information in this regard can be found in the privacy policy of the respective Partner.

GOOGLE ANALYTICS

8.2 Google Analytics cookies are files used by Google to analyze how the User uses 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 ADWORDS
8.3 Google AdWords is a tool that allows measuring the effectiveness of advertising campaigns implemented by the Administrator, allowing analytics such as keywords or the number of unique users. The Google Adwords 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 / META

8.4 Facebook Pixels is a tool to measure 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://plpl.facebook.com/help/443357099140264?helpref=about_content.

9. MANAGING COOKIE SETTINGS

9.1 The use of cookies for the purpose of collecting data through them, including gaining access to data stored on the User’s device, requires the User’s consent. This consent may be withdrawn at any time.
9.2. Permission is not required only for cookies, the use of which is necessary for the provision of the telecommunications service (data transmission to display content).
9.3. Withdrawal of consent for the use of cookies is possible through browser settings. Detailed information on this subject can be found at the following links:
9.3.1. Internet Explorer: https://support.microsoft.com/pl-pl/help/17442/windows-internetexplorer-delete-manage-cookies
9.3.2. Mozilla Firefox: http://support.mozilla.org/pl/kb/ciasteczka
8/9
9.3.3. Google Chrome:
http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
9.3.4. Opera: http://help.opera.com/Windows/12.10/pl/cookies.html
9.3.5. Safari: https://support.apple.com/kb/PH5042?locale=en-GB
9.4. The User may at any time verify the status of his/her current privacy settings for the browser used using the tools available at the following links:
9.4.1. http://www.youronlinechoices.com/pl/twojewybory
9.4.2. http://optout.aboutads.info/?c=2&lang=EN

10. PERIOD OF PROCESSING OF PERSONAL DATA

10.1 The period of data processing by the Administrator depends on the type of service provided and the purpose of processing. As a general rule, data are processed for the duration of providing the service or fulfilling the order, until the withdrawal of the expressed consent or filing of an effective objection to data processing in cases where the legal basis for data processing is the legitimate interest of the Administrator.
10.2 The period of data processing may be extended in cases where the processing is necessary for the establishment and investigation 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.

11. USER RIGHTS

11.1 The User has the right to access the content of the data and to request their 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 to the supervisory authority dealing with the protection of Personal Data.
11.2 To the extent that the User’s data are processed on the basis of consent, the consent may be withdrawn at any time by contacting the Administrator.
11..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).

12. DATA RECIPIENTS

12.1 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 performance of an order), marketing agencies (in connection with marketing services) and entities related to the Administrator,
including companies in its capital group.
12.2 The Administrator reserves the right to disclose selected information concerning the User to competent authorities or third parties who submit a request for such information, based on the relevant legal basis and in accordance with the provisions of the applicable law.

13. TRANSFER OF DATA OUTSIDE THE EOG

13.1 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:
13.1.1. cooperating with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the determination to ensure an adequate level of protection of
Personal Data;
13.1.2. application of standard contractual clauses issued by the European Commission;
13.1.3. application of binding corporate rules approved by the competent
supervisory authority;
13.2. The Controller shall always inform about the intention to transfer Personal Data outside the EEA
at the stage of collection.

14. SECURITY OF PERSONAL DATA

14.1 The Administrator shall, on an ongoing basis, conduct a risk analysis to ensure that
Personal Data is processed by it 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.
14.2 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.

15. CONTACT INFORMATION

15.1 Contact with the Administrator is possible through the mailing address of Umbrella NetCon Sp. z o.o.
Aleja Ken 36/112 B, 02-797 Warsaw
15.2 The Administrator has appointed a Data Protection Supervisor with whom you can contact
by mail at the above address on any matter concerning the processing of Personal Data.

16. PRIVACY POLICY CHANGES

16.1 The Policy is continuously reviewed and updated as necessary.
16.2 The current version of the Privacy Policy is effective as of 01/08/2023.