§ 1 General provisions
- This document defines the Privacy Policy of https://loneworker.pl/, run by "NOVATEL" spółka z ograniczoną odpowiedzialnością with its registered office in Bieruń (43-155) at ul. Turystyczna 1, registered in the register of entrepreneurs kept by the District Court of Katowice-Wschód in Katowice, VIII Economic Department of the National Court Register under KRS no.: 147518, with REGON no.: 270098047 and NIP no.: 6340134843, with the share capital of PLN 50,400.00, which in particular includes regulations on personal data protection and security of other data entered into the Service by the User.
- The Privacy Policy is an integral appendix to the Regulations of the "Novatel" online shop, which is available HERE.
§ 2 Definitions
Terms used in this document mean:
- The controller of personal data (also referred to as the Administrator) - "NOVATEL" spółka z ograniczoną odpowiedzialnością with its registered office in Bieruń (43-155) at ul. Turystyczna 1, registered in the register of entrepreneurs kept by the District Court Katowice-Wschód in Katowice, VIII Economic Department of the National Court Register under KRS no.: 147518, holding REGON no.: 270098047 and NIP no.: 6340134843, with a share capital of PLN 50,400.00;
- Service - website at https://loneworker.pl/ and all its sub-sites;
- User - a natural person who uses the Website and provides personal data as part of the Website;
- Personal data - information about a natural person identified or identifiable by one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity, including an image, a voice recording, contact details, location data, information contained in correspondence, information collected through recording equipment or other similar technology;
- RODO - 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;
- Regulations - Rules and regulations of the "NOVATEL" online shop, available at https://loneworker.pl/. HERE.
§ 3 Protection of Personal Data
- The controller is the controller of personal data within the meaning of the RODO.
- The controller collects and processes personal data in accordance with the relevant legislation, including in particular the RODO, and in accordance with the principles provided for in that legislation.
- The Administrator informs about the processing of data at the moment of their collection. The Administrator processes data to the extent, time and purposes each time indicated in the content provided under the forms used to collect personal data from the User or in this Privacy Policy.
- The Administrator transfers Personal Data only to the Administrator's trusted subcontractors, i.e. suppliers responsible for the operation of IT systems, entities such as banks and payment operators, accounting and legal service providers, marketing agencies (for marketing services).
- The Administrator shall have the right to communicate selected Personal Data of the User to competent authorities and third parties if such a necessity arises from the applicable legislation and if these entities make a request for such data on the basis of an appropriate legal basis.
- The Administrator shall ensure the security of the processed Personal Data and its confidentiality, and shall allow the User access to information about the data processing. If, despite the security measures in place, a breach of the protection of Personal Data occurred (e.g. a "leak" of data or a loss of data) and such a breach could cause a high risk of infringement of the User's rights or freedoms, the Administrator shall inform the User of such an event in accordance with the regulations.
- The user can contact the data controller. The contact details are as follows:
- mailing address: "NOVATEL" spółka z ograniczoną odpowiedzialnością with registered office in: Bieruń (43-155), ul. Turystyczna 1;
- e-mail address: handel@novatel.pl;
- telephone number: +48 32 201 17 04.
§4 Security of Personal Data
- The Administrator uses all the technical and organisational possibilities at his disposal to ensure the security of the User's personal data and to protect them against accidental or intentional destruction, accidental loss, modification, unauthorised disclosure or access. Users' personal data is stored and processed on high-security servers, with appropriate security measures that meet the requirements of Polish law.
- Entrusted data is stored on top-of-the-range hardware and servers in appropriately secure information storage centres, to which only authorised persons have access.
- The Controller shall carry out personal data processing activities respecting all legal and technical requirements imposed on him by the personal data protection legislation. The Administrator shall analyse on an ongoing basis the risks involved in his/her processing of personal data and shall ensure that only authorised persons have access to the data and only to the extent necessary for the performance of their duties.
- The Administrator shall take all necessary measures to ensure that also its subcontractors and other cooperating entities guarantee the application of appropriate security measures whenever they process Personal Data on behalf of the Administrator.
- The Administrator undertakes to keep a security copy containing the User's personal data.
§ 5 User rights
- If personal data changes, the User should update it by sending a relevant message to the Administrator.
- The user has the following rights:
- The right to be informed about the processing of Personal Data,
- The right to obtain a copy of the Personal Data that the Administrator processes,
- The right to rectification of Personal Data,
- The right to erasure of Personal Data (on this basis, you can request the erasure of data whose processing is no longer necessary for any of the purposes for which they were collected),
- The right to restrict the processing of Personal Data,
- The right to portability of Personal Data,
- The right to object to the processing of Personal Data for marketing purposes (the User may object to the processing of Personal Data for marketing purposes at any time, without having to justify such objection),
- The right to object to other purposes of processing (the User may object at any time - on grounds relating to his/her particular situation - to the processing of Personal Data that is carried out on the basis of a legitimate interest of the Controller; such objection shall require a justification),
- The right to withdraw consent, where Personal Data is processed on the basis of consent given (withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal),
- The right to lodge a complaint with the supervisory authority for the processing of Personal Data, which has jurisdiction over the User's habitual place of residence, place of work or the place where the alleged infringement was committed. In Poland, the supervisory authority is the President of the Office for Personal Data Protection.
- The Administrator may refuse to delete the User's personal data if the preservation of the personal data is necessary due to an obligation imposed on the Administrator by law.
- The user has the right to submit a request for the exercise of his/her rights as indicated above by letter or electronic means (e-mail). The contact details of the Administrator are indicated in § 3 section 7.
- Where, on the basis of the request referred to in paragraph 4, the Administrator is unable to establish and identify the natural person to whom the request relates, it shall request additional information from the applicant. Failure to provide additional information will result in a refusal to comply with the applicant's request.
- Where, on the basis of the request referred to in paragraph 4, the Administrator is unable to establish and identify the natural person to whom the request relates, it shall request additional information from the applicant. Failure to provide additional information will result in a refusal to comply with the applicant's request.
§ 6 Basis, Purpose and Period of Storage of Personal Data
- Personal data is processed for the following purposes and on the following grounds:
- Use of the Website - Personal data of all persons using the Website (including IP address or other identifiers and information collected through cookies or other similar technologies), is processed by the Administrator in order to:
- the provision of services by electronic means (legal basis: the necessity of the processing for the performance of the contract - Article 6(1)(b) RODO),
- for analytical and statistical purposes (legal basis: the Administrator's legitimate interest - Article 6(1)(f) RODO, which is to conduct analyses of Users' activities, as well as of their preferences in order to improve the applied functionalities and provided services),
- Establishing and pursuing claims or defending against claims (legal basis: the Administrator's legitimate interest - Article 6(1)(f) RODO, which is to protect the Administrator's rights),
- for marketing purposes of the Administrator and other entities, in particular related to the presentation of behavioural advertising (legal basis: consent - Article 6(1)(a) RODO).
- Requesting a quote and accepting an offer - in order to request a quote and place an order on the Website, the User is requested to provide the Personal Data indicated in the request for quote form and the data necessary to complete the order, which the User should send in the e-mail confirming acceptance of the offer (name and surname, company, address, e-mail address, telephone number). The provision of data is not obligatory, but refusal to provide such data results in the impossibility of submitting an enquiry for a quotation or an order. The Personal Data indicated by the User is processed by the Administrator in order to:
- the provision of services by electronic means (legal basis: the necessity of the processing for the performance of the contract - Article 6(1)(b) RODO),
- for analytical and statistical purposes (legal basis: the Administrator's legitimate interest - Article 6(1)(f) RODO, which is to conduct analyses of Users' activities, as well as of their preferences in order to improve the applied functionalities and provided services),
- Establishing and pursuing claims or defending against claims (legal basis: the Administrator's legitimate interest - Article 6(1)(f) RODO, which is to protect the Administrator's rights),
- for marketing purposes of the Administrator and other entities, in particular related to the presentation of behavioural advertising (legal basis: consent - Article 6(1)(a) RODO).
- Newsletter - Users who have expressed their wish to the Administrator to receive e-mails with commercial information content. Signing up for the Newsletter involves providing the Administrator with the User's Personal Data. Providing such data is not obligatory, but refusal to provide it results in inability to provide the Newsletter service. The sending of the Newsletter may involve profiling. The Personal Data indicated by the User is processed by the Administrator in order to:
- the provision of services by electronic means (legal basis: necessity of processing for the performance of the contract - Article 6(1)(b) RODO- in the scope of data necessary for the dispatch of the Newsletter, in the scope of optional data legal basis: consent - Article 6(1)(a) RODO),
- for analytical and statistical purposes (legal basis: the Administrator's legitimate interest - Article 6(1)(f) RODO, which is to conduct analyses of Users' activities, as well as of their preferences in order to improve the applied functionalities and provided services),
- Establishing and pursuing claims or defending against claims (legal basis: the Administrator's legitimate interest - Article 6(1)(f) RODO, which is to protect the Administrator's rights),
- for the Administrator's marketing purposes - directing marketing content via the Newsletter, (legal basis: the Administrator's legitimate interest - Article 6(1)(f) RODO - dictated by the User's consent to use the Newsletter 'a service).
- Marketing - The Administrator processes the Users' Personal Data in order to carry out marketing activities, which may consist in particular in displaying marketing content corresponding to the User's interests or sending commercial information by electronic means for the purposes of direct marketing of goods and services. In this case, the User's Personal Data is processed by the Administrator on the basis of the User's consent (Art. 6(1)(a) RODO), which may be withdrawn. The fulfilment of the Administrator's marketing purposes may be carried out through profiling, which involves the automatic processing of Personal Data and its evaluation in order to analyse the User's behaviour and create a forecast for the future, which is sued for displaying content to the User in accordance with the User's individual preferences and interests.
- Contact form, traditional and electronic correspondence (e-mail) - the User may send messages to the Administrator by post, using e-mail with the Administrator's contact details available in the Service, the Terms of Use or this Privacy Policy, as well as through the contact form available in the Service. Personal Data contained in such correspondence shall be used by the Administrator solely for the purpose of communication and settlement of the matter to which the correspondence relates. The basis for the processing of the Data is the legitimate interest of the Administrator - Article 6(1)(f) of the DPA - consisting in the maintenance of the correspondence addressed to it in connection with its business activity, and in the case of contact related to the services provided or a contract - the necessity of the processing to perform the contract - Article 6(1)(b) of the DPA.
- Telephone contact - the User may contact the Administrator by telephone for the purposes related to the services provided or the contract concluded as well as for other matters. In the case of telephone contact in matters not related to the concluded contract or the provided service, the Administrator may require the User to provide Personal Data only if it is necessary to handle the reported matter. The legal basis for the processing of Personal Data is the legitimate interest of the Administrator - Article 6(1)(f) RODO - consisting in the necessity to resolve the reported matter related to the Administrator's business activity, and in the case of contact related to the services provided or the contract - the necessity of the processing to perform the contract - Article 6(1)(b) RODO.
- Social media profiles - The Administrator has profiles on social media (including Facebook and LinkedIn). The Administrator processes Personal Data left by persons responding to the profiles, e.g. comments or web IDs. The Administrator uses this data in order to run the profiles effectively, to enable activity on these profiles, as well as for analytical or statistical purposes. The legal basis for the processing of Personal Data is the Administrator's legitimate interest - Article 6(1)(f) RODO - consisting in the promotion of its activities and services provided, possibly for the purpose of asserting claims or defending against third-party claims. The above does not apply to the processing of personal data by social networks. Please refer to their Personal Data processing policies for the processing of data by social networks.
- The duration of data processing depends on the service provided, the purpose and the basis for processing. As a rule of thumb, data shall be processed for the duration of the service provided or the execution of the order. Where the basis for the processing of Personal Data is consent, the data are processed until the consent is effectively withdrawn. Where the basis for the processing of Personal Data is the legitimate interest of the Administrator, the data are processed until an effective objection is made.
- The period of processing of the Personal Data referred to in paragraph 2 may be extended in case the processing is necessary for the establishment, investigation and defence of possible claims. After this period, the Personal Data may be processed only if and to the extent required by the provisions of the applicable law.
- At the end of the processing period, the Personal Data is deleted or irreversibly anonymised.
§ 7 Cookies policy
- The Administrator uses cookies. Cookies are small text files sent (saved) by the Website on the User's terminal device (e.g. computer, smartphone).
- The Administrator uses cookies to provide services electronically, to improve and enhance their quality, as well as for analytical and statistical purposes and to adapt the Website to the needs of its Users. Through the use of cookies, the Administrator personalises content and advertising. The Administrator shares information about how the User uses the Website with trusted social, advertising and analytics partners in order to provide the best possible service in terms of e-commerce operation, analytics, customisation and personalisation. A list of trusted partners can be found below:
- Google LLC. (Google Analytics) - privacy policy: https://policies.google.com/privacy?hl=pl-pl;
- WordPress.org - privacy policy: https://pl.wordpress.org/about/privacy/;
- MailerLite - privacy policy: https://www.mailerlite.com/legal/privacy-policy.
- Microsoft Corporation - privacy policy: https://privacy.microsoft.com/pl-PL/privacystatement
- Three types of cookies are used within the Service: "temporary", "session" and "permanent". "Temporary" cookies are stored for a predetermined period of time, calculated in days or years. "Session" cookies are stored on the User's terminal equipment until the User logs out, leaves the website or switches off the software (web browser). "Permanent" cookies are stored on the User's terminal equipment for the time specified in the parameters of the cookies or until they are deleted by the User.
- The Administrator uses or reserves the right to use the following types of cookies on the Website:
- indispensable - they enable the use of the services and functionalities available on the Website, e.g. used for User authentication;
- preferential - they enable the User's choices to be remembered and customised on the Website, e.g. with regard to language preferences, font size, appearance of the Website, etc;
- marketing and advertising - to adapt the content displayed on and off the Website, including advertising, to the interests of Users. The presentation of personalised content may be based on browsing history, website activity (e.g. shopping history, use of services, type of content and advertising displayed) or geolocalisation data. A profile of the User's interests may be built on the basis of information from the Website and the User's activity on other websites;
- analytical - they enable a range of information to be obtained, including the number of visits and sources of traffic on the Website. The collection of this data is used to determine which pages are most frequently visited and leads to the creation of statistics on traffic on the Website. The collection of this data is used by the Administrator to improve the efficiency of the Website. The collected data is processed in anonymised form;
- unclassified - this group includes cookies that could not be classified in the above-mentioned groups.
- Preferred, analytical, marketing and advertising and unclassified cookies may be installed by the Administrator and its trusted partners through the Service.
- The legal basis for data processing in connection with the use of essential cookies is the necessity of the processing of Personal Data for the performance of the contract (Article 6(1)(b) RODO). In the case of other cookies, the basis for processing Personal Data is the legitimate interest of the Administrator or the consent of the User (Article 6(1)(a) and (f) RODO). In order to use preferential, analytical and marketing-advertising cookies and unclassified cookies, the Administrator must obtain the User's consent.
- The consent referred to in paragraph 6 shall be given by means of the relevant form displayed when you first visit the Website. The consent given may be withdrawn or adapted differently at any time. To amend or withdraw the consent given, click on HERE.
- The User can modify their cookie settings from their web browser. Links to web browsers (containing information on how to modify their settings on the User's terminal equipment) are provided below:
- Chrome – https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DDesktop&hl=pl
- Internet Explorer - https://support.microsoft.com/pl-pl/help/278835/how-to-delete-cookie-files-in-internet-explorer
- Firefox - https://support.mozilla.org/pl/kb/usuwanie-ciasteczek-i-danych-stron-firefox?redirectlocale=pl&redirectslug=usuwanie-ciasteczek
- Opera - https://help.opera.com/pl/latest/web-preferences/#cookies
- Microsoft Edge – https://support.microsoft.com/pl-pl/microsoft-edge/wy%C5%9Bwietlanie-i-usuwanie-historii-przegl%C4%85darki-w-programie-microsoft-edge-00cf7943-a9e1-975a-a33d-ac10ce454ca4
- Safari - https://support.apple.com/pl-pl/guide/safari/sfri11471/mac
- Changing the settings of cookies and similar technologies may affect the way the Website works and the services it provides.
§ 8 Logs
- In accordance with the practice of most websites, the Administrator stores HTTP requests directed to its server (server logs). Accordingly, the Administrator stores the following information:
- the IP addresses from which users browse the Website's information content,
- the timing of the enquiry,
- time of sending the reply,
- the name of the client station - identification via the HTTP protocol,
- information about errors that occurred during the execution of the HTTP transaction,
- the URL of a page previously visited by the user (referer link),
- information about the user's browser.
- The collected logs are stored for an indefinite period of time as support material for the administration of the Website. The information contained therein is not disclosed to anyone other than those authorised to administer the Website. Based on the log files, statistics may be generated to assist in the administration of the Website. Aggregate summaries in the form of such statistics do not contain any identifying characteristics of visitors to the Website.
- The Administrator processes the information contained in the logs for technical and 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 the processing of Personal Data is the Administrator's legitimate interest (Article 6(1)(f) RODO).
§ 9 Transfers of Data Outside the EEA
As part of the Administrator's use of tools to support its day-to-day operations provided, for example, by Google, Users' Personal Data may be transferred to countries outside the European Economic Area (EEA), in particular to the United States of America (USA) or another country in which an entity cooperating with it maintains tools for processing Personal Data in cooperation with the Administrator. The Administrator transfers Personal Data outside the EEA only when necessary and with an adequate level of protection, in particular through the use of standard contractual clauses issued by the European Commission.
§ 10 Final provisions
- This privacy policy is subject to updates due to the ongoing analysis of the technical and legal conditions related to the processing of personal data.
- This Privacy Policy is effective as of 31 January 2023.