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      Privacy policy

      Privacy policy


      What are "cookies"?

      "Cookies" should be understood as IT data, in particular text files, stored in users’ terminal equipment (computers, telephones, etc.) intended for using websites. These files allow to recognize the user's device and properly display the website adapted to his individual preferences. "Cookies" usually contain the name of the website from which they originate, their storage time on the terminal device and a unique number.


      What do we use “cookies” for?

      Cookies are contained in the HTTP protocol, which is used for communication between the Internet server and the browser. It consists of: a key specifying the name, value and lifetime after which the browser should delete the cookie file. Their functions are mostly standard for the settings provided by the browser. Cookies are used to facilitate the use of the website and to customize its content, including our offers, to user preferences and to increase the usability and personalization of website content.


      What "cookies" are used by us?

      There are two types of "cookie" files - "session" and "permanent". The first ones are temporary files that remain on the user's device the user logs out of the website or disables the software (web browser) - after that they are automatically removed from the user's device. "Permanent" files remain on the user's device for the time specified in the "cookie" files parameters or until they are manually removed by the user. The "cookie" files used by the website operator's partners are subject to their own privacy policy.

      The cookies we use are primarily designed to facilitate the use of our website, for example by "remembering" information once provided, so that the user does not have to provide them every time. We also use cookies that allow to customize the content presented on the Internet to the preferences of a user (such as ads and photos).


      Privacy and "cookies"

      When the user uses our site, we use cookies to identify the browser or user device - "cookies" files collect various types of information, which in principle do not constitute personal data (do not allow the identification of the user). Some information, depending on their content and use, may, however, be associated with a specific person (e.g., our adult Club Member or User who creates an account on our website), and thus be considered as personal data. Due to the CCC policy, the data is encrypted, making it impossible for unauthorized persons to access it.


      Profiling

      By using the cookie technology used on our website, it is possible to learn about the preferences of users - for example, by analysing how often they visit our website, or what products they usually view. Analysis of online behaviour helps us to understand better users' habits and expectations and to adapt to their needs and interests. Thanks to this technology, we can present to the user an ad tailored to it (for example, the advertisement resulting from the recent review of shoes only in the category "derby shoes') and from the available offers, primarily present those that best suit the needs of the user.

      The user's resignation from cookies allowing the display of advertisements tailored to his interests does not mean that he will not receive advertisements when using our or other websites - in this case, the user will still receive the same number of ads, but not related to his or her current activity.

      Access to information on the activity of users on the Internet using cookies will also allow us to conduct market and statistical analyses. Information collected and contained in cookies can be stored after the end of the browser session, which allows, for example, to use them during subsequent visits by the user.


      Retargeting

      Based on cookies, we use technology that allows us reaching users who have previously visited our website, when they visit other websites, including those belonging to entities cooperating with our partners.

      The lack of connection between the advertisement displayed to the user and his interests and needs may be disruptive to him. Therefore, we believe that it is more attractive and practical for the user to receive the message that corresponds to his interests and needs identified as a result of the analysis of his previous behaviour based on the cookies technology. Therefore, we are interested in following advertising content for a user using different websites to provide advertising content adapted to his previous internet activity.


      Third party cookie files

      The cookies we use are primarily aimed at optimizing user service when using our website. However, we cooperate with other companies in the scope of their marketing (advertising) activity - for the purposes of this cooperation, the browser or other software installed on a computer or other user's device also stores cookies from entities conducting such marketing activities. You can read the list of our trusted partners in point 8.14 below. Cookies sent by these entities are supposed to improve the effectiveness of presenting to the user advertisements that correspond to his online activity - third parties provide advertising content to users.

      Therefore, during the visit to our website, cookies from our partners are also stored on your computer or other device. This way, for example, information about products being viewed or purchased is collected.


      Removing / blocking "cookies"

      Remember that you can manage your consents to use of cookies via your web browser.

      By default, Internet browsers or other software installed on a computer or other user's device connected to the network allow for the inclusion of certain types of "cookies" on such device. These settings can be changed in such a way as to block the use of "cookies" in the settings of the web browser or inform about their every transfer to the user's device. In this way, the consent expressed on the use of this technology may be modified or cancelled at any time (blocking the saving of cookies in the future).

      It is also possible to block cookies of third parties with the simultaneous acceptance of "cookies" used directly by CCC.

      Detailed information about the possibilities and ways of handling "cookies" are available in the software (web browser) settings.

      Limiting the use of "cookies" may affect some functionalities available on the website.

      Please note that resigning from cookies shall only apply to a specific browser. This means that the same actions shall have to be taken for any other browser used on the same or another device.


      PRIVACY POLICY AND COOKIES OF CCC GROUP


      1. GENERAL PROVISIONS

      1.1. This privacy policy of the Website, Application (mobile application) and CCC Club (hereinafter: "Policy') is for informational purposes, which means that it is not a source of obligations for the User of the Website or Application, Member or Licensor (within the meaning of point 1.7 below). The policy is also not a source of Users' obligations.

      1.2. The information contained in the Policy is of a general nature. Detailed information regarding the processing of specific personal data is made available each time in the content of the information clause placed in a visible and easily accessible place during their collection. This applies in particular to information about the purpose and legal basis of the processing of personal data, the period of their storage and the recipients to whom they are transferred.

      1.3. The Controller of personal data:

      - collected via the Website, Application (including using cookies), or other communication channels with the User or Club Member;

      - collected via the Application Form for CCC Club and other data collected in connection with membership of the CCC Club, including data on transactions made with the use of the Card;

      - obtained on the basis of the User or Member's activity on the Internet, in mobile applications or CCC Group's brick and mortar stores;

      - provided by the Licensor as part of a cooperation under the rules described in the Regulations for the dissemination of #yesCCC works, in particular using the websites https://www.instagram.com and https://www.facebook.com and other websites marked or co-marked with trademarks of Instagram and Facebook (including sub-domains, international versions, widgets and versions for mobile phones), or by introducing into the IT system via functions available on the websites that allow adding photos or opinions;

      - data location;

      is a company CCC S.A., with the registered office in Polkowice at 6 Strefowa Street, 59-101 Polkowice, entered into the Register of Entrepreneurs kept by the District Court for Wrocław-Fabryczna in Wrocław, 9th Commercial Division of the National Court Register under the number KRS 0000211692, National Business Registry Number (REGON) 390716905, Tax Number (NIP) 692-22-00-609, with share capital of PLN 4.116.400,00 paid in full (contact at the above-mentioned address, e-mail address: [email protected] or telephone number +48 76 845 86 68 - payment as per standard connection - according to the price list of the relevant operator) - hereinafter referred to as " Controller”.

      In the event of consent, the Controllers of the personal data of the User, Member or Licensor (e.g. obtained on the basis of Internet activity using technologies such as cookies) may also be the CCC Partners indicated below in point 8.15.

      1.4. Under the contact details from point 1.3 you can also contact the Data Protection Officer.

      1.5. Personal data of the User, Member or Licensor are processed in accordance with the Regulation (EU) 2016/679  of the European Parliament and of the Council of 27 April2016 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/WE (Official Journal No. 119, page 1) (hereinafter also "GDPR') and other regulations currently in force, i.e. throughout the entire period of data processing, legal provisions on the protection of personal data. Personal data means any information about an identified or identifiable natural person (hereinafter: "Personal Data'). An identifiable natural person is a person who can be directly or indirectly identified, in particular on the basis of an identifier such as name, identification number, location data, internet identifier or one or more specific factors determining physical, physiological, genetic, psychological, economic, cultural or social identity of a natural person.

      1.6 The  Controller  takes special care to protect the interests of the data subjects, and in particular ensures that the data collected by him is:

      - processed in accordance with the law, fairly and transparently for the data subject;

      - collected for specific, explicit and legitimate purposes and not further processed in a way incompatible with these purposes;

      - adequate, relevant and limited to what is necessary for the purposes for which they are processed;

      - correct and updated if necessary;

      - kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which the data are processed;

      - processed in a manner that ensures adequate security of Personal Data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, by appropriate technical or organizational measures.

      1.7 All words, phrases and abbreviations appearing on this page and beginning with a capital letter (e.g. Website, CCC Club) should be understood in accordance with their definition contained in the Website Regulations , the CCC Club Loyalty Program Regulations or the Regulations for distributing works of #yesCCC (all regulations available on the Website [https://ccc.eu/pl]). In the event that the aforementioned documents use the same word, phrase or abbreviation in a different sense, the provisions of this Policy should be read in accordance with the definition contained in the Website Regulations , the CCC Club Loyalty Program Regulations or the Regulations for distributing works of #yesCCC, or refer them to all these meanings together, adequately to the context of the use of the word, expression or abbreviation in the Policy.


      2. OBJECTIVE, LEGAL BASIS AND DATA PROCESSING RANGE


      2.1. Each time, the purpose and scope of data processed by the  Controller results mainly from the scope of services used by the given person. For example: (I) The  Controller processes a different data directory depending on whether the User is also a member of the Club; (II) only the Member's Personal Data may be processed in order to grant, present or give him or her dedicated offers and promotions, adapted to the preferences (not available for non-members of the Club)

      2.2. The purpose and scope of the data results also from the consent of the User, Member or Licensor, or from the applicable law, and are further specified as a result of actions taken by him on the Website, Application or as part of the CCC Club. For example, if the User of the Website does not agree to receive commercial information by email, the  Controller shall not process his personal data in this regard.

      2.3. Possible purposes of Personal Data processing by the  Controller are in particular:

      a. conclusion and implementation of a given contract, or taking action at the request of a future User, Club Member or Licensor before its conclusion;

      b. presenting to the User or Club Member advertisements, offers or promotions (discounts) regarding the products or services of the  Controller or entities from the CCC Group, intended for all recipients. The entities of the CCC Group are understood as entities each time indicated in the attached list of entities;

      c. assessment and analysis of activity and information about the User, including as part of the automated processing of Personal Data (profiling), in order to present advertisements, offers or discounts regarding the  products or services of the Controller  or entities from the CCC Group, intended for all recipients, in a manner adapted to the interests of a given User, market and statistical analysis;

      d. pursuing claims and defending against claims by parties and third parties;

      e. compliance with legal obligations arising from regulations, e.g. tax and accounting regulations;

      f. correspondence with Users, Members and Licensors.

      2.4. In the case of adult Members, Personal Data may also be processed for the following purposes:

      a. presenting general advertisements, offers or discounts regarding products or services of the  Controller or entities from the CCC Group, in a manner adapted to the interests of a given Member (profiling);

      b. presenting, creating, awarding and implementing dedicated ads, offers or discounts (including Promotions and Gifts) to the Member regarding products or services of the  Controller or CCC Group entities (not available to persons who are not Club members), adapted to their preferences (profiling), including as a result of automated decision making.

      2.5. In the case of Licensors, Personal Data may also be processed for the purpose of distributing the Works, presenting the Licensor's image and the image of third parties for whom the Licensor is authorized to consent to its use.

      2.6. The basis for the processing of the Personal Data of a User, Member or Licensor is primarily the necessity to perform the contract of which a User, Member or Licensor is a party or the need to take action at his request prior to its conclusion (Article 6 paragraph 1 letter b of the GDPR). This applies primarily to Personal Data provided in the Booking Form or when registering an Account on the Website or Application, and the Application Form for CCC Club, and in the case of Licensors, Personal Data provided in particular via websites https://www.instagram.com and https://www.facebook.com or through their introduction to the IT system via the functionalities available on the Website that allow adding photos or reviews.

      2.7. The necessity to perform the contract is also the basis for the processing of Personal Data in order to present advertisements, offers or rebates adapted to the interests of the Member, as well as their creation, granting and implementation in a version dedicated to the Member. However, this applies only to adult Members.

      2.8. In the case of other processing operations for marketing purposes, the basis for such processing is the fulfilment of objectives arising from legally justified interests pursued by the  Controller or by entities from the CCC Group (Article 6 paragraph 1, letter f of the GDPR).

      2.9. In other (different) purposes, the User's, Member's or Licensor's Personal Data may be processed on the basis of free consents, applicable legal provisions (when processing is necessary to fulfil the legal obligation of the  Controller) or when processing is necessary for objectives other than listed in point 2.6 and 2.7 above, resulting from the legally legitimate interests pursued by the  Controller or by a third party, in particular to determine, pursue or defend claims (i.e. respectively Article 6, section1, letter a, c and f of the GDPR).

      2.10. The  Controller may process, in particular, the Personal Data of:

      a. Users of the Website or Application:

      - Personal Data provided in the Reservation form or at the Account registration (in particular: name and surname, e-mail address, telephone number, Brick and Mortar store selected for Reservation) and other data collected during the use of the Website or Application;

      - other data, in particular obtained on the basis of the User or Member's activity on the Internet, in mobile applications or CCC Group Brick and Mortar Stores, including those obtained via the Website, Application or other communication channels with the User or Club Member;

      b. Club Members:

      - Personal Data provided in the CCC Club Application Form (in particular: name, Polish telephone number, date of birth, e-mail address) and other data collected in connection with membership of the CCC Club, including transactions made with the Card ;

      c. Licensors:

      - Personal Data provided as part of a cooperation as described in the Regulations for distributing #yesCCC works, including, as part of photos or opinions provided using websites https://www.instagram.com and https://www.facebook.com or through their introduction via functions available on the Website that enable their addition;

      2.11. Providing Personal Data is voluntary, however, it may be necessary, for example, to submit a User's Reservation or Account registration, and in the case of a Club Member and Licensor respectively, to join the CCC Club and to grant a Licence to the  Controller. The consequence of not submitting Personal Data may be the inability to effectively perform the above-mentioned activities.

      2.12. The  Controller for the purpose of presenting general advertisements, offers or discounts, intended for all CCC Clients, in a manner adapted to the interests of a given User or adult member, may get acquainted with his preferences, e.g. by analysing how often the User visits the Website, or and what products he or she buys in CCC Group Stores. This allows a better understanding of the User's or Club Member's expectations and adaptation to his needs. Thanks to the use of advanced technologies by the  Controller, the above actions should often be performed by the system in an automated manner, thanks to which the content sent shall be the most up-to-date and the User or Club Member should be able to quickly become familiar with them.

      2.13. In the case of adult Members, the above-mentioned interest analysis or preferences shall also be used to create, award and implement customized ads, offers or rebates dedicated to the Club Member (not available for Club non-members).The more often a Club Member uses the services of the  Controller and purchases its products, the better promotions and surprises can be prepared for him. Lack of participation in the CCC Club shall prevent such  Controller actions.

      2.14. In order to prevent a Licensor from transferring via the Application the relevant content within cooperation on the terms specified in the Regulations for distributing #yesCCC works, in particular, in the form of photos of the chosen products, uploaded by the Licensor . The Controller can gain, including, with the consent of the Licensor, access to the following areas of the mobile device of the Licensor:

      a. camera;

      b. gallery.


      3. DATA RECEIVERS


      3.1. Each time the catalogue of recipients of Personal Data processed by the  Controller results mainly from the scope of services used by the User or Member.

      3.2. The catalogue of recipients of the data also results from the consent of the User or the Club Member, or from the applicable law and is further specified as a result of actions taken by him on the Website, Application or within the CCC Club.

      3.3. The CCC Partners may participate in the processing of Personal Data in a limited scope, in particular those who technically help efficiently run the Website, Application or CCC Club, e.g. hosting or IT services providers, companies that service the software, support the  Controller in marketing campaigns whether they run Brick and Mortar Stores, in which one can use the benefits received in the CCC Club and purchase reserved Products, as well as providers of legal and consulting services.

      3.4. Each time, the User's, Member or Licensee's personal data may be transferred to companies from the CCC Group.

      3.5. As part of marketing (advertising) activities, the  Controller uses the services of third parties that use cookies on the Website / Application. The catalogue of these entities is indicated in detail in point 8.15 of this Policy.


      4. RIGHTS OF ADATA SUBJECTS


      4.1. Each User, Club Member or Licensor is entitled at any time to:

      - lodge a complaint to the President of the Office for the Protection of Personal Data;

      - transfer of Personal Data that has been provided to the  Controller, and which are processed in an automated manner, and the processing takes place on the basis of consent or under a contract, e.g. to another  Controller;

      - access to Personal Data (including, for example, receiving information that Personal Data is processed);

      - request for rectification and limitation of processing (e.g. if Personal Data is incorrect) or deletion of Personal Data (e.g. if they were processed unlawfully).

      4.2. Each User, Member or Licensor has the right to object at any time to the processing of Personal Data related to him, based on the condition of indispensability for purposes arising from legitimate interests pursued by the  Controller or by a third party, including in particular processing for marketing purposes, including profiling (if there are no other valid legitimate grounds for processing that override the interests of the User, the Member or the Licensee).

      4.3. If the processing is based on the consent of the User, Member or Licensor, one may withdraw his consent at any time. Withdrawal of consent, however, does not affect the legality of the processing carried out on the basis of consent before its withdrawal.



      5. TRANSFER OF PERSONAL DATA TO A THIRD COUNTRY


      5.1. As part of the  Controller's use of tools supporting his day-to-day actions provided by, for example, Google, the User's, Member's or Licensor's Personal Data may be transferred to a country outside the European Economic Area, 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  Controller.

      5.2. In addition, Personal Data provided by the Licensor as part of cooperation under the rules described in the Regulations of distributing works of #yesCCC, may be transferred to a country outside the European Economic Area, i.e. to the United States of America because the transfer is necessary to provide cooperation between the  Controller and Licensor by IT service providers.

      5.3. The User, Member and Licensor have the right to obtain a copy of security applied by the  Controller regarding the transfer of Personal Data to a third country, by contacting the  Controller.


      6. PERIOD OF STORING PERSONAL DATA


      6.1. Personal Data may be stored for the period of using the Website, Application or participation in the CCC Club, but shall be deleted three years after the last activity of a given person on the Website,

      Application or CCC Club, unless the applicable law (e.g. accounting or tax regulations) shall oblige the  Controller to process Personal Data for a longer period.

      6.2. In the case of Personal Data provided in accordance with the Regulations of distributing #yesCCC works, they may be stored for the duration of cooperation between the  Controller and the Licensor on the terms set out in it (e.g. until the termination of the licence), unless the applicable law (e.g. tax law provisions) obliges the  Controller process Personal Data for a longer period.

      6.3. If the processing of Personal Data depends on the consent of the User, Member or Licensor, Personal Data may be processed until it is withdrawn.

      6.4. Part of the Personal Data may be stored longer in case the User, Member or Licensor should have any claims against the  Controller in order to pursue claims by the  Controller, or to pursue and defend against claims of third parties.

      6.5. Depending on the scope of Personal Data and the purposes of its processing, it may be stored for a different period of time.

      6.7. In all cases, a longer period of storage of Personal Data is decisive.


      7. COMMERCIAL INFORMATION


      7.1. The  Controller has the technical ability to communicate with the User, Club Member or Licensor remotely (e.g. e-mail).

      7.2. Commercial information regarding the products or services of the  Controller or entities from the CCC Group may be sent only in accordance with the consent expressed by the User, the Member or the Licensor. Sometimes such consent may be necessary for the conclusion and performance of a contract - example.g.  in the case of joining the CCC Club.


      8. COOKIES


      8.1. Due to the fact that the cookie technology used by the  Controller collects information about each person visiting the Website or Application, the following provisions of the Policy apply to all Users who use the Website or Application regardless of whether they remain Club Members or Licensors.

      8.2. The Website and Application uses technology that stores and gains access to information on a computer or other device connected to the network (cookies), in order to ensure maximum comfort when using the Website or Application, including for statistical purposes and for adaptation to interests of the User of the presented advertising content. During the User's visit to the Website or the Application, data on User's activity of the Internet may be automatically collected.

      8.3. A cookie file is small text information sent by the server and saved on the user's device side (usually on the computer hard disk or in a mobile device). It stores information that the Website or Application may need to adapt to the ways the User uses it and to collect statistical data about the Website or Application, e.g. about which websites were visited, which elements are downloaded, and the domain name of the Internet Service Provider or User's country of origin. The technology that stores and gains access to the User's identifier, allows the Application to work in offline mode and save the preferences of the user not logged in. The application stores the current User ID until the User logs in to the Application, changes the Application site to the Website in the language version proposed by CCC or uninstalls (deletes) the Application from the mobile device.

      8.4. When the User uses the Website or Application, cookies are used to identify his browser or device - cookies collect various types of information which, as a rule, do not constitute personal data (do not allow identification of the User). Some information, depending on their content and use, may, however, be associated with a specific person - assigning certain behaviours to a specific User, e.g. by linking them to data provided during the registration of an Account on the Website - and thereby can be considered as personal data.

      8.5. Used cookies are primarily to facilitate the User's use of the Website and the Application, for example, by "remembering" the information once provided so that it does not have to be provided every time, as well as to adjust their content, including advertising, to User preferences. Cookies are also used to increase the usability and personalization of the content of websites and applications, including the presentation, creation, award and implementation of advertisements, offers or discounts dedicated to the User in accordance with his interests (applies only when he is also a member).

      By means of the cookie technology used on the Website and Application, it is possible to get acquainted with the User's preferences - for example, by analysing how often he visits the Website or what products he buys in CCC Group Brick and Mortar Stores. The analysis of online behaviour helps to better understand the users' habits and expectations and to adapt to their needs and interests. Thanks to this technology, it is possible to present the Users advertisements tailored to their needs and interests (for example, advertising resulting from reviewing only shoes in the "derby shoes" category recently) and preparing better promotions and surprises for Club Members.

      Based on cookies, the  Controller also uses technology that allows to reach with the advertising message the Users who have previously visited the Website or the Application while using the websites belonging to other internet service providers.

      8.5. A User who is not a Club Member may oppose the  Controller's actions undertaken for the purposes described in point. 8.5 above, when they are based on a legitimate interest pursued by the  Controller or by a third party. In the case of Users who are Club Members, the processing of data for these purposes is necessary for the performance of the contract which the given person concludes by joining the CCC Club.

      8.6. Obtaining and storing information using cookies is possible based on the consent of the User. By default, Internet browsers or other software installed on a computer or other device connected to the network allow cookies to be placed on such devices by default, and thus to collect information about Users. On the web browser's settings, the consent expressed on the use of cookie technology may be modified or revoked at any time. Withdrawal of consent does not affect the legality of the processing, which was made on the basis of consent before its withdrawal (detailed information on how to withdraw consent is presented in paragraphs 8.17 - 8.20 of this Policy). The basis for processing data obtained in such a way is the legitimate interest of the  Controller - which is the need to provide the highest quality content presented by the  Controller by adapting them to the preferences of users and marketing - including direct -  Controller's products and services, and for Club Members - the need to perform the contract. In case of withdrawal of the above our company shall not be able to provide services under the CCC Club to the full extent.

      8.7. In relation to information collected by cookie files that may be associated with a specific person, the provisions of the Policy relating to Personal Data apply, in particular regarding the rights of the data subject. Detailed information on data collected by cookies is also made available, among others in the text of the information clause placed in a visible and easily accessible place during the first visit to the Website.

      8.8. Cookies used on the Website or in the Application are not harmful to the User or to the computer / terminal device used by it, therefore we recommend not to use them in browsers. On the Website and Application, two types of cookies are used: session cookies that remain saved on the User's computer or mobile device until logging out of the website or turning off the software (web browser) and permanent ones that remain on the User's device for the time specified in the file parameters cookies or until they are manually removed in a web browser.

      8.9. Depending on whether the Personal Data collected by cookies refer to the User, Member or Licensor, they may be stored in accordance with point 6 of this Policy.

      8.10. The Personal Data collected by cookies regarding a User who does not have an Account and is not a Member or Licensor, shall be stored until an objection is raised. The  Controller shall delete the Personal Data each time if it is not used for marketing purposes for 3 years, unless the law obliges the  Controller to process Personal Data for a longer period.

      8.11. Part of the Personal Data may be stored longer in case the User had any claims against the  Controller, in order to assert claims by the  Controller, or in order to assert and defend against claims of third parties.

      8.12. In all cases, a longer period of storage of Personal Data is decisive.




      8.15. The cookies used by the  Controller are mainly used to optimize the User's service when using the Website or the Application. However, the  Controller cooperates with other companies in the scope of their marketing (advertising) activity - for the purposes of this cooperation, the browser or other software installed on a computer or other User's device also saves cookies from entities conducting such marketing activities. Cookies sent by these entities are to ensure effective implementation of the assumption of presenting to the User only those advertisements that correspond to their individual interests and needs - in the  Controller's opinion, displaying a personalized advertisement is more attractive to the User than an advertisement not related to his needs. Without these files, it would not be possible because it is the companies cooperating with the  Controller that provide advertising content to Users.

      As part of the marketing activities, the  Controller uses the services of companies using cookies on the Website / Application, in particular:

      1. Google AdWords

      2. Google Analytics

      3. Google DoubleClick

      4. Hotjar

      5. Facebook

      6. AdForm

      8.16 More information about cookies used by these companies can be found in their privacy policies.

      8.17 The Customer may change the way cookies are used by the browser or the Application, including blocking or deleting those that come from the Website (and other websites). To do this, change the browser or Application settings. The removal method varies depending on the web browser used. Information on how to delete cookies should be located in the "Help" tab of the selected web browser. Removal of cookies is not the same as deletion of Personal Data by the  Controller of Personal Data obtained through cookies.

      8.18 For example, in Internet Explorer, cookies can be modified from: Tools -> Internet Options -> Privacy; in the Mozilla Firefox browser: Tools -> Options -> Privacy; while in Google Chrome: Settings -> Show advanced settings -> Privacy -> Content settings -> Cookies. Access paths may vary depending on the browser version used.

      8.19 Detailed information on managing cookies on a mobile phone or other mobile device can be found in the user's manual / user guide for a given telephone or mobile device.

      8.20 Restricting the use of cookies on a given device makes it impossible or significantly impedes the correct use of the Website or the Application, for example it is connected with the inability to maintain a login session.

      8.21 It is also possible to block cookies of third parties with the simultaneous acceptance of cookies used directly by the  Controller (depending on the browser settings you have selected).


       9. CONTACT WITH THE  CONTROLLER


      9.1. At any time, there is a possibility of direct contact with the  Controller by sending a relevant message in writing or by e-mail to the  Controller's address indicated at the beginning of the Policy, or by phone or email at the phone number or e-mail address indicated at the beginning of the Policy.

      9.2. The  Controller stores correspondence for statistical purposes and for the best and quickest response to appearing inquiries, as well as in the scope of complaint settlements and decisions made on the basis of notifications about administrative interventions in the indicated Account. The addresses and data collected in this way shall not be used for communication for purposes other than the implementation of the application.

      9.3. In the case of contact with the  Controller in order to perform specific actions, the  Controller may ask the person again for the transfer of data, including personal data, e.g. in the form of name, surname, e-mail address, etc., to confirm his identity and allow return contact in a given case and carrying out the requested action. Providing these data is not mandatory, but it may be necessary to carry out activities or to obtain information that is of interest to the person concerned.


      10. SECURITY


      10.1. The  Controller, taking into account the state of technical knowledge, the cost of implementation and the nature, scope, context and purposes of processing and the risk of violating the rights or freedoms of individuals with different probability of occurrence and threat severity, applies appropriate technical and organizational measures to ensure that Personal Data processed is adequate to threats and categories protection data, in particular, protects data from being made available to unauthorized persons, being taken away by an unauthorized person, processing in violation of applicable laws and changes, loss, damage or destruction. Providing information on technical and organizational measures that provide protection of processing outside may impair their effectiveness, thus jeopardizing the proper protection of Personal Data.

      10.2. The  Controller provides the following technical measures to prevent the unauthorized access and modification of Personal Data sent electronically:

      a. Securing Personal Data against unauthorized access.

      b. SSL Certificate on the Website pages where Personal Data is provided.

      c. Encryption of data used to authorize a person using the Website's functionality.

      d. Access to the Account only after providing an individual login and password.



      11. FINAL PROVISIONS


      11.1. The Website may contain links to other websites. The  Controller encouragesto read the terms and privacy policies used for other websites. This Policy applies only to the  Controller's indicated activities.

      11.2. The  Controller reserves the right to change the Policy in the future - this may occur, among others for the following important reasons:

      a. changes in the binding provisions, in particular regarding the protection of Personal Data, telecommunications law, services provided electronically and regulating consumer rights, affecting the rights and obligations of the  Controller or the rights and obligations of the data subject;

      b. development of functionality or Electronic Services dictated by the progress of internet technology, including the application / implementation of new technological or technical solutions affecting the scope of the Policy.

      11.3. The  Controller is each time shall place information about changes in the Policy on the Website and in the Application. With every change, the new version of the Policy shall appear with a new date.

      11.4. In case of doubts or contradictions between the Policy and the consents given by a given person or information provided by the  Controller in the information clauses provided during the collection of Personal Data (e.g. under the registration form on the Website), regardless of the provisions of the Policy, always the basis for taking and determining by the  Controller the scope of activities are free consents or legal provisions, and the information which data subject should be guided is provided to him within the aforementioned information clauses. This document is, however, of a general, informative nature (it is not a contract or regulation).

      11.5. This version of the Policy is effective from 25.06.2018.


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