Hello, good morning!
If you have arrived here, it is a reliable sign that you value your privacy. We understand this very well, therefore we are providing you with a document, in which in one place you will find the principles of personal data processing and the use of cookies and other tracking technologies in connection with the functioning of the zamelplatform.eu website.
Formal information to start with - the administrator of the website is ZAMEL SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, ul. Juliusza Słowackiego 1, 21-500 Biała Podlaska, NIP: 5372349871, KRS: 0000230948, share capital: PLN 50000, registration court: District Court Lublin-East in Lublin with registered office in Świdnik, VI Economic Division of the National Court Register.
This privacy policy has been structured in the form of questions and answers. The choice of such a form was dictated by the care for clarity and legibility of the information presented to you.
If you have any doubts about the privacy policy, you can contact us at any time by sending a message to info@zamelplatform.eu.
# 1: Who is the administrator of your personal data?
The administrator of your personal data is ZAMEL SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, ul. Juliusza Słowackiego 1, 21-500 Biała Podlaska, NIP: 5372349871, KRS: 0000230948, share capital: PLN 50000, registration court: District Court Lublin-East in Lublin with registered office in Świdnik, VI Economic Division of the National Court Register.
# 2: Who can you contact regarding the processing of your personal data?
As part of the implementation of personal data protection in our organisation, we have decided not to appoint a Data Protection Officer due to the fact that it is not mandatory in our situation. You can contact us on matters relating to data protection and privacy more broadly at info@zamelplatform.eu.
# 3: What information do we hold about you?
The scope of the personal data processed is indicated separately in relation to the different purposes for which we process personal data in Annex 1 to the privacy policy. Furthermore, we use tools that collect a range of information about you related to your use of our website. This concerns, in particular, the following information:
- information about your device, operating system and browser
- user-ID
- IP address subject to truncation and anonymisation
- the date of your visit to the website
- sub-pages viewed
- time spent on the site
- transitions between pages
- mouse clicks or screen taps
- clicks on individual links
- source from which you came to the page
- your age bracket
- your gender
- Your approximate location limited to your town
- Your interests as determined by your online activities
- This information is referred to hereafter in this privacy policy as "Anonymous Information"
Anonymous Information does not, in itself, in our view, have the character of personal data, as it does not allow us to identify you and we do not collate it with the typical personal data we collect about you. Nevertheless, given the strict jurisprudence of the Court of Justice of the European Union and the divided opinions among lawyers, as a precaution, in case Anonymous Information is attributed the character of personal data, we have also included detailed explanations in this privacy policy regarding the processing of this information.
We are not able to provide you with access to Anonymous Information about you, as we are not able to attribute any of the Anonymous Information to any specific user. From the tools that collect Anonymous Information, we only have access to a set of statistics and information that is not assigned to specific individuals. Furthermore, we do not have access to the information collected by some tools at all, as we are only interested in the correct functioning of the function provided by the tool, not the information collected by the tool. For example, a particular plug-in may collect some information, but it is not made available to us in any way, and we are not interested in this information at all, as we are only interested in the particular functionality of the plug-in (e.g. sending a newsletter form) simply working.
The processing of Anonymous Information allows us to ensure that you can use the functionality available on the website. Furthermore, Anonymous Information is used for analytical and statistical purposes as well as for marketing purposes, such as setting and targeting advertisements.
As Anonymous Information is collected by external tools we use, Anonymous Information is also processed by the tool providers under the terms of their terms of use and privacy policies.
Anonymous Information is also used by the providers of the individual tools to provide and improve the services, to manage the services, to develop new services, to measure the effectiveness of advertising, to protect against fraud and abuse, and to personalise the content and advertising displayed on the individual services, sites and applications.
The tools we use that involve the collection of Anonymous Information are listed in Appendix 2 of this privacy policy.
# 4: Where do we get your personal data from?
In most cases, you provide it to us yourself. This happens when:
- you register a user account
- fill in your user profile
- placing an order
- you submit a complaint or cancel a contract
- subscribe to our newsletter
- contact us by e-mail
- send us a request or revocation of content stored by us
- following our social media profiles or interacting with content
- published by us on social media
- you submit a request related to the processing of personal data
- In Appendix 1 of this privacy policy, we have attributed the source of data acquisition to each of the processing purposes.
In addition, some information about you may be automatically collected by the tools we use:
- the website mechanism collects your IP address
- the mechanism of the newsletter system collects your IP address and information about your activity in relation to the content sent to you within the newsletter, such as opening messages, clicking on links, etc.
- the external tools listed in Annex 2 to this privacy policy collect Anonymous Information about your activities on the site
# 5: Is your data secure?
We take care of the security of your personal data. We have analysed the risks involved in the various processes of processing your data and then implemented appropriate security and data protection measures. We monitor the state of the technical infrastructure on an ongoing basis, train our staff, look at the procedures in place and make the necessary improvements. If you have any questions about your personal data, we are at your disposal at info@zamelplatform.eu.
# 6: For what purposes do we process your personal data?
The purposes for which we process your personal data are listed in Annex 1 to this privacy policy.
# 7: How long will we keep your personal data?
We will keep your personal data for as long as is reasonable under the particular purpose of processing your personal data, and therefore the processing periods vary according to the purpose - you will find their determination in the table attached to the privacy policy.
Please note that the termination of the processing of your data for one purpose does not necessarily lead to the complete deletion or destruction of your personal data, as data may be processed for another purpose for the period indicated for that purpose. For example, when we terminate the exchange of correspondence, we terminate the processing of your personal data in pursuit of the purpose of handling correspondence, but the data collected in relation to handling correspondence is further stored for archiving for the purpose of establishing, investigating or defending claims relating to the correspondence. The complete deletion or destruction of the data takes place when we have completed all the purposes, usually after the expiry of the limitation period for claims or the limitation period for administrative liability, or the period for which we are legally obliged to keep certain data.
# 8: Who are the recipients of your personal data?
We would venture to say that modern business cannot do without services provided by third parties. We also make use of such services. Some of these services involve the processing of your personal data. Third-party service providers that are involved in the processing of your personal data are: the hosting provider, who stores the data on the server
- your email provider
- cloud software providers, where the data processing takes place
- accounting office, which processes your data as shown on invoices
All the entities listed above process your data on the basis of personal data processing entrustment agreements concluded with us and guarantee an adequate level of personal data protection.
If the need arises, your data may be shared with a legal advisor or lawyer bound by professional secrecy. The need may arise from the need for legal assistance requiring access to your personal data.
Your personal data may also be provided to the tax authorities to the extent necessary for the fulfilment of tax and accounting obligations. This includes, in particular, all declarations, reports, statements and other accounting documents containing your personal data.
Your data is shared with courier companies to the extent necessary for the delivery of your order. These companies become independent controllers of your personal data.
Furthermore, when it comes to Anonymous Information, access is granted to providers of tools or plug-ins that collect Anonymous Information. The providers of these tools are independent controllers of the data collected in them and may share this data under the terms and conditions they set out in their own terms and conditions and privacy policies, over which I have no control.
# 9: Do we transfer your data to third countries or international organisations?
No, we do not transfer your data to third countries or international organisations.
# 10: Do we use profiling? Do we make automated decisions based on your personal data?
We do not make decisions to you based solely on automated processing, including profiling, which would produce legal effects on you or similarly significantly affect you.
Yes, we do use tools that may take certain actions depending on the information collected through tracking mechanisms, but we believe that these actions do not materially affect you as they do not differentiate your situation as a customer, do not affect the terms of the contract you may enter into with us, etc.
Using certain tools, we may, for example, target you with personalised advertising based on previous actions you have taken on the website or suggest products that may be of interest to you. This is known as behavioural advertising. We encourage you to learn more about behavioural advertising, particularly with regard to privacy issues. You will find detailed information, including the possibility of managing your settings with regard to behavioural advertising, here.
We emphasise that within the tools I use, I only have access to Anonymous Information.
This information is stored on the servers of the providers of the individual tools, and these servers can most often be located around the world.
# 11: What rights do you have in relation to the processing of your personal data?
The RODO grants you the following potential rights in relation to the processing of your personal data:
- the right to access your data and to receive a copy of it,
- The right to rectify (amend) your data,
- the right to erasure (if, in your opinion, there are no grounds for us to process your data, you can request that we erase it),
- the right to restrict the processing of your data (you can request that we restrict the processing of your data only to storing it or carrying out activities agreed with you, if in your opinion we have incorrect data or are processing it unfoundedly),
- the right to object to processing (you have the right to object to processing on the basis of a legitimate interest; you should indicate the particular situation which you think justifies us stopping the processing covered by your objection; we will stop processing your data for these purposes unless we can demonstrate that the grounds for our processing override your rights or that your data is necessary for us to establish, assert or defend our claims),
- the right to data portability (you have the right to receive from us in a structured, commonly used machine-readable format the personal data you have provided to us under the contract or your consent; you can have this data sent directly to another party),
- the right to withdraw your consent to the processing of personal data where you have previously given such consent,
- the right to lodge a complaint with a supervisory authority (if you find that we are processing your data unlawfully, you may lodge a complaint to this effect with the President of the Office for Personal Data Protection or any other competent supervisory authority).
The rules related to the exercise of the rights indicated above are described in detail in Articles 16 - 21 of the RODO.
We encourage you to familiarise yourself with these provisions. For our part, we consider it necessary to explain to you that the rights indicated above are not absolute and you will not be entitled to them in relation to all processing activities of your personal data.
We would like to emphasise that one of the rights indicated above is always available to you - if you consider that we have committed an infringement of data protection legislation in the processing of your personal data, you have the possibility to lodge a complaint with the supervisory authority (the President of the Office for Personal Data Protection).
You can also always ask us to provide you with information about what data we hold about you and for what purposes we process it. All you need to do is send an email to info@zamelplatform.eu. However, we have made every effort to ensure that the information of interest to you is comprehensively set out in this privacy policy. You can also use the e-mail address given above if you have any questions about the processing of your personal data.
# 12: Do we use cookies or other similar technologies and what are they?
Our website, like almost all other websites, uses cookies and other similar technologies such as tracking codes or pixels, conversion APIs, etc.
The use of cookies or other similar technologies may collect certain information which is then used for a variety of purposes, ranging from ensuring the correct functioning of the various functions of the website, to analysing user behaviour on the website, to targeting targeted advertising.
If you would like to find out more about cookies and other similar technologies, you can read, for example, these materials:
- explanations on cookies,
- an explanation of tracking pixels
- an explanation of the conversion API.
# 13: On what basis do we use cookies or other similar technologies?
We use cookies and other similar technologies on the basis of your consent, except when cookies or other similar technologies are necessary for the proper provision of an electronic service to you.
Cookies or other similar technologies that are not necessary for the proper provision of the electronic service to you remain blocked until you consent to the use of cookies or other similar technologies. On your first visit to the website, we display a message asking you for your consent.
Please note that disabling or restricting cookies or other similar technologies may prevent you from using some of the features available on our website and may cause difficulties in using the website, as well as many other websites that use cookies or other similar technologies. For example, if you block social media plug-in cookies, buttons, widgets and social features implemented on the website may not be available to you.
# 14: Can you disable cookies or other similar technologies?
Yes, you can manage the settings for cookies or other similar technologies within your web browser. You can block all or selected cookies. You can also block cookies of specific websites. You can also delete previously saved cookies and other website and plug-in data at any time.
Web browsers also offer the option of using incognito mode. You can use this mode if you do not want information about websites you have visited and files you have downloaded to be saved in your browsing and download history. Cookies created in incognito mode are deleted when all windows in this mode are closed.
Browser plug-ins to control cookies are also available, such as Ghostery (https://www.ghostery.com). The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc.
In addition, there are tools available on the internet that allow you to control certain types of cookies, in particular to collectively manage your behavioural advertising settings (e.g. www.youronlinechoices.com/, www.networkadvertising.org/choices).
Please note that disabling or restricting cookies or other similar technologies may prevent you from using some of the features available on our website and may cause difficulties in using our website, as well as many other websites that use cookies. For example, if you block social media plug-in cookies, the buttons, widgets and social features implemented on our site may not be available to you.
# 15: For what purposes do we use our own cookies?
Proprietary cookies are used to ensure the correct functioning of the various mechanisms of the site, such as the correct submission of forms visible on the site.
Our own cookies also store information about your consent to cookies.
# 16: What third-party cookies are used?
Our website uses cookies or other similar third-party technologies related to the tools listed in Annex 2 of this privacy policy. Individual tools may use more than one cookie, but we have refrained from listing them in detail so as not to overwhelm you with excessive information and on the basis that it will be clearer for you to use a list of the tools together with a statement of the purposes for which they are used than to list all the cookies or other similar technologies technically operating within each tool.
We have also refrained from indicating the extent of information collected in cookies for each tool used, taking into account that each tool collects information related to
Your characteristics and behaviours undertaken within our website. In this respect, we are dealing with Anonymous Information, which we mentioned earlier within this privacy policy.
Aware of the requirements created by the Court of Justice of the European Union, we have nevertheless refrained from indicating the lifespan of the cookies used by each tool. If we wished to indicate the lifespan of each cookie, we would have to overwhelm you with excessive information, which would in no way meet the principle of transparency and legibility of the information provided to you. Furthermore, the lifespan of cookies can change so actively on the part of tool providers that we are unable to exercise reliable control over this. Aside from determining the lifespan of cookies, we would like to remind you that the only option for real control over the length of time information is stored in cookies is for you to manage cookies directly. From the level of your web browser, you can delete cookies stored on your device at any time.
At this point, we would like to emphasise once again that within the framework of cookies or other similar technologies, we do not have access to information that would allow us to identify you. In this respect, we are dealing with Anonymous Information, which we have mentioned as part of this privacy policy.
Furthermore, while in the case of statistical and marketing tools we can view various reports generated from Anonymous Information, in relation to other tools we do not even gain any access to the information collected in the cookies, being only interested in whether the functions of the tool for which the tool has been installed are working properly within our website.
# 17: Do we track your behaviour on our site?
Yes, we use tools that involve collecting information about your activities on our website. These tools are listed in Appendix 2 of this privacy policy.
# 18: Do we target you with targeted advertising?
Yes, we use advertising tools whereby we can target advertisements to specific target groups defined on the basis of various criteria such as age, gender, interests, occupation, work, activities previously undertaken on our site. These tools are listed in Appendix 2 of this privacy policy.
§ 19: How can you manage your privacy?
The answer to this question can be found in a number of places in this privacy policy when describing individual tools, behavioural advertising, consent to cookies, etc. Nevertheless, we have once again gathered this information in one place for your convenience. Below you will find a list of options for managing your privacy.
- browser cookie settings
- browser plug-ins supporting cookie management, e.g. Ghostery
- Additional software for managing cookies,
- incognito mode in your browser
- behavioural advertising settings, e.g. youronlinechoices.com
- settings on the part of third-party tool providers (links to the settings have been collected as part of Annex 2 to this privacy policy)
# 20: What are server logs?
Using the website involves sending requests to the server where the website is stored. Each request made to the server is recorded in the server logs.
The logs include, among other things, your IP address, the date and time of the server, information about your browser and the operating system you are using. The logs are saved and stored on the server.
The data stored in the server logs are not associated with specific users of the website and are not used by us to identify you.
The server logs are only ancillary material for the administration of the site and their contents are not disclosed to anyone other than those authorised to administer the server.
# 21: Is there anything else you should know?
As you can see, the topics of personal data processing, the use of cookies and the management of privacy in general are quite complex. We have done our best to ensure that this document provides you with the most far-reaching knowledge on the issues that are important to you. If anything is unclear to you, you would like to know more or simply discuss your privacy, please email us at info@zamelplatform.eu.
# 22: Is this privacy policy subject to change?
Yes, we may modify this privacy policy, in particular due to technological changes on the part of our service and changes in legislation. If a change affects the way we process your personal data and we hold your electronic contact details, you will receive a message about any change to the privacy policy.
This content of the Privacy Policy is effective as of 2024-05-01
In addition, all archived versions of the privacy policy are linked below.
Annex 1 - purposes of personal data processing
https://zamelplatform.eu/img/cms/Regulamin sklepu internetowego_cele_przetwarzania.pdf