1. General information
The data controller is Winterro Sp. z o.o., with its registered office in Lublin, tax ID (NIP) 7123435727. Data protection is carried out in accordance with the requirements of generally applicable law, and data is stored on secure servers.
For the interpretation of the terms, the glossary of the Personal Data Protection Policy applies.
For better readability of this Privacy Policy, the term “data subject” has been replaced with “you” or “User”, and “Controller” with “we”. The term “GDPR” refers to 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.
We respect your right to privacy and care about the security of your data. For this purpose, we use, among others, a secure SSL encryption protocol.
Personal data provided in the registration form are treated as confidential and are not visible to unauthorised persons.
Registering on the Website, using any services and/or functionalities of the Website (including as a User who has not completed the registration procedure), as well as posting any information, photos, announcements, comments on the Website constitutes confirmation that the User accepts these rules and is obliged to fully comply with their provisions.
2. Data Controller
The Controller processes only the data that the Platform User has voluntarily provided in the registration form: name, telephone number, e-mail address, as well as the actions that the User performs on the Website. Personal data is processed:
- in accordance with the regulations on personal data protection,
- in accordance with this Privacy Policy,
- to the extent and for the purposes necessary for the proper provision of the Services, and to the extent and for the purposes necessary to pursue legitimate interests (lawfully justified purposes), provided that the processing does not violate the rights and freedoms of the data subject.
Every person whose data we process (where we act as the data controller) has the right of access to their data, the right to rectification, erasure or restriction of processing, the right to object, and the right to lodge a complaint with a supervisory authority.
You can contact the person supervising the processing of personal data electronically at: info@winterro.com
.
We reserve the right to process your data after you have withdrawn your consent only to the extent necessary for the establishment, exercise or defence of legal claims before a court, or where national, EU or international law obliges us to retain the data.
The Controller has the right to make the Platform User’s personal data and other data available to entities authorised under applicable law (e.g. law enforcement authorities).
Personal data may be deleted as a result of withdrawing consent or lodging a legally admissible objection to the processing of personal data.
The Service Provider makes personal data available to entities authorised under the relevant provisions of law or exclusively for the purpose of providing its services to the Platform User.
Personal data is processed only by persons authorised by us or by processors with whom we closely cooperate.
3. Cookies
The Website uses cookies. These are small text files sent by a web server and stored by your browser’s software on your device. When the browser reconnects to the site, the website recognises the type of device from which the user connects. The parameters allow only the server that created them to read the information contained in them. Cookies make it easier to use websites that have been previously visited. The collected information concerns the IP address, type of browser used, language, type of operating system, Internet service provider, information about time and date, location, and information transmitted via the contact form.
On our Website, we use the following types of cookies:
- Session cookies: stored on the Platform User’s device and remain there until the end of a given browser session. The stored information is then permanently deleted from the device’s memory. The session cookies mechanism does not allow any personal data or confidential information to be collected from the Platform User’s device.
- Persistent cookies: stored on the Platform User’s device and remain there until they are deleted. Ending the browser session or switching off the device does not remove them from the Platform User’s device. The persistent cookies mechanism does not allow any personal data or confidential information to be collected from the Platform User’s device.
The Controller uses first-party cookies for the following purposes:
- Configuration of the service: recognising the Platform User’s device and its location and displaying the website appropriately, tailored to individual needs; adjusting font size, website appearance, etc.
- Carrying out processes necessary for the full functionality of the website: adapting the content of the website pages to the Platform User’s preferences and optimising the use of the website. In particular, these files make it possible to recognise the basic parameters of the Platform User’s device and properly display the website tailored to their individual needs;
- Analysis, research and audience measurement: creating anonymous statistics that help us understand how Platform Users use the Website, which enables us to improve its structure and content.
- To ensure the security and reliability of the Platform, the Controller uses third-party cookies for the following purposes:
- Collecting general and anonymous statistical data via analytical tools such as Google Analytics (cookie controller: Google Inc., based in the USA); using interactive functions to promote the service via social networks such as Facebook.com (cookie controller: Facebook Inc., based in the USA, or Facebook Ireland, based in Ireland).
Options for setting the storage conditions and access to cookies:
- The Platform User may independently and at any time change the settings regarding cookies, specifying the conditions for their storage and access to the Platform User’s device. Such changes may be made through the browser settings.
- In particular, these settings may be changed so as to block the automatic handling of cookies in the browser settings or to inform the User each time cookies are placed on the Platform User’s device. Detailed information on how to handle cookies is available in the browser settings;
- The User may delete cookies at any time using the relevant functions in the web browser they use;
- Restricting the use of cookies may affect certain functionalities available on the Platform.
4. Purposes and legal bases of processing
The purposes for which your data is processed have been defined. As the Controller, we will process your data for the following purposes:
- Accepting requests to use intermediation services and direct marketing of the services offered,
- Our legitimate interest, which consists in processing data for the establishment, exercise or defence of possible claims (Article 6(1)(f) GDPR),
- Carrying out all necessary activities related to ensuring full security,
- Archiving data related to requests to participate,
- Sending responses to submitted comments, letters, applications, reservations and complaints,
- Fulfilling the Controller’s legal obligations.
5. Information on registration forms
The Website collects information provided voluntarily by the user.
The Website may also save information about connection parameters (time stamp, IP address).
Personal data provided in the registration form are recorded by the Website Controller and by persons or organisations authorised by us.
A person who has filled in the registration form has the right to access, modify and request the cessation of processing of their data at any time.
6. Right to object
You have the right to object at any time to the processing of your data as described above. We will stop processing your data for these purposes unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or your data is necessary for the establishment, exercise or defence of legal claims.
You have the right to object at any time to the processing of your data for direct marketing purposes. If you exercise this right, we will stop processing your data for this purpose.
The processing of data prior to the withdrawal of your consent remains lawful.
7. Data retention period
Your personal data resulting from concluded agreements or submitted letters will be processed for:
- the period during which intermediation services or direct marketing of services provided by the Website are carried out;
- the period necessary to protect the interests of the Controller;
- the period for which consent has been granted;
- the period during which legal provisions may oblige the Controller to process the data for a specified time (e.g. accounting regulations);
Your objection to the processing of your personal data will be accepted where the basis for processing your data was the legitimate interest of the Controller or where the data was processed for direct marketing purposes, including user profile registration on the Website.
8. Data recipients
Your data may be transferred to:
- Partners and clients with whom the Controller cooperates in order to provide the service;
- Courier and postal companies delivering parcels to you;
- Law firms and legal service providers to whom the Controller has entrusted, for example, the conduct of proceedings;
- Entities providing us with technical support;
- Entities or authorities authorised under the provisions of law.
9. Rights of data subjects
In accordance with the GDPR, you have:
- The right of access to your data and to obtain a copy of it;
- The right to rectify (correct) your data;
- The right to erase data and to restrict processing;
- The right to object to the processing of data;
- The right to data portability;
- The right to lodge a complaint with a supervisory authority.
10. Voluntary provision of data
Providing data is voluntary, but necessary to use intermediation services or direct marketing of the services offered via the Website.