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PRIVACY POLICY

Dear User and User,

due to the fact that you visit our website, we process certain information about you, such as information about the device you use, the country you come from, the web browser you use or your IP address, including the personal data you provide us e.g. by subscribing to the newsletter, using the contact form or otherwise interacting with the website.

In addition, we also process your personal data when you visit our Facebook® fanpage or profile on LinkedIn® or on another social networking site. In this case, we may process your personal data, such as name, surname, image as part of the profile picture, as well as information in the form of the content of comments or sent to us via chats through these portals.

Any personal data collected by us through the above websites will be used in accordance with generally applicable regulations in this regard, including 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 personal data and the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as "GDPR").

This privacy policy concerns how we process your personal data collected through our website on which there is a link to this privacy policy, which we refer to as the "Website" hereinafter.

 

1. WHO IS THE ADMINISTRATOR OF YOUR PERSONAL DATA?

The administrators (co-administrators) of all personal data collected through the Website are:

Rawlplug Spółka Akcyjna with its registered office in Wrocław, ul. Kwidzyńska 6, 51-416 Wrocław, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Wrocław-Fabryczna, VI Commercial Division of the National Court Register, under the number 0000033537, NIP: 8951687880; and

Koelner Rawlplug IP Spółka z ograniczoną odpowiedzialnością with its registered office in Wrocław, ul. Kwidzyńska 6, 51-416 Wrocław, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Wrocław-Fabryczna, VI Commercial Division of the National Court Register, under the number 0000370378, NIP: 6772354296; and

- (hereinafter collectively referred to as "Rawlplug" or "we").

We are part of a capital group that includes companies listed on the website at: https://rodo.rawlplug.com/pl/processing/ , sometimes collectively referred to as the " Rawlplug Group ".

You can contact us at any time regarding the personal data we process.

 

Rawlplug contact details: gdpr.rsa@rawlplug.com or gdpr.krip@rawlplug.com   

 

2.WHAT DATA DOES THE POLICY APPLY TO?

This privacy policy applies to all information, including personal data, collected by us:

- through the Website;

- through mobile and computer applications that create a system of your interaction with the Website that is not based on web browsers;

- in connection with your interaction with advertising materials and applications located on third party websites or as part of the services provided by these third parties, provided that these applications or advertising materials contain a link or reference to this policy.

 

The policy does not apply to information collected by:

- Rawlplug offline;

- any third parties (including subsidiaries or affiliates of Rawlplug), in particular through an application or content (including marketing content) available on or through the Website.

 

The term "personal data" used in this policy refers to any information about an identified or identifiable natural person; an identifiable natural person is a person who can be identified, directly or indirectly, in particular on the basis of an identifier such as name and surname, identification number, location data, online identifier or one or more specific physical, physiological, genetic, mental factors, the economic, cultural or social identity of a natural person.

3. PERSONS UNDER 16 YEARS OF AGE

The website is not intended for use by persons under the age of 16. No one under this age may transmit any information through the Site or post it on the Site. Rawlplug does not intentionally collect personal data from persons under the age of 16. If you are under 16, you may not use or submit any information through the Site, use any interactive content, including posting public comments on the Site, or submit any personal information to Rawlplug. If it turns out that Rawlplug has collected or received any personal data concerning a person under the age of 16 without the consent and knowledge of their legal guardians, we will immediately delete such personal data. If you suspect that we have this type of personal data, please contact us.

4. INFORMATION COLLECTED THROUGH THE SITE

Rawlplug collects information, including personal data:

- directly from you or automatically when you enter and use the Website, always with your consent; or

- automatically, when you enter and use the Website, collected through the so-called cookies essential cookies or performance cookies, without your express consent. The information collected in this way applies in particular to the way you use the Website, information about the device you use, the country you come from, the web browser you use or your IP address. We do not collect other personal data in this way, e.g. name, surname or e-mail address.

 

If your consent is required for the collection of personal data, personal data will be processed only to the extent provided for by this consent. You can withdraw your consent at any time, however, this will not affect the lawfulness of the processing of your personal data carried out before the withdrawal of consent.

 

Personal data collected for purposes other than the performance of legal obligations may be subject to profiling, i.e. automated analysis of your data in order to make predictions about preferences or future behavior (e.g. to match the content of the Website or marketing materials sent to you). This applies, for example, to Google marketing services or Meta Platforms.

For our part, we inform you that we do not perform automated data processing in a way that would result in us making any decisions regarding you or otherwise affect your situation.

Providing any personal data is not mandatory , however, it is necessary to browse and use the Website and use its functionalities.

The information collected by Rawlplug may also be used to evaluate, develop and improve the goods and services we sell.

Where applicable, we also collect information that you have posted or displayed ("posted") on the Site as a result of using the Site's functionality (collectively, "User Information"). Users' information about you is posted or transferred to third parties only at your request and risk. However, you should be aware that no security measures are perfect. Additionally, Rawlplug is unable to control the actions of other users of the Site or third parties to whom you choose to provide User Information. Therefore, we do not guarantee that Users' Information will not be displayed by unauthorized persons.

The publication by you on the Website of any photos containing your image constitutes consent for us to use this image on this Website.

Rawlplug may require specific personal information in order to provide certain services available through the Site. If you do not provide this data, you will not be able to send a request to Rawlplug for the provision of services by Rawlplug, and therefore the contract for the provision of such services cannot be concluded.

5. COOKIES

Cookies (so-called cookies) are text files containing small amounts of information that are downloaded to your device when you visit websites. More information on cookies can be found on the website: www.allaboutcookies.org or https://wszystkoociasteczkach.pl/

Cookies perform a number of functions, such as efficiently navigating between different websites, remembering user preferences (e.g. language selection), and generally increasing the comfort of using websites. Thanks to them, the advertisements appearing on the pages are more tailored to the user's interests.

There are two types of cookies: session cookies or permanent cookies, depending on how long they are stored on your computer or device:

- session cookies last for the duration of the internet session. They disappear as soon as you close your browser.

- permanent cookies remain on the computer or device also after closing the web browser and last for the time specified in the cookie. They are activated after the user enters the website from which they come.

 

Rawlplug does not use cookies to collect commercial information for sale to third parties.

We currently use the following types of cookies on the Site:

Necessary cookies

They enable you to enter the Website and display its content correctly, use the services available within the Website, e.g. detecting abuses in the field of authentication within the Website.

These files are automatically saved on your device, because their use does not require your express consent. You can disable their use only in your web browser.

Performance cookies

Performance cookies collect information about how users use the website, for example which pages are visited most often or if they receive error messages from the website. They do not collect information that allows you to be identified. All information collected by these cookies is general and anonymous. They are used to improve the functionality of the website.

As part of performance cookies, the Website uses Google Analytics.

Google Analytics is an analytics service provided by Google, Inc. Google Analytics creates a cookie whose purpose is to evaluate how the website is used and to compile reports on user activity. Google stores the information collected in this way on servers in the United States and other countries. Google may transfer this information to third parties if required to do so by law, or if a third party processes this information on Google's behalf. Google does not associate your IP address with any information held by Google. By using the Site, you agree to the manner and purpose of processing information by Google.

The use of these cookies requires your explicit consent, which you can express through the Website options (cookie banner) or in the options of the web browser used, or opt out of them on the Google Analytics website:  http://tools.google.com/dlpage/gaoptout

Functional cookies

Functional cookies allow us to remember your choices (e.g. username, language, region) and provide you with more personalized services. For example, a website may provide a weather forecast for the region you are in based on a cookie that carries information about the region you are in. These types of cookies can also be used to remember text size, fonts and other customizable page elements. They may also be used to provide services you have requested, such as watching a video. The information collected by these cookies may be anonymous and they cannot track your activity on other sites.

The use of these cookies requires your explicit consent, which you can express through the options of the Website (cookie banner) or in the options of the web browser used, with the proviso that this does not apply to the service (content of the Website) that you request from us (e.g. playing a movie or providing newsletter).

Advertising cookies

Third party cookies, enabling the provision of advertising content to users more tailored to their interests, advertising affiliation, marketing analysis.

We currently use:

Facebook Pixel - promotional and marketing activities in the retargeting process. Cookies are intended to be delivered by Meta Platforms Inc. with a properly tailored advertising message to users who have visited our Website. These functions serve to attract those users who have already used it back to the Website. Details regarding ads displayed on Facebook® or other Meta Platforms® can be found at the following link: https://www.facebook.com/adpreferences/ad_settings

The use of the above cookies requires your explicit consent, which you can express through the Website options (cookie banner) or in the options of the web browser used.

Managing cookies in the web browser

Modern web browsers allow you to take a number of actions in relation to cookies, including the ability to preview cookies stored on your computer or device, delete them, block cookies from a third party or only from a specific website, prevent cookies from being saved or delete all cookies after closing the browser.

Keep in mind that all individual arrangements will be lost after deleting cookies, including the decision to opt-out from saving cookies, as this requires downloading an opt-out cookie. If you choose to block cookies altogether, many websites will not function properly and some functionality will disappear.

6. INFORMATION PROCESSING

Rawlplug will use the properly collected information to deliver the services available on the Site and to personalize the Site. Rawlplug may use this information to communicate with you. The information collected from you will enable you to be informed about important functionalities of the Website and their changes, and will be used for statistical analysis in order to increase the quality of services offered to you.

We may process the information collected from you, with the exception of personal data (the processing of which is described in detail below), for the purposes of business activity, in particular to:

- presenting the Website and its content and enabling the use of the Website's functionality and its content;

- recognizing and responding to your inquiries, requests and requests submitted e.g. via the contact form on the website;

- communicating with you through various communication channels;

- publish product and service reviews or comments that you submit;

- comply with the obligations provided for by law, including protecting and preventing illegal transactions, managing complaints and increasing online security;

- controlling your compliance with all obligations provided for by law and Rawlplug's policies and other regulations; establishing, defending and pursuing claims by Rawlplug, including - transfer of claims against you;

- creating lists, analyzes and statistics in order to implement, evaluate and improve Rawlplug's business activities, goods, services (including the development of new products and services; communication management; determining and managing the effectiveness of advertising and marketing; analyzing products, services, websites and applications ; managing the Website and applications);

- direct marketing;

- pursue other purposes for which the information was collected;

other purposes and as otherwise described by us when collecting information;

- for any other purposes with your consent.

 

The following personal data collected through the Website are processed by Rawlplug for the following purposes and on the following legal grounds:

Objective

Personal data

Legal basis

Time

conclusion and performance of a contract for the sale of goods, services and products of the Rawlplug Group concluded via the Website

Identification and billing data: name and surname, address, tax identification number, e-mail, telephone number

Article 6 par. 1 letter b of the GDPR - performance of the contract

For the time necessary to perform the concluded contract as well as the limitation of mutual claims of the parties related to the contract

presenting the Website and its content and enabling the use of the functionality of the Website and its content and increasing security on the web.

Data obtained automatically from devices used to access the Site: IP address, location and time

Article 6 par. 1 lit. f GDPR - legitimate interest

for the duration of your stay on the Website and after leaving it until the browser is closed

creating lists, analyzes and statistics in order to implement, evaluate and improve the functioning of the Website, Rawlplug's business activities, goods, services (including the development of new products and services; communication management; determining and managing the effectiveness of advertising and marketing; analyzing products, services of websites and applications; managing the Site and applications).

Data obtained automatically from devices used to access the Site: IP address, location and time.

Article 6 par. 1 lit. f GDPR - legitimate interest, and in the case of processing this data through cookies - Art. 6 para. 1 lit. a - consent

For the time necessary to carry out these activities, not longer than 14 months.

recognizing and responding to inquiries, requests and applications submitted through the Website.

Contact and identification data obtained from you: name, surname, email address.

Article 6 par. 1 lit. and GDPR - consent

for the time needed to complete the communication and 3 years after the end or until the consent is withdrawn.

communicating with you through various communication channels, including for the purpose of sending marketing materials (e.g. newsletter), but we never initiate contact.

Contact and identification data obtained from you: name, surname, email address, telephone number .

Article 6 par. 1 lit. and GDPR - consent

until the consent is withdrawn

complying with legal obligations incumbent on Rawlplug, including protecting and preventing illegal transactions, managing complaints and increasing online security;

Data obtained automatically from devices used to access the Site: IP address, location and time.

Contact and identification data obtained from you: name and surname, email address.

Article 6 par. 1 lit. c GDPR - legal obligation

For the time needed to perform the obligation.

control your compliance with all obligations provided for by law and Rawlplug's policies and other regulations; establishing, defending and pursuing claims by Rawlplug, including the transfer of claims against you;

Data obtained automatically from devices used to access the Site: IP address, location and time.

Contact and identification data obtained from you: name and surname, email address.

Article 6 par. 1 lit. f GDPR - legitimate interest

For the period of limitation of claims.

marketing re-targeting

Data obtained automatically from devices used to access the Site: IP address, location and time.

Article 6 par. 1 lit. and GDPR - consent

For a period not longer than 180 days in the case of Facebook Pixel or until consent is withdrawn.

posting reviews of products and services submitted by you or comments on the Site.

Data obtained from you when interacting with the Website: name, surname, placed content, photos.

Article 6 par. 1 lit. f GDPR - legitimate interest

In time to remove the review/comment.

For other purposes.

As agreed

Article 6 par. 1 lit. a - consent

 

 

The following personal data collected via the Website (Facebook® or LinkedIn® social network) are processed by Rawlplug for the following purposes and on the following legal grounds:

 

creating lists, analyzes and statistics in order to implement, evaluate and improve the functioning of the Website, Rawlplug's business activities, goods, services (including the development of new products and services; communication management; determining and managing the effectiveness of advertising and marketing; analyzing products, services of websites and applications; managing the Site and applications).

Data obtained automatically from devices used to access the Site: IP address, location and time.

Article 6 par. 1 lit. f GDPR - legitimate interest

For the time necessary to carry out these activities, not longer than 14 months.

recognizing and responding to inquiries, requests and applications submitted through the Website.

Contact and identification data obtained from you: name, surname, email address.

Article 6 par. 1 lit. and GDPR - consent

for the time needed to complete the communication and 3 years after the end or until the consent is withdrawn.

communicating with you through various communication channels, but we never initiate contact.

Contact and identification data obtained from you: name, surname, email address .

Article 6 par. 1 lit. and GDPR - consent

for the time needed to complete the communication and 3 years after the end or until the consent is withdrawn, the latter applies especially in the case of continuous messages.

complying with legal obligations incumbent on Rawlplug, including protecting and preventing illegal transactions, managing complaints and increasing online security;

Data obtained automatically from devices used to access the Site: IP address, location and time.

Contact and identification data obtained from you: name and surname, email address.

Article 6 par. 1 lit. c GDPR - legal obligation

For the time needed to perform the obligation.

control your compliance with all obligations provided for by law and Rawlplug's policies and other regulations; establishing, defending and pursuing claims by Rawlplug, including the transfer of claims against you;

Data obtained automatically from devices used to access the Site: IP address, location and time.

Contact and identification data obtained from you: name and surname, email address.

Article 6 par. 1 lit. f GDPR - legitimate interest

For the period of limitation of claims.

posting reviews of products and services submitted by you or comments on the Site.

Data obtained from you when interacting with the Website: name, surname, placed content, photos.

Article 6 par. 1 lit. f GDPR - legitimate interest

For as long as you have an account on a social network or delete a review/comment.

 

7. TRANSMISSION OF INFORMATION COLLECTED BY RAWLPLUG

Rawlplug uses third parties to perform certain activities on its behalf. An example of this type of activity may be the operation of ICT systems, including e-mail, Website hosting, sharing ICT resources, data analysis, marketing support, customer service, legal services, accounting services, audit services, etc. Such third parties are entities processing personal data in on our behalf for the sole purpose of performing their function and may not process personal data for their own purposes. Rawlplug will ensure that the processing of your personal data by entities processing personal data on behalf of Rawlplug takes place in accordance with the principles set out in the GDPR, in particular that each such entity is aware of the obligations arising from the GDPR and complies with them. We assure

We may also share your personal data with other personal data administrators, in particular if it is necessary to fulfill the obligations imposed by law, in particular to ensure the protection of rights or security on the Website, other users or third parties (e.g. for purposes related to the prosecution of crimes). , billing). For example, it also concerns situations in which we provide personal data to state authorities, local government authorities or the judiciary, entities running economic information offices or buyers of receivables. Each time, Rawlplug will assess the admissibility of providing personal data, taking into account the type of applicant, the type of personal data requested and the impact that such sharing may have on your rights and the purposes for which the data was collected.

Rawlplug may share the collected personal data described in this Privacy Policy with a purchaser or other legal successor in the event of a merger, restructuring, reorganization, dissolution, diversification or sale of all or part of Rawlplug's assets, whether on an independent basis or as part of liquidation or restructuring proceedings or liquidation, if personal data are part of the assets sold.

We may share your personal information with carefully selected third parties for marketing or other purposes, provided that you have consented to this.

Recipients of personal data may be located in different countries, including countries where the law on the protection of personal data provides a lower level of protection than European Union law, in particular countries outside the territory of the European Union ("third countries"). Rawlplug may transfer your personal data to a third country only if:

- the competent authority of the European Union determines by means of an implementing act that this third country, territory or specific sector or specific sectors in that third country or the international organization in question ensure an adequate level of protection, or

- in the absence of the decision referred to above, only if appropriate safeguards are provided and provided that there are enforceable rights of data subjects and effective legal remedies, in particular through standard contractual clauses, or

other requirements of the GDPR have been met.

 

We currently transfer personal data obtained through the Website to the following entities in connection with the services provided to us:

- Google LLC based in California, USA and Google Ireland Ltd - an entity that is responsible for the tool and cookies for analyzing traffic on this website (Google Analytics) and for the operation of the Google Ads cookie. Details on the functioning of cookies can be found in chapter 5 of the Privacy Policy. The transfer of data to the USA is based on an agreement containing Standard Contractual Clauses, approved by the European Commission.

- Meta Platforms, Inc. based in California, USA and Meta Platforms Ireland Ltd - these entities are responsible for the operation of the Facebook Pixel cookie and the operation of the fan page on Facebook. They process your personal data if you have an active Facebook account. They allow, among others, to like our fanpage, read content posted on the fanpage, watch materials posted by us, publish your own content, such as writing comments or liking entries. Details on the functioning of the Facebook Pixel cookie can be found in chapter 5 of the Privacy Policy. The transfer of data to the USA is based on an agreement containing Standard Contractual Clauses, approved by the European Commission.

- Entities providing us with mass correspondence services, in relation to people who have subscribed to the newsletter. The transfer takes place on the basis of a personal data processing agreement.

 

8.LINKS TO THIRD PARTY SITES

Rawlplug may enter into business relations with third parties, as a result of which the Website may contain links originating from or originating from third party websites. We intend to provide on the Site only links to websites with high-quality and reputable content that Rawlplug believes may be useful to you. However, it should be borne in mind that Rawlplug has no control over third party websites and does not participate in any way in the creation of these websites.

If you follow a link on the Site and access a website provided by a third party, you leave the area managed by us. Third-party websites should have their own privacy policies, which you should read before using such a website. We are not responsible for any processing of your personal data by third parties referred to above, for the content on third party websites or for services offered by third parties, as well as for any damage suffered by you in this respect. Therefore, Rawlplug recommends that you read the policies found on all websites before submitting any data through those websites.

9. SAFETY

Rawlplug applies administrative, technical and physical security measures to protect personal data against accidental, illegal or unauthorized destruction, loss, alteration, access, disclosure or use. However, Rawlplug does not guarantee that as a result of these measures, your personal data will always be fully secure, due to the inherent risk and uncertainty in the functioning of the Internet and IT systems, as well as potential illegal hacking attacks.

Information security also depends on you. If you receive from Rawlplug or you choose a password needed to access certain content of the Site, you are obliged not to disclose this password to third parties and are responsible for its disclosure. Rawlplug also recommends that you carefully disclose and publish any postings on the Site, as they may be visible and accessible to third parties viewing the Site.

Any transmission of personal data via the Internet is not completely secure. Rawlplug strives to fully secure the personal data provided by you, but does not guarantee the security of personal data provided by the Website. The transfer of personal data is at your own risk. We are also not responsible for any circumvention of the security settings and security measures employed on the Site.

10. YOUR RIGHTS

The GDPR grants you the following rights regarding your personal data:

- access to personal data (including obtaining a copy of data) - on the terms set out in art. 15 GDPR;

- rectification (correction) of personal data - on the terms set out in art. 16 GDPR

- deletion of personal data - on the terms set out in art. 17 GDPR;

- restriction of processing - on the terms set out in art. 18 GDPR;

- transfer of data to another data administrator - on the terms set out in art. 20 GDPR.

 

You can exercise the above rights by contacting the administrator's representative for personal information security or by submitting an application to the following e-mail address:    gdpr.rsa@rawlplug.com ; gdpr.krip@rawlplug.com    

When submitting an application or during contact, we may ask you to provide additional information that allows us to verify your person.

Objection

In addition to the rights referred to in the preceding paragraphs, you can object to the processing of your personal data (including profiling) for direct marketing purposes at any time. After raising an objection, Rawlplug will stop processing data for this purpose.

For reasons related to your particular situation, you can object at any time to our processing of personal data (including profiling), if the basis for processing is a legitimate interest or public interest. In the event of an objection, we will stop processing your personal data, unless there are valid legitimate grounds for data processing, which according to the law should override your interests, rights and freedoms; or there are grounds for establishing, pursuing or defending our claims.

Complaint

You have the right to lodge a complaint with the President of the Personal Data Protection Office. Details and contact details can be found on the authority's website: https://uodo.gov.pl/

- if you believe that the processing of personal data by Rawlplug violates the law.

11.CHANGES TO THE PRIVACY POLICY

We may make changes to this Privacy Policy at any time, without the need to inform you about this fact.

__________________

Wroclaw, 07.08.2023

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