The following Privacy Policy sets out the rules for saving and accessing data on Users' Devices using the Website for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users' personal data, which they have provided personally and voluntarily through the tools available on the Website.
This Privacy Policy is an integral part of the Terms of Service, which defines the rules, rights and obligations of Users using the Website.
§1 Definitions
- Website – the "egzooedu.eu" website operating at https://egzooedu.eu
- External Website – websites of partners, service providers or recipients cooperating with the Administrator
- Website/Data Administrator – The Administrator of the Website and the Data Administrator (hereinafter referred to as the Administrator) is the company "Egzoovet lek. wet. Przemysław Łuczak", conducting business at: ul. Lipowa 3, 87-800 Włocławek, with tax identification number (NIP): 8882912278, providing electronic services through the Website
- User – a natural person for whom the Administrator provides electronic services through the Website
- Device – an electronic device with software through which the User accesses the Website
- Cookies – text data collected in the form of files placed on the User's Device
- GDPR – 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 (General Data Protection Regulation)
- Personal Data – means information about an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
- Processing – means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
- Restriction of Processing – means the marking of stored personal data with the aim of limiting their processing in the future
- Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements
- Consent – of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
- Personal Data Breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
- Pseudonymisation – means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
- Anonymisation – data anonymisation is an irreversible process of operations on data that destroys/overwrites "personal data" making it impossible to identify or link a given record to a specific user or natural person
§2 Data Protection Officer
Based on Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer.
For matters concerning data processing, including personal data, please contact the Administrator directly.
§3 Types of Cookies
- Internal Cookies – files placed and read from the User's Device by the Website's IT system
- External Cookies – files placed and read from the User's Device by IT systems of External Websites. Scripts of External Websites that may place Cookies on User Devices have been consciously placed on the Website through scripts and services made available and installed on the Website
- Session Cookies – files placed and read from the User's Device by the Website during a single session of that Device. After the session ends, the files are deleted from the User's Device
- Persistent Cookies – files placed and read from the User's Device by the Website until they are manually deleted. The files are not automatically deleted after the Device session ends unless the User's Device configuration is set to delete Cookie files after the Device session ends
§4 Data Storage Security
- Cookie storage and reading mechanisms – The mechanisms for storing, reading and exchanging data between Cookies saved on the User's Device and the Website are implemented through built-in web browser mechanisms and do not allow the collection of other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, Trojan horses and other worms to the User's Device is also practically impossible.
- Internal Cookies – the Cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content or information that could threaten the security of personal data or the security of the Device used by the User.
- External Cookies – the Administrator makes all possible efforts to verify and select Website partners in terms of User security. The Administrator selects well-known, large partners with global social trust for cooperation. However, the Administrator does not have full control over the content of Cookie files from external partners. The Administrator is not responsible for the security of Cookie files, their content and the use in accordance with the licence by Scripts installed on the website, originating from External Websites, to the extent permitted by law. A list of partners is included later in this Privacy Policy.
- Cookie control
- The User can at any time independently change the settings for saving, deleting and accessing data from saved Cookie files by any website.
- Information on how to disable cookies in the most popular computer browsers is available at: how to disable cookies or from one of the following providers:
- The User can at any time delete all previously saved Cookie files using the tools of the User's Device through which they use the Website services.
- User-side threats – the Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User's activity. The Administrator is not responsible for interception of this data, impersonation of the User's session or their deletion, as a result of conscious or unconscious User activity, viruses, Trojan horses and other spyware that may have infected the User's Device. Users should follow general internet safety guidelines to protect themselves from these threats.
- Personal data storage – the Administrator ensures that it makes every effort to ensure that personal data voluntarily entered by Users is secure, access to it is limited and carried out in accordance with its purpose and processing purposes. The Administrator also ensures that it makes every effort to secure the data it holds against loss by using appropriate physical and organizational safeguards.
- Password storage – the Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. Decryption of passwords provided on the Website is practically impossible.
§5 Purposes of Cookie Usage
- Improving and facilitating access to the Website
- Personalising the Website for Users
- Enabling login to the Website
- Marketing, Remarketing on external websites
- Conducting statistics (users, number of visits, device types, connection, etc.)
- Serving multimedia services
- Providing social services
§6 Purposes of Personal Data Processing
Personal data voluntarily provided by Users is processed for one of the following purposes:
- Provision of electronic services:
- User account registration and maintenance service on the Website and related functionalities
- Newsletter service (including sending advertising content with consent)
- Commenting/liking posts on the Website without registration
- Service for sharing information about content posted on the Website on social networks or other websites
- Communication between the Administrator and Users on matters related to the Website and data protection
- Ensuring the legitimate interest of the Administrator
Data about Users collected anonymously and automatically is processed for one of the following purposes:
- Conducting statistics
- Remarketing
- Ensuring the legitimate interest of the Administrator
§7 Third-Party Cookies
The Administrator uses javascript scripts and web components from partners on the Website who may place their own cookies on the User's Device. Remember that in your browser settings you can decide for yourself which cookies may be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:
- Multimedia services:
- Social/combined services: (Registration, Login, content sharing, communication, etc.)
- Newsletter services:
- Statistics services:
§8 Types of Collected Data
The Website collects data about Users. Some data is collected automatically and anonymously, and some data is personal data voluntarily provided by Users when signing up for services provided by the Website.
Anonymously collected data:
- IP address
- Browser type
- Screen resolution
- Approximate location
- Opened website subpages
- Time spent on each subpage
- Operating system type
- Previous subpage address
- Referring page address
- Browser language
- Internet connection speed
- Internet service provider
Data collected during registration:
- First name / surname / nickname
- Login
- Email address
- Residential address
- Phone number
- IP address (collected automatically)
- Tax identification number (NIP)
Data collected when subscribing to Newsletter:
- First name / surname / nickname
- Email address
- IP address (collected automatically)
Data collected when adding comments:
- First name and surname / nickname
- Email address
- Website URL
- IP address (collected automatically)
Some data (without identifying data) may be stored in cookie files. Some data (without identifying data) may be transferred to statistical service providers.
§9 Access to Personal Data by Third Parties
As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided is not transferred or sold to third parties.
Access to data (usually based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the website, i.e.:
- Hosting companies providing hosting or related services for the Administrator
- Companies through which the Newsletter service is provided
- Companies intermediating in online payments for goods or services offered through the Website (in case of making a purchase transaction on the Website)
Entrusting personal data processing – Newsletter
The Administrator, in order to provide the Newsletter service, uses the services of a third party – the MailerLite service. Data entered in the newsletter subscription form is transferred, stored and processed in the external service of this provider.
We inform you that the indicated partner may modify the indicated privacy policy without the Administrator's consent.
Entrusting personal data processing – Hosting, VPS or Dedicated Server Services
The Administrator uses the services of an external hosting, VPS or Dedicated Server provider to run the website. All data collected and processed on the website is stored and processed in the service provider's infrastructure. Access to data may occur as a result of maintenance work carried out by the service provider's personnel. Access to this data is regulated by an agreement concluded between the Administrator and the Service Provider.
Data processing in case of online payments
In case of online payments, all payment data is transferred directly by the User to the payment processor – Przelewy24 (for PLN transactions) or Stripe (for EUR transactions). Selected data necessary to complete the transaction is then transferred by this entity to the Administrator. Data transfer is regulated by an agreement concluded between the Administrator and the Service Provider.
§10 Method of Personal Data Processing
Personal data voluntarily provided by Users:
- Personal data will not be transferred outside the European Union, unless published as a result of individual User action (e.g., entering a comment or post), which will make the data available to anyone visiting the website.
- Personal data will not be used for automated decision-making (profiling).
- Personal data will not be sold to third parties.
Anonymous data (without personal data) collected automatically:
- Anonymous data (without personal data) will be transferred outside the European Union.
- Anonymous data (without personal data) will not be used for automated decision-making (profiling).
- Anonymous data (without personal data) will not be sold to third parties.
§11 Legal Basis for Personal Data Processing
The Website collects and processes User data based on:
- 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 (GDPR)
- Art. 6(1)(a)
the data subject has given consent to the processing of his or her personal data for one or more specific purposes - Art. 6(1)(b)
processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract - Art. 6(1)(f)
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
- Polish Act on the Protection of Personal Data of 10 May 2018 (Journal of Laws 2018, item 1000)
- Polish Telecommunications Law Act of 16 July 2004 (Journal of Laws 2004, No. 171, item 1800)
- Polish Copyright and Related Rights Act of 4 February 1994 (Journal of Laws 1994, No. 24, item 83)
§12 Personal Data Retention Period
Personal data voluntarily provided by Users:
As a rule, the indicated personal data is stored only for the period of providing the Service within the Website by the Administrator. They are deleted or anonymised within 30 days from the end of service provision (e.g., deletion of a registered user account, unsubscription from the Newsletter, etc.)
An exception is a situation that requires securing the legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User's request for its deletion, for no longer than 3 years in case of violation or suspected violation of the website's terms of service by the User.
Anonymous data (without personal data) collected automatically:
Anonymous statistical data, which does not constitute personal data, is stored by the Administrator for the purpose of maintaining website statistics for an indefinite period.
§13 User Rights Related to Personal Data Processing
The Website collects and processes User data based on consent. The User has the following rights:
- Right of access to personal data
Users have the right to obtain access to their personal data, implemented upon request submitted to the Administrator - Right to rectification of personal data
Users have the right to request from the Administrator immediate rectification of personal data that is inaccurate and/or completion of incomplete personal data, implemented upon request submitted to the Administrator - Right to erasure of personal data
Users have the right to request from the Administrator immediate erasure of personal data, implemented upon request submitted to the Administrator. In the case of user accounts, deletion of data consists of anonymisation of data enabling identification of the User. The Administrator reserves the right to suspend the implementation of the erasure request in order to protect the Administrator's legally justified interest (e.g., when the User has violated the Terms of Service or the data was obtained as a result of correspondence).
In the case of the Newsletter service, the User has the option to independently delete their personal data using the link included in each email sent. - Right to restriction of personal data processing
Users have the right to restrict the processing of personal data in the cases indicated in Art. 18 GDPR, including challenging the accuracy of personal data, implemented upon request submitted to the Administrator - Right to personal data portability
Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used, machine-readable format, implemented upon request submitted to the Administrator - Right to object to personal data processing
Users have the right to object to the processing of their personal data in the cases specified in Art. 21 GDPR, implemented upon request submitted to the Administrator - Right to lodge a complaint
Users have the right to lodge a complaint with the supervisory authority dealing with the protection of personal data (President of the Personal Data Protection Office in Poland).
§14 Contact with Administrator
The User can contact the Administrator in the following ways:
- Postal address – Egzoovet lek. wet. Przemysław Łuczak, ul. Lipowa 3, 87-800 Włocławek, Poland
- Email address – [email protected]
- Phone – +48 785 518 821
§15 Website Requirements
- Limiting or disabling cookies and local storage may cause some Website functions to be unavailable.
- The Website requires cookies to be enabled for proper operation.
§16 External Links
The Website may contain links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated by them may be dangerous for your Device or pose a threat to your data security. The Administrator is not responsible for content outside the Website.
§17 Changes to Privacy Policy
- The Administrator reserves the right to make any changes to this Privacy Policy without informing Users regarding the use of anonymous data or cookies.
- The Administrator reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, of which it will inform Users with user accounts or subscribed to the newsletter service, via email within 7 days of the change. Continued use of the services means familiarisation with and acceptance of the introduced changes to the Privacy Policy. If the User does not agree with the introduced changes, they are obliged to delete their account from the Website or unsubscribe from the Newsletter service.
- Changes to the Privacy Policy will be published on this Website subpage.
- Changes come into effect upon publication.