Privacy Policy

This Privacy Policy defines the rules for storing and accessing data on Users' Devices when using the Service for the purpose of electronic service provision by the Administrator, and the rules for collecting and processing Users' personal data, which they have provided personally and voluntarily through the tools available in the Service.

This Privacy Policy is an integral part of the Service Regulations, which define the rules, rights, and obligations of Users using the Service.

§1 Definitions

• Service - the "NS POLAND" website operating at https://www.nspoland.com

• External Service - websites of partners, service providers or recipients cooperating with the Administrator

• Service / Data Administrator - The Administrator of the Service and the Data Administrator (hereinafter referred to as the Administrator) is the company "Daniel Bąkowski, NS POLAND", operating at: Racice 18A, 88-150 Kruszwica, with tax identification number (NIP): 5562812993, providing electronic services through the Service

• User - a natural person for whom the Administrator provides electronic services through the Service.

• Device - an electronic device with software, through which the User gains access to the Service

• 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 any information relating to 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 using 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 - 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 - Anonymisation of data is an irreversible process of data operations 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

Pursuant to Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer.

For matters regarding 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 Service's ICT system

• External Cookies - files placed and read from the User's Device by ICT systems of External Services. Scripts of External Services, which may place Cookies on the User's Devices, have been consciously placed in the Service via scripts and services made available and installed in the Service

• Session Cookies - files placed and read from the User's Device by the Service during one session of a given 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 Service 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 Cookie files saved on the User's Device and the Service are implemented through built-in web browser mechanisms and do not allow for the retrieval of other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojan horses, and other worms to the User's Device is also practically impossible.

• Internal Cookies - the Cookie files 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 takes all possible steps to verify and select service partners in terms of User safety. The Administrator chooses well-known, large partners with global public trust for cooperation. However, the Administrator does not have full control over the content of Cookie files originating from external partners. To the extent permitted by law, the Administrator is not responsible for the security of Cookie files, their content, and their licensed use by Scripts installed in the service, originating from External Services. A list of partners is provided later in the Privacy Policy.

• Cookie Control

  • The User may at any time, independently change the settings for saving, deleting, and accessing data saved in Cookies by any website.

  • Information on how to disable Cookies in the most popular desktop browsers is available at: how to disable cookies or from one of the indicated providers:

    • Manage cookies in Chrome browser

    • Manage cookies in Opera browser

    • Manage cookies in FireFox browser

    • Manage cookies in Edge browser

    • Manage cookies in Safari browser

    • Manage cookies in Internet Explorer 11 browser

  • The User may at any time delete all Cookie files saved so far using the tools of the User's Device through which the User uses the Service.

• User-side Risks - The Administrator applies all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of these data depends on both parties, including the User's activity. The Administrator is not responsible for the interception of these data, impersonation of the User's session, or their deletion as a result of the User's conscious or unconscious activity, viruses, Trojan horses, and other spyware with which the User's Device may be or has been infected. To protect themselves from these threats, Users should adhere to the rules for safe internet use.

• Storage of Personal Data - The Administrator ensures that all efforts are made to keep personal data voluntarily entered by Users secure, with access limited and carried out in accordance with their purpose and processing objectives. The Administrator also ensures that all efforts are made to protect the data held from loss through the application of 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. Decrypting account access passwords provided in the Service is practically impossible.

§5 Purposes for which Cookies are Used

• Improvement and facilitation of access to the Service

• Personalization of the Service for Users

• Enabling login to the service

• Marketing, Remarketing in external services

• Ad serving services

• Affiliate services

• Statistical analysis (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 are processed for one of the following purposes:

• Provision of electronic services:

  • Registration and maintenance services for the User's account in the Service and related functionalities

  • Newsletter service (including sending promotional content with consent)

  • Commenting / liking posts in the Service without the need for registration

  • Services for sharing information about content placed in the Service on social networks or other websites.

• Communication between the Administrator and Users on matters related to the Service and data protection

• Ensuring the Administrator's legitimate interest

Data about Users collected anonymously and automatically are processed for one of the following purposes:

• Statistical analysis

• Remarketing

• Serving advertisements tailored to Users' preferences

• Affiliate program management

• Ensuring the Administrator's legitimate interest

§7 External Service Cookies

The Administrator uses javascript scripts and web components from partners in the Service, who may place their own cookie files on the User's Device. Remember that in your browser settings, you can decide which cookie files are allowed to be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookie files:

• Multimedia services:

  • YouTube

• Social / Connected services:
  (Registration, Login, content sharing, communication, etc.)
  

  • Twitter

  • Facebook

  • Google+

  • LinkedIn

• Ad serving and affiliate networks:

  • Google Adsense

• Statistics:

  • Google Analytics

Services provided by third parties are beyond the Administrator's control. These entities may at any time change their terms of service, privacy policies, purpose of data processing, and the manner of using cookie files.

§8 Types of Data Collected

The Service collects data about Users. Some data is collected automatically and anonymously, and some data is personal data voluntarily provided by Users when subscribing to individual services offered by the Service.

Anonymous data collected automatically:

• IP address

• Browser type

• Screen resolution

• Approximate location

• Subpages opened on the service

• Time spent on the relevant subpage of the service

• Operating system type

• Address of the previous subpage

• Referring page address

• Browser language

• Internet connection speed

• Internet service provider

Data collected during registration:

• First name / last name / nickname

• Login

• E-mail address

• Avatar / Profile picture

• Date of birth / age

• Website addresses

• Phone number

• PESEL number (Polish national identification number)

• IP address (collected automatically)

• NIP number (Polish tax identification number)

Data collected when subscribing to the Newsletter service

• First name / last name / nickname

• E-mail address

• IP address (collected automatically)

Data collected when adding a comment

• First name and last name / nickname

• E-mail address

• Website address

• IP address (collected automatically)

Part of the data (without identifying data) may be stored in cookie files. Part of the 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 are not transferred or resold to third parties.

Access to data (most often based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary for operating the service, such as:

• Hosting companies providing hosting or related services for the Administrator

• Companies through which the Newsletter service is provided

• Companies mediating online payments for goods or services offered within the Service (in case of making purchase transactions in the Service)

Entrustment of personal data processing - Newsletter

The Administrator does not use the services of a third party for the provision of the Newsletter service. Data entered in the newsletter subscription form are not transferred, stored, or processed in an external service of any other service provider.

Entrustment of personal data processing - Hosting, VPS, or Dedicated Server Services

To operate the service, the Administrator uses the services of an external hosting, VPS, or Dedicated Server provider - OVH sp. z o.o. All data collected and processed in the service are stored and processed in the provider's infrastructure located in Poland. Access to data may occur due to maintenance work performed by the provider's personnel. Access to these data is governed by an agreement concluded between the Administrator and the Service Provider.

Data processing in case of online payments

In the case of online payments, all payment-related data are transferred directly by the User to the entity processing the payment - Autopay S.A. Selected data necessary to complete the transaction are then transferred by this entity to the Administrator. The data transfer is governed 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 an individual action by the User (e.g., entering a comment or post), which will make the data available to anyone visiting the service.

• Personal data will not be used for automated decision-making (profiling).

• Personal data will not be resold 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) may be used for automated decision-making (profiling).
  Profiling of anonymous data (without personal data) does not produce legal effects or similarly significantly affect the person whose data is subject to automated decision-making.

• Anonymous data (without personal data) will not be resold to third parties.

§11 Legal Bases for Personal Data Processing

The Service 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 and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

  • 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)(c)
    processing is necessary for compliance with a legal obligation to which the administrator is subject

  • Art. 6(1)(f)
    processing is necessary for the purposes of the legitimate interests pursued by the administrator or by a third party

• Act of 10 May 2018 on personal data protection (Journal of Laws 2018 item 1000)

• Act of 16 July 2004 - Telecommunications Law (Journal of Laws 2004 No. 171 item 1800)

• Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No. 24 item 83)

§12 Personal Data Processing Period

Personal data voluntarily provided by Users:

As a rule, the indicated personal data are stored only for the period of service provision within the Service by the Administrator. They are deleted or anonymized within 30 days from the end of service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation that requires safeguarding the Administrator's legitimate interests for further processing of these data. In such a situation, the Administrator will store the indicated data, from the time of the User's request for their deletion, for no longer than 3 years in the event of a violation or suspected violation of the service regulations by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, are stored by the Administrator for the purpose of maintaining service statistics for an indefinite period.

§13 User Rights Related to Personal Data Processing

The Service collects and processes User data based on:

• Right to access personal data
  Users have the right to access their personal data, exercised through the user panel available after logging in and tools enabling account access in case of a forgotten password.

• Right to rectification of personal data
  Users have the right to request from the Administrator immediate rectification of personal data that is inaccurate or / and completion of incomplete personal data, exercised through the user panel available after logging in and tools enabling account access in case of a forgotten password.

• Right to erasure of personal data
  Users have the right to request from the Administrator immediate erasure of personal data, exercised upon a request submitted to the Administrator. In the case of user accounts, data deletion involves the anonymization of data enabling User identification. The Administrator reserves the right to withhold the implementation of a data erasure request to protect the Administrator's legitimate interest (e.g., if the User has violated the Regulations or data was obtained as a result of ongoing correspondence).
  In the case of the Newsletter service, the User can independently delete their personal data using the link provided in each sent e-mail message.

• Right to restriction of personal data processing
  Users have the right to restrict the processing of personal data in cases specified in Art. 18 GDPR, inter alia, disputing the accuracy of personal data, exercised upon a request submitted to the Administrator.

• Right to data portability
  Users have the right to receive from the Administrator their personal data in a structured, commonly used and machine-readable format, exercised upon a 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 cases specified in Art. 21 GDPR, exercised upon a request submitted to the Administrator.

• Right to lodge a complaint
  Users have the right to lodge a complaint with the supervisory authority dealing with personal data protection.

§14 Administrator Contact

The Administrator can be contacted in one of the following ways:

• Postal address - Daniel Bąkowski, NS POLAND, Racice 18A, 88-150 Kruszwica

• E-mail address - office@nspoland.com

• Telephone connection - +48 692 156 185

• Contact form - available at: /pl/kontakt

§15 Service Requirements

• Restricting the saving and access to Cookie files on the User's Device may cause some Service functions to malfunction.

• The Administrator bears no responsibility for improperly functioning Service features if the User in any way limits the ability to save and read Cookie files.

§16 External Links

In the Service - in articles, posts, entries, or user comments, there may be links to external websites with which the Service 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 the security of your data. The Administrator is not responsible for content located outside the Service.

§17 Changes to the Privacy Policy

• The Administrator reserves the right to change this Privacy Policy at any time without prior notice to Users regarding the application and use of anonymous data or the use of Cookie files.

• The Administrator reserves the right to change this Privacy Policy at any time regarding the processing of Personal Data, of which it will inform Users who have user accounts or are subscribed to the newsletter service, via e-mail within 7 days of the changes. Continued use of the services implies reading and accepting 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 Service or unsubscribe from the Newsletter service.

• Introduced changes to the Privacy Policy will be published on this subpage of the Service.

• Introduced changes come into effect upon their publication.