Processing of personal data
In relation to compliance with the 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, applicable from 25 May 2018 (hereinafter “GDPR”) EU OJ L 119 of 4 May 2016), on the basis of Article 13 of the GDPR and in relation to the application of the Act on the Protection of Personal Data of 10 May 2018 (Journal of Laws 2018, item 1000, as amended), we would like to provide you with the information on the processing of your personal data.
I – Administrator:
The administrator of your personal data is Małgorzata Franke conducting business activity under the name MotoFocus Małgorzata Franke entered into the Polish Central Registration and Information on Business (CEIDG) by the competent minister of economy, operating under the address: ul. Za Dębami 3, 05-075 Warszawa, using the following NIP [Tax Identification Number]: 5251049153, REGON [National Business Registry Number]: 011752326 and e-mail address: email@example.com (hereinafter “ADO”).
II – Objectives and categories of your personal data and their processing basis
We process your personal data for the following purposes:
- managing the Website, based on the legitimate interest of the administrator (Article 6(1)(f) of the GDPR) which is to ensure the proper functioning of the Website – IP address, session data, browser data – the data is automatically collected
- ensuring the security of the Website and other users – based on the legitimate interest of the administrator (Article 6(1)(f) of the GDPR) which is to ensure the security of the website and the users – automatic collection of the IP address, browser name, browser type, operating system type
- displaying advertisements tailored to your preferences and interests in the legitimate interest of ADO (Article 6(1)(a) of the GDPR) – the data from the website you visited and the actions you performed on this website. The legitimate interest of ADO means the marketing of the products and services of ADO partners.
- fulfilling the legal obligations resulting from the GDPR in terms of the execution of your rights, and therefore archiving your requests addressed to us, or informing you of any threats to your privacy (Article 6(1)(c) of the GDPR) – your name, e-mail address, the type of request, information on its implementation, the description of the events constituting a violation, the estimation of its effect on the rights and freedoms of a natural person, the description of taken actions.
III – Data recipients
- Your personal data may be transferred to the hosting company as well as to public or private entities if such an obligation arises from generally applicable laws.
- In order to display advertisements tailored to your preferences, we use an adserver provided by Gemius. Therefore, we may transfer the personal data to subcontractors providing technical services of tailoring advertisements if such transfers comply with the GDPR and are consistent with the processing purposes.
- We use Facebook pixel in order to display advertisements as part of remarketing, therefore, your personal data will be processed by Facebook Ireland Ltd. which will be the administrator of your personal data.
The transfer to the entities specified hereinabove will be based exclusively on the outsourcing agreements made between ADO and the entities specified hereinabove. The exceptions constitute the entities which are entitled to access your personal data under applicable laws.
IV – Data retention period
We will process your personal data during the following period:
- the analysis of your activity on the Website – as long as we find it useful. In terms of Google Analytics, the data is stored for 14 months, and it is automatically removed afterwards.
- management of the Website – as long as we find such data useful.
- ensuring the safety of the Website and users – until the data renders useless
- displaying advertisements tailored to your needs and creating your profile – until you provide us with your objection. The data is stored for a period of 3 years, and afterwards – among others, for the purpose of protecting the privacy of Internet users, it is sampled (31 out of 32 records are removed) which allows for the fulfilment of statistical purposes while securing the rights and freedoms of the persons whose data is processed, the fulfilment of legal obligations resulting from the GDPR in terms of the execution of your rights, and therefore archiving your requests addressed to us, or informing you of any threats to your privacy – until the expiration of limitation periods.
V – Transfer of data to a third country
Your personal data will not be transferred to a third country, i.e., outside the EEA.
VI – Your rights:
Please be advised that you have the following rights:
- The right to access your personal data and its copies,
- The right to rectify (correct) your personal data,
- The right to remove data – if you believe that we have no right to process it, you may request its removal,
- The right to restrict the data processing – you may request to restrict the processing of personal data to the storage of agreed actions if your data is incorrect or its processing is illegal, and you do not wish us to delete it because it is necessary for the investigation, establishment or defence of claims or for the period of determining the legitimacy of an objection.
- The right to object – you may object to the processing of your data for marketing purposes if such processing is based on the legitimate interest of the administrator, and we cease such processing. You may also object to the processing of your data for other purposes, including the profiling of your data, if the legal basis for such processing is the legitimate interest of the administrator. The request should include the justification of the objection through defining the specific circumstances resulting in you submitting an objection. The objection will not be considered if we prove that our legitimate interest is superior to your claim, or that we require your data for the establishment, investigation or defence of claims against the State.
- The right to transfer data – the right to transfer the data applies to automatically processed data that you provided on the basis of consent or an agreement. You may receive it in a structured format, for example xml, or we can send it directly to the designated personal data administrator.
- The right to submit a complaint – since 25 May 2018, if you decide that we are responsible for unlawful processing of your data, you may submit a complaint to the President of the Personal Data Protection Office or any other supervisory authority.
- In the event that your data is processed on the basis of your consent, you may withdraw such consent which will result in the cessation of our processing of such data in the absence of any other legal basis providing us with the possibility of such processing. The withdrawal of your consent will not affect the lawfulness of the processing before such withdrawal.
If you wish to exercise your rights, please send a request via e-mail: firstname.lastname@example.org.
VII – Information on the required/voluntary data submission
1. In the case of data necessary to display the advertisements, the provision of such data is voluntary and it is required to fulfil the objective. You have the right to withdraw your consent to such data processing at any time via the Gemius Privacy Tool: privacypolicy.gemius.com or by changing your browser settings.
- Providing your personal data to exercise your rights resulting from the GDPR is necessary to enable us to fulfil our obligations towards you pursuant to the GDPR. In the absence of this, we cannot identify you or evaluate the legitimacy of your request.
- In other cases, providing the data is voluntary.
VIII – Automated Personal Data Processing
We process your personal data automatically by profiling, however, this does not result in any legal consequences towards you, nor does it affect your position in a similar way.
- When starting to use the website, you accept the storage of cookies from the website on your device (e.g. computer, phone) by pressing the “Accept” button.
- The collected data is used to monitor and check how the users utilise the websites, and to improve the functioning of the website, ensuring more effective and problem-free navigation.
- We monitor user information using the Google Analytics tool which records user behaviour on the website. We have implemented IP address anonymisation in Google Analytics, therefore, we collect only aggregated, anonymous data which does not enable us to identify individuals.
- The information collected with cookies also allows us to specify the target groups of advertisement recipients, measure the advertising effectiveness and help us determine the most appropriate audience for a particular advertising campaign. Due to these mechanisms, each Internet user can view advertisements consistent with their interests without having to deal with uninteresting content. For more information about the tools that we used to display your advertisements, please visit: http://www.privacypolicy.gemius.com/
- We also use Facebook pixel for remarketing purposes (that is, e.g., if you enter our website and your become interested in a certain topic – you might see advertisements tailored to your interests on your Facebook). Detailed information on how the pixel operates and what data is collected can be found at: https://www.facebook.com/business/gdpr
- To summarise, the website uses the following cookies:
a) “essential” cookies enabling the use of services available within the website, for example, authentication cookies used for services that require authentication within the website;
b) cookie files which help to ensure security, e.g., they are used to detect misuses involving authentication within the website;
c) “performance” cookies which make it possible to collect information about the way in which the websites are used (we apply Google Analytics for statistical purposes);
d) “functional” cookies allowing “remembering” the settings selected by the user and personalising the user interface, e.g., in terms of the language or region of the user’s origin, the font size, the website appearance, etc.
e) “advertising” cookies enabling us to provide users with advertising content more tailored to their interests.
- The user may at any time disable or restore the option of collecting cookies by changing the settings in the web browser. Instructions for managing cookies are available on the following website: