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Privacy Policy

 

Terms used in these Rules and Regulations have the meaning assigned to them in the Rules and Regulations of the omnichannel Synerise platform.

Service Provider, bearing in mind privacy and protection of personal data uploaded into the Application, shall apply required technical and organizational measures to ensure protection of the processed data. This applies, including but not limited to data encryption systems as well as to the system granting authorization to process said data. The Service Provider shall take all reasonable endeavours to make sure the data does not become available to unauthorized persons.

Personal Data

  1. Service Provider shall process personal data of the User, including but not limited to the name, surname, and electronic mail address in the scope that enables a proper performance of Services and for marketing of products and services both own and of third parties. Service Provider shall be entitled to assign the protection of data for the purposes mentioned hereinabove.
  2. Personal data administrator shall be Synerise S. A. with registered office in Kraków at the address: ul. Podole 60, Kraków 30-394, entered into the Register of Entrepreneurs of the National Court Register maintained by the District Court for Kraków Śródmieście in Kraków, Ninth Commercial Division of the National Court Register with the KRS number 0000468034, NIP number: 679 309 32 92, initial capital in the amount of PLN 225 800.00, paid up in full.
  3. The User shall entrust for processing to the Service Provider personal data uploaded to the Application, which belong to third parties. Data obtained in such manner may only be processed in order to render Services. Service Provider shall be entitled to subcontract data obtained in such manner for processing, for the purposes of rendering the Services. At the same time the User acknowledges that data obtained this way was acquired in the manner compliant with the legal provisions in force.
  4. Any and all personal data within the meaning of this Article shall be processed by the Service Provider in accordance with the provisions of the Act of 29 August 1997 on Protection of Personal Data.
  5. The User shall have the right to inspect and edit his personal data as well as demand that they cease to be processed. In case when said data is requisite for provision of Services and the User demanded that they cease to be processed, such demand shall be treated as having effect of a statement of termination of the Agreement for Provision of Services with immediate effect.
  6. With the moment of termination of the Agreement for Provision of Services the Service Provider shall cease to process any and all data uploaded to the Application during the term of the Agreement, unless the right to further process said data transpires from the provisions of the law.
  7. Service Provider shall employ all technical methods required to protect personal data uploaded to the Application, pursuant to legal provisions in force.
  8. Service Provider reserves the right to use, for the purposes of business activity conducted by him, created on the basis of processed data collective summary statistics, always making all the data anonymous prior to its use, in such manner so as to make it impossible to identify individual Users.
  9. Transaction data, including personal data, can be transferred to PayLane sp. z o.o. with its registered office at Arkońska 6/A3 Street, postal code: 80-387, KRS: 0000227278th to the extent which is necessary to support payments for the order.

Commercial Information

Service Provider shall be entitled to send to the electronic mail address of the User any commercial information within the meaning of the Article 10 of the Act of 18 July 2002 on Providing Services by Electronic Means coming from the Service Provider or third parties.

Cookies

In order to streamline the use of the Website and the Application, including but not limited to by its adjustment to personal needs of the Users, Administrator uses cookies, i.e., short text and numerical information registering with a device by means of which the User browses the service or uses the Application. Such files enable a future identification of said device and, consequently, the User at the subsequent visits to the Website or logging in with the Application. The User may, however, block or limit the access of cookies to his own device himself and permanently remove already saved files. In order to do so, the User should perform several modifications of settings in his web browser used for the Website or for using the Application. Failure to undertake said actions shall be deemed tantamount to granting consent for the cookies being recorded in the Users device. Administrator also states that blocking or limitation of the access of cookies to the Users device may adversely affect the functionality of the Website or Application, and guarantees that recording cookies in the Users device does not result in any configuration changes in the settings, either in the device itself or in its software.

Types of cookies:

  1. Administrator Cookies – means cookies placed by the Administrator, via the Service.
  2. Third-party Cookies – means cookies placed by the Administrator’s partners, via the Service.
  3. Session cookies – are stored within the Users device and stay there until a browser session is finished. Recorded information is later permanently removed from the device memory. Mechanism of session cookies does not allow for downloading any personal data or any confidential information from the Users device.
  4. Permanent cookies – are stored within the Users device and stay there until they are deleted. Ending a session of a web browser or turning off a device does not cause their removal from the Users device. Mechanism of permanent cookies does not allow for downloading any personal data or any confidential information from the Users device.

What are cookies used for?

Administrator cookies are used with the following purposes:

  1. to adjust the contents of the Website to User preferences and optimize the use of the Website and Application;
  2. recognize the device of the User, its location, and, as appropriate, to display Website content relevant to his individual needs;
  3. to optimize the use of the Website and Application by the User;
  4. to adjust the contents of the Website to User preferences and optimize the use thereof – specifically, said files allow for recognizing basic parameters of the Users device and displaying Website content customized for his individual needs;
  5. analyses, research and audit of website traffic by creating anonymous statistics which help understand how the Users benefit from websites, which allows for improvement of structure and content;
  6. to guarantee safety and reliability of the Website and Application
  7. for User profiling.

Third-party cookies are used with the following purposes:

  1. to present multimedia content sourced from outside internet services, e.g. YouTube, within the Website and Application;
  2. to collect general and anonymous statistical data by way of analytical tools, e.g. Google Analytics.
  3. to present commercial content customized to User preference by way of Internet advertising tool, e.g. Google AdSense.
  4. to use interactive functionalities in order to advertise the Website by means of social media, inter alia, Facebook.com, Pinterest.com, etc.

Appendix 2 for the Rules and Regulations of the  Synerise Omnichannel platform:

Anti-spam policy:

Terms used in these Rules and Regulations have the meaning assigned to them in the Rules and Regulations of the  Synerise omnichannel platform.

Service Provider, with a thorough understanding of spam as an infringing problem of the Internet, by creating this policy to supplement the provisions of the Rules and Regulations, introduces standards that aim to minimize the threat of spam.

The User shall bear sole and exclusive liability for uploading any and all content and data to the Application, including but not limited to the fact that the User shall bear sole and exclusive liability for the manner of processing thereof. An infringement of this policy shall constitute an infringement of these Rules and Regulations.

The User shall bear sole and exclusive liability for obtaining relevant consents of the persons whose personal data he is processing, as stipulated by the provisions of the law. This means a general ban on sending spam by way of the Application, namely, unsolicited commercial information within the meaning of Article 10 of the Act of 18 July 2002 on Providing Services by Electronic Means, and if the data processed within the Application have the status of personal data, the strict obligation to process them pursuant to the Act of 29 August 1997 on Protection of Personal Data and Orders issued on the basis thereof.

Examples of behaviours that may result in Users breach of the above mentioned ban on sending spam and/or constitute an infringement of the provisions on protection of personal data may be (this is not a full list):

  1. processing of data gathered in publicly available registers such as Central Registration and Information on Business
  2. processing data collected in purchased databases, already after the purchase of such bases, without obtaining the consents for processing of personal data from the persons whose data are already in such bases;
  3. processing data of persons who previously demanded a cessation of their data being processed.

Moreover, it must be underlined that:

  1. Contents sent by means of the Application must be compliant with the provisions of the law at all times, including but not limited to the following:
    • they may not infringe intellectual rights of third parties (e.g. unlawful use of someones trademark or work);
    • may not infringe personal rights or rights of third parties;
    • they may not constitute acts of unfair competition within the meaning of the Act of 16 April 1993 on Combating Unfair Competition (e.g. false marking of a product or service that may mislead potential clients as to their crucial characteristics, dissemination of false information on own or third party products or services for financial gains or to cause damages to a third party or, finally, infringement of advertising standards);
    • they may not infringe standards and limitations in the scope of advertisements in force in a given branch of industry (e.g. pharmaceutics);
  2. each message sent via Application:
    • must contain true registration data and contact details of the User;
    • should contain true and not misleading data in the fields ‘from’ (od) or ‘reply-to’ (odpowiedz do);
    • should not contain misleading marking that may suggest it was a continuation of previous correspondence, like, for example: RE, ODP, FWD;
    • should contain information on possibility of unsubscribing from further correspondence accompanied by the link for direct unsubscribing, which makes it possible to immediately remove the data of the recipient from a relevant subscription list;
  3. the following situations shall also be regarded as infringements of privacy policy:
    • If a User sends a message via the Application to the electronic address created in order to identify cases of sending messages to the addresses gathered in the databases and created with infringements of the laws (so-called spamtrap);
    • as the result of Users actions, the domain or the IP address used by the Service Provider are put on the so-called black lists, i.e. databases that contain the data of entities that send out spam;
    • the sum of undelivered correspondence within the send out exceeds 10% or the sum of recipients marking the correspondence as spam (so-called ‘spam complaint’) exceeds 0,01 %.