This is a translation of the Polish version of the Privacy Policy. In the event of any discrepancy, the Polish version shall prevail.
This Privacy Policy sets out the rules for storing and accessing data on the Devices of Users who use the Website for the purpose of the Administrator providing services by electronic means, and the rules for collecting and processing the personal data of Users that they have provided personally and voluntarily using the tools available on the Website.
This Privacy Policy is an integral part of the Terms of Service, which set out the rules, rights and obligations of Users using the Website.
§1 Definitions
- Website – the “mtdspecial.pl” website available at https://mtdspecial.pl
- External Website – websites of partners, service providers or service recipients cooperating with the Administrator
- Website / Data Administrator – the Administrator of the Website and the Data Administrator (hereinafter the Administrator) is “MTD SPECIAL Sp. z o. o.”, with its business address at Leszczanka 72B, 21-404 Trzebieszów, Poland, tax identification number (NIP): 8252198767, KRS number: 0000995287, providing services by electronic means through the Website
- User – a natural person for whom the Administrator provides services by electronic means 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 – 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 – any operation or set of operations 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 – the marking of stored personal data with the aim of limiting their processing in the future
- Profiling – 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 – 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 – 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 – 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 or 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 Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.
In matters concerning data processing, including personal data, please contact the Administrator directly.
§3 Types of Cookies
- Internal cookies – files placed on and read from the User’s Device by the Website’s IT system
- External cookies – files placed on and read from the User’s Device by the IT systems of External Websites. Scripts of External Websites that may place Cookies on Users’ Devices have been deliberately placed on the Website through scripts and services made available and installed on the Website
- Session cookies – files placed on and read from the User’s Device by the Website or External Websites during a single session of the Device. When the session ends, the files are deleted from the User’s Device.
- Persistent cookies – files placed on and read from the User’s Device by the Website or External Websites until they are deleted manually. The files are not deleted automatically when the Device session ends, unless the User’s Device is configured to delete Cookies at the end of the session.
§4 Data storage security
- Mechanisms for storing and reading Cookies – the mechanisms for storing, reading and exchanging data between the Cookies saved on the User’s Device and the Website are implemented through the built-in mechanisms of web browsers and do not allow other data to be retrieved from the User’s Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, Trojan horses or 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 takes all possible steps to verify and select website partners with regard to User security. The Administrator chooses well-known, large partners with global public trust. However, the Administrator does not have full control over the content of Cookies originating from external partners. To the extent permitted by law, the Administrator is not responsible for the security of Cookies, their content or their licensed use by Scripts installed on the website that originate from External Websites. A list of partners is provided later in this Privacy Policy.
- Cookie control
- The User may, at any time, change the settings for saving, deleting and accessing data stored in Cookies by any website
- Information on how to disable Cookies in the most popular desktop browsers is available at: how to disable cookies (in Polish) or from one of the following providers:
- The User may, at any time, delete all Cookies saved so far using the tools of the User’s Device through which the User uses the Website’s services.
- Threats on the User’s side – the Administrator uses all possible technical measures to ensure the security of data placed in Cookies. Please note, however, that the security of this data depends on both parties, including the User’s actions. The Administrator is not responsible for the interception of this data, the hijacking of the User’s session or the deletion of data as a result of the User’s conscious or unconscious actions, viruses, Trojan horses or other spyware with which the User’s Device is or has been infected. To protect themselves against these threats, Users should follow the rules for using the internet (in Polish).
- Storage of personal data – the Administrator ensures that it makes every effort to keep the personal data entered voluntarily by Users secure, to limit access to it and to use it in accordance with its intended purpose and the purposes of processing. The Administrator also ensures that it makes every effort to protect the data it holds against loss by applying appropriate physical and organisational safeguards.
- Storage of passwords – the Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this area. Decrypting account passwords provided on the Website is practically impossible.
§5 Purposes for which Cookies are used
- Improving and facilitating access to the Website
- Personalising the Website for Users
- Enabling Users to log in to the Website
- Marketing and remarketing on external websites
- Ad serving services
- Affiliate services
- Keeping statistics (users, number of visits, device types, connection, etc.)
- Providing multimedia services
- Providing social media services
§6 Purposes of processing personal data
Personal data provided voluntarily by Users are processed for one of the following purposes:
- Provision of electronic services:
- Registration and maintenance of a User account on the Website and related functionality
- Newsletter service (including, with consent, sending advertising content)
- Commenting on / liking posts on the Website without registration
- Sharing information about content posted on the Website on social media or other websites
- Communication between the Administrator and Users on matters related to the Website and data protection
- Pursuing the Administrator’s legitimate interest
Data about Users collected anonymously and automatically are processed for one of the following purposes:
- Keeping statistics
- Remarketing
- Serving advertisements tailored to Users’ preferences
- Running affiliate programmes
- Pursuing the Administrator’s legitimate interest
§7 Cookies of External Websites
On the Website, the Administrator uses JavaScript scripts and web components of partners who may place their own cookies on the User’s Device. Remember that in your browser settings you can decide 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 / connected services: (registration, login, content sharing, communication, etc.)
- Ad serving services and affiliate networks:
- Keeping statistics:
- Other services:
Services provided by third parties are beyond the Administrator’s control. These entities may at any time change their terms of service, privacy policies, purposes of data processing and the way they use cookies.
§8 Types of data collected
The Website collects data about Users. Some data are collected automatically and anonymously, and some are personal data provided voluntarily by Users when signing up for individual services offered by the Website.
Anonymous data collected automatically:
- IP address
- Browser type
- Screen resolution
- Approximate location
- Pages of the website opened
- Time spent on a given page of the website
- Operating system type
- Address of the previous page
- Referring page address
- Browser language
- Internet connection speed
- Internet service provider
Data collected during registration:
- First name / last name / nickname
- E-mail address
- Telephone number
- IP address (collected automatically)
Data collected when signing up for the Newsletter service
- First name / last name / nickname
- E-mail address
- IP address (collected automatically)
Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to the provider of statistical services.
§9 Access to personal data by third parties
As a rule, the only recipient of the 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 the data (most often on the basis of a data processing agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the website, i.e.:
- Hosting companies providing hosting or related services to the Administrator
- Companies through which the Newsletter service is provided
Entrusting the processing of personal data – Hosting, VPS or Dedicated Server services
To run the website, the Administrator uses the services of an external provider of hosting, VPS or Dedicated Servers – Oracle Corporation. All data collected and processed on the website are stored and processed in the service provider’s infrastructure located within the borders of the European Union. The service provider’s staff may gain access to the data as a result of maintenance work. Access to this data is governed by an agreement concluded between the Administrator and the Service Provider.
§10 How personal data are processed
Personal data provided voluntarily by Users:
- Personal data will not be transferred outside the European Union, unless they have been published as a result of an individual action by the User (e.g. posting a comment or entry), 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 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 are subject to automated decision-making.
- Anonymous data (without personal data) will not be resold to third parties.
§11 Legal bases for processing personal data
The Website collects and processes Users’ data on the basis of:
- 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)
- Article 6(1)(a)
the data subject has given consent to the processing of his or her personal data for one or more specific purposes - Article 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 - Article 6(1)(f)
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
- Article 6(1)(a)
- Polish Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
- Polish Act of 16 July 2004 – Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)
- Polish Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24, item 83)
§12 Period of processing personal data
Personal data provided voluntarily by Users:
As a rule, the personal data indicated are stored only for the period during which the Administrator provides the Service on the Website. They are deleted or anonymised within 30 days of the end of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.).
An exception is a situation that requires securing the legitimate purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the data, from the time the User requests their deletion, for no longer than 3 years in the event of a breach or suspected breach of the website terms by the User.
Anonymous data (without personal data) collected automatically:
Anonymous statistical data that do not constitute personal data are stored by the Administrator for an indefinite period in order to keep website statistics.
§13 Users’ rights related to the processing of personal data
The Website collects and processes Users’ data on the basis of:
- Right of access to personal data
Users have the right to access their personal data, exercised upon request submitted to the Administrator - Right to rectification of personal data
Users have the right to demand that the Administrator promptly rectify inaccurate personal data and/or complete incomplete personal data, exercised upon request submitted to the Administrator - Right to erasure of personal data
Users have the right to demand that the Administrator promptly erase their personal data, exercised upon request submitted to the Administrator. In the case of user accounts, erasure consists in anonymising the data that allow the User to be identified. The Administrator reserves the right to suspend the execution of a request for erasure in order to protect the Administrator’s legitimate interest (e.g. when the User has violated the Terms or the data were obtained as a result of correspondence). In the case of the Newsletter service, the User can delete their personal data themselves using the link included in every e-mail sent. - Right to restriction of processing of personal data
Users have the right to restrict the processing of their personal data in the cases specified in Article 18 of the GDPR, including when they contest the accuracy of their personal data, exercised upon request submitted to the Administrator - Right to data portability
Users have the right to receive from the Administrator the personal data concerning them in a structured, commonly used and machine-readable format, exercised upon request submitted to the Administrator - Right to object to the processing of personal data
Users have the right to object to the processing of their personal data in the cases specified in Article 21 of the GDPR, exercised upon request submitted to the Administrator - Right to lodge a complaint
Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.
§14 Contacting the Administrator
The Administrator can be contacted in one of the following ways:
- Postal address – MTD SPECIAL Sp. z o. o., Leszczanka 72B, 21-404 Trzebieszów, Poland
- E-mail address – info@mtdspecial.pl
- Telephone – +48 882 644 386
- Contact form – available at: https://mtdspecial.pl/en/contact/
§15 Website requirements
- Restricting the saving of and access to Cookies on the User’s Device may cause some Website functions to work incorrectly.
- The Administrator accepts no liability for Website functions that work incorrectly if the User restricts in any way the ability to save and read Cookies.
§16 External links
The Website – in articles, posts, entries or Users’ comments – may contain links to external websites with which the Website owner does not cooperate. These links and the pages or files they point to may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for content located outside the Website.
§17 Changes to the Privacy Policy
- The Administrator reserves the right to change this Privacy Policy at any time without notifying Users with regard to the use of anonymous data or the use of Cookies.
- The Administrator reserves the right to change this Privacy Policy at any time with regard to the processing of Personal Data, of which it will inform Users who have user accounts or who have subscribed to the newsletter service by e-mail within 7 days of the change. Continued use of the services means that the User has read and accepts the changes made to the Privacy Policy. If the User does not agree with the changes, the User must delete their account from the Website or unsubscribe from the Newsletter service.
- Changes to the Privacy Policy will be published on this page of the Website.
- Changes come into force upon publication.