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Privacy Policy of the Website www.mokamed.pl

The following Privacy Policy defines the rules for storing and accessing data on Users’ Devices who use the Website for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users’ personal data voluntarily and personally provided by them through tools available on the Website.

This Privacy Policy constitutes an integral part of the Website’s Terms of Service, which define the rules, rights, and obligations of Users using the Website.

§1 Definitions

  • Website – the website “mokamed.pl” operating at https://mokamed.pl

  • External website – websites of partners, service providers, or service recipients cooperating with the Administrator

  • Website/Data Administrator – The Website Administrator and Data Administrator (hereinafter referred to as the Administrator) is the company “Comfortel Sp. z o.o.”, operating at the following address: ul. Dojazdowa 9b, TYCHY, with the following tax identification number (NIP): 6462714151, KRS number: 0000253533, providing services electronically via the Website

  • User – a natural person for whom the Administrator provides services electronically via 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 April 27, 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 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, organization, structuring, storage, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making available, aligning or combining, restricting, erasing, or destroying;

  • Restriction of processing – means marking 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 analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements

  • Consent – 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, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed

  • Pseudonymization – 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person

  • Anonymization – Anonymization 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

The administrator has appointed Małgorzata Tchorz-Nowak as Data Protection Officer.

The Officer can be contacted by email at odo@comfortel.pl or in writing at ul. Dojazdowa 9b, TYCHY 43-100, Poland.

The Data Protection Officer can be contacted in all matters relating to the processing of personal data.

§3 Types of Cookies

  • Internal cookies – files placed on and read from the User’s Device by the Website’s ICT system

  • External cookies – files placed on and read from the User’s Device by the ICT systems of external Websites. Scripts of external Websites that may place cookies on the User’s 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 during a single session of a given Device. After 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 until they are manually deleted. The files are not automatically deleted after the end of the Device session unless the User’s Device configuration is set to delete cookies after the end of the Device session.

§4 Data storage security

  • Mechanisms for storing and reading cookies – Mechanisms for storing, reading, and exchanging data between cookies saved on the User’s Device and the Website are implemented through built-in mechanisms of web browsers 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. It is also virtually impossible to transfer viruses, Trojan horses, and other worms to the User’s Device.

  • 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 measures to verify and select website partners in the context of User security. The Administrator selects well-known, large partners with global social trust for cooperation. However, it does not have full control over the content of cookies from external partners. The Administrator is not responsible for the security of cookies, their content, and their use in accordance with the license by scripts installed on the website and originating from external websites, to the extent permitted by law. The list of partners is provided further in the Privacy Policy.

  • Cookie control
    The user can change the settings for saving, deleting, and accessing data stored in cookies by each website at any time.

  • Threats on the part of the User – The Administrator uses all possible technical measures to ensure the security of data stored in cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activities. The Administrator is not responsible for the interception of this data, impersonation of the User’s session, or its deletion as a result of conscious or unconscious User activity, viruses, Trojan horses, and other spyware that may be or have been infecting the User’s Device. In order to protect themselves against these threats, Users should follow the recommendations for safe use of the Internet.

  • Storage of personal data – The Administrator ensures that it makes every effort to ensure that the personal data processed, voluntarily entered by Users, is secure, access to it is restricted and carried out 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 organizational security measures.

§5 Purposes for which cookies are used

  • Improving and facilitating access to the Website

  • Personalizing the Website for Users

  • Marketing, remarketing on external websites

  • Affiliate services

  • Keeping statistics (users, number of visits, types of devices, connection, etc.)

  • Providing multimedia services

  • Providing social networking 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:
  • Communication between the Administrator and Users in matters related to the Website and data protection
  • Ensuring the legitimate interests of the Administrator

User data collected anonymously and automatically is processed for one of the following purposes:

  • Keeping statistics
  • Remarketing
  • Affiliate program services
  • Ensuring the legitimate interests of the Administrator

§7 Cookies from external websites

The Website Administrator uses JavaScript scripts and web components from partners who may place their own cookies on the User’s Device. Please note that in your browser settings, you can decide for yourself which cookies are allowed to be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, privacy policies, data processing purposes, and cookie usage at any time.

§8 Types of data collected

The Website collects data about Users. Some of the data is collected automatically and anonymously, while some of the data is 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
  • Website subpages opened
  • Time spent on a given subpage of the Website
  • Operating system type
  • Address of the previous subpage
  • Referrer address
  • Browser language
  • Internet connection speed
  • Internet service provider
  • Demographic data (age, gender)

Data collected during registration:

  • First name / last name / nickname
  • Email address
  • Phone number
  • IP address (collected automatically)

    Data collected when subscribing to the newsletter service
  • Email address

Some data (without identifying information) may be stored in cookies. Some data (without identifying information) may be transferred to a statistical service provider.

§9 Access to personal data by third parties

As a rule, the Administrator is the sole recipient of personal data provided by Users. Data collected as part of the services provided is 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 operate the website, i.e.:

  • Hosting companies providing hosting or related services to the Administrator
    Entrusting the processing of personal data – Hosting, VPS, or Dedicated Server Services

In order to operate the website, the Administrator uses the services of an external hosting provider, VPS or Dedicated Servers – <arel=”nofollow external” href=”https://rejestracjadomen.pl/pl/page/obowiazek-informacyjny-rodo”>RejestracjaDomen.pl sp. z o.o.. All data collected and processed on the website is stored and processed in the service provider’s infrastructure located within the European Union. It is possible to access the data as a result of maintenance work carried out by the service provider’s staff. Access to this data is regulated by an agreement between the Administrator and the Service Provider.

§10 Method of processing personal data

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union unless it has 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).
  • The 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 basis for the processing of personal data

The website collects and processes User data on the basis of:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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

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

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

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

§12 Period of personal data processing

Personal data provided voluntarily by Users:

As a rule, the personal data provided is stored only for the period of providing the Service within the Website by the Administrator. It is deleted or anonymized within 30 days from the moment of termination of the service (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.).

An exception is a situation that requires the protection of legitimate purposes for 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 the event of a violation or suspected violation of the website’s terms and conditions 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 of time.

§13 Users' rights related to the processing of personal data

The website collects and processes User data on the basis of:

  • Right of access to personal data
    Users have the right to access their personal data, which is exercised upon request submitted to the Administrator.

  • Right to rectify personal data
    Users have the right to request the Administrator to immediately rectify personal data that is incorrect and/or to supplement incomplete personal data, upon request submitted to the Administrator

  • Right to erasure of personal data
    Users have the right to request the Administrator to erase personal data without undue delay, upon request submitted to the Administrator. In the case of user accounts, the erasure of data consists in anonymizing data that enables the identification of the User. The Administrator reserves the right to suspend the execution of a request to delete data in order to protect the Administrator’s legitimate interest (e.g., if the User has violated the Terms and Conditions or the data has been obtained as a result of correspondence).
    In the case of the Newsletter service, the User has the option of deleting their personal data themselves using the link provided in each email message.

  • Right to restrict the processing of personal data
    Users have the right to restrict the processing of personal data in the cases specified in Article 18 of the GDPR, including questioning the accuracy of personal data, upon request submitted to the Administrator.

  • Right to transfer personal data
    Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used, machine-readable format, 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, 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 Contact the Administrator

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

  • Postal address – Comfortel Sp. z o.o., ul. Dojazdowa 9b, TYCHY
  • Email address – biuro@comfortel.pl
  • Telephone number – +48 32 218 02 80
  • Contact form – available at: /kontakt

§15 Website Requirements

  • Restricting the storage of and access to cookies on the User’s Device may cause some of the Website’s functions to malfunction.

  • The Administrator shall not be liable for any malfunctioning of the Website’s functions if the User restricts the storage and reading of cookies in any way.

§16 External Links

Within the Website – articles, posts, entries, or User comments may contain links to external websites with which the Website Owner does not cooperate. These links, as well as the pages or files they lead to, may be unsafe for your Device or pose a threat to the security of your data. The Administrator is not responsible for any content located outside the Website.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to make any changes to this Privacy Policy without notifying Users, insofar as the changes concern the use and processing of anonymous data or the use of Cookies.

  • The Administrator also reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, of which Users who have registered accounts or are subscribed to the newsletter service will be informed by email within 7 days of the change. Continued use of the services shall constitute acknowledgment and acceptance of the amended Privacy Policy. If the User does not agree with the introduced changes, they are required to delete their account from the Website or unsubscribe from the newsletter service.

  • Any changes to the Privacy Policy will be published on this subpage of the Website.

  • The introduced changes take effect upon publication.