The following Privacy Policy outlines the rules for storing and accessing data on User Devices using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing the personal data of Users that have been provided by them personally and voluntarily via tools available in the Service.
This Privacy Policy is an integral part of the Terms of Service, which defines the principles, rights, and obligations of Users using the Service.
§1 Definitions
Service – the “aero4x4” website operating at aero4x4.pl or aero4x4.com
External Service – internet services of partners, service providers, or service recipients cooperating with the Administrator
Service/Data Administrator – The Service and Data Administrator (hereinafter the Administrator) is “Auto Podlasie Sp. z o.o.”, operating at: ul. Terespolska 14, 08-110 Siedlce, providing electronic services via the Service
User – a natural person for whom the Administrator provides electronic services via 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 – 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, identification number, location data, 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 – an 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 – 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 – 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 – Anonymisation of data is an irreversible process of operations on data that destroys / overwrites “personal data” making it impossible to identify or link a 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.
For matters related to 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. External service scripts that can place Cookies on the User’s Device have been deliberately placed in the Service through scripts and services provided 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 deleted automatically after the session ends unless the User’s Device is configured to delete Cookies after the session ends.
§4 Data Storage Security
Mechanisms for storing and reading Cookie files – mechanisms for storing, reading, and exchanging data between Cookies stored on the User’s Device and the Service are implemented through built-in web browser mechanisms and do not allow for 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. Transferring viruses, Trojan horses, and other worms to the User’s Device is also practically impossible.
Internal Cookies – Cookies used by the Administrator are safe for the User’s Devices and do not contain scripts, content, or information that could pose a threat to the security of personal data or the security of the Device used by the User.
External Cookies – The Administrator takes all possible actions to verify and select service partners in terms of user safety. The Administrator selects large, well-known partners with global social trust. However, he does not have full control over the content of Cookies from external partners. The security of Cookies, their content, and their lawful use by scripts installed in the Service from external services is not the responsibility of the Administrator as far as the law allows. The list of partners is provided in the further part of the Privacy Policy.
Cookie Control
The User can change the settings for saving, deleting, and accessing saved Cookies at any time by any website.
Information on how to disable Cookies in the most popular computer browsers is available on the page: how to disable cookies or from one of the indicated providers:
- Managing cookies in Chrome
- Managing cookies in Opera
- Managing cookies in Firefox
- Managing cookies in Edge
- Managing cookies in Safari
- Managing cookies in Internet Explorer 11
The User can delete all Cookies saved so far at any time using the tools of the User’s Device through which the User uses the Service.
User-side threats – The Administrator takes all possible technical measures to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of these data depends on both parties, including the User’s activities. The Administrator is not responsible for intercepting this data, impersonating the User’s session, or deleting it as a result of the User’s conscious or unconscious activities, viruses, Trojan horses, and other spyware that may be or have been infected with the User’s Device. Users should follow safe internet usage recommendations to protect against these threats.
Personal data storage – The Administrator ensures that all efforts are made to ensure that personal data voluntarily provided by Users are safe, access to them is limited, and implemented in accordance with their purpose and objectives of processing. The Administrator also ensures that he makes every effort to secure the data held against loss by using appropriate physical and organizational security measures.
§5 Purposes for Using Cookies
- Improve and facilitate access to the Service
- Personalize the Service for Users
- Marketing, Remarketing in external services
- Conducting statistics (users, number of visits, types of devices, connections, etc.)
- Providing multimedia services
§6 Purposes of Processing Personal Data
Personal data voluntarily provided by Users are processed for one of the following purposes:
- Providing electronic services:
- Services for sharing information about content posted in the Service on social networks or other websites
- Communication between the Administrator and Users regarding the Service and data protection
- Ensuring the legitimate interests of the Administrator
Data about Users collected anonymously and automatically are processed for one of the following purposes:
- Conducting statistics
- Remarketing
- Ensuring the legitimate interests of the Administrator
§7 Cookies of External Services
The Administrator uses JavaScript scripts and web components of partners in the Service, which may place their own Cookies on the User’s Device. Remember that in the settings of your browser, you can decide on the allowed Cookies that can be used by individual websites. Below is a list of partners or their services implemented in the Service, which may place Cookies:
- Multimedia services:
- Conducting statistics:
- Google Analytics
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 ways of using cookies at any time.
§8 Types of Data Collected
The Service collects data about Users. Some data are collected automatically and anonymously, while some are personal data provided voluntarily by Users during registration for specific services offered by the Service.
Anonymous data collected automatically:
- IP address
- Browser type
- Browser language
Data collected during registration:
- Email address
Data collected when subscribing to the Newsletter:
- Email address
Some data (without identifying data) may be stored in Cookies. Some data (without identifying data) may be transmitted to the statistical service provider.
§9 Access to Personal Data by Third Parties
In principle, 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 data (usually based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary for the operation of the service, such as:
§10 How Personal Data is Processed
Personal data voluntarily provided by Users:
- Personal data will not be transferred outside the European Union unless published due to an individual action of the User (e.g., entering a comment or post), which makes 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) will not be used for automated decision-making (profiling).
- Anonymous data (without personal data) will not be resold to third parties.
§11 Legal Basis for Processing Personal Data
The Service collects and processes Users’ 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)
- 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 10 May 2018 on the Protection of Personal Data (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:
In principle, the indicated personal data are stored only for the period of providing the Service by the Administrator. They are deleted or anonymized within 30 days from the termination of the provision of services (e.g., deletion of a user account, unsubscribe from the Newsletter, etc.).
An exception is a situation that requires securing the legally justified purposes of further processing of these data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of requesting their deletion by the User, for no longer than 3 years in case of violation or suspicion of violation of the service regulations by the User.
Anonymous data (without personal data) collected automatically:
Anonymous statistical data, which do not constitute personal data, are stored by the Administrator for an indefinite period to conduct service statistics.
§13 Users’ Rights Related to Personal Data Processing
The Service collects and processes Users’ data based on:
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Right of access to personal data Users have the right to obtain access to their personal data, implemented upon a request submitted to the Administrator.
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Right to rectify personal data Users have the right to request the Administrator to immediately rectify their personal data that are incorrect or to complete incomplete personal data, implemented upon a request submitted to the Administrator.
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Right to erase personal data Users have the right to request the Administrator to immediately delete their personal data, implemented upon a request submitted to the Administrator. In the case of user accounts, the deletion of data involves the anonymization of data that allows the User to be identified. The Administrator reserves the right to suspend the request to delete data to protect the legally justified interests of the Administrator (e.g., if the User has violated the Regulations or if the data were obtained as a result of correspondence). In the case of the Newsletter service, the User can independently delete their personal data using the link included in each sent email.
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Right to restrict the processing of personal data Users have the right to restrict the processing of personal data in cases specified in Article 18 of the GDPR, including questioning the accuracy of personal data, implemented upon a request submitted to the Administrator.
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Right to data portability Users have the right to obtain from the Administrator personal data concerning them in a structured, commonly used, and machine-readable format, implemented upon a request submitted to the Administrator.
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Right to object to the processing of personal data Users have the right to object to the processing of their personal data in cases specified in Article 21 of the GDPR, implemented upon a request submitted to the Administrator.
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Right to lodge a complaint Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.
§14 Contact with the Administrator
The Administrator can be contacted in one of the following ways:
- Postal address – Auto Podlasie Sp. z o.o., ul. Terespolska 14, 08-110 Siedlce
- Email address – kontakt@approduct.pl
- Telephone – +48 22 120 17 20
- Contact form – available at: https://aero4x4.com/kontakt/
§15 Service Requirements
Restricting the recording and access to Cookies on the User’s Device may cause some functions of the Service to malfunction.
The Administrator is not responsible for malfunctioning functions of the Service if the User restricts in any way the ability to save and read Cookies.
§16 External Links
In the Service – articles, posts, entries, or comments of Users may contain links to external websites that the Service Owner does not cooperate with. These links and the pages or files indicated under them may be dangerous for your Device or pose a threat to your data security. The Administrator is not responsible for the content found outside the Service.
§17 Changes to the Privacy Policy
The Administrator reserves the right to change this Privacy Policy at any time without notifying Users in terms of the use and use of anonymous data or the use of Cookies.
The Administrator reserves the right to change this Privacy Policy in terms of processing Personal Data, about which he will inform Users with user accounts or subscribed to the newsletter service, via email within 7 days from the change. Further use of services means familiarization and acceptance of the changes made to the Privacy Policy. In case the User disagrees with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter.
The changes to the Privacy Policy will be published on this subpage of the Service.
The introduced changes come into force upon their publication.