Privacy Policy

Privacy Policy

The following Privacy Policy sets out the rules for storing and accessing data on Users’ Devices using the Service for the purpose of providing electronic services by the Controller, as well as the rules for collecting and processing Users’ personal data, which have been provided by them personally and voluntarily via the tools available on the Service.

This Privacy Policy is an integral part of the Service Terms and Conditions, which define the rules, rights, and obligations of Users using the Service.

§1 Definitions

  • Service – the “INTRIST.pl” website operating at https://intrist.pl
  • External Service – websites of partners, service providers, or clients cooperating with the Controller
  • Service/Data Controller – the Controller of the Service and Data (hereinafter the Controller) is the company “INTRIST PROSTA SPÓŁKA AKCYJNA”, conducting business at: Prowansji 9c / 05-500 Józefosław, with tax identification number (NIP): 1231519984, and KRS number: 0000995143, providing electronic services via the Service
  • User – a natural person for whom the Controller provides electronic services via the Service
  • Device – an electronic device with software through which the User accesses 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 – 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, 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 – 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, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction
  • Restriction of processing – means the marking of 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 – the data subject’s 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 – means 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 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 operations on data 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

Pursuant to Article 37 of the GDPR, the Controller has not appointed a Data Protection Officer.

For matters concerning data processing, including personal data, please contact the Controller directly.

§3 Types of Cookies

  • Internal cookies – files placed and read from the User’s Device by the Service’s IT system
  • External cookies – files placed and read from the User’s Device by the IT systems of External Services. Scripts of External Services that may place cookies on the User’s Devices have been intentionally included 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 a single 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 Device session ends unless the User’s Device configuration is set to delete cookies after the session ends

§4 Data Storage Security

  • Mechanisms for storing and reading cookies – The mechanisms for storing, reading, and exchanging data between Cookies saved on the User’s Device and the Service are implemented through built-in web browser mechanisms and do not allow for the retrieval 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 practically impossible to transfer viruses, trojans, or other worms to the User’s Device.
  • Internal cookies – Cookies used by the Controller 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 Controller takes all possible measures to verify and select the Service’s partners in the context of User security. The Controller selects well-known, large partners with global social trust for cooperation. However, the Controller does not have full control over the content of cookies from external partners. The Controller is not responsible for the security of cookies, their content, or their licensed use by scripts installed in the Service from External Services, to the extent permitted by law. The list of partners is provided later in the Privacy Policy.

Cookie control

The User may, at any time, independently change the settings regarding the saving, deletion, and access to data of saved cookies for any website.

Information on how to disable cookies in the most popular desktop browsers is available at: how to disable cookies or from one of the indicated 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 Service.

User-side risks – The Controller uses all possible technical measures to ensure the security of data placed in cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Controller is not responsible for the interception of this data, impersonation of the User’s session, or their deletion as a result of conscious or unconscious activity of the User, viruses, trojans, and other spyware that may or have infected the User’s Device. Users should follow network usage recommendations to protect themselves from these risks.

Storage of personal data – The Controller ensures that all efforts are made to keep the personal data voluntarily entered by Users secure, access to them is limited, and processing is carried out in accordance with their intended purpose. The Controller also ensures that all efforts are made to secure the data held against loss, by using appropriate physical and organizational safeguards.

§5 Purposes for which Cookies are used

  • Improving and facilitating access to the Service
  • Personalizing the Service for Users
  • Affiliate services
  • Compiling statistics (users, number of visits, types of devices, connection, etc.)

§6 Purposes of personal data processing

Personal data voluntarily provided by Users are processed for one of the following purposes:

  • Provision of electronic services
  • Communication between the Controller and Users regarding matters related to the Service and data protection
  • Ensuring the legitimate interests of the Controller

Data about Users collected anonymously and automatically are processed for one of the following purposes:

  • Compiling statistics
  • Operation of affiliate programs
  • Ensuring the legitimate interests of the Controller

§7 Cookies of External Services

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

Statistics:

Services provided by third parties are beyond the Controller’s control. These entities may change their terms of service, privacy policies, data processing purposes, and methods of using cookies at any time.

§8 Types of data collected

The Service collects data about Users. Some data is collected automatically and anonymously, and some data is personal data voluntarily provided by Users when signing up for specific services offered by the Service.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Opened subpages of the Service
  • Time spent on a given subpage
  • Type of operating system
  • Address of the previous subpage
  • Referrer address
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected when expressing interest in contact:

  • Name / surname / pseudonym
  • Email address
  • IP address (collected automatically)

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

§9 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Controller. Data collected as part of the services provided are not transferred or sold 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, i.e.:

  • Hosting companies providing hosting or related services to the Controller
  • Companies through which the email contact service is provided

Entrusting the processing of personal data – Hosting, VPS, or Dedicated Server Services

The Controller, in order to operate the Service, uses the services of an external hosting provider, VPS, or Dedicated Servers – Kru.pl sp. z o.o. All data collected and processed in the Service are stored and processed in the provider’s infrastructure located in Poland. There is a possibility of access to data as a result of maintenance work carried out by the provider’s personnel. Access to this data is regulated by an agreement between the Controller and the Provider.

§10 Method of personal data processing

Personal data voluntarily provided by Users:

  • Personal data will not be transferred outside the European Union unless 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 any person visiting the Service.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be sold 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 sold to third parties.

§11 Legal bases for personal data processing

The Service 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
  • The Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
  • The Act of 16 July 2004 – Telecommunications Law (Journal of Laws 2004, No. 171, item 1800)
  • The Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994, No. 24, item 83)

§12 Period of personal data processing

Personal data voluntarily provided by Users:

As a rule, the specified personal data are stored only for the duration of the Service provided by the Controller. They are deleted or anonymized within 30 days from the 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 the legitimate interests of the Controller for further processing of this data. In such a situation, the Controller will store the specified data, from the time of the User’s request for deletion, for no longer than 3 years in the event of a breach or suspected breach of the Service’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 Controller for the purpose of compiling Service statistics for an indefinite period.

§13 Users’ rights related to personal data processing

The Service collects and processes Users’ data on the basis of:

  • Right of access to personal data
    Users have the right to obtain access to their personal data, exercised upon request submitted to the Controller.
  • Right to rectification of personal data
    Users have the right to request the Controller to promptly rectify any inaccurate personal data and/or complete incomplete personal data, exercised upon request submitted to the Controller.
  • Right to erasure of personal data
    Users have the right to request the Controller to promptly erase their personal data, exercised upon request submitted to the Controller. In the case of user accounts, data erasure consists of anonymizing data that enables identification of the User. The Controller reserves the right to suspend the execution of a data erasure request in order to protect the legitimate interests of the Controller (e.g., if the User has violated the Terms and Conditions or the data was obtained as a result of correspondence).
    In the case of the Newsletter service, the User may independently delete their personal data by using the link provided in each email message.
  • 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, for example, contesting the accuracy of personal data, exercised upon request submitted to the Controller.
  • Right to data portability
    Users have the right to obtain from the Controller their personal data in a structured, commonly used, machine-readable format, exercised upon request submitted to the Controller.
  • 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 Controller.
  • 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 Controller

You can contact the Controller in one of the following ways:

§15 Service Requirements

Restricting the saving and access to cookies on the User’s Device may cause some functions of the Service to malfunction.

The Controller is not responsible for any malfunctioning functions of the Service if the User restricts in any way the ability to save and read cookies.

§16 External links

The Service – articles, posts, entries, or User comments may contain links to external websites with which the Service Owner does not cooperate. These links and the sites or files indicated by them may be dangerous for your Device or pose a threat to the security of your data. The Controller is not responsible for content found outside the Service.

§17 Changes to the Privacy Policy

The Controller reserves the right to make any changes to this Privacy Policy without the need to inform Users regarding the use and processing of anonymous data or the use of cookies.

The Controller reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, of which Users with user accounts or subscribed to the newsletter will be informed by email within 7 days of the changes. Continued use of the services means that you have read and accept the changes to the Privacy Policy. If the User does not agree with the changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter.

Changes to the Privacy Policy will be published on this subpage of the Service.

The changes come into force upon their publication.