Privacy Policy

Your privacy is very important to us, therefore we kindly ask you to become familiar with the following information.

As part of our operations, we process personal data of natural persons. If you use our services, our website, our mobile application, or if you communicate with us in any other way it means that most probably we are processing your personal details.

The policy below includes all of the important information in this scope, such as who we are, in what situations, for what purposes, and in what scope do we process your personal details and what are your rights in relation to the processing of your personal data.

For your convenience and for the sake of transparency we include a table of contents so that you can find your way about this document and quickly find the information you are looking for.

If you find any of the information is unclear or needs to be discussed, you can always get in touch with us – we provide our contact details below.

Table of Contents

  1. Who we are and how to reach us?
  2. What do we do?
  3. For what purpose and on what grounds do we process your personal data?
  4. From whom do we collect your personal data
  5. Sending commercial information by electronic means
  6. Marketing profiling
  7. What type of data do we process?
  8. How long do we store your data?
  9. To whom do we disclose your data?
  10. Transfer of data outside the European Economic Area
  11. Withdrawing your consent for processing and objecting to processing
  12. Your other rights
  13. Voluntary data provision
  14. Age
  15. Cookie files and other similar technologies
  16. Changes to this Privacy Policy

Who we are and how to reach us?

Data Controller

Napoleon Sp. z o.o. (Ltd.) with its registered office in 9 Górskiego St., 00-033 Warsaw, POLAND registered within the register of entrepreneurs maintained by the District Court for the Capital City of Warsaw, 12th Commercial Division of the National Court Registry under KRS#: 0000470410, with a share capital of PLN 4,115,200, VAT#: PL5213650977 is the Data Controller for the personal data you share with us.

Whenever this Policy mentions the “Data Controller”, “us”, “our” etc. it refers to Napoleon Sp. z o.o. (Ltd.).

Contact details

You can reach us in the following ways:

  • by electronic mail: hello@napoleoncat.com,
  • by phone, from Monday to Friday between 9 a.m. and 5 p.m., +48 22 378 32 99,
  • by mail: Napoleon Sp. z o.o., 9 Górskiego St., 00-033 Warsaw, POLAND.

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What do we do?

We offer our users particular services (hereinafter referred to as “services”) consisting of providing marketing tools for social media platforms, e.g. for managing their presence within those platforms, their profiles, fanpages, etc. We provide those services in the form of a software application called NapoleonCat (hereinafter referred to as the “application”), which is made available in a Software-as-a-Service model. We operate a website under URL https://napoleoncat.com, and a mobile NapoleonCat application, which our Users can use to take advantage of our services (hereinafter jointly referred to as the “website and mobile app”).

Our users include mainly companies and organizations, with whom we conclude a service provision agreement. Details of the services which we provide are regulated by the Terms and Conditions of Services Provided by Electronic Means of Communication (hereinafter referred to as the “terms and conditions”).

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For what purpose and on what grounds do we process your personal data?

The grounds for processing your personal data depend on how you use our services or how you contact us and what role you assume in our interactions. We list some specific cases below.

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Using the website and the mobile app without prior registration

We process your personal data in order for the features of our website and mobile app to work correctly. Those features include mostly the possibility to review any content included on the website and in the mobile app, the possibility to use the webchat and contact forms, as well as to adapt the contents of the website and the mobile app to your preferences.

In such case, the grounds for the processing of your personal data by us is our legitimate interest consisting in making it possible for you to use the website and the mobile app and their features, according to Art 6(1)(f) of the Regulation of the European Parliament and Council (EU) 2016/679 of April 27, 2016, hereinafter referred to as “GDPR”.

Registration for use of the services, the website, and the mobile app

In order to use our services through the NapoleonCat applications, you must register.

Considering the specificity of social media platforms, which our services relate to, registration is always carried out by a particular natural person. It may be the user themself if they are a natural person, but it may also be a natural person representing an entity, their proxy, employee, or contractor with whom they have a civil contract in place – in such case that person acts on behalf of the user. To simplify we will just call them “associates”, without detailing the grounds on which they act on behalf of the user.

Hence, we can process your personal data if you are one of our users or their associates registered within our website and mobile app.

During the registration process, we ask for some specific information. In the case of a user being a natural person, it includes their personal data. In case registration is carried out by an associate on behalf of the user, we ask them to provide both their own details and the details of the user.

In both cases, the obtained data is processed with the purpose of concluding and executing the agreement between us and the user regarding the provision of services in relation to the registration.

In the case of users being natural persons, the grounds for the processing of their personal data is the possibility to execute the agreement in which the user takes part as one of its parties (Article 6(1)(b) GDPR). In the case of associates of users, the grounds for the processing of their personal data is our legitimate interest consisting of making it possible for us to execute the provisions of the agreement (Article 6(1)(f) GDPR).

Commercial communication – users, contractors, and their associates

Regardless of whether someone registers to use our services or not, as part of our operations, we interact with potential and current users (customers), contractors, suppliers, and natural persons, who represent them (e.g. are members of their boards, proxies, employees, contractors, etc.). Such communication may take place through different channels – e.g. in the form of e-mails or by phone, and in such case, we also process personal data of natural persons, who take part in that communication. Personal data of such persons may also be provided e.g. in commercial agreements which we conclude (as representatives signing those agreements or as contact persons).

Therefore we may process your personal data if you are one of the above persons.

In case of concluding a commercial agreement with a natural person, the grounds for processing the personal data of such a person is the possibility to execute such agreement (Article 6(1)(b) GDPR). In the case of associates of our users, their contractors, suppliers, etc. the legal grounds for processing personal data result from our legitimate interest and the necessity to maintain communication as part of our business operations and to conclude and execute agreements (Article 6(1)(f) GDPR).

Marketing

We process your personal data with the purpose of conducting our own marketing activities, i.e. to promote our service.

Marketing purposes include presenting you with our offers and promotions, proposing additional features, etc., including displaying ads in external services (such as e.g. Facebook or Google).

If you provide your consent we may also target you with some commercial information regarding our offer of services in a way which you indicate – e.g. by e-mail, text messages (SMS/MMS), by phone, through “push” messages, or by other means of electronic communication. In such a case, we will be using your personal data in order to send you commercial information using the channels you have chosen.

The data regarding your use of the website and the mobile App which we gather through our use of cookie files and similar technologies and use of marketing purposes is processed on the basis of your consent expressed in compliance with Art. 173 of the Telecommunications Law. For details regarding cookie files go to the Cookie Files section below.

The legal ground for processing your data for marketing purposes is our legitimate interest in promoting our own services, as per Art 6(1)(f) GDPR.

Contact forms

On the website and in the mobile application we provide contact forms and a webchat in order to make it easier for you to reach us. Using the form requires you to provide your personal data so that we can get back to you and respond to your questions. You can also provide us with other information to facilitate our communication and the processing of your request. In such cases we process your personal data with the purpose of identifying you and processing your request – the legal ground for the processing of your data is our legitimate interest consisting of communicating with our customers (Article 6(1)(f) GDPR).

Users’ social media profiles

As part of our services, we provide our users with an interface and some software tools which allow them to carry out communication activities on their social media profiles connected to our applications. The users (or their associates) may publish content on and communicate with other end users through those social media platforms. This also includes means of direct communication, such as Facebook Messenger.

Hence, by executing our services we process all data which our users (or their associates) place on social media and communication platforms through our applications or receive from those social media platforms – we assume the role of a passive intermediary by transferring this data between the user (or their associates) and the operators of those social media platforms. This information may include personal data of the users or their associates and third parties visiting user profiles on social platforms covered by our service(e.g. their authentication details for social media platforms), as well as the contents of their communications (posts, comments, etc.).

We process this data with the purpose of providing our services to the user and executing our agreement with the user. In the case the user is a natural person, the legal ground for processing is the requirement to execute the provisions of the agreement between us and the user (Article 6(1)(b) GDPR). In the case of representatives of the user, the legal ground is our legitimate interest consisting of making it possible to provide our services to the user (Article 6(1)(f) GDPR). In the case of third parties visiting user profiles or communicating with him on social platforms covered by our service, the legal basis for the processing of their data is our legitimate interest consisting of the necessity to perform the contract with the user (Article 6 (1) (f) of the GDPR).

NapoleonCat’s social media profiles

We also process personal data of the users visiting our own social media profiles (e.g. on Facebook, YouTube, Instagram, Twitter, Google My Business, LinkedIn). The data is processed in relation to maintaining our profile, including with the purpose of informing our users of our activity and promoting different events, services, and products in order to communicate with our users through those social media platforms. If you communicate with us using such social media platforms then, as result, we may process your personal data included in that communication. The legal ground for processing data for this purpose is our legitimate interest (Article 6(1)(f) GDPR) consisting of promoting our brand and building and maintaining a community loyal towards our brand.

In addition, we hereby inform that the operators of those social media platforms where we maintain our profiles also process personal data of their users and visitors of those profiles, including through the use of cookie files. In order to learn more about processing personal data by operators of social media platforms, you should become familiar with the privacy policies and terms and conditions of their respective services.

Other own purposes of the administrator

We process your personal data also with the purpose of executing purposes consisting of our own legitimate interests, i.e.:

  • in order to establish, investigate, exercise, defend, or settle any legal claims including those related to the provision of our services;
  • to conduct analyses and gather statistics regarding the use of our applications by users in order to improve them – which consists of e.g. analysis of user traffic across our website and mobile application in order to understand how our users use the service and make it more intuitive and convenient to use in the future;
  • for the purpose of reaching out to you – in order to react to your requests for information, complaints, to be able to contact you with regards to the provision of our services, inform you about changes in our Terms and Conditions of Service and the Privacy Policy.
  • to verify accounts, investigate any suspicious activity, discover and prevent fraud and other infringements of the law and the Terms and Conditions of Service;
  • to monitor, test, and improve our services and resolve any related problems;

The ground for this type of processing is Article 6(1)(f) GDPR.

Aside from the above we also process our users’ data with the purpose of executing any legal duties imposed upon us, resulting in particular from any fiscal regulations, accounting laws, including ensuring accountability (proving compliance with the duties imposed by the provisions of the law). We cooperate with law enforcement and other institutions that are authorized to request access to your data based on relevant regulations. The legal ground for this type of processing is our legal obligation (Article 6(1)(c) GDPR).

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From whom do we collect your personal data

Data collected directly from the person whom it is regarding or from the user

We collect your personal data mainly from you. You provide it to us, for example, when you set up an account on our website or mobile application, subscribe to a newsletter or other forms of marketing.

If you are an associate or a client of our user or their contractor, it is also possible that we have received your data from the user or contractor or their other associates – e.g. if you are the contact person for a given contract or are involved in a given project or if you contact the user on social media platforms covered by our service.

You can also provide us with your personal information by communicating with us – e.g., by asking questions about services, making complaints – on the website or through the mobile application, by e-mail, on social networking platforms, by phone, or by mail.

In addition, we process your data on how you use the website and the mobile app, our offer, and our services.

Registration and authentication with the use of a Facebook account

Your personal data may also be provided to us by Facebook, upon your request. This applies if you wish to register on our site using the Facebook functionality. If you use this option, you will first be asked by Facebook to confirm that it can provide us with your data to the extent necessary to register on our site. With your consent, Facebook will provide us with some of your data for registration purposes. In order to complete the registration process, it may be necessary to complete your profile with additional personal data. After creating an account in our service you will be able to log in to our service using the functionality offered by Facebook.

Sending commercial information by electronic means

If you agree to receive commercial information by electronic means (e.g., by e-mail or by means of push messages, web chat, or chatbot), the sending of such messages will constitute the transmission of commercial information by electronic means of communication and may also constitute direct marketing by means of telecommunication end devices, carried out by means of automatic calling devices – depending on which device you receive such communication.

In case you agree to contact us by phone or SMS for marketing purposes, commercial information will be presented by phone using the phone number you provided for this purpose. Such contact will constitute direct marketing using telecommunication terminal equipment and may be conducted using automatic calling devices.

You can withdraw your consent or limit how we send you such information at any time – see “Withdrawal of Consent and Objection to Processing” below for details.

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Marketing profiling

In some cases, when conducting our marketing activities, we make decisions about you in an automated fashion based on profiling, i.e. automatic processing of your personal data. Profiling is a way of processing personal data, which involves, among other things, using personal data to analyze or forecast personal preferences, interests, etc. The use of profiling enables the personalization of advertisements and content presented to the user.

The type of profiling, which we use, consists of using computer algorithms to analyze your personal data (your behavior on the site, the way you use the application, the data collected by cookies, as well as the personal data you provide) in order to display it directly on the site, or for direct marketing (e-mails, SMS/MMS, telephone marketing, push notifications, web chat or chatbot, etc.), as well as on websites outside of our site and mobile application (so-called remarketing), a personalized offer, based on your potential preferences and interests that may concern our services.

As a rule, the legal ground for profiling is our legitimate interest in marketing our own services in a way that suits your hypothetical preferences (Article 6(1)(f) GDPR) of the GDPR). However, in some cases, we ask you to agree to the chosen forms of marketing or profiling – in this case, the legal ground for profiling is your consent (Article 6(1)(a) GDPR).

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What type of data do we process?

General information

What data we process depends on the situation, including how you use the service, as well as what data you provide us with, and your role in our interactions. In particular, we may process the following categories of your personal data:

  • first and last name,
  • company name, VAT number, company registered address;
  • your position within the company;
  • data which allows us to identify you on social media platforms (e.g. your nickname);
  • e-mail address, phone number – which you provide when registering or for marketing purposes based on a separate consent;
  • information regarding what services you use;
  • data required for making payments for our services (e.g. the number of your bank account and the name of your bank);
  • information about your use of our website collected by means of cookies (in case you give us consent to use cookie files – details about cookie files can be found below in the Cookie Files section).
  • the IP address which you are using to communicate with our services, information regarding the device which you are using, and its settings (e.g. which web browser you use, your screen resolution);
  • the information which you include in your statements and any communication you direct at us – e.g. in our e-mail correspondences or telephone conversations, as well as the contents of your complaints;
  • the contents and scope of any statements of consent that you provide through our website or mobile application.

The data collected automatically

While you are using our website or mobile application, some information is gathered automatically.

The data automatically gathered by our Website

We process the so-called operational data (information about the way you use the webite), including information about your IP number, the telecommunications network endpoint, computer network, your browser, the language it is set to, information regarding the use of our services, information regarding the time you began and ended using them and every instance of use, type and version of your operating system, screen resolution, any data gathered within server logs and other similar information.

The data automatically gathered by our Mobile Application

If you use our mobile application we will collect and store such information as the details of the smartphone or tablet you are using to connect the given mobile application, including its Device ID, your User ID, the type, and version of the operating system.

Our mobile application may ask you, depending on what’s necessary, to allow access to different peripheral devices, which you can deny.

Purposes of processing for the data gathered automatically

The above data (i.e. the data collected through the website and the mobile application) is used for the purpose of maintaining transmission of information within the website and mobile application, as well as for the purpose of delivering the service you have ordered.

Regardless of the above, we will use the automatically gathered data to personalize content and adverts of our services within our website and outside of it as part of our remarketing efforts (for more information about this subject please refer to the section regarding Cookie Files found below). The automatically gathered data may be used for profiling.

The automatically gathered data is also used to study traffic on our website and within our mobile application.

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How long do we store your data?

The period for which we store your personal data depends on the particular legal ground for processing, hence:

  • in case we process your personal data on the basis of your consent – we do so until you revoke your consent;
  • in case we process your data for the purpose of executing an agreement we have concluded with you – we do so throughout the duration of this agreement or as long as it takes to perform our obligations;
  • in case we process your data on the basis of our legitimate interests – we do so until this interest expires (e.g. for the duration of the statute of limitations on claims) or until you object – in cases where such objection should be honored according to provisions of the law.

However, the period for which data is processed may be extended in the case when such processing is necessary in order to determine and enforce any claims or defend against such claims related to accountability for data processing, and after that time only within the scope required by provisions of the law.

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To whom do we disclose your data?

Entities which process data on our behalf

We disclose personal data to companies that provide services to us making it possible for us to carry out our obligations towards you or to conduct our business activity, according to legitimate purposes of data processing. Hence, your personal data which is required to carry out a particular purpose may be transferred to the following parties, which constitute data controllers doing so on our behalf:

  • in case of payment for our services – entities which act as intermediaries in processing payments for the purpose of carrying out their services, banks;
  • companies which provide us with their technological solutions and services required for our services to work properly;
  • providers of marketing, analytical and statistical services who help us understand what our clients are interested in and create more suitable offers, promotions and to personalize our marketing efforts;
  • companies conducting direct marketing services on our behalf (e.g. mailing services) or other advertising services;
  • companies which carry out customer service support – for this service to be carried out properly;
  • companies which provide us with accounting services, legal services, auditing, consulting, and tax advisory services;
  • providers of standard services related to the flow and storage of information – hosting services providers, email providers, providers of IT infrastructure, database maintenance services, and other IT services.

We also share your data with our authorized employees and associates.

Social media platform operators

Moreover, as we have mentioned in the “Users’ social media profiles” section above, within the scope in which we deliver a tool for transferring data between the user (or the user’s associate) and social media platforms, we transfer information from users or their associates, which may include their personal data, to the operators of those social media platforms and provide the user (or the user’s associates) with information from the operators of social media platforms which may contain personal data of third parties who contact the user on these platforms.

However, due to the terms for the integration of our service with social media platforms, each one of our users (or their associates) or third person hold their own accounts within the social media platform, and the social media platform operator is also a data controller on the basis of a separate agreement concluded directly between the operator and the user (or, respectively, their associate) or third person. Hence, within the scope of this data transfer, we only act as a passive intermediary provider of a tool made to transfer information between our user (or their associate) and another data controller, i.e. the operator of the particular social media platform.

reover, as we have mentioned in the “Users’ social media profiles” section above, within the scope in which we deliver a tool for transferring data between the user (or the user’s associate) and social media platforms, we transfer information from users or their associates, which may include their personal data, to the operators of those social media platforms.

However, due to the terms for the integration of our service with social media platforms, each one of our users (or their associates) hold their own accounts within the social media platform, and the social media platform operator is also a data controller on the basis of a separate agreement concluded directly between the operator and the user (or, respectively, their associate). Hence, within the scope of this data transfer, we only act as a passive intermediary provider of a tool made to transfer information between our user (or their associate) and another data controller, i.e. the operator of the particular social media platform.

Public authorities

We may also be required to provide personal information to entities authorized to obtain data under applicable laws, such as law enforcement agencies and other public institutions.

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Transfer of data outside the European Economic Area

The level of personal data security outside of the European Economic Area (EEA) may differ from that provided by European laws. For this reason, we only transfer personal data outside the EEA if an adequate level of protection is ensured.

The transfer of data to a third country is based on the decision of the European Commission on the adequate level of protection of personal data. If in relation to a given third country no decision of the European Commission on the adequate level of protection of personal data has been issued, then the transfer to this third country shall be made subject to ensuring appropriate security referred to in Article 46 section 2 GDPR.

Providing our services, we use services offered by Google, and therefore your personal data may be transferred outside the European Economic Area, i.e. to Google LLC in Delaware with its seat on Amphitheater Parkway No. 1600, Mountain View, California 94043, USA, as well as to entities directly or indirectly controlling Google LLC, controlled by Google LLC or under joint control with Google LLC and to their subcontractors. Due to the lack of a decision by the European Commission on the determination of an adequate level of personal data protection in relation to the United States, in order to adequately secure personal data, we used standard contractual clauses adopted by the European Commission, referred to in Article 46 section 2 GDPR. As part of standard contractual clauses, basic data security guarantees have been applied, such as: the obligation to process data in accordance with the instructions of the exporter and the clauses, the obligation to suspend the transfer of data, providing technical and organizational security measures, the obligation to notify about requests for disclosure of personal data, the obligation to notify about accidental or unauthorized access, obligation to provide facilities for audit. The full text of the contract containing standard contractual clauses, the scope of data processing and the level of data protection provided by Google is available at: https://cloud.google.com/terms/eu-model-contract-clause. For more information on standard contractual clauses, the scope of data processing and the level of data protection, please visit https://cloud.google.com/blog/products/identity-security/google-clouds-commitment-to-eu-international-data- transfers-and-the-cjeu-ruling.

You have the right to obtain a copy of your personal data transferred to a third country at any time.

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To the extent that processing is based on your consent, you may withdraw your consent at any time, without giving any reason. Withdrawal of consent does not affect the lawfulness of the processing that has been carried out on the basis of consent before it is withdrawn.

However, we would like to point out that in some cases, your consent is needed to provide certain services or activities – which we will inform you of when we receive your consent. In such a case, the withdrawal of your consent will make it impossible to provide such service or perform such action.

Objection to the processing of personal data

At any time you can also:

  • object to the processing of data for direct marketing purposes, including operations based on profiling, and
  • object, for reasons related to your specific situation, to the processing of data on the basis of our legitimate interest, other than direct marketing and profiling.

We hereby point out that if you object to the processing of data for a specific purpose (e.g. marketing), we will be able to continue to process the data for other purposes – e.g. in order to execute the provisions of an agreement.

You may withdraw your consent or issue an objection by sending an email to hello@napoleoncat.com.

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Your other rights

Provisions of the law foresee a scope of rights that you can exercise in relation to the processing of your personal data.

The right to access your personal data

You can request a confirmation that we are processing your personal data and if we do, you can demand access to the data we have on file. Details of this privilege are included in Art. 15 of GDPR.

The right to obtain a copy of the personal data on file

On this ground, we may present you with a copy of your data which we process.

The right to rectify

If the personal data of yours which we are processing is incorrect, you have the right to demand this data to be rectified and made complete in case it is incomplete.

The right to erasure – right to be forgotten

You have the right to demand your personal data to be removed by us from our files in case the criteria listed in the provisions of the law are met, e.g. in case the data is not required for the purposes for which it has been gathered anymore, or when you withdraw your consent for processing and there is are no other legitimate grounds for your data to be processed. Details of the right to be forgotten are regulated by Art. 17 of the GDPR.

The right to restriction of processing

You have the right to demand the processing to be restricted in cases and on conditions defined in Art. 18 of the GDPR.

The right to data portability

In cases and upon meeting the conditions defined in Art. 19 of the GDPR you have the right to transfer your data, i.e. to receive in a structured, commonly used format which can be read by a machine the data which refers to you, which you have shared with us, and you have the right to transfer this data to another entity.

How can you exercise your additional rights?

You can exercise the rights described above by sending an e-mail to hello@napoleoncat.com.

Exercising these rights is free of charge. However, if the data subject’s requests are manifestly unreasonable or excessive, in particular, due to their continuing nature (e.g., unreasonable, repeated requests for information), we will be able to charge a reasonable fee for providing the information, conducting any related communication or taking the requested action, taking into account the administrative costs, as well as to refuse to act on the request.

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Voluntary data provision

Provision of the data is voluntary but may be necessary for some purposes – for example, to set up an account on the site. Providing data and giving permissions for marketing purposes is voluntary.

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Age

The service is not designed for use by any person under sixteen years of age and is not intended for such individuals. We do not foresee any intentional collection of data concerning persons under sixteen years of age.

If we become aware that you are under the age of sixteen, we will take reasonable steps to remove your information from the database and restrict your future access to the service.

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Our website uses cookie files. Cookie files (so-called cookies) include IT data, in particular text files, commonly used on the internet, stored on your terminal device used for browsing the web (e.g. computer, smartphone, tablet).

Information contained in cookie files can be retrieved by our IT system or the systems of other entities. Cookies collect information concerning the use of the website – e.g. by remembering your visits to the website and the actions you perform on it.

We also use other technologies of this type, such as writing and reading information from localStorage, i.e. data storage. The LocalStorage technology allows for storing information similar to cookie files in your browser, especially in environments where the cookie file technology does not or cannot work properly.

Our website utilizes both internal cookie files managed by us and external cookie files originating from third parties, our partners.

Internal cookie files are used for the purpose of managing registration and authentication of users, maintaining navigation parameters for the site, monitoring traffic on the site and the way it is used, optimizing and personalizing content, processing forms, adapting the content of the site to user preferences, ensuring proper operation of the site and its features, discovering errors and abuse, as well as for statistical, analytical and marketing-related purposes.

External cookies files are used for operational purposes, for content personalization, statistical, analytical, and marketing-related purposes.

In many cases, the software for browsing internet sites (internet browser) allows for storing cookie files on your device by default.

You can change the browser settings regarding the use of cookie files and local storage at any time. There is, for example, a possibility to configure your internet browser in such a way, so that the possibility to store cookie files on your end device is limited or impossible. Changes to this configuration can be made through the settings panel of your internet browser. Depending on which browser you use, those settings can be changed e.g. in such a way that it blocks automatic use of cookies or informs you every time a cookie file is placed on your end-device.

You can also remove cookie files after they are stored on your device by using a particular feature of your internet browser.

Detailed instructions on allowing for cookie storage and removing cookie files can be found on customer support websites of internet browser providers or in relevant instruction manuals for those browsers.

In order for our system to be able to permanently remember your decision not to allow the use of cookies and local storage for the above-indicated purposes, we must store one cookie file on your device which will include such information. If the settings of your device prevent the use of cookie files we will naturally ask you for your consent upon every visit.

In order not to receive any cookie files you should take advantage of the features of the internet browser which you use to connect to our services and select the option of automatically rejecting cookie files. Those settings usually also allow you to manage cookie files.

The above remarks regarding internet browsers also apply to other software that can be used for browsing internet sites.

Particular browsers

The list below includes links to examples of official internet sites of the most commonly used internet browsers, where you can find information on what you have to do to change the settings of your internet browser as mentioned above:

Internet Explorer, Windows 10:

https://support.microsoft.com/en-us/topic/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d

Mozilla Firefox:

https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer

Google Chrome:

http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647

Opera:

http://help.opera.com/Windows/12.10/en/cookies.html

Safari:

https://support.apple.com/guide/safari/manage-cookies-and-website-data-sfri11471/mac

In order not to allow for use of the localStorage technology you should switch off the possibility of using this technology on your web browser, which usually works in a similar way to blocking cookie files.

In order to switch off the localStorage technology it is also recommended that you carry out the following activities, depending on which browser you use:

Configuration of the internet browser in a way that limits or makes it impossible to use cookie files on your end-device, as well as deleting the cookie files stored on your device, may limit the functionality of our site and incorrect functioning of our services.

The most significant tools used by third parties.

Google Analytics

We use the Google Analytics tool delivered by Google Inc. (“Google”) with its registered office in the USA. The service allows for an internet analysis which is carried out by Google (Google is the data controller in this case) on our behalf, using cookie files. The information gathered by cookie files regarding your use of our site, which is described here: https://policies.google.com/privacy?hl=en, is transferred to and stored by Google in the US. Within our services, we have activated the anonymization of IP addresses which limits the length of IP addresses of Google users. As an exception, the full IP address is transferred to a server in the US and shortened there. Anonymization takes place directly after downloading the data before it is stored. Upon our order, Google will use the information obtained to allow you to use our services, create reports regarding our features, and in order for additional services to be performed to us with by digital means and or the internet, particularly Google Analytics reports regarding our services in the context of demographic data and user interests. The IP address disclosed by your web browser within Google Analytics will not be combined with any other data by Google.

You can prevent storing the data obtained by means of cookie files and the data (including IP address) related to the use of our site by Google and prevent the processing of such data by Google by downloading and installing a web browser plugin which is available here: https://tools.google.com/dlpage/gaoptout?hl=en.

Facebook pixel

We use the Facebook Pixel technology for the purpose of measuring the effectiveness of the ads we publish on Facebook and optimizing their effectiveness. This tool allows us to measure the effectiveness of our ads based on the analysis of user activity on our Site. We process Facebook Pixel data in the following scope:

  • displaying ads for the proper target group,
  • creating cohorts of ad viewers,
  • analyzing the results of ad clicks,
  • using Facebook’s other advertising tools.

Information about the data which is collected by Facebook can be found here:

https://www.facebook.com/business/gdpr#faqs, in the „What data is the Facebook Pixel collecting?” tab.

Following the conversion path and the Google AdWords tag

For the purpose of measuring the effectiveness of advertising activities for our Site and Mobile Application on Google AdWords and optimization of the ads which we present there we use conversion following methods and remarketing. Those tools allow us to learn what happens after the Client interacts with an ad – have they completed the following activity, which we have indicated as valuable for the purpose of further conversion. This allows us to optimize our advertising activity on the Google AdWords platform. With the use of those tools:

  • we can see what keywords, ads, ad groups, and campaigns most effectively attract clients,
  • we know our Return on Investment (ROI) in advertising and we can make thoughtful decisions considering our business goals,
  • we can display AdWords ads to the visitors of our site.

You can find information about the data processed by our partners here:

https://policies.google.com/technologies/ads?hl=en

https://support.google.com/adwords/answer/93148?hl=en&ref_topic=3119146

You can prevent storing of the data obtained through cookie files and the data (including IP address) related to the use of the site by Google, and you can prevent the processing of such data by Google by changing the settings available under the following link:

https://adssettings.google.com/authenticated?hl=en

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Changes to this Privacy Policy

This Privacy Policy is continuously verified and amended as necessary.

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