Privacy policy

Hello, good morning! If you have arrived here, it is a reliable sign that you value your privacy. We understand this very well, which is why we are providing you with a document in which you will find, in one place, the principles of personal data processing and the use of cookies and other tracking technologies in connection with the operation of the asmapoland.com website A formal information to start - the administrator of the service is ASMA Polska Sp. z o.o., Wola Ducka ul. Mostów 10, 05-408 Glinianka k.Warszawy e-mail: biuro@asmapoland.com. This privacy policy has been constructed in the form of questions and answers. The choice of this form was dictated by the care for clarity and legibility of the information presented to you. If you have any doubts about the privacy policy, you can contact us at any time by sending a message to leszek.stempel@asmapoland.com.

# 1: Who is the controller of your personal data?

The administrator of your personal data is ASMA Polska Sp. z o.o., Wola Ducka ul. Mostów 10, 05-408 Glinianka k.Warszawy e-mail: biuro@asmapoland.com.

# 2: Who can you contact about the processing of your personal data?

As part of the implementation of data protection in our organisation, we have decided not to appoint a Data Protection Officer due to the fact that it is not mandatory in our situation. You can contact us on matters relating to data protection and privacy more broadly at leszek.stempel@asmapoland.com.

# 3: What information do we have on you?

Depending on the purpose, we may process the following information about you:

• name
• e-mail address
• data contained in e-mail correspondence
• information visible on social media profiles
• VAT number
• phone number
• IP address
• approximate location
• statistics relating to newsletters received
• content of comments/opinions added on the site

We have listed specific information above. On the other hand, you will find the categories of personal data allocated to the different processing purposes in Annex 1 of this privacy policy. Furthermore, we use tools that collect a range of information about you in relation to your use of our website. This includes, in particular, the following information:

• information about your device, operating system and browser
• user-ID
• IP address subject to truncation and anonymisation
• date of site visit
• subpages viewed
• time spent on the site
• transitions between sub-pages
• mouse clicks or screen taps
• clicks on individual links
• the source from which you go to the page
• your age bracket
• Your gender
• Your approximate location limited to
• Your interests determined by your online activities
• This information is referred to hereafter in this privacy policy as "Anonymous information„

Anonymous Information does not, in itself, in our view, have the character of personal data, as it does not allow us to identify you and we do not collate it with the typical personal data we collect about you. Nevertheless, taking into account the strict jurisprudence of the Court of Justice of the European Union and the divided opinions among lawyers, as a precaution, in case Anonymous Information is attributed with the character of personal data, we have also included detailed explanations in this privacy policy regarding the processing of this information. We are not able to provide you with access to Anonymous Information about you, as we are not able to attribute any of the Anonymous Information to any specific user. From the tools that collect Anonymous Information, we only have access to a set of statistics and information that is not attributed to specific individuals. Furthermore, we do not have access to the information collected by some tools at all, as we are only interested in the correct functioning of the function provided by the tool, not the information collected by the tool. For example, a particular plug-in may collect some information, but it is not made available to us in any way, and we are not interested in this information at all, as we are only interested in the particular functionality of the plug-in (e.g. sending a newsletter form) simply working. The processing of Anonymous Information allows us to ensure that you can use the functionality available on the website. Furthermore, Anonymous Information is used for analytical and statistical purposes as well as for marketing purposes, such as setting and targeting advertisements. As Anonymous Information is collected by external tools we use, Anonymous Information is also processed by the tool providers under the terms of their terms of use and privacy policies. Anonymous Information is also used by the providers of the individual tools to provide and improve services, manage services, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalise the content and advertising displayed on individual services, sites and applications. The tools we use that involve the collection of Anonymous Information are listed in Appendix 2 of this privacy policy.

# 4: Where do we get your personal data from?

In most cases, you give them to us yourself. This happens when:

• you sign up to the newsletter
• add your comment or opinion on the product
• you contact us by e-mail
• you follow our social media profiles or interact with content we publish on social media

In Annex 1 to this privacy policy, we have allocated the source of data acquisition to each of the processing purposes. In addition, some information about you may be automatically collected by the tools we use:

• the website mechanism collects your IP address
• the mechanism of the newsletter system collects your IP address and information about your activity in relation to the content sent to you within the newsletter, such as opening messages, clicking on links, etc.
• the external tools listed in Appendix 2 of this privacy policy collect Anonymous Information related to your activities on the site

# 5: Is your data safe?

We care about the security of your personal data. We analyse the risks involved in the various processes of processing your data and then implement appropriate security and personal data protection measures. We monitor the state of the technical infrastructure on an ongoing basis, train our staff, look at the procedures in place and make the necessary improvements. If you have any questions about your personal data, we are at your disposal at leszek.stempel@asmapoland.com.

# 6: For what purposes do we process your personal data?

The purposes of the processing of your personal data are listed in Annex 1 to this privacy policy.

# 7: How long will we keep your personal data?

Data retention periods are indicated separately in relation to each processing purpose. You will find this information in Annex 1 to this privacy policy. The majority of data is deleted after the expiry of the limitation period for claims, although the limitation period for claims may vary according to the applicable legislation (e.g. for businesses it may be 3 years and for consumers 6 years).

# 8: Who are the recipients of your personal data?

We would venture to say that modern business cannot do without services provided by third parties. We also make use of such services. Some of these services involve the processing of your personal data. Third-party service providers that are involved in the processing of your personal data are:

• the hosting provider, which stores the data on the server
• cloud software provider where data processing takes place
• the accountancy office that processes your invoice data
• a maintenance service provider who gains access to the data if the technical work carried out concerns areas where personal data are located
• other subcontractors who gain access to the data if the scope of their activities requires such access

All entities listed above process your data on the basis of personal data processing trust agreements with us and guarantee an adequate level of personal data protection. If the need arises, your data may be shared with a legal advisor or lawyer bound by professional secrecy. The need may arise from the need for legal assistance requiring access to your personal data. Furthermore, when it comes to Anonymous Information, access is granted to providers of tools or plug-ins that collect Anonymous Information. The providers of these tools are their own controllers of the data collected in them and may share this data under the terms and conditions they set out in their own terms and conditions and privacy policies, over which I have no control.

# 9: Do we transfer your data to third countries or international organisations?

No, we do not transfer your data to third countries or international organisations.

# 10: Do we use profiling? Do we make an automated decision based on your personal data?

We do not make decisions towards you based solely on automated processing, including profiling, which would produce legal effects towards you or similarly significantly affect you. Yes, we do use tools that may take certain actions depending on the information collected through tracking mechanisms, but we consider that these actions do not materially affect you as they do not differentiate your situation as a customer, do not affect the terms of the contract you may enter into with us, etc. Using certain tools, we may, for example, target you with personalised advertising based on previous actions you have taken on the website or suggest products that may be of interest to you. This is known as behavioural advertising. We encourage you to learn more about behavioural advertising, particularly with regard to privacy issues. You will find detailed information, including the possibility of managing your settings with regard to behavioural advertising, here here. We emphasise that within the tools I use I only have access to Anonymous Information. This information is stored on the servers of the providers of the individual tools, and these servers can most often be located around the world.

# 11: What rights do you have in relation to the processing of your personal data?

The RODO grants you the following potential rights in relation to the processing of your personal data:

• The right to access and receive a copy of your data,
• The right to rectification (amendment) of your data,
• The right to erasure (if, in your opinion, there are no grounds for us to process your data, you can request that we erase it),
• The right to restrict processing (you can request that we restrict processing to only storing your data or carrying out activities agreed with you if, in your opinion, we have inaccurate data or are processing it unduly),
• The right to object to processing (you have the right to object to processing on the basis of a legitimate interest; you should indicate the particular situation which you think justifies us stopping the processing covered by the objection; we will stop processing your data for these purposes unless we can demonstrate that the grounds for our processing override your rights or that your data is necessary for us to establish, assert or defend our claims),
• The right to data portability (you have the right to receive from us in a structured, commonly used machine-readable format the personal data you have provided to us on the basis of a contract or your consent; you can have this data sent directly to another entity),
• The right to withdraw your consent to the processing of your personal data if you have previously given such consent,
• the right to lodge a complaint with a supervisory authority (if you find that we are processing your data unlawfully, you may lodge a complaint to the President of the Office for Personal Data Protection or any other competent supervisory authority).

The rules related to the exercise of the rights indicated above are described in detail in Articles 16 - 21 of the RODO. We encourage you to familiarise yourself with these provisions. For our part, we consider it necessary to explain to you that the rights indicated above are not absolute and you will not be entitled to them in relation to all processing activities of your personal data. We would like to emphasise that one of the rights indicated above is always available to you - if you consider that we have violated data protection regulations in the processing of your personal data, you have the possibility to lodge a complaint to the supervisory authority (President of the Office for Personal Data Protection). You can also always ask us to provide you with information about what data we hold about you and for what purposes we process it. All you need to do is send an email to leszek.stempel@asmapoland.com. However, we have made every effort to ensure that the information of interest to you is comprehensively set out in this privacy policy. You can also use the e-mail address given above if you have any questions about the processing of your personal data.

# 12: Do we use cookies and what are they?

Our website, like almost all other websites, uses cookies. Cookies are small textual information stored on your terminal device (e.g. computer, tablet, smartphone), which can be read by our ICT system (our own cookies) or by third-party ICT systems (third-party cookies). In cookies, specific information can be recorded and stored, which ICT systems can then access for specific purposes. Some of the cookies we use are deleted when your browser session ends, i.e. when you close your browser (so-called session cookies). Other cookies are stored on your terminal device and enable us to recognise your browser the next time you visit the website (persistent cookies). If you would like to find out more about cookies as such, you can read, for example, this material: https://pl.wikipedia.org/wiki/HTTP_cookie.

# 13: On what basis do we use cookies?

We use cookies on the basis of your consent, except where cookies are necessary for the proper provision of an electronic service to you. Cookies that are not necessary for the correct provision of the electronic service to you remain blocked until you have given your consent to the use of cookies. On your first visit to the website, we display a message to you asking for your consent. Please note that disabling or restricting cookies may prevent you from using some of the features available on our website and may cause difficulties in using the website, as well as many other websites that use cookies. For example, if you block social media plug-in cookies, buttons, widgets and social features implemented on the website may not be available to you.

# 14: Can you disable cookies?

Yes, you can manage your cookie settings within your web browser. You can block all or selected cookies. You can also block cookies for specific sites. You can also delete previously saved cookies and other site and plug-in data at any time. Web browsers also offer the option of using incognito mode. You can use this mode if you do not want information about websites you have visited and files you have downloaded to be saved in your browsing and download history. Cookies created in incognito mode are deleted when you close all windows in this mode. There are also browser plug-ins available to control cookies, such as Ghostery (https://www.ghostery.com). The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc. Furthermore, there are tools available on the Internet that allow the control of certain types of cookies, in particular the collective management of behavioural advertising settings (e.g. www.youronlinechoices.com/, www.networkadvertising.org/choices). Please note that disabling or restricting cookies may prevent you from using some of the features available on our site and may cause difficulties in using our site, as well as many other websites that use cookies. For example, if you block social media plug-in cookies, the buttons, widgets and social features implemented on our site may not be available to you.

# 15: For what purposes do we use our own cookies?

Proprietary cookies are used to ensure the correct functioning of the various mechanisms of the website, such as the correct transmission of the forms visible on the website. Own cookies also store information about your consent to cookies.

# 16: What third-party cookies are used?

Our website uses third-party cookies associated with the tools listed in Appendix 2 of this privacy policy. Individual tools may use more than one cookie, but we have refrained from listing them in detail so as not to overwhelm you with excessive information and on the assumption that it will be clearer for you to use a list of the tools together with an indication of the purposes for which they are used than to list all the cookies technically operating within each tool. We have also refrained from indicating the extent of the information collected in cookies for each tool used, taking into account that each tool collects information related to your characteristics and behaviour undertaken on our website. In this respect, we are dealing with Anonymous Information, which we mentioned earlier within this privacy policy. Aware of the requirements created by the Court of Justice of the European Union, we have nevertheless refrained from indicating the lifespan of the cookies used by each tool. If we wished to determine reliably the lifespan of each cookie, we would have to overwhelm you with excessive information, which would in no way meet the principle of transparency and legibility of the information provided to you. Furthermore, the lifespan of cookies can change so actively on the part of tool providers that we are unable to exercise reliable control over this. Aside from determining the lifespan of cookies, we would like to remind you that the only option for real control over the length of time information is stored in cookies is for you to manage cookies directly. From the level of your web browser, you can delete cookies stored on your device at any time. At this point, we would like to emphasise once again that, within the framework of cookies, we do not have access to information that would allow us to identify you. In this regard, we are dealing with Anonymous Information, which we have mentioned as part of this privacy policy. Furthermore, while in the case of statistical and marketing tools, we can view various reports generated on the basis of Anonymous Information, with regard to other tools, we do not even gain any access to the information collected in the cookies, being only interested in whether the functions of the tool for which the tool has been installed work correctly within our website.

# 17: Do we track your behaviour undertaken within our service?

Yes, we use tools that involve collecting information about your activities on our website. These tools are listed in Appendix 2 of this privacy policy.

# 18: Are we targeting you with targeted advertising?

Yes, we use advertising tools whereby we can target advertising to specific target groups defined on the basis of various criteria such as age, gender, interests, profession, job, activities previously undertaken on our website. These tools are listed in Appendix 2 of this privacy policy.

§ 19: How can you manage your privacy?

The answer to this question can be found in many places in this privacy policy when describing individual tools, behavioural advertising, consent to cookies, etc. Nevertheless, we have once again gathered this information in one place for your convenience. Below you will find a list of options for managing your privacy.

• the cookie settings of your internet browser
• browser plug-ins supporting cookie management, e.g. Ghostery
• additional cookie management software,
• incognito mode in the web browser
• behavioural advertising settings, e.g. youronlinechoices.com
• settings on the part of third-party tool providers (the links to the settings have been collected as part of Annex 2 to this privacy policy)

# 20: What are server logs?

The use of the website involves sending requests to the server where the website is stored. Each request made to the server is recorded in the server logs. The logs include, among other things, your IP address, the date and time of the server, information about your browser and the operating system you are using. The logs are saved and stored on the server. The data stored in the server logs are not associated with specific users of the website and are not used by us to identify you. The server logs are only ancillary material for the administration of the site, and their contents are not disclosed to anyone other than those authorised to administer the server.

# 21: Is there anything else you should know?

As you can see, the topics of personal data processing, the use of cookies and the management of privacy in general are quite complex. We have done our best to ensure that this document provides you with the most far-reaching knowledge on the issues that are important to you. If anything is unclear to you, you would like to find out more, or you just want to talk about your privacy, please email us at leszek.stempel@asmapoland.com.

# 22: Is this privacy policy subject to change?

Yes, we may modify this privacy policy, in particular due to technological changes on the part of our service and changes in legislation. If you are a registered user of the service, you will receive a message about any change to the privacy policy. This Privacy Policy is effective as of 2023-02-20

Annex 1 - Purposes of personal data processing

Purpose of processing	Legal basis processing	Categories processed data	Storage period data	Source of acquisition data
Handling the newsletter	Art. 6(1)(f) RODO - legitimate interest pursued by the controller to send messages after receiving prior consent to receive the newsletter.	Identification data. Contact details. Statistical information related to the messages sent.	Until the expiry of the statute of limitations for claims relating to the sending of the newsletter or the statute of limitations for our data protection liability.	Newsletter sign-up form.
Handling comments/feedback	Art. 6(1)(f) RODO - legitimate interest pursued by the controller to publish the comment / opinion after the user has submitted it.	Identification data. Contact details. Details of comment/feedback.	Until the comment / opinion is removed.	Form to add comments/feedback.
Correspondence handling	Article 6(1)(f) RODO - legitimate interest pursued by the controller to exchange correspondence with the user and its possible archiving.	Identification data. Contact details. Correspondence details.	Not clearly identifiable. Some correspondence may be subject to ongoing deletion and some may be archived if we consider that there is a need to retain it, in particular to ensure future traceability.	Contact form. Incoming message.
Social media handling	Article 6(1)(f) RODO - legitimate interest pursued by the controller to operate social media profiles.	Data visible to the public in the user's social media profile. Details of user interactions within social media profiles.	Until the user deletes the data from the social network.	Social media profiles. Content published by the user on social media.
Analysis and statistics	Art. 6(1)(f) RODO - legitimate interest pursued by the controller to create, review and analyse statistics related to users' activity on the website in order to draw conclusions allowing for the subsequent optimisation of the website.	Anonymous Information (details discussed under the definition of Anonymous Information in the privacy policy)	Until suitability ceases or objections are raised.	Tracking code embedded in the page.
Own marketing	Article 6(1)(f) RODO - legitimate interest pursued by the controller to measure and target advertisements in the marketing of its own products or services.	Anonymous Information (details discussed under the definition of Anonymous Information in the privacy policy)	Until suitability ceases or objections are raised.	Tracking code embedded in the page.

Annex 2 - List of external tools

Tool	Supplier	Purpose of use	Explanations from the supplier	Supplier settings
Google Analytics	Google LLC	Analysis and statistics related to website visitor behaviour.	See	See
reCaptcha	Google LLC	Assessing whether a website visitor is a real human or a bot.	See	See
Google Ads	Google LLC	Measurement and targeting of advertising.	See	See
Meta Pixel	Meta Platforms, Inc.	Measurement and targeting of advertising.	See	See
MailerLite	MailerLite Limited	Embedding newsletter sign-up forms and measuring the effectiveness of these forms.	See	No