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Privacy policy

Dear User,

when you visit our website we process certain information about you such as information on a device you use, country you are from, web browser you use and your IP address, including personal data you wish to share with us by subscribing for a newsletter, using contact form or otherwise interacting with the website.

Additionally, we process your personal data when you enter and interact with our fanpage on Facebook® and/or profile on LinkedIn® or on other social media websites. In such case we may process your personal data for example your name, surname, profile picture and other information you send us via chats or your comments published on these websites.

Any personal data we collect will be used in accordance with applicable laws, including 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 (“GDPR”).

This privacy policy governs how we process your personal data we collect through our above websites on which you find the link to this policy, which in this policy are referred to as “Website”.

1.WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

Any personal data collected via the Websites are controlled (co-controlled) by:

Rawlplug Spółka Akcyjna with its registered office in Wrocław, ul. Kwidzyńska 6, 51-416 Wrocław, entered into the business register of KRS (national court register) under no 0000033537, having NIP (tax identification number) 8951687880; and

Koelner Rawlplug IP Spółka z ograniczoną odpowiedzialnością with its registered office in Wrocław, ul. Kwidzyńska 6, 51-416 Wrocław, entered into the business register of KRS (national court register) under no 0000370378, having NIP (tax identification number) 6772354296 ; and

- (hereafter referred to jointly as “Rawlplug” or “we”).

We are the part of a capital group consisting of private companies enlisted under  https://rodo.rawlplug.com/processing/ , which may jointly be referred to as the “Rawlplug Group”.

You may contact us at any time in relation to personal data of yours processed by us.

Our contact details: gdpr.rsa@rawlplug.com or gdpr.krip@rawlplug.com

2.DATA THIS POLICY APPLIES TO.

This privacy policy applies to information, including personal data, we collect:

- through the Website.

- through mobile and desktop applications which provide dedicated non-browser-based interaction between you and this Website.

- when you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links or any reference to this policy.

It does not apply to information collected by:

- Rawlplug offline; or

- any third party (including Rawlplug’s affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or on the Website.

The term ‘personal data’ as used herein comprises any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

3.CHILDREN UNDER THE AGE OF 16

The Website is not intended for children under 16 years of age. No one under age 16 may provide any personal data to or on the Website. We do not knowingly collect personal data from children under 16. If you are under 16, please do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Website or provide any personal data to Rawlplug. If we learn that we collected or received personal data from a child under 16 without verification of parental consent, Rawlplug will delete that information. If you believe we might have any personal data about a child under 16, please contact us.

4.INFORMATION RAWLPLUG COLLECTS THROUGH THE WEBSITE

Rawlplug collects information, including personal data:

- directly from you when you provide it to us or automatically as you enter and navigate through the Website always with your consent; or

- automatically as you enter and navigate through the Website, collected through essential and functional cookies, without your express consent. Such information may include usage details, information on a device you use, country you are from, web browser you use and your IP address. We do not collect any other personal data in such way, for example name, surname or e-mail address.

If we collect personal data with your expressed consent such personal data will be collected and processed only within the scope of such consent. You are entitled to withdraw the consent at any time, however the withdrawal of the consent will not affect the lawfulness of processing based on consent before its withdrawal.

Personal data collected for purposes other than compliance with legal obligation may be subject of profiling, which is an automated processing of personal data to analyse or predict aspects concerning your personal preferences or behaviour (for example, to personalize the Website or marketing content sent to you). This pertains for example to Google or Meta Platforms advertising services.

We will not use automated individual decision-making producing any legal effects or significantly affecting you.

The provision of all personal data is voluntary, however necessary for you to be presented with and use the Website and its functionalities.

The information Rawlplug collects will also be used to help us review, develop and improve the products and services we offer.

If it is applicable, we collect information you have published or displayed (hereinafter, “posted”) on public areas of the Website by using the functionalities of the Website (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although, please be aware that no security measures are perfect or impenetrable. Additionally, Rawlplug cannot control the actions of other users of the Website with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Any publication of a photograph on the Website containing your image, constitutes a consent to use such image by Rawlplug on the Website.

We may request additional personal data to provide certain services available on the Website. If such personal data are not provided by you, Rawlplug will not be able to provide you requested services.

5.COOKIES

Cookies are text files containing small amounts of information which are downloaded to your device when you visit a website. You can find more information about cookies at: www.allaboutcookies.org and www.youronlinechoices.eu.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your preferences (for example language choice), and generally improving the user experience. They can also help to ensure that adverts you see online are more relevant to you and your interests.

Cookies are referred to as session or persistent, depending on how long they are stored on your computer or device:

- Session cookies only last for the length of your online session. They disappear from your computer or device when you close your browser.

- Persistent cookies stay on your computer or device after the browser has been closed and last for a set period of time specified in the cookie. These cookies are activated each time you visit the site that generated the cookie.

Rawlplug does not use cookies with the aim of collecting commercial data for sale to third parties.

Currently we use following types of cookies on the Website.

Necessary (essential) cookies

This type of cookies are necessary for you to enter and display the Website and to use services available on the Website, for example authentication cookies used for authentication services on the Website during a session or user-centric security cookies which are used for increasing the security of the service explicitly requested by the user.

These cookies are automatically saved on your device without your explicit consent as they are exempted from such consent. You may disable such cookies only in cookies management section of your web browser.

Performance cookies

Performance cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies do not collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

The Website currently uses one performance cookie - Google Analytics.

Google Analytics is a web analytics service provided by Google, Inc. Google Analytics sets a cookie in order to evaluate your use of the Website and compiles reports on user activity. Google stores the information collected by the cookie on servers in the United States and other countries. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. By using the Website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

Use of these cookies requires your express consent which you may give us through cookie banner on the Website or options of your web browser or you can generally opt-out of these cookies on the website Google Analytics: http://tools.google.com/dlpage/gaoptout

Functional cookies

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports by storing in a cookie the region in which you are currently located. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. They may also be used to provide services you have asked for such as watching a video. The information these cookies collect may be anonymized and they cannot track your browsing activity on other websites.

Use of these cookies requires your express consent which you may give us through cookie banner on the Website or options of your web browser, however such consent is not necessary under applicable laws when you ask us to provide you services through the Website (Website content).

Advertising cookies

Cookies of third parties that are used for behavioral advertising and other purposes such as advertisement affiliation, research and market analysis.

Currently on the Website we use:

Facebook Pixel - promotional and advertising actions based on re-engagement. These cookies serve for Meta Platforms Inc. to reach people who previously visited our Website, and match the right people with the right message. These features’ goal is to attract past visitors back to our Website. You may find privacy policy regarding advertisement on Facebook® or other social media platforms of Meta Platforms® here: https://www.facebook.com/adpreferences/ad_settings

Use of these cookies requires your express consent which you may give us through cookie banner on the Website or options of your web browser.

Managing cookies in your browser

Modern browsers allow you to perform a number of tasks in relation to cookies including the ability to view the cookies currently stored on your computer or device and delete them on an individual basis, block third party cookies, block cookies from particular sites, prevent all cookies from being set and delete all cookies when you close your web browser.

You should note that any individual preferences will be lost if you delete cookies, including a preference to opt out of cookies (since this requires an opt-out cookie to be set). If you choose to block cookies completely, many websites will not work properly and some functionality may be lost.

Rawlplug does not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

6.PROCESSING OF INFORMATION

Rawlplug will use your information to provide and personalize the Website. We may also use your contact details to communicate with you. Your information will enable us to notify you about important functionality changes to the Website and will be used for statistical analysis purposes to improve the quality and the services offered to you.

We may use the information, except for personal data (processing of which is described below), it collects for a range of business purposes, including but not limited to:

- present the Website and its contents to you and enable you to use functions of the Website and its contents;

- evaluate and respond to your requests, inquiries, and applications made e.g. using any contact form available on the website;

- communicate with you through various channels;

- publish public product reviews as submitted by you;

- compliance with obligations as required by applicable laws, including protection against and prevention from fraud and unauthorized transactions, investigate and manage claims, risk exposure, and quality, generally improve and provide security;

- control the compliance of your actions with and enforcement of applicable legal requirements and Rawlplug’s policies and terms; determine, protect and enforce any of Rawlplug’s rights, including an assignment to any third party;

- carry out summaries, analysis, statistics in order to operate, evaluate, and improve  business, products, and services (including developing new products and services; managing our communications; determining and managing the effectiveness of  advertising and marketing; analyzing  products, services, websites and applications; administering the Website and applications);

- direct marketing;

- conclude and perform contracts to provide services and deliver products;

- fulfill any other purpose for which you provide it;

- in any other way Rawlplug may describe when you provide the information; and

- for any other purpose with your consent.

Following personal data collected through the Website are processed by Rawlplug for following purposes and on following legal grounds:

PurposePersonal dataLegal basisDuration
concluding and execution of a sales contract of Rawlplug’s Group goods, services and products via the WebsiteTrade and billing data: name and surname, address, tax identification, e-mail, telephone numberArticle 6 pt. 1.b GDPR – performance of a contractFor the time necessary to conclude and execute (perform) a contract, and for a legal  limitation period of claims related to the contract
present the Website and its content to you and enable you to use functions of the Website and its contents, generally improve and provide security.Data received automatically from the computer, mobile phone or other device you use to access the Website: IP address, location and time.Article 6 pt. 1.f GDPR – legitimate interestFor the time of using the Website and afterwards until you end the session of web browser.
carry out summaries, analysis, statistics in order to operate, evaluate, and improve the Website,  business, products, and services (including developing new products and services; managing our communications; determining and managing the effectiveness of  advertising and marketing; analyzing  products, services, websites and applications; administering the Website and applications).Data received from the computer, mobile phone or other device you use to access the Website: IP address, location and time.Article 6 pt. 1.f GDPR – legitimate interest, or in case of collecting these data through cookies: Article 6 pt. 1.a - consentFor the time needed to carry out such activities, no longer than 14 months.
evaluate and respond to your requests, inquiries, and applications.Contact and identification information provided by you: name, surname, email address.Article 6 pt. 1.a GDPR -consentFor the time needed to complete the exchange of communication and 3 years afterwards or until withdrawal of the consent.
communicate with you through various channels, including for advertisement purposes (for example newsletter), however we do not initiate contact.Contact and identification information provided by you: name, surname, email address, phone number.Article 6 pt. 1.a GDPR -consentFor the time until the withdrawal of your consent.
carry out obligations as required by applicable laws, including protection against and prevention from fraud and unauthorized transactions, investigate and manage claims, risk exposure, and quality, generally improve and provide security.

Data received automatically from the computer, mobile phone or other device you use to access the Website: IP address, location and time.

Contact and identification information provided by you: name, surname, email address.

Article 6 pt. 1.c GDPR – legal obligationFor the time needed to carry out such obligation.
control the compliance of your actions with and enforcement of applicable legal requirements and Rawlplug’s policies and terms; determine, protect and enforce any of Rawlplug’s rights, including an assignment to any third party;

Data received automatically from the computer, mobile phone or other device you use to access the Website: IP address, location and time.

Contact and identification information provided by you: name, surname, email address.

Article 6 pt. 1.f GDPR – legitimate interestUntil the expiry of limitation period.
re-engagement advertisementData received automatically from the computer, mobile phone or other device you use to access the Website: IP address, location and time.Article 6 pt. 1.a GDPR – consentNo longer than 180 days in case of Facebook Pixel or until withdrawal of the consent.
publish on the Website public product reviews as submitted by you or comments.Data received when you interact with the Website: name, surname, posted content, photographs.Article 6 pt. 1.f GDPR -legitimate interestFor the time until you or we delete such comment.
Other purposeAs agreedArticle 6 pt.1.a GDPR- consent 

Following personal data collected through the Website (Facebook® fanpage and LinkedIn® profile) are processed by Rawlplug for following purposes and on following legal grounds:

carry out summaries, analysis, statistics in order to operate, evaluate, and improve the Website,  business, products, and services (including developing new products and services; managing our communications; determining and managing the effectiveness of  advertising and marketing; analyzing  products, services, websites and applications; administering the Website and applications).Data received from the computer, mobile phone or other device you use to access the Website: IP address, location and time.Article 6 pt. 1.f GDPR – legitimate interestFor the time needed to carry out such activities, no longer than 14 months.
evaluate and respond to your requests, inquiries, and applications.Contact and identification information provided by you: name, surname, email address.Article 6 pt. 1.a GDPR -consentFor the time needed to complete the exchange of communication and 3 years afterwards or until withdrawal of the consent.
communicate with you through various channels, however we do not initiate contact.Contact and identification information provided by you: name, surname, email address.Article 6 pt. 1.a GDPR -consentFor the time needed to complete the exchange of communication and 3 years afterwards or until withdrawal of the consent, the latter applies especially to continuous communication.
carry out obligations as required by applicable laws, including protection against and prevention from fraud and unauthorized transactions, investigate and manage claims, risk exposure, and quality, generally improve and provide security.

Data received automatically from the computer, mobile phone or other device you use to access the Website: IP address, location and time.

Contact and identification information provided by you: name, surname, email address.

Article 6 pt. 1.c GDPR – legal obligationFor the time needed to carry out such obligation.
control the compliance of your actions with and enforcement of applicable legal requirements and Rawlplug’s policies and terms; determine, protect and enforce any of Rawlplug’s rights, including an assignment to any third party;

Data received automatically from the computer, mobile phone or other device you use to access the Website: IP address, location and time.

Contact and identification information provided by you: name, surname, email address.

Article 6 pt. 1.f GDPR – legitimate interestUntil the expiry of limitation period.
publish on the Website public product reviews as submitted by you or comments.Data received when you interact with the Website: name, surname, posted content, photographs.Article 6 pt. 1.f GDPR -legitimate interestFor the time you have an account on social media portal or until you delete such comment.

7.SHARING OF THE INFORMATION WE RECEIVE

Rawlplug uses third parties service providers to carry out certain activities on its behalf. Examples include operating IT systems, including e-mail, hosting services, providing IT resources, analyzing data, providing marketing assistance and providing customer service, legal services, accounting services etc. These third parties are processors of your personal data needed to perform their functions, but may not use it for other purposes. We will ensure that any processing of personal data by processors complies with provisions of GDPR, especially that any such processor is aware of and abides by obligations set for the therein. We will also ensure that any processor treats your personal data no less protective as required by applicable data protection laws and that they adopt adequate technical and organizational security measures.

We may share your personal data with other controllers, when we believe it necessary to comply with the law, to protect the rights or safety of the Website, other users, or third parties (e.g., for fraud protection purposes, settlements purposes). Without limitation, this may include cases in which we share your personal data with government authorities, local authorities or court authorities, persons running offices of business information and assignees. Rawlplug will carefully determine the permissibility of providing personal data in each such context, paying particular attention to the type of request, types of data affected and any impact that a disclosure of personal data would have on the user affected. Should we decide to disclose personal data in such context we will also consider ways of reducing the scope of the disclosure, for instance by redacting the information provided. 

We may disclose personal data as described in this Privacy Policy to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Rawlplug’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about the Website users is among the assets transferred

We may share your personal data with carefully selected third parties so they may contact you with offers and information about their goods and services or for other purposes, unless you expressed your consent.

Recipients of your personal data may be located in any country. This may include countries where applicable data protection laws provide a lesser degree of protection than EU laws, especially countries outside the territory of European Union (“third countries”). In such case, we may transfer your personal data to a third country only where:

- the Commission has decided that the third country, a territory or one or more specified sectors within that third country, ensures an adequate level of protection. Such a transfer shall not require any specific authorization, or

- adequate level of protection is applied for your personal data, for instance by ensuring that the recipient abides by so-called EC Model Clauses, which are sets of contractual clauses adopted by the European Commission for the purpose of adducing adequate safeguards to personal data in connection with cross-border transfers, or

- the transfer meets other requirements set forth in GDPR.

Currently we transfer your personal data collected through the Website to following entities who provide us with certain services:

- Google LLC with its registered office in California, USA and Google Ireland Ltd – entities that have provided and are responsible for a tool and cookies for website traffic analysis (Google Analytics) and for a Google Ads cookies. In Section 5 of this privacy policy you may find details regarding cookies on the Website. Export of personal data to the USA is based on Standard Contractual Clauses accepted by European Commission.

- Meta Platforms, Inc with its registered office in California, USA and Meta Platforms Ireland Ltd. – entities that have provided and are responsible for Facebook Pixel cookie and access to our Facebook® fanpage. As a result you may like our fanpage, read our posts, watch materials posted by us and post you own content like comments or give likes and more. Export of personal data to the USA is based on Standard Contractual Clauses accepted by European Commission.

- Entities that provide us with mass correspondence services in relations to subscribers of our newsletter. Personal data transfer is governed by Data Processing Agreement.

8.LINKS TO THIRD PARTY WEBSITES

Rawlplug may from time to time establish relationships with other third party companies and the Website may contain links to and from such third party websites. We will try to provide you with links to high quality, reputable sites which it believes will be of interest and relevant to you, but please note that such third party sites are not under its control and Rawlplug does not contribute to the content of such sites.

If you follow a link to any third party website, please note that they will have their own policies. When you click through to these sites you leave the area controlled by us. We cannot accept responsibility for any issues arising in connection with either the third party's use of your data, the site content or the services offered to you by these sites. Rawlplug therefore encourages you to check any third party website's policies before you submit any personal data to these sites.

9.SECURITY

Rawlplug maintains administrative, technical, and physical safeguards designed and intended to protect personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure or use. Despite these safeguards, due to inherent uncertainty in the use of the Internet and information systems and the potential for unlawful attacks by third parties, Rawlplug cannot guarantee that the use of  systems, websites (including the Website) or applications will be completely safe or secure.

The safety and security of your personal data also depends on you. Where Rawlplug has given you (or where you have chosen) a password for access to certain parts of the Website, you are responsible for keeping this password confidential. We kindly ask you not to share your password with anyone. Rawlplug also urges you to be careful about giving out information in public areas of the Website like message boards. The information and personal data you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although Rawlplug does its very best to protect your personal data, we cannot guarantee the security of your personal data transmitted to the Website. Any transmission of personal data is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

10.YOUR RIGHTS

You have following rights under GDPR in relation to your personal data:

- accessing your personal data (including receiving copies thereof) – under article 15 GDPR;

- correcting your personal data – under article 16 GDPR;

- deleting your personal data – under article 17 GDPR;

- to demand restriction of processing – under article 18 GDPR;

- to demand transmission of personal data – under article 20 GDPR.

You may enforce the above rights by contacting our representative for data protection or sending a respective email to our address: gdpr.rsa@rawlplug.com or gdpr.krip@rawlplug.com

We may require additional information enabling us to verify your identity and your right to enforce the above rights.

You can review and change your personal data by logging into the Website and visiting your account profile page.

Right to object

Apart from rights referred to in preceding paragraphs, you have the right to object, at any time, to processing of your personal data by us (including profiling) for direct marketing purpose. After filing the objection, we will restrain from processing your data for this purpose.

You have also right to object, on grounds relating to your particular situation, at any time to processing of your personal data which is based on legitimate interest or public interest (including profiling). The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

Complaint

You have the right to lodge a complaint to Prezes Urzadu Ochrony Danych Osobowych. You may find details on the website: https://uodo.gov.pl/

- if you are of the opinion that we process your personal data illegaly.

11.CHANGES TO OUR PRIVACY POLICY

We may revise, update and change this privacy policy at any time and without notice to you.

____________________

Wroclaw, 20.09.2023 r.

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