1. This Privacy Policy defines the principles of personal data processing collected via the B2B platform promotorzy.pl (hereinafter: "B2B Platform").
2. The owner of the B2B Platform and the Data Controller is PROMOTORZY TRADING SP. Z O.O. SP.K., based in Warsaw (03-310), Św. Jacka Odrowąża 15, registered in the Entrepreneurs' Register of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under KRS number 0000590334, NIP: 5242754308, Regon: 146331264, hereinafter referred to as PROMOTORZY TRADING SP. Z O.O. SP.K., represented by the general partner: PROMOTORZY TRADING SP. Z O.O. based in Warsaw (03-310), Św. Jacka Odrowąża 15, registered in the Entrepreneurs' Register maintained by the District Court for the Capital City of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under KRS number 146139035, with a share capital of PLN 5,000, NIP: 5242751528, Regon: 0000422037.
3. Personal data collected by PROMOTORZY TRADING SP. Z O.O. SP.K. via the B2B Platform are processed in accordance with the Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, on the protection of natural persons regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as GDPR.
4. PROMOTORZY TRADING SP. Z O.O. SP.K. takes particular care to respect the privacy of Clients visiting the B2B Platform.
1. PROMOTORZY TRADING SP. Z O.O. SP.K. collects information about natural persons conducting business or professional activities on their own behalf and natural persons representing legal entities or organizational units without legal personality that are granted legal capacity by law, hereinafter referred to collectively as Clients.
2. Personal data of Clients are collected in the following cases:
a) Account registration on the B2B Platform to create and manage an individual account. Legal basis: necessity for the performance of a contract for account services (Article 6(1)(b) GDPR);
b) Placing an order on the B2B Platform to execute a sales contract. Legal basis: necessity for the performance of the sales contract (Article 6(1)(b) GDPR);
c) Subscribing to a newsletter to execute the contract for providing the newsletter service electronically. Legal basis: consent of the data subject for the performance of the newsletter service contract (Article 6(1)(a) GDPR);
d) Using the contact form service on the B2B Platform to execute the contract for providing the contact form service electronically. Legal basis: necessity for the performance of the contact form service contract (Article 6(1)(b) GDPR).
3. In the case of registering an account on the B2B Platform, the Client provides:
a) email address;
b) first and last name.
4. On the B2B Platform, the Client independently sets a personal password to access their account. The Client can change the password later as described in §5.
5. In the case of placing an order on the B2B Platform, the Client provides the following data:
a) email address;
b) address details:
a. postal code and town;
b. street with house/apartment number;
c) first and last name;
d) phone number.
6. In the case of Entrepreneurs, the above data is additionally extended to include:
a) the Entrepreneur's business name;
b) NIP (Tax Identification Number).
7. In the case of subscribing to the newsletter, the Client provides only their email address.
8. In the case of using the contact form service, the Client provides only their email address.
9. During use of the B2B Platform's website, additional information may be collected, including: the IP address assigned to the Client's computer or the external IP address of the internet service provider, domain name, browser type, access time, operating system type.
10. Navigation data may also be collected from Clients, including information on links and references they choose to click or other activities performed on the B2B Platform. Legal basis: legitimate interest (Article 6(1)(f) GDPR), which involves facilitating the use of electronic services and improving the functionality of these services.
11. To establish, pursue, and enforce claims, some personal data provided by the Client in connection with using the features on the B2B Platform, such as first and last name, usage data, and other necessary information to prove the existence of a claim, including the size of any damage incurred, may be processed. Legal basis: legitimate interest (Article 6(1)(f) GDPR), which involves establishing, pursuing, and enforcing claims, and defending against claims in proceedings before courts and other state bodies.
12. Providing personal data to PROMOTORZY TRADING SP. Z O.O. SP.K. is voluntary in connection with sales contracts or services provided via the B2B Platform. However, failure to provide certain data in the registration forms during the registration process will prevent the creation of a Client's account, and placing an order without registering the account will prevent the Client from placing and fulfilling the order.
1. Client's personal data is provided to service providers used by PROMOTORZY TRADING SP. Z O.O. SP.K. in the operation of the B2B Platform. Depending on contractual arrangements and circumstances, the service providers either follow the instructions of PROMOTORZY TRADING SP. Z O.O. SP.K. regarding the purposes and methods of data processing (processors) or determine the purposes and methods of processing data independently (controllers).
a) Processors. PROMOTORZY TRADING SP. Z O.O. SP.K. uses service providers who process personal data only on the instructions of PROMOTORZY TRADING SP. Z O.O. SP.K., including hosting services, accounting services, marketing systems, website traffic analysis systems, and marketing campaign effectiveness analysis systems;
b) Controllers. PROMOTORZY TRADING SP. Z O.O. SP.K. uses service providers who do not act solely on instructions but determine the purposes and methods of personal data processing, such as electronic payment and banking service providers.
2. Location. Service providers are located in Poland and other European Economic Area (EEA) countries.
3. Personal data of Clients are stored:
a) When the basis for data processing is consent, the data are processed by PROMOTORZY TRADING SP. Z O.O. SP.K. as long as the consent is not withdrawn, and after withdrawal, for a period corresponding to the statute of limitations for claims that may be raised by PROMOTORZY TRADING SP. Z O.O. SP.K. or against it. Unless otherwise stipulated by a specific law, the statute of limitations is six years, and for claims regarding periodic payments and business activities, three years.
b) When the basis for processing data is contract performance, the data are processed by PROMOTORZY TRADING SP. Z O.O. SP.K. as long as necessary to perform the contract, and after that, for a period corresponding to the statute of limitations for claims. Unless otherwise stipulated by a specific law, the statute of limitations is six years, and for claims regarding periodic payments and business activities, three years.
4. In the case of a purchase on the B2B Platform, personal data may be shared with the courier company for the delivery of the ordered goods.
5. Navigation data may be used to provide better service to Clients, analyze statistical data, adjust the B2B Platform to Client preferences, and manage the Platform.
6. If the Client subscribes to the newsletter, PROMOTORZY TRADING SP. Z O.O. SP.K. will send electronic messages with promotional information about new products and offers available on the B2B Platform.
7. In the case of a request, PROMOTORZY TRADING SP. Z O.O. SP.K. may disclose personal data to authorized state bodies, particularly the Prosecutor's Office, Police, President of the Personal Data Protection Office, President of the Office of Competition and Consumer Protection, or the President of the Office of Electronic Communications.
1. The B2B Platform uses small files called cookies. These are saved by PROMOTORZY TRADING SP. Z O.O. SP.K. on the device of the person visiting the B2B Platform if the web browser allows it. A cookie typically contains the domain name from which it comes, its "expiration time," and a randomly chosen identifying number. The information collected using these files helps tailor the products offered by PROMOTORZY TRADING SP. Z O.O. SP.K. to the individual preferences and actual needs of the B2B Platform visitors. It also allows the creation of general statistics on visits to products presented on the B2B Platform. .
2. PROMOTORZY TRADING SP. Z O.O. SP.K. uses two types of cookies:
a) Session cookies: After the session ends or the computer is turned off, the stored information is deleted from the device's memory. Session cookies do not collect any personal data or confidential information from Clients' computers. .
b) Persistent cookies: These are stored in the memory of the Client's device and remain there until deleted or expired. Persistent cookies do not collect any personal data or confidential information from Clients' computers.
3. PROMOTORZY TRADING SP. Z O.O. SP.K. uses its own cookies for:
a) Authenticating Clients on the B2B Platform and maintaining their session after login, so Clients do not have to re-enter their login and password on each page.
b) Analysis, research, and audits, particularly creating anonymous statistics to understand how Clients use the B2B Platform, which helps improve its structure and content.
4. PROMOTORZY TRADING SP. Z O.O. SP.K. uses external cookies for:
a) Displaying a map showing the location of the PROMOTORZY TRADING SP. Z O.O. SP.K. office via maps.google.com (administrator of the external cookie: Google Inc, USA);
b) Collecting general anonymous statistical data via Google Analytics (administrator of the external cookie: Google Inc, USA);
c) Displaying the Reliable Regulations Certificate via rzetelnyregulamin.pl (administrator of the external cookie: Rzetelna Grupa sp. z o.o., Warsaw).
5. The cookies mechanism is safe for Clients' computers. It is impossible to infect the Clients' computers with viruses or other unwanted or malicious software through cookies. However, Clients have the option to limit or disable cookie access in their browsers. If this option is used, the B2B Platform will still be accessible, but features that inherently require cookies may not work.
6. Below is how to change cookie settings in popular web browsers:
a) Chrome and Chrome Mobile;
b) Facebook in-app Browser;
c) Internet Explorer;
d) Microsoft EDGE;
e) Mozilla Firefox;
f) Opera;
g) Safari and Safari Mobile;
h) Samsung Browser.
7. PROMOTORZY TRADING SP. Z O.O. SP.K. may collect Clients' IP addresses. An IP address is a number assigned to a computer visiting the B2B Platform by the internet service provider. The IP address allows internet access. It is usually dynamically assigned, changing with each connection to the internet. PROMOTORZY TRADING SP. Z O.O. SP.K. uses IP addresses for diagnosing server issues, creating statistical analyses (e.g., determining which regions have the most visits), and for security and potential identification of server overload or unwanted automated browsing programs on the B2B Platform.
8. The B2B Platform contains links to other websites. PROMOTORZY TRADING SP. Z O.O. SP.K. is not responsible for the privacy practices on those websites.
1. Right to Withdraw Consent – Legal basis: Art. 7(3) of the GDPR.
a) The Client has the right to withdraw any consent given to PROMOTORZY TRADING SP. Z O.O. SP.K.
b) Withdrawal of consent is effective from the moment the consent is withdrawn.
c) Withdrawal of consent does not affect processing carried out by PROMOTORZY TRADING SP. Z O.O. SP.K. lawfully prior to its withdrawal.
d) Withdrawal of consent does not result in any negative consequences for the Client, but may prevent further use of services or functionalities that, by law, PROMOTORZY TRADING SP. Z O.O. SP.K. may only provide with consent.
2. Right to Object to Data Processing – Legal basis: Art. 21 of the GDPR.
a) The Client has the right to object at any time, on grounds relating to their particular situation, to the processing of their personal data, including profiling, if PROMOTORZY TRADING SP. Z O.O. SP.K. processes their data based on a legitimate interest, such as marketing products and services, statistics on the use of functionalities of the B2B Platform, facilitating the use of the B2B Platform, or satisfaction surveys.
b) Opting out via email from receiving marketing communications regarding products or services will be treated as an objection to the processing of personal data, including profiling for these purposes.
c) If the Client's objection is justified, and PROMOTORZY TRADING SP. Z O.O. SP.K. has no other legal basis for processing their personal data, the personal data to which the objection pertains will be deleted.
3. Right to Erasure (“Right to be Forgotten”) – Legal basis: Art. 17 of the GDPR.
a) The Client has the right to request the deletion of all or some of their personal data.
b) The Client has the right to request the deletion of personal data if:
a. the personal data is no longer necessary for the purposes for which it was collected or processed;
b. the Client has withdrawn consent, in the scope in which their personal data was processed based on their consent;
c. the Client has objected to the use of their data for marketing purposes;
d. the data has been processed unlawfully;
e. the data must be deleted in order to comply with a legal obligation under Union or Member State law to which PROMOTORZY TRADING SP. Z O.O. SP.K. is subject;
f. the data was collected in connection with the offering of information society services.
c) Despite the request to erase personal data, PROMOTORZY TRADING SP. Z O.O. SP.K. may retain certain personal data to the extent necessary to establish, exercise, or defend legal claims, as well as to comply with a legal obligation that requires processing under Union or Member State law. This includes, in particular, personal data such as name, surname, email address, which is retained for complaint and claim handling purposes related to the use of PROMOTORZY TRADING SP. Z O.O. SP.K.'s services, or additionally the residential/correspondence address, order number, which are retained for complaint and claim handling related to sales contracts or service provision.
4. Right to Restrict Processing – Legal basis: Art. 18 of the GDPR.
a) The Client has the right to request the restriction of processing their personal data. A request for restriction will temporarily prevent the use of certain functionalities or services, where the use would involve the processing of the data in question. PROMOTORZY TRADING SP. Z O.O. SP.K. will also not send any communications, including marketing ones.
b) The Client has the right to request restriction of personal data processing in the following cases:
a. when the accuracy of their personal data is contested – in this case, PROMOTORZY TRADING SP. Z O.O. SP.K. restricts its use for the time necessary to verify the accuracy of the data, but no longer than 7 days;
b. when the processing is unlawful, and instead of deletion, the Client requests the restriction of its use;
c. when the personal data is no longer necessary for the purposes for which it was collected or used, but is required by the Client to establish, exercise, or defend legal claims;
d. when the Client has objected to the use of their data – in this case, the restriction lasts for the time needed to consider whether, due to the particular situation, the protection of the Client’s interests, rights, and freedoms outweighs the interests pursued by the Administrator in processing the Client’s personal data.
5. Right to Access Data – Legal basis: Art. 15 of the GDPR.
a) The Client has the right to obtain confirmation from the Administrator as to whether their personal data is being processed, and if so, the Client has the right to:
a. access their personal data;
b. obtain information about the purposes of processing, categories of personal data processed, recipients or categories of recipients of those data, the planned retention period of the Client’s data or the criteria for determining that period (if determining the planned retention period is not possible), the rights available to the Client under the GDPR, the right to lodge a complaint with the supervisory authority, the source of the data, the existence of automated decision-making, including profiling, and the safeguards in place regarding the transfer of those data outside the European Union;
c. obtain a copy of their personal data.
6. Right to Rectification – Legal basis: Art. 16 of the GDPR.
a) The Client has the right to request that the Administrator promptly rectify any inaccurate personal data relating to them. Considering the purposes of processing, the Client has the right to request the completion of incomplete personal data, including by providing an additional statement, by contacting via the email address specified in §6 of the Privacy Policy.
7. Right to Data Portability – Legal basis: Art. 20 of the GDPR.
a) The Client has the right to receive their personal data provided to the Administrator and transfer it to another data controller of their choice. The Client also has the right to request that their personal data be sent directly by the Administrator to another controller, where technically feasible. In such cases, the Administrator will send the personal data in a CSV file format, which is commonly used and suitable for machine-readable transmission, enabling the Client to transfer the data to another data controller.
8. In the case of exercising any of the rights mentioned above, PROMOTORZY TRADING SP. Z O.O. SP.K. will fulfill the request or refuse to do so promptly, but no later than within one month of receipt. However, if the request is complex or numerous, PROMOTORZY TRADING SP. Z O.O. SP.K. may take an additional two months to fulfill it, informing the Client in advance within one month of receiving the request about the intended extension and its reasons.
9. The Client may submit complaints, queries, and requests to the Administrator concerning the processing of their personal data and the exercise of their rights.
10. The Client has the right to request from PROMOTORZY TRADING SP. Z O.O. SP.K. a copy of the standard contractual clauses by submitting an inquiry in the manner specified in §6 of the Privacy Policy.
11. The Client has the right to lodge a complaint with the President of the Personal Data Protection Office if they believe that their rights to personal data protection or any other rights under the GDPR have been violated.
1. PROMOTORZY TRADING SP. Z O.O. SP.K. ensures secure and encrypted connections when transmitting personal data and when logging into the Client's Account on the Service. PROMOTORZY TRADING SP. Z O.O. SP.K. uses an SSL certificate issued by one of the leading global security and encryption companies for data transmitted over the Internet.
2. If a Client with an account on the B2B Platform loses their password in any way, the B2B Platform allows for generating a new password. PROMOTORZY TRADING SP. Z O.O. SP.K. does not send password reminders. Passwords are stored in an encrypted form, making them unreadable. To generate a new password, the Client should provide their email address in the form available through the "Forgot your password?" link provided on the login form to the B2B Platform. The Client will receive an email at the address provided during registration or the last profile update, containing a link to a dedicated form on the B2B Platform website, where the Client can set a new password.
3. PROMOTORZY TRADING SP. Z O.O. SP.K. will never send any correspondence, including electronic communication, asking for login details, especially the access password to the Client’s account.
1. The Privacy Policy may change, and PROMOTORZY TRADING SP. Z O.O. SP.K. will inform Clients 7 days in advance.
2. Questions regarding the Privacy Policy should be directed to: dh@promotorzy.pl