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PRIVACY AND COOKIES POLICY

PRIVACY AND COOKIES POLICY

Last update October 1, 2020

Introduction

  1. TOBILET makes every effort to protect personal data against disclosure to unauthorized persons, removal by an unauthorized person, processing in violation of applicable law and change, loss, damage or destruction, and respect the privacy of every person whose personal data is processed.
  2. Personal data is processed by TOBILET in compliance with the requirements of generally applicable law, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement such data and repealing Directive 95/46 / EC (General Data Protection Regulation or GDPR, OJ L 119, 4.5.2016, p. 1-88).
  3. This Privacy Policy (hereinafter: Policy) sets out the rules for the processing and protection of personal data adopted by TOBILET. The Policy regulates:
    1. types of personal data collected by TOBILET,
    2. how this data is used,
    3. the rights of persons whose data is processed by TOBILET,
    4. categories of entities to whom the data is shared,
    5. personal data protection and security measures,
    6. the method of contact regarding the exercise of the rights of persons whose data is processed by TOBILET,
    7. measures and methods of personal data protection used by TOBILET,
    8. information on cookies.

I. Basic concepts

  1. Personal data - all information relating to an identified or identifiable natural person, e.g. name and surname, telephone number, address, ID card number. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more specific factors determining his physical, physiological, mental, economic, cultural or social characteristics. Information is not considered to enable the identification of a person if it would require excessive costs, time or activities;
  2. Data processing - any operations performed on personal data, such as collecting, recording, storing, developing, changing, sharing and deleting, especially those performed in IT systems;
  3. Breach of personal data protection - a breach of security leading to accidental or unlawful destruction, loss, modification, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise processed;
  4. User - a natural person whose personal data is processed by TOBILET.

II. Personal Data Administrator and Data Protection Officer

MTP SP. z o. o. with its seat in Poznań at ul. Głogowska 14, 60-734 Poznań (hereinafter: "TOBILET"). TOBILET has appointed a data protection officer who can be contacted at the following e-mail address: iod@grupamtp.pl.

III. Principles of collecting personal data

  1. TOBILET obtains personal data mainly directly from Users. If the business contact details have not been collected directly from the data subject (e.g. by TOBILET receiving a business card containing such data or from the employer of such a person), they could have been provided by the represented entity or obtained from publicly available sources, such as as public registers (e.g. the National Court Register).
  2. The TOBILET obtains personal data, in particular within the scope of:
    • contact information (such as name and surname, address of residence / stay / correspondence / business activity, e-mail and telephone number);
    • business contact information (such as job title, department and institution name);
    • needed to issue a VAT invoice (such as NIP, REGON);
    • data concerning the User necessary to perform the contract concluded with TOBILET and to fulfill the legal obligations incumbent on TOBILET;
    • data necessary to authenticate the User, e.g. login and password;
    • the content provided (such as photos, articles and comments);
    • cookies and other data regarding the User's activity on the tobilet.pl website, in particular the IP address, domain name, browser type, operating system type.

IV. The method of processing personal data

  1. TOBILET provides control over the type and scope of personal data processed, the period and method of their processing, as well as the persons authorized to process them.
  2. TOBILET makes every effort to protect the information and personal data it collects.
  3. The TOBILET provides adequate administrative, technical and physical protection of personal data against accidental, unlawful or unauthorized damage, loss, modification, access, disclosure or use.
  4. TOBILET stores personal data only as long as it is necessary to achieve the purpose for which the personal data was collected, unless otherwise provided for in applicable law. When determining this period, TOBILET takes into account the provisions of law that require the administrators to process personal data for the time specified in these provisions, the period of operation of the User, the period that is necessary to establish, defend or pursue claims by TOBILET, the period for which the User grants consent to processing his personal data by TOBILET (in particular to withdraw such consent. TOBILET takes measures to destroy or permanently remove the possibility of identifying personal data,
  5. TOBILET declares that:
    • processes personal data in accordance with the law;
    • collects personal data for specified, lawful purposes and does not subject it to further processing incompatible with these purposes;
    • stores personal data in a form that allows the identification of persons to whom they relate, no longer than it is necessary to achieve the purpose of processing;
    • the processed personal data are factually correct and adequate in relation to the purposes for which they are processed.
  1. Access to personal data is granted to: TOBILET, its employees authorized in writing, associates and persons providing services to it. Access to personal data by the above-mentioned persons takes place only for the purpose and scope specified by TOBILET.
  2. TOBILET keeps a register of persons authorized to process personal data. Persons authorized to process data are required to keep personal data and the methods of securing it strictly confidential.
  3. The TOBILET and the persons authorized to process these data apply technical and organizational measures ensuring protection of the personal data being processed.
  4. The data collected by TOBILET may be used, inter alia, for the following purposes:
    • provision of services or performance of contracts, in particular contracts for the sale of tickets offered by TOBILET, administering them and informing about them by TOBILET; in the case of processing personal data of a person on whose request steps have been taken to conclude a contract with TOBILET or to perform a contract concluded with it pursuant to art. 6 sec. 1 lit. b GDPR; in the event of obtaining personal data for purposes related to the performance of a specific contract, TOBILET provides the data subject with detailed information on the processing of his personal data at the time of concluding such a contract - acceptance of the TOBILET Regulations;
    • implementation of legal obligations incumbent on TOBILET, which result from the provisions regulating the provision of services or activities of TOBILET, as well as accounting and tax regulations (pursuant to Article 6 (1) (c) of the GDPR);
    • conducting electronic and traditional correspondence; in the case of directing to TOBILET via e-mail or traditional correspondence not related to the services provided by TOBILET or other contract concluded with TOBILET, personal data contained in this correspondence are processed only for the purpose of communication and resolving the matter the correspondence relates to, which is a legitimate interest TOBILET (based on: Article 6 (1) (f) of the GDPR);
    • conducting telephone contacts; in the case of contacting the TOBILET by phone, in matters not related to the services provided by TOBILET or other contract concluded with TOBILET, TOBILET may request personal data only if it is necessary to handle the case to which the telephone contact relates, which is legally justified the interest of TOBILET (based on: Article 6 (1) (f) of the GDPR);
    • collecting personal data in connection with TOBILET's activity: in connection with its activities, TOBILET may obtain personal data also for other purposes, e.g. concluding and maintaining business contacts, which in each case will be based on the legitimate interest of TOBILET (legal basis: art. 6 paragraph 1 (f) of the GDPR).
    • risk assessment and improvement of TOBILET's activity (including the development of the services provided, communication management, analysis and improvement of the services provided by it), which is the legitimate interest of TOBILET pursuant to art. 6 sec. 1 lit. f GDPR;
    • as required by law or in connection with pending legal proceedings or in connection with a request of a public authority (e.g. the Head of the Tax Office) to disclose information held by TOBILET, which is the legitimate interest of TOBILET within the meaning of Art. 6 sec. 1 lit. f GDPR, and in the event of a request from an authorized public authority, performance of the TOBILET legal obligation;
    • ensuring compliance of processing with the provisions on the protection of personal data and internal TOBILET regulations in this regard, which is the legitimate interest of TOBILET within the meaning of art. 6 sec. 1 lit. f GDPR;
    • in terms of specific categories of personal data, e.g. information about the User's health condition provided to TOBILET - these data may be processed by TOBILET pursuant to art. 9 sec. 2 lit. f) GDPR, i.e. processing is necessary to establish, assert or defend claims or in the course of the administration of justice by courts or art. 9 sec. 2 lit. a) GDPR - express consent of the User.
  1. Providing personal data is voluntary, but failure to provide it will make it impossible to achieve the objectives referred to above, in particular, providing data may be a necessary condition to conclude a contract (e.g. creating a User account, purchasing a ticket), without providing such data, such contracts cannot be included.

V. Providing and entrusting the processing of personal data

  1. TOBILET does not share, sell or disclose in any other way collected personal data, except for situations described in the Policy or when it results from generally applicable law.
  2. TOBILET may entrust the processing of personal data to service providers acting on its behalf, in particular electronic services, e.g. IT, accounting, legal, courier, postal services related to the services provided by TOBILET. TOBILET requires these service providers to comply with the law, with a high level of privacy protection and the security of personal data processed by them on behalf of TOBILET.
  3. Personal data may also be disclosed to external entities due to the activity initiated by the User on the website tobilet.plto entities such as: Facebook, Google, HotJar, Youtube, Google Analitycs, Microsoft, which may place their own cookies.

VI. Rights of persons whose data is processed by TOBILET

  1. Within the limits of the law, the User has the right to access his personal data, in particular as a form of control over the processing of his personal data by TOBILET, in particular obtaining information about the purpose, scope and method of data processing.
  2. Within the limits of the law, the User also has the right to change, supplement, rectify and update his personal data processed by TOBILET.
  3. Within the limits of the law, the User also has the right to request the deletion of his personal data processed by TOBILET.
  4. If the processing of personal data is based on the consent of the User, he has the right to withdraw consent to the processing of his personal data by reporting it in any way TOBILET. In such situations, TOBILET will adapt to the User's decision in relation to future activities, which means that the withdrawal of consent does not affect the lawfulness of the processing carried out before the consent is withdrawn.
  5. The User has the right - in cases provided for by law - to request TOBILET to limit the processing of his personal data.
  6. For reasons related to the specific situation of the User and within the limits of the law, the User has the right to object to the processing of his personal data by TOBILET based on the implementation of its legitimate interest.
  7. Within the limits of the law, the User has the right to receive, in a structured, commonly used, machine-readable format, his personal data provided by TOBILET, and the right to send this personal data to another administrator without any obstacles on the part of TOBILET. However, TOBILET will do this only if such a message is technically possible to send. The right to transfer personal data applies only to the data processed by TOBILET on the basis of the contract concluded with the User or on the basis of his consent.
  8. The above rights may be exercised by sending an e-mail to the following address: info@tobilet.pl.
  9. If it is found that the processing of personal data by TOBILET violates the law, the User may submit a complaint to the supervisory body, in the case of the Republic of Poland - the President of the Personal Data Protection Office.

VII. Using the website www.tobilet.pl and the contact form

  1. Using the website www.tobilet.pl is voluntary and free for all Users. The user may resign from using the website www.tobilet.pl at any time.
  2. Regardless of the above-mentioned principle of free use of the website www.tobilet.pl, the User may incur costs related to the use of the Internet network which he uses. The costs of connecting to the Internet are in line with the rates of the User's network operator.
  3. The User is not entitled to provide illegal content while using the website www.tobilet.pl. The user should use the website www.tobilet.pl in accordance with applicable law and the principles of social coexistence.
  4. The materials contained on the Website, in particular images, graphics, content, layout and composition of these elements (the so-called layout), are subject to copyright protection and may not be distributed, modified or copied in whole or in part, without prior written notice consent of the authorized entity (except for use within the fair use, in accordance with the law).
  5. For the proper functioning of the website www.tobilet.pl it is necessary to have a computer or other device connected to the Internet with a properly installed and configured web browser.
  6. TOBILET may make available to Users on the website www.tobilet.pl the voluntary and free contact form service
  7. In order to use the contact form to send a message to TOBILET, the User fills in the fields of the contact form marked with an asterisk (required fields), accepts the Privacy Policy and clicks on the "Send" field.
  8. For convenience and to provide additional information, the website www.tobilet.pl may contain links to websites administered by entities independent of TOBILET, eg Facebook. They may have separate clauses or privacy policy. TOBILET encourages you to read their content. With regard to any websites to which links are on the website tobilet.pl, which are not owned or controlled by TOBILET, TOBILET shall not be liable for their content, the User's use of these websites, or for the applicable in relation to them, the principle of protecting the confidentiality of information.

VIII. Cookies and analysis software

  1. Using the website tobilet.pl may require providing your data, such as information from cookies.
  2. TOBILET, its service providers and business partners collect some information by automatic means, such as cookies, while browsing the tobilet.pl website. The information collected in this way may include: IP address, browser type, operating system, visited URLs, as well as information on activities performed on the website.
  3. Cookies contain little information and are downloaded to a computer or other device by the server operating the tobilet.pl website. The web browser used by the User sends them back to the website www.tobilet.pl each time the User uses it, thanks to which the server recognizes the User and remembers, for example, his preferences (visits or previous activities) or User's login data. However, cookies may download information about the User (e.g. about the language, country and previously viewed pages) each time the website www.tobilet.pl is visited.
  4. TOBILET uses cookies only to test the functionality of the tobilet.pl website. TOBILET stores this information for up to 5 years. This information cannot be linked to any natural person.
  5. By using the tobilet.pl website, the User may consent to the placement of the cookies described above on his computer or on another device. However, the user can always control the installed cookies. However, deleting or blocking cookies may affect the way you use the www.tobilet.pl website, as some of its areas may become inaccessible. This control is done through the browser settings. Information on the possibility of modifying browser settings, blocking and filtering cookies can be found at:

  https://support.google.com/chrome/answer/95647?hl=pl for the Google Chrome search engine

  https://support.mozilla.org/pl/kb/usewka-ciasteczek for the Mozilla Firefox internet search engine

  https://support.microsoft.com/pl-pl/help/278835/how-to-delete-cookie-files-in-internet-explorer for Microsoft Internet Explorer

  https://support.apple.com/kb/ph21411?locale=pl_PL for the Safari web search engine.

  1. To monitor the tobilet.pl website, TOBILET may use analyzing software belonging to third parties, eg Google Analytics. Google Analytics can be disabled using the browser extension, which can be downloaded from the website: https://tools.google.com/dlpage/gaoptout.

 

IX. Policy changes and updates

  1. The policy may be modified periodically. The modifications are intended to take into account the changes in TOBILET's practices regarding the handling of personal data and to strengthen the personal data protection system in TOBILET, as a consequence of the change in applicable law that regulates TOBILET's business, the need to adapt the Policy to applicable law or the need to make editorial changes in Politics; changes in the way the website www.tobilet.pl is operated or operated, which will be caused by objective and independent reasons of technological or technical nature; changes to the terms of use of the website www.tobilet.pl, not worsening the situation of Users compared to the existing ones; the need to update the information indicated in the Policy.
  2. Significant changes to the Policy will be signaled by clearly visible messages posted on the TOBILET website. At the top of the page with the content of the Policy, there will be information about the date of its latest update.


X. Final provisions, contact and complaints

  1. The User may at any time contact TOBILET to obtain information on whether and how TOBILET uses or intends to use his personal data, as well as in case of any questions or comments about the Policy.
  2. Complaints regarding the use of the website www.tobilet.pl may be submitted to the e-mail address: reklamacje@tobilet.pl. Complaints are considered by TOBILET within 14 days from the date of its submission by the User. Information about the consideration of the complaint will be provided to the User to the e-mail address provided by the user or another method indicated by him.
  3. Any disputes or claims related to the use of the website www.tobilet.pl will be settled by a common court in the Republic of Poland, and the law applicable to the Policy is Polish law, unless otherwise stipulated in mandatory provisions of law.
  4. The choice of Polish law on the basis of the Policy does not deprive the user who is a consumer of the protection granted to him on the basis of provisions that cannot be excluded by way of an agreement between TOBILET and the User, under the law which, in accordance with the relevant regulations, would be appropriate in the absence of a choice. Nothing in the Policy limits the consumer's rights under applicable law.

Pursuant to Regulation (EU) No 524/2013 of the European Parliament and of the Council of May 21, 2013 on online dispute resolution for consumer disputes and amending Regulation (EC) No 2006/2004 and Directive 2009/22 / EC (Regulation on ODR in consumer disputes), the User may file a complaint in order to resolve a possible dispute with TOBILET via the ODR internet platform (the ODR platform is available at - http://ec.europa.eu/consumers/odr/).