Privacy & Cookie Policy [EN]

Contents

Privacy Policy

The following Privacy Policy defines the rules for saving and accessing data on User Devices using the Website for the purposes of providing services electronically by the Administrator, as well as the rules for collecting and processing Users’ personal data,
which they have provided personally and voluntarily using the tools available on the Website.

The following Privacy Policy is an integral part of the Service Regulations, which defines the rules, rights, and obligations of Users using the Website.

§1 Definitions

  • Website – the “PRIMESTEP” website operating at https://primestep.pl
  • External Website – websites of partners, service providers, or service recipients cooperating with the Administrator
  • Website/Data Administrator – “Primestep Małgorzata Żukowska” with its registered office at Glądy 28, 11-220 Górowo Iławeckie, Tax Identification Number (NIP): 7431634842
  • User – a natural person for whom the Administrator provides services electronically via the Website.
  • Device – an electronic device with software through which the User accesses the Website.
  • Cookies – text data collected in the form of files placed on the User’s Device.
  • GDPR – 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 (General Data Protection Regulation).
  • Personal data – means information about an identified or identifiable natural person (“data subject”); 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing – means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring,
    storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, matching or combining, restriction, erasure or destruction;
  • Restriction of processing – means marking stored personal data for the purpose of limiting their future processing.
  • Profiling – means any form of automated processing of personal data that involves the use of data Personal data for the purpose of assessing certain personal factors of a natural person, in particular for the analysis or forecasting of aspects relating to that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.

    Consent – Consent of the data subject means the voluntary, specific, informed, and unambiguous expression of the data subject’s will by which the data subject, in the form of a declaration or a clear affirmative action, consents to the processing of personal data concerning him or her.

    Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or unauthorized access to, personal data transmitted, stored, or otherwise processed.

    Pseudonymization – means the processing of personal data in such a way that it can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separate and subject to technical measures. and organizational measures that prevent their assignment to an identified or identifiable natural person.

  • Anonymization – Data anonymization is an irreversible data operation process that destroys/overwrites “personal data,” making it impossible to identify or link a given record to a specific user or natural person.

§2 Data Protection Officer

Pursuant to Article 37 of the GDPR, the Controller has not appointed a Data Protection Officer.

In matters concerning data processing, please contact the Controller directly.

§3 Types of Cookies

  • Internal Cookies – files placed and read from the User’s Device by the Website’s IT system.
  • External Cookies – files placed and read from the User’s Device by the IT systems of External Services.
  • Session Cookies – files placed and read during a single session of a given Device.
  • Persistent Cookies – files placed and read until they are manually deleted.

§4 Data Storage Security


  • Cookie Storage and Reading Mechanisms     – The mechanisms for storing, reading, and exchanging data between Cookies stored on the User’s Device and the Website are implemented through built-in web browser mechanisms and do not allow for the downloading of other data from the User’s Device or data from other websites the User has visited, including personal data or confidential information. Transferring viruses, Trojan horses, and other worms to the User’s Device is also practically impossible.
  • Internal Cookies – Cookies used by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that may threaten the security of personal data or the security of the Device used by the User.
  • External Cookies – The Administrator takes all possible measures to verify and select the website’s partners with the security of Users in mind. The Administrator selects well-known, large partners with global public trust for cooperation. However, the Administrator does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the security of Cookies, their content and the use of Scripts from external websites installed on the website in accordance with the license, to the extent permitted by law. The list of partners is included later in the Privacy Policy.
  • Cookie Control
  • Threats on the User’s Side – The Administrator uses all possible technical measures to ensure the security of data stored in Cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Administrator is not responsible for intercepting this data, impersonating the User’s session or deleting it as a result of the User’s conscious or unconscious activity, viruses, Trojan horses and other software.spyware that may be or have infected the User’s Device. To protect themselves against these threats, Users should adhere to the principles that increase their cybersecurity.
  • Personal Data Storage – The Administrator ensures that it makes every effort to ensure that the processed personal data voluntarily entered by Users is secure, access to it is limited, and processed in accordance with its intended use and processing purposes. The Administrator also ensures that it makes every effort to protect its data against loss by using appropriate physical and organizational security measures.
  • Password Storage – The Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this area. Decrypting account passwords provided on the Website is practically impossible.

§5 Purposes for which Cookies are used

  • Improving and facilitating access to the Website
  • Personalizing the Website for Users
  • Enabling Login to the Website
  • Marketing, Remarketing on External Websites
  • Advertising Services
  • Affiliate Services
  • Maintaining Statistics (User Statistics, Number of Visits, etc.)
  • Providing Multimedia Services
  • Providing Social Media Services

§6 Purposes of Personal Data Processing

Personal data voluntarily provided by Users is processed for one of the following purposes:

  • Services for registering and maintaining a User account on the Website
  • Newsletter services (including sending advertising content with consent)
  • Services for commenting/liking posts without registration
  • Services for sharing information about content on social media
  • Communication between the Administrator and Users
  • Ensuring the legitimate interest of the Administrator

User data collected anonymously and automatically is processed for one of the following purposes:

  • Maintaining statistics
  • Remarketing
  • Serving advertisements tailored to User preferences
  • Operating affiliate programs
  • Ensuring the Administrator’s legitimate interest

§7 Cookies from External Websites

The Administrator uses JavaScript and web components from partners on the Website, which may place their own cookies on the User’s Device. Remember that you can decide which cookies can be used by individual websites in your browser settings. Below is a list of partners or their services implemented on the Website that may place cookies:

Services provided by third parties are beyond the Administrator’s control. These entities may change their terms of service, privacy policies, data processing purposes, and cookie usage methods at any time.

§8 Types of Collected Data

The Website collects data about Users. Some data is collected automatically and anonymously, while some data is personal data provided voluntarily by Users when signing up for individual services offered by the Website.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Subpages opened
  • Time spent on the relevant subpage of the website
  • Operating system type
  • Address of the previous subpage
  • Referrer address
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected during registration:

  • Name / surname / nickname
  • Login
  • Email address
  • IP address (collected automatically)

Data collected when subscribing to the Newsletter service

  • Name / surname / nickname
  • Email address
  • Gender
  • IP address (collected automatically) (automatically)

Data collected when adding a comment

  • Name and surname / nickname
  • Email address
  • Website address
  • IP address (automatically collected)

Some data (without identifying data) may be stored in cookies.
Some data (without identifying data) may be transferred to a statistical service provider.

§9 Access to personal data by third parties

As a rule, the sole recipient of personal data provided by Users is the Administrator.
Data collected as part of the services provided is not transferred or resold to third parties.

Entities responsible for processing data (usually under a Data Processing Agreement) may have access to the data. for maintaining the infrastructure and services necessary to operate the website, i.e.:

  • Hosting companies providing hosting or related services to the Administrator
  • Companies through which the Newsletter service is provided
  • IT service and support companies performing maintenance or responsible for maintaining the IT infrastructure
  • Companies intermediating in online payments for goods or services offered on the Website
    (in the case of purchase transactions on the Website)

§10 Method of processing personal data

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless published as a result of an individual action by the User (…)
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) will not be transferred outside the European Union.
  • Anonymous data (without personal data) will not be used for automated decision-making (profiling).
  • Anonymous data (without personal data) will not be resold to third parties.

§11 Legal basis for personal data processing

The website collects and processes User data based on:

  • 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 (General Data Protection Regulation)
    • Article 6(1)(a)
      The data subject has given consent
      I consent to the processing of my personal data…
    • Article 6(1)(b)
      Processing is necessary for the performance of a contract to which the data subject is a party…
    • Article 6(1)(b) f
      processing is necessary for the purposes of legitimate interests…
  • Act of 10 May 2018 on Personal Data Protection (Journal of Laws of 2018, item 1000)
  • Act of 16 July 2004 – Telecommunications Law (Journal of Laws of 2004, No. 171, item 1800)
  • Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws of 1994, No. 24, item 83)

§12 Period of Personal Data Processing

Personal data provided voluntarily by Users:

As a general rule, the personal data indicated are stored only for the duration of the Service provided by the Administrator within the Website. They are deleted or anonymized within 30 days of the termination of the service (e.g., deletion of a registered user account, unsubscription from the Newsletter list, etc.).

The exception is a situation requiring the Administrator to secure legitimate purposes for further processing of such data. In such a situation, the Administrator will store the indicated data from the time the User requests its deletion, but no longer than for a period of 3 years in the event of a violation or suspected violation of the provisions of the website’s terms and conditions by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, is stored by the Administrator
for the purpose of maintaining website statistics for an indefinite period.

§13 User Rights Related to the Processing of Personal Data

The website collects and processes User data based on:

  • Right to Access Personal Data
    Users have the right to access their personal data,
    exercised upon request submitted to the Administrator.
  • Right to Correct Personal Data
    Users have the right to request from the Administrator immediate
    correction of personal data that is incorrect and/or supplementation of incomplete personal data, upon request submitted to the Administrator.
  • Right to delete personal data
    Users have the right to request the Administrator to immediately
    delete their personal data, upon request submitted to the Administrator.

    In the case of user accounts, data deletion involves anonymizing
    the data that allows the User to be identified. The Administrator reserves the right to suspend the execution of a request to delete data in order to protect
    the Administrator’s legitimate interest (e.g., if the User
    has violated the Terms and Conditions or the data was obtained as a result of
    conducted correspondence).

    In the case of the Newsletter service, the User has the option of deleting
    their personal data themselves using the link included in each
    sent email.

  • Right to restrict the processing of personal data
    Users have the right to restrict the processing of personal data
    in the cases indicated in Article 18 of the GDPR, including: questioning the accuracy of personal data, upon request submitted to the Controller.
  • Right to personal data portability
    Users have the right to obtain from the Controller personal data
    concerning the User in a structured, commonly used, machine-readable format, upon request submitted
    to the Controller.
  • Right to object to the processing of personal data
    Users have the right to object to the processing of their personal data in the cases specified in Art. 21 GDPR, implemented
    upon request submitted to the Controller
  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority
    responsible for personal data protection.

§14 Contacting the Controller

You can contact the Controller in one of the following ways:

  • Postal address – Primestep Małgorzata Żukowski, Glądy 28, 11-220 Górowo Iławeckie
  • Email address – kontakt@primestep.pl
  • Telephone number – +48791810111
  • Contact form – available at: https://primestep.pl/contact

§15 Website Requirements

  • Restricting the saving and access of Cookies on the User’s Device may result in some Website functions not functioning correctly.
  • The Administrator is not responsible for any malfunctioning Website functions
    if the User restricts the saving and reading of Cookies in any way.

§16 External Links

The Website – articles, posts, entries, or comments by Users – may contain links
to external websites with which the Website Owner does not cooperate. These links and the pages or files
linked below them may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for content located outside the Website.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to change this Privacy Policy at any time without notifying Users regarding the use and utilization of anonymous data or the use of Cookies.
  • The Administrator reserves the right to change this Privacy Policy at any time regarding the processing of Personal Data, and will notify Users with user accounts or those subscribed to the newsletter service via email within 7 days of the change.

    Continued use of the services constitutes acceptance of the changes to the Privacy Policy. If the User does not agree with the changes, they must delete their account from the Website
    or unsubscribe from the Newsletter service.

  • Changes made to the Privacy Policy will be published on this subpage of the Website.
  • Changes made take effect upon publication.

Our goal is to help people in the best way possible. this is a basic principle in every case and cause for success. contact us today for a free consultation. 

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