Table of Contents

PRIVACY POLICY OF THE FOXO365.PL WEBSITE

1) GENERAL PROVISIONS
  1. This privacy policy of the Website is informative, which means that it is not a source of obligations for Website Users. The privacy policy contains mainly rules regarding the processing of personal data by the Administrator on the Website, including the grounds, purposes and period of personal data processing and the rights of data subjects, as well as information on the use of cookies and analytical tools on the Website.
  2. The administrator of personal data collected via the Website is DELKOM 2000 SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNNOŚCIĄ with its registered office in Wejherowo (registered office and delivery address: ul. I Brygady Pancernej WP 36, 84-200 Wejherowo); entered into the Register of Entrepreneurs of the National Court Register under the KRS number: 0000037202; registry court where the company's documentation is kept: District Court Gdańsk-Północ in Gdańsk, VIII Commercial Division of the National Court Register; share capital in the amount of: PLN 50,000.00; NIP: 5881943861; REGON: 19202076900000 and e-mail address: info@foxo365.pland telephone number: 58 506 55 76 - hereinafter referred to as "Administrator"And being at the same time the Service Provider of the Website.
  3. Personal data on the Website are processed by the Administrator in accordance with applicable law, in particular in accordance with 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 on the free movement of such data and repealing Directive 95/46 / EC (General Data Protection Regulation) - hereinafter referred to as "GDPR" or "GDPR Regulation". The official text of the GDPR Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679.
  4. Using the Website, including concluding contracts, is voluntary. Similarly, the provision of personal data by the Service User using the Website is voluntary, subject to two exceptions: (1) concluding contracts with the Administrator - failure to provide, in the cases and to the extent indicated on the Website and in the Regulations of the Website and this privacy policy, personal data necessary for the conclusion and performance of the contract for the provision of Electronic Services or another contract with the Administrator results in the inability to conclude this contract. Providing personal data is in this case a contractual requirement and if the data subject wants to conclude a given contract with the Administrator, he is obliged to provide the required data. Each time the scope of data required to conclude a contract is previously indicated on the website of the Website and in the Regulations of the Website; (2) statutory obligations of the Administrator - providing personal data is a statutory requirement resulting from generally applicable legal provisions imposing on the Administrator the obligation to process personal data and failure to provide them will prevent the Administrator from performing these obligations.
  5. The administrator takes special care to protect the interests of persons whose personal data being processed by him, and in particular is responsible and ensures that the data collected by him are: (1) processed in accordance with the law; (2) collected for specified, lawful purposes and not subjected to further processing incompatible with these purposes; (3) factually correct and adequate in relation to the purposes for which they are processed; (4) stored in a form that permits the identification of persons to whom they relate, no longer than it is necessary to achieve the purpose of processing, and (5) processed in a manner ensuring adequate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, by appropriate technical or organizational measures.
  6. Taking into account the nature, scope, context and purposes of processing as well as the risk of violating the rights or freedoms of natural persons with different probability and severity of the threat, the Administrator implements appropriate technical and organizational measures so that the processing takes place in accordance with this regulation and to be able to prove it. These measures are reviewed and updated as necessary. The administrator uses technical measures to prevent the acquisition and modification of personal data sent electronically by unauthorized persons.
  7. Any words, phrases and acronyms that appear in this privacy policy and start with a capital letter (e.g. Service Provider, Internet service, Electronic service) should be understood in accordance with their definition contained in the Regulations of the Website available on the Website pages.
2) BASIS OF DATA PROCESSING

1.The administrator is entitled to process personal data in cases where - and to the extent that - at least one of the following conditions is met: (1) the data subject has consented to the processing of his personal data in one or more specific goals; (2) processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary to fulfill the legal obligation incumbent on the Administrator; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject, requiring the protection of personal data , in particular when the data subject is a child.

2. The processing of personal data by the Administrator requires each time the existence of at least one of the bases indicated in point 2.1 of the privacy policy. The specific grounds for processing the personal data of the Website Service Users by the Administrator are indicated in the next section of the privacy policy - in relation to the given purpose of personal data processing by the Administrator.

3) PURPOSE, BASIS AND PERIOD OF DATA PROCESSING ON THE WEBSITE

         Each time the purpose, basis and period as well as the recipients of personal data processed by the Administrator result from the actions taken by the given Service User on the Website. 

3. The Administrator may process personal data on the Website for the following purposes, on the following grounds and for the following period:

Purpose of data processing

Legal basis for data processing

Data storage period

Performance of the contract for the provision of Electronic Services, another contract or taking action at the request of the data subject, before concluding the above-mentioned contracts

Article 6 (1) 1 lit. b) GDPR Regulations (performance of the contract) - processing is necessary for the performance of the contract to which the data subject is party, or to take action at the request of the data subject, before concluding the contract (e.g. presenting the Service offer in response to an inquiry Recipients)

The data is stored for the period necessary to perform, terminate or otherwise terminate the concluded contract.

Marketing

Article 6 (1) 1 lit. a) GDPR Regulations (consent) - the data subject has consented to the processing of his personal data for marketing purposes by the Administrator

The data is stored until the data subject withdraws the consent for further processing of his data for this purpose.

Determining, investigating or defending claims that may be raised by the Administrator or that may be raised against the Administrator

Article 6 (1) 1 lit. f) GDPR Regulations (legitimate interest of the administrator) - processing is necessary for the purposes of the Administrator's legitimate interests - consisting in establishing, investigating or defending claims that may be raised by the Administrator or which may be raised against the Administrator

The data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of claims that may be raised against the Administrator (the basic limitation period for claims against the Administrator is six years).

Using the website of the Website and ensuring its proper functioning

Article 6 (1) 1 lit. f) GDPR Regulations (legitimate interest of the administrator) - processing is necessary for purposes resulting from the legitimate interests of the Administrator - consisting in running and maintaining the Website

The data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims in relation to the data subject, due to the business activity conducted by the Administrator. The limitation period is defined by law, in particular by the Civil Code (the basic limitation period for claims related to running a business is three years).

Keeping statistics and traffic analysis on the Website

Article 6 (1) 1 lit. f) GDPR Regulations (legitimate interest of the administrator) - processing is necessary for purposes resulting from the legitimate interests of the Administrator - consisting of keeping statistics and analyzing traffic on the Website in order to improve the functioning of the Website and increase the range of Electronic Services provided

The data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of the Administrator's claims in relation to the data subject, due to the business activity conducted by the Administrator. The limitation period is defined by law, in particular by the Civil Code (the basic limitation period for claims related to running a business is three years).

 

4) DATA RECIPIENTS ON THE WEBSITE

1. For the proper functioning of the Website, including the proper provision of Electronic Services by the Administrator, it is necessary for the Administrator to use the services of external entities (such as, for example, a software provider). The administrator uses only the services of such processors who provide sufficient guarantees to implement appropriate technical and organizational measures, so that the processing meets the requirements of the GDPR Regulation and protects the rights of data subjects.

2. The transfer of data by the Administrator does not take place in every case and not to all recipients or categories of recipients indicated in the privacy policy - the Administrator provides data only when it is necessary to achieve a given purpose of personal data processing and only to the extent necessary to achieve it.

3. Personal data of the Service Users of the Website may be transferred by the Administrator to the following recipients or categories of recipients:

and.       carriers / forwarders / courier brokers - in the case of the Service Recipient to whom the Administrator, in accordance with the arrangements, is to send a specific movable item (e.g. documents, paper contract), the Administrator provides the collected personal data of the Service Recipient to the selected carrier, forwarder or intermediary performing the shipment at the request of the Administrator only for the purpose and to the extent necessary to complete deliveries to the Customer.

b.       service providers providing the Administrator with technical, IT and organizational solutions, enabling the Administrator to conduct business activities, including the Website and the Electronic Services provided through it (in particular, computer software providers to run the Website, e-mail and hosting providers, and software providers for company management and providing technical support to the Administrator) - the Administrator provides the collected personal data to the Service User to a selected provider acting on his behalf only in the case and to the extent necessary to perform for a given purpose of data processing in accordance with this privacy policy.

c.        legal and advisory service providers providing the Administrator with legal or advisory support (in particular a law firm or a debt collection company) - the Administrator provides the collected personal data to the Service Recipient to a selected supplier acting on his behalf only in the case and to the extent necessary to achieve a given purpose of data processing in accordance with this privacy policy.

5) PROFILING ON THE WEBSITE

1. The GDPR Regulation imposes an obligation on the Administrator to inform about automated decision-making, including profiling referred to in art. 22 sec. 1 and 4 of the GDPR Regulation, and - at least in these cases - relevant information about the rules for their adoption, as well as the meaning and anticipated consequences of such processing for the data subject. With this in mind, the Administrator provides information on possible profiling in this point of the privacy policy.

2. The Administrator may use profiling on the Website, but the decisions made on its basis by the Administrator do not concern the conclusion or refusal to conclude a contract or the possibility of using Electronic Services on the Website. The effect of using profiling on the Website may be, for example, granting a given person a discount, reminding about unfinished activities on the Website, sending a Service proposal that may correspond to the interests or preferences of a given person or proposing better conditions compared to the Administrator's standard offer. Despite profiling, a given person makes a free decision whether he will want to use the rebate received in this way or the Administrator's offer.

3. Profiling on the Website consists in an automatic analysis or forecast of a given person's behavior on the Website or by analyzing the history of activities undertaken on the Website so far. The condition for such profiling is the Administrator having personal data of a given person in order to be able to send it, for example, a discount or an offer.

4. The data subject has the right not to be subject to a decision which is based solely on automated processing, including profiling, and produces legal effects or significantly affects the person in a similar way.

6) RIGHTS OF THE PERSON WHO THE DATA CONCERNS

         Right to access, rectify, limit, delete or transfer - the data subject has the right to request the Administrator to access his personal data, rectify it, delete it ("the right to be forgotten") or limit processing, and has the right to object to processing, and has the right to transfer his data . Detailed conditions for the exercise of the above-mentioned rights are set out in Art. 15-21 of the GDPR Regulation.

5.       The right to withdraw consent at any time - a person whose data is processed by the Administrator on the basis of expressed consent (pursuant to art.6 par.1 lit.a) or art. 9 paragraph 2 lit. a) of the GDPR Regulation), it has the right to withdraw consent at any time without affecting the lawfulness of the processing which was carried out on the basis of consent before its withdrawal.

6.       The right to lodge a complaint with the supervisory authority - the person whose data is processed by the Administrator has the right to lodge a complaint with the supervisory authority in the manner and mode specified in the provisions of the GDPR Regulation and Polish law, in particular the Act on the protection of personal data. The supervisory body in Poland is the President of the Personal Data Protection Office.

7.       Right to object - the data subject has the right to object at any time - for reasons related to his particular situation - to the processing of his personal data based on art. 6 sec. 1 lit. e) (public interest or tasks) or f) (legitimate interest of the administrator), including profiling based on these provisions. In such a case, the administrator is no longer allowed to process this personal data, unless he demonstrates the existence of valid legally valid grounds for processing, overriding the interests, rights and freedoms of the data subject, or the grounds for establishing, investigating or defending claims.

8. In order to exercise the rights referred to in this point of the privacy policy, you can contact the Administrator by sending an appropriate message in writing or by e-mail to the Administrator's address indicated at the beginning of the privacy policy.

7) COOKIES ON THE WEBSITE AND ANALYTICS

         Cookies (cookies) are small text information in the form of text files, sent by the server and saved on the side of the person visiting the Website (e.g. on the hard drive of the computer, laptop or on the smartphone's memory card - depending on which device is used) visitors to the Website). Detailed information on cookies, as well as the history of their creation, can be found, among others. here: https://pl.wikipedia.org/wiki/HTTP_cookie.

9. Cookies that can be sent via the Website can be divided into various types, according to the following criteria:

Because of their supplier:

1) own (created by the Administrator's Website) and

2) belonging to persons / third parties (other than the Administrator)

Due to their storage period on the device of the person visiting the Website:

1) session (stored until logging out of the Website or turning off the web browser) and

2) permanent (stored for a specified period of time, defined by the parameters of each file or until they are manually deleted)

Due to the purpose of their use:

1) necessary (enabling the proper functioning of the Website),

2) functional / preferential (enabling the adjustment of the Website page to the preferences of the website visitor),

3) analytical and performance (collecting information on how to use the Website),

4) marketing, advertising and social networks (collecting information about a person visiting the Website in order to display personalized advertisements to that person and conduct other marketing activities, including on websites separate from the Website, such as social networks)

10. The Administrator may process the data contained in Cookies when visitors use the Website for the following specific purposes:

Purposes of using cookies on the Website

remembering data from completed forms and surveys on the Website (necessary and / or functional / preferential cookies)

remembering the Services added to the basket in order to place an Order (necessary cookies)

adjusting the content of the Website page to the individual preferences of the Service Recipient (e.g. regarding colors, font size, page layout) and optimizing the use of the Website pages (functional / preferential cookies)

keeping anonymous statistics showing how to use the Website (statistical cookies)

remarketing, i.e. research on the behavior of visitors to the Website by anonymous analysis of their activities (e.g. repeated visits to specific pages, keywords, etc.) in order to create their profile and provide them with advertisements tailored to their expected interests, also when they visit other websites in the advertising network of Google Ireland Ltd. and Facebook Ireland Ltd. (marketing, advertising and social cookies)

11. Checking in the most popular web browsers which Cookies (including the period of operation of Cookies and their supplier) are currently sent by the Website is possible in the following way:

In the Chrome browser:
(1) in the address bar, click the lock icon on the left, (2) go to the "Cookies" tab.

In Firefox:
(1) in the address bar, click on the shield icon on the left, (2) go to the "Allowed" or "Blocked" tab, (3) click the "Cross-site tracking cookies", "Social trackers" or "Content from trackers "

In Internet Explorer:
(1) click the "Tools" menu, (2) go to the "Internet options" tab, (3) go to the "General" tab, (4) go to the "Settings" tab, (5) click the "View files" field

In the Opera browser:
(1) in the address bar, click the lock icon on the left, (2) go to the "Cookies" tab.

in the Safari browser:
(1) click the "Preferences" menu, (2) go to the "Privacy" tab, (3) click the "Manage website data" field

Regardless of the browser, using the tools available e.g. on the website: https://www.cookiemetrix.com/  or:  https://www.cookie-checker.com/

12. By default, most internet browsers available on the market accept cookies by default. Everyone has the option to define the terms of using cookies using the settings of their own web browser. This means that you can, for example, partially limit (e.g. temporarily) or completely disable the option of saving Cookies - in the latter case, however, it may affect some of the Website's functionalities.

13. The web browser settings in the field of cookies are important from the point of view of consent to the use of cookies by our Website - in accordance with the law, such consent may also be expressed through the web browser settings. Detailed information on changing cookie settings and their self-removal in the most popular web browsers is available in the help section of the web browser and on the following pages (just click on the link):

in the Chrome browser

in the Firefox browser

in Internet Explorer

in the Opera browser

in the Safari browser

in the Microsoft Edge browser

14. The Administrator may use the services of Google Analytics, Universal Analytics provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) and the Hotjar service provided by Hotjar Limited (Level 2, St Julian's Business Center, 3, Elia Zammit Street, St Julian's STJ 1000, Malta). These services help the Administrator keep statistics and analyze traffic on the Website. The collected data is processed as part of the above services to generate statistics helpful in the administration and analysis of traffic on the Website. These data are collective. The Administrator, using the above services on the Website, collects such data as the sources and medium of obtaining visitors to the Website and the manner of their behavior on the Website, information on devices and browsers from which they visit the website, IP and domain, geographic data and demographic data (age , gender) and interests.

15. It is possible for a given person to easily block information about their activity on the website of the Website by a given person - for this purpose, you can, for example, install a browser plug-in provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=pl.

8) FINAL PROVISIONS

The website may contain links to other websites. The administrator urges that after switching to other websites, read the privacy policy established there. This privacy policy applies only to the Administrator's Website.