PRIVACY POLICY

I.

DT-Automation Sp. z o.o., NIP: 542 323 57 76, tel: info@dt-automatyzacja.pl, as the Administrator of your personal data hereinafter referred to as ‘ADO’ cares about your privacy, therefore, based on the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 on the protection of natural persons in relation to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (Dz. Urz. EU L 119, p. 1) – hereinafter referred to as RODO, we provide you with the most important information about ADO’s rules on the processing of your personal data, including cookies, which are used by our online platform.

II.

ADO collects and processes personal data in accordance with the relevant legislation, including in particular the RODO, and the data processing rules provided for therein. We endeavour to provide you with transparency in data processing, in particular we always inform you about the data processing at the time of collection, including the purpose and legal basis of the processing – e.g. when creating an Account on the Website, entering into a contract, signing up for a newsletter. The ADO ensures that data is only collected to the extent necessary for the stated purpose and is only processed for the period of time it is necessary.

III.

In the course of processing personal data, we ensure its security and confidentiality and that data subjects have access to information about this processing. In the event that, despite the security measures in place, there is a breach of personal data protection (e.g. data ‘leakage’ or data loss), we apply the provisions of the RODO and inform the supervisory authority and the data subjects of such an event in a manner that is consistent with the provisions of the RODO.

IV.

PERSONAL DATA ADMINISTRATOR (‘Administrator’)

The administrator of your personal data in connection with the use of www.dt-automatyzacja.pl, hereinafter referred to as the ‘Service’, is DT-Automation Sp. z o.o., NIP: 542 323 57 76, tel: info@dt-automatyzacja.pl, hereinafter referred to as ADO

If you have any questions about the processing of your personal data and your rights, please contact us:
a) in writing to: Jana Matejki 43 Street, 15-196 Białystok,
b) by e-mail to: info@dt-automatyzacja.pl
c) by phone on +48 602 779 049, with our employee in charge of supporting the Users in the implementation of their questions and rights related to personal data protection.

V.

FOR WHAT PURPOSE AND ON WHAT BASIS WE PROCESS PERSONAL DATA

ADO may process the following personal data of Users or Clients using the Website: first and last name; e-mail address; contact telephone number; delivery address (street, house number, apartment number, postal code, town, country), address of residence/business/site (if different from delivery address). In the case of Users or Clients who are not consumers, the Administrator may additionally process the company name and tax identification number (NIP) of the Customer or Client. Provision of the personal data referred to in the point above may be necessary to conclude and perform a Sales Agreement or an Agreement for the provision of Electronic Services on the Website. Each time the scope of data required to conclude an agreement is indicated beforehand on the Site.

Depending on which functionalities of the Website you use, we process your data provided voluntarily by you for the following purposes:

OBJECTIVE	LEGAL BASIS
Display of web pages	Our legitimate interest (Article 6(1)(f) GDPR), consisting of providing the service and the need to safeguard against misuse.
Creation and maintenance of a User Account, User authentication, Provision of services offered on our web portal	Necessity for the performance of the contract for the provision of the Account service (Article 6(1)(b) RODO). and with regard to data provided on an optional basis, the legal basis for processing is consent (Article 6(1)(a) RODO); In order to create an account on the website, you are asked to provide the data necessary for the creation and operation of your account, i.e. your e-mail address or to give your consent to the download of this data from the Google or Facebook platform. If you create an account or log in to the service via social networks (Facebook, G+, Instagram, Twitter), the service, with your consent, will only download the data necessary for registration and account maintenance from your social network account. legitimate interest (Article 6(1)(f) of the DPA) to analyse users’ activity on the service and how they use their account, as well as their preferences, in order to improve the functionalities used; for the purpose of possibly establishing, investigating or defending against claims – the legal basis for the processing is our legitimate interest (Article 6(1)(f) RODO) consisting in protecting your rights;
Services requiring an Account We process your personal data in order to provide services requiring an Account.	We process your personal data in order to provide you with services that require you to create an Account.
Sending a newsletter	Consent (Article 6(1)(a) RODO).
Order processing in order to fulfill the order placed (including any complaints)	The legal basis for the processing is the necessity of the processing for the performance of the contract (Art. 6(1)(b) RODO); with regard to data provided on an optional basis, the legal basis for the processing is consent (Art. 6(1)(a) RODO); The legal basis for the processing is a legal obligation (Art. 6(1)(c) RODO) in order to comply with statutory obligations incumbent on the controller, arising in particular from tax and accounting regulations.
Statistics on the use of the various functionalities of the Website and to facilitate the use of the Website and the mobile application and to ensure the IT security of the Website	Legal basis. Our legitimate interest (Article 6(1)(f) RODO) in facilitating the use of electronically provided services and improving the functionality of these services.
Determination, investigation and enforcement of claims	The legal basis for the processing is the legitimate interest of the controller (Article 6(1)(f) RODO) to establish, assert and enforce claims and to defend against claims in proceedings before courts and other state authorities.
For analytical and statistical purposes	The legal basis for the processing is the legitimate interest of the controller (Article 6(1)(f) of the RODO), which consists in conducting analyses of users’ activity on the website, as well as their purchasing preferences, in order to improve the functionalities used;
Handling complaints and requests, responding to inquiries. Scope of data. For this purpose, we may process certain personal data provided by you in your profile, as well as data related to your use of our services, which are the reason for the complaint or request, and data contained in documents attached to the complaint or request.	Legal basis. Our legitimate interest (Article 6(1)(f) GDPR), consisting of improving the functionality of services provided electronically and building positive relationships with Users and non-logged-in Users, based on reliability and loyalty.

VI.

HOW LONG WE KEEP PERSONAL DATA

1 The period of processing depends on the type of service provided and the purpose of the processing. The period of processing may also be determined by the regulations, where they provide the basis for the processing.

2. We retain your personal data for the period you have an Account on the Website for the purposes of providing the Account service and related functionalities and other services in accordance with the Regulations for the provision of electronic services. After deletion of the Account, your data will be anonymised, except for the following personal data, which we will leave for the purposes of handling complaints and claims related to the use of ADO services, investigation or defence against claims.

3. Where the basis for processing is necessity for the conclusion and performance of a contract, the data will be processed for the duration of the provision of the service or the fulfilment of the order until the contract is fulfilled.

4. Where processing is based on consent, the data shall be processed until the consent is withdrawn or an effective objection is made or an effective request for erasure is made.

5. If processing is done on the basis of the legitimate interest of the ADO – data shall be processed for the period of time enabling its fulfilment or until an effective objection to the processing is raised.

6. The processing period may be extended if the processing is necessary for the establishment, investigation or defence against possible claims, and thereafter, only if and to the extent required by law. We will only process your data for as long as we have a legal basis to do so, which is until:
A) we are no longer under a legal obligation obliging us to process your data
B) the possibility for either party to assert claims related to a contract concluded by the Shop ceases
C) you withdraw your consent to the processing of your data, if it was the basis for such processing
– whichever is applicable in the case and which occurs at the latest.

7 After the expiry of the processing period, the data shall be irreversibly deleted or anonymised.

VII.

CATEGORIES OF RECIPIENTS OF PERSONAL DATA

1. In connection with the provision of services by ADO, your personal data may be disclosed to external entities, including, in particular, suppliers responsible for the operation of IT systems used to provide the services, entities such as banks and payment operators, entities providing accounting services, companies providing courier and delivery services to marketing agencies (within the scope of marketing services), entities providing legal or accounting services, couriers, marketing agencies; and

2. If you have given your consent, your data may also be shared with other entities for their own purposes, including marketing.

3. Your data may be disclosed to competent authorities or third parties who request such information, based on the relevant legal basis from which the legal obligation to provide information arises and in accordance with the provisions of the applicable law – we make your personal data available if we are requested to do so by authorised state authorities, in particular organisational units of the public prosecutor’s office, the Police, the President of the Office for Personal Data Protection, the President of the Office for Competition and Consumer Protection or the President of the Office of Electronic Communications.

4. The ADO knows that the level of protection of personal data outside the European Economic Area (EEA) differs from that provided by European law. The entities with which the ADO cooperates are mainly based in Poland and in other countries of the European Economic Area (EEA). The ADO transfers personal data outside the EEA only when necessary, and with an adequate level of protection, primarily by: cooperation with entities, processing personal data in countries for which a relevant decision of the European Commission has been issued; application of standard contractual clauses, issued by the European Commission; application of binding corporate rules, approved by the relevant supervisory authority; in case of data transfer to the USA, cooperation with entities participating in the Privacy Shield programme, approved by a decision of the European Commission. The ADO always informs of its intention to transfer personal data outside the EEA at the stage of collection.

VIII.

RIGHTS OF THE PERSON WHOSE PERSONAL DATA WE ARE PROCESSING

We ensure the exercise of your rights as outlined below. You can exercise your rights by submitting a request to the contact details provided in Section IV above. Individuals whose data is being processed have the following rights:

A) Right to Rectify Data
You have the right to rectify and complete your personal data. You can do this independently in the Settings (Privacy) tab. For other personal data, you have the right to request rectification (if incorrect) and completion (if incomplete).

B) Right to Object to Data Usage
You have the right to object at any time to the use of your personal data, including profiling, if we process your data based on our legitimate interests, e.g., for statistical analysis of service usage, facilitating use of the Service, or satisfaction surveys. If your objection is justified and we have no other legal basis to process your data, we will delete the data against which you objected.

C) Right to Erasure (“Right to Be Forgotten”)
You have the right to request the deletion of all or some of your personal data. A request to delete all data will be treated as a request to delete your account. You have the right to request deletion of personal data if:

• You have withdrawn your consent, where data processing was based on your consent.
• Your personal data is no longer necessary for the purposes for which it was collected or processed.
• You objected to data usage for marketing purposes.
• You objected to data usage for statistical analysis or satisfaction surveys, and the objection was deemed valid.
• Your personal data is processed unlawfully.

Despite a request for deletion due to an objection or withdrawal of consent, we may retain certain personal data as necessary for establishing, pursuing, or defending claims. This applies particularly to data such as your name, email address, and application history, which we retain for handling complaints and claims related to our services.

D) Right to Restrict Data Processing
You have the right to request the restriction of your data processing. If such a request is submitted, we will prevent you from using certain functionalities or services that require processing of the data in question until the request is resolved. We will also refrain from sending you communications, including marketing messages.
You can request restriction of data use in the following cases:

• When you dispute the accuracy of your personal data – we will restrict its use until the accuracy is verified, but no longer than 7 days.
• When data processing is unlawful, but you request restriction instead of deletion.
• When your data is no longer needed for the purposes for which it was collected, but you require it for establishing, pursuing, or defending claims.
• When you objected to data usage – restriction applies while it is being determined whether your particular situation outweighs the interests pursued by processing your personal data.

E) Right of Access to Data
You have the right to obtain confirmation of whether we process your personal data, and if so, you have the right to:

• Access your personal data.
• Obtain information about the purposes of processing, categories of processed data, recipients or categories of recipients, planned retention period or criteria for determining this period, rights under GDPR, the right to lodge a complaint with a supervisory authority, the data source, automated decision-making, including profiling, and safeguards for data transfer outside the EU.
• Obtain a copy of your personal data.

F) Right to Withdraw Consent
If your data is processed based on consent, you have the right to withdraw it at any time. Withdrawal does not affect the lawfulness of processing carried out before consent was withdrawn.

G) Right to Data Portability
You have the right to receive your personal data, provided to us, and transfer it to another data controller of your choice, e.g., a similar service provider. You also have the right to request direct transfer to another controller, if technically feasible. Your personal data will be provided in a commonly used, machine-readable format.

H) Right to Lodge a Complaint
If you believe that the processing of personal data violates GDPR or other data protection regulations, you can lodge a complaint with the President of the Personal Data Protection Office.

How quickly do we process your request?
If you submit a request exercising the above rights, we will fulfill it or refuse without undue delay, but no later than one month after receiving it. If, due to the complexity of the request or the number of requests, we cannot fulfill it within a month, we will fulfill it within the next two months, informing you in advance of the extension. For technical reasons, we require 24 hours to update the settings you select in our systems. Therefore, you may receive an email during the update process, even if you opted out of receiving such messages.

If the data controller cannot identify the applicant based on the submitted request, they will request additional information. The request can be submitted personally or via a representative (e.g., a family member).

For security reasons, the controller encourages using a power of attorney certified by a notary or an authorized legal adviser or advocate, which will significantly speed up authentication.

Responses are provided in writing unless the request was submitted via email or requested in electronic form.

Submitting Complaints, Queries, and Requests
You can submit complaints, queries, and requests related to the processing of your personal data and the exercise of your rights.

IX.

PROFILING

As part of the Service, we may automatically tailor certain content to your needs, i.e. carry out profiling, using the personal data you have provided. Before we carry out profiling on the basis of which decisions are made:

A) having legal effects on you,
B) affecting you in a similarly significant manner,b>.

we will ask you for your consent. Remember that you can revoke your consent at any time. Data processing remains lawful until you revoke your consent.

X.

REQUIREMENT TO PROVIDE PERSONAL DATA

The provision of personal data by you, dear User, is voluntary, but in some cases may be necessary to conclude a contract. Depending on the purpose for which the data is provided:

A) inability to register on the Website,
B) no possibility of using the Website’s services,
C) no possibility of making purchases on the Website.

XI.

DATA SECURITY

ADO is committed to ensuring the security of your personal information. The Service uses encrypted data transmission (SSL) during registration and login, which ensures the protection of your identifying data and makes it significantly more difficult for unauthorised systems or persons to intercept access to your Account. To ensure data integrity and confidentiality, ADO:

A) has implemented procedures that allow access to personal data only to authorised persons and only to the extent that this is necessary for their tasks.
B) apply organisational and technical arrangements to ensure that all operations on personal data are recorded and performed only by authorised persons.
C) shall furthermore take the necessary measures to ensure that t subcontractors and other entities cooperating with the ADO guarantee the application of appropriate security measures whenever they process personal data on behalf of the ADO,
D) conduct a risk analysis and monitor the adequacy of the applied data security measures to the identified risks.
E) if necessary, the ADO shall implement additional measures to enhance data security.

XII.

COOKIES

Cookies are small pieces of information in the form of text files which are sent by a server and stored on the website visitor’s side (e.g. on the hard drive of a computer, laptop or smartphone memory card – depending on the device used by the visitor to our online shop). Detailed information on cookies as well as the history of their creation can be found, inter alia, here. The Website uses the following types of cookies:

1.1. ‘session’ or ‘temporary’ cookies, which are session-related and are stored on the user’s device until the user exits the website;

1.2. ‘persistent’ cookies, which remain on the browser after the session has ended (unless deleted by the user);

1.3.third party cookies (third party cookies), originating from the advertising servers of entities cooperating with the website.

2. ADO may process the data contained in Cookies when visitors use the website of the Online Shop for the following purposes:
A) identifying the Service Recipients as logged in to the Online Shop and showing that they are logged in; B) remembering the Products added to the basket for the purpose of placing an Order;
C) memorise data from completed Order Forms, surveys or login data to the Online Shop;
D) adapting the content of the Website to individual User preferences (e.g. as regards colours, font size, page layout) and optimising the use of the Website pages;
E) conduct anonymous statistics presenting the manner of use of the Site.

3. By default, most web browsers available on the market accept the storing of cookies. You have the possibility to determine the conditions for the use of cookies through the settings of your browser. This means that you can, for example, partially restrict (e.g. temporarily) or completely disable the possibility of storing cookies – in the latter case, however, this may affect some of the functionality of the Internet Shop (for example, it may not be possible to follow the path of the Order through the Order Form due to failure to remember the Products in the shopping cart during the subsequent steps of submitting the Order).

4. The settings of your Internet browser with respect to Cookies are relevant to your consent to the use of Cookies by our Online Shop – in accordance with the regulations, such consent may also be expressed through the settings of your Internet browser. In the absence of such consent, the cookie settings of your browser must be changed accordingly.

5. Detailed information on how to change the settings for cookies and how to delete them yourself in the most popular web browsers is available in the help section of your web browser and on the following pages (just click on the given link):

Chrome
Firefox
Internet Explorer
Opera
Safari
Microsoft Edge

(6) ADO also processes anonymised usage data related to the use of the Website (IP address, domain) to generate statistics to assist in the administration of the Website. This data is aggregated and anonymous, i.e. it does not contain identifying characteristics of visitors to the Website. This data is not disclosed to third parties.

XIII.

FINAL PROVISIONS

The website may contain links to other websites. ADO recommends that when you go to other sites, you review the privacy policy established there. This privacy policy applies only to this Website.