Dear ladies and gentlemen!
In order to ensure the proper use of our clients' personal data and taking into account the provisions of 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 of such data and the repeal of Directive 95/46/EC (the "GDPR"), and in particular Article 14 of the GDPR, we inform you of the following provisions:
I. Personal data administrator.
The controller of your personal data is Kludi GmbH & Co. KG Am Vogelsang 31-33 58706 Menden Deutschland.
II. Contacts for personal data protection issues.
From 25.05.2018, you have the opportunity to contact the Administrator for the protection of personal data and the exercise of your rights by email: datenschutzbeauftragter@kludi.de or in writing to the address of our head office indicated in point I. marked "Data protection - personal / confidential ", as well as in German "Datenschutz persönlich / vertraulich".
III. Purposes and basics of processing.
Purposes of personal data processing:
- performance of a contract to which the person whose personal data is in question is a party; or performing actions at the request of a person regarding his or her personal data, prior to the conclusion of the contract (grounds - Article 6(1)(a) and (b) of the General Data Protection Regulation (GDPR));
- possible agreements, investigations or defense against claims that are in our legitimate interest (basis - Article 6(1)(f) GDPR);
- researching the degree of customer satisfaction and determining the quality of service, which is our legitimate interest (basis - Article 6(1)(f) GDPR);
- fulfillment of obligations arising from applicable law, in particular in the field of taxation (grounds - Article 6(1)(c) and (f) of the GDPR);
Collection, processing and use of personal data through the website www.kludi.com/ua.
1. Collecting data through the website and creating a file log. Each time you launch our website, the system automatically saves data and information from the operating system of the computer requesting the website.
The following data is collected:
- Information about your browser type and version
- The version of the user's operating system
- User's IP address
- Date and time of access
- URL of the sending site
- Name of the uploaded file
- The amount of data transferred.
The above data is stored in the logs of our system, separately from other personal data of the user. The legal basis for the temporary storage of the data and the file log is Art. 6 para. f of the General Data Protection Regulation (GDPR). The temporary storage of the user's IP address by the system is necessary for the display of the website on the user's computer (from launching to closing the website). The files are stored in the log file in order to ensure the full functionality of the website. This data is used to optimize the website and ensure the security of our information systems. The data stored in the file logs is not used for marketing purposes. The purposes described above constitute a legitimate interest of the Data Controller pursuant to Art. 6 para. f of the General Data Protection Regulation (GDPR). The data necessary for the correct display of the website on the user's computer will be deleted after the end of the website browsing session, except for the data stored in the file log. The data stored in the file log is subject to deletion after seven days. After that, the IP address becomes anonymous, which makes it impossible to identify the user's computer and thus the user. The user has no right to object to the collection of data necessary for the correct display of the website. The collection of data by the means and for the purposes specified above does not violate the fundamental rights and freedoms of the person whose data is in question. The user has the right to close the website at any time, and the collected data will be deleted in accordance with the provisions of the previous paragraph.
2. User data.
The personal data you provide (first and last name, address, telephone number, e-mail address, account information) will be used for the following purposes: processing is necessary for the performance of a contract to which the person whose data is in question is a party or to perform actions at the request of that person, prior to the conclusion of the contract. The legal basis for data processing in this area is Article 6(1)(b) of the General Data Protection Regulation (GDPR).
3. Data from the newsletter.
On the website of the service provider, there is an option to subscribe to receive a free newsletter. If you want to receive this newsletter, we need your email address and information (e.g., computer IP address, date and time of registration) that will allow us to verify that you are the owner of the specified email address and agree to receive the newsletter. This information is used solely for the purpose of sending the requested information. No further data is collected. In connection with the processing of data for the purpose of sending the newsletter, your personal data is not passed on to third parties. In the course of registration, we obtain your consent for the purpose of data processing and refer to these provisions on personal data protection. The legal basis for processing data after subscribing to the newsletter is the User's consent - Art. 6 para. 1 lit. a GDPR. The use of Double-Opt-In for logging in is used to confirm that the e-mail is sent with your consent. As part of the procedure, Double-Opt-In confirms with a link that will be sent to the email address you provided. To activate your subscription, just follow the link. The user can cancel the consent to the processing of personal data, as well as the e-mail address, at any time free of charge. If you do not agree to further data processing, the Administrator will immediately delete your personal data.
4. Contact form.
The Administrator provides a contact form on its website that can be used as a means of electronic communication. If you use this form, the data entered in the form will be transmitted to the Administrator and stored. These include: first and last name, gender, postal address, e-mail address and, optionally, telephone number, fax number, country of residence, company name. The data specified in the contact form is not provided to third parties. The data is used exclusively for the purpose of fulfilling the request specified in the text of the contact form. By accepting these personal data protection regulations, you agree to the processing of the personal data you provide under the conditions specified in these personal data protection regulations in accordance with Article 6, paragraph 1, subparagraph a of the General Data Protection Regulation (GDPR). The personal data specified in the contact form is processed by the Administrator solely for the purpose of storing it for the time necessary to send the information you have requested or to establish contact. The personal data provided by you in the contact form will be deleted after fulfillment of your request.
5. Processing of cookies.
The administrator processes cookies. Cookies are small text files that a WWW server places on your computer's hard disk, they do not cause any harm. Cookies improve navigation and make it easier to familiarize yourself with the Administrator's offer. Most of the cookies processed by us are so-called "Session-cookies", which are automatically deleted when you close the page. Other cookies are stored on your device until they are deleted. The above cookies allow us to recognize your browser the next time you visit the website. Cookies can be used by Google's advertising networks to display customized ads. If you do not want cookies to be stored on your device in the future, you should follow the recommendations contained in the browser developer's instructions and select the appropriate options. It should be remembered that deleting the Administrator's cookies or disabling cookies in the future may result in the inability to access certain areas or functions of the Administrator's website. The legal basis for data processing is the justified interest of the Administrator in accordance with Art. 6 para. f of the General Data Protection Regulation (GDPR), i.e. displaying the website in a fully functional version on your device.
6. Use of Google Analytics.
The Administrator's website uses Google Analytics, a website traffic analysis service provided by Google Inc. (1600 Amphitheatre Parkway Mountain View, CA 94043, USA). The Universal Analytics operating mode is also used. This allows you to record data, sessions and interactions between several user devices, their identifiers and analyze user activity on different devices. Google Analytics uses so-called cookies, text files stored on the user's device that allow analyzing the use of websites. The information generated by the cookies and related to the use of this website is usually sent to a Google server in the United States and stored there. However, if you activate IP anonymization on this website, your IP address will be shortened by Google within the EU or in other countries that are parties to the Agreement on the European Economic Area. Only in exceptional cases will the IP address be sent to a Google server in the USA and shortened there. The IP address provided to Google Analytics as part of Google Analytics will not be merged with other Google data. On behalf of the Website Administrator, Google uses this information to evaluate the use of the website, to prepare reports on website activity and to provide other services relating to website activity and internet usage. These purposes are a legitimate interest in data processing. The website uses Google Ads remarketing codes and may display ads to users who have visited our website through a search engine (RLSA - Remarketing List for Search Ads) and when using selected portals that are part of the Google Display Network (GDN - Google Display Network). In addition, the data collected is processed to determine the profiles of users of our website in order to display relevant materials to them in Google's advertising networks. The legal basis for the use of Google Analytics is Art. 6 para. f of the General Data Protection Regulation (GDPR). The administrator has a legitimate interest in analyzing user behavior in order to optimize both the online offer and advertising. Data sent by us and related to cookies, user identifiers (e.g. USER ID) or advertising identifiers will be automatically deleted after 14 months. Deletion of expired data will be carried out automatically once a month. You can prevent the storage of cookies by adjusting your browser settings accordingly; however, please note that this may result in your not being able to fully use all the functions of this website. Moreover, you can prevent the collection of data generated by the cookie and related to the use of the site (including your IP address) and the processing of this data by Google by downloading and installing the available browser driver tools.google.com/dlpage/gaoptout. Opt-Out cookies prevent the collection of data in the future when you refresh this page. To prevent Universal Analytics from tracking you on different devices, you must perform the Opt-Out operation on all systems you use. The administrator also uses Google Analytics to analyze data from AdWords and the DoubleClick cookie for purely statistical purposes and to analyze the behavior of website users. If you do not want this, you can disable it using the Ads Manager adssettings.google.com/authenticated. For more information on the topic of user data in Google Analytics, please read the Google Privacy Policy at support.google.com/analytics/answer/6004245.
IV. Data recipients.
We may provide your personal data for the following categories of subjects:
1) To the companies included in the holding.
2) In justified cases - to entities providing legal services and taxation advice in favor of the Administrator or companies included in the Kludi holding.
3) Data may only be provided to public authorities, such as law enforcement and judicial authorities, upon presentation of a preliminary judicial or administrative decision or administrative and/or in accordance with applicable law, if such an obligation exists.
V. Transfer of data to third countries or international organizations.
We do not transfer your data outside of Poland/EU/EEA.
VI. Data storage period.
Your personal data will be stored for the period specified in the Security Policy applicable to the Administrator, depending on the type of documents in which the personal data is contained.
VII. Your rights.
You have the right to: a) to access your personal data, as well as to receive a copy of it, b) to change (correct) your data, c) to delete your data: If you believe that there is no reason for us to process your data, you may request its deletion. d) restriction of data processing: You may restrict the processing of personal data only to its storage or implementation of actions agreed with you, if you believe that we have incorrect data or process it unreasonably; or you do not want us to delete it because you need it for the establishment, investigation or resolution of disputes; or for the duration of your objection to the processing. e) the right to object to data processing: "Marketing" objection. You have the right to object to the processing of your personal data for the purpose of direct marketing activities. If you exercise this right, we will stop processing your personal data for this purpose. Objection due to a special case: You have the right to object to the processing of your data on the basis of legitimate interest for a purpose other than direct marketing. In this case, you must inform us of your special case, which justifies the termination of data processing. We will stop processing your data for these purposes, or we will tell you that the grounds for processing your data override your rights, or that we need your data to establish, investigate or resolve disputes; f) the right to data portability: You have the right to receive from us, in a structured, commonly used and machine-readable format (e.g., "csv" format), your personal data that we have received on the basis of a contract or your consent. You may also request that we forward this data directly to another entity. g) the right to lodge a complaint with a supervisory authority: If you believe that the processing of your personal data is unlawful, you may lodge a complaint with the Chairman of the Data Protection Authority or other relevant supervisory authority: Landesbeauftragte für Datenschutz und Informationsfreiheit Nordrhein-Westfalen, Postfach 2004 44 40102 Düsseldorf Tel.:0211/38424-0 Fax: 0211/38424-10 h) the right to withdraw consent to the processing of personal data: At any time, you have the right to withdraw your consent to the processing of the personal data that we process on the basis of your consent. The withdrawal of consent does not contradict the legislation on the processing of personal data that was based on your consent before the withdrawal. In order to exercise your rights, you should send a request to the following e-mail address: datenschutzbeauftragter@kludi.de. Please note that before exercising your rights, we will have to identify you.
VIII. Information on the requirements / voluntariness of data provision:
Your provision of data is a condition for the conclusion of a contract or the exercise of rights arising from the warranty - however, failure to provide data in the area required by the Administrator may result in the denial of these rights. Kludi GmbH & Co. KG, May 2018.
