Hello, good morning!

If you ended up here, it’s a reliable sign that you value your privacy. We understand this perfectly well, so we give into your hands a document in which in one place you will find the rules for the processing of personal data and the use of cookies and other tracking technologies in connection with the functioning of the halmod.pl website Formal information at the beginning – the administrator of the service is HalMod Group sp.
z o.
o.
based in Łysomice, place of business ul.
Polna 4a, 87-148 Łysomice, entered in the Register of Entrepreneurs of the National Court Register under the KRS number 0000566165, place of storage of documents District Court in Torun, VII Economic Department of the National Court Register, NIP 879 274 69 65, REGON 525009902, share capital PLN 85 000 paid in full.
This privacy policy has been constructed in the form of questions and answers. The choice of such a form was dictated by attention to clarity and readability of the information presented to you. If you have any concerns about the privacy policy, you can contact us at any time by sending an email to rodo@halmod.pl.

Who is the controller of your personal data?
The administrator of your personal data is HalMod Group sp.
z o.
o.
based in Łysomice, place of business ul. Polna 4a, 87-148 Łysomice, entered in the Register of Entrepreneurs of the National Court Register under KRS number 0000566165, place of storage of documents District Court in Torun, VII Economic Department of the National Court Register, NIP 879 274 69 65, REGON 525009902, share capital PLN 5,000 paid in full.

Who can you contact regarding the processing of your personal data?
As part of the implementation of data protection in our organization, we have decided not to appoint a data protection officer due to the fact that it is not mandatory in our situation. You can contact rodo@halmod.pl by e-mail on matters related to data protection and privacy more broadly.

What information do we have about you?
Depending on the purpose, we may process the following information about you:

• name
• email address
• data contained in e-mail correspondence
• information visible in social media profiles
• tax ID number
• phone number
• details of orders placed
• IP address
• approximate location
• statistics related to newsletters received

Above we have listed specific information. On the other hand, in Appendix 1 to this privacy policy you will find the categories of personal data assigned to the various purposes of processing.

Moreover, we use tools that collect a range of information about you related to your use of our website. This includes, in particular, the following information:

• information about your device, operating system and web browser
• user-ID
• IP address subject to truncation and anonymization
• date of site visit
• subpages viewed
• time spent on the site
• transitions between different subpages
• mouse clicks or screen taps
• clicks on individual links
• the source from which you go to the site
• the age range you are in
• Your gender
• Your approximate location limited to localities
• Your interests determined by your online activity
• This information is referred to hereafter in this privacy policy as “Anonymous Information”

Anonymous information by itself does not, in our opinion, have the character of personal information, because it does not allow us to identify you and we do not collate it with the typical personal information we collect about you. Nevertheless, given the strict jurisprudence of the Court of Justice of the European Union and divided opinions among lawyers, as a precautionary measure, in case Anonymous Information is assigned the nature of personal data, we have also included detailed explanations in this privacy policy regarding the processing of such information.

We are unable to provide you with access to Anonymous Information about you because we are unable to attribute any of the Anonymous Information to any specific user. From the tools that collect Anonymous Information, we can only see a set of statistics and information not assigned to specific individuals. Moreover, we do not have access to the information collected by some of the tools at all, as we are only interested in the correct operation of the function provided by the tool, not the information collected by it. For example, a particular plug-in may collect some information, but it is not shared with us in any way, and we are not interested in this information at all, because we are only interested in making a particular functionality of the plug-in (e.g., sending a newsletter form) simply work. The processing of Anonymous Information allows us to provide you with the functionality available on the website. In addition, Anonymous Information is used for analytical and statistical and marketing purposes, such as ad setup and targeting.

Because Anonymous Information is collected by third-party tools we use, Anonymous Information is also processed by tool providers under the terms of their terms of use and privacy policies. Anonymous information is also used by providers of particular tools to provide and improve services, manage services, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalize content and ads displayed on particular services, sites and applications.

The tools we use that involve the collection of Anonymous Information are listed in Appendix 2 to this Privacy Policy.

How do we get your personal information?
In most cases, you give them to us yourself. This happens when:

• you submit an inquiry
• you place an order
• you send a complaint or withdraw from the contract
• you sign up for the newsletter
• you fill out the forms on our website
• you contact us by email
• you observe our social media profiles or interact with content we publish on social media

In Appendix 1 to this privacy policy, we have assigned the source of data acquisition to each of the processing purposes.

In addition, some information about you may be automatically collected by the tools we use:

• The mechanism of the site collects your IP address
• The newsletter system mechanism collects your IP address and information about your activity in relation to the content sent to you within the newsletter, such as opening messages, clicking on links, etc.
• The third-party tools listed in Appendix 2 of this privacy policy collect Anonymous Information related to your activities on the site

Is your data safe?
We care about the security of your personal information. We have analyzed the risks involved in the various processes of processing your data, and then implemented appropriate security and data protection measures. We continuously monitor the state of the technical infrastructure, train staff, look at the procedures in place, and make the necessary improvements. If you have any questions about your personal information, we are at your service at rodo@halmod.pl

PW what purposes do we process your personal data?
The purposes of processing your personal data are listed in Appendix 1 to this privacy policy.

How long will we keep your personal information?
Data retention periods are indicated separately for each processing purpose. You will find this information in Appendix 1 to this privacy policy. Most of the data is deleted after the expiration of the statute of limitations for claims, although the period of limitation for claims may vary under applicable laws (for example, for businesses it may be 3 years, and for consumers 6 years).

Who are the recipients of your personal information?
We would venture to say that modern business cannot do without third-party services. We also use such services. Some of these services involve the processing of your personal data. Third-party service providers that are involved in the processing of your personal data are:

• The hosting provider that stores the data on the server
• Cloud software provider, where data processing takes place
• other subcontractors who access the data, if the scope of their activities requires such access

All of the entities listed above process your data on the basis of personal data processing entrustment agreements with us and guarantee an adequate level of personal data protection.
If the need arises, your data may be shared with a legal advisor or attorney bound by professional secrecy.
The need may arise from the need for legal assistance requiring access to your personal information.
Furthermore, when it comes to Anonymous Information, access is granted to providers of tools or plug-ins that collect Anonymous Information. The providers of these tools are independent controllers of the data collected in them, and may share this data under the terms of their own regulations and privacy policies, which are beyond my control.

Do we transfer your data to third countries or international organizations?
We transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, particularly in the USA. The providers of these tools guarantee an adequate level of personal data protection through the relevant compliance mechanisms provided by the RODO, in particular through the use of standard contractual clauses. In addition, we use third-party tools that may collect Anonymous Information. Providers of these tools often use servers located around the world, particularly in the United States of America (US), to store the information they collect. The full list of tools is listed in Appendix 1.

Do we use profiling? Do we make an automated decision based on your personal information?
We do not make decisions with respect to you based solely on automated processing, including profiling, which would produce legal effects with respect to you or similarly affect you in a material way.

Yes, we do use tools that may take certain actions depending on the information collected by the tracking mechanisms, but we believe that these actions do not have a significant impact on you, as they do not differentiate your situation as a customer, do not affect the terms of the contract you may enter into with us, etc.

Using certain tools, we may, for example, target you with personalized ads based on previous actions you have taken on the site or suggest products that may interest you. We are talking here about the so-called. behavioral advertising. We encourage you to deepen your knowledge of behavioral advertising, particularly with regard to privacy issues. You can find detailed information, along with the ability to manage your behavioral advertising settings, here.

We emphasize that within the tools I use I only have access to Anonymous Information. This information is stored on the servers of the providers of the individual tools, and these servers can most often be located around the world.

What rights do you have in relation to the processing of your personal data?
The RODO grants you the following potential rights related to the processing of your personal data:

• The right to access your data and receive a copy of it,
• The right to rectify (amend) your data,
• The right to erasure (if, in your opinion, there is no basis for us to process your data, you can request that we erase it),
• The right to restrict data processing (you can request that we restrict the processing of your data only to storing it or performing activities agreed with you, if in your opinion we have incorrect data or are processing it unduly),
• The right to object to processing (you have the right to object to processing on the basis of a legitimate interest; you should indicate the particular situation that you think justifies us stopping the processing covered by the objection; we will stop processing your data for these purposes unless we demonstrate that the grounds for our processing override your rights or that your data are necessary for us to establish, assert or defend claims),
• The right to data portability (you have the right to receive from us in a structured, commonly used machine-readable format the personal data you have provided to us on the basis of a contract or your consent; you can have us send this data directly to another entity),
• The right to withdraw consent to the processing of personal data, if you have previously given such consent,
• The right to lodge a complaint with a supervisory authority (if you find that we are processing your data in violation of the
• The right to lodge a complaint with a supervisory authority (if you find that we are processing your data unlawfully, you can file a complaint about it with the President of the Office for Personal Data Protection or any other competent supervisory authority).

The rules related to the exercise of the rights indicated above are described in detail in Art. 16 – 21 RODO. We encourage you to familiarize yourself with these regulations. For our part, we deem it necessary to explain to you that the rights indicated above are not absolute and you will not be entitled to all processing activities of your personal data.

We emphasize that one of the rights indicated above is always available to you – if you consider that we have violated data protection regulations in the processing of your personal data, you have the opportunity to file a complaint with the supervisory authority (President of the Office for Personal Data Protection).

You can also always request that we provide you with information about what data we have about you and for what purposes we process it. Just send an email to rodo@halmod.pl. However, we have made every effort to ensure that the information of interest to you is comprehensively presented in this privacy policy. You can also use the e-mail address provided above if you have any questions about the processing of your personal data.

Do we use cookies and what are they actually?
Our website, like almost all other websites, uses cookies.

Cookies are small text information stored on your terminal device (e.g. computer, tablet, smartphone), which can be read by our ICT system (our own cookies) or by third-party ICT systems (third-party cookies). Cookies may record and store certain information, which can then be accessed by ICT systems for specific purposes.

Some of the cookies we use are deleted when the browser session ends, i.e. when the browser is closed (so-called session cookies). Other cookies are stored on your terminal device and allow us to recognize your browser the next time you visit the site (persistent cookies). If you want to learn more about cookies as such, you can read, for example, this resource: https://pl.wikipedia.org/wiki/HTTP_cookie.

On what basis do we use cookies?
We use cookies on the basis of your consent, except when cookies are necessary for the proper provision of an electronic service to you.

Cookies that are not necessary for the proper provision of the electronic service will remain blocked until you consent to the use of cookies. During your first visit to the site, we display a message asking for your consent.

Please note that disabling or restricting cookies may prevent you from using some of the features available on our website and cause difficulties in using the website, as well as many other websites that use cookies. For example, if you block the cookies of social networking plug-ins, the buttons, widgets and social features implemented on the site may not be available to you.

Can you disable cookies?
Yes, you can manage your cookie settings within your web browser. You can block all or selected cookies. You can also block cookies of specific sites. You can also delete previously saved cookies and other site and plug-in data at any time.

Web browsers also offer incognito mode. You can use it if you don’t want information about the pages you visited and the files you downloaded to be stored in your browsing and download history. Cookies created in incognito mode are deleted when all windows of this mode are closed.

There are also browser plug-ins available to control cookies, such as. Ghostery ( https://www.ghostery.com). The option to control cookies may also be provided by additional software, especially antivirus packages, etc.

In addition, there are tools on the Internet that allow you to control certain types of cookies, in particular to collectively manage behavioral advertising settings (e.g. www.youronlinechoices.com/, www.networkadvertising.org/choices).

Please note that disabling or restricting cookies may prevent you from using some of the features available on our site and cause difficulties in using our site, as well as many other websites that use cookies. For example, if you block the cookies of social networking plug-ins, the buttons, widgets and social features implemented on our site may not be available to you.

For what purposes do we use our own cookies?
Proprietary cookies are used to ensure the proper functioning of the various mechanisms of the site, such as the correct submission of forms visible on the site. Custom cookies also store information about your consent to cookies.

What third-party cookies are used?
Our website operates third-party cookies related to the tools listed in Appendix 2 of this privacy policy. Individual tools may use more than one cookie, but we have refrained from listing them in detail, not wanting to overwhelm you with an excess of information and on the assumption that it will be clearer for you to use a list of tools along with a statement of the purposes of using these tools than to list all the cookies that technically function within each tool.

We have also refrained from indicating the extent of the information collected in cookies for each tool used, given that each tool collects information related to your characteristics and behaviors undertaken on our website. In this regard, we are dealing with Anonymous Information, which we mentioned earlier as part of this privacy policy.

Knowing the requirements created by the Court of Justice of the European Union, we have nevertheless refrained from indicating the lifespan of cookies used by individual tools. If we wanted to determine reliably the lifetime of each cookie, we would have to overwhelm you with an excess of information that would not in any way realize the principle of transparency and readability of the information directed to you. In addition, the lifespan of cookies may be subject to such active changes on the part of tool providers that we are unable to exercise reliable control over it. Setting aside the determination of the lifespan of cookies, we would like to remind you that the only option for real control over the length of time information is stored in cookies is for you to manage cookies directly. From your web browser, you can delete cookies stored on your device at any time.

At this point, we would like to emphasize once again that within the framework of cookies, we do not have access to information that would allow us to identify you. In this regard, we are dealing with Anonymous Information, which we have mentioned as part of this privacy policy.

Moreover, while in the case of statistical and marketing tools we can view various types of reports generated from Anonymous Information, with regard to other tools we do not even gain any access to the information collected in the cookies, being interested only in whether the functions of the tool for which the tool was installed are working properly within our site.

Do we track your behavior taken within our service?
Yes, we use tools that involve collecting information about your activities on our site. These tools are listed in Appendix 2 to this privacy policy.

Are we targeting you with targeted ads?
Yes, we use advertising tools where we can target ads to specific target groups defined based on various criteria such as age, gender, interests, occupation, job, activities previously undertaken on our site. These tools are listed in Appendix 2 to this privacy policy.

How can you manage your privacy?
The answer to this question is found in many places in this privacy policy when describing specific tools, behavioral advertising, cookie consent, etc. Nevertheless, we have once again gathered this information in one place for your convenience. Below you will find a list of options for managing your privacy.

• cookie settings within your web browser
• Browser plug-ins that support cookie management, e.g. Ghostery
• additional software that manages cookies
• incognito mode in the web browser
• behavioral advertising settings, such as youronlinechoices.com
• settings on the part of third-party tool providers (links to settings have been collected as part of Appendix 2 to this privacy policy)

What are server logs?
Using the site involves sending requests to the server where the site is stored. Each request to the server is recorded in the server logs. Logs include, among others. Your IP address, the date and time of the server, information about the web browser and the operating system you are using. Logs are saved and stored on the server. The data recorded in the server logs are not associated with specific individuals using the site and are not used by us to identify you. Server logs are only auxiliary material for the administration of the site, and their contents are not disclosed to anyone except those authorized to administer the server.

Is there anything else you should know about?
As you can see, the topics of processing personal data, using cookies and managing privacy in general are quite complicated. We have made every effort to ensure that this document provides you with the most far-reaching knowledge on issues important to you. If anything is unclear to you, you would like to learn more or just talk about your privacy, please email us at rodo@halmod.pl.

Is this privacy policy subject to change?
Yes, we may modify this privacy policy, in particular due to technological changes on the part of our service and changes in the law. If you are a registered user of the site, you will receive a message about any change in the privacy policy.

This Privacy Policy is effective as of 2023-01-23