Privacy Policy

This Privacy Policy outlines the rules for storing and accessing data on User Devices used for the purpose of providing electronic services by the Administrator and the rules for collecting and processing Users' personal data that have been provided by them personally and voluntarily through the tools available on the Website. This Privacy Policy is an integral part of the Website's Terms of Service, which defines the rules, rights, and obligations of Users using the Website.

§1 Definitions

• Service - the Zyrek Ferrara Consulting website operating at zyrekferrara.com.
• External Service - internet services of partners, service providers, or clients cooperating with the Administrator.
• Service/Data Administrator - The Administrator of the Service and Data (hereinafter referred to as the Administrator) is ZYREK FERRARA CONSULTING SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, operating at: UL. PRZYJAŹNI 6 / U5, 53-030 WROCŁAW, with the assigned tax identification number (NIP): 8992956822, (REGON): 524962064, (KRS): 0001029163, providing electronic services through the Service.
• User - a natural person for whom the Administrator provides electronic services through the Website.
• Device - an electronic device with software through which the User gains access to the Service.
• 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
• Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
• Restriction of Processing - means the marking of stored personal data with the aim of limiting their processing in the future.
• Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular, to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
• Consent - consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
• Personal Data Breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.
• Pseudonymization - means the processing of personal data in such a manner that the data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
• Anonymization - Data anonymization is an irreversible process of operations on data that destroys/overwrites 'personal data,' making it impossible to identify or associate a given record with a specific user or natural person.

§2 Data Protection Officer

Based on Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer. For matters related to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

• Internal Cookies - files placed and read from the User's Device by the Service's teleinformation system.
• External Cookies - files placed and read from the User's Device by teleinformation systems of external services. Scripts of external services that may place Cookies on the User's Device have been intentionally placed in the Service through scripts and services made available and installed in the Service.
• Session Cookies - files placed and read from the User's Device by the Service during a single session of that Device. After the session ends, the files are deleted from the User's Device.
• Permanent Cookies - files placed and read from the User's Device by the Service until they are manually deleted. The files are not deleted automatically after the end of the Device's session unless the User's Device configuration is set to delete Cookie files after the session ends.

§4 Data Storage Security

• Mechanisms for storing and reading Cookie files - The mechanisms for storing, reading, and exchanging data between Cookie files saved on the User's Device and the Service are implemented through built-in mechanisms of internet browsers and do not allow the retrieval of other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, trojans, 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 could threaten the security of personal data or the security of the Device used by the User.
• External Cookies - The Administrator makes every possible effort to verify and select partners of the Service in the context of User safety. The Administrator selects well-known, large partners with global social trust for cooperation. However, the Administrator does not have full control over the content of Cookie files originating from external partners. The Administrator is not responsible for the security of Cookie files, their content, or the lawful use of Scripts installed in the Service, originating from external Services, to the extent permitted by law. The list of partners is included in the further part of the Privacy Policy.
• Cookie Control - The User can independently change the settings regarding the storage, deletion, and access to data saved in Cookie files by any website at any time. Information on how to disable Cookie files in the most popular computer browsers is available on the browser's website. The User can delete all Cookie files saved so far at any time using the tools of the User's Device through which the User uses the Service.
• User Risks - The Administrator takes all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of these data depends on both parties, including the User's activities. The Administrator is not responsible for the interception of these data, impersonation of the User's session, or their deletion, resulting from conscious or unconscious activities of the User, viruses, trojans, and other spyware that the User's Device may or may not be infected with. Users should follow safe internet usage practices to protect themselves from these risks.
• Personal Data Storage - The Administrator ensures that all efforts are made to keep personal data voluntarily provided by Users safe, access to them is limited, and processing is carried out in accordance with their purpose and goals. The Administrator also ensures that all efforts are made to secure the data held against loss by using appropriate physical and organizational security measures.
• Password Storage - The Administrator declares that passwords are stored in an encrypted form, using the latest standards and guidelines in this area. Decrypting passwords entered in the Service to access accounts is practically impossible.

§5 Purposes for which Cookie files are used

§6 Purposes of processing personal data

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

• Providing electronic services:
• Registration and maintenance of the User's account in the Service and the functionalities associated with it
• Services for sharing information about the content posted on the Service in social networking services or other websites.
• Communication between the Administrator and Users regarding the Service and data protection
• Ensuring the legitimate interest of the Administrator

Data about Users collected anonymously and automatically are processed for one of the following purposes:

• Conducting statistics
• Remarketing
• Serving ads tailored to Users' preferences
• Handling affiliate programs
• Ensuring the legitimate interest of the Administrator

§7 Types of data collected

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

Anonymous data collected automatically:

• IP Address

Data collected during the Newsletter sign-up

• Email address

Some data (without identifying information) may be stored in cookie files. Some data (without identifying information) may be provided to statistical service providers.

§8 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or resold to third parties. Access to data (usually based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the service, such as hosting companies, providing hosting or related services to the Administrator.

Entrustment of personal data processing - Hosting, VPS, or Dedicated Server Services. The Administrator, for the purpose of running the service, uses the services of an external hosting, VPS, or Dedicated Server provider - OVH sp. z o.o. All data collected and processed in the service is stored and processed in the service provider's infrastructure located within the European Union. There is a possibility of access to data as a result of maintenance work carried out by the service provider's personnel. Access to these data is governed by an agreement between the Administrator and the Service Provider.

§9 How personal data is processed

Personal data voluntarily provided by Users:

• Personal data will not be transferred outside the European Union unless published as a result of an individual action by the User (e.g., posting a comment or entry), making the data available to anyone visiting the service.
• Personal data will not be used for automated decision-making (profiling).
• Personal data will not be sold to third parties.

Anonymous data (without personal data) collected automatically:

• Anonymous data (without personal data) will 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 sold to third parties.

§10 Legal bases for processing personal data

The Service collects and processes Users' 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 to the processing of their personal data for one or more specific purposes
• Article 6(1)(b) - processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract
• Article 6(1)(f) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
• Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
• Act of 16 July 2004 - Telecommunications Law (Journal of Laws 2004, No. 171, item 1800)
• Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994, No. 24, item 83)

§11 Period of processing personal data

Personal data voluntarily provided by Users:

As a rule, the specified personal data is stored only for the period of providing the Service by the Administrator. They are deleted or anonymized within 30 days from the time the service is terminated (e.g., deleting a registered user account, unsubscribing from the Newsletter, etc.)

An exception is a situation that requires securing the legitimate purposes of further processing of these data by the Administrator. In such a situation, the Administrator will store the specified data from the time the User requests their deletion, for no longer than 3 years in the case of violation or suspected violation 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 running service statistics for an indefinite period

§12 User rights related to the processing of personal data

The Service collects and processes Users' data based on:

• Right of access to personal data - Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator
• Right to rectification of personal data - Users have the right to request the Administrator to promptly rectify any inaccurate personal data, and to complete any incomplete personal data, exercised upon request submitted to the Administrator
• Right to erasure of personal data - Users have the right to request the Administrator to promptly erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, the erasure of data consists of anonymizing data that allows the identification of the User. The Administrator reserves the right to withhold the execution of the request for data erasure in order to protect the legitimate interests of the Administrator (e.g., when the User has violated the Terms and Conditions or the data has been obtained as a result of correspondence). In the case of the Newsletter service, the User has the option to independently delete their personal data by using the link provided in each sent email.
• Right to restriction of 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, e.g., challenging the accuracy of personal data, exercised upon request submitted to the Administrator
• Right to data portability - Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used, and machine-readable format, exercised upon request submitted to the Administrator
• 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 Article 21 of the GDPR, exercised upon request submitted to the Administrator
• Right to file a complaint - Users have the right to file a complaint with the supervisory authority responsible for data protection.

§13 Contacting the Administrator

You can contact the Administrator in one of the following ways

• Postal address: UL. PRZYJAŹNI 6 / U5, 53-030 WROCŁAW
• Email address: biuro@zyrekferrara.com
• Phone: +48519772306

§14 Service Requirements

Restricting the ability to save and access Cookie files on the User's Device may cause some functions of the Service to malfunction. The Administrator bears no responsibility for malfunctioning Service functions if the User limits the ability to save and read Cookie files in any way.

§15 External Links

In the Service - articles, posts, entries, or User comments may contain links to external websites with which the Service Owner does not cooperate. These links and the sites or files they point to may be dangerous to your Device or pose a security threat to your data. The Administrator is not responsible for the content found outside the Service.

§16 Changes to the Privacy Policy

The Administrator reserves the right to change this Privacy Policy at any time without the need to notify Users in regard to the use and application of anonymous data or the use of Cookie files.

The Administrator reserves the right to change this Privacy Policy regarding the processing of Personal Data, of which Users with user accounts or subscribed to the newsletter will be informed via email within 7 days of the change. Continued use of the services signifies acknowledgment and acceptance of the changes made to the Privacy Policy. If the User disagrees with the changes made, they are obligated to delete their account from the Service or unsubscribe from the Newsletter.

Changes made to the Privacy Policy will be published on this subpage of the Service.

The changes made come into force upon their publication.