Privacy Policy & Cookies
Purpose
The Policy is for information purposes and serves satisfaction of the information obligations imposed on the data controller under the GDPR, i.e. Regulation (EU) 2016/679 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 CONTROLLER
The controller of personal data is Primotly sp. z o.o. with its registered office in Warsaw (01-194), ul. Młynarska 8/12, entered in the register of entrepreneurs of the National Court Register (KRS) under number KRS: 0000636383, Tax Identification Number NIP: 5223071494, National Business Registry number REGON: 36540263200000, share capital in the amount of PLN 5,000 (hereinafter referred to as “Primotly”).
Contact details of the data controller: Bernhard Huber – bernhard.huber@primotly.com
DATA PROCESSING METHOD
The scope, purposes and legal grounds for the processing of personal data are presented in the table below.
| Purpose | Scope of data | Legal ground | Processing period |
|---|---|---|---|
| Phone calls | Phone number, other personal data voluntarily provided | Art. 6(1)(f) GDPR (legitimate interest) | Until a call ends or objection |
| Correspondence (e-mail) | E-mail, name, organization, other provided data | Art. 6(1)(f) GDPR (legitimate interest) | Until correspondence ends or objection |
| Contact form | E-mail, name, organization, other provided data | Art. 6(1)(f) GDPR (legitimate interest) | Until correspondence ends or objection |
| Website access | IP address | Art. 6(1)(b) GDPR (performance of agreement) | Until lapse of limitation of claims |
| Marketing | E-mail address | Art. 6(1)(f) GDPR (legitimate interest) | Until data cease to be useful or objection |
| Newsletter | E-mail address | Art. 6.1.(b) GDPR (performance of agreement) | Until lapse of limitation of claims |
| Traffic analysis | IP address, Cookie files | Art. 6(1)(a) GDPR (consent) | Until data cease to be useful or consent withdrawal |
| Claims protection | E-mail, name, other provided data | Art. 6(1)(f) GDPR (legitimate interest) | Until lapse of limitation period |
Primotly does not transfer personal data to third countries (beyond the EEA).
Primotly does not process personal data for automated decision-making, including profiling.
RECIPIENTS OF DATA
Primotly may entrust data to third parties for performance of activities, such as: hosting providers, e-mail operators, technical support, e-mail marketing systems, law firms, and accounting firms. Data may also be disclosed to competent state bodies upon request. Each entity guarantees an adequate level of security.
RIGHTS OF DATA SUBJECT
Each data subject has the right to:
- (a) delete the collected personal data
- (b) restrict the processing of data
- (c) portability of data (including receiving in a structured form)
- (d) access and rectify personal data
- (e) object to processing
- (f) withdraw consent at any time
- (g) lodge a complaint to the supervisory authority (President of the Personal Data Protection Office)
OTHER DATA
Primotly may store http enquiries (web server logs) for administration and statistical purposes (traffic, errors). These logs do not enable identification of a natural person and are accessible only to authorized administrators.
SECURITY
Primotly applies technological and organizational means (e.g., SSL certificates, pseudonymization) to secure data against unauthorized access, loss, or destruction. However, as internet services pose threats, Primotly recommends that users also employ technical security measures (e.g., updated antivirus software).
COOKIES
Primotly uses cookies to ensure correct operation of the website and to improve the user experience.
- Session cookies: Deleted upon closing the browser.
- Permanent cookies: Remain on the device until deleted.
The user may disable or remove cookies via browser settings, although this may disable certain functions of the website.
Third-Party Cookies:
- Google Analytics – Analyzing website usage.
- Google Ads Conversion Tracking – Tracking actions after interaction.
- Facebook Pixel – Personalized advertisements.
- Linkedin Insight Tags – Displaying content based on visits.
- Hot Jar – Analyzing behavioral patterns.
- Matomo – Analyzing visitor information.
FINAL PROVISIONS
This Privacy Policy comes into effect on 1 March 2022.