PRIVACY POLICY

1. Preliminary provisions

• The Data Controller of your personal data, within the meaning of the provisions of the law on the protection of personal data, is PROMLIFT Sp. z o.o. with its registered office in Bydgoszcz (85-033) at Plac Kościeleckich 3, entered into the Register of Entrepreneurs kept by the District Court in Bydgoszcz, under KRS number 0000541254, NIP: 9532646546, (hereinafter referred to as the: "PROMLIFT"). This means that we are responsible for the use of your data in a safe manner and in accordance with applicable regulations, in particular with the provisions of 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) (Journal of Laws UE L 119, p. 1), hereinafter referred to as "GDPR".
• This document (hereinafter referred to as the: "Privacy Policy") is information on the rules for the processing and protection of personal data collected by PROMLIFT from you in connection with the purchase of PROMLIFT products, use of PROMLIFT services (including provided by electronic means), inquiries addressed to PROMLIFT, tendering process, participation in events organized by PROMLIFT, participation in the recruitment of PROMLIFT employees, subscription to the Newsletter or other information channels about PROMLIFT products and services, exchange of correspondence, etc., in particular in connection with the use of our website.
• The Privacy Policy is informative, which means that it is not a source of obligations for persons whose personal data are processed in accordance with its provisions, and one of its main functions is to fulfill the information obligation referred to in Art. 13 GDPR.

2. For what purpose and on what basis we process your personal data

• Personal data obtained from you by PROMLIFT are processed for the following purposes, depending on the situation in which the data was provided:
1. to conclude and perform the agreement concluded with PROMLIFT (regardless of the form of its conclusion: in writing or by using our services provided by electronic means via the website) – to the extent necessary to conclude, shape the content, change, terminate and correctly perform the agreement;
2. to fulfill legal obligations incumbent on PROMLIFT, e.g. issuing and storing invoices and accounting documents, responding to complaints, fulfilling obligations under the warranty for product defects, ensuring the safety of services provided;
3. to establish, defend and pursue claims;
4. for direct marketing of PROMLIFT products and services;
5. to create reports, analyses and statistics for PROMLIFT's internal needs, including in particular reporting, marketing research, advertising targeting, remarketing, service development planning, development work in IT systems, creating statistical models; evaluation of the functioning of the PROMLIFT website, including subpage viewing statistics;
6. if you consent to PROMLIFT sending you commercial information by electronic means, your personal data will also be processed by us in order to provide you with information on our services, offer and events organized by us, as well as information on products and services of entities cooperating with us (with our knowledge and explicit consent).
• Personal data is not used for purposes other than those specified in the Privacy Policy, unless PROMLIFT obtains your consent to the processing of data for other purposes, or another way of using this information is required or permitted by law.
• The processing of your personal data is necessary:
1. to perform the agreement concluded with you or to take action at your request before concluding the agreement – the legal basis for the processing of your personal data by PROMLIFT is the agreement;
2. to fulfill the legal obligation incumbent on us – the legal basis is this legal obligation;
3. for the purposes resulting from legitimate interests pursued by PROMLIFT, i.e. for the purposes of direct marketing of our products and services, preventing fraud or pursuing and defending claims – the legal basis is the legitimate interest of PROMLIFT.
• If our use of your data is not necessary for the performance of the agreement, the fulfillment of a legal obligation or does not constitute our legitimate interest, we may ask for your consent to certain ways of using your data. Consent may be granted by ticking a checkbox when browsing the website, may consist in selecting technical settings for the use of information society services, or in any other statement or behaviour which, in a given context, clearly indicates that you have accepted the proposed processing of personal data. You can withdraw your consent at any time (this will not affect the lawfulness of the use of your data before the withdrawal of such consent).
• Providing your personal data is not obligatory, however failure to provide data will result in PROMLIFT not being able to perform the activities for which the data is required.
• Based on your personal data, PROMLIFT will not make automated decisions about you, including decisions resulting from profiling.

3. Your rights

• Each person whose personal data is processed by PROMLIFT has the right to access their personal data and to immediately correct incorrect data. Taking into account the purposes of processing, the data subject has the right to request supplementing incomplete personal data, including by providing an additional statement.
• If you consent to the processing of data, in particular for marketing purposes (including sending commercial information by electronic means), your consent may be withdrawn at any time. A user receiving certain information or services, such as an electronic newsletter (the so-called Newsletter), may unsubscribe at any time by following the instructions in any such document sent.
• The person providing their personal data to PROMLIFT has the right to request PROMLIFT to delete their personal data immediately, and PROMLIFT is obliged to delete personal data without undue delay if one of the following circumstances occurs:
1. personal data are no longer necessary for the purposes for which they were collected;
2. the data subject has withdrawn the consent on which the processing is based and there is no other legal basis for the processing;
3. the data subject objects to the processing;
4. personal data has been unlawfully processed;
5. personal data must be removed in order to comply with the legal obligation provided for in the EU law or the law of the Member State to which PROMLIFT is subject.
o Persons providing their personal data to PROMLIFT have the right to request the restriction of the processing of personal data if:
4. the data subject questions the correctness of personal data – for a period allowing PROMLIFT to verify the correctness of such data;
5. the processing is unlawful and the data subject opposes the deletion of personal data and requests the restriction of their use instead;
6. PROMLIFT no longer needs personal data for the purposes of processing, but they are needed by the data subject to establish, pursue or defend claims;
7. the data subject has objected to the processing – until it is determined whether the legitimate grounds on the part of PROMLIFT prevail over the grounds for objection of the data subject.
• If the processing of personal data by PROMLIFT takes place in an automated manner on the basis of consent or agreement, the data subject has the right to receive, in a structured, commonly used and machine-readable format, personal data concerning him/her, provided by PROMLIFT, and has the right to send this personal data to another data controller. The data subject has the right to request that personal data be sent by PROMLIFT directly to another data controller, if technically possible.
• In order to exercise the rights referred to above, you can contact PROMLIFT in the manner indicated in point 8 below.
• PROMLIFT will inform each recipient to whom personal data has been disclosed about the rectification or deletion of personal data or limitation of processing, which it has made at your request, unless it turns out to be impossible or will require a disproportionate effort.
• In connection with the processing of your personal data by PROMLIFT, you have the right to lodge a complaint with the supervisory body, i.e. the President of the Personal Data Protection Office.

4. To whom we provide your personal data?

• We provide your data to:
 entities processing data on our behalf, participating in the performance of our activities:
1. to entities servicing IT systems and computer hardware that we use;
2. entities managing our real estate
3. our business partners, advertising agencies and other intermediaries in the sale of our products and services or the organization of marketing campaigns;
4. subcontractors supporting us, e.g. in the performance of our services, transport of ordered products, product service, handling correspondence or in the customer service process;
5. entities providing us with advisory, consulting, auditing services, legal, tax and accounting assistance, as well as research agencies acting on our behalf;
 other data controllers processing data on their own behalf:
1. entities conducting postal or courier activities;
2. entities purchasing debts or dealing with their collection – if you fail to pay our invoices on time;
3. entities cooperating with us in handling accounting, tax and legal matters – to the extent that they will become the data controller.
 Currently, PROMLIFT does not plan to transfer your data outside the EEA (including the European Union, Norway, Liechtenstein and Iceland). But it may turn out that during the term of the agreement we will decide to transfer data outside the EEA – only to the extent permitted by law.
 PROMLIFT may disclose personal data at the request of authorities or law enforcement authorities, or when required by applicable laws, court judgments or other state regulations. The necessity to provide personal data may also be caused by conducting data privacy or security audits and/or when handling complaints or taking actions related to the security risk. PROMLIFT does not sell personal data to third parties, and does not entrust the processing of personal data provided by users to third parties, which information could be used by such third parties for their marketing purposes.

5. How long do we store personal data?

• Your personal data will be stored for no longer than it is necessary, i.e. depending on the purpose of their processing:
 conclusion and performance of the agreement between you and PROMLIFT – for the duration of the agreement and settlements after its completion, including for the duration of the warranty period for defects or quality guarantee provided in the agreement;
 fulfillment of the legal obligation incumbent on PROMLIFT:
1. for the duration of the obligations;
2. for the period in which the regulations require us to store data (e.g. tax legislation); or
3. for the period in which we can suffer the legal consequences of failure to perform the obligation, e.g. receive a financial penalty from state offices;
• purposes resulting from legitimate interests pursued by PROMLIFT:
1. direct marketing of our products and services – for the duration of the agreement, and then for the period of providing warranty and/or post-warranty service;
2. fraud prevention – for the duration of proceedings before competent authorities;
3. exercise or defence of legal claims – for the period in which the claims are time-barred.
• If we process your personal data on the basis of your consent for specific ways of using the data, your data will be processed during the period indicated when obtaining consent, and in the absence of such indication – until you withdraw your consent.

6. Automatic data collection

COOKIES. operating data. Google Tools
• When using the PROMLIFT website, user data is also collected automatically. These data can be collected in the system logs of the website, through the so-called cookies. Cookies are small text information in the form of text files, sent by the server and saved on the side of the person visiting the website (e.g. on the hard drive of a computer, laptop or smartphone's memory card).
• By saving cookies on the website user's device (computer, smartphone, tablet, etc.) PROMLIFT may, among others:
1. Adapt the functioning of the website to your needs.
2. Eliminate the need to log in each time you visit the website (in the case of areas for registered users/customers).
3. Remember your settings from session to session.
4. Increase the speed of operation and the security of the website.
5. Personalize the website according to your needs and enable users to find the information they need faster.
6. Constantly improve the website with its users in mind.
7. Increase the effectiveness of marketing activities.
• Cookies do not contain data identifying the user, it is impossible to determine anyone's identity on their basis. These files are in no way harmful to the end user's device and do not change its settings or the settings of the software installed on it. Reading the content of these files is possible only by the server that created them.
• When the user uses our website, PROMLIFT uses three types of cookies: session, permanent and marketing. Session files are temporary files that are stored in the user's device memory until logging out of the website, leaving the website or closing the browser. Permanent files are stored in the memory of the user's device for the time specified in the parameters of these files or until they are deleted by the user. Marketing files are "cookies" saved by other external scripts used on our website. They are mainly used by us for remarketing purposes (see sections 6.11.- 6.14 below).
• As a standard, most internet browsers available on the market accept saving cookies by default. The user can independently and at any time change the cookies settings, specifying the conditions for their storage and access to the user's device via cookies. Changes to the settings referred to in the previous sentence can be made by the user via the web browser settings or via the service configuration. These settings can be changed in particular in such a way as to block the automatic handling of cookies in the web browser settings or to inform about each posting of cookies on the user's device. Detailed information about the possibilities and methods of handling cookies is available in the software (web browser) settings.
• The user may at any time delete cookies using the functions available in the web browser he/she uses.
• Restricting the use of cookies may affect some of the functionalities available on the PROMLIFT website.
• Detailed information on changing cookies settings and their deletion in the most popular web browsers are available in the help section of the web browser.
• PROMLIFT also processes anonymised operating data related to the use of its website (so-called logs – IP address, domain) to generate statistics helpful in website administration. From the moment the user connects to the website, information about the number (including IP) and type of the end user's device from which the user connects to the website appears in the website system logs. These data are aggregate and anonymous, i.e. they do not contain features that identify website visitors. Logs are not disclosed to third parties.
• PROMLIFT can use the Google Analytics service that uses cookies to collect anonymous information about the PROMLIFT websites you visit. Detailed rules regarding the privacy policy of Google Analytics can be found at: http://www.google.com/intl/pl/analytics/privacyoverview.html.
• Additionally, PROMLIFT can use Google AdWords and Google Analytics remarketing codes of display advertisers. These codes are used to create remarketing lists in order to match personalized ads to users who visited our website, and then display them on the Google AdWords advertising network, Google search engine, as well as on websites of entities that are members of the Google partner network.
• Our website, using the "similar audiences" function, works within the Google AdWords system and checks how browsing websites on the display network looked in the last thirty days and subjects this information to a contextual targeting mechanism to determine the profile of remarketing audiences. On its basis, Google AdWords finds a group of new users who have similar browsing patterns to those on the PROMLIFT remarketing list. This list is never created based on your browsing history on topics considered sensitive, such as those related to race, religion, sexual orientation or health.
• By using the remarketing tools and the "similar audiences" function, our website does not collect your personal data via cookies, but only the browsing history, and thus – the user remains anonymous.
• The user has the option to opt out of collecting remarketing codes and display advertiser codes through Google AdWords and Google Analytics, as well as displaying non-standard ads on the Google advertising network in the manner specified in point 6.5 above.
• The PROMLIFT website may contain functions that allow content to be shared using third party social networking applications, such as the "Like" button on Facebook or a widget on Twitter. All of these social networking applications can collect and use data on user activity on the PROMLIFT website. Any personal data provided by users through such social networking applications may be collected and used by other users of the above social networking applications, and interactions via those applications are subject to the privacy policy of the companies that are the application providers. We have no influence and we are not responsible for the above companies and their use of user data.

7. How we protect personal data?

• PROMLIFT declares that it makes every effort to ensure a high level of security of the personal data it processes. Any events affecting data security, including the suspicion of sharing files containing viruses and other files of a similar nature or other than destructive mechanisms files, should be reported to the e-mail address indicated in point 8 below.
• PROMLIFT uses technical and organizational measures to ensure protection of personal data being processed, appropriate to the threats and categories of data to be protected, and in particular, protects data against their disclosure to unauthorized persons, take-over by an unauthorized person, processing in violation of applicable law, as well as alteration, loss, damage or destruction. In addition, PROMLIFT takes special care that personal information is:
• correct and lawfully processed,
• obtained only for specific purposes and not further processed in a manner inconsistent with these purposes,
• adequate, relevant and not redundant,
• accurate and up-to-date,
• not kept longer than necessary,
• processed in accordance with the rights of persons (whom they relate to), including the right to restrict sharing,
• safely stored,
• not transferred without adequate protection.
• Personal data is stored in a database in which technical and organizational measures have been applied to ensure protection of the processed data in accordance with the requirements set out by generally applicable law on the protection of personal data. Only persons authorized by the data controller have access to the database.
• PROMLIFT applies appropriate policy and procedures to protect personal data against unauthorized loss, incorrect application, alteration or destruction. We make every effort to ensure that access to your personal data is limited to those who need to know this information. Persons who have access to the data are obliged to keep it confidential. In addition, one of the principles of the PROMLIFT policy in this regard is to store personal information only for the period in which it is necessary to process the user's request or until the user requests the deletion of such information.

8. Contact

In matters related to the processing of personal data, you can contact PROMLIFT, as its data controller, at: 85-033 Bydgoszcz, Plac Kościeleckich 3, or by writing to: rodo@projprzem.com.

9. Changes to the Privacy Policy

PROMLIFT may introduce changes to this document that reflect the current Privacy Policy. In case of modification, the date of the last update indicated below also changes.


Date of the last update of the Privacy Policy: 24-03-2020