Privacy Policy

Privacy Policy

This Privacy Policy contains information on how we protect the privacy of users and how personal data is processed on the website www.sodecor.pl.

I. Data Controller / Data Protection Officer / Supervisory Authority

Data Controller

This Privacy Policy applies to the processing of data by:

MARBET Spółka z o.o.
ul. Chochołowska 28
43-346 Bielsko-Biała, Poland
tel. +48 33 81 27 100

Data Protection Officer

If the information contained in this Privacy Policy is insufficient or unclear, please contact our Data Protection Officer:

Grzegorz Krawiec
MARBET Spółka z o.o.
ul. Chochołowska 28
43-346 Bielsko-Biała, Poland
e-mail: rodo@marbet.com.pl
tel. +48 790 215 608

Competent Supervisory Authority

President of the Personal Data Protection Office
ul. Stawki 2
00-193 Warsaw, Poland
website: www.uodo.gov.pl

II. Definitions

The definitions result from Regulation (EU) 2016/679 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 (hereinafter referred to as the “General Data Protection Regulation” or “GDPR”).

III. General Principles / Information

1. Scope of Personal Data Processing

We collect and use users’ personal data only to the extent necessary to provide and deliver our services and to display our website.
Personal data may be processed for other purposes only:

  • with the user’s consent,

  • if the processing is necessary for the performance of a contract, or

  • for the purposes of the legitimate interests pursued, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject requiring the protection of personal data.

Exceptions apply where data processing is permitted by law.

2. Legal Basis for Processing

Where personal data is processed based on the consent of the data subject, the legal basis is Article 6(1)(a) GDPR.
Where personal data is processed for the performance of a contract to which the data subject is a party, the legal basis is Article 6(1)(b) GDPR. This also applies to processing necessary to take steps prior to entering into a contract.
Where personal data is processed to comply with a legal obligation, the legal basis is Article 6(1)(c) GDPR.
Processing for the purposes of legitimate interests pursued by the Data Controller or a third party is based on Article 6(1)(f) GDPR, provided that the interests, fundamental rights, and freedoms of the data subject do not override those interests.

3. Consent / Right to Withdraw Consent

Consent pursuant to Article 6(1)(a) GDPR is generally obtained electronically.
Consent is given by selecting the appropriate checkbox, which serves as documentation of consent.
Consent may be withdrawn at any time with effect for the future. Withdrawal should be communicated using the contact details provided in Section I for the Data Controller or the Data Protection Officer.

4. Recipients of Personal Data

For the operation of our website, we partially use external service providers who act on our behalf and in accordance with our instructions (data processors).
These service providers may receive or have access to personal data and are therefore considered third parties or recipients within the meaning of the GDPR.

We ensure that our service providers provide appropriate guarantees, implement suitable technical and organizational measures, process data in compliance with the GDPR, and protect the rights of data subjects (cf. Article 28 GDPR).

If personal data is transferred to third parties and/or recipients other than for commissioned processing, we ensure that this is done solely in compliance with GDPR requirements (e.g. Article 6(4) GDPR) and only where an appropriate legal basis exists.

5. Processing of Data in Third Countries

Personal data is generally processed within the European Union or the European Economic Area (“EEA”).
Only in exceptional cases (e.g. when using services from web analytics providers) may data be transferred to so-called third countries.

Third countries are countries outside the EU and/or the EEA where an adequate level of data protection in accordance with EU standards cannot be assumed.

If transferred information includes personal data, we ensure prior to such transfer that an adequate level of data protection is guaranteed in the third country or by the recipient in the third country. This may result from an EU adequacy decision or be ensured through EU standard contractual clauses.

6. Data Deletion and Storage Period

Personal data of the data subject is deleted or blocked once the purpose of processing no longer applies.
Storage without a processing purpose occurs only if required by European or national legislation (e.g. to comply with statutory retention obligations and/or in the case of legitimate interests, such as limitation periods for legal defense).

Data is also blocked or deleted once the storage period specified by the applicable regulations expires, unless further storage is required for the conclusion of a contract or other purposes.

IV. Display of the Website

1. Purpose and Legal Basis

When accessing our website, the browser installed on your device automatically sends the following data to our server, which is temporarily stored (so-called “log data”):

  • browser type and version used,

  • operating system,

  • internet service provider,

  • IP address (without personal identification),

  • date and time of access,

  • websites from which the user’s system accesses our website,

  • websites accessed by the user’s system via our website,

  • user navigation within the website.

The legal basis for processing the IP address and the above data is Article 6(1)(f) GDPR. Our legitimate interest arises from the processing purposes listed above.
If the website display serves to prepare a contract, the legal basis is Article 6(1)(b) GDPR.

2. Data Recipients / Categories of Recipients

The data is not transferred to third parties.

3. Data Deletion and Storage Period

The IP address is stored for 30 days and then automatically deleted.
With regard to data such as browser type/version, operating system used, referring URL, host name of the accessing computer (IP address), and time of the server request, further information on processing can be found in Section VI.2.

4. Right to Object and Deletion

The collection of log data for the purpose of providing the website and its storage in log files within the specified scope is essential for the operation of the website.
Users therefore have no right to object.

Different rules apply where log data is processed for analytical purposes, as described in Section VIII, depending on the web analytics tool used or the type of data analysis (personalized / anonymized / pseudonymized).

V. Use of Cookies

1. Purpose and legal basis

Cookies are used on our website. Cookies are text files that are stored on your device (laptop, tablet, smartphone, etc.) when you visit our websites. A cookie stores information related to the specific device you use. Such a cookie contains a distinctive string of characters that enables the browser to be uniquely identified when you revisit the website. This does not mean, however, that we are directly informed of your identity.

The use of cookies serves the following purposes, depending on the cookie category:

Necessary. The purpose of these cookies is to facilitate the use of the website. Some functions of our website are not available without the use of cookies (e.g. to display our website / the functions you wish to use, to remember your registration in the login area, etc.). To use these functions, the browser must be recognized again even after you navigate to another page. User data is not used to create user profiles. The cookies used involve, in particular, the processing of the following categories of personal data: user input (to remember entries across multiple subpages), authentication data (to identify the user after registration in order to provide access to authorized content during subsequent visits), security-relevant events (e.g. detection of multiple failed login attempts), and data for playback of multimedia content.

Preferences. These cookies allow us to take into account your actual or presumed preferences regarding convenient use of our website (e.g. to display our websites in the appropriate language). The cookies used involve, in particular, the processing of categories of personal data related to user interface customization settings that are not linked to a permanent identifier (e.g. the active selection of language or specific display of search queries).

Statistical. These cookies enable us to compile anonymous statistics on the use of our services in order to adapt them to your needs (e.g. to determine how we can further tailor our websites to users’ habits). The cookies used involve, in particular, the processing of the following categories of personal data related to pseudonymized user profiles with information on the use of our website, including: browser type/version, operating system used, referrer URL, host name of the accessing computer, IP address, server request time, individual user identifier, and events triggered on the website. We link the user identifier with other data provided by you (e.g. name, e-mail address, etc.) only with your explicit consent. Based solely on the user identifier, we cannot draw any conclusions about your identity.

Advertising. These cookies enable us to display advertising content that is relevant to you, based on an analysis of your usage pattern. We may also track usage patterns across different websites, browsers, or end devices using the user identifier (a unique identifier). The cookies used involve, in particular, the processing of the following categories of personal data related to pseudonymized user profiles with information on the use of our website, including: IP address, individual user identifier, potential interest in products, and events triggered on the website. We link the user identifier with other data provided by you (e.g. name, e-mail address, etc.) only with your explicit consent. Based solely on the user identifier, we cannot draw any conclusions about your identity. Where applicable, we share the user identifier and related usage profiles with third parties via advertising network providers.

The legal basis for the use of technically necessary cookies is Article 6(1)(b) GDPR and may also be Article 6(1)(f) GDPR, meaning that we process your data on the basis of our legitimate interest, which is to enable you to use our website without disruption.

The legal basis for the use of cookies for preference settings, statistical purposes, and marketing purposes is your consent pursuant to Article 6(1)(a) GDPR.

You may withdraw/adjust your consent at any time with effect for the future, without affecting the lawfulness of processing based on consent before its withdrawal. By removing the relevant checkmarks, you can easily withdraw your consent for the respective processing purposes.

2. Data recipients / categories of recipients

With regard to processing usage data by means of cookies, we use specialized service providers, in particular from the online marketing sector. These service providers process your data on our behalf as processors and are, in each case, bound by contractual obligations in accordance with Article 28 GDPR. If you have consented to processing for marketing purposes, we may share your user identifier and related user profiles with third parties via advertising network providers.

3. Data deletion and storage period

Cookies are stored on the user’s end device (mobile device / computer) and transmitted from there to our websites. A distinction is made between so-called persistent cookies and session cookies. Session cookies are stored for the duration of a browser session and are deleted when the browser is closed. Persistent cookies are not deleted when a browser session ends, or they are stored on the user’s end device for a longer period of time.

4. Right to object and deletion

When users access our website, they are informed via an information banner about the use of cookies and about this data protection notice. The banner is also used to obtain the user’s consent to the processing of personal data within this scope.

Users have full control over the use and storage of cookies. By changing the settings of your web browser, you can generally disable or restrict the transmission of cookies. Cookies that have already been stored can be deleted at any time. This can also be done automatically. If cookies are disabled for our website, it may not be possible to use all functions of the website to their full extent.

VI. Web Analytics / Social Media Plugins

In order to optimize our websites and adapt them to the changing habits and technical conditions of our users, we use tools for so-called web analytics. We analyze which elements are visited by users, whether the information they seek is easy to find, etc. On our website and within our online offerings, we conduct analyses or use the web analytics tools listed below.

We have also integrated social media screen buttons (“plugins”) on our website. These plugins provide various functions, the subject and scope of which are determined by the administrators of the respective social media platforms. Please note that the IP address of the browser session may be linked to your own profile on a given social media platform if you are logged in at that time. A visit to our website may also be linked to your social media profile if the platform recognizes you via a previously set and still existing social media cookie stored on your device.

1. Analysis of log data

Log data is used for analytical purposes exclusively in an anonymous manner. In particular, it is not linked to personal data of the user and/or an IP address or a cookie. Such analysis of log data is not subject to GDPR data protection provisions.

2. Google Analytics

For the purpose of adapting the content of our website to users’ preferences and continuously optimizing it (i.e. statistical and advertising cookies), and based on Article 6(1)(a) GDPR, we use Google Analytics, a web analytics service provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA (“Google”).

In this context, pseudonymized user profiles are created and cookies are used. The cookie generates the following information regarding the use of this website:

  • browser type/version,

  • operating system used,

  • referrer URL (previously visited page),

  • host name of the accessing computer (IP address),

  • time of the server request.

This information is used to analyze the use of our website, compile reports on website activity, and provide other services related to website and internet usage for the purposes of market research and adapting website content to users’ preferences. IP addresses are anonymized so that they cannot be assigned (so-called IP masking).

You can manage your consent to the installation of cookies via your settings; however, please note that if consent is not granted or is withdrawn, it may not be possible to use all functionalities of this website to their full extent.

You may also prevent the collection and processing of data generated by cookies and related to your use of the website (including your IP address) by Google by downloading and installing the browser add-on available at:
https://tools.google.com/dlpage/gaoptout?hl=pl

Further information on data protection in relation to Google Analytics can be found on the Google Analytics website.

3. Google Remarketing

We use remarketing tools provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA; “Google”). These tools enable us to target advertising materials to users who visit partner websites within the Google network and who have previously visited our website and shown interest in our offer.

Advertisements are displayed through the use of cookies. Cookies enable the analysis of user behavior during website visits and the subsequent use of this information to recommend specific products and display tailored advertisements.

Users who do not wish to receive personalized advertisements may deactivate the use of cookies by Google by visiting:
https://www.google.pl/settings/ads/onweb

Using our services constitutes consent to the processing of user data collected by Google in the manner and for the purposes described above. Please note that Google applies its own data protection guidelines. We are not responsible for such guidelines or procedures.

4. Facebook Pixel

The Facebook Pixel enables us to track actions on our website and, based on this, display product information tailored to your needs (i.e. advertising cookies).

Information on how this works can be found on Facebook’s website:
https://www.facebook.com/about/privacy

The Pixel operates using pseudonymization, meaning that it does not create any direct connection to any personal information about you.

Opt-out options. You can adjust your consent regarding the use of the Facebook Pixel by:

When cookie blocking is removed, data will again be collected by the Facebook Pixel.

VII. Contact Form and E-mail Contact

Our website contains a contact form that can be used to contact us electronically. If a user uses this option, the data entered in the input fields is transmitted to us and stored.

Alternatively, contact is possible via the e-mail address provided on our website. In this case, the user’s personal data transmitted with the e-mail will be stored. Data is never passed on to third parties, except in cases where we must involve third parties to process the inquiry.

1. Purpose and legal basis

Data is processed solely for the purpose of handling the inquiry or meeting the user’s needs. Other data collected during transmission is used to prevent misuse of the contact form and to ensure the security of our technical information systems.

The legal basis is Article 6(1)(f) GDPR or, where applicable, Article 6(1)(b) GDPR. Our legitimate interest arises from the purpose of responding to your inquiries and resolving potential issues.

2. Data recipients / categories of recipients

In exceptional cases, your data may be processed on our behalf by subcontractors. These companies are selected with the utmost care, audited, and contractually obligated to comply with the provisions of Article 28 GDPR.

3. Data deletion and storage period

All personal data obtained from you via inquiries through this website or by e-mail is stored until the request has been fully processed and is deleted or anonymized no later than upon its closure.

If data subject rights under the GDPR are exercised, personal data will be stored for three (3) years after our final response in order to demonstrate that we have provided comprehensive information and complied with legal requirements.

4. Right to object and deletion

Users may terminate communication with us at any time and/or withdraw their inquiry and object to the further use of their data. In such cases, communication cannot be continued, and all personal data stored in the course of contact will be deleted.

VIII. Rights of Data Subjects

Under the GDPR, users are entitled in particular to the following rights:

1. Right of access (Article 15 GDPR)

You have the right to request information as to whether we process your personal data. If personal data is processed, you have the right to information about:

  • the purposes of processing;

  • the categories of personal data processed;

  • the recipients or categories of recipients to whom the data has been or will be disclosed, in particular recipients in third countries;

  • where possible, the planned storage period or the criteria used to determine that period;

  • the right to rectification, erasure, restriction of processing, and the right to object;

  • the right to lodge a complaint with a supervisory authority;

  • the source of the data, if the data was not collected directly from you.

You also have the right to be informed whether your personal data is subject to automated decision-making within the meaning of Article 22 GDPR and, if so, about the logic involved and the significance and envisaged consequences of such processing.

Where personal data is transferred to a third country, you have the right to be informed of the appropriate safeguards pursuant to Articles 45 and 46 GDPR.

You have the right to obtain a copy of your personal data. The first copy is provided free of charge; reasonable fees may be charged for further copies.

2. Right to rectification (Article 16 GDPR)

You have the right to request the immediate rectification of inaccurate personal data concerning you. Taking into account the purposes of processing, you also have the right to request completion of incomplete personal data.

3. Right to erasure (“right to be forgotten”) (Article 17 GDPR)

You have the right to request the immediate erasure of your personal data if one of the following grounds applies:

  • the personal data is no longer necessary for the purposes for which it was collected;

  • you withdraw consent and there is no other legal basis for processing;

  • you object to processing pursuant to Article 21 GDPR and there are no overriding legitimate grounds;

  • the personal data has been unlawfully processed;

  • erasure is required to comply with a legal obligation;

  • the personal data was collected in relation to the offer of information society services pursuant to Article 8(1) GDPR.

Where we have made personal data public and are obliged to erase it, we shall take reasonable steps, taking into account available technology and implementation costs, to inform other controllers processing the data of your request for erasure.

4. Right to restriction of processing (Article 18 GDPR)

You have the right to request restriction of processing where:

  • the accuracy of the data is contested;

  • processing is unlawful and you request restriction instead of erasure;

  • the data is no longer needed by us but is required for legal claims;

  • you have objected pursuant to Article 21(1) GDPR pending verification.

5. Right to data portability (Article 20 GDPR)

You have the right to receive your personal data in a structured, commonly used, and machine-readable format and to transmit it to another controller without hindrance, provided that:

  • processing is based on consent or a contract, and

  • processing is carried out by automated means.

You may also request direct transmission to another controller where technically feasible.

6. Right to object (Article 21 GDPR)

You may object at any time, with effect for the future, to the processing of personal data based on Article 6(1)(e) or (f) GDPR. In such cases, processing shall cease unless compelling legitimate grounds exist or processing is required for legal claims.

You may object at any time to processing for direct marketing purposes, including profiling related to such marketing. In such cases, processing for direct marketing shall cease.

7. Right to lodge a complaint with a supervisory authority

You have the right to lodge a complaint with the competent supervisory authority responsible for data protection. In Poland, this authority is the President of the Personal Data Protection Office, as indicated in Section I.