PRIVACY AND COOKIES POLICY

Valid from 9.03.2023.

The administrator of your personal data is ŻUBROWA 10 JAN WALENCIK, ul. Żubrowa 10, 17-230 Białowieża PL, VATIN 821 141 34 99.

We process your personal data primarily for purposes related to your use of our website, such as contact and correspondence handling, analysis, statistics, marketing, etc. We process your personal data for the period necessary to fulfill the particular purpose. You have the right to access personal data, rectify it, delete or limit processing, object to processing, as well as the right to transfer data. In addition, you can submit a complaint to the President of the Office for Personal Data Protection.

Detailed information on the principles of processing your personal data can be found in the further part of the Privacy Policy. Here is a list of the issues discussed next:

  1. WHO IS THE ADMINISTRATOR OF PERSONAL DATA?
  2. WHO CAN YOU CONTACT REGARDING THE PROCESSING OF PERSONAL DATA?
  3. FOR WHAT PURPOSES DO WE PROCESS PERSONAL DATA?
  4. WHAT INFORMATION DO WE HAVE ABOUT YOU?
  5. WHAT IS „ANONYMOUS INFORMATION”?
  6. WHERE DO WE GET YOUR PERSONAL DATA FROM?
  7. IS THE DATA SAFE?
  8. HOW LONG WILL WE KEEP YOUR PERSONAL DATA?
  9. WHO ARE THE RECIPIENTS OF PERSONAL DATA?
  10. DO WE TRANSFER DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS?
  11. WHAT RIGHTS DO YOU HAVE?
  12. DO WE USE COOKIES AND WHAT EXACTLY ARE THEY?
  13. ON WHAT BASIS DO WE USE COOKIES?
  14. CAN YOU TURN COOKIES OFF?
  15. FOR WHAT PURPOSES DO WE USE OUR OWN COOKIES?
  16. WHAT THIRD PARTY COOKIES ARE USED?
  17. DO WE TRACK YOUR BEHAVIOR UNDERTAKEN WITHIN THE WEBSITE?
  18. HOW CAN YOU MANAGE YOUR PRIVACY?
  19. IS THERE ANYTHING ELSE YOU SHOULD KNOW?
  20. CAN THIS PRIVACY POLICY BE CHANGED?

             ATTACHMENT TO THE PRIVACY POLICY

In case of any doubts related to the Privacy Policy, you can contact us at any time by sending a message to info(at)zubrowa10.pl.

1. Who is the administrator of personal data?

The administrator of your personal data is ŻUBROWA 10 JAN WALENCIK, ul. Żubrowa 10, 17-230 Białowieża PL, VATIN 821 141 34 99.

This Privacy Policy applies to the website zubrowa10.pl.

With regard to social media profiles related to our website, in accordance with the case law of the Court of Justice of the European Union, the provider of the social network is a joint controller of personal data together with the controller of the respective profile. You can find details about the processing of personal data by individual social network providers here:

2. Who can you contact regarding the processing of personal data?

As part of the implementation of the personal data protection system in our organization, we have decided not to appoint a personal data protection inspector due to the fact that in our situation it is not mandatory.

In matters related to data protection and privacy in the broadest sense, you can contact us at e-mail info(at)zubrowa10.pl. In terms of social media, you can additionally contact directly the administrators of the social networking sites where we maintain our profiles.

3. For what purposes do we process personal data?

These purposes are more than one. Below is a list of them, along with a more detailed discussion. We have also assigned to each purpose the corresponding legal basis for processing:

Purpose of processing: Contact and correspondence handling.
By contacting us via e-mail or social communicators, you naturally provide your personal data contained in the correspondence. Providing data is a condition for establishing contact. In addition, the communication system saves your IP number that you used when sending the message. The communication system may be operated by an external provider. In such a situation, the use of the system is subject to the regulations and privacy policy of the external provider. Detailed information on third-party tools can be found in the section dedicated to the tools we use. The data is processed for the purpose of communication, which is our legitimate interest. After the communication is completed, the data is stored in the archive for the purpose of possible determination, investigation or defense of claims related to the conducted communication.
Legal basis: art. 6 sec. 1 lit. f GDPR.

Purpose of processing: Creating an archive.
For the needs of our activity, we may create archives: both in traditional and digital form. The archives include personal data that we have processed in connection with you, and the scope of the archives may vary depending on what data has come to us and the scope of the data justified in terms of archives. In this case, we rely on our legitimate interest in ordering and organizing personal data carriers.
Legal basis: art. 6 sec. 1 lit. f GDPR.

Purpose of processing: Social media support.
If you follow our profiles on social media or interact with the content we publish on social media, we naturally see your data that is publicly available on your social profile. We process this data only within a given social network and only for the purpose of operating a given social network, which is our legitimate interest. If you contact us via private message, you naturally provide us with your personal data contained in the content of the correspondence, in particular your image and name and surname. In this case, your data is processed in order to contact you, and the basis for processing is our legitimate interest. It may happen that we will be the party initiating contact with you via social media in order to offer cooperation, then your data will be processed in order to search for potential contractors, offer and establish cooperation, which is our legitimate interest. Messages sent to us via social media are automatically archived using the tools available on individual social media sites and are available to us until you delete them. You can view all exchanged messages with us in the private messages tab. Your use of social networking sites is subject to the regulations and privacy policies of the administrators of these websites, and these administrators provide electronic services for you, fully independently and autonomously of us.
Legal basis: art. 6 sec. 1 lit. f GDPR.

Purpose of processing: Analysis and statistics using only Anonymous Information.
We conduct analytical and statistical activities using tools provided by external suppliers. As part of the analytical tools, we only have access to Anonymous Information. We base the processing of Anonymous Information on a legitimate interest, which consists in creating, viewing and analyzing statistics related to the activity of users on the website in order to draw conclusions allowing for the subsequent optimization of our activities. From the level of tools, we can only view a set of statistics and information not assigned to specific people. Detailed information on third-party tools can be found in the section dedicated to the tools we use.
Legal basis: art. 6 sec. 1 lit. f GDPR.

Purpose of processing: Self-marketing using only Anonymous Information.
We conduct marketing activities using tools provided by external suppliers. As part of marketing tools, we only have access to Anonymous Information. We base the processing of Anonymous Information on a legitimate interest, which consists in creating marketing activities based on Anonymous Information and targeting advertisements within external systems based on Anonymous Information, for the purposes of marketing our own products and services. From the level of tools, we can only view a set of statistics and information not assigned to specific people. Detailed information on third-party tools can be found in the section dedicated to the tools we use.
Legal basis: art. 6 sec. 1 lit. f GDPR.

Purpose of processing: Providing additional functions using only Anonymous Information.
We may embed video or audio players, social widgets or other tools provided by third parties on our pages. All of these tools process Anonymous Information. We base the processing of Anonymous Information on a legitimate interest, which in this case consists in ensuring the possibility of using additional functions on the website. We do not have access to other information from the tools level, moreover, we do not need this information for anything – Anonymous Information is processed only so that additional functions can work. Detailed information on third-party tools can be found in the section dedicated to the tools we use.
Legal basis: art. 6 sec. 1 lit. f GDPR.

Purpose of processing: Fulfillment of obligations related to the protection of personal data.
As the administrator of personal data, we are obliged to fulfill the obligations related to the protection of personal data. Therefore, we may process your personal data as long as it is necessary to perform these duties (e.g. in the case of processing your request regarding your personal data). The scope of data depends on what data we need to fulfill the obligation and prove compliance with the GDPR. In addition, in this case, we also rely on our legitimate interest, which consists in securing the data necessary to demonstrate accountability.
Legal basis: art. 6 sec. 1 lit. c GDPR, art. 6 sec. 1 lit. f GDPR.

4. What information do we have about you?

We have described the scope of the processed data in relation to each processing purpose. Information in this regard can be found above, in point 3 of the Privacy Policy. The data includes information such as:

  • first name and last name,
  • e-mail address,
  • phone number,
  • IP address,
  • information visible in social media profiles,
  • information contained in correspondence,
  • Anonymous Information.

5. What is „Anonymous Information”?

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

  • information about the operating system and web browser,
  • viewed subpages,
  • time spent on the website,
  • transitions between individual subpages,
  • clicks on individual links,
  • mouse movements,
  • page scrolling,
  • the source from which you come to the page,
  • the age range you are in,
  • your gender
  • your approximate location limited to the city.
  • your interests or other preferences based on your online activity,
  • video recordings of your sessions on our websites,
  • heatmaps illustrating your behavior on our sites.


This information is referred to in this Privacy Policy as „Anonymous Information”.

Anonymous Information itself does not, in our opinion, have the nature of personal data, because it does not allow us to identify you and we do not compare it with typical personal data that we collect about you. Nevertheless, taking into account the strict jurisprudence of the Court of Justice of the European Union and the divided opinion among lawyers, as a precaution, in the event that Anonymous Information is assigned the nature of personal data, we have also included in the Privacy Policy detailed explanations regarding the processing of this information.

We are unable to provide you with access to Anonymous Information about you as we cannot assign any Anonymous Information to any specific user. From the level of tools collecting Anonymous Information, we can only view a set of statistics and information not assigned to specific persons.

The processing of Anonymous Information allows us to provide you with the ability to use the functionalities available on the website. In addition, Anonymous Information is used for analytical, statistical and marketing purposes, such as setting and targeting advertisements.

Anonymous Information is also processed by tool providers on the terms resulting from their regulations and privacy policies. They may be used by these providers to provide and improve services, manage them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, as well as personalize the content and advertising displayed on individual services, sites and applications. Detailed information related to this can be found in the section dedicated to the tools we use.

6. Where do we get your personal data from?

In most cases, you provide it to us yourself. For example, this is the case when you contact us via e-mail or use the functionalities available on external websites (e.g. social networks).

In addition, some information about you may be automatically collected by the tools we use. Detailed information on third-party tools can be found in the section dedicated to the tools we use.

7. Is the data safe?

We care about the security of your personal data. We have analyzed the risks associated with individual processing of your data, and then implemented appropriate security and personal data protection measures. We monitor the condition of the technical infrastructure on an ongoing basis, we train the staff, we look at the procedures used, and we introduce the necessary improvements.

8. How long will we keep your personal data?

We process your personal data for as long as it is justified within the given purpose of personal data processing, therefore the processing periods vary depending on the purpose. Remember that the end of the processing of your data for one purpose does not necessarily lead to the complete deletion or destruction of your personal data, because the same set of data may be processed for another purpose, for the period indicated for it. Complete deletion or destruction of data takes place when we complete the implementation of all purposes and in other cases indicated in the GDPR.

Below you will find a description of the processing periods:

  • Contact and correspondence handling – data related to correspondence handling will be processed for the duration of the contact between us;
  • Archive – data related to the archive will be processed until the information contained in the archive is no longer useful;
  • Social media – basically, I have no influence on the period of storage of your personal data in social media. They are available on Facebook, Instagram or YouTube on the terms resulting from the regulations and privacy policy of these websites. We are not able to delete your data from Facebook, Instagram or YouTube – only you can do it;
  • Analysis and statistics – data related to analytics and statistics will be processed until they become useless or you successfully raise an objection;
  • Own marketing – data related to own marketing will be processed until it becomes useless or you successfully raise an objection;
  • Additional tools – data related to additional tools will be processed until they become useless or you successfully raise an objection;
  • Obligations related to the protection of personal data – data related to the protection of personal data will be processed until they become useless, you successfully raise an objection or the limitation period of our responsibility as the personal data administrator expires.

If we process your personal data on the basis of your consent, you can withdraw such consent at any time: either by your actions or by contacting us using the contact details provided. Remember that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

9. Who are the recipients of personal data?

The external service provider that participates in the processing of your personal data – for the purposes of storing data on the server – is the hosting provider with whom the relevant content of the contract for entrusting the processing of personal data has been concluded.

E-mail correspondence is stored on external servers of e-mail service providers with whom the relevant content of the contract for entrusting the processing of personal data has been concluded.

If necessary, your data may be made available to a legal adviser or advocate bound by professional secrecy. The need may result from the necessity of legal assistance requiring access to your personal data.

If such a necessity arises, your personal data may be made available to entities, bodies or institutions authorized to access data under the law, such as police, security services, courts, prosecutor’s offices.

As far as Anonymous Information is concerned, it is available to providers of tools or plug-ins that collect Anonymous Information. The providers of these tools are independent administrators of the data collected in them and may share this data on the terms set out by them in their own regulations and privacy policies, which we have no influence on.

10. Do we transfer data to third countries or international organizations?

No, we do not transfer your personal data to third countries. However, we use third-party tools that may collect Anonymous Information. The providers of these tools often use servers located around the world to store the collected information, in particular in the United States of America. Anonymous Information collected in connection with the use of the tools indicated in the attachment to this Privacy Policy may be transferred to third countries, in particular the USA.

11. What rights do you have?

The GDPR grants you the following potential rights related to the processing of your personal data:

  • the right to access your data and receive a copy thereof;
  • the right to rectify (correct) your data;
  • the right to delete data (if in your opinion there are no grounds for us to process your data, you can request that we delete it);
  • the right to limit data processing (you can demand that we limit the processing of data only to their storage or performance of actions agreed with you, if in your opinion we have incorrect data or we process them unjustifiably);
  • the right to object to data processing (you have the right to object to data processing on the basis of a legitimate interest; you should indicate a particular situation which, in your opinion, justifies us ceasing the processing covered by the objection; we will stop processing your data for these purposes, unless we demonstrate that the grounds for data processing by us are superior to your rights or that your data is necessary for us to establish, pursue or defend claims);
  • the right to transfer data (you have the right to receive from us in a structured, commonly used machine-readable format personal data that you have provided to us on the basis of your consent; you can instruct us to 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 the supervisory authority (if you find that we are processing data unlawfully, you can submit a complaint to the President of the Office for Personal Data Protection or other competent supervisory authority).

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

We emphasize that you always have one of the rights indicated above: if you believe that we have violated the provisions on the protection of personal data when processing your personal data, you can lodge a complaint with the supervisory body (President of the Office for Personal Data Protection).

12. Do we use cookies and what exactly are they?

Our website, like almost all other websites/websites, uses cookies.

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

Some of the cookies we use are deleted after the end of the web browser session, i.e. after closing it (so-called session cookies). Other cookies are stored on your end device and allow your browser to be recognized the next time you visit the website/page (persistent cookies). If you want to learn more about cookies as such, you can read, for example, this material.

13. 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 electronic services to you.

Cookies that are not necessary for the proper provision of electronic services remain blocked until you consent to the use of cookies. During your first visit to the website, we display a message asking for your consent along with the ability to manage cookies, i.e. decide which cookies you accept and which you want to block.

14. Can you turn cookies off?

Yes, you can manage cookie settings in your web browser. You can block all or selected cookies. You can also block cookies for specific websites. You can also delete previously saved cookies and other website and plug-in data at any time.

Web browsers also offer the option of using incognito mode. You can use it if you do not want information about visited pages and downloaded files to be saved in the browsing and download history. Cookies created in incognito mode are deleted when all windows of this mode are closed.

Browser plug-ins are also available to control cookies, such as Ghostery  The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc.

In addition, there are tools available on the Internet that allow you to control certain types of cookies, in particular for collective management of behavioral advertising settings.

We also give you the ability to control cookies directly from our website. We have implemented a special cookie management mechanism that allows you to block cookies that you do not want. Remember that disabling or limiting the use of cookies may prevent you from using some of the functions available on our websites and cause difficulties in using the website’s pages, as well as many other websites that use cookies.

15. For what purposes do we use our own cookies?

Own cookies are used to ensure the proper functioning of the contact form. Own cookies also store information about cookie settings defined by you made from the level of the cookie management mechanism.

16.  What third party cookies are used?

The following third-party cookies operate on our website:

  • Google Analytics,
  • YouTube.

Details on individual third-party cookies can be found in the attachment to this Privacy Policy.

17. Do we track your behavior undertaken within the website?

Yes, we use the Google Analytics tool, which involves the collection of information about your activities on our website. This tool is described in detail in the appendix to this Privacy Policy.

18. How can you manage your privacy?

The answer to this question can be found in many places in this Privacy Policy when describing individual tools, behavioral advertising, consent to cookies, etc. Nevertheless, for your convenience, we have collected this information again in one place. Below you will find a list of options to manage your privacy:

  • cookie settings within the web browser;
  • browser plug-ins supporting cookie file management, e.g. Ghostery;
  • additional cookie management software;
  • incognito mode in the web browser;
  • behavioral advertising settings, e.g. youronlinechoices.com;
  • mechanism for managing cookies from our website;
  • Google Analytics Opt-out;
  • Google Ads Settings;
  • Facebook Ads Settings.

19. Is there anything else you should know?

As you can see, the subject of personal data processing, the use of cookies and managing privacy in general is 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 want to learn more or just talk about your privacy, write to us at info(at)zubrowa10.pl.

20. Can this Privacy Policy be changed?

Yes, we may modify this Privacy Policy, in particular due to technological changes and changes in the law. Changes to the Privacy Policy become effective after 7 days at the earliest. All archived versions of the Privacy Policy are linked below.

Attachment to the Privacy Policy

LIST OF TOOLS USING COOKIES

Google Analytics

We use the Google Analytics tool provided by the American company Google LLC. In order to use Google Analytics, a special Google Analytics tracking code has been implemented in the website code. The tracking code uses cookies for the Google Analytics service. You can block the Google Analytics tracking code at any time by installing a browser add-on provided by Google.

Google Analytics automatically collects information about your activity on our website. As part of Google Analytics, we only have access to Anonymous Information. Thanks to the information collected in this way, we can analyze user behavior on our website and keep statistics related to it, and then draw conclusions from these statistics in order to design solutions that improve the efficiency of the website.

If you are interested in details related to Google’s use of data from websites and applications that use Google services, we encourage you to familiarize yourself with this information.

YouTube

YouTube widgets are embedded on our pages, allowing you to play recordings available on YouTube directly from our pages. YouTube is operated by the American company Google LLC. When you play the recording, YouTube saves cookies on your device and receives information that you played the recording from a specific website, even if you do not have a Google account or are not currently logged in. If you have logged in to your Google account, this service provider will be able to directly assign a visit to our website to your account. The purpose and scope of data collection and their further processing and use by Google, as well as the possibility of contact and your rights in this regard and the possibility of making settings to protect your privacy are described in Google’s privacy policy.

If you do not want Google to assign the data collected during video playback directly to your profile, you must log out of your account before playing the video. You can also completely prevent the loading of plug-ins on the website by using appropriate extensions for your browser, e.g. script blocking.

The information collected as part of cookies related to YouTube videos embedded on our websites is used by Google to ensure the proper and safe functioning of the widget, analysis and optimization in the field of services provided by YouTube, as well as for personalization and advertising purposes. We do not have access to this information. For us, it is only important that the player works properly.

Remember that by playing the recordings available on YouTube, you use services provided electronically by Google LLC. Google LLC is an independent entity that provides electronic services to you, independent of us. Details on the rules of using YouTube, including privacy protection, can be found in the documents provided directly by YouTube: regulations and privacy policy.

Archived version of the Privacy Policy valid until March 8, 2023 (pdf).