Privacy Policy
This Privacy Policy outlines the rules for storing and accessing data on Users' Devices using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users' personal data that they have provided personally and voluntarily through the tools available on the Service.
This Privacy Policy is an integral part of the Service Regulations, which defines the rules, rights, and obligations of Users utilizing the Service.
§1 Definitions
Service - the website "cremedor.pl" operating at https://cremedor.pl/
External Service - websites of partners, service providers, or recipients cooperating with the Administrator
Service / Data Administrator - The Administrator of the Service and Data Administrator (hereinafter referred to as the Administrator) is the company "GRUPA KJAN - POL Sp. z o.o.", operating at: Belęcin 89A 64-231, Belęcin, with Tax Identification Number (NIP): 9231734474, providing electronic services through the Service.
User - a natural person for whom the Administrator provides electronic services through the Service.
Device - an electronic device with software, through which the User accesses 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 relating to 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, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
Pseudonymisation - means the processing of personal data in such a manner that the personal 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
Anonymisation - Anonymisation of data is an irreversible process of data operations that destroys / overwrites "personal data" making it impossible to identify or link a given record to a specific user or natural person.
§2 Data Protection Officer
Pursuant to Art. 37 of the GDPR, the Controller has not appointed a Data Protection Officer.
For matters concerning data processing, including personal data, please contact the Controller directly.
§3 Types of Cookies
Internal Cookies - files placed and read from the User's Device by the Service's ICT system
External Cookies - files placed and read from the User's Device by the ICT systems of External Services. Scripts from External Services that may place Cookies on Users' Devices have been consciously 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 a given Device. After the session ends, the files are deleted from the User's Device.
Persistent Cookies - files placed and read from the User's Device by the Service until they are manually deleted. The files are not automatically deleted after the Device session ends, unless the User's Device configuration is set to delete Cookies after the Device session ends.
§4 Data Storage Security
Cookie Storage and Reading Mechanisms - The mechanisms for storing, reading, and exchanging data between Cookies saved on the User's Device and the Service are implemented through built-in web browser mechanisms and do not allow for 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. The transfer of viruses, Trojan horses, 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 takes all possible steps to verify and select service partners in the context of User security. The Administrator selects well-known, large partners with global public trust for cooperation. However, the Administrator does not have full control over the content of Cookies originating from external partners. The Administrator is not responsible for the security of Cookies, their content, and their licensed use by Scripts installed in the service, originating from External Services, to the extent permitted by law. A list of partners is provided later in the Privacy Policy.
Cookie Control
The User can, at any time, independently change the settings regarding the saving, deletion, and access to data stored in Cookies by any website.
Information on how to disable Cookies in the most popular computer browsers is available on the page: how to disable cookies or from one of the indicated providers:
The User can, at any time, delete all previously saved Cookies using the tools of the User's Device through which the User uses the Service.
User-side Threats - The Administrator employs all possible technical measures to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User's activity. The Administrator is not responsible for the interception of this data, impersonation of the User's session, or its deletion, as a result of conscious or unconscious User activity, viruses, Trojan horses, and other spyware that may have infected or currently infect the User's Device. To protect themselves from these threats, Users should adhere to principles that enhance their cybersecurity.
Storage of Personal Data - The Administrator ensures that all efforts are made to keep personal data voluntarily provided by Users secure, with access restricted and carried out in accordance with their purpose and processing objectives. The Administrator also ensures that all efforts are made to protect the data held against loss, through the application of appropriate physical and organizational safeguards.
Password Storage - The Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. Decryption of account access passwords provided in the Service is practically impossible.
§5 Purposes for which Cookies are used
- Improving and facilitating access to the Service
- Personalization of the Service for Users
- Enabling Login to the service
- Marketing, Remarketing on external services
- Ad serving services
- Affiliate services
- Maintaining statistics (users, number of visits, device types, connection, etc.)
- Serving multimedia services
- Providing social services
§6 Purposes of Personal Data Processing
Personal data voluntarily provided by Users is processed for one of the following purposes:
- Provision of electronic services:
- Services for registration and maintenance of a User account on the Website and related functionalities
- Newsletter services (including sending promotional content with consent)
- Services for commenting on / liking posts on the Website without the need for registration
- Services for sharing information about content placed on the Service on social media or other websites.
- Communication between the Controller and Users regarding the Website and data protection
- Ensuring the Controller's legitimate interest
User data collected anonymously and automatically is processed for one of the following purposes:
- Maintaining statistics
- Remarketing
- Serving advertisements tailored to User preferences
- Supporting affiliate programs
- Ensuring the Controller's legitimate interest
§7 External Service Cookies
The Administrator uses JavaScript scripts and web components from partners in the Service, who may place their own cookies on the User's Device. Remember that in your browser settings, you can decide which cookies are allowed to be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:
- Multimedia services:
- Social / Integrated Services:
(Registration, Login, content sharing, communication, etc.) - Content sharing services:
- Newsletter Services:
- Maintaining statistics:
Services provided by third parties are beyond the Administrator's control. These entities may at any time change their terms of service, privacy policies, data processing purposes, and methods of using cookies.
§8 Types of Data Collected
The Service collects User data. Some data is collected automatically and anonymously, while some data is personal data voluntarily provided by Users when signing up for individual services offered by the Service.
Anonymous data collected automatically:
- IP Address
- Browser Type
- Screen Resolution
- Approximate Location
- Visited Subpages
- Time Spent on the Respective Subpage
- Operating System Type
- Previous Subpage Address
- Referring Page Address
- Browser Language
- Internet connection speed
- Internet Service Provider
Data collected during registration:
- First name / last name / pseudonym
- Login
- Email address
- Phone number
- IP address (collected automatically)
- Tax Identification Number (NIP)
Data collected when subscribing to the Newsletter service
- First name / last name / pseudonym
- Email address
- IP address (collected automatically)
Data collected when adding a comment
- First and last name / pseudonym
- Email address
- Website address
- IP address (collected automatically)
Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to a statistical service provider.
§9 Access to Personal Data by Third Parties
As a rule, the sole recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided is not transferred or resold to third parties.
Access to data (most often based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary for operating the service, i.e.:
- Companies through which the Newsletter service is provided
Entrustment of Personal Data Processing - Newsletter
To provide the Newsletter service, the Administrator uses the services of a third-party entity - the Mailerlite service. Data entered in the newsletter subscription form is transferred, stored, and processed on the external service of this provider.
Please be informed that the indicated partner may modify the stated privacy policy without the Administrator's consent.
§10 Method of Personal Data Processing
Personal data voluntarily provided by Users:
- Personal data will not be transferred outside the European Union, unless published as a result of an individual User action (e.g., posting a comment or entry), which will make the data accessible to anyone visiting the website.
- Personal data will not be used for automated decision-making (profiling).
- Personal data will not be resold 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 resold to third parties.
§11 Legal Bases for Personal Data Processing
The Website collects and processes User 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)
- Art. 6(1)(a)
the data subject has given consent to the processing of his or her personal data for one or more specific purposes - Art. 6(1)(b)
processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract - Art. 6(1)(f)
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
- Art. 6(1)(a)
- Act of May 10, 2018, on Personal Data Protection (Journal of Laws 2018, item 1000)
- Act of July 16, 2004, Telecommunications Law (Journal of Laws 2004, no. 171, item 1800)
- Act of February 4, 1994, on Copyright and Related Rights (Journal of Laws 1994, No. 24, item 83)
§12 Period of Personal Data Processing
Personal data voluntarily provided by Users:
As a rule, the indicated personal data is stored only for the period of Service provision by the Administrator within the Service. They are deleted or anonymized within 30 days from the end of service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter list, etc.).
An exception is a situation that requires securing the legally legitimate purposes for further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User's request for deletion, for no longer than 3 years in the event of a violation or suspected violation of the service regulations 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 maintaining service statistics indefinitely.
§13 User Rights related to Personal Data Processing
The Website collects and processes User 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 Controller.Right to rectification of personal data
Users have the right to demand from the Controller the immediate rectification of personal data that is inaccurate and/or the completion of incomplete personal data, exercised upon request submitted to the Controller.Right to erasure of personal data
Users have the right to request the Administrator to immediately erase personal data, exercised upon a request submitted to the Administrator. For user accounts, data deletion involves anonymizing data that enables User identification. The Administrator reserves the right to suspend the fulfillment of a data deletion request to protect the Administrator's legally legitimate interest (e.g., when the User has violated the Regulations or data was obtained as a result of ongoing 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 email sent.Right to restriction of personal data processing
Users have the right to restrict the processing of personal data in cases indicated in Art. 18 of the GDPR, including challenging the accuracy of personal data, exercised upon request submitted to the Controller.Right to data portability
Users have the right to receive from the Controller personal data concerning the User in a structured, commonly used, machine-readable format, exercised upon request submitted to the Controller.Right to object to personal data processing
Users have the right to object to the processing of their personal data in cases specified in Art. 21 of the GDPR, exercised upon request submitted to the Controller.Right to lodge a complaint
Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.
§14 Contacting the Administrator
The Controller can be contacted in one of the following ways
Postal address - GRUPA KJAN - POL Sp. z o.o., Belęcin 89A 64-231, Belęcin
Email address - biuro@cremedor.pl
Phone call - +48 519 195 110
Contact form - available at: https://cremedor.pl/kontakt
§15 Service Requirements
Restricting the saving and access to Cookies on the User's Device may cause some Service functions to operate incorrectly.
The Administrator bears no responsibility for incorrectly functioning Service features if the User restricts the ability to save and read Cookies in any way.
§16 External Links
On the Service - in articles, posts, entries, or User comments - there may be links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated under them may be dangerous for your Device or pose a security threat to your data. The Administrator is not responsible for content located outside the Service.
§17 Changes to the Privacy Policy
The Administrator reserves the right to make any changes to this Privacy Policy without the need to inform Users regarding the use of anonymous data or the application of Cookies.
The Administrator reserves the right to modify this Privacy Policy at any time regarding the processing of Personal Data, of which it will inform Users with user accounts or subscribed to the newsletter service, via email, within 7 days of the changes being implemented. Continued use of the services implies acknowledgment and acceptance of the changes introduced to the Privacy Policy. Should the User disagree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
The introduced changes to the Privacy Policy will be published on this subpage of the Service.
The introduced changes come into effect upon their publication.