Privacy Policy

This Privacy Policy defines the rules for storing and accessing data on Users’ Devices using the Website for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users’ personal data provided by them personally and voluntarily via tools available on the Website.

§1 Definitions

Website – the “ZUMiR” website operating at zumir.com.pl
External Website – partner, service provider, or client websites cooperating with the Administrator
Website/Data Administrator – The Administrator of the Website and Data (hereinafter “Administrator”) is the company “ZUMiR Elżbieta Stępień”, operating at ul. Przemysłowa 9, 26-900 Kozienice, NIP: 8121038388, providing electronic services via the Website
User – a natural person for whom the Administrator provides services electronically via the Website
Device – an electronic device with software through which the User accesses the Website
Cookies – text data files stored 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
Personal data – information about an identified or identifiable natural person (“data subject”); an identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural, or social identity of that person
Processing – any operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, 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 – marking stored personal data with the aim of limiting their future processing
Profiling – 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 analyze or predict aspects concerning that person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements
Consent – a 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 – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed
Pseudonymization – the processing of personal data in such a manner that the 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 organizational measures to ensure non-attribution to an identified or identifiable natural person
Anonymization – an irreversible process that destroys or overwrites “personal data” so that identification or association of a given record with a specific user or natural person is impossible.

§2 Data Protection Officer

Pursuant to Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.
For matters related to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

Internal cookies – files placed and read from the User’s Device by the Website’s IT system
External cookies – files placed and read from the User’s Device by IT systems of external websites. Scripts from external websites that may place cookies on User Devices are intentionally included in the Website through scripts and services provided and installed on the Website
Session cookies – files placed and read from the User’s Device by the Website during a single session. 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 Website until manually deleted. The files are not deleted automatically after the session ends unless the User’s Device is configured to delete cookies after the 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 Website are implemented through built-in browser mechanisms and do not allow retrieval of other data from the User’s Device or data from other websites visited by the User, including personal or confidential information. Transferring viruses, trojans, or other malware to the User’s Device via cookies is practically impossible.
Internal cookies – Cookies used by the Administrator are safe for User Devices and do not contain scripts, content, or information that could threaten the security of personal data or the Device.
External cookies – The Administrator takes all possible measures to verify and select service partners regarding User security. The Administrator cooperates with well-known, reputable partners, but does not have full control over the content of cookies from external partners. The Administrator is not responsible for the security, content, or licensed use of cookies from external services installed on the Website, to the extent permitted by law.
Cookie control – The User may change the settings for storing, deleting, and accessing cookies for each website at any time. Information on disabling cookies in the most popular browsers can be found on the browser’s support pages. The User may also delete all previously saved cookies at any time using the tools of their Device.
User-side risks – The Administrator uses all possible technical measures to ensure the security of data stored in cookies. However, ensuring the security of this data depends on both parties, including the User’s actions. The Administrator is not responsible for data interception, session impersonation, or deletion resulting from the User’s actions, viruses, trojans, or spyware that may have infected the User’s Device. Users should follow internet safety recommendations.
Storage of personal data – The Administrator ensures that all efforts are made so that personal data voluntarily entered by Users is secure, access is limited, and processing is performed according to its purpose. The Administrator also strives to secure the data against loss by using appropriate physical and organizational safeguards.

§5 Purposes of Using Cookies

Improving and facilitating access to the Website
Personalizing the Website for Users
Compiling statistics (users, number of visits, device types, connections, etc.)

§6 Purposes of Processing Personal Data

Personal data voluntarily provided by Users is processed for one of the following purposes:

Provision of electronic services
Communication between the Administrator and Users regarding the Website and data protection
Pursuing the Administrator’s legitimate interests

Data about Users collected anonymously and automatically is processed for:

Compiling statistics
Pursuing the Administrator’s legitimate interests

§7 Cookies from External Services

The Administrator uses JavaScript scripts and web components from partners, who may place their own cookies on the User’s Device. Remember that in your browser settings, you can decide which cookies are allowed for individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

Statistics: Google Analytics

Services provided by third parties are beyond the Administrator’s control. These entities may change their terms of service, privacy policies, purposes of data processing, and methods of using cookies at any time.

§8 Types of Collected Data

The Website collects data about Users. Some data is collected automatically and anonymously, while some consists of personal data voluntarily provided by Users when signing up for specific services offered by the Website.

Anonymous data collected automatically:

IP address
Browser type
Screen resolution
Approximate location
Opened subpages of the Website
Time spent on a given subpage
Operating system type
Previous subpage address
Referring page address
Browser language
Internet connection speed
Internet service provider

Data collected during registration:

Email address

Data collected when subscribing to the Newsletter:

Email address

Some data (without identifying information) may be stored in cookies. Some data (without identifying information) may be transferred to a statistics service provider.

§9 Access to Personal Data by Third Parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the provided services is not transferred or sold to third parties.

Access to data (usually based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to operate the Website, such as:

Hosting companies providing hosting or related services to the Administrator

Entrusting personal data processing – Hosting, VPS, or Dedicated Server Services:
To operate the Website, the Administrator uses the services of an external hosting, VPS, or Dedicated Server provider – CyberFolks. All data collected and processed on the Website is stored and processed within the provider’s infrastructure located in Poland. There is a possibility of access to the data as a result of maintenance work carried out by the provider’s personnel. Access to this data is regulated by an agreement between the Administrator and the Service Provider.

§10 Method of Processing Personal Data

Personal data voluntarily provided by Users:
Personal data will not be transferred outside the European Union unless published as a result of the User’s individual action (e.g., posting a comment or entry), making the data available to anyone visiting the Website.
Personal data will not be used for automated decision-making (profiling).
Personal data will not be sold to third parties.

Anonymous data (without personal data) collected automatically:
Anonymous data (without personal data) may 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 sold to third parties.

§11 Legal Basis for Processing Personal Data

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 (GDPR)
- Art. 6(1)(a): the data subject has given consent to the processing of their 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 Administrator or by a third party
The Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)
The Act of 16 July 2004 – Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)
The Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No. 24, item 83)

§12 Period of Processing Personal Data

Personal data voluntarily provided by Users:
As a rule, the indicated personal data is stored only for the duration of the Service provided by the Administrator within the Website. It is deleted or anonymized within 30 days after the end of service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.).

An exception is a situation that requires securing legally justified purposes for further processing of this data by the Administrator. In such a case, 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 Website’s regulations by the User.

Anonymous data (without personal data) collected automatically:
Anonymous statistical data, which does not constitute personal data, is stored by the Administrator for the purpose of maintaining website statistics for an indefinite period.

§13 Users’ Rights Regarding Personal Data Processing

The Website collects and processes User data based on:

Right of access to personal data – Users have the right to access their personal data, exercised upon request to the Administrator
Right to rectify personal data – Users have the right to request the Administrator to immediately correct personal data that is incorrect and/or complete incomplete personal data, exercised upon request to the Administrator
Right to delete personal data – Users have the right to request the Administrator to immediately delete personal data, exercised upon request to the Administrator. In the case of user accounts, data deletion consists of anonymizing data that enables User identification. The Administrator reserves the right to suspend the deletion request to protect the Administrator’s legitimate interest (e.g., when the User has violated the Terms of Service or data was obtained as a result of correspondence). For the Newsletter service, the User can independently delete their personal data using the link included in each email.
Right to restrict processing of personal data – Users have the right to restrict processing in cases specified in Article 18 of the GDPR, e.g., contesting the accuracy of personal data, exercised upon request to the Administrator
Right to data portability – Users have the right to obtain from the Administrator their personal data in a structured, commonly used, machine-readable format, exercised upon request to the Administrator
Right to object to the processing of personal data – Users have the right to object to the processing of their personal data in cases specified in Article 21 of the GDPR, exercised upon request to the Administrator
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

You can contact the Administrator in one of the following ways:

Postal address: ZUMiR Elżbieta Stępień, ul. Przemysłowa 9, 26-900 Kozienice, Poland
Email address: kontakt@zumir.com.pl
Telephone: +48 885 102 000
Contact form: available at /kontakt

§15 Website Requirements

Restricting the storage and access to cookies on the User’s Device may cause some Website functions to malfunction.
The Administrator is not responsible for the incorrect operation of Website functions if the User restricts the possibility of storing and reading cookies in any way.

§16 External Links

On the Website – in articles, posts, entries, or User comments – there may be links to external websites with which the Website Owner does not cooperate. These links, as well as the pages or files indicated under them, may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for content found outside the Website.

§17 Changes to the Privacy Policy

The Administrator reserves the right to change this Privacy Policy at any time without the need to inform Users regarding the use of anonymous data or cookies.
The Administrator reserves the right to change this Privacy Policy regarding the processing of Personal Data, about which Users with user accounts or subscribed to the newsletter will be informed by email within 7 days of the change. Continued use of the services means acceptance of the changes to the Privacy Policy. If the User does not agree with the changes, they are obliged to delete their account or unsubscribe from the Newsletter.
Changes to the Privacy Policy will be published on this subpage of the Website and take effect upon publication.