This document governs the Privacy and Cookies Policy of the website operated under the domain www.atfpartners.pl (hereinafter referred to as the „Website”). ATF Partners spółka z ograniczoną odpowiedzialnością sp. j. and ATF Partners spółka z ograniczoną odpowiedzialnością (hereinafter collectively referred to as the "Administrator") shall exercise all due diligence to respect the privacy of the Website Users based on the provisions of the Regulation of the European Parliament and of the Council (EU) 2016/679 of April 27, 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 (hereinafter referred to as "GDPR").
- Data controller
The personal data administrator of the www.atfpartners.pl website is ATF Partners Spółka z ograniczoną odpowiedzialnością sp.j. with its registered office at ul. Składowa 42a, 62-081 Przeźmierowo, KRS: 0000870133, NIP: 7811917440 and ATF Partners Spółka z ograniczoną odpowiedzialnością with its registered office at ul. Składowa 42a, 62-081 Przeźmierowo, KRS: 0000244662, NIP: 7772893154. Contact details: rodo@atfpartners.pl.
- Purpose of personal data processing, legal basis, and scope of data
- Goal:
Evaluation and analysis of activity, including profiling (automated processing of personal data for market and statistical analysis);
- Scope of data processed:
IP address, Service traffic information, number of views, country, and type of device connecting to the Service;
- Legal basis:
The legal basis for processing is the legitimate interest of the Data Controller, resulting from Article 6(1)(f) of the GDPR, which consists of analyzing User activity and their preferences in order to improve applied functionalities and provided services.
- Personal data processing time
Personal data processed using cookies and similar technologies will be processed until such cookies are deleted via browser or device settings or an objection to their processing is raised.
- User Permissions
In connection with the processing of personal data, the following rights are available to the data subjects:
- Data Access Law
The data subject is entitled to obtain from the Controller confirmation as to whether personal data concerning them are being processed. If so, they are entitled to access them and additional information (including purposes, categories, recipients, retention, rights, source).
- Right to data correction
The data subject has the right to request from the Controller the immediate rectification of personal data concerning them that are inaccurate. Taking into account the purposes of processing, they have the right to request the completion of incomplete personal data, including by means of providing an additional statement. The data subject submits a request in this regard, in particular, in writing to the Controller's address or by email to the address indicated in point 1 of the Privacy Policy.
- The right to be forgotten
The data subject has the right to request from the Controller the immediate erasure of personal data concerning them. The Controller shall then be obliged to erase personal data without undue delay if one of the following circumstances applies:
- consent to the processing of personal data has been withdrawn and there is no other basis for processing,
- the data subject has objected to the processing,
- personal data were processed unlawfully,
- personal data must be erased to comply with a legal obligation,
- data was collected in connection with the offering of information society services.
The data subject submits a request in this regard, in particular in writing to the Administrator's address or by e-mail to the address indicated in paragraph 1 of the Privacy Policy.
- Right to restrict processing
The data subject has the right to request from the Controller restriction of processing in the following cases:
- questioning the correctness of personal data - for a period allowing the Administrator to check the correctness of this data;
- processing is unlawful, and the data subject objects to the erasure of the personal data and requests instead that their use be restricted;
- The administrator no longer needs the personal data for processing purposes, but it is needed by the data subject to establish, exercise, or defend legal claims.;
- the data subject objected under Article 21(1) of the GDPR to the processing – pending the determination of whether the legitimate interests pursued by the controller override those of the data subject.
The data subject submits a request in this regard, in particular in writing to the Administrator's address or by e-mail to the address indicated in paragraph 1 of the Privacy Policy.
- Right to object and right to lodge a complaint with a supervisory authority
The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (f) of Article 6(1) (including profiling). The Controller shall no longer process the personal data unless the Controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Furthermore, the data subject shall have the right to lodge a complaint with a supervisory authority if he or she believes that the processing of personal data concerning him or her infringes the GDPR.
- System logs
These are internal server event logs for the Service, which automatically record page requests sent when Users visit its websites. The system logs contain the page request sent by the User, IP address, browser type, browser language, date and time of the request, and at least one „cookie” that can uniquely identify the User's browser.
- Cookies„
These are small files containing a string of characters that are sent and stored on the end device (e.g., computer, laptop, tablet, smartphone) used by the User when they visit the Service. This information is sent to the clipboard of the browser used, which sends it back on subsequent visits to the website. „Cookies” contain information necessary for the proper use of the Service. Most often, they contain the name of the website they come from, their storage time on the end device, and a unique number.
These files allow us to identify the User's device and display the Service's website tailored to their individual expectations, making the use of the pages easier and more enjoyable. By saving these files on the User's device, it is possible to, among other things, adjust the website to the User's preferences, such as content layout, language, or color.
- What „cookies” are used?
The administrator can categorize cookies using three classification methods.
Regarding the purposes for using cookies, three categories are distinguished:
- essential files – these files enable the proper functioning of the Service and the functionalities the User wishes to use, e.g., authentication cookies. Without saving them on the User's device, it is impossible to use the Service.,
- functional files – files that allow for remembering settings chosen by the User and adapting them to their needs and preferences, e.g., in terms of the chosen language, font size, website appearance. They allow the Personal Data Administrator to improve the functionality and performance of the website. Without saving them on the User's device, the use of some website functionalities may be limited,
- Business files – this category includes, for example, advertising cookies. They allow advertisements displayed on or off the Website to be tailored to the User's preferences. Without saving them on the User's device, the use of some of the Website's functionalities may be limited.
In terms of their validity period, two categories of cookies are distinguished:
- session files – data that exists until the end of a given User session,
- Persistent files – existing after the User's session is completed.
Regarding the distinction of the cookie-administering entity, the following have been identified:
- Cookies Administrator of personal data,
- Third-party cookies.
As part of „business” cookies, the Administrator may use cookies that enable learning about the preferences of people using the Website. For example, it is possible to analyze the frequency of visits to the Website. The personal data administrator may use cookies used by Google Inc. 1600 Amphitheatre Pkwy, Mountain View, CA 94043, United States as part of the following services:
- Google Ads – they allow for running and evaluating the quality of advertising campaigns carried out using the Google Ads service,
- Google Analytics – they allow for the assessment of the quality of advertising campaigns carried out using the Google Adwords service, as well as for the analysis of User behavior and traffic, and the compilation of traffic statistics.,
- Google Maps - they allow for the storage of User information that enables the use of map functionalities available within the Google Maps service. Google Inc. may track the User's location,
- YouTube – they allow storing information about the User, which enables the use of YouTube service functionalities. Google Inc. may track the User's video playback.
- Cookie Management„
Most browser settings by default allow „cookies” to be placed on the end device. If the User does not agree to the saving of these files, it is necessary to change the web browser settings accordingly. It is possible to disable the saving of „cookies” for all connections from a given browser or for a specific website, as well as to delete them. The method of managing „cookies” depends on the software used, therefore detailed information on the possibilities and methods of their handling can be found in the settings of the web browser used to connect to the Website.
Consent to the processing of „cookies” is voluntary. However, please note that restricting their use may make it difficult or impossible to use the services offered on the Website.
- Data aggregation
Data collected in system logs is used by the Data Administrator solely for the purpose of administering the Service. It is not transferred to third parties, except in the circumstances described in this document.
In connection with the User's use of the Service, the Administrator may collect and store in server logs technical details regarding the use of services, requests sent by the User related to the provision of services electronically, IP address, and technical data about the Service's operation in connection with actions taken by the User. The Administrator may collect information for the purpose of storing it locally on the User's device, using the browser's memory mechanism.
While providing services to Users, the Administrator uses professional technologies to collect and store information, such as „cookies”. Google may also have access to „cookie” data through Google Analytics and Google Adwords tools, in order to compile traffic statistics and the effectiveness of promotional campaigns carried out by the Personal Data Administrator using the aforementioned tools.
The data collected on the Service is stored on external, secure, and professional servers, based on agreements concluded by the Personal Data Administrator. The Personal Data Administrator takes due care to protect Users' personal data from unauthorized access, destruction, disclosure, and unlawful use. Only the Users themselves, the Personal Data Administrator, and third parties indicated in this document are authorized to process the data of Service Users.
- Other
The service may contain links to other websites. The administrator is not responsible for the privacy policy principles in force on those websites. It is recommended to familiarize yourself with the privacy policy of those websites after visiting them.
The Data Controller reserves the right to change the Privacy Policy and cookie policy.