PRIVACY AND COOKIE POLICY

1. GENERAL INFORMATION

This privacy and cookie policy (hereinafter referred to as the “Policy“) is for information purposes only and is intended for:

1. users of our website at www.inplag.pl (hereinafter the “Website”);
2. our associates collaborating with us based on a direct agreement or an agreement signed by the entity whom they represent or on whose behalf they act (hereinafter referred to as “Collaboration”);
3. persons who contact us or who are contacted by us by email (hereinafter referred to as “Contact”);

The Policy aims to provide information on the processing of personal data on the Website in accordance with 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) (“GDPR“).

This Policy ensures our compliance with information obligations under articles 13 and 14 of GDPR.

Any questions concerning the Policy or rules of processing personal data on the Website can be sent to us by email at rodo@inplag.pl

1. CONTROLLER OF PERSONAL DATA

The Website is operated and maintaned by Inplag Sp. z o.o. with its registered office in Wrocław (53-033), address: ul. Zwycięska 41, entered into the register of businesses kept by District Court for Wrocław-Fabryczna, 6th Commerce Division of the National Court Register under number 0000653940, NIP (Tax Identification Number): 8992805135, REGON (National Business Register): 366153869, share capital: PLN 500,000.00.

• PURPOSES AND LEGAL BASIS OF PROCESSING

When you use our Website, we process your personal data (including IP address or other identifiers and information collected through cookies or other similar technologies) for the following purposes:

WEBSITE

1. provision of electronic services to enable users to access content published on the Website –processing is necessary for the performance of a contract for the provision of electronic services (article 6 (1) (b) of GDPR);
2. analytical and statistical purposes – the legal basis for processing is our legitimate interest (article 6 (1) (f) of GDPR) in analysing your actions and your preferences for the purpose of improving the functionalities used and services provided.

COLLABORATION

When you collaborate with us based on a direct agreement or an agreement signed by the entity whom you represent or on whose behalf you act:

1. for the purposes of concluding an agreement with us, performing and monitoring it, including in particular for the purposes of contact, complying with disclosure obligations, collaborating in the performance of an agreement or arrangements – processing is based on the fact that it is necessary for the performance of an agreement (article 6 (1) (b) of GDPR), and if you are not our customer (but e.g. an employee or representative of our customer), then the legal basis for processing is our legitimate interest (article 6 (1) (f) of GDPR) in performing the agreement concluded with the Customer;

CONTACT

When you contact us by email or regular mail, we will process your personal data for the following purposes:

1. in order to contact you to handle your request sent to us by email or regular mail, in order to contact you in connection with our agreement or arrangements, in order to engage in further correspondence with you – the legal basis for processing is our legitimate interest in enabling us to answer questions concerning our business or respond to other request for contact or to enter into or perform an agreement with the person or entity represented by you (article 6 (1) (f) of GDPR); where we send our correspondence to you or respond to your correspondence in connection with an agreement that is or will be concluded with you, the legal basis for processing is that processing is necessary to perform the agreement or in order to take steps at your request prior to entering into such agreement (article 6 (1) (b) of GDPR);

1. in the case of marketing correspondence, we also process your data in order to promote our Products or business – the legal basis for processing is our legitimate interest (article 6 (1) (f) of GDPR).

SOCIAL MEDIA

We may process your personal data when you visit our social media accounts, such as:

1. Facebook (Facebook inplag)
2. LinkedIn (LinkedIn inplag)
3. Instagram (Instagram inplag)
4. Youtube (https://www.youtube.com/@INPLAG)

Videos about our products hosted on YouTube may be posted on our Website, our social media accounts and other webpages. When you play these videos, our Website will collect cookies that may contain personal data.

When you visit our social media accounts or use other content made available by us on social media, we may process your personal data for the following purposes:

1. to run our social media accounts, inform you of our activities and promote various events and our Products. The legal basis for the processing of your personal data for this purpose is our legitimate interest (article 6 (1) (f) of GDPR) in promoting our own brand and products.

Facebook | Instagram

Our Website uses Meta Platforms plugins. Clicking takes you to our Facebook or Instagram account. In such event, your data, such us information about the web browser or app you use, online identifiers, including IP addresses and Facebook or Instagram-related identifiers, if any (such as mobile operating system advertising identifiers), as well as information on the status of provision of advertisements are sent to Facebook or Instagram. In respect of this data, Facebook or Instagram (Meta Platforms Ireland Limited) and the Controller act as joint controllers in accordance with article 26 of GDPR.

For information on how Facebook processes personal data, including the legal basis and how to exercise your rights, please see YouTube Facebook ‘s privacy policy at: https://www.facebook.com/about/privacy.

More details on the arrangement where Facebook and Inplag act as joint data controllers can be found in the addendum on joint control available at https://www.facebook.com/legal/controller_addendum.

LinkedIn

When you visit our company profile on LinkedIn, it will also process your data disclosed to LinkedIn, such as your job title, country, industry, job level, size of company and employment status. In addition, LinkedIn will process information about your interactions with the Controller’s company profile. In connection with this processing, LinkedIn (LinkedIn Ireland Unlimited Company) and Inplag will act as joint controllers in respect of the data included in page information provided by LinkedIn to the Controller. Page information provided to the Controller contains aggregated data and LinkedIn will not disclose your data to the Controller and will not enable the Controller to associate it with you.

Information about the processing of your personal data by LinkedIn can be found in the privacy policy available at: https://www.linkedin.com/legal/privacy-policy?#use.

More detailed information on the joint controllership between LinkedIn Ireland and Inplag can be found in the joint controllership addendum available at: https://legal.linkedin.com/pages-joint-controller-addendum

YouTube

Our Website uses the YouTube plugin. By clicking, you access our YouTube channel. In such event, your data, such as information about the internet browser or application used, online identifiers, including IP addresses and, if provided, identifiers associated with YouTube (such as mobile operating system advertising identifiers), as well as information on the status of advertising, are sent to YouTube. In respect of this data, YouTube (Google Ireland Limited) and the Controller act as joint controllers pursuant to Article 26 of GDPR.

For information on how YouTube processes personal data, including the legal basis and how to exercise your rights, please see YouTube’s privacy policy at: https://policies.google.com/privacy.

More detailed information on the joint controllership between YouTube and Inplag can be found in the Joint Controllership Addendum available at: https://policies.google.com/terms/controllerterms.

OTHER PURPOSES OF PROCESSING

We may also process your personal data for the following purposes:

1. to fulfil legal obligations incumbent on the Controller, such as providing information and documents required by public administration bodies – the legal basis for processing is the necessity to fulfil the legal obligation incumbent on the Controller (Article 6 (1) (c) of GDPR);
2. to establish or pursue claims or defend against claims – the legal basis for processing is our legitimate interest (Article 6 (1) (c) of GDPR) in the protection of rights.

1. SOURCE AND CATEGORIES OF PERSONAL DATA

In most cases, you are the direct source of the personal data processed by the Controller.

In addition, if you are an employee or representative of our contractor, we may receive identifying information from them (such as first name, surname, e-mail address, position).

1. PERIOD OF RETENTION OF PERSONAL DATA

We will not use or retain your personal data longer than necessary to achieve the above-mentioned purposes, and we will erase the collected personal data after the period necessary to achieve the purposes described in this document or to fulfill the contractual obligations or to the extent permitted or required by applicable law. Specific periods for retention of personal data are indicated for each of the listed processing purposes:

1. where we process your data in order to perform a contract (e.g. to provide you with content on the Website or engage in e-mail correspondence related to the contract concluded with us) – your data will be processed for the duration of the contract, and afterwards for a period no longer than the period of any limitation of claims;
2. where we process your data in order to fulfill our legal obligations – your data will be processed for no longer than the duration of such legal obligations
3. where we process your data on the basis of our legitimate interest – your data will be processed until our interest is fulfilled (e.g. for the duration of correspondence) but no longer than until you object to the processing of your data for such purposes. Where we process your data for the purpose of establishing or pursuing claims or defending against claims, your data will be processed for the duration of the proceedings and, optionally, for the period of limitation of claims.
4. RECIPIENTS OF PERSONAL DATA

The Controller does not and will not sell your personal data. We disclose your data only to the extent permitted by this policy. We may share information with the types of third parties described below and will always ensure that when sharing information, such third parties adhere to the same principles.

In relation to the processing of data for the purpose specified in this Policy, the recipients of your personal data may include:

1. our authorised personnel, as well as authorised personnel of our subcontractors;
2. entities providing services to us, i.e. those operating our IT systems, hosting, managing websites, advertising agencies, entities providing advisory, legal, debt collection, accounting and auditing services, in particular:
3. the provider of our e-mail system – where we engage in correspondence via e-mail;
4. social media providers;

We reserve the right to disclose selected information about the user to competent authorities or third parties who request such information on an appropriate legal basis and in accordance with applicable law.

• TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

Your personal data is generally processed within the European Economic Area (hereinafter referred to as the “EEA”). In the event that the Controller establishes cooperation with an entity outside this area, your personal data may exceptionally also be transferred to the country in which this entity is based. In such a case, the data will be transferred only: (i) to the extent necessary, related to the provision of services by this entity to the Controller; (ii) in accordance with the requirements specified in Chapter V of GDPR, including appropriate safeguards such as standard contractual clauses adopted by decision of the European Commission. You can obtain a copy of the safeguards for personal data transferred outside the EEA by contacting the Controller.

• PROFILING

When using the Website, you may be subject to profiling. Profiling may occur in connection with the implementation of the marketing goals of the Controller or a third party, especially using marketing cookies (which we describe below). Profiling consists in the fact that your personal data will be used in such a way as to match the content displayed to you on the Website to your interests.

1. GOOGLE ANALYTICS

Google Analytics cookies are files used by Google to analyze how the user uses the Service, create statistics and reports on the operation of the Service. Google does not use the collected data to identify the user, nor does it combine this information to enable identification. Detailed information on the scope and principles of data collection in connection with this service can be found here.

1. YOUR RIGHTS AS DATA SUBJECTS

In connection with the processing of your personal data, you have certain rights – find out about them below.

As data subjects, you have the following rights:

1. right to access your personal data (including e.g. to be informed of what personal data is processed);
2. right to request the rectification and restriction of processing of personal data (e.g. if your personal data is inaccurate or incomplete, you may request for appropriate changes to be made to your personal data);
3. right to erasure of your personal data (e.g. if your data is unlawfully processed);
4. right to object to processing of personal data, including processing (you may object to processing of personal data if the legal basis for its processing is the legitimate interest of the Controller or a third party – in such event, processing of your personal data will be allowed only if the interest of the Controller or a third party obviously overrides your interest);
5. right to data portability. This right applies to personal data that was disclosed by you to the Controller and which is processed using automated means, and processing takes place based on consent or an agreement made with the Controller;
6. right to lodge a complaint with the competent supervisory authority – President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw);
7. withdraw consent (only to the extent where processing is based on consent) at any time, provided that withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal – if you withdraw consent, we may continue to process your personal data if a different legitimate ground for processing exists (e.g. processing is necessary for compliance with a legal obligation to which the controller is subject).

If you wish to exercise any of the above rights, provisions of GDPR require us to ensure prior verification of your identity – we therefore reserve the right to ask you additional questions to confirm your identity prior to complying with your request.

1. COOKIES
2. COOKIES USED ON THE WEBSITE

The Website uses cookies (small text files) or technologies with similar functionality to cookies, saved to your device (e.g. laptop, smartphone) by your browser.

We use session cookies and persistent cookies. Session cookies are temporary files stored on your device until you log out of or navigate away from the Website. Persistent cookies are kept on your end device for a period defined in cookie parameters or until deleted.

We may use the following types of cookies on the Website:

1. essential cookies – you cannot disable these cookies as they are essential for the functioning of the Website. We use them to ensure the proper functioning of the website and its safe use – without them, using the Website would be impossible
2. functional cookies – these require your consent. They help us analyse how the Website is used. They allow, for example, to determine the number of people visiting the website, as well as to detect and eliminate irregularities in its functioning;
3. analytical cookies – these require your consent. They help provide you with an efficient and user-friendly Website, tailored to your preferences. They allow, among other things, to check how you use the Website, e.g. how often you visit the Website and what functionalities you use;
4. marketing cookies – these require your consent. These cookies are used to tailor marketing content to your needs and interests, and may also be used to tailor content and advertisements presented to you by third parties.

Detailed information on the cookies used on the Website is available in the table below:

LEGAL BASIS FOR THE USE AND MANAGEMENT OF COOKIE FILES

Obtaining and storing information using cookies, except when necessary to ensure the proper operation of the Website and your use of its functionalities, is only possible on the basis of your consent.

Withdrawing consent to the use of cookies is possible via your browser settings. Detailed information on this can be found at the following links:

• Internet Explorer
• Mozilla Firefox
• Google Chrome
• Opera
• Safari

You can verify the status of your current privacy settings in your browser at any time by using the tool available at https://optout.aboutads.info/?c=2&lang=EN

Withdrawal of consent will not affect the lawfulness of actions taken on the basis of consent before its withdrawal. Limiting the use of cookies may affect some functionalities available on the Website, prevent or significantly impede the proper use of the Website.

Cookies are used to collect various types of information – some of them may be attributed to a specific person and thus be considered personal data. The provisions of the Privacy Policy apply accordingly to this type of information. To the extent that cookies contain your personal data, the basis for their processing is the legitimate interest of the Website Operator or a third party – article 6 (1) (f) of GDPR. In some cases, in particular if a given cookie provider (third party) requires it, the basis for the processing of personal data may also be your voluntary consent. Cookie providers (third parties) may in some cases act as controllers of your personal data.

Last revision: July 2024