PRIVACY POLICY

INTRODUCTION

1. STALKO Limited Liability Company sp.k. with registered office in Warsaw at: ul. Solec 24/253, 00-403 Warsaw, address for correspondence: ul. Gdyńska 32/14, 26-600 Radom, registered by the District Court for the M.St. The Management Board of the Warsaw Stock Exchange in Warsaw, XII Economic Division of the National Court Register under KRS no.: 0000836475, REGON no.: 361379132, NIP no.: 9482603545 (hereinafter: the Administrator) shall make every effort to protect the personal data of www.sorter.pl website Users from disclosure to unauthorised persons, from being taken by an unauthorised person, from being processed in breach of the applicable laws, and from being altered, lost, damaged or destroyed, and to respect the privacy of each User.
2. Personal data is information about an identified or identifiable natural person. When using the Administrator’s servers, such data is, for example, the e-mail address, IP address or data in the service offered by the Administrator. Personal data may be stored in cookies or similar technologies that are used when using the website.
3. Users’ personal data are processed in accordance with the requirements of generally applicable law, in particular the Act of 10 May 2018 on the protection of personal data, Coll. 2018 pos. 1000 and 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 or GDPR, OJ L 119, 4.5.2016, p. 1-88).
4. This Privacy Policy (hereinafter: the Policy) sets out the rules for the processing and protection of Users’ personal data by the Administrator. The Policy regulates the types of personal data collected by the Administrator, how this data is used, the rights of users, the categories of entities to which the data is made available, information on cookies. The Policy also sets out measures for the protection and security of personal data and how to contact the Administrator about the measures and methods used to protect personal data.

I. Basic concepts

personal data – any information relating to an identified or identifiable natural person, e.g. name and surname, number, telephone number, address, ID card number. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his or her physical, physiological, mental, economic, cultural or social characteristics. Information shall not be deemed to identify a person if it would require unreasonable expense, time or effort;

data processing – any operations performed on personal data, such as collecting, recording, storing, developing, changing, making available and deleting, and in particular those performed in IT systems;

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;

User – a natural person whose data is processed by the Administrator;

Customer – an entity for which the Administrator provides services or purchases goods from the Administrator.

II. Personal Data Administrator

The administrator of the Users’ personal data is STALKO Limited liability company with registered office in Warsaw at: ul. Solec 24/253, 00-403 Warsaw, address for correspondence: ul. Gdyńska 32/14, 26-600 Radom, registered by the District Court for the M.St. Warsaw, XII Commercial Division of the National Court Register under KRS number: 0000836475, REGON: 361379132, NIP: 9482603545.

The Personal Data Protection Officer is Bartłoimiej Kida, correspondence address: ul. Solec 24/253 00-403 Warsaw (iod@sorter.pl), who supervises compliance with the principles of processing and security of the Administrator’s personal data.

III. Rules for the collection of personal data of users

1) The Administrator, to the extent permitted by law, may collect information on the following. Users, using a variety of sources.

2) The Administrator, as a processor of personal data in the provision of services, obtains Users’ personal data primarily directly from its Customers or on the basis of contracts concluded with the Customers for the entrustment of the processing of personal data for the performance of the main contract for the provision of services.

3) The controller obtains personal data, in particular, in terms of:

• contact information (such as name, surname, address of residence/correspondence/business, e-mail and telephone number);
• business contact information (such as position, department and name of institution);
• VAT invoice requirements (such as NIP, REGON)
• content provided (such as photos, articles and comments).

IV. Processing of personal data

1) The controller shall ensure control over the type and scope of personal data processed, the period and manner of processing, and the persons authorised to process them.

2) The controller shall make the utmost effort to protect the information and personal data it collects.

3) The Administrator shall ensure adequate administrative, technical and physical protection of the personal data provided by the User against accidental, unlawful or unauthorised damage, loss, modification, access, disclosure or use.

4) The controller shall only retain personal data for as long as necessary to fulfil the purpose for which the personal data was collected, unless otherwise required by applicable law.

5) The controller shall take measures to destroy or permanently de-identify personal data if required by applicable law or if the personal data are no longer necessary for the purpose for which they were collected.

6) The administrator declares that:

• processes personal data in accordance with the law;
• collects personal data for specified, legitimate purposes and does not subject it to further processing incompatible with those purposes;
• shall keep personal data in a form which permits identification of data subjects for no longer than is necessary to achieve the purpose of the processing;
• the personal data are substantively correct and adequate in relation to the purposes for which they are processed.

7) Access to personal data is available to: The Administrator, its written authorised employees, associates and persons providing services to it. Access to personal data by the above-mentioned persons takes place only for the purpose and to the extent specified by the Administrator.

8) Administrator prowadzi ewidencję osób upoważnionych do ich przetwarzania. Persons who have been authorised to process data are obliged to keep the personal data and the means of securing them strictly confidential.

9) The controller and the persons authorised to process such data shall apply technical and organisational measures ensuring the protection of the personal data processed.

10) The data collected by the Administrator may be used, inter alia, to. for the following purposes:

• provision, administration and communication of services by the Administrator;
• risk assessment and improvement of the Administrator’s activities (including the development of the services provided, communication management, analysis and improvement of its services;
• newsletter mailing;
• estimating the Users’ interest in employment and contact regarding employment opportunities with the Administrator;
• as required by law or in connection with pending legal proceedings or in connection with a request by a public authority for access to information held by the Administrator;
• ensuring compliance with the provisions of personal data protection and internal regulations of the Administrator in this respect;
• performance of the employment contract, including the performance of duties specified in the legislation or collective agreements, management, planning and organization of work, equality and diversity in the workplace, occupational health and safety and for the purposes of individual or collective exercise of rights and benefits related to employment, as well as for the purpose of terminating the employment relationship;
• keeping records on matters relating to the employment relationship and maintaining employees’ personal files, and keeping the designated records and personal files in conditions that do not pose a risk of damage or destruction.

11) As part of the services provided by the Administrator, data will be processed only if at least one of the permissible legal grounds is available and only for the purpose adapted to a given basis, as described above. The data will be processed until there is a basis for the processing – that is, in the case of the granting of consent until it is withdrawn, limited or otherwise restricted, in the case of the necessity of the data for the performance of a contract – for the duration of its performance, and in the case where the basis for the processing is the legitimate interest of the Controller – for as long as that legitimate interest exists.

V. Sharing and delegation of the processing of personal data

1) The Administrator shall not share, sell or otherwise disclose the personal data collected about Users, except as described in the Policy or when this is required by generally applicable law.

2) The controller may entrust the processing of personal data to service providers acting on its behalf. In accordance with the agreements concluded with them for entrusting the processing of personal data, the Administrator requires from these service providers a high level of privacy protection and security of personal data processed by them on behalf of the Administrator in accordance with the law.

VI. Users’ rights

1) The user has the right to control the Administrator’s processing of data concerning him/her, in particular to obtain information on the purpose, scope and manner of data processing.

2) The User has the right to access his/her personal data, as well as to amend, supplement, rectify and update them, and to request their anonymisation, temporary or permanent suspension of their processing or their deletion if they are incomplete, outdated, untrue or have been collected in violation of the law, or their deletion under the terms of the law, with the proviso that the Administrator is entitled to further processing of personal data under the provisions of the law.

3) If the processing of personal data is based on the User’s consent, the User has the right to withdraw consent to the processing of his/her personal data by notifying the Administrator in writing. In such situations, the Administrator will adapt to the User’s decision in relation to future activities.

4) The user has the right – in cases provided for by law – to request the Administrator to stop processing his/her personal data, as well as to object to the processing of his/her personal data.

5) Requests for information, withdrawal of consent to the processing of personal data, as well as the exercise of other rights of the User resulting from the provisions of law should be made by sending an e-mail to the following address: marketing@sorter.pl

VII. Cookies and analysis software

1) The Controller, its service providers and business partners collect some information by automated means, such as cookies, when browsing the www.sorter.pl website.

The information collected in this way may include: IP address, browser type, operating system, URLs visited, as well as information regarding activities on the Administrator’s website. We encourage you to read the Administrator’s Cookie Policy available at: www.sorter.pl

2) The recipient of the cookie information is STALKO Spółka z ograniczoną odpowiedzialnością sp.k.

1. The www.sorter.pl website uses the so-called cookies. These are small text files placed on End Users’ devices (e.g. computers) via web browsers. These files allow certain information to be stored on the end user’s device and then read by the service that created the files. Cookies usually contain, in addition to the domain name of the originating website, the length of time they are stored on the terminal device and a unique number.
2. Cookies are used by us for:
   • to adapt the content of the website to the individual preferences of the user and to optimise the use of the website (cookies allow, in particular, the recognition of the device of the website user and the appropriate display of the website, so that it is best adapted to his individual needs),
   • maintain the session of the website user after logging in (this is extremely useful for the user, as it prevents the need to log in again (enter login and password) on each subsequent page of the website),
   • production of statistics.
3. The www.sorter.pl system does not store any information about the hardware configuration of the computer or programs installed on the User’s computer.
4. The IT system used by www.sorter.pl automatically collects data related to the device used by the User to connect to www.sorter.pl in logs. This data is collected only for statistical purposes and concerns: device type, operating system, type of web browser, screen resolution, color depth, IP, Internet service provider, or www.sorter.pl entry address in order to ensure the greatest possible convenience of use.
5. These data are never combined with the reported data referred to in Part III and only provide material for statistical analysis and mechanisms to correct system errors.
6. Usually, the User’s web browser allows cookies to be stored on the User’s terminal device by default. At any time, however, website users have the possibility and the right to change their cookie settings. In order to change the cookie settings, Users should refer to the detailed information on the possibilities and ways of handling cookies, which is available in the settings of their Internet browser.
7. If you do not agree to cookies being placed on your device, you can block them by configuring your web browser accordingly. He will find information on how to do this in the help files of his internet browser. Unfortunately, if you block cookies from the www.sorter.pl website, we cannot guarantee its correct operation.
8. If the User does not change their cookie settings, the cookies will be stored on the User’s terminal equipment. This means that we will store information on your end device and access this information.
   Notwithstanding the above, we inform you that www.sorter.pl uses Google Analytics technology.
9. If you have any questions or concerns about the privacy policy and the security of your personal data, we encourage you to contact us via e mail: iod@sorter.pl

3) The use of the website www.sorter.pl does not require you to log in, create an account or enter your data, except for the use of forms. In order to monitor the website www.sorter.pl, the Administrator may use analysis software belonging to third parties, such as. Google Analytics. Google Analytics can be disabled by using a browser extension that can be downloaded from the following page: https://tools.google.com/dlpage/gaoptout.

4) For more information on the cookies used by Google Analytics, which is an online tool used to analyse website statistics (including demographic and interest reports), please see the Google Analytics Privacy Policy.

5) For convenience and to provide Users with additional information, the www.sorter.pl website contains links to websites administered by entities independent of the Administrator. They may have separate clauses or privacy policies in place. The administrator encourages you to familiarise yourself with their content. With regard to any websites linked to the Website that are not owned or controlled by the Administrator, the Administrator does not accept any responsibility for their content, the Users’ use of these websites or the confidentiality protection rules applicable to them.

6) The website www.sorter.pl includes a registration form which allows customers to make a service request, sign up for the newsletter and agree to be contacted by phone and e-mail. The data collected in this way is mainly used to contact customers and fulfil commitments to them.

7) In particular, subscribing to the electronic and free newsletter issued by the Administrator requires the provision of an e-mail address in the relevant form. This field is mandatory.

The data obtained in the aforementioned manner is added to the e-mailing list. An e-mail address is necessary in order to be able to send the reader the newsletter he or she has requested.

8) Customer contact information is also used to contact customers when necessary (e.g. when an order needs to be confirmed). At any time, users of the Services who have subscribed to the newsletter have the option to unsubscribe.

9) The legal basis for the processing of your personal data in the case of the newsletter is the consent of the customer expressed by ticking the relevant checkbox when signing up for the newsletter. Such consent can be withdrawn at any time by unsubscribing from the newsletter.

10) Through the website www.sorter.pl – tab ,,Career”, recruitment of new employees, trainees, apprentices, partners for the Administrator can be carried out. The personal data obtained in this way is used exclusively for the purposes of recruitment for current and future recruitment processes. By filling in the application, the User agrees to participate in the current and future recruitment processes conducted by the Administrator in accordance with the provisions of the Act of 29 August 1997. on the protection of personal data. This consent applies to all documents submitted as part of recruitment processes.

11) Other information is used to determine the profile of people using the websites and ordering newsletters and allows for better adaptation of the content of the website and the newsletter to the needs of people using this form of information.

Their processing, however, is always carried out in accordance with the provisions of the Personal Data Protection Act and the Act of 18 July 2002. on the provision of services by electronic means (Journal of Laws No. 144, item 1204, as amended) and the Act of 16 July 2004. Telecommunications Law.

VIII. Changes and updates to the Policy

The policy may be modified from time to time. The modifications are intended to address changes in the Administrator’s practices regarding the handling of personal data and to strengthen the Administrator’s data protection regime.

Significant changes to the Policy will be signalled by clearly visible notices posted on the Website. At the top of the Policy content page, there will be an indication of the date of the latest update of the Policy.

IX. Contact

You may contact the Administrator or the Data Protection Officer (iod@sorter.pl) at any time to obtain information about whether and how the Administrator uses or intends to use your personal data, as well as if you have any questions or comments about this Policy.