Information on the processing of personal data of natural persons using the lubsta.pl online service
WHO ACTS AS THE PERSONAL DATA CONTROLLER
The following company acts as the controller of the personal data collected as part of the lubsta.pl online service (hereinafter: the Controller), i.e. as the entity responsible for ensuring the safety of your personal data:
LUBSTA Spółka z ograniczoną odpowiedzialnością [limited liability company] with its registered office in Lublin, ul. Garbarska 18, 20-340 Lublin, registered by the Lublin-Wschód District Court in Lublin, with its registered office in Świdnik, 6th Economic Division of the National Court Register, entry No. 0000319760, NIP [Tax Identification Number]: 5050089393, REGON [business activity type]: 060429140.
You are hereby informed that the provision of your personal data is voluntary.
WHY WE PROCESS YOUR PERSONAL DATA AND TO WHOM WE PROVIDE THEM
Your personal data, i.e. the data you provide in connection with using our services, shall be:
1. stored on our server and/or external server;
2. provided to you when using you are using our online service;
3. used for profiling (more information to be found in the subsequent sections);
4. used for protecting the rights vested in you as a party to the contract, e.g. for processing your complaints;
5. used for marketing measures, e.g. for providing you with our commercial information (this does not apply to persons under the age of 18) ‒ such information can only be sent by e-mail if you have consented to doing so (this also applies to persons under the age of 18);
6. used for issuing sales documents;
7. stored in our contract performance, accounting and fiscal documentation (available in electronic or paper format);
8. disclosed to our subcontractors and companies providing us with marketing, IT, profiling, accounting, legal, debt-collection, payment, bank and other business support services, when such disclosure is deemed necessary;
9. used for determining, securing and legally pursuing your or our claims;
10. used for making compilations, analyses and statistics for our internal purposes, including in particular reports, marketing surveys, the planning of sales of goods and services, development work in IT systems, and the creation of statistical models.
We shall process such data for the afore-mentioned purposes as it is necessary to fulfil our legal obligations (e.g. settlements with contractors and tax obligations), to conduct marketing and statistical activities within our economic interest, and to protect our rights as arising from the contract concluded with you.
We shall remove the said data after 3 months of the last processing purpose ceasing to apply. In the meantime, we shall cease personal data processing for the following purposes, within the following time frames:
1. data used for performing the concluded contract shall cease to be processed for this purpose after 3 months of the contract's being fulfilled or otherwise terminated;
2. data processed in connection with fulfilling our legal obligation shall cease to be processed after 3 months of the expiry of this obligation;
3. data processed for the purpose of protecting our legal interest shall cease to be processed after 3 months of the expiry of the legal processing interest, whereas data serving the purpose of determining, securing and legally pursuing claims by you or us shall cease to be processed after 3 months of the limitation of your claims, or after 3 months of the expiry of our claims, whichever occurs later;
4. data used for our marketing purposes shall cease to be processed after 18 months of their last use (except if you grant your express consent to the processing of personal data for marketing purposes);
5. data serving the specific correspondence exchange purposes shall cease to be processed after 3 months of the last correspondence regarding a given matter;
6. data used for providing you with commercial information by e-mail (subject to your prior consent) shall cease to be processed after 60 months of our last contact with you.
YOUR PERSONAL DATA OBTAINED FROM OTHER SOURCES
If you make or receive payments (e.g. in the invoice settlement process), for instance, by hand of a bank or payment institution, we shall obtain information on the account and institution used to make any such payment, or to receive such payment from us. We shall process these data with the aim of verifying whether the payment has been made, recorded and settled properly, and, when necessary, also to make a return payment.
We may also obtain your data from generally-accessible registers, record, etc., for the afore-mentioned purposes (e.g. for contract conclusion/performance, the fulfilment of statutory accounting/archiving duties, the pursuing of our claims or the protection against your or third-party claims, marketing, or correspondence exchange between you and us). We shall process such data for the afore-mentioned purposes as it is necessary to perform our contract concluded with you, to fulfil our legal obligations (e.g. tax obligations), to protect our rights as arising from the contract concluded with you, and also to create statistics and analyses within our economic interest.
DATA, INCLUDING PERSONAL DATA COLLECTED AUTOMATICALLY THROUGH OUR IT SYSTEMS
The IT system used by the www.lubsta.pl online service automatically collects data in data logs, regarding the device used for connecting with www.lubsta.pl. Such data are gathered only for statistical purposes and concern the device type, the operating system, the browser type, screen resolution, colour depth, IP, the Internet service provider or the point of entry to www.lubsta.pl. They are only used for the www.lubsta.pl optimisation purposes, to ensure the highest user comfort.
Such data are never combined with the data provided by you, and they are only used for statistical analyses and system error correction mechanisms.
Such data can be processed for the aforementioned purposes as it is necessary to improve the quality and efficiency of our operations.
COOKIES
• LUBSTA.PL
The online service uses “cookies,” i.e. text files stored on your device for the purpose of identifying the Client and adjusting the service to your needs.
The www.lubsta.pl online service uses cookies for:
1. remembering the display preferences;
2. creating viewing statistics and reports.
• GOOGLE ANALYTICS (COOKIES)
Google Analytics uses “cookies,” i.e. text files stored on your device for the purpose of analysing the traffic sources by the online service, and the ways the service is used by the visitors.
Google stores the data collected through the cookie files stored on user devices on its servers and uses such information to create reports, and to render other services related to Internet traffic and use. Google can also transfer such information to third parties when required under the applicable regulations or when these parties process such information on behalf of Google. Such data are never combined with the data provided by you, and they are only used for statistical analyses and system error correction mechanisms.
• GOOGLE ADWORDS (COOKIES)
Google AdWords uses “cookies,” i.e. text files stored on your device for the purpose of enabling lubsta.pl to assess the correctness and efficiency of the advertising activities conducted using the AdWords network.
Google stores the data collected through the cookie files stored on user devices on its servers and uses such information to create reports, and to render other services related to Internet traffic and use. Google can also transfer such information to third parties when required under the applicable regulations or when these parties process such information on behalf of Google. Such data are never combined with the data provided by you, and they are only used for statistical analyses and system error correction mechanisms.
If you do not consent to placing cookies on your device, you can block them by adequately configuring your browser. You can do this by following the instruction outlined in the user's Internet browser help. Unfortunately, when you block the Google cookie files, we cannot guarantee the correct functioning of our online service.
If you consent to placing Google cookie files on your device but, after visiting our online service, you would like to remove them, you can do so without any risk by following the instruction outlined in the user's Internet browser help documents.
WHAT RIGHTS YOU HAVE IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA BY OUR COMPANY
You are at any time entitled to:
1. rectify (correct) any incorrect data or supplement incomplete data;
2. restrict the processing (discontinue operations performed on your data or request non-removal, in accordance with your request);
3. obtain access to data (including to information on the data we process, processing purposes, data recipients or recipient categories) or data copies;
4. transfer your data to a different data controller;
5. remove your personal data (“the right to be forgotten”) under any of the circumstances described in Article 17 (1) (a)-(f) of GDPR, with the exceptions listed in Article 17 (3) of GDPR.
You can exercise any of these rights by submitting the relevant request by e-mail to biuro@lubsta.pl or in any other way.
In order for us to make sure that you are authorised to make the request, you may be asked to provide additional data for applicant authentication purposes. The scope of all such rights, and the circumstances in which they can be exercised, arises from legal regulations. The right which you may exercise shall depend, inter alia, on the legal basis on which we use your personal data, and on the data processing purpose. This means that, under certain circumstances, we may refuse to grant your request. In such cases, the reasons for our decision shall be explained to you, along with the relevant legal basis. In any case, we shall promptly provide you with the necessary clarifications and assistance with exercising your rights.
RIGHT TO OBJECT
Regardless of the aforementioned rights, you may at any time object to the processing of your personal data for direct marketing purposes. Following the receipt of your request made to this end, we shall cease to process your personal data for such purposes. In exceptional cases, you may at any time object to the processing of your personal data by our company if the legal basis for doing so stems from our legitimate interest or public interest. In this event, having considered your request, we shall no longer be able to process the personal data to which the objection refers on that basis unless we prove that there are:
1. significant legally justifiable bases to process such data, which prevail over your interests, rights and freedoms, in compliance with the law;
2. grounds to determine, secure and pursue claims.
CONSENT
If the use of your personal data is not required to fulfil the contract or legal obligation, and does not constitute our legitimate interest, we may seek your consent to employing certain methods of using your personal data. Such consent can allow us, inter alia, to transfer your data to other entities for their publicity actions, or to make automatic decisions based on your data and at your request. The consent, once granted, can be withdrawn at any time (which shall not impact the legal compliance of the use of your personal data prior to such withdrawal).
When requesting your consent, we shall also indicate the simplest mode of its withdrawal.
COMPLAINT
Please note that you also have the right to lodge a complaint with the President of the Office for Personal Data Protection if you believe that the processing of your personal data violates the law.
We guarantee that our company abides by a restrictive personal data safety policy. Your data are safe with us and we make our best efforts to increase the safety level each year. We believe that, once you familiarise yourself with our privacy policy, you will feel at ease.
HOW WE PROTECT YOUR PERSONAL DATA
The most important elements of our personal data protection system are as follows:
Access to your personal data is only granted to those employees of LUBSTA Sp. z o.o. who have undergone training in compliance with the personal data safety policy and signed the adequate undertakings to protect such data.
The IT systems utilised by the www.lubsta.pl online service meet all the applicable personal data protection standards.
We have taken the adequate technical and organisational measures ensuring the protection of the processed data, in compliance with our risk assessment and the requirements stipulated in the Regulation of the Minister of the Interior and Administration of 29 April 2004 on the documentation of the processing of personal data, and the technical and organizational conditions which should correspond to the devices and information systems for personal data processing (Journal of Laws No. 100, item 1024), and in the guidelines of the General Personal Data Protection Inspector.
The controller has satisfied all the personal data protection obligations as stipulated in the law.
Please note that your consent to the processing of your personal data by our company is not required when:
1. you demand us to conclude a contract, providing your personal data to this end;
2. this proves necessary to implement the contract concluded between you and us;
3. this proves necessary for us to fulfil our legal obligations, e.g. connected with issuing an invoice, or keeping the accounting or tax documentation;
4. this proves necessary for conducting our marketing activities, e.g. direct marketing, or for showing you the content adjusted to your profile (this does not concern persons below the age of 18).
If you choose not to provide us with the data indispensable for the aforementioned activities, we shall not be able to perform them.
PARTNER SAFETY AND PRIVACY POLICY
LUBSTA.PL chooses its business partners with extreme care and carefully verifies the links placed in the online service. However, it cannot be held liable for the privacy protection standards and policies used by the owners, operators or administrators of such websites. Therefore, we recommend that you independently verify all of our partners whose links are included in the online service, and make your own decision whether you want to provide them with your data for processing, or not.
PROCESSING ENTRUSTMENT
We guarantee that, under any agreements concluded, we oblige all the entities entrusted with the processing of your data on our behalf (e.g. accounting offices) to comply with the principles and standards as arising from the binding regulations.
AMENDMENTS TO THE DATA CONTROLLER'S PRIVACY POLICY
LUBSTA sp. z o.o. reserves the right to amend the privacy policy if the binding law so requires, or if the technological conditions of the online service operation are changed, or if such amendments introduce a standard higher than the legally required minimum. LUBSTA sp. z o.o. shall notify the users of any such amendments via the online service.
CONTACT
LUBSTA.PL shall contact you via the e-mail address provided. In exceptional cases we shall use the phone number provided by you.
Should you have any questions or doubts regarding our privacy policy or the safety of your personal data, feel free to contact us by phone: +48 81 748 75 56, or by e-mail: biuro@lubsta.pl.
You can also write to us in the reference matter, using the following address:
LUBSTA Sp. z o.o.
ul. Mełgiewska 74
20-340 Lublin
This privacy policy has been in force since 25 May 2018.