The following Privacy Policy defines the rules for storing and accessing data on Users’ Devices using the Service for the purpose of providing electronic services by the Administrator and the rules for collecting and processing Users’ personal data, which have been provided by them personally and voluntarily through the tools available in the Service.

The following Privacy Policy is an integral part of the Service Regulations, which define the rules, rights, and obligations of Users using the Service.

§1 Definitions

  • Service – the “Grocholski.pl” website operating at https://Grocholski.pl
  • External Service – websites of partners, service providers, or service recipients cooperating with the Administrator
  • Service/Data Administrator – the Service Administrator and Data Administrator (hereinafter Administrator) is a natural person “Henryk Grocholski” residing in Warsaw, providing electronic services via the Service
  • User – a natural person for whom the Administrator provides electronic services via the Service.
  • Device – an electronic device with software through which the User gains access to the Service
  • Cookies – text data collected in the form of files placed 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, and repealing Directive 95/46/EC (General Data Protection Regulation)
  • Personal Data – means information about an identified or identifiable natural person (“data subject”); an identifiable natural 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 factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person
  • Processing – means an operation or set of operations which is performed on personal data or on 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 – means the marking of stored personal data with the aim of limiting their processing in the future
  • Profiling – means 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 natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements
  • Consent – consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them
  • Personal Data Breach – means 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 – means the processing of personal data in such a way 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 that the personal data are not attributed to an identified or identifiable natural person
  • Anonymization – Data anonymization is an irreversible process of operations on data that destroys/overwrites “personal data” preventing identification or linking a given record with a specific user or natural person.

§2 Data Protection Officer

Pursuant to Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

In matters concerning 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 Service’s teleinformation system
  • External Cookies – files placed and read from the User’s Device by teleinformation systems of External Services. Scripts of External Services that may place Cookies on Users’ Devices have been consciously placed in the Service through scripts and services made available and installed in the Service
  • Session Cookies – files placed and read from the User’s Device by the Service or External Services during a single session of the given Device. 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 Service or External Services until they are manually deleted. Files are not deleted automatically after the Device session ends unless the User’s Device configuration is set to the mode of deleting Cookie files after the Device session ends.

§4 Data Storage Security

  • Mechanisms for storing and reading Cookie files – The mechanisms for storing, reading, and exchanging data between Cookie Files saved on the User’s Device and the Service are implemented through built-in web browser mechanisms and do not allow for retrieving other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, trojans, and other worms to the User’s Device is also practically impossible.
  • Internal Cookies – Cookies used by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the Device used by the User.
  • External Cookies – The Administrator takes all possible measures to verify and select service partners in the context of User security. The Administrator selects well-known, large partners with global social trust for cooperation. However, he does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the security of Cookie files, their content, and their use in accordance with the license by Scripts installed in the service, originating from External Services, to the extent permitted by law. The list of partners is included later in the Privacy Policy.
  • Cookie Control
  • Threats on the User’s side – The Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of these data depends on both parties, including the User’s activities. The Administrator is not responsible for intercepting this data, impersonating the User’s session, or deleting it due to the conscious or unconscious activity of the User, viruses, trojans, and other spyware that may or have infected the User’s Device. Users should follow network usage rules to protect themselves from these threats.
  • Storage of personal data – The Administrator ensures that he makes every effort to ensure that personal data voluntarily provided by Users is secure, access to them is limited and carried out in accordance with their purpose and processing objectives. The Administrator also ensures that he makes every effort to secure the data he holds against loss by using appropriate physical and organizational safeguards.

§5 Purposes for which Cookies are used

  • Improvement and facilitation of access to the Service
  • Personalization of the Service for Users
  • Enabling login to the service
  • Marketing, Remarketing in external services
  • Advertising services
  • Affiliate services
  • Conducting statistics (users, number of visits, types of devices, connection, etc.)
  • Serving multimedia services
  • Providing social services

§6 Purposes of processing personal data

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

  • Provision of electronic services:
    • Registration and maintenance of a User account in the Service and related functionalities
  • Communication of the Administrator with Users on matters related to the Service and data protection
  • Ensuring the legitimate interest of the Administrator

Data about Users collected anonymously and automatically are processed for one of the following purposes:

  • Conducting statistics
  • Remarketing
  • Serving ads tailored to Users’ preferences
  • Support for affiliate programs
  • Ensuring the legitimate interest of the Administrator

§7 Cookies of External Services

The Administrator uses javascript scripts and web components of partners in the Service who may place their own cookies on the User’s Device. Remember that in your browser settings you can decide on the allowed cookies that can be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

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

§8 Types of data collected

The Service collects data about Users. Some data is collected automatically and anonymously, and some data is personal data voluntarily provided by Users during registration for individual services offered by the Service.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Opened subpages of the service
  • Time spent on the appropriate subpage of the service
  • Type of operating system
  • Address of the previous subpage
  • Referring page address
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected during registration:

  • Email address
  • IP address (collected automatically)

Data collected during registration for the Newsletter service

  • Email address

Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to the statistical services 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 services provided are not transferred or resold to third parties.

Entities responsible for maintaining the infrastructure and services necessary to run the service may have access to the data (usually based on a Data Processing Agreement):

§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., entering a comment or post), which will make the data available to anyone visiting the service.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) will 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 resold to third parties.

§11 Legal basis for processing personal data

The Service collects and processes Users’ data based on:

  • 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)
    • art. 6 sec. 1 lit. a
      the data subject has given consent to the processing of their personal data for one or more specific purposes
    • art. 6 sec. 1 lit. b
      processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract
    • art. 6 sec. 1 lit. f
      processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
  • Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)
  • Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)
  • 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 period of providing the Service by the Administrator. They are deleted or anonymized within 30 days from the end of the service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation that requires securing the legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User’s request for their deletion, for no longer than 3 years in the event of a violation or suspected violation of the service regulations by the User

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, is stored by the Administrator for the purpose of conducting service statistics for an indefinite period

§13 Users’ rights related to the processing of personal data

The Service collects and processes Users’ data based on:

  • Right of access to personal data
    Users have the right to access their personal data, exercised by a request submitted to the Administrator
  • Right to rectify personal data
    Users have the right to request from the Administrator the immediate rectification of personal data that is incorrect and/or completion of incomplete personal data, exercised by a request submitted to the Administrator
  • Right to erasure of personal data
    Users have the right to request from the Administrator the immediate erasure of personal data, exercised by a request submitted to the Administrator. In the case of user accounts, deletion of data involves anonymization of data enabling User identification. The Administrator reserves the right to withhold the execution of the data deletion request in order to protect the Administrator’s legitimate interest (e.g., when the User has violated the Regulations or the data was obtained as a result of conducted correspondence).
    In the case of the Newsletter service, the User can independently delete their personal data using the link included in each email sent.
  • Right to restrict processing of personal data
    Users have the right to restrict the processing of personal data in cases specified in Art. 18 GDPR, including questioning the correctness of personal data, exercised by a request submitted to the Administrator
  • Right to data portability
    Users have the right to obtain from the Administrator the personal data concerning the User in a structured, commonly used, machine-readable format, exercised by a request submitted 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 Art. 21 GDPR, exercised by a request submitted to the Administrator
  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority dealing with personal data protection.

§14 Contact to the Administrator

You can contact the Administrator in one of the following ways

  • Contact form – available at: /contact

§15 Service Requirements

  • Limiting the storage and access to Cookie files on the User’s Device may result in incorrect functioning of some of the Service’s features.
  • The Administrator bears no responsibility for incorrectly functioning Service features if the User restricts the possibility of saving and reading Cookie files in any way.

§16 External Links

In the Service – articles, posts, entries, or User comments may contain links to external websites with which the Site Owner does not cooperate. These links and the pages or files indicated by them may be dangerous for your Device or pose a security threat to your data. The Administrator is not responsible for the content located outside the Service.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to change this Privacy Policy at any time without notifying Users in the scope of using and processing anonymous data or using Cookie files.
  • The Administrator reserves the right to change this Privacy Policy at any time in the scope of processing Personal Data, about which he will inform Users with user accounts or subscribed to the newsletter service, via email within 7 days of the change. Continued use of the services signifies acceptance of the changes to the Privacy Policy. If the User does not agree with the changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
  • Introduced changes to the Privacy Policy will be published on this subpage of the Service.
  • Introduced changes take effect upon their publication.