This Privacy Policy (hereinafter referred to as: “the Policy”) contains information regarding the processing of your personal data in relation to the use of services and delivery of the Newsletter through the website […] (hereinafter referred to as: “the Website”).

Any capitalized terms that have not been defined otherwise in the Policy shall have the meaning assigned to them in the Terms and Conditions available here: […].

Personal data administrator

The administrator of your personal data shall be Bartosz Grochulski who conducts business activity under the name “Merge Model Bartosz Grochulski” (address of the permanent place of business: ul. Jana Długosza 19, 86-300 Grudziądz), entered in to the Central Registration and Information on Business managed by the competent minister of economy, holder of NIP (Tax ID no.): 8762332414, REGON (National Business Registry Number): 388303636 (hereinafter referred to as: “the Administrator”).

Contact with the Administrator

For all matters related with the processing of personal data, you can contact the Administrator via electronic mail (e-mail address: […]).

Personal data protection measures

The Administrator utilizes advanced organizational and technical safety measures in order to ensure the best possible protection of your personal data and hereby guarantees that the data is processed in accordance with the provisions of the Regulation of the European Parliament and the Council (EU) 2016/679 of 27 April 2016 on protection of individuals with regard to processing of personal details and on free movement of such data and repeal to Directive 95/46/EC (the General Data Protection Regulation) (hereinafter referred to as: “the GDPR”), the act of 10 May 2018 on personal data protection and other regulations regarding protection of personal data.

Information on the processing of personal data

The use of the Service and delivery of the Newsletter require processing of your personal data. Below, you will find the detailed information on the purpose and legal basis of the processing as well as the period of the processing and the mandatory or voluntary provision thereof.

Profiling

In order to create your profile for marketing purposes and send you direct marketing that is adjusted to your preferences, the Administrator shall process your personal data in an automated way, including profiling – however, it shall not result in any legal consequences for you nor significantly affect your situation in a similar manner.

The scope of profiling of personal data is identical as the scope indicated above with regard to the analysis of your activity on the Website.

The legal basis for the processing of personal data for the above-mentioned purpose is Art. 6 section 1 letter f of the GDPR which stipulates that the Administrator can process personal data in order to implement their legally justified interest, which in this case is to conduct marketing activities adjusted to the recipients' preferences. Provision of the a/m personal data is voluntary but necessary for the implementation of the a/m purpose (if not provided, the Administrator will be unable to conduct marketing activities adjusted to the preferences of the recipients).

The Administrator shall process personal data for their profiling, until an effective objection is submitted or the purpose of the processing is fulfilled.

Personal data recipients

The recipients of the personal data can include the following third-party entities cooperating with the Administrator:

1. the hosting company;
2. the domain provider;
3. the electronic mail service provider;
4. the newsletter provider;
5. the companies providing tools used to analyze the activity on the Website and addressing direct marketing to its users (such as Google Analytics); 

Moreover, personal data can also be provided to public or private entities, if such an obligation results from the commonly applicable regulations of law, a binding court decision or a binding administrative decision. 

Transfer of personal data to a third country

In connection with the Administrator's use of the services provided by Google LLC, your personal data can be transferred to the following third countries: Great Britain, Canada, USA, Chile, Brazil, Israel, Saudi Arabia, Qatar, India, China, South Korea, Japan, Singapore, Taiwan (the Chinese Republic), Indonesia and Australia. The basis for the transfer of the data to the a/m countries is as follows:

• in the case of Great Britain, Canada, Israel and Japan - the decision of the European Commission on the relevant level of personal data protection in each of the a/m third countries;
• in the case of the USA, Chile, Brazil, Saudi Arabia, Qatar, India, China, South Korea, Singapore, Taiwan (the Chinese Republic), Indonesia and Australia -  the contractual clauses ensuring the proper level of protection, according to standard contractual clauses provided for in the Implementing Decision of the Commission (EU) 2021/914 of 4 June 2021 on standard contractual clauses for the transfer of personal data to third countries under the Regulation of the European Parliament and the Council (EU) 2016/679.

You can obtain a copy of the data transferred to the third country from the Administrator.

Rights

In connection with the processing of personal data, you shall have the following rights:

1. right to information on the type your personal data processed by the Administrator and the right to receive a copy of such data (the so-called access right). The issue of the first copy is free of charge. The Administrator may charge a fee for further copies;
2. if the processed data is outdated or incomplete (or incorrect in another way), you shall have the right to rectify it;
3. in some situations, you can contact the Administrator with a request to have your personal data removed e.g., when:
   1. the data is no longer needed by the Administrator for the purposes that they informed on;
   2. you effectively revoked the consent to data processing - provided that the Administrator does not have the right to process the data under a different legal basis; 
   3. the processing is illegal;
   4. the removal of data results from the legal obligation imposed on the Administrator;
4. in the case when personal data is processed by the Administrator under a given consent to the processing or for the purpose of performance of the Agreement concluded with the Administrator, you shall have the right to transfer your data to a different administrator;
5. in the case when personal data is processed by the Administrator under your consent to the processing, you shall have the right to revoke the consent at any time (revocation of the consent will not affect the lawfulness of the processing that was performed under the consent prior to its revocation);
6. if you decide that the processing of personal data is improper, its processing is illegal or that the Administrator no longer needs the specific data, you can demand from the Administrator to cease any operations on the data for a specific, necessary period (e.g. needed to verify the correctness of data or pursue claims) and only to store the said data;
7. you shall have the right to raise an objection to the processing of personal data that is processed under a legally justified interest of the Administrator. In case of an effectively submitted objection, the Administrator shall stop the processing of personal data for the a/m purpose;
8. should you decide that the processing of personal data infringes the provisions of the GDPR, you shall have the right to submit a complaint to the President of the Office of Personal Data Protection.

Cookie files

1. The Administrator would like to inform that the Website uses “cookie” files that are installed on your end device. Cookie files are small text files that can be read by the Administrator's system as well as systems of other entities whose services are used by the Administrator (e.g. Facebook, Google).
2. The Administrator uses cookie files for the following purposes:
   1. to ensure the proper functioning of the Website – cookie files ensure proper functioning of the Website, the use of its features and convenient switching between individual subpages;
   2. to increase the comfort of browsing the Website – thanks to cookie files, it is possible to detect errors on some subpages and to continuously improve them;
   3. to generate statistics – cookie files are used to analyze the manner in which the Website is used. This allows for continuous improvements of the Website and adjusting it to the preferences of the persons visiting it;
   4. to carry out marketing activity – thanks to cookie files, the Administrator can send the visitors advertisement that is adjusted to their preferences.
3. The Administrator may store on your device both permanent as well as temporary (session) files. Session files are usually removed when the browser is closed. However, closing the browser will not erase the permanent files.
4. The information on cookie files used by the Administrator is displayed in the panel in the bottom section of the Website. Depending on your decision, you may switch individual categories of cookie files on and off (except for the necessary cookie files) and change those settings at any time.
5. The Administrator is unable to identify you based on the data collected through cookie files.
6. The Administrator uses the following cookie files and tools which utilize them:

1. By using most of the common web browsers, you can check whether there have been any cookie files installed on your device as well as remove the installed cookie files or block their installation by the Website in the future. However, turning off or limiting the operation of cookie files can cause serious difficulties in using the Website.

Final Provisions

For matters not regulated by the Policy, the commonly applicable regulations on protection of personal data shall apply. 

The Policy shall be valid from […].