PRIVACY POLICY
1. This Privacy Policy shall define the rules for the processing of personal data obtained through the website www.neuronic.com.pl (hereinafter referred to as: “the Online Service”).

2. The owner of the Online Service and also the controller of the data shall be PANKOWSKI BARTŁOMIEJ “SET” with its registered office in ul. Polna 05-500 Mysiadło, Poland, tax identification number (NIP): 948-15-81-445, National Business Registry number REGON 012859776, hereinafter referred to as SET B.Pankowski.

3. The personal data gathered by SET B.Pankowski through the Online Service shall be processed in accordance with the 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), also referred to as the GDPR.

4. SET B.Pankowski shall exercise due diligence to respect the privacy of Users visiting the Online Service.

Article 1 The type of data to be processed, purposes and legal ground

1. SET B.Pankowski shall gather information relating to natural persons conducting business or professional activity on their own behalf and natural persons representing legal persons or organisational units other than legal persons which are given legal capacity under the act, conducting business or professional activity on their own behalf, hereinafter jointly referred to as the Users.

2. Personal data of the Users shall be gathered in the following situations:
a) registering an account in the Online Service in order to create and manage an individual account. Legal ground: necessary for the performance of the Account service agreement (Article 6(1)(b) of the GDPR);
b) placing an order in the Online Service for the performance of a sales agreement. Legal ground: necessary for the performance of the sales agreement (Article 6(1)(b) of the GDPR);
c) subscribing to the Newsletter for the performance of an agreement whose subject matter is a service provided on-line. Legal ground – data subject’s consent for the performance of the Newsletter service agreement (Article 6(1)(a) of the GDPR);
d) using the contact form service in the Online Service for the performance of an agreement provided on-line. Legal ground: necessary for the performance of the contract form service agreement (Article 6(1)(b) of the GDPR).

3. In case of registering an account in the Online Service, the User shall provide:
a) his/her e-mail address;
b) contact details:
a. post code and town/city;
b. street name and flat/house number;
c) first and last name;
d) telephone number.

4. In case of Entrepreneurs, the above data scope shall also include:
a) business name of the Entrepreneur;
b) tax identification number NIP.

5. While registering an account on the Website, the User shall independently set an individual password to gain access to his/her account. The User may later change the password in accordance with the principles specified in Article 5.

6. While placing an order in the Online Service, the User shall provide the following data:
a) his/her e-mail address;
b) contact details:
a. post code and town/city;
b. street name and flat/house number;
c) first and last name;
d) telephone number.

7. In case of Entrepreneurs, the above data scope shall also include:
a) business name of the Entrepreneur;
b) tax identification number NIP.

8. In case of using the Newsletter service, the User shall only provide his/her e-mail address.
9. In case of using the contact form service, the User shall provide the following data:
a) his/her e-mail address;
b) first and last name;
c) business name of the Entrepreneur;
d) tax identification number NIP;
e) address for sending invoices;
f) address for sending sticky traps;
g) contact telephone number.

11. Navigation data, including information about links and references, which they decide to click and other activities taken in our Online Service can be also gathered from the Users. Legal ground – legitimate interest (Article 6(1)(f) of the GDPR) consisting in facilitating the use of the services provided on-line and improving the functionality of such services.

12. For the establishment, pursuit and enforcement of claims, there may be processed some personal data given by the User as part of using the functionality in the Online Service, such as: first name, last name, data relating to the use of the services, if the claims result from the manner in which the User uses the services, other data necessary to prove the claim, including the extent of incurred damage. Legal ground – legitimate interest (Article 6(1)(f) of the GDPR) consisting in the establishment, pursuit and enforcement of claims and defence against claims in the proceedings before courts and other state authorities.

13. The provision of personal data to SET B.Pankowski shall be voluntary, in connection with the concluded sales agreements, or the provision of services through the Online Service Website, with a stipulation, however, that failure to provide the data specified in the forms during the Registration process shall render impossible the Registration and creating the User Account, while in case of placing an order without Registration of the User Account, it shall render impossible the placement and execution of User’s order.

Article 2 Who the data are made available or entrusted to and how long are they kept?

1. The personal data of the User shall be provided to service providers used by SET B.Pankowski while running the Online Service. The service providers whom the personal data are provided to, depending on contractual arrangements and the circumstances, shall be either subject to SET B.Pankowski’s instructions as regards the purposes and means of the processing of such data (the processors) or shall independently determine the purposes and means of their processing (controllers).

a) The Processors. SET B.Pankowski shall use providers who process the personal data only at SET B.Pankowski’s request. They shall include, inter alia, the providers of the hosting service, accounting services, systems for marketing, systems for the Online Service traffic analysis, systems for assessing the effectiveness of marketing campaigns.

b) The Controllers SET B.Pankowski shall use providers who do not only act at the request, but on their own determine the purposes and means of using the personal data of the Users. They shall provide the electronic payment and banking services.

2. Location. The service providers shall have their registered offices mainly in Poland and other countries of the European Economic Area (EEA).

3. The personal data of the Users shall be stored:
a) In case when the processing of personal data is based on consent, then the User’s personal data shall be processed by SET B.Pankowski for as long as the consent is not withdrawn, and after withdrawal of the consent, for a period corresponding to the statute of limitation on claims that may be lodged by SET B.Pankowski and that may be lodged against SET B.Pankowski. Unless a specific regulation provides otherwise, the statute of limitation shall be six years and for claims concerning periodical performances and claims connected with conducting business activity – three years.

b) In case when the processing is based on performance of an agreement, then the User’s personal data shall be processed by SET B.Pankowski for as long as it is necessary for the performance of the agreement, and after this period for a period corresponding to the statute of limitation on claims. Unless a specific regulation provides otherwise, the statute of limitation shall be six years and for claims concerning periodical performances and claims connected with conducting business activity – three years.

4. The navigation data may be used in order to ensure better service for the Users, carry out statistical data analyses and adapt the Online Service to the preferences of the Users as well as to administer the Online Service.

5. If the User subscribes to the Newsletter, SET B.Pankowski shall send to his or her e-mail address e-mails containing commercial information about promotions and new products available in the Online Service.

6. If such a request is submitted, SET B.Pankowski shall make the personal data available to the authorised state bodies, in particular the Prosecutor’s Office units, the Police, the President of the Personal Data Protection Office, the President of the Office for Competition and Consumer Protection and the President of the Office of Electronic Communications.

Article 3 Cookie mechanism, IP address
1. The Online Service shall use small files called cookies. They shall be stored by SET B.Pankowski on the terminal device of a person visiting the Online Service, if the browser allows it. A cookie file shall typically contain the name of the domain from which the cookie has come from, the “lifetime” and an individual randomly generated number identifying the file. Information gathered by means of this type of files help to adapt the products offered by SET B.Pankowski to individual preferences and actual needs of persons visiting the Online Service. They shall also allow to prepare general statistics of visits to products presented in the Online Service.

2. SET B.Pankowski shall use two types of cookie files:
a) Session cookies: after the end of a given browser session or after turning off the computer, the stored data are deleted from the device’s memory. The mechanism of the session cookies does not allow to collect any personal data or any confidential information from the User’s computer.
b) Persistent cookies: are stored in the memory of the User’s terminal device until they are deleted or until they expire. The mechanism of the persistent cookies does not allow to collect any personal data or any confidential information from the User’s computer.

3. SET B.Pankowski shall use its own cookies for:
a) authenticating the User in the Online Service and ensuring the User’s session in the Online Service (after signing in), thanks to which the User does not have to enter his/her username and password on each Online Service subsite;
b) analyses, surveys, traffic audit, and in particular for creating anonymous statistics which help to understand how the Users use the Online Service Website, which allows to improve its structure and content.

4. SET B.Pankowski shall use external cookies for:
a) presenting in the Online Service information websites a map showing the location of SET B.Pankowski office through the website maps.google.com (the administrator of external cookies: Google Inc with its registered office in the USA);
b) presenting in the Online Service websites the multimedia content collected from the external website www.youtube.com (the administrator of external cookies: YouTube, LLC. with its registered office in the USA);

d) gathering general and anonymous statistical data through analytical tools Google Analytics (the administrator of external cookies: Google Inc with its registered office in the USA);
e)
5. The cookie mechanism shall be safe for the computers of the Online Service Users. In particular, in this way no virus nor any other unwanted software or malware can gain access to the User’s computer. Nevertheless, the Users’ browsers offer an option to limit or block cookie files from gaining access to their computers. If this option is used the use of the Online Service will be possible except for the functions which, given their nature, require cookie files.

6. Below please find ways of changing the settings of popular web browsers as regards the use of cookie files:
a) Internet Explorer web browser;
b) Microsoft EDGE web browser;
c) Mozilla Firefox web browser;
d) Chrome web browser;
e) Safari web browser;
f) Opera web browser.

7. SET B.Pankowski may gather IP addresses of the Users. The IP address is a number assigned by the Internet Service Provider to the computer of the person visiting the Online Service. The IP number gives access to the Internet. In most cases, it is assigned to a computer on a dynamic basis, i.e. it changes whenever the User connects to the Internet. The IP address is used by SET B.Pankowski to diagnose technical problems with the server, create statistical analyses (e.g. to determine the regions from which we get most visits), in the form of information useful for the administration and management of the Online Service as well as for the purposes of safety and potential identification of an unwanted automated software for browsing the content of the Online Service that places excessive load on the server.

8. The Online Service contains links and references to other websites. SET B.Pankowski shall not be held liable for the principles of privacy protection applied there.

Article 4 The rights of the data subjects
1. The right to withdraw consent – legal ground: Article 7(3) of the GDPR.
a) The User shall have the right to withdraw his or her consent granted to SET B.Pankowski.
b) The withdrawal of consent shall take effect from the moment of withdrawal of consent.
c) The withdrawal of consent shall not affect the lawfulness of processing by SET B.Pankowski based on consent before its withdrawal.
d) The withdrawal of consent shall not entail any negative consequences for the User, it may prevent, however, further use of the services or functionalities which may be lawfully provided by SET B.Pankowski only upon obtaining consent.

2. The right to object to data processing – legal ground: Article 21 of the GDPR.
a) The User shall have the right to object at any time – on grounds relating to his or her particular situation – to processing of personal data concerning him or her, including profiling, if SET B.Pankowski processes his or her data based on a legitimate interest, e.g. marketing of SET B.Pankowski products and services, maintaining statistics of the use of individual functionalities of the Online Service and facilitating the use of the Online Service as well as satisfaction measurement.
b) Resigning through an e-mail from receipt of marketing communications relating to products and services shall be deemed the User’s objection to the processing of his or her personal data, including the profiling for such purposes.
c) If the User’s objection is reasonable and SET B.Pankowski has no other legal ground to process the personal data, the User’s personal data, to the processing of which the User objects, shall be deleted.

3. The right to erasure (“the right to be forgotten”) – legal ground: Article 17 of the GDPR.
a) The User shall have the right to demand erasure of all or some of his or her personal data.
b) The User shall have the right to demand the erasure of his or her personal data, if:
a. the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b. the data subject withdraws consent to the extent to which the processing was based on his or her consent;
c. the data subject has objected to the processing of his or her data for marketing purposes;
d. the personal data have been unlawfully processed;
e. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which SET B.Pankowski is subject;
f. the personal data have been collected in relation to the offer of information society services.
c) Despite the demand to erase the personal data in connection with objection or withdrawal of consent, SET B.Pankowski may keep some personal data to the extent that the processing is necessary to establish, pursue and enforce claims, as well as to perform the legal obligation of processing under the Union or Member State law to which SET B.Pankowski is subject. This shall apply in particular to such personal data as: first name, last name, e-mail address, which are kept for the purpose of examining complaints and other claims relating to the use of SET B.Pankowski services and, additionally, residence/correspondence address, order number, which are kept for the purpose of examining complaints and claims relating to the concluded sales and service provision agreements.

4. The right to restriction of data processing – legal ground: Article 18 of the GDPR.
a) The User shall have the right to restriction of the processing of his or her data. Making such a demand prevents, until it is examined, the use of certain functionalities or services the use of which involves the processing of data covered by the demand. Besides, SET B.Pankowski shall not send any communications, including marketing communications.
b) The User shall have the right to demand restriction of the use of his or her personal data where one of the following applies:
a. the accuracy of the personal data is contested by the User – then SET B.Pankowski shall restrict the use thereof for a period enabling it to verify the accuracy of the data, no more, however, than 7 days;
b. the processing is unlawful and the User opposes the erasure of the personal data and requests the restriction of their use instead;
c. the personal data are no longer needed for the purposes for which they have been gathered or used, but they are required by the User for the establishment, pursuit or enforcement of claims;
d. the User has objected to the use of his or her data – then the restriction shall be applied for the period necessary to consider whether – due to the special situation – the protection of the interests, rights and freedoms of the User overrides the interests pursued by the Controller through the processing of the User’s personal data.

5. The right of access to the data – legal ground: Article 15 of the GDPR.
a) The User shall have the right to obtain from the Controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, the User shall have the right:
a. to access his or her personal data;
b. to obtain information on the purpose of the processing, categories of the personal data processed, recipients or categories of recipients of such data, the envisaged period for which the User’s data will be stored or on the criteria used to determine that period (when it is not possible to determine the envisaged period for which the data will be processed), the rights vested in the User under the GDPR and on the right to lodge complaints with the supervisory bodies, on the source of such data, the existence of automated decision-making, including the profiling, and on safeguards used in connection with the transfer of such data outside the European Union;
c. to obtain a copy of his or her personal data.

6. The right to rectification – legal ground: Article 16 of the GDPR.
a) The User shall have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the User who is the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement, by sending a request to the e-mail address in accordance with Article 6 of the Privacy Policy.

7. The right to data portability – legal ground: Article 20 of the GDPR.
a) The User shall have the right to receive the personal data concerning him or her, which he or she has provided to the Controller and to transmit such data to another controller of personal data selected by the User. The User shall also have the right to have the personal data transmitted directly by the Controller to such controller, where technically feasible. In this case, the Controller shall send the personal data of the User in the CSV file format, which is a commonly used, machine-readable format that allows for the transmission of the received data to another personal data controller.
8. If the User submits a request resulting from the above mentioned rights, SET B.Pankowski shall immediately fulfil or refuse to fulfil the request, not later however than within a month of receipt thereof. If, however, due to a complex nature of the request or the number of requests, SET B.Pankowski is unable to fulfil it within a month, it shall fulfil the said request within the next two months and shall previously notify the User, within a month of receipt of the request, of the intended extension of the time limit and causes thereof.
9. The User may file with the Controller complaints, queries and requests relating to the processing of his or her personal data and the exercise of his or her rights.
10. The User shall have the right to demand from SET B.Pankowski the provision of copies of standard contractual clauses through a request sent in a manner specified in Article 6 of the Privacy Policy.
11. The User shall have the right to lodge a complaint with the President of the Personal Data Protection Office as regards infringement of his or her right to personal data protection or other rights granted thereto under the GDPR.

Article 5 Security management – password

1. SET B.Pankowski shall provide the Users with a secure encrypted connection during the transfer of personal data and during the signing in to the User Account in the Service. SET B.Pankowski shall use an SSL certificate issued by one of a leading world companies in the field of security and encryption of data sent across the Internet.
2. If the User having an account in the Online Service has lost his account password in any way, the Online Service offers an option to reset a new password. SET B.Pankowski never sends any password reminders. Passwords are stored in an encrypted form that prevents them from being read. In order to reset a new password, you have to provide your e-mail address in the access form under “I don’t remember my password” link available in the form for signing in to your account in the Online Service. To his or her e-mail address given during registration or saved during the most recent change of the account profile, the User will receive an e-mail redirecting to a dedicated form made available on the Online Service Website, where the User will be able to reset a new password.

Article 6 Amendments to Privacy Policy

1. The Privacy Policy may be amended and SET B.Pankowski shall notify the Users thereof 7 days in advance.
2. Should you have any questions relating to this Privacy Policy, please sent them to: panko@panko.pl
3. Last update: 19 February 2019