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Privacy Policy of the ttms.pl website

  1. Definitions
    1. Administrator – means Transition Technologies MS S.A. with its registered office in Warsaw at Pawia 55, entered in the Register of Entrepreneurs kept by the District Court for the City of Warsaw in Warsaw, XII Economic Division of the National Court Register under KRS no.: 0000539306, REGON: 360679205, NIP: 5272728327.

    2. Personal Data - information about a natural person identified or identifiable by one or more factors specific to physical, physiological, genetic, psychological, economic, cultural or social identity, including device IP, Internet ID and information collected through cookies and other similar technology.

    3. Policy - this Privacy Policy.

    4. GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.

    5. Website - the website operated by the Administrator at ttms.pl

    6. User - any natural person visiting the Website or using one or more services or functionalities described in the Policy.

  2. Processing of Personal Data in connection with the use of the Site.
    1. In connection with the use of the Website by the User, the Administrator collects data to the extent necessary to provide the individual services offered. The detailed principles and purposes of the processing of Personal Data collected during use of the Website by the User are described below.

  3. Purposes and legal basis for the processing of Personal Data on the Website
    1. Use of the Website

      1. Personal Data of all persons using the Website is processed by the Administrator:

        1. in order to provide services electronically in terms of providing Users with access to the content collected on the Website - in which case the legal basis for the processing is the necessity of the processing for the performance of the agreement (Article 6.1.b GDPR);

        2. for the purpose of establishing and investigating claims or defending against claims - the legal basis for processing is the legitimate interest of the Administrator (Article 6.1.f GDPR), consisting in the protection of his/her rights.

    2. Contact form

      1. Administrator zapewnia możliwość skontaktowania się z nim przy wykorzystaniu elektronicznego formularza kontaktowego. Skorzystanie z formularza wymaga podania Danych osobowych niezbędnych do nawiązania kontaktu z Użytkownikiem i udzielenia odpowiedzi na zapytanie. Użytkownik może podać także inne dane w celu ułatwienia kontaktu lub obsługi zapytania. Podanie danych oznaczonych jako obowiązkowe jest wymagane w celu przyjęcia i obsługi zapytania, a ich niepodanie skutkuje brakiem możliwości obsługi. Podanie pozostałych danych jest dobrowolne.

      2. Personal data is processed in order to identify the sender and to handle his/her enquiry sent via the form provided - the legal basis of the processing is the necessity of the processing for the performance of the contract for the provision of the service (Article 6.1.b GDPR); with regard to the data provided optionally, the legal basis of the processing is consent (Article 6.1.a GDPR).

    3. Marketing

      1. The User's personal data may also be used by the Administrator to direct marketing content to the User by email or telephone. Such activities are only undertaken by the Administrator if the User has given his/her consent, which he/she may withdraw at any time.

      2. Personal data shall be processed:

        1. for the purpose of sending the requested commercial information - the legal basis for the processing, including with the use of profiling, is the legitimate interest of the Administrator (Article 6.1.f GDPR) in relation to the consent given;

        2. for analytical and statistical purposes - the legal basis of the processing is the Administrator's legitimate interest (Article 6.1.f GDPR), consisting of conducting analyses of Users' activity on the Website in order to improve the applied functionalities.

  4. Cookies
    1. The Administrator uses cookies on the Website. For the purposes and rules concerning the use of cookies, please refer to the Cookie Policy.

  5. Period of processing of Personal Data
    1. The period of data processing by the Administrator depends on the type of service provided and the purpose of the processing. As a general rule, data shall be processed for the duration of the service provided, until the withdrawal of the consent given or until an effective objection is made to the processing of the data in cases where the legal basis for the processing is the legitimate interest of the Administrator.

    2. The processing period may be extended where the processing is necessary for the establishment and assertion of possible claims or the defence against claims, and thereafter only where and to the extent required by law. After the expiry of the processing period, the data shall be irreversibly deleted or anonymised.

  6. Rights of the User
    1. The User has the right to access the content of the data and to request rectification, erasure, restriction of processing, the right to data portability and the right to lodge a complaint to the supervisory authority dealing with the protection of Personal Data.

    2. The User shall also have the right to object to data processing that is based on the legitimate interest of the Administrator.

    3. To the extent that the User's data is processed on the basis of consent, this consent may be withdrawn at any time by contacting the Administrator via e-mail at rodo@ttms.pl.

  7. Recipients of Personal Data
    1. In connection with the provision of the Webistes, Personal Data will be disclosed to external entities, including in particular IT service providers enabling the correct use of the Website.

    2. In the case of obtaining the User's consent, his/her data may also be disclosed to other entities for their own purposes, including marketing purposes.

    3. The Administrator reserves the right to disclose selected information concerning the User to the competent authorities or to third parties, who will submit a request for such information on the basis of the relevant legal basis and in accordance with the provisions of the applicable law.

  8. Transfer of Personal Data outside the EEA
    1. The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Administrator transfers Personal Data outside the EEA only when necessary and with an adequate level of protection, primarily by:

      1. cooperating with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued as to whether an adequate level of protection of Personal Data is ensured,

      2. applying the standard contractual clauses issued by the European Commission,

      3. the application of binding corporate rules approved by the competent supervisory authority.

    2. The Administrator shall always inform of its intention to transfer Personal Data outside the EEA at the stage of collection.

  9. Security of Personal Data
    1. The Administrator shall, on an ongoing basis, conduct a risk analysis to ensure that Personal Data is processed by the Administrator in a secure manner - ensuring, in particular, that only authorised persons have access to the data and only to the extent that this is necessary for their tasks. The Administrator shall ensure that all operations on Personal Data are recorded and performed only by authorised employees and associates.

    2. The Administrator shall take all necessary measures to ensure that also its subcontractors and other cooperating entities guarantee the application of appropriate security measures whenever they process Personal Data on behalf of the Administrator.

  10. Contact details
    1. Contact with the Administrator is possible via rodo@ttms.pl.

  11. Changes in the Privacy Policy
    1. The Policy is reviewed on an ongoing basis and updated as necessary.

    2. The current version of the Policy has been adopted and is effective as of 27.02.2023.