PRIVACY POLICY OF [SYSTELL.PL]

I. INFORMATION WE COLLECT

1. This Privacy Policy sets forth the rules of processing of personal information that we collect in connection with the use of pl (hereinafter referred to as the Service).
2. Systell spółka z ograniczoną odpowiedzialnością spółka komandytowa, entered into the Register of Entrepreneurs of the District Court for Poznań Nowe Miasto and Wilda, 8th Commercial Division of the National Court Register under KRS (National Court Register) number: 0000762978, NIP [Polish tax identification no.] 7822371938, REGON [Polish statistical identification no.] 300414650, represented by Systell Spółka z ograniczoną odpowiedzialnością, email address: systell@systell.pl (hereinafter referred to as SYSTELL or the Operator) is the Operator of the Service.
3. The Operator collects the following personal information in connection with the use of the Service:
   1. Personal data submitted by users via contact forms;
   2. Personal data submitted by users in connection with the ordering of Systell ebooks;
   3. Data collected via cookie files;
   4. Server logs.

II. PERSONAL DATA SUBMITTED BY USERS VIA CONTACT FORMS

1. The Operator collects data by means of the contact form available on the pl/kontakt/ website, as well as by means of the shortened form included in the widget for requesting a phone contact.
2. The Operator collects the following data:

Contact form: name and possibly surname, email address, telephone number

Widget: telephone number

3. Providing one’s personal data is voluntary. However, it is necessary in order for the User to be able to use the selected form of contact with SYSTELL. The User’s refusal to submit the aforementioned contact data (email address, telephone number) will result in SYSTELL not being able to contact the User in the way selected by the User (in the case the user refuses to submit his/her phone number, contact via phone will not be possible). The User’s refusal to submit name or surname shall not affect the contact – this information is submitted solely for the purpose of informing SYSTELL employees.
4. Below we present the information related to the processing of data submitted via contact forms:

III. PERSONAL DATA SUBMITTED BY USERS IN CONNECTION WITH THE ORDERING OF THE SYSTELL EBOOK

1. The Operator collects data by means of forms for the ordering of Systell ebooks. These forms become available after the User selects one of the ebooks on stronie systell.pl/ebooki/.
2. The Operator collects the following data:
   1. name and surname;
   2. email address;
   3. telephone;
   4. company name.

3. Providing the aforementioned data is voluntary. However, it is necessary in order for the User to be able to order ebooks provided by SYSTELL. The User’s refusal to submit the aforementioned data will result in the User not being able to download the ebooks.
4. Below we present the information related to the processing of data submitted in connection with the ordering of ebooks:

IV. ADDITIONAL INFORMATION COMMON FOR ALL CASES OF PROCESSING OF SERVICE USERS’ PERSONAL DATA

1. The Administrator shall ensure that all personal data is processed in accordance with the applicable provisions of law, in particular with the General Data Processing Regulation and with other personal data protection laws. Furthermore, the Administrator shall ensure that the data is collected exclusively for clearly identified and lawful purposes, is correct contentwise and adequate to the purposes, for which it is processed.

User rights with respect to the processing of personal data

2. Users have the right to access their data and correct, delete, restrict the processing of and transfer their data, as well as the right to object according to the rules specified in Art. 15-22 of the General Data Protection Regulation.
3. Furthermore, users have the right to withdraw their consent, if the processing of their data is performed on the basis of such content. Users have the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.
4. The aforementioned rights can be executed by contacting us at the following email address: systell@systell.pl, or by writing to us at the following address: Systell Sp. z o.o. sp.k. ul. Pułtuska 10, 61-052 Poznań, with the following annotation: “Personal data. Systell”.
5. Moreover, users have the right to submit a complaint to the President of the Polish Data Protection Authority, should they find that the processing of their personal data constitutes an infringement of the law.

Option to extend data storage period

6. Despite the expiry of the data storage period defined in pts II and III above, SYSTELL shall retain the User’s personal data for a longer period of time, should it be necessary to fulfil its legal obligations (Art. 6(1) pt c) of the General Data Protection Regulation shall constitute the legal basis for the processing), or to settle disputes or pursue/defend any possible claims (Art. 6(1) pt f) of the General Data Protection Regulation).

Unsolicited commercial communication

7. SYSTELL shall not send to the User unsolicited commercial communication, i.e. unsolicited emails or text messages, unless the User gives his/her consent to receive such communication. Messages containing answers to questions about our offer shall not be deemed unsolicited commercial communication.

V. INFORMATION CONTAINED IN COOKIE FILES

Cookie files used by the Service

1. SYSTELL uses cookie files, i.e. IT data stored by Internet servers on users’ end devices (PC, smart phone or tablet), which may subsequently be read by IT servers every time the User’s end device connects to the server.
2. SYSTELL uses cookie files for:
3. the creation of statistics that help us understand the way the Service users use websites in order to optimise website structure and content;
4. the purpose of remarketing, i.e. surveying behaviour characteristics of users visiting a given website.
5. The Service uses two basic types of cookie files: session cookies and persistent cookies. Session cookies are temporary files that are stored on the User’s end device until he/she logs out, leaves the website or turns the software (web browser) off. Permanent cookies are kept on the User’s device for the period specified in the cookie file parameters or until the User deletes them.
6. The data obtained from cookie files shall not be linked to the personal data the User provides in contact forms.
7. If the User does not consent to SYSTELL’s using of cookie files, he/she should adequately change the settings of his/her browser or cease to use the Systell.pl website.

Managing cookie files – how to give/withdraw your consent in practice

6. Software applications for browsing the Web (Internet browser) usually by default allow for cookie files to be stored in the User’s end device. Users have the option of adjusting these settings. Internet browsers provide the option of removing cookies. Cookies can also be automatically blocked. More detailed information on this topic can be found in the Help function or Manual of your browser.
7. Please note that disabling of cookie files that are necessary for authentication, security and keeping track of the User’s preferences may make it difficult, and, in extreme cases, prevent the use of the websites.
8. In order to manage your cookie settings, select your browser/system from the list below and follow the instructions:

1. 1. Internet Explorer
   2. Chrome
   3. Safari
   4. Firefox
   5. Opera
   6. Android
   7. Safari (ios)
   8. Windows Phone
   9. Blackberry

VI. PROFILING

1. User data may also be processed in an automated way, including profiling. Profiling may consist of analysing data obtained from cookie files relating to the User’s behaviour, and predicting the User’s probable preferences on the basis of such data, with the purpose of serving targeted ads or presenting the Systell offer while the User browses other websites.
2. The User has the right not to be subject to profiling, in particular the right to object at any time. This right can be executed by applying appropriate settings to your browser, according to Art. V.7-9 above.

VII.     SERVER LOGS

1. Information about certain user behaviours is subject to logging in the server layer. This data is used exclusively for the purpose of administering the Service and ensuring the most efficient hosting services.
2. Browsed resources are identified by URL addresses. The following data may also be saved:
   1. request time;
   2. reply sending time;
   3. name of the client’s station – the identification is carried out by the HTTP protocol;
   4. information about errors that occurred during the implementation of the HTTP transaction;
   5. URL address of the previously visited page (referer link), if the website was accessed through a reference link;
   6. information about the User’s browser;
   7. information about the IP address.
3. The aforementioned data is not associated with individual persons browsing the websites.
4. The aforementioned data is used exclusively for the server administration purposes.

VIII.   PASSING DATA TO THIRD PARTIES

1. SYSTELL can pass the collected data to its subcontractors, including the entities which have been entrusted with the processing of personal data of the users, pursuant to Art. 28 of the General Data Protection Regulation. Such entrustment can only be made for the purposes defined herein, carried out on behalf of SYSTELL.
2. User data can also be passed to other entities than described in pt 1 above, should it be required or permitted under applicable laws, in particular:
   1. in the event of a merger, division or reorganisation, the data shall be passed to the buyer or to the buyer of all or most of our assets;
   2. to comply with the requirements and orders of government bodies or to provide assistance, including responding to the request of law enforcement authorities, administration authorities or courts;
   3. to fight economic malpractice and criminal activities, as well as to protect our rights and the rights of our affiliates, business partners and users;
   4. to carry out internal audits related to the protection of personal data.
3. The data collected via the Service may also be made available to the authorities entitled to obtaining of such data pursuant to applicable laws, i.e. in particular to courts, prosecutor’s offices and the police.
4. The data collected via cookie files may be made available to:
   1. entities providing remarketing services,
   2. advertisers cooperating with SYSTELL,
   3. entities within Google’s advertising network (with regard to the information about the User’s preferences collected by Google’s advertising network, the User can view and edit the data resulting from cookie files with the help of the following tool: https://www.google.com/ads/preferences/).
5. The User’s data may be passed to a third country, i.e. the United States of America, in connection with the Administrator’s use of services provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA), pursuant to the EU’s framework (Privacy Shield) which ensures the appropriate level of personal data protection by entities established in the U.S. that have joined the program.

IX. CONTACT

1. Should you have any questions, comments or recommendations in connection with this Privacy Policy, or should you wish to execute the aforementioned right(s), please contact us at systell@systell.pl or write to us at the following address: Systell Sp. z o.o. sp.k. ul. Pułtuska 10, 61-052 Poznań, with the following annotation: “Personal data. Systell”.
2. SYSTELL has not appointed the Data Protection Officer, as defined in Art. 37 of the General Data Protection Regulation.