PROXIMA ADHESIVES

GDPR / Privacy Policy

Information obligation under GDPR

The information below is a concise, understandable and clear summary of the information provided in the Privacy Policy regarding the data controller, the purpose and manner of processing of personal data and your rights in relation to such processing, in the form required to comply with GDPR’s information obligations. Details of the processing methods and the parties involved can be found in the stated policy.

Who is the data controller?

The Controller of the Personal Data (hereinafter referred to as Controller ) is “Proxima Adhesives Sp. z o.o.”, with registered office at ul. Piłsudskiego 38, 97-400 Bełchatów, with the assigned tax identification number (NIP): 5272669949, with assigned KRS number: 0000402532, providing services electronically through the website.

How can I contact the data controller?

Has the Controller appointed a Data Protection Officer?

The Controller can be contacted at the following addresses

  • Postal address – Proxima Adhesives Sp. z o.o., ul. Piłsudskiego 38, 97-400 Belchatów

  • E-mail address – pxa@pxa.com.pl

  • Telephone – +48 44 6321131

  • Contact form – available at: [contact]

Pursuant to Article 37 RODO, the Controller has not appointed a Data Protection Officer.

For matters concerning data processing, including personal data, please contact the Controller directly.

Where do we obtain personal data from and what are its sources?

Data is obtained from the following sources:

  • from data subjects

What personal data do we process?

The site processes ordinary personal data provided voluntarily by the persons concerned by means of

(For example, name, login, email address, phone, IP address, etc.)

The detailed scope of the data processed is available in the Privacy Policy.

What are the purposes of our data processing?

The Service collects and processes User data on the basis of

  • 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)
    • Article 6(1)(a)
      the data subject has given his or her consent to the processing of his or her personal data for one or more specified purposes
    • Article 6(1)(b)
      the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; or
    • Article 6(1)(f)
      processing is necessary for the purposes of the legitimate interests of the controller or of a third party
  • Law of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)
  • Act of 16 July 2004. Telecommunications Act (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)

What is the legitimate interest pursued by the Controller?

For the possible establishment, investigation or defence of claims – the legal basis for the processing is our legitimate interest (Article 6(1)(f) of the DPA) to protect our rights, including but not limited to

  • For the purpose of risk assessment of potential customers
  • To evaluate planned marketing campaigns
  • To carry out direct marketing

How long do we process personal data?

As a general rule, the personal data provided will be kept only for the duration of the service provided by the Controller.

They will be erased or made anonymous within a period of up to 30 days from the end of the provision of the service (e.g. deletion of a registered user account, unsubscription from the newsletter list, etc.).

In exceptional cases, this period may be extended in order to safeguard the legitimate interest pursued by the Controller. In such a case, the Controller will store the indicated data from the time of the User’s request for deletion, for a maximum period of 3 years, in case of violation or suspected violation of the provisions of the Regulations of the Service by the person concerned.

Who is the recipient of the data, including personal data?

As a general rule, the Controller is the only recipient of the data.

However, data processing may be entrusted to other entities that provide services to the Controller in order to maintain the activity of the Website.

Such entities may include, but are not limited to

  • Hosting companies that provide hosting or related services to the Controller.

Will your personal information be transferred outside the European Union?

Personal data will not be transferred outside the European Union unless it is published as a result of an individual action by the user (e.g. posting a comment or entry) which makes the data available to any visitor to the website.

Will personal data be the basis for automated decision making?

Personal data will not be used for automated decision making (profiling).

What rights do you have in relation to the processing of your personal data?

  • Right of access to personal data
    Users have the right to access their personal data, which can be exercised by making a request to the Controller.
  • Right to rectify personal data
    Users have the right to request the Administrator to rectify without delay their personal data that is inaccurate and/or to complete incomplete personal data, exercised upon request made to the Controller.
  • Right to erasure of personal data
    Users have the right to request from the Controller the immediate deletion of their personal data, exercised upon request submitted to the Controller.
    In the case of user accounts, the cancellation of the data will consist in the anonymisation of the data which makes it possible to identify the user.
    In the case of the newsletter service, the user has the option of cancelling his/her personal data using the link contained in each email sent.
  • Right to restrict the processing of personal data
    Users have the right to restrict the processing of their personal data in the cases indicated in article 18 of the RODO, such as questioning the accuracy of their personal data, exercised upon request made to the data controller.
  • Right to portability of personal data
    Users have the right to obtain from the Data Controller the personal data concerning them in a structured, commonly used format suitable for machine reading, exercised upon request made to the Data Controller.
  • Right to object to the processing of personal data
    Users have the right to object to the processing of their personal data in the cases provided for by article 21 of the RODO, exercised upon request made to the Controller.
  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority for the protection of personal data.

Privacy Policy

The following Privacy Policy sets out the rules governing the storage of and access to data on the Devices of Users who use the Website for the purposes of providing electronic services by the Administrator, as well as the rules governing the collection and processing of personal data provided by users personally and voluntarily through the tools available on the Website.

§1 Definitions

  • Service – the website of “Proxima Adhesives” operating at https://proxima-adhesives.pl.
  • External Service – websites of partners, service providers or customers who cooperate with the Administrator.
  • Administrator of the website/data – the administrator of the website/data (hereinafter referred to as the Administrator) is “Proxima Adhesives Sp. z o.o.” with the following address: ul. Piłsudskiego 38, 97-400 Bełchatów, with the assigned tax identification number (NIP): 5272669949, with assigned KRS number: 0000402532, providing electronic services through the Service.
  • User – a natural person to whom the Administrator provides electronic services via the Website.
  • Device – an electronic device containing software through which the User accesses the Website.
  • 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 individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.
  • Personal data – means information relating to 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, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.
  • Processing – means an operation or set of operations which is performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, 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 for the purpose of restricting its processing in the future.
  • Profiling – means any form of automated processing of personal data which involves the use of personal data to evaluate certain personal factors about an individual, in particular to analyse or predict aspects relating to that individual’s performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement.
  • Consent – the data subject’s consent is a freely given, specific, informed and unambiguous indication of intent by which the data subject, either by a statement or by a clear affirmative action, gives his or her consent to the processing of personal data concerning him or her.
  • Personal data breach – means a breach of security resulting in the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or unauthorised access to personal data transmitted, stored or otherwise processed.
  • Pseudonymisation – means the processing of personal data in such a way that they can no longer be associated with a specific data subject without the use of additional information, provided that such additional information is kept separate and covered by technical and organisational measures which make it impossible to associate it with an identified or identifiable natural person.
  • Anonymisation – Data anonymisation is an irreversible process of data operations that destroys/overwrites “personal data”, making it impossible to identify or link a particular set of data to a specific user or individual.

§2 Data Protection Officer

In accordance with Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

For matters relating to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

  • Internal Cookies – files placed on and read from the User’s Device by the Service’s information transmission system.

  • External Cookies – files placed on and read from the User’s device by the information transmission systems of external services. The scripts of external services that may place cookies on the User’s Device have been deliberately placed on the Website through scripts and services made available and installed on the Website.

  • Session Cookies – files placed by the Service on the User’s Device and read by the Service during a single session of a given Device. The files are deleted from the User’s device at the end of the session.

  • Persistent Cookies – files placed and read by the Website on the User’s Device until manually deleted. The files are not automatically deleted at the end of a session of the Device, unless the configuration of the User Device is set to delete cookies at the end of a session of the Device.

§4 Data storage security

  • Mechanisms for storing and reading cookies – The mechanisms for storing, reading and exchanging data between cookies stored on the User’s Device and the Website are implemented through the built-in mechanisms of Internet browsers and do not allow the retrieval of any other data from the User’s Device or from other websites visited by the User, including personal data or confidential information. The transmission of viruses, Trojan horses and other worms to the User’s Device is also practically impossible.
  • Internal cookies – the cookies used by the Administrator are safe for the User’s Device and do not contain any scripts, content or information that could compromise the security of the User’s personal data or the security of the User’s Device.
  • External cookies – The Administrator makes every effort to verify and select service partners in the context of user security. The Administrator selects well-known, large, globally trusted partners to work with. However, the Administrator does not have full control over the content of the Cookie files sent by external partners. The Administrator is not responsible for the security of Cookies, their content and their use by the scripts installed in the Service, coming from external services in compliance with the licence, as far as the law allows. The list of partners can be found in the Privacy Policy.
  • Cookie control
  • Threats from the User – The Administrator uses all possible technical measures to ensure the security of the data stored in cookies. However, it should be noted that the security of this data depends on both parties, including the activity of the User. The Administrator shall not be liable for the interception of such data, the spoofing of the User’s session or its deletion as a result of the User’s conscious or unconscious activity, viruses, Trojan horses and other spyware with which the User’s Device may be or has been infected. In order to protect themselves from these threats, Users should follow the recommendations for using the Internet.
  • Storage of Personal Data – The Administrator shall ensure that it makes every effort to ensure that the processed personal data voluntarily provided by Users is secure, that access to it is limited and that it is carried out in accordance with its purpose and the purposes of the processing. The Administrator also ensures that it makes every effort to protect the data in its possession against loss by applying appropriate physical and organisational safeguards.

§5 Purposes for which cookies are used

  • Streamlining and facilitating access to the Service
  • Personalize the service for users
  • Marketing, Remarketing on external services
  • Ad serving services
  • Affiliate services
  • Maintenance of statistics (users, number of visits, types of devices, links, etc.)
  • Serving multimedia services

§6 Purposes of processing personal data

Personal data voluntarily provided by users will be processed for one of the following purposes

  • Realization of electronic services:
  • Communication of the Administrator with the Users on matters related to the Service and data protection.
  • To safeguard the legitimate interests of the Administrator

§7 Cookies from external Services

The Administrator of the site uses Javascript and web components from partners that may place their own cookies on the User’s Device. Remember that your browser settings allow you to decide which cookies are allowed to be used by certain websites. Below is a list of partners or their services implemented on the Site that may set cookies:

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

§8 Types of data to be collected

The Service collects information about users. Some of the data is collected automatically and anonymously, and some of the data is personal information that Users voluntarily provide when registering for certain services offered by the Service.

Anonymous Information collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Subpages of the website that were opened
  • Time spent on relevant sub-page of the website
  • Type of operating system
  • Address of the previous subpage
  • Address of the referring page
  • Browser language
  • Internet connection speed
  • Internet service provider
  • Demographic data (age, gender)

Data collected during registration:

  • E-mail address
  • IP address (collected automatically)

Data collected when signing up for the Newsletter service:

  • E-mail address

Some of the data (without identifying information) may be stored in cookies. Some of the data (without identifying information) may be transferred to a statistical service provider.

§9 Access to Personal Information by Third Parties

As a general rule, the only recipient of personal data provided by users is the Administrator. Data collected as part of the services provided will not be transferred or resold to third parties.

Access to the data (most often on the basis of a Data Processing Entrustment Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to operate the Service, i.e:

  • Hosting companies that provide hosting or related services to the Administrator

 

Entrusting the Processing of Personal Data – Hosting, VPS or Dedicated Server Services

The Administrator uses a third party hosting provider, VPS or dedicated servers, to operate the Site. All data collected and processed within the framework of the Service are stored and processed in the infrastructure of the Service Provider located in Poland. There is a possibility of access to the data as a result of maintenance work carried out by the Service Provider’s employees. Access to such data is regulated by an agreement between the Administrator and the Service Provider.

§10 Processing of personal data

Personal information voluntarily provided by Users:

  • Personal data will not be transferred outside the European Union, unless it has been published as a result of an individual action by the User (e.g. posting a comment or entry), which makes the data available to any visitor to the site.
  • Personal information will not be used for automated decision making (profiling).
  • Personal information is not sold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (not including personal data) will be transferred outside the European Union.
  • Anonymous non-personal data may be used for automated decision making (profiling). Profiling of anonymous data (without personal data) does not have legal effects or similarly materially affect the person whose data is the subject of automated decision making.
  • Anonymous data (without personal data) will not be sold to third parties.

§11 Legal basis for the processing of personal data

The Service collects and processes User data on the basis of

  • 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)
    • Article 6(1)(a)
      the data subject has given his or her consent to the processing of his or her personal data for one or more specified purposes
    • Article 6(1)(b)
      the processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract; or
    • Article 6(1)(f)
      processing is necessary for the purposes of the legitimate interests of the controller or of a third party
  • Law of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)
  • Act of 16 July 2004. Telecommunications Act (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 Duration of the processing of personal data

Personal data provided voluntarily by users:

As a rule, the personal data provided will be stored by the Administrator only for the duration of the provision of the Service. They are deleted or made anonymous within 30 days from the termination of the service (e.g. deletion of a registered user account, unsubscription from the newsletter list, etc.).

The exception is the situation that requires securing the legitimate purposes of further processing of such data by the Administrator. In such a case, the Administrator will keep the specified data for no longer than 3 years from the date of the User’s request for deletion in case of violation or suspected violation of the provisions of the Regulations by the User.

Automatically collected anonymous data (without personal data):

Anonymous statistical data, not constituting personal data, are stored by the Administrator for an indefinite period of time for the purpose of keeping statistics of the Service.

§13 Users' rights regarding the processing of personal data

The Service collects and processes users’ data on the basis of the following:

  • Right of access to personal data
    Users have the right to access their personal data, which can be exercised by submitting a request to the Administrator.
  • Right to rectify personal data
    Users have the right to request the Administrator to promptly rectify their personal data that is inaccurate and/or to complete incomplete personal data, exercised upon request submitted to the Administrator.
  • Right to delete personal data
    Users have the right to request from the Administrator the immediate deletion of personal data, which will be realized upon request submitted to the Administrator. In the case of user accounts, the deletion of data consists in the anonymization of data that does not allow the identification of the user.
    The Administrator reserves the right to withhold the execution of a request for data deletion in order to protect the legitimate interests of the Administrator (e.g. if the User has committed a violation of the Rules and Regulations or the data was obtained as a result of correspondence conducted).
    In the case of the newsletter service, the user has the possibility of deleting his/her personal data using a link included in each e-mail sent.
  • Right to limit the processing of personal data
    Users have the right to restrict the processing of personal data in the cases indicated in Article 18 of the RODO, including questioning the accuracy of personal data, exercised upon request submitted to the Administrator.
  • Right to portability of personal data
    Users have the right to obtain from the Administrator, personal data concerning the User in a structured, commonly used machine-readable format, exercised upon 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 the cases specified in Article 21 of the RODO, exercised upon request made to the Administrator.
  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority for the protection of personal data.
 

§14 Contact to the Administrator

The Administrator may be contacted in one of the following ways

  • Postal address – Proxima Adhesives Sp. z o.o., 38 Piłsudskiego St., 97-400 Belchatow
  • E-mail address – pxa@pxa.com.pl
  • Telephone call – +48 44 6321131
  • Contact form – available at: [contact]

§15 Service requirements

  • Restricting the storage of and access to cookies on the User’s Device may cause certain functions of the Website to malfunction.
  • The Administrator shall not be held liable for any malfunction of the Website if the User restricts the storage and reading of cookies in any way.

§16 External links

The Service – Articles, Postings, Entries or Comments made by Users may contain links to external sites with which the Owner of the Service is not associated. These links, as well as the sites or files displayed below them, may be dangerous to your Device or pose a threat to the security of 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 modify this Privacy Policy at any time, without informing Users, with respect to the use and application of anonymous data or the use of cookies.
  • The Administrator reserves the right to modify this Privacy Policy at any time with respect to the processing of Personal Data, of which it will inform Users who have User accounts or who have subscribed to the newsletter service by e-mail within 7 days of the modification. Continued use of the services implies that the User has read and accepted the changes made to the Privacy Policy. If the User does not agree with the changes introduced, he/she must delete his/her account from the website or unsubscribe from the newsletter service.
  • The changes made to the Privacy Policy will be published on this subpage of the Service.
  • The changes will take effect from the date of publication.

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