Privacy Policy

The following Privacy Policy sets out the rules for saving and accessing data on Users’ Devices using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users’ personal data provided by them personally and voluntarily through the tools available in the Service.

The following Privacy Policy is an integral part of the Service Terms and Conditions, which sets out the rules, rights, and obligations of Users using the Service.

§1 Definitions

• Service – the “NETY.pl” website operating at https://nety.pl/en

• External Service – websites of partners, service providers, or service recipients cooperating with the Administrator

• Service/Data Administrator – the Service Administrator and Data Administrator (hereinafter Administrator) is the company “ZP20 Piotr Markowski”, conducting business at: Al. KEN 36 / 112B in Warsaw, with the assigned tax identification number (NIP): 9482256434, providing electronic services via the Service

• User – a natural person for whom the Administrator provides services electronically via the Service.

• Device – an electronic device with software through which the User gains access to the Service

• 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 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)

• Anonymization – Data anonymization is an irreversible process of operations on data that destroys/overwrites “personal data” making it impossible to identify or link a given record with a specific user or natural person.

§2 Data Protection Officer

Based on Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

In matters related to data processing, including personal data, please contact the Administrator directly.

The Administrator has appointed a Data Protection Officer, Mr. Piotr Markowski.
You can contact the Officer via email at office@zp20.pl, by phone at +48 530 909 998, or in writing at the Administrator’s registered office address.
You can contact the Data Protection Officer on all matters related to the processing of personal data.

§3 Types of Cookies

• Internal Cookies – files placed and read from the User’s Device by the Service’s teleinformation system

• External Cookies – files placed and read from the User’s Device by the teleinformation systems of External Services. Scripts of External Services that may place cookies on the User’s Device were deliberately placed in the Service through scripts and services provided and installed in the Service

• Session Cookies – files placed and read from the User’s Device by the Service or External Services during a single session of that Device. After the session ends, the files are deleted from the User’s Device.

• Persistent Cookies – files placed and read from the User’s Device by the Service or External Services until they are manually deleted. The files are not deleted automatically after the end of the Device session unless the User’s Device configuration is set to the cookie deletion mode after the end of the Device session.

§4 Data Storage Security

• Mechanisms for storing and reading Cookie files – Mechanisms for storing, reading, and exchanging data between Cookies stored on the User’s Device and the Service are implemented through built-in mechanisms of web browsers and do not allow the collection of other data from the User’s Device or other websites visited by the User, including personal data or confidential information. It is also practically impossible to transfer viruses, trojans, and other worms to the User’s Device.

• Internal Cookies – Cookies used by the Administrator are safe for the Users’ Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the Device used by the User.

• External Cookies – The Administrator takes all possible actions to verify and select the service partners in the context of User security. The Administrator chooses well-known, large partners with global social trust. However, he does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the security of Cookies, their content, or their lawful use by scripts installed in the Service from External Services to the extent permitted by law. The list of partners is included in the further part of the Privacy Policy.

• Cookie Control

  • The User may, at any time, independently change the settings for storing, deleting, and accessing the data of stored Cookies for each website

  • Information on how to disable Cookies in the most popular computer browsers is available at: how to disable cookies or from one of the indicated providers:

    • Managing cookies in Chrome browser
    • Managing cookies in Opera browser
    • Managing cookies in Firefox browser
    • Managing cookies in Edge browser
    • Managing cookies in Safari browser
    • Managing cookies in Internet Explorer 11 browser

  • The User may delete all Cookies saved so far at any time using the tools of the User’s Device through which the User uses the Service.

• User Threats – The Administrator takes all possible measures to ensure the security of the data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both sides, including the User’s activities. The Administrator is not responsible for the interception of this data, impersonation of the User’s session, or its deletion, as a result of conscious or unconscious activities of the User, viruses, trojans, and other spyware that may infect the User’s Device. Users should follow the rules of safe internet use to protect themselves from these threats.

• Storing Personal Data – The Administrator ensures that all efforts are made to ensure that the personal data voluntarily provided by Users is safe, access to it is limited and carried out in accordance with their intended purpose and processing objectives. The Administrator also ensures that all efforts are made to secure the data held against loss, by using appropriate physical and organizational security measures.

• Storing Passwords – The Administrator states that passwords are stored in an encrypted form, using the latest standards and guidelines in this regard. Decryption of the passwords provided in the Service is practically impossible.

§5 Purposes for Using Cookies

• Improve and facilitate access to the Service
• Personalize the Service for Users
• Enable login to the Service
• Marketing, Remarketing in external services
• Advertising services
• Affiliate services
• Conducting statistics (users, number of visits, types of devices, connection, etc.)
• Providing multimedia services
• Providing social media services

§6 Purposes of Processing Personal Data

Personal data voluntarily provided by Users is processed for one of the following purposes:

• Provision of electronic services:
  • Newsletter service (including sending advertising content with consent)
  • Registration and maintenance of a User account in the Service and related functionalities
  • Commenting/liking posts in the Service without registration
  • Sharing information about the content posted in the Service on social networks or other websites.
• Communication between the Administrator and Users regarding the Service and data protection
• Ensuring the Administrator’s legitimate interest

Data about Users collected anonymously and automatically is processed for one of the following purposes:

• Conducting statistics
• Remarketing
• Serving advertisements tailored to User preferences
• Ensuring the Administrator’s legitimate interest

§7 Cookies from External Services

The Administrator uses javascript scripts and web components of partners in the Service, who may place their own cookies on the User’s Device. Remember that you can decide on the allowed cookies for each website in your browser settings. Below is a list of partners or their services implemented in the Service, who may place cookies:

• Multimedia services:
  • YouTube
  • Vimeo
  • Livestream
  • SoundCloud
  • PlayerFM
  • Cloud Caster
  • Spotify
  • Stitcher
  • Podchaser
  • Castbox
• Social media / combined services:
  (Registration, Login, sharing content, communication, etc.)
  
  • Twitter
  • Microsoft
  • Facebook
  • Google+
  • LinkedIn
• Content sharing services:
  • AddThis (Oracle)
  • Pinterest
  • SnapChat
  • Reddit
  • Slack
  • WhatsApp
  • AmazonWish
  • Foursquare
  • Instagram
• Newsletter services:
  • Freshmail
  • MailChimp
  • Mailerlite
  • GetResponse
  • FreeBot
  • SALESmanago
  • GetAll
  • Sendy
  • Constant Contact
  • SendInBlue
  • HubSpot
  • ConvertKit
  • AWeber
  • Keap
• Advertising services and affiliate networks:
  • Google Adsense
  • AdTaily
  • Gemius
  • Video target
  • Royal Ad
  • OAN.pl
  • AdTukti
  • Lead.Network
  • ebrokerpartner.pl
  • Bluepartner.pl
  • Adtraction
  • Solutions4Ad
  • NetSalesMedia
  • MyLead
  • Admitad GmbH
  • Awin
  • ProperMoney
  • LINKPROFIT
  • CityAds
  • Affiliate44
  • Kwanko
  • Novem
  • SalesTube Affiliate Network
  • Optimise
  • Convertiser
  • Afiliant
  • TradeDoubler
  • Money2Money
• Conducting statistics:
  • Google Analytics
  • Piwik PRO Analytics Suite
  • Kissmetrics
  • Woopra
  • GoSquared
  • FoxMetrics
  • Mixpanel
  • Heap
  • Statcounter
  • Clicky
  • Matomo
  • Serpstat
  • SE Ranking
  • SEMrush
  • Ahrefs
  • Mention
  • Chartbeat
  • HubSpot
  • Optimizely
  • Marketo
  • Adobe Analytics
  • WordPress Stats (Automattic Inc.)
  • Facebook Analytics for Apps
• Other services:
  • Internet Archive
  • Google Maps

Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, purpose, and use of cookies at any time.

§8 Types of Data Collected

The Service collects data about Users. Some data is collected automatically and anonymously, while some data is personal data provided voluntarily by Users during registration for specific services offered by the Service.

Anonymous data collected automatically:

• IP address
• Browser type
• Screen resolution
• Approximate location
• Pages visited within the service
• Time spent on each page within the service
• Type of operating system
• Previous page address
• Referring page address
• Browser language
• Internet connection speed
• Internet service provider

Data collected during registration:

• First name / last name / nickname
• Login
• Email address
• Avatar / Profile picture
• Home address
• Interests
• Gender
• Date of birth / age
• Social media profile addresses
• Website addresses
• Phone number
• PESEL number
• IP address (collected automatically)
• Tax ID number

Data collected when subscribing to the Newsletter service:

• First name / last name / nickname
• Email address
• Home address
• Gender
• Date of birth / age
• IP address (collected automatically)

Data collected when adding a comment:

• First name and last name / nickname
• Email address
• Website address
• IP address (collected automatically)

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

§9 Access to Personal Data by Third Parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected within the services provided is not transferred or resold to third parties.

Access to data (usually based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary for operating the Service, such as:

• Hosting companies providing hosting or related services for the Administrator
• Service and IT support companies performing maintenance or responsible for maintaining IT infrastructure
• Companies intermediating online payments for goods or services offered within the Service (in case of purchase transactions in the Service)
• Companies intermediating mobile payments for goods or services offered within the Service (in case of purchase transactions in the Service)
• Companies responsible for maintaining the Administrator’s accounting (in case of purchase transactions in the Service)

Entrustment of Personal Data Processing – Newsletter

In order to provide the Newsletter service, the Administrator uses the services of a third party – MailChimp. Data entered in the newsletter subscription form is transferred, stored, and processed in the external service of this provider.

Link to the Privacy Policy of the mentioned service.

Please note that the mentioned partner may modify the privacy policy without the Administrator’s consent.

Entrustment of Personal Data Processing – Hosting, VPS, or Dedicated Servers Services

To operate the service, the Administrator uses the services of an external provider of hosting, VPS, or Dedicated Servers – OVH. All data collected and processed in the service is stored and processed in the provider’s infrastructure located in POLAND. Access to the data may be possible as a result of maintenance work carried out by the provider’s personnel. Access to this data is regulated by an agreement between the Administrator and the Service Provider.

Entrustment of Personal Data Processing – Website Service Maintenance

To maintain the service, the Administrator uses the services of an external service provider – ENTITY NAME. The personnel of the mentioned entity have access to the data entered by users during the registration and editing of the user account and/or data related to the Newsletter service. Access to this data is regulated by an agreement between the Administrator and the Service Provider.

Processing of Data for Online Payments

In the case of online payments, all payment data is provided directly by the User to the entity processing the payment – PayPal. Selected data necessary for transaction processing is then provided by this entity to the Administrator. The transfer of data is regulated by an agreement between the Administrator and the Service Provider.

Processing of Data for Mobile Payments

In the case of mobile payments, all payment data is provided directly by the User to the entity processing the payment – Tpay. Selected data necessary for transaction processing is then provided by this entity to the Administrator. The transfer of data is regulated by an agreement between the Administrator and the Service Provider.

Transfer of Personal Data – Accounting Services

In the case of a transaction, some personal data of individuals or data of individuals conducting business activities are transferred to the entity providing accounting services to the Administrator – IFIRMA. The transfer of this data is regulated by the Act … and the agreement between the Administrator and the Service Provider.

Transfer of Personal Data – Courier Services

In the case of a transaction that requires the transfer of the subject matter of the transaction by mail or courier, some personal data of individuals or data of individuals conducting business activities are transferred to the entity providing postal/courier services to the Administrator, selected by the User. The transfer of this data is regulated by the agreement between the Administrator and the Service Provider.

§10 Method of Processing Personal Data

Personal data voluntarily provided by Users:

• Personal data will not be transferred outside the European Union unless published as a result of an individual action by the User (e.g., entering a comment or post), which will make the data available to anyone visiting the service.
• Personal data will not be used for automated decision-making (profiling).
• Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

• Data will be transferred outside the European Union.
• Data may be used for automated decision-making (profiling).
• Data will not be resold to third parties.

§11 Legal Bases for Processing Personal Data

The Service collects and processes User data based on:

• 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)
  • Art. 6 sec. 1(a)
  • Art. 6 sec. 1(b)
  • Art. 6 sec. 1(c)
  • Art. 6 sec. 1(d)
  • Art. 6 sec. 1(e)
  • Art. 6 sec. 1(f)
• Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)
• Act of 16 July 2004 Telecommunications Law (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 Period of Personal Data Processing

Personal data provided voluntarily by Users:

As a rule, the specified personal data is stored only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized within 30 days from the end of the service provision (e.g., deletion of a registered user account, unsubscribe from the Newsletter, etc.).

An exception is a situation that requires securing the legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the specified data, from the time of the User’s request for deletion, for no longer than 3 years in case of a violation or suspected violation of the service regulations by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, which is not personal data, is stored by the Administrator for an indefinite period to maintain service statistics.

§13 User Rights Related to Personal Data Processing

The Service collects and processes User data based on:

• Right to access personal data
  Users have the right to access their personal data, which is realized through the user panel available after logging in and tools that enable access to the account in case of a forgotten password.

• Right to rectify personal data
  Users have the right to request the Administrator to immediately rectify personal data that is incorrect or to complete incomplete personal data, which is realized through the user panel available after logging in and tools that enable access to the account in case of a forgotten password.

• Right to delete personal data
  Users have the right to request the Administrator to immediately delete personal data, which is realized through the user panel available after logging in and tools that enable access to the account in case of a forgotten password.
  In the case of user accounts, deleting data involves anonymizing data that allows the identification of the User. The Administrator reserves the right to withhold the execution of the data deletion request to protect the Administrator’s legally justified interest (e.g., when the User has violated the Terms and Conditions or the data was obtained as a result of correspondence).
  In the case of the Newsletter service, the User can independently delete their personal data by using the link included in each sent email.

• Right to restrict the processing of personal data
  Users have the right to restrict the processing of personal data in the cases specified in Art. 18 of the GDPR, including questioning the correctness of personal data.

• Right to data portability
  Users have the right to obtain from the Administrator the personal data concerning the User in a structured, commonly used, and machine-readable format.
  This right is realized at the User’s request. To do so, contact 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 Art. 21 of the GDPR.

• Right to lodge a complaint
  Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.

§14 Contacting the Administrator

You can contact the Administrator in one of the following ways:

• Postal address – ZP20 Piotr Markowski, Al. KEN 36 / 112B, 02-793 Warsaw

• Email address – office@zp20.pl

• Phone call – +48 530 909 998

• Contact form – available at: https://nety.pl/en/contact

§15 Service Requirements

• Restricting the storage and access to Cookies on the User’s Device may cause some Service functions to malfunction.

• The Administrator is not responsible for the malfunctioning of Service functions if the User restricts the possibility of storing and reading Cookies in any way.

§16 External Links

In the Service – articles, posts, entries, or User comments may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files they point to may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content found outside the Service.

§17 Changes to the Privacy Policy

• The Administrator reserves the right to change this Privacy Policy at any time without notifying Users about the application and use of anonymous data or the use of Cookies.

• The Administrator reserves the right to change this Privacy Policy at any time regarding the processing of Personal Data, about which Users with user accounts or subscribed to the newsletter will be informed via email within 7 days from the change. Continued use of the services implies acknowledgment and acceptance of the changes to the Privacy Policy. If the User does not agree with the changes, they must delete their account from the Service or unsubscribe from the Newsletter.

• Changes to the Privacy Policy will be published on this subpage of the Service.

• Changes take effect upon publication.