- This Privacy Policy defines principles of gathering, processing and using personal data obtained by website www.acp-credit.com (hereinafter referred as “the Website”).
- The Website is owned by ACP CREDIT ADVISORY SPÓ?KA Z OGRANICZON? ODPOWIEDZIALNO?CI? with its registered seat in Warsaw (00-120), ul. Z?ota 59, NIP (Tax ID. No.): 5252806952, REGON (National Business Registry No.): 384858811, entered in the Register of Entrepreneurs kept by the District Court for the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division of the National Court Register under the KRS number 0000813168, with share capital in the amount of 5.000 PLN; e-mail: info@acp-credit.com, hereinafter referred to as ACP CREDIT ADVISORY SP. Z O.O.. ACP CREDIT ADVISORY SP. Z O.O. is also the Personal Information Administrator.
- Personal data collected by ACP CREDIT ADVISORY SP. Z O.O. via the Online Store are processed in compliance with 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), hereinafter also referred to as GDPR.
- ACP CREDIT ADVISORY SP. Z O.O. acts with utmost care in order to ensure privacy of Users who visit the Website.
Article 2 – Type of processed data, objectives and legal ground
- ACP CREDIT ADVISORY SP. Z O.O. collects data on individuals who run economic or professional activity on their own behalf (hereinafter referred to as the Entrepreneurs), and data on individuals who perform legal actions that are not directly related to their activity, hereinafter referred to as Customers.
- Customer personal data are collected for: a) use of the contact form service for the purpose of the performance of a contract executed by electronic means. Legal grounds: processing is necessary for the performance of a contract on contact form services (article 6 sec. 1 letter b of GDPR).
- When using the contact form service, the Customer shall provide the following data: a) e-mail; b) Name.
- During the Website browsing additional information may be collected such as IP address assigned to User’s computer or external IP address of your ISP’s, domain name, browser type, time of access, the type of operating system.
- Also navigation data may be collected from the Customers, including information on links and references they click or other activities undertaken by them in our Online Store. Legal grounds- legitimate interests (article 6 sec. 1 letter f of GDPR) in form of facilitation of use of services rendered by electronic means and improvement of functionality of such services.
- To determine, exercise and enforce claims, come personal data provided by the Customer when using functionalities of the Online Store may be provided, such as: name, surname, information about use of services, if claims result from the manner of user of services by the Customer, other data necessary to prove existence of claim, including the volume of suffered losses. Legal grounds- legitimate interests (article 6 sec. 1 letter f of GDPR) in form of determination, exercising and enforcement of claims and defence against claims in litigation and proceeding in front of other public authorities.
- Personal data are provided to ACP CREDIT ADVISORY SP. Z O.O. on voluntary, in connection with the provision of services via the Website, with the reservation, however, that failure to specify specified in the data forms makes it impossible to use the services provided electronically.
Article 3 – To whom are data disclosed or provided and how long are they stored?
- Customer’s personal data are provided to providers of services used by ACP CREDIT ADVISORY SP. Z O.O. when operating the Online Store depending on contractual arrangements and circumstances, they are either subject to ACP CREDIT ADVISORY SP. Z O.O.’s instructions about manners and ways of data processing (processors) or they define purposes and manners of processing on their own (data controllers). a) Processors. ACP CREDIT ADVISORY SP. Z O.O. uses services of providers processing data on ACP CREDIT ADVISORY SP. Z O.O.’s request only. They include for instance hosting providers, accounting services, providers of marketing systems, systems of traffic analysis in the Online Store, systems for analysis of marketing campaign efficiency; b) Controllers. ACP CREDIT ADVISORY SP. Z O.O. uses services of providers that do not act on request only, but they define the objectives and manners of use of Customers’ personal data. They render electronic payment and banking services.
- Location. Location. Service providers are based mainly in Poland and other countries of the European Economic Area (EEA). Some of the suppliers are established outside the EEA. In connection with the transfer of data outside the EEA, the Administrator made sure that suppliers would guarantee a high level of personal data protection. These guarantees result in particular from the obligation to use standard contractual clauses adopted by the Commission (EU) or participation in the Privacy Shield program established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of protection provided by by the EU-US Privacy Shield.
- Customers’ personal data are stored: a) If Customer’s personal data are processed on the basis of a consent, they shall be processed by ACP CREDIT ADVISORY SP. Z O.O. until the consent is not cancelled, and after cancellation of the consent – for a period of time corresponding to the period of limitation of claims that may be raised by or against ACP CREDIT ADVISORY SP. Z O.O.. If it is not provided otherwise in a specific provision, period of limitation amounts to six years, and in case of claims concerning periodical services or claims related to business activity – three years; b) If personal data are processed on the basis of execution of the contract, then the Customers’ personal data shall be processed by ACP CREDIT ADVISORY SP. Z O.O. as long, as it is necessary for execution of the contract, and afterwards – for a period of time corresponding to the period of limitation of claims. If it is not provided otherwise in a specific provision, period of limitation amounts to six years, and in case of claims concerning periodical services or claims related to business activity – three years.
- Navigational Data may be used to provide better services for Users, 3/9 perform analyses of statistical data and adjust the Website to Users’ preferences and to administer with the Website.
- In case of a respective request, ACP CREDIT ADVISORY SP. Z O.O. discloses personal data to authorised state authorities, in particular to organisational units of the prosecutor’s office, the Police, the Chairperson of the Personal Data Protection Office, the Chairperson of the Office of Competition and Consumer Protection or the Chairperson of the Office of Electronic Communications.
Article 4 – Cookies mechanism, IP address
- The Website uses small files called cookies. They are recorded by ACP CREDIT ADVISORY SP. Z O.O. Website on a computer of a visitor to the Website, if a web browser allows so. Cookie file usually contains a name of domain, where it comes from, its expiry time and an individual random number that identifies such file. Information collected by means of such type of files allow to adjust services offered by ACP CREDIT ADVISORY SP. Z O.O. to individual preferences and actual needs of visitors at the Website. It gives also an opportunity to work out general statistics of hits into information presented at the Website.
- ACP CREDIT ADVISORY SP. Z O.O. uses two types of cookie files: a) Session cookie: recorded information is deleted from memory of a device after an end of a session of a given web browser or after a computer is turned off. Session cookie mechanism does not allow for collection of any personal data and other confidential information from User’s computer. b) Persistent cookie: they are kept on User’s hard disk drive until they are deleted. Persistent cookie mechanism does not allow to collect any personal information or any confidential information from users computer.
- ACP CREDIT ADVISORY SP. Z O.O. uses its own cookies for: a) analyzes and surveys and audits audience, and in particular to create anonymous statistics that help to understand how customers use the Website, which allows improvement of its structure and content.
- ACP CREDIT ADVISORY SP. Z O.O. uses external cookies to: a) presenting on the Website map, indicating the location of the office Noskashop.com using maps.google.com website (external cookies administrator: Google Inc., based in the US); b) to present the Certificate Trusted Regulations through the Service rzetelnyregulamin.pl (external cookies administrator Rzetelna Grupa Sp. z o.o. with its registered office Warsaw, Poland).
- The cookie mechanism is safe for computers of the Website’s Users. In 4/9 particular this way does not give a possibility for viruses or other unwanted or malicious software to enter your computers. Still, Users have an option in their web browsers to limit or switch off the access of cookie files to their computers. If you use this option, you may still use the Website except functions that due to their nature require cookies.
- Below you can find how to change the settings for web browsers on the use of cookies: a) Internet Explorer; b) Microsoft EDGE; c) Mozilla Firefox; d) Chrome; e) Safari; f) Opera.
- ACP CREDIT ADVISORY SP. Z O.O. may collect your IP address. IP address is a number assigned to the computer of a website visitor by your ISP. IP number allows you to access the Internet. In most cases, the computer is assigned dynamically, ie it changes every time you connect to the Internet and therefore is widely regarded as a non-personally identifying information. The IP address is used by ACP CREDIT ADVISORY SP. Z O.O. in diagnosing technical problems with the server, creating a statistical analysis (eg determining regions from which we note the most visits), as information useful in administering and improving the Website, as well as for security purposes and the possible identification of aggravating server unwanted automatic programs for viewing Website content.
- The Website contains links and hyperlinks to other web pages. ACP CREDIT ADVISORY SP. Z O.O. shall not be responsible for privacy policies in force therein.
Article 5 – Rights of data subjects
- The right to withdraw consent – legal ground: article 7 sec. 3 of GDPR. a) The Customer has a right to withdraw consent granted to ACP CREDIT ADVISORY SP. Z O.O.. b) Withdrawal of consent shall be effective as the time of withdrawal. c) Withdrawal of consent shall not affect the lawfulness of processing before its withdrawal. d) Withdrawal of consent shall not entail any negative consequences for the Customer, but may prevent them from further use of services of functionalities, which may be lawfully provided by ACP CREDIT ADVISORY SP. Z O.O. only upon consent of the Customer.
- Right to object to personal data processing – legal ground: article 21 of GDPR. a) The Customer shall have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning them, including profiling, if ACP CREDIT ADVISORY SP. Z O.O. processes their data on the basis of a legitimate interest, such e.g. marketing of ACP CREDIT ADVISORY SP. Z O.O.’s products and services, statistic concerning use of individual functionalities of the Online Store and facilitation of use of the Online Store, and Customer satisfaction surveys; b) An e-mail resignation from marketing communications on products or services will mean the Customer’s objection to processing of their personal data, including profiling for those purposes; c) If the Customer’s objection is reasonable and ACP CREDIT ADVISORY SP. Z O.O. has no other legal grounds to process personal data, the Customer’s personal data, whose processing has been objected by the Customer, will be deleted.
- Right to erasure (“right to be forgotten” ) – legal ground: article 17 of GDPR. a) The Customer has the right to demand erasure of all or some personal data; b) The Customer has the right to demand the erasure of some personal data, if: a. the personal data are no longer necessary in relation to the purposes for which they were collected or processed; b. the Customer has withdrawn consent in the scope in which personal data have been processed on the basis of their consent; c. the Customer has objected to use of their data for marketing purposes; d. the personal data are unlawfully processed; e. the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which ACP CREDIT ADVISORY SP. Z O.O. is subject; f. the personal data have been collected in relation to the offer of information society services. c) Despite of demand of erasure of personal data in relation to an objection or withdrawal of consent, ACP CREDIT ADVISORY SP. Z O.O. may retain some full personal data in the scope, in which processing is necessary for determination, claiming or defence against claims, and for fulfilment of the legal obligation requiring data processing under the legislation of the European Union or a Member State to which ACP 6/9 CREDIT ADVISORY SP. Z O.O. is subject. It refers in particular to: name, surname, e-mail address, which are retained for the purpose of examination of complaints and claims related to use of ACP CREDIT ADVISORY SP. Z O.O. services, or additionally an address of residence/ correspondences, order number, which are retained for the purpose of examination of complaints and claims related to concluded sales agreements or service agreements.
- Right to restriction of processing- legal ground: article 18 of GDPR. a) The Customer shall have the right to obtain from the controller restriction of their personal data processing. Submission of such demand, until its examination, prevents the use of specified functionalities or services, the use of which would be related with processing of personal data subject to such demand. Moreover, ACP CREDIT ADVISORY SP. Z O.O. will not send any message, including marketing communications. b) The Customer shall have the right to demand restriction of their personal data processing in the following cases: a. When they contest the acccuracy of their personal data; then ACP CREDIT ADVISORY SP. Z O.O. shall restrict their use for a period enabling verification of the accuracy of the personal data, but no longer than for 7 days; b. When data processing is unlawful and the Customer demands restriction of their use instead of their erasure; c. When personal data are no longer necessary for the purposes of their collection or use, but they are needed by the Customer in order to determine, exercise or defend claims; d. When the Customer objected to proceeding of their data- then the restriction is introduced for a period necessary to consider whether, due to exceptional circumstances – protection of the Customer’s interests, rights and freedoms prevails over the interests, which are exercise by the Controller when proceeding Customer’s personal data.
- Right of access to data – legal ground: article 15 of GDPR. a) The Customer shall have the right to obtain a confirmation from the Controller, whether or not it processes personal data, and if yes, the Customer shall have the right to: a. obtain access to their personal data; b. obtain information on the purposes of the processing, the categories of processes personal data, the recipients or categories of recipients of such data, the envisaged period for which the personal data will be stored or the criteria used to determine that period (if determination of the planned period of data processing is not possible), on Customer’s rights under the GDPR and the right to lodge a complaint with a supervisory authority, on the source of such data, automated decision-making, including profiling and security devices applied due to the transfer of such data outside the European Union; c. obtain copies of their personal data.
- Right to rectification – legal ground: article 16 of GDPR a) The Customer shall have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning the Customer. Taking into account the purposes of the processing, the Customer shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement, sending the respective request to the email address in compliance with of the Privacy Policy.
- Right to data portability- legal ground: article 20 of GDPR. a) The Customer shall have the right to obtain their personal data, which were provided to the Controller, and then to send them to another data controller selected by the Customer. The Customer shall have the right to demand that such personal data are sent directly by us to another data controller, if this is technically feasible. In such case the Controller shall sent the Customer’s personal data in a csv file, which is a commonly used machine-readable format, allowing transfer of processed data to another data controller.
- If the Customer wishes to exercise any of the foregoing rights, ACP CREDIT ADVISORY SP. Z O.O. fulfils a request or refuses to fulfil it promptly, but no later than within a month of its receipt. If, however, due to a complex nature of a demand or a number of demands ACP CREDIT ADVISORY SP. Z O.O. is not able to fulfil demand within one month, it shall fulfil it during the following two month, notifying the Customer earlier within a month from receipt of the demand on the intended prolongation of the period and about own activities.
- The Customer may file complaints, questions or requests concerning processing of their personal data and execution of this rights.
10 . The Customer has the right to demand that ACP CREDIT ADVISORY SP. Z O.O. provides copies of standard contractual clauses, sending a request in the was define in of the Privacy Policy.
11 . The Customer shall have the right to file a complaint to the Chairperson of the Office of Personal Data Protection in respect to violation of their rights for personal data processing or other rights granted under the GDPR. Article 6 – Amendments to the Privacy Policy 8/9
- Privacy Policy may change as ACP CREDIT ADVISORY SP. Z O.O. inform users in advance of 7 days.
- Please send all additional questions related to the Privacy Policy to: info@acp-credit.com.
- Date of the last amendment: 16.12.2020.