Privacy policy

  1. General
  2. PJP Makrum S.A. with registered office in Bydgoszcz (85-033) at ul. Plac Kościeleckich 3, entered into the register of businesses kept by the District Court in Bydgoszcz under KRS number 24679, VAT ID 554-023-40-98 (hereinafter referred to as “PM”), is the controller of your personal data within the meaning of personal data protection regulations. This means that we are responsible for using your data safely in compliance with applicable regulations, in particular with provisions 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) (OJEU L 119, p. 1), hereinafter referred to as the “GDPR”.
  3. This document (hereinafter referred to as the “Privacy Policy”) is a communication about rules of processing and protecting personal data collected by PM from you with regard to purchase of PM products, use of PM services (including services provided by electronic means), requests submitted to PM, the tendering process, participation in events organised by PM, participation in PM employee recruitment process, subscription to the Newsletter or other channels of information about PM products and services, exchange of correspondence, etc., which particularly includes data collected with regard to the use of our website www.shop.promstahl.com.
  4. This Privacy Policy is informative in character, which means that it is not a source of obligations for persons whose personal data is processed under its provisions and one of its functions is to fulfil the obligation to inform referred to in Article 13 of the GDPR.
  5.  
  1. PURPOSES AND BASIS OF OUR PROCESSING OF YOUR PERSONAL DATA
    1. Personal data obtained from you by PM is processed for the following purposes, correspondingly to situations where it is provided:
      1. execution and performance of agreements entered into with PM (regardless of the form of execution – either in writing or by using our services provided electronically by means of our website) – insofar as necessary to enter into, modify the text of, amend, terminate, and duly perform the agreement;
      2. performance of legal obligations binding upon PM, e.g. issue and maintenance of invoices and accounting documents, responding to customer claims, performance of obligations under statutory warranties for product defects, ensuring security of the services provided;
      3. establishment, defence, and exercise of legal claims;
      4. direct marketing of PM products and services;
      5. creation of reports, analyses, and statistics for PM’s internal purposes, specifically including reporting, marketing research, targeted advertising, remarketing, service development planning, development works in IT systems, creation of statistical models; evaluation of PM website operation, including subpage viewing statistics;
      6. if you give your consent to PM sending you commercial information by electronic means, we will also process your personal data in order to inform you about our services, offer, and events we organise as well as products and services of our cooperating parties (subject to our acknowledgment and express permission).
    1. The personal data shall not be used for purposes other than specified in the Privacy Policy, save where PM obtains your consent to processing of the data for other purposes or where another way of using such information is required or permitted by law.
    2. Insofar as processing of your personal data is necessary:
      1. to perform an agreement entered into with you or to take any action upon your request before execution of the agreement, the legal basis for the processing of your personal data by PM is the agreement;
      2. to perform a legal obligation binding upon us, the legal basis is that legal obligation;
      3. for the purposes of the legitimate interests pursued by PM, i.e. for the purposes of direct marketing of our products and services, preventing fraud, or exercise and defence of legal claims, the legal basis is the legitimate interest of PM.
    1. If the use of your data by us is not necessary for the performance of an agreement or performance of a legal obligation, or does not constitute our legitimate interest, we may ask for your consent to certain uses of your data. Your consent may take the form of a tick box when you browse the website, may consist of a choice of technical settings for the use of information society services, or other statement or behaviour which clearly indicates in the context in question that you have accepted the proposed processing of personal data. You may withdraw your consent at any time (this will not affect the lawfulness of the use of your data before withdrawing such consent).
    2. Provision of personal data by you is not mandatory but failure to provide such data will result in PM not being able to carry out the activities for which the data is requested.
    3. PM shall not make any automated decisions, including decisions resulting from profiling, with regard to you based on your personal data.
    4.  
  1. YOUR RIGHTS
    1. Any person whose personal data is processed by PM has the right to access the content of their personal data and to rectify immediately any data that is inaccurate. Subject to the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
    2. If you have given your consent to the processing of the data, in particular for marketing purposes (including consent to sending commercial information by electronic means), your consent may be withdrawn at any time. A user who receives certain information or services, such as an electronic newsletter (“Newsletter”), may unsubscribe at any time by following the instructions contained in each such document sent.
    3. A person disclosing their personal data to PM has the right to request PM to promptly erase personal data relating to them, and PM is obliged to erase the personal data without undue delay, if one of the following circumstances applies:
      1. the personal data is no longer necessary for the purposes for which it was collected;
      2. the data subject has withdrawn the consent on which the processing is based and there is no other legal basis for the processing;
      3. the data subject objects to the processing;
      4. the personal data has been processed unlawfully;
      5. the personal data must be erased in order to comply with a legal obligation contemplated by Union or Member State law to which PM is subject.
    1. Persons who disclose their personal data to PM have the right to request restriction of processing of the personal data in the event that:
  1. the accuracy of the personal data is contested by the data subject, for a period enabling PM to verify the accuracy of the personal data;
  2. the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of its use instead;
  3. PM no longer needs the personal data for the purposes of the processing, but it is required by the data subject for the establishment, exercise, or defence of legal claims;
  4. the data subject has objected to processing, pending the verification whether the legitimate grounds of PM override those of the data subject.
    1. If the processing of personal data by PM is carried out by automated means based on consent or under an agreement, the data subject shall have the right to receive the personal data concerning them, which they have provided to PM, in a structured, commonly used and machine-readable format and have the right to transmit this personal data to another controller. The data subject shall have the right to have the personal data transmitted directly by PM to another controller, where technically feasible.
    2. To exercise the rights referred to above, please contact PM as instructed in Section 8 below.
    3. PM shall communicate any rectification or erasure of personal data or restriction of processing carried out at your request to each recipient to whom the personal data has been disclosed, unless this proves impossible or involves disproportionate effort.
    4. In regard to processing of your personal data by PM, you have the right to lodge a complaint with a supervisory authority, i.e. to the President of the Polish Personal Data Protection Office.
    5.  
  1. parties to whom your personal data is transferred
    1. We transfer your data to:
      1. entities processing data on our behalf, participating in our operations:
        1. entities handling maintenance of IT systems and computer equipment we use;
        2. entities managing our properties,
        3. our business partners, advertising agencies, and other entities brokering sales of our products and services or organisation of marketing campaigns;
        4. subcontractors supporting us, e.g. in provision of our services, transit of products ordered, maintenance of products, handling correspondence, or in the customer service process;
        5. entities providing advisory, consultancy, and auditing services as well as legal, tax, and accounting assistance to us, and research agencies acting on our request;
      1. other data controllers processing data on their own behalf:
        1. entities carrying on a postal or courier business;
        2. entities purchasing debts or debt collectors, in the event of your default in timely payment of our invoices;
        3. entities cooperating with us in handling of accounting, tax, and legal matters, to the extent that they become data controllers.
    1. At the moment, PM has no plans to transfer your data outside the EEA (covering the European Union, Norway, Liechtenstein, and Iceland). But it may be that during the term of the agreement we will decide to transfer your data outside the EEA – only to the extent permitted by law.
    2. PM may make the personal data available upon request by law enforcement authorities or bodies, or when required by applicable laws, court judgements, or other state regulations. The need to make the personal data available may also be due to data privacy or security audits and/or when investigating complaints or taking action to address security risks. PM does not sell personal data to third parties, nor does it entrust the processing of personal data provided by users to third parties, as the data could be used by such third parties for their marketing purposes.

 

  1. HOW LONG WE KEEP YOUR PERSONAL DATA
    1. Your personal data will be stored no longer than necessary, i.e. according to the purpose of processing:
      1. execution and performance of your agreement with PM – during the term of the agreement and settlements after its termination, which includes the period of statutory warranty for defects or quality guarantee granted under the agreement;
      2. performance of a legal obligation binding upon PM:
      1. during the period of performing the obligations;
      2. during the period of data storage imposed by regulations (e.g. tax regulations); or
      3. for as long as we might suffer legal consequences of failure to perform an obligation, e.g. be fined by state authorities;
      1. purposes of the legitimate interests pursued by PM:
      1. direct marketing of our products and services – during the term of the agreement and subsequently for the period of warranty and/or out-of-warranty service;
      2. preventing fraud – as long as proceedings before relevant authorities last;
      3. exercise and defence of legal claims – during the limitation period of the claim in question.
    1. Whenever we process personal data on the basis of your consent to certain uses of the data, your data will be processed for the period indicated in your consent or, if not indicated, until you withdraw your consent.

 

  1. AUTOMATIC DATA COLLECTION

COOKIES. OPERATING DATA. GOOGLE TOOLS

    1. While you are using the PM website, your data is collected automatically as well. This data can be collected in system logs of the website via so-called cookies. Cookies are small pieces of text data in the form of text files, sent by the server and saved on the website visitor’s side (e.g. on the hard drive of a computer, laptop, or smartphone memory).
    2. By saving cookies on a website user’s device (computer, smartphone, tablet, etc.), PM is able to:
    1. Adjust operation of the website to your needs.
    2. Eliminate the need to sign in every time the website is visited (for sections accessible to registered users/customers).
    3. Remember your settings across sessions.
    4. Improve performance and security of the website.
    5. Customise the website according to your needs and enable users to find the information they need faster.
    6. Continually implement user-focused improvements to the website.
    7. Increase the effectiveness of marketing activities.
    1. Cookies do not contain any data identifying the user and no one can be identified from them. These files are in no way harmful to the user’s end device and do not change user settings or settings of the software installed on the device. The content of these files can only be read by the server that created them.
    2. While you are using our website, PM uses three types of cookies: session, persistent, and marketing cookies. Session cookies are temporary files that are stored in your device memory until you log out of the website, leave the website, or close your browser. Persistent files are stored in your device memory for the time specified in the parameters of these files or until you delete them. Marketing files are “cookies” saved by other external scripts used on our website. They are mainly used by us for remarketing purposes (see Sections 6.11-6.14 below).
    3. By default, most web browsers on the market will accept saving cookies. You have the ability to change your cookies settings yourself at any time by specifying the conditions under which cookies are stored and accessed on your device. Changes to the settings referred to in the previous sentence can be made via the settings of your web browser or by using service configuration. These settings can be changed in particular so as to block automatic handling of cookies in the settings of your web browser or to notify you whenever a cookie is saved on your device. Detailed information about the options and methods of handling cookies are available in the software (web browser) settings.
    4. You can delete cookies at any time by using the functions available in the web browser you are using.
    5. Limiting the use of cookies may affect some of the functionalities available on the PM website.
    6. Detailed information on how to change your cookies settings and how to delete cookies yourself in major web browsers is available in the help section of your web browser.
    7. PM also processes anonymised operating data associated with the use of its website (so-called logs – IP address, domain) to generate statistics to help manage the website. As soon as the user connects to the website, information about the number (including IP) and type of the user’s end device from which the user connects to the website appears in system logs of the website. This data is aggregated and anonymous, i.e. it does not contain any identifying characteristics of the visitors to the website. Logs are not disclosed to third parties.
    8. PM may use Google Analytics, which collects anonymous information about the PM websites you visit using cookies. Please refer to the Google Analytics privacy policy on this website: http://www.google.com/intl/pl/analytics/privacyoverview.html.
    9. In addition, PM may use Google AdWords and Google Analytics remarketing codes of display advertisers. These codes are used to create remarketing lists in order to match the users who have visited our website with individualised ads and then display them on the Google Ad-Words advertising network, Google’s search engine as well as on the websites of entities that are members of the Google partner network.
    10. Our website, using the “similar audiences” function, operates within the Google AdWords system and checks how sites within the advertising network have been viewed in the last thirty days, and submits this information to a contextual targeting engine to determine the profile of remarketing audiences. On the basis of that information, Google AdWords finds a group of new users who have similar browsing patterns to those on the PM remarketing list. This list is never created based on the history of browsing websites with themes considered sensitive, such as race, religion, sexual orientation, or health issues.
    11. When using remarketing tools and the “similar audiences” function, our website does not collect your personal data via cookies but only your browsing history and therefore you remain anonymous.
    12. You have the option to opt out of collecting remarketing codes and display advertisers’ codes through Google AdWords and Google Analytics as well as of displaying non-standard ads in Google’s advertising network by following the procedure in Section 6.5 above.
    13. The PM website may contain features that allow you to share content via third party social networking applications, such as the “Like” button on Facebook or a widget on Twitter. All of these social media applications may collect and use data about your activity on the PM website. Any personal data you provide via such social media applications may be collected and used by other users of such applications and interactions effected via such applications are governed by privacy policies of the companies that provide the applications. We do not control and are not liable for these companies or their use of your data.

 

  1. HOW WE SAFEGUARD PERSONAL DATA
  1. PM declares that it is committed to ensuring a high level of security for the personal data it processes. Any events affecting data security, including those relating to the suspicion of sharing files containing viruses and other files of similar nature or destructive mechanisms other than files, should be reported to the email address indicated in Section 9 below.
  2. PM applies technical and organisational measures to ensure protection of the processed personal data appropriate to the threats and categories of protected data, and in particular, PM protects the data against unauthorised disclosure, illegal takeover, processing in breach of applicable regulations and change, loss, damage, or destruction. In addition, PM exercises particular care to ensure that the personal information is:
  • accurate and processed in a lawful manner,
  • obtained for specific purposes only and not processed further contrary to those purposes,
  • adequate, relevant, and not excessive,
  • precise and up-to-date,
  • kept no longer than necessary,
  • processed in accordance with rights of the persons (data subjects), including the right to restrict disclosure,
  • kept safely,
  • not transferred without proper protection.
  1. The personal data is stored in a database to which technical and organisational measures have been applied to ensure protection of the processed data in accordance with the requirements laid down by generally applicable legal regulations on personal data protection. Access to the database is only available to persons who have been authorised by the data controller.
  2. PM has an appropriate policy and procedures in place to protect personal data against unauthorised loss, misuse, change, or destruction. We use our best efforts to ensure that access to your personal data is limited to persons who need to know this data. Those who have access to your data are required to keep it confidential. In addition, one of the principles of PM’s policy in this respect is to keep personal information only for such period of time as is necessary to process your request or until you request removal of such information.
  1. CONTACT

For matters connected with personal data processing, you may contact PM as the data controller by means of our appointed data protection officer at: 85-719 Bydgoszcz, ul. Fordońska 40, or by writing to: iod@projprzem.com, or by calling: +48 52 321 20 29.

  1. CHANGES IN THE PRIVACY POLICY

PM may make changes to this document to reflect the updated Privacy Policy. In case of modifications, the date of last update provided below is also changed.

 

Date of last update to the Privacy Policy: 01.02.20