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PRIVACY POLICY

In order to ensure Users of this Website that the protection of the Users’ privacy is very important to us and provide Users with information on the personal data collected by the Website, the purpose of collecting and using cookies – we present this privacy policy. We provide privacy protection at a level at least equivalent to the standards set in applicable legal regulations, in particular in the Act of 18 July 2002 on providing services by electronic means (OJ 2013.1422 as amended), Act of 29 August 1997 on the protection of personal data (OJ 2015.2135 with later amendments), as well as the Act of 16 July 2004 – the Law on telecommunications (OJ 2014.243, as amended).

1. The objectives of the adopted privacy policy and the use of cookies on the website.

1.1. This Privacy Policy and the use of cookies regulates the rules of processing personal data, collecting and using information about users on the website at www.smartcities.pl; (hereinafter: “Website”). The administrator of personal data is ASA Polska S.A. with headquarters at ul. Mikołaja Kopernika 21 in Warsaw, hereinafter referred to as: Administrator

1.1.1. The personal data transferred by the User is processed to the extent necessary only for the purposes of: concluding an agreement for the provision of services provided electronically, statistical kind, contact and answers to questions asked by the User. By checking the option “I consent to sending me marketing information, including sending commercial information by electronic means”, the User’s personal data will be processed by the Website also for the purpose of providing information about services. Providing personal information is voluntary.

1.2. Please be advised that there may be referrals on the Website – links that after clicking on them enable you to reach other websites managed by other administrators. The Administrator of this Website has no influence on the privacy policy pursued by these administrators or the policy of using cookies and is not responsible for them. Therefore, the Administrator asks you to read the privacy policy of these websites and the use of cookies.

1.3. Please be advised that we use the “Google Analytics” service – collecting anonymous information about visited websites of our we services. Detailed rules regarding the “Google Analytics” privacy policy, including information on how you can block the collection of data, can be found at: Terms of Use of Google Analytics.

2. Data collected about users on the Website, including personal data, its use, User’s rights.

By visiting our Website, user data can be shared in two ways: passively and actively. Data collected passively is information automatically saved by the website: anonymous information about the time of the User’s visit, IP address, URL address, type of browser (so-called system logs) / number of visits, device data / language of the browser, operating system type, etc. The data collected automatically is analyzed for the purpose specified in point 1.2

The Website also downloads data on the User’s geolocation to verify what place (continent, country, city) the User of the Web service uses. Data collected in the manner described above is kept for an indefinite period only for the purpose of administration of the Website, enabling its efficient functioning and application of user-friendly solutions. Please be assured that this information is not disclosed to anyone except those authorized to administer the Website.

2.1. The data collected by the Website is also data provided by the User actively.

2.1.1. The Website enables contacting the relevant departments of the Website using the contact / phone / e-mail form. Contacting in one of the above ways you enter the e-mail address, name and phone number. These data are used only for the purpose of contact, i.e. the preparation of an answer to a question posed by the User.

2.1.2. At any time, the User has the right to inspect the data processed by the Administrator, the right to request their change, as well as to delete them. For this purpose, please contact us at: iod@smartcities.pl

2.1.3. Personal data collected for the needs of the customer’s account, the User can at any time, independently and freely edit and delete. The user may unsubscribe from the newsletter or subscription at any time.

3. Cookies and how they are used

3.1. When using the Website, small files, in particular text files, are stored on the User’s end device, which contain information that allows you to remember login details, recently selected products, products in the User’s basket (hereinafter: “cookies”). Cookies also allow to collect statistical data referred to in point 1.2.2.

3.2. Cookies do not contain data identifying the User, which means it is not possible to determine the User’s identity on their basis. Files used by the Website are not in any way detrimental to the User or the User’s device and do not interfere with its software or settings.

3.3. As a reminder, in general browsers in the default settings have the option to save cookies.

If the User does not agree to save these files on the end device, the User should change the settings of the web browser he uses. Preventing the saving of cookies may consist of: To use the option that is appropriate for the User, read the information about the management of cookies, which are most often found in the browser’s “Settings” or in the “Help” tab. However, you should be aware that in the case where files are necessary for the Website to work, restricting their use may make it difficult to use the Website.

4. Security

.The User’s personal data is stored in a database to which technical and organizational measures have been applied to ensure the protection of data processed in accordance with the requirements set by law on the protection of personal data, in particular in the Act of 18 July 2002 on providing services by electronic means (OJ 2013.1422, as amended), the Act of 29 August 1997 on the Protection of Personal Data (OJ 2015.2135 with later amendments), the Act of 16 July 2004 – the Law on Telecommunications (OJ 2014.243, as amended), as well as the Ordinance of the Minister of Interior and Administration of 29 April 2004 on the personal data processing documentation and technical and organizational conditions which should be met by devices and IT systems used to process personal data ( Official Journal of 2004, No. 100, item 1024). Access to the database is available only to persons authorized by the data controller.

5. Changes

Changes to the privacy policy will be made only to increase the privacy protection standards or to adapt the policy to legal requirements. Each time the User will be informed about the change in the information sent to the email address, if the User has agreed to be contacted in this way.

GDPR (General Data Protection Regulation) INFORMATION CLAUSE

According to art. 13 of the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free flow of such data and repealing Directive 95/46 / EC (General Data Protection Regulation , hereinafter referred to as “GDPR”), acting by the name of ASA Polska SA with headquarters at 00-526 Warsaw, ul. Krucza 16/22 we would like to inform you that:

1. The administrator of your personal data is ASA Polska S.A. with headquarters at 00-526 Warsaw, ul. Krucza 16/22 entered into the National Court Register in the Register of Entrepreneurs under the KRS number: 0000395340, Tax Identification Number: 8331398124, (hereinafter referred to as the “Administrator”);

2. Contact in matters related to the processing of personal data by the Administrator and in order to use the rights related to the processing of personal data is available by phone: +48 22 87 38 700 by email to: dok@asa-fin.com or in writing to the Administrator’s address given above.

3. Your personal data is processed in particular for the purposes of:

related to the implementation of the signed agreement, related to the investigation of possible claims, compensation, responding to letters, applications and complaints, responding in pending proceedings, ensuring security on the premises belonging to the Company and property protection (including monitoring of IT systems, internal visual identification of employees / contractors, application of access control system), financial, administrative and IT services, including assumption and maintenance of accounts in IT systems, sharing data with entities authorized to do so on the basis of law and entities to whom the application is necessary due to the use by the employee with special rights provided for in the labor law.

4. The legal basis for the processing of your personal data is: indispensability to conclude and execute the agreement(Article 6 paragraph 1 letter b) of the GDPR), legal provision – within the scope of obligations resulting from these provisions (Article 6 paragraph 1 letter c) GDPR), legitimate interests of the administrator (Article 6 paragraph 1 letter f) of the GDPR), i.e. providing security on the premises belonging to the Company – where it is a justified interest to guarantee security; management of development and human resources, including raising qualifications – where it is a justified interest to care for the highest level of management and other employees / contractors, consent in a wider scope than that resulting from the provisions of law (Article 6 paragraph 1 letter a) GDPR).

5. Your personal data will be stored for the time necessary to achieve the purposes for which these data are collected, the performance of obligations arising from the law, and for the maximum period of securing the materials necessary for legal proceedings and until the time limits for claims. In the event of processing personal data based on the expressed consent, the Administrator will keep the data until the consent is withdrawn. The administrator will complete the processing of data collected on the basis of a legitimate interest if there is objection to the processing of data for these purposes. After the processing period, the data is irreversibly deleted or irreversibly anonymised.

6. The administrator may transfer personal data to the following external entities:

a) entities providing services in the field of protection of persons and property,

b) IT systems and IT service providers,

c) entities with which the Administrator has concluded cooperation agreements with in order to perform the duties of the Administrator provided for by law, protection of its rights in accordance with the law and implementation of the justified interest of the Administrator in the meaning of the provisions on the protection of personal data, such as entities providing consulting services to the Administrator, as well as services concerning: consultancy , audit, training, organizational, legal, tax, accounting, human resources and accounting,

(d) supervisory authorities, authorities and other third parties where this is necessary

7. You have the right to:

  • access to your data, requests for rectification, deletion or limitation of their processing,
  • raise objections to the processing of personal data to the extent that the basis for the processing of personal data is the legitimate interest of the Administrator,
  • the withdrawal of consent at any time to the extent that it is the basis for data processing. Withdrawal of consent shall not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal,
  • transfer of the personal data, i.e. to receive information from the Administrator about the personal data being processed, in a structured, commonly used machine-readable format, to the extent that your data is processed in order to conclude and perform the contract or on the basis of consent,
  • lodging a complaint to the President of the Office for the Protection of Personal Data.

Asa Polska S.A., Warsaw (00-526), ul. Krucza 16/22, KRS (National Court Register number) : 0000395340 share capital PLN 2,400,000.00 fully paid up.