Privacy Policy

The following Privacy Policy defines the rules for storing and accessing data on Users’ Devices who use the Service for the purposes of electronic service provision by the Administrator, as well as the rules for collecting and processing Users’ personal data, which they have personally and voluntarily provided through the tools available in the Service.

§1 Definitions

1. Service – an online service operating at https://irot.pro
2. External Service – internet services of partners, service providers, or service recipients cooperating with the Administrator
3. Service/Data Administrator – The Service Administrator and Data Administrator (hereinafter the Administrator) is the company "Instytut Rozwoju Oporządzenia Taktycznego Sp. z o.o.", operating at the address: ul. Przemysłowa 19, 11-130 Orneta, Poland, with the tax identification number (NIP): 7432036959, and KRS number: 0000762072, providing electronic services through the Service
   
4. User – a natural person for whom the Administrator provides electronic services via the Service.
5. Device – an electronic device with software through which the User gains access to the Service
6. Cookies – text data collected in the form of files placed on the User’s Device
7. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
8. Personal Data – means information about 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 first and last name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person
9. Processing – means any operation or set of operations performed on personal data or on sets of personal data, whether by automated means or not, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment or combination, restriction, erasure, or destruction;
10. Restriction of processing – means the marking of stored personal data with the aim of limiting their processing in the future
11. Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements
12. Consent – the consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject's wishes, by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them
13. Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed
14. Pseudonymization – means the processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that they are not attributed to an identified or identifiable natural person
15. 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 to a specific user or a natural person.

§2 Data Protection Officer

1. Under Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.
2. In matters concerning data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookie Files

1. Internal cookies – files placed and read from the User’s Device by the Service’s IT system
2. External cookies – files placed and read from the User’s Device by IT systems of external Services. The scripts of external Services that may place cookies on the User’s Devices are intentionally embedded in the Service through scripts and services made available and installed in the Service
3. Session cookies – files placed and read from the User’s Device by the Service during a single session of a given Device. After the session ends, the files are removed from the User’s Device.
4. Persistent cookies – files placed and read from the User’s Device by the Service until they are manually deleted. The files are not automatically deleted after the Device session ends unless the User’s Device configuration is set to delete Cookie files after the Device session ends.

§4 Data Storage Security

1. Mechanisms for storing and reading Cookie files – The mechanisms for storing, reading, and exchanging data between Cookie Files saved on the User’s Device and the Service are implemented through the built-in mechanisms of web browsers and do not allow other data to be downloaded from the User’s Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, trojans, and other worms to the User’s Device is also practically impossible.
2. Internal cookies – the Cookie files 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 User’s Device.
3. External cookies – The Administrator takes all possible actions to verify and select partners of the service in terms of User security. The Administrator selects well-known, large partners with global social trust. However, the Administrator does not have full control over the content of Cookie files from external partners. To the extent permitted by law, the Administrator is not responsible for the security of these Cookie files, their content, or the licensed use by the scripts installed in the service that come from external Services. A list of partners is included later in the Privacy Policy.
4. Cookie control
   1. The User may independently change the settings regarding the saving, deletion, and access to data of saved Cookie files by this website at any time, using the built-in Cookie management module.
   2. Simultaneously, the user can use a global cookie opt-out in the most popular browsers:
      • Manage cookies in Chrome
      • Manage cookies in Opera
      • Manage cookies in FireFox
      • Manage cookies in Edge
      • Manage cookies in Safari
      • Manage cookies in Internet Explorer 11
   3. The User may delete all Cookie files saved so far at any time, using the tools of the User’s Device through which the User accesses the Service.
5. Risks on the User’s side – The Administrator applies all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activities. The Administrator is not responsible for the interception of this data, impersonation of the User’s session, or deletion thereof as a result of conscious or unconscious activity of the User, viruses, trojans, or other spyware that may infect or have infected the User’s Device. Users should follow safe network usage guidelines to protect themselves from these threats.
6. Storing personal data – The Administrator ensures that it makes every effort to keep any personal data voluntarily provided by Users safe, that access to it is restricted and carried out in accordance with its purpose and processing objectives. The Administrator also ensures that it makes every effort to secure the data it holds against loss through the use of appropriate physical and organizational security measures.

§5 Purposes for Which Cookie Files Are Used

1. Improving and facilitating access to the Service
2. Personalizing the Service for Users
3. Marketing, Remarketing on external services
4. Keeping statistics (users, number of visits, types of devices, connection, etc.)
5. Providing multimedia services
6. Providing social networking services

§6 Purposes of Personal Data Processing

1. Personal data voluntarily provided by Users are processed for one of the following purposes:
   1. Provision of electronic services:
      • Newsletter service (including the sending of advertising content with consent)
      • Sharing information about the content published in the Service on social networking sites or other websites.
   2. Communication of the Administrator with Users on matters related to the Service and data protection
   3. Ensuring the legitimate interests of the Administrator
2. Data on Users collected anonymously and automatically are processed for one of the following purposes:
   1. Compiling statistics
   2. Remarketing
   3. Ensuring the legitimate interests of the Administrator

§7 External Services’ Cookie Files

1. The Administrator uses JavaScript scripts and web components of partners in the Service, who may place their own cookies on the User’s Device. Please remember that you can decide in your browser settings which cookies are allowed to be used by specific websites. Below is a list of partners or their services implemented in the Service that may place cookies:

   1. Multimedia services:
      • YouTube
      • Vimeo
   2. Social / combined services:
      (Registration, Login, content sharing, communication, etc.)
      • Twitter
      • Facebook
      • Google
      • LinkedIn
   3. Newsletter services:
      • GetResponse
   4. Statistics services:
      • Google Analytics
      • Ahrefs
   5. Other services:
      • Google Maps
2. Services provided by third parties are beyond the Administrator’s control. These entities may change their terms of service, privacy policies, data processing purposes, and cookie usage methods at any time.

§8 Types of Collected Data

1. The Service collects data about Users. Some data is collected automatically and anonymously, and some are personal data provided voluntarily by Users when signing up for specific services offered by the Service.
   1. Anonymous data collected automatically:
      • IP Address
      • Browser type
      • Screen resolution
      • Approximate location
      • Opened subpages of the service
      • Time spent on a given subpage of the service
      • Type of operating system
      • Address of the previous subpage
      • Referrer page address
      • Browser language
      • Internet connection speed
      • Internet service provider
   2. Data collected during registration:
      • First name / last name / nickname
      • Email address
      • Phone number
      • IP address (collected automatically)
      • NIP (Tax ID Number)
      • KRS (Company Registration Number)
      • REGON (Business Registry Number)
   3. Data collected when subscribing to the Newsletter service
      • First name / last name / nickname
      • Email address
      • IP address (collected automatically)
2. Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be provided to the statistics service provider.

§9 Access to Personal Data by Third Parties

1. In principle, the only recipient of personal data provided by Users is the Administrator. The data collected as part of the services provided are not transferred or resold to third parties.
2. Access to data (usually based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the service, i.e.:
   1. Hosting companies providing hosting or related services for the Administrator
   2. Companies through which the Newsletter service is provided
   3. Service and IT support companies performing maintenance or responsible for maintaining the IT infrastructure
   4. Companies responsible for the Administrator’s accounting (in the case of using paid services from the Administrator)
   5. Companies responsible for delivering physical products to the User (postal / courier services if any information needs to be sent in writing)
3. Entrusting the processing of personal data:
   1. Newsletter – The Administrator uses the services of a third party – GetResponse – to provide the Newsletter service. The data entered in the newsletter sign-up form are transferred, stored, and processed in the external service of this provider.
      Please note that the indicated partner may modify its privacy policy without the Administrator’s consent.
   2. Hosting, VPS, or Dedicated Server Services – To run the Service, the Administrator uses an external hosting provider, VPS, or Dedicated Servers – ABHOST Sp. z o.o.. All data collected and processed within the Service are stored and processed in the provider’s infrastructure located within the EU. Access to these data may occur due to maintenance work carried out by the provider’s personnel. Access to these data is regulated by an agreement between the Administrator and the Service Provider.
   3. Website service support – The Administrator uses the services of an external service provider – ABHOST Sp. z o.o. – to service the website. The personnel of the said entity have access to the data entered by users during registration and editing of the user account and/or data related to the Newsletter service. Access to these data is regulated by an agreement between the Administrator and the Service Provider.
4. Transfer of personal data:
   1. Accounting services – In the event of a transaction, some personal data of natural persons or data of natural persons conducting business activity are transferred to the entity providing accounting services to the Administrator. The transfer of these data is regulated by the Act and the agreement concluded between the Administrator and the Service Provider.
   2. Courier services – In the event of a transaction that requires transferring the item to which the transaction relates via mail or courier, some personal data of natural persons or data of natural persons conducting business activity are transferred to the entity providing postal/courier services for the Administrator, chosen by the User. The transfer of these data is regulated by the agreement concluded between the Administrator and the Service Provider.

§10 Method of Processing Personal Data

1. Personal data voluntarily provided by Users:
   1. Personal data will not be transferred outside the European Union unless they have been published as a result of an individual action by the User (e.g., adding a comment or posting), which will make the data available to anyone visiting the Service.
   2. Personal data will not be used for automated decision-making (profiling).
   3. Personal data will not be resold to third parties.
2. Anonymous data (without personal data) collected automatically:
   1. Anonymous data (without personal data) will be transferred outside the European Union.
   2. Anonymous data (without personal data) will not be used for automated decision-making (profiling).
   3. Anonymous data (without personal data) will not be resold to third parties.

§11 Legal Grounds for Personal Data Processing

1. The Service collects and processes Users’ data based on:
   1. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR)
      • Art. 6(1)(a)
        the data subject has given consent to the processing of their personal data for one or more specific purposes
      • Art. 6(1)(b)
        processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract
      • Art. 6(1)(f)
        processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
   2. Act of 10 May 2018 on the protection of personal data (Polish Journal of Laws 2018 item 1000)
   3. Act of 16 July 2004 Telecommunications Law (Polish Journal of Laws 2004 No. 171 item 1800)
   4. Act of 4 February 1994 on Copyright and Related Rights (Polish Journal of Laws 1994 No. 24 item 83)

§12 Period of Personal Data Processing

1. Personal data voluntarily provided by Users:

   In principle, the personal data in question is stored only for the duration of the provision of the Service by the Administrator. They are deleted or anonymized within up to 30 days from the moment of terminating the provision of services (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.).

   An exception is a situation that requires securing legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the data, from the time the User requests their deletion, no longer than for 3 years if the User violates or is suspected of violating the Service’s regulations.

2. Anonymous data (without personal data) collected automatically:

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

§13 Users’ Rights Related to the Processing of Personal Data

1. The Service collects and processes Users’ data based on:
   1. The right of access to personal data – Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator
   2. The right to rectification of personal data – Users have the right to request the Administrator to promptly rectify any personal data that is inaccurate or to complete any incomplete personal data, exercised upon request submitted to the Administrator
   3. The right to erasure of personal data – Users have the right to request the Administrator to promptly erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, erasing data involves anonymizing data that enables the User to be identified. The Administrator reserves the right to suspend the request to erase data to protect the legally justified interests of the Administrator (e.g., if the User has violated the Service Regulations or if the data was obtained as a result of correspondence).
      In the case of the Newsletter service, the User can delete their personal data themselves by using the link included in each email message sent.
   4. The right to restrict the processing of personal data – Users have the right to restrict the processing of personal data in the cases indicated in Art. 18 of the GDPR, e.g., questioning the correctness of personal data, exercised upon request submitted to the Administrator
   5. The right to data portability – Users have the right to receive from the Administrator the personal data concerning them in a structured, commonly used, and machine-readable format, exercised upon request submitted to the Administrator
   6. The 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, exercised upon request submitted to the Administrator
   7. The right to lodge a complaint – Users have the right to lodge a complaint with the supervisory authority in charge of personal data protection.

§14 Contact with the Administrator

1. The Administrator can be contacted in one of the following ways
   1. Postal address – Instytut Rozwoju Oporządzenia Taktycznego, Przemysłowa 19, 11-130 Orneta, Poland
   2. Email address – irot@irot.pro
   3. Telephone – +48 883 356 411
   4. Contact form – available at: https://irot.pro/kontakt

§15 Service Requirements

1. Restricting the saving and accessing of Cookie files on the User’s Device may cause some of the Service’s functions to malfunction.
2. The Administrator assumes no responsibility for the improperly functioning Service features if the User restricts, in any way, the ability to save and read Cookie files.

§16 External Links

1. In the Service – in articles, posts, entries, or Users’ comments – there may be links to external websites with which the Owner of the Service does not cooperate. These links and the sites or files under them may be dangerous for your Device or may pose a threat to the security of your data. The Administrator is not responsible for any content located outside the Service.

§17 Changes to the Privacy Policy

1. The Administrator reserves the right to make any changes to this Privacy Policy without notifying Users, to the extent of using and processing anonymous data or using Cookie files.
2. The Administrator reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, of which it will inform Users with user accounts or who are subscribed to the newsletter by email within 7 days of the changes. Continuing to use the services means having read and accepted the changes to the Privacy Policy. If the User does not agree with the changes made, they are obliged to delete their account from the Service or unsubscribe from the Newsletter.
3. The introduced changes to the Privacy Policy will be published on this subpage of the Service.
4. The introduced changes come into effect upon their publication.