Privacy Policy

Data of the Personal Data Administrator

1. We kindly inform you that the administrator of your personal data is the company BESTLER Paweł Jędrychowicz, Akacjowa 25 Street, 08-110 Siedlce, NIP: 8361761641, hereinafter referred to as „ADO”. The ADO can be contacted regarding personal data protection at the following e-mail address: bestler@bestler.pl.

Purposes and grounds for processing personal data

1. In order to provide services in accordance with its business profile, ADO processes personal data of visitors to this website for various purposes, but always in accordance with the law. Below are the specific purposes of personal data processing, along with the legal basis.
2. In order to handle inquiries, consultations, telephone contact with customers and persons interested in the company's services, we process such personal data as name, surname, telephone number, e-mail address, gender, order number, date of registration. The legal basis for such data processing is Article 6(1)(a) and (b) of the RODO, which allows us to process personal data if it is necessary for the performance of a contract or taking steps to conclude a contract, e.g. handling an inquiry from a contact form, and on the basis of voluntary consent, which in this case is expressed by completing and submitting a contact form on the website;
3. For analytical purposes, i.e. researching and analyzing activity on the website belonging to ASO, we process such personal data as: date and time of website visit, type and version of operating system, approximate location, screen resolution, number of colors supported by the screen, type and version of Internet browser, time spent on the website, subpages visited, subpage where contact form was filled in. The legal basis for such data processing is Article 6(1)(f) of the RODO, which allows personal data to be processed if, by doing so, the Personal Data Controller pursues its legitimate interest (in this case, the interest is to learn about customer activity on the website);
4. In order to use cookies and local storage on the website, we process such textual information (cookies will be described in a separate section). The legal basis for such processing is Article 6(1)(a) of the RODO, which allows us to process personal data on the basis of voluntarily given consent (when you first access the website, you are asked if you agree to the use of cookies);
5. In order to administer the website, we process such personal data as IP address, port number, server date and time, browser information, operating system information. These data are recorded automatically in the so-called server logs every time you use a website belonging to ADO. Administration of the website without the use of the server and without this automatic recording would not be possible. The legal basis for such data processing is Article 6(1)(f) of the RODO, which allows personal data to be processed if, by doing so, the Personal Data Administrator pursues its legitimate interest (in this case, the Company's interest is the administration of the website);

Cookies

1. ADO on its website, as well as other entities, uses so-called cookies, which are short text information stored on your computer, phone, tablet or other device. They can be read by our system, as well as by systems belonging to other entities whose services we use (such as Google and Facebook).
2. Cookies perform a great many functions on the website, most often useful, which we will try to describe below (if the information is insufficient, please contact us):
   • providing security - cookies are used to authenticate users and prevent unauthorized use of the customer panel. Thus, they are used to protect the user's personal information from unauthorized access;
   • Influence on the processes and efficiency of the use of the website - cookies are used so that the website works efficiently and so that you can use the functions available on it, which is possible, among other things, by remembering your settings between visits to the website. Thanks to them, therefore, you can efficiently navigate the website and individual subpages;
   • session status - cookies often store information about how visitors use the website, such as which subpages they view most often. They also make it possible to identify errors displayed on certain subpages. Cookies for storing so-called „session state” therefore help to improve services and enhance the browsing experience;
   • Maintaining session status - if the customer logs in to his/her panel, cookies allow the session to be maintained. This means that when you go to another subpage, you do not have to re-enter your login and password each time, which promotes the comfort of using the website;
   • creation of statistics - cookies are used to analyze how users use the website (how many open the website, how long they stay on it, which content arouses the most interest, etc.). This allows us to continuously improve the website and adapt its operation to users' preferences. We use Google's tools, such as Google Analytics, to track activity and generate statistics; in addition to reporting website usage statistics, the Google Analytics pixel can also be used, along with some of the cookies described above, to help display more relevant content to you on Google's services (e.g., Google Search) and across the web;
   • use of social features - we have a so-called Facebook pixel on the website, which allows you to like our fanpage on this site when using the website. However, for this to be possible, we must use cookies provided by Facebook.
3. Your web browser, by default, allows the use of cookies on your device, so please agree to the use of cookies on your first visit. However, if you do not wish to use cookies when browsing the website, you can change the settings in your web browser - completely block the automatic handling of cookies or request notification whenever cookies are placed on your device. You can change your settings at any time.
4. While respecting the autonomy of everyone using the website, we feel obliged to warn you that disabling or restricting cookies may cause difficulties in using the website, such as the need to log in to each subpage, longer page load times, limitations on the use of functionality, limitations on liking the Facebook page, etc.

Right to withdraw consent

1. If the processing of personal data is based on consent, this consent can be withdrawn at any time.
2. To withdraw your consent to the processing of personal data, send an e-mail with the relevant information on the subject directly to ADO by writing to: bestler@bestler.pl.
3. If the processing of personal data was carried out on the basis of consent, revoking it does not make the processing of personal data up to that point illegal. In other words, we have the right to process personal data until we revoke consent, and revoking consent does not affect the legality of previous processing.

Requirement of personal data

1. The provision of any personal data is voluntary and subject to individual decision. However, in some cases, the provision of certain personal data is necessary to meet the expectations for the use of services.
2. In order to be contacted by phone on matters related to the implementation of the service or the handling of an inquiry from the contact form, it is necessary to provide a telephone number - without this we are unable to make telephone contact.

Automated decision-making and profiling

1. We do not perform automated decision-making, including based on profiling. The content of an inquiry that is sent via a contact form is not evaluated by an information system. Information systems do not make any assessments based on data obtained from our website.

Recipients of personal data

1. Like most entrepreneurs, we use the assistance of other entities in our business, which sometimes involves the transfer of personal data. Therefore, if necessary, we transfer personal data to cooperating lawyers who perform services, payment processing companies, an accounting company, a hosting company, a company responsible for sending SMS messages, as well as an insurance company (should there be a need to repair a loss).
2. In addition to this, it may happen that, for example, on the basis of a relevant provision of law or a decision of a competent authority, we may also have to provide personal data to other entities, whether public or private. Therefore, it is extremely difficult for us to predict who may come forward with a request for personal data. Nevertheless, for our part, we assure you that we analyze each request for personal data very carefully and thoroughly, so that we do not pass the information to an unauthorized person.

Transfer of personal data to third countries

1. Like most businesses, we use a variety of popular services and technologies, offered by entities such as Facebook, Microsoft, Google, Cloudflare and Zendesk. These companies are based outside the European Union, and are therefore considered third countries under the provisions of the RODO.
2. The RODO introduces certain restrictions on the transfer of personal data to third countries, because since European laws do not apply there, as a rule, the protection of personal data of EU citizens may be insufficient. Therefore, each personal data controller is required to establish a legal basis for such transfers.
3. For our part, we assure you that when using our services and technologies, we transfer personal data only to entities in the United States and only to those that have joined the Privacy Shield program, based on the European Commission's executive decision of July 12, 2016. - You can read more about this at European Commission website. Entities that have joined the program Privacy Shield, guarantee that they will comply with the high standards of personal data protection that apply in the European Union, so the use of their services and offered technologies in the processing of personal data is lawful.
4. We will provide additional clarification on the transfer of personal data at any time, especially if the issue is of concern.
5. At any time you have the right to obtain a copy of personal data transferred to a third country.

Period of personal data processing

1. In accordance with applicable laws, we do not process personal data „indefinitely”, but for the time it takes to achieve the designated purpose. After this period, personal data will be irreversibly deleted or destroyed.
2. In situations where we do not need to perform operations on personal data other than storing them (for example, when we store the contents of an order for the purpose of defending against claims), we additionally secure them - by pseudonymization - until they are permanently deleted or destroyed. Pseudonymization involves encrypting personal data, or a set of personal data, in such a way that it cannot be read without an additional key, and therefore such information becomes completely useless to an unauthorized person.
3. Regarding specific processing periods for personal data, we kindly inform you that we process personal data for a period of time:
   • the duration of the contract - with respect to personal data processed for the purpose of concluding and performing the contract;
   • 3 years or 10 years + 1 year - for personal data processed for the purpose of establishing, asserting or defending claims (the length of the period depends on whether both parties are entrepreneurs or not);
   • 6 months - with regard to personal data that was collected in the valuation of the service, while there was no immediate conclusion of the contract;
   • 5 years - for personal data involving compliance with tax law obligations;
   • Until the consent is withdrawn or the purpose of the processing is achieved, but for no longer than 5 years - for personal data processed on the basis of consent;
   • until an effective objection is lodged or the purpose of the processing is achieved, but for no longer than 5 years - with regard to personal data processed on the basis of the legitimate interest of the Personal Data Controller or for marketing purposes;
   • Until obsolete or no longer useful, but for no longer than 3 years - for personal data processed primarily for analytical purposes, use of cookies and website administration.
4. We count periods in years from the end of the year in which we began processing personal data in order to streamline the process of deleting or destroying personal data. Counting the period separately for each concluded contract would involve significant organizational and technical difficulties, as well as a significant financial outlay, so establishing a single date for the deletion or destruction of personal data allows us to manage these processes more efficiently. Of course, in the event that the right to forget is exercised by a person, such situations are considered on a case-by-case basis.
5. The extra year associated with the processing of personal data collected for contract performance is dictated by the fact that, hypothetically, you may make a claim moments before the expiration of the statute of limitations, the demand may be served with a significant delay, or you may misstate the statute of limitations for your claim.

Entitlements of data subjects

1. We kindly inform you that you have the right to:
   • Access to their personal data;
   • rectification of personal data;
   • deletion of personal data;
   • limitation of personal data processing;
   • Object to the processing of personal data;
   • portability of personal data.
2. We respect your rights under data protection laws and strive to facilitate their exercise to the greatest extent possible.
3. We point out that the enumerated rights are not absolute, and therefore in certain situations we may lawfully refuse to comply with them. However, if we refuse to grant a request, it is only after careful consideration and only in situations where denial of the request is necessary.
4. Regarding the right to object, we explain that you have the right to object at any time to the processing of your personal data on the basis of the legitimate interest of the Personal Data Controller in relation to your particular situation. However, please note that according to the regulations, we may refuse to consider your objection if we demonstrate that:
   • there are legitimate grounds for processing that override your interests, rights and freedoms,
   • there are grounds for the establishment, investigation or defense of claims.
5. In addition, you may object to the processing of your personal data for marketing purposes at any time. In such a situation, upon receipt of your objection, we will cease processing for such purposes.
6. You may exercise your rights by sending an email directly to ADO at bestler@bestler.pl.

The right to file a complaint

1. If you believe that your personal data is being processed in violation of applicable law, you may file a complaint with the President of the Office for Personal Data Protection.

Final provisions

1. To the extent not covered by this Privacy Policy, the data protection regulations shall apply.
2. You will be notified by email of any changes made to this Privacy Policy.
3. This Privacy Policy is effective as of May 25, 2018.