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Privacy policy of NEWATER Sp. z o. o.

This document sets out the PRIVACY POLICY applied in the daily operations of NEWATER Sp. z o.o. with its registered office in Gdańsk, ul. Norwida 2, 80-280 Gdańsk, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court Gdańsk – North in Gdańsk, 7th Commercial Division of the National Court Register, under KRS number: 0001147474, with NIP number: 8992872309 (hereinafter referred to as the Personal Data Controllerfor the purposes of this document).

Considering the principles underlying the introduction 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 (hereinafter referred to as GDPR (RODO)), this PRIVACY POLICY is intended to respect the privacy and ensure the security of all data and information – including personal data – entrusted by persons using or interested in using the services of the Personal Data Controller, including users of the website at https://newater.pl, owned by the Personal Data Controller, while focusing on enabling efficient and effective contact between the parties and on recognising the needs and behaviours of interested parties and adapting the services offered by the Controller to them.

This PRIVACY POLICY covers with particular care the protection of personal data of natural persons, whereby personal data should be understood as any information about an identified or identifiable natural person, such as, for example: name and surname, nickname, identification number, address, telephone/fax number, email address, geolocation data, internet ID, bank account number, preferences regarding the services offered, interests – regardless of the form these data take (materialised, dematerialised), including in particular personal data processed in a fully or partially automated manner.

This PRIVACY POLICY applies regardless of how contact between the Personal Data Controller and the data subject has been established – this may include, among others, personal contact, contact by telephone, email, letter, social media, or even use of the Controller’s website at https://newater.pl.

Among other things, this document – PRIVACY POLICY – contains information about:

(1) methods and (2) reasons for collecting and processing data and information from the Controller’s customers and users of this website, (3) rules regarding personal data security observed by the Controller in the course of its activities, including provision of services, as well as (4) information on the possibility and procedure for an interested natural person to exercise their rights under the law (in particular under GDPR) with regard to their personal data processed by the Controller.

Please read this PRIVACY POLICY to the extent that is necessary, since by entering into interaction with the Personal Data Controller or by visiting the website at https://newater.plor by using it and sending any data via this website, including personal data, you accept the terms of this PRIVACY POLICY applied by the Controller.

Please note that by leaving the indicated website (e.g. by following a link to another website), the user is transferred to a website where this PRIVACY POLICY does not apply, and the Personal Data Controller is not responsible for the privacy policies applicable to websites operated by third parties.

The Personal Data Controller reserves the right to amend the above PRIVACY POLICY by publishing its applicable content on this website. Changes to the PRIVACY POLICY may be influenced by changes in personal data protection regulations, as well as other factors beyond the Controller’s discretion, and furthermore, by enhancement or improvement of the protection of personal data processed by the Controller. Information about any changes to the PRIVACY POLICY, as well as the content of the currently applicable PRIVACY POLICY, will always be available on the Controller’s websites.

How and to what extent may your personal and other data be collected?

We only collect and process personal data provided voluntarily by a given natural person, with the exception of data collected automatically via ‘cookies’ or ‘web beacons’ in certain situations, as detailed below.

When visiting the Personal Data Controller’s website, data relating to the visit, such as the user’s IP address, domain name, browser type, operating system type (login data), is collected automatically. Data collected automatically may be used to analyse user behaviour on our website, collect demographic data about our users, or to personalise the content of our websites in order to improve its content. However, this data is processed solely for administrative purposes and to ensure efficient operation of the website, and is not associated with personal data of individual users.

Visit our website https://newater.pl to find the e-mail address: politykaprywatnosci@newater.pl, for direct contact with the Personal Data Controller in any matter. Please provide the following information when writing to us: your name and surname, return email address/telephone number, description of your enquiry – provision of this data is voluntary, yet necessary for the Personal Data Controller to prepare and provide response to your enquiry. The data you provide will not be used by the Controller for any other purpose, unless you expressly consent to this, e.g. by subscribing to the newsletter.

Furthermore, in relation to or in connection with offering and providing services or in order to establish contact between the parties, the Personal Data Controller may collect and process, among other things, the following personal data necessary or required for the Personal Data Controller to conduct its business:

first and last name;
residence and mailing address;
e-mail address;
phone number.

Personal data may be obtained by the Personal Data Controller via:

online forms – information is collected via forms available on this website which are used for contact purposes, submitting questions and comments. By completing the form at https://newater.pl the user agrees that their data will be transferred to the following e-mail addresses: biuro@newater.pl; serwis@newater.pl;
contact with the Personal Data Controller outside the website in any possible way – the website contains information about the Controller’s registered office, telephone numbers and email addresses at which you can contact the Controller;
recording data on network traffic and statistics on the frequency of visits to websites which belong to the Controller – there may be a register of information on traffic data which is automatically recorded by the server, such as the user’s IP address, the URL visited before visiting this website, URLs visited after visiting this website, and other visited websites. Statistics on the number of visits to the the website and page views, may also be collected, whereby the Controller is not able to directly determine the identity of the user on the basis of traffic data and statistics on the use of the website;
use of resources on the website belonging to the Personal Data Controller – information about users of this website may be collected via mechanisms such as ‘cookies’ or ‘web beacons’, whereby:
1. cookies’ – are small text files called ‘cookies’, sent by this website and stored on the user’s end device (computer, laptop, smartphone). We use them to customise content and services to the individual needs and interests of website users, understand the way users use our website, and continuously improve our website, making it even more user-friendly and customised to the needs of users. The user may disable the option of accepting cookies in their browser at any time, however such a change may significantly limit the functionality or optimisation of the Personal Data Controller’s website;
2. ‘web beacons’ – electronic graphic elements (also known as web bugs, clear gifs or trackers), which enable to determine the number of users who visited our website by clicking on an advertisement for our products and services from the website of another operator. Web beacons collect a limited amount of information, including cookie number, time and date of page access, and a description of the page where the web beacon is located. As web beacons are used in connection with cookies, they can be deactivated by disabling cookies or changing the cookie settings in your browser.
The Controller uses ‘cookies’ for the following purposes:
1. for website configuration
  1. to adapt the content of the website to user preferences and optimise the use of the website;
  2. to identify the user’s device and location and display the website accordingly, tailored to the user’s individual needs;
  3. to save the settings selected by the user and personalise user interface, e.g. in terms of the selected language or region where the user comes from;
  4. to remember the history of pages visited on the site in order to recommend content;
  5. font size, website appearance, etc.
2. for user authentication on the website and securing the user’s session on the website
  1. for correct configuration of selected website functions, enabling in particular verification of the authenticity of the browser session;
  2. to optimise and improve the efficiency of the services provided by the Controller.
3. for implementation of processes necessary for the full functionality of the websites
  1. to adapt the content of the website to user preferences and optimise use of the website. In particular, these files allow the basic parameters of the user device to be recognised and the website to be displayed accordingly, customised to their individual needs;
  2. proper operation of the affiliate programme, enabling in particular the verification of sources of user redirects to the website.
4. to remember user location
  1. for correct configuration of selected website functions, enabling in particular the adaptation of the information provided to the user, based on their location.
5. Analyses, research and audience auditing
  1. to generate anonymous statistics to help understand how users use the website, which enables us to improve its structure and content.
6. for the provision of advertising services and other marketing activities
  1. to customise the advertisements of third-party services and products presented via the website
7. to ensure safety and reliability of the website.

What is the legal basis for the collection and processing of your personal and other data?

As part of business activities consisting in the broadly understood provision of investment, design and consultancy services, the Personal Data Controller collects and processes personal data of natural persons on an occasional and subsidiary basis in relation to the above-mentioned core business. The Personal Data Controller does not collect sensitive personal data within the meaning of Art. 9 of the GDPR, such as information about racial/ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, sexuality or sexual orientation.

Personal data is collected and processed by the Personal Data Controller within the limits permitted by Art. 6 of the GDPR, exclusively on the following grounds:

on the basis of the consent granted by a natural person to the processing of their personal data for a specific purpose, or;
when processing personal data is indispensable for the performance of a contract to which the data subject in question is a party, or for taking action at the request of the data subject in question prior to entering into a contract; or
when processing is necessary to comply with a legal obligation; or
when processing is necessary to protect the vital interests of the data subject or another natural person; or
when processing is necessary for the performance of a task carried out for reasons of public interest or in the exercise of official authority;
when processing is necessary for the purposes of legitimate interests pursued by the Personal Data Controller or by a third party, unless the interests or fundamental rights and freedoms of the data subject, which require the protection of personal data, override those interests.

How is your personal and other data protected?

All personal data is processed by the Personal Data Controller in accordance with the requirements of generally applicable law, in particular in accordance with Regulation 216/679 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 (GDPR) and the Act of 10 May 2018 on the protection of personal data.

The Personal Data Controller acts with due diligence to ensure that all personal data is processed in accordance with the purpose for which it was obtained and used in accordance with the scope, areas and categories of data processing permitted by law. Furthermore, we make every effort to ensure that personal data is processed in a manner that is fair and transparent for data subjects.

We ensure that personal data is processed in accordance with the principles of substantive correctness and in a manner appropriate to the purposes for which the data was obtained. We process and store data only for the period necessary to achieve the purposes for which it was obtained, and for a longer period if we are required to do so by generally applicable laws.

Considering the state of technical knowledge, the cost of implementation, and the nature, scope and purposes of processing, as well as the risk of varying likelihood and severity of the rights and freedoms of natural persons, we implement and apply appropriate technical and organisational measures to ensure a level of security appropriate to the processing of personal data, ensuring confidentiality, integrity and accountability of personal data processing.

Personal data processed by the Personal Data Controller shall not be disclosed to third parties without the consent of the data subjects, unless such disclosure is necessary or required for the performance of a contract between the parties or for the protection of legitimate interests of the Controller, whereby any disclosure of personal data to third parties shall be based on an authorisation to process personal data or a data processing agreement. In particular, the Personal Data Controller reserves the right to entrust the personal data obtained to entities currently cooperating with them, such as: state administration, judicial authorities, human resources and accounting services, entities providing IT and network services, law and audit firms, and other entities authorised under applicable law.

The processed personal data will not be transferred to countries outside the European Union and the European Economic Area, unless the Controller informs the person whose data is to be transferred in advance.

What is the purpose for which the collected personal data may be used?

Personal data obtained by the Personal Data Controller may be used primarily for the purposes of contact between the parties and for the purposes of offering and providing services by the Personal Data Controller, and additionally – to fulfil the legal obligations incumbent on the Controller, e.g. tax settlements.

If a natural person consents to receiving marketing communications, their personal data (in particular: email address, telephone number) will be used to provide information about the products and services of the Personal Data Controller or its business partners. The provision of data, as well as the granting of such consent, is voluntary, however, failure to do so prevents you from receiving marketing communications.

In the case of contact forms posted on the Controller’s websites, personal data will be processed for the purpose of direct contact in the indicated form with the data subject in connection with the submitted enquiry. Personal data may be used by the Controller for statistical purposes.

What are the rights of a person whose personal data is being processed, and how can these rights be exercised?

The Personal Data Controller fully respects the rights of every person whose data is processed, pursuant to the generally applicable regulations in this regard, including in particular the right of a natural person to:

obtain information about the processing of their personal data by the Personal Data Controller and access to it;
request correction of your personal data;
deletion of personal data (“right to be forgotten”);
restrict the processing of personal data;
transfer of personal data;
withdrawal of previously granted consent to the processing of personal data;
object to the processing of personal data for the purposes of the Personal Data Controller, including direct marketing of its services and profiling, as well as the right not to be subject to a decision based solely on automated processing.

If processing is based on the consent of the data subject, that person has the right to withdraw their consent at any time, provided that this does not affect the lawfulness of the processing carried out on the basis of consent prior to its withdrawal, and the withdrawal shall be effective from the moment the Personal Data Controller becomes aware of it, whereby the Controller shall cease processing personal data upon withdrawal of consent only if processing is not possible on another legally permissible basis.

A person whose data is processed by the Personal Data Controller may exercise their rights mentioned above by sending an email to the Personal Data Controller at politykaprywatnosci@newater.pl, stating and describing their request in such a way that it can be fulfilled.

In compliance with the obligation stipulated in GDPR (RODO), we hereby inform that the person whose personal data we process also has the right to lodge a complaint with a supervisory authority if they believe that their rights have been violated.

If you have any questions, comments or other issues with regard to the PRIVACY POLICY applied by the Data Controller, please contact us by e-mail at politykaprywatnosci@newater.pl – we will try to help you learn more about the protection of your personal data!