Privacy Policy
The following Privacy Policy defines the principles of storing and accessing data on User Devices using the Service for the purposes of providing electronic services by the Administrator and the principles of collecting and processing Users' personal data, which were provided by them personally and voluntarily through tools available in the Service.
The following Privacy Policy is an integral part of the Service Terms, which defines the rules, rights and obligations of Users using the Service.
§1 Definitions
- Service - the "ZYNT" web service operating at https://getzynt.com
- External Service - web services of partners, service providers or service recipients cooperating with the Administrator
- Service/Data Administrator - The Service Administrator and Data Administrator (hereinafter Administrator) is the company "2WM", conducting business at the address: ul. Świętego Mikołaja 8/11 lok. 208, 50-125 Wrocław, with tax identification number (NIP): 8971943352, providing electronic services through the Service
- User - a natural person for whom the Administrator provides electronic services through the Service
- Device - electronic device together with software, through which the User gains access to the Service
- Cookies - text data collected in the form of files placed on the User's Device
- GDPR - 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)
- 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 name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
- Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
- Restriction of processing - means the marking of stored personal data with the aim of limiting their future processing
- 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 analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements
- Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
- Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
- Pseudonymisation - means the processing of personal data in such a manner that the personal data 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
- Anonymisation - Anonymisation of data is an irreversible process of operations on data that destroys/overwrites "personal data" making it impossible to identify or link a given record with a specific user or natural person
§2 Data Protection Officer
Based on Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer.
In matters concerning data processing, including personal data, please contact the Administrator directly.
§3 Types of Cookie Files
- Internal Cookies - files placed and read from the User's Device by the Service's teleinformation system
- External Cookies - files placed and read from the User's Device by teleinformation systems of External Services. Scripts of External Services that may place Cookie files on User Devices have been consciously placed in the Service through scripts and services made available and installed in the Service
- Session Cookies - files placed and read from the User's Device by the Service or External Services during one session of the given Device. After the session ends, files are deleted from the User's Device
- Persistent Cookies - files placed and read from the User's Device by the Service or External Services until their manual deletion. 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
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Cookie storage and reading mechanisms - The mechanisms for storing, reading and exchanging data between Cookie Files stored on the User's Device and the Service are implemented through built-in mechanisms of web browsers and do not allow downloading other data from the User's Device or data from other websites that the User visited, including personal data or confidential information. Transfer of viruses, trojans and other worms to the User's Device is also practically impossible.
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Internal Cookies - Cookie files used by the Administrator are safe for User Devices and do not contain scripts, content or information that could threaten the security of personal data or the security of the Device from which the User uses.
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External Cookies - The Administrator makes every possible effort to verify and select service partners in the context of User security. The Administrator selects known, large partners with global social trust for cooperation. However, it does not have full control over the content of Cookie files originating from external partners. The Administrator is not responsible for the security of Cookie files, their content and compliant use by Scripts installed in the service, originating from External Services, to the extent permitted by law. The list of partners is included in the further part of the Privacy Policy.
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Cookie control
- The User can at any time independently change settings regarding saving, deleting and accessing data stored in Cookie files by each website
- Information on how to disable cookies in the most popular computer browsers is available at: how to disable cookies or from one of the indicated providers:
- The User can at any time delete all Cookie files saved so far using the tools of the User's Device through which the User uses the Service's services.
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Threats on the User side - The Administrator uses all possible technical means 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 activity. The Administrator takes no responsibility for intercepting this data, impersonating the User's session or deleting it, as a result of conscious or unconscious User activity, viruses, trojans and other spyware with which the User's Device may be or was infected. Users should follow safe internet usage rules to protect themselves from these threats.
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Personal data storage - The Administrator ensures that it makes every effort to ensure that personal data entered voluntarily by Users is safe, access to it is limited and implemented in accordance with their purpose and processing purposes. The Administrator also ensures that it makes every effort to secure the data it possesses against loss, by using appropriate physical and organizational security measures.
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Password storage - The Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. Decryption of passwords provided in the Service for account access is practically impossible.
§5 Purposes for Which Cookie Files Are Used
- Improving and facilitating access to the Service
- Personalizing the Service for Users
- Enabling login to the service
- Marketing, Remarketing in external services
- Affiliate services
- Conducting statistics (users, number of visits, types of devices, connection, etc.)
- Serving multimedia services
- Providing social services
§6 Purposes of Personal Data Processing
Personal data provided voluntarily by Users is processed for one of the following purposes:
- Implementation of electronic services:
- User registration and account maintenance services in the Service and related functionalities
- Newsletter services (including sending advertising content with consent)
- Services for commenting/liking posts in the Service without the need to register
- Services for sharing information about content placed in the Service on social networks or other websites
- Administrator's communication with Users regarding Service-related matters
- Ensuring the Administrator's legally justified interest
Data about Users collected anonymously and automatically is processed for the purposes of:
- Conducting statistics
- Remarketing
- Handling affiliate programs
- Ensuring the Administrator's legally justified interest
§7 Cookie Files from External Services
The Administrator uses javascript scripts and web components of partners in the Service, who may place their own cookie files on the User's Device. Remember that in your browser settings you can decide on allowed cookies that can be used by individual websites.
Below is a list of partners or their services implemented in the Service that may place cookie files:
- Multimedia services:
- Social/connected services:
(Registration, Login, content sharing, communication, etc.)
- Content sharing services:
- Newsletter services:
- Statistics services:
- Other services:
§8 Types of Collected Data
The Service collects data about Users. Some data is collected automatically and anonymously, and some data is personal data provided voluntarily by Users during registration for individual services offered by the Service.
Anonymous data collected automatically:
- IP address
- Browser type
- Screen resolution
- Approximate location
- Opened subpages of the service
- Time spent on the appropriate subpage of the service
- Operating system type
- Previous subpage address
- Referring page address
- Browser language
- Internet connection speed
- Internet service provider
Personal data provided voluntarily by Users:
- First name / last name / pseudonym
- Login
- Email address
- IP address (collected automatically)
- Other ordinary data
Data collected during newsletter subscription:
- First name / last name / pseudonym
- Email address
- IP address (collected automatically)
Data collected when adding a comment:
- First and last name / pseudonym
- Email address
- Website address
- IP address (collected automatically)
Some data (without identifying data) may be stored in cookie files. Some data (without identifying data) may be transferred to the statistics service provider.
§9 Access to Personal Data by Third Parties
As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the provided services is not transferred or sold to third parties.
Access to data (usually based on a Data Processing Agreement) may be held by entities responsible for maintaining infrastructure and services necessary to run the service, such as:
- Hosting companies providing hosting services or related services for the Administrator
- Companies through which the Newsletter service is provided
Entrusting Personal Data Processing - Newsletter
The Administrator, in order to provide the Newsletter service, uses the services of a third party - MailChimp, Mailerlite, HubSpot services. Data entered in the newsletter subscription form is transferred, stored and processed in the external service of this service provider.
We inform that the indicated partner may modify the indicated privacy policy without the Administrator's consent.
Entrusting Personal Data Processing - Hosting, VPS or Dedicated Server Services
The Administrator, in order to run the service, uses the services of an external hosting, VPS or Dedicated Server provider - OVH sp. z o.o. All data collected and processed in the service is stored and processed in the service provider's infrastructure located within the borders of the European Union. There is a possibility of access to data as a result of service work performed by the service provider's personnel. Access to this data is regulated by the contract concluded between the Administrator and the Service Provider.
§10 Method of Personal Data Processing
Personal data provided voluntarily by Users:
- Personal data will not be transferred outside the European Union, unless it has been published as a result of individual User action (e.g. entering a comment or post), which will make the data available to anyone visiting the service.
- Personal data is used for automated decision-making (profiling).
- Profiling of personal data does not produce legal effects or similarly significantly affect the person whose data is subject to automated decision-making.
- Personal data will not be sold to third parties.
Anonymous data (without personal data) collected automatically:
- Anonymous data (without personal data) will be transferred outside the European Union.
- Anonymous data (without personal data) will not be used for automated decision-making (profiling).
- Anonymous data (without personal data) will not be sold to third parties.
§11 Legal Basis for Personal Data Processing
The Service collects and processes User data based on:
- 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)
- Art. 6 para. 1 lit. a - the data subject has given consent to the processing of his or her personal data for one or more specific purposes
- Art. 6 para. 1 lit. b - processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
- Art. 6 para. 1 lit. f - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
- Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018 item 1000)
- Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171 item 1800)
- Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No. 24 item 83)
§12 Personal Data Processing Period
Personal data provided voluntarily by Users:
As a rule, the indicated personal data is stored only for the period of providing the Service within the Service by the Administrator. It is deleted or anonymized within 30 days from the moment of termination of service provision (e.g. deletion of a registered user account, unsubscription from the Newsletter list, etc.)
The exception is a situation that requires securing legally justified purposes for further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the request for their deletion by the User, for no longer than 3 years in case of violation or suspicion of violation of the service regulations by the User.
Anonymous data (without personal data) collected automatically:
Anonymous statistical data, not constituting personal data, is stored by the Administrator for the purpose of conducting service statistics for an indefinite period.
§13 User Rights Related to Personal Data Processing
The Service collects and processes User data based on:
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Right of access to personal data
Users have the right to obtain access to their personal data, implemented upon request submitted to the Administrator
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Right to rectify personal data
Users have the right to request that the Administrator immediately rectify personal data that is incorrect and/or supplement incomplete personal data, implemented upon request submitted to the Administrator
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Right to delete personal data
Users have the right to request that the Administrator immediately delete personal data, implemented upon request submitted to the Administrator. In the case of user accounts, data deletion involves anonymization of data enabling User identification. The Administrator reserves the right to suspend the implementation of the data deletion request in order to protect the Administrator's legally justified interest (e.g. when the User violated the Terms or data was obtained as a result of conducted correspondence).
In the case of the Newsletter service, the User has the ability to independently delete their personal data using the link placed in each sent email message.
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Right to restrict personal data processing
Users have the right to restrict personal data processing in cases indicated in Art. 18 GDPR, including questioning the correctness of personal data, implemented upon request submitted to the Administrator
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Right to personal data portability
Users have the right to obtain from the Administrator, personal data concerning the User in a structured, commonly used, machine-readable format, implemented upon request submitted to the Administrator
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Right to object to personal data processing
Users have the right to object to the processing of their personal data in cases specified in Art. 21 GDPR, implemented upon request submitted to the Administrator
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Right to lodge a complaint
Users have the right to lodge a complaint with a supervisory authority dealing with the protection of personal data.
§14 Contact with the Administrator
You can contact the Administrator in one of the following ways:
§15 Service Requirements
Restricting the recording and access to Cookie files on the User's Device may cause improper functioning of some Service functions.
The Administrator bears no responsibility for improperly functioning Service functions in case the User restricts in any way the possibility of saving and reading Cookie files.
§16 External Links
The Service - articles, posts, entries or User comments may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files they point to may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for content found outside the Service.
§17 Changes to the Privacy Policy
- The Administrator reserves the right to freely change this Privacy Policy without the need to inform Users about it in terms of the use and utilization of anonymous data or the use of Cookie files.
- The Administrator reserves the right to freely change this Privacy Policy in terms of Personal Data processing, about which it will inform Users having user accounts or subscribed to the newsletter service, via email within 7 days from the change of provisions. Continued use of services means familiarization with and acceptance of the introduced changes to the Privacy Policy. In case the User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
- Changes introduced to the Privacy Policy will be published on this subpage of the Service.
- The introduced changes come into effect from the moment of their publication.