Information about the Administrator and its processing of personal data

1. 1. The administrator of your personal data is Tophoe Polska Sp. z o.o., based in Wrocław, at ul. Strzegomska 55D.

1. 1. The Administrator operates a website at www.tophoe.pl hereinafter referred to as the Service.

1. 1. Personal data under this Privacy Policy is all information about an individual identified or identifiable through one or more specific factors, including device IP, location data, Internet ID, and information collected through cookies and other similar technology.

1. 1. Provision of personal data for the performance of the contract for the provision of services specified on the Website is voluntary, but it is also a condition for the conclusion of the contract. The consequence of not providing personal data will be the inability to conclude a contract and provide services.

1. 1. By the acronym RODO is meant Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC.

1. 1. A User, as defined in this Privacy Policy, is any individual who visits the Service.

1. 1. Those who register with the Service are asked to provide the data necessary to create and operate an account. In order to facilitate the service, the User may provide additional data, thereby consenting to its processing. Such data can be deleted at any time.

1. 1. The Administrator shall exercise due diligence in selecting and applying appropriate technical and organizational measures to ensure the protection of the processed personal data. Only persons duly authorized by the Administrator have full access to the databases.

1. 1. The Administrator shall protect personal data from being made available to unauthorized persons, as well as from being processed in violation of applicable laws.

1. 1. Personal data will not be processed by automated means.

1. 1. Visitors can browse the Service without registering or providing personal information.

Purposes and grounds for processing of personal data by the Administrator

1. 1. Personal data will be processed for:

1. 1. Performance of the contract for the provision of services specified on the Site (based on Article 6(1)(b) of the RODO);

1. 1. Fulfillment of a legal obligation incumbent on the Administrator (based on Article 6(1)(c) of the DPA);

1. 1. Analytical and statistical, consisting of conducting analyses of Users' activities, as well as their preferences in order to improve the functionalities used and services provided (based on Article 6(1)(b) of the DPA);

1. 1. Marketing of its own products or services, including personalized ones (based on Article 6(1)(f) of the DPA);

1. 1. To assert or secure claims (based on Article 6(1)(f) of the RODO);

1. 1. The User's activity on the Website, including his/her personal data, may be recorded in system logs. Information collected in logs processed in connection with the provision of services. The Administrator also processes them for technical purposes - in particular, data may be temporarily stored and processed to ensure the security and proper functioning of IT systems, e.g. in connection with making security copies, testing changes to IT systems, detecting irregularities or protecting against abuse and attacks.

Processing time for personal data

1. 1. As a general rule, data are processed for the duration of providing the service or fulfilling the order, until the withdrawal of the consent given, or until an effective objection is made to data processing in cases where the legal basis for data processing is the legitimate interest of the Administrator.

1. 1. The period of data processing may be extended if the processing is necessary for the establishment, investigation or defense of possible claims, and thereafter only if and to the extent required by law. At the end of the processing period, the data are irreversibly deleted or anonymized.

Recipients of data

1. 1. In connection with the implementation of services, personal data will be disclosed to external entities, including, in particular, suppliers responsible for the operation of IT systems, entities such as banks and payment operators, entities providing accounting, legal, auditing, consulting, courier services.

1. 1. If the User's consent is obtained, his data may also be made available to other entities for their own purposes, including marketing purposes.

1. 1. Personal data will not be transferred to a third country/international organization.

Cookies Policy

1. 1. The website does not automatically collect any information, except for the information contained in cookies.

1. 1. Cookies (so-called "cookies") are IT data, in particular text files, which are stored in the Service User's terminal equipment and are intended for use on the Service's websites. Cookies usually contain the name of the website from which they originate, the time they are stored on the end device and a unique number.

1. 1. The entity placing on the Service User's terminal device cookies and accessing them is the operator of the Service Tophoe Polska Sp. z o.o., based in Wrocław, at ul. Strzegomska 55D.

1. 1. Cookies are used for:

1. 1. adjustment of the content of the Website's pages to the User's preferences and optimization of the use of websites; in particular, these files allow for recognition of the Website User's device and appropriate display of the website, adjusted to his/her individual needs;

1. 1. creation of statistics, which help to understand how the Users of the Website use the websites, which allows to improve their structure and content

1. 1. maintaining a session of the Service User (after logging in), thanks to which the User does not have to re-enter his/her login and password on each sub-page of the Service;

1. 1. The Service uses two main types of cookies:

"session" (session cookies) and

"permanent" (persistent cookies).

"Session" cookies are temporary files that are stored on the User's terminal device until the User logs out, leaves the website or shuts down the software (web browser).

"Permanent" cookies are stored on the User's terminal device for the time specified in the parameters of the cookies or until they are deleted by the User.

1. 1. The following types of cookies are used within the Service:

1. 1. "necessary" cookies to enable the use of services available on the Website, such as authentication cookies used for services that require authentication on the Website;

1. 1. cookies used for security purposes, e.g. used to detect abuse of authentication on the Website;

1. 1. "performance" cookies, which allow you to collect information about how you use the Website's websites;

1. 1. "functional" cookies, which allow "remembering" the User's selected settings and personalizing the User's interface, e.g. with regard to the User's chosen language or region of origin, font size, website design, etc;

1. 1. "advertising" cookies, allowing to provide Users with advertising content more tailored to their interests.

1. 1. In many cases, web browsing software (web browser) allows cookies to be stored on the user's terminal device by default. Users of the Website may change their cookie settings at any time. These settings can be changed, in particular, in such a way as to block the automatic handling of cookies in the settings of your web browser or inform on their each time they are placed on the device of a Service User. Detailed information about the possibility and methods of handling cookies is available in the settings of your software (web browser).

1. 1. The Operator of the Website informs that restrictions on the use of cookies may affect some of the functionalities available on the Website.

1. 1. Cookies placed in the Service User's terminal equipment and used may also be used by advertisers and partners cooperating with the Service Operator.

1. 1. More information about cookies is available at http://wszystkoociasteczkach.pl/ or in the "Help" section of your web browser menu.

DELETION AND MANAGEMENT OF COOKIES

1. 1. Most browsers allow users to control cookies in their preference settings. Users should read the privacy policies of these browsers to understand their cookie policies. Restricting the setting of cookies may impair the overall functionality of your use of www.tophoe.pl.

To manage your cookie settings as well as delete them, select the web browser you are using from the list below and follow the instructions on each device from which you have visited the site in the tophoe.co.uk domain:

Internet Explorer Chrome Safari Firefox Edge Opera

Mobile devices:

Android Safari Windows Phone



User Privileges

1. 1. You have the right to access the content of your data, obtain a copy of your data, the right to rectification, erasure, restriction of processing, the right to data portability, the right to object to the processing of your data on the basis of the legitimate interest of the Administrator or to the processing for direct marketing purposes, the right to withdraw your consent at any time without affecting the lawfulness of the processing (if processing is carried out on the basis of consent) that was carried out on the basis of consent before its withdrawal.

1. 1. The right to rectify data is exercised with respect to a User with an account on the Website also by allowing him to edit the data.

1. 1. A user with an account on the Service has the right to delete it.

1. 1. In order to delete your account, you must send a message titled "Account Cancellation" to: kontakt@tophoe.pl The message must be sent from the email address that is assigned to your account on tophoe.co.uk. Cancellation of the account is not the same as deletion of personal data.

1. 1. If the processing of personal data is deemed to violate the provisions of the RODO or other data protection laws, the data subject may file a complaint with the President of the Office for Personal Data Protection.

1. 1. A request for the exercise of the rights of data subjects, can be submitted in writing or by email to the contact details of the Controller indicated below or directly to the Data Protection Officer.

1. 1. The request should, as far as possible, indicate precisely what the request is about. In particular, what entitlement the requester wants to exercise and what processing the request concerns.

1. 1. If the Administrator is unable to determine the content of the request or identify the requester based on the notification made, it will ask the requester for additional information.

1. 1. Applications will be responded to within a month of receipt. If it is necessary to extend this period, the Administrator will inform the applicant of the reasons for such extension.

1. 1. The response will be provided to the e-mail address from which the application was sent, and in the case of applications sent by letter, by regular mail to the address indicated by the applicant, unless the content of the letter indicates a desire to receive feedback to the e-mail address (if such an e-mail address is provided).

Contact details of the Administrator

Contact with the Administrator is possible through the e-mail address kontakt@tophoe.pl. Or the mailing address of Tophoe Polska Sp. z o.o. 53-611 Wrocław, ul. Strzegomska 55D.





Rules for changing the privacy policy

The policy is reviewed on an ongoing basis and updated as necessary.