Privacy Policy

The following Privacy Policy sets out the rules for storing and accessing data on the Devices of Users who use the Website for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing personal data of Users, which they have provided personally and voluntarily through the tools available on the Website.

§1 Definitions

• Website - the website "AIAVIE" operating at the address https://aiaviem.eu

• External Website - websites of partners, service providers or service recipients cooperating with the Administrator

• Website / Data Administrator - The Administrator of the Website and the Data Administrator (hereinafter referred to as the Administrator) is the company "Spółdzielnia NPN", conducting business at: ul. Eugeniusza Romera 10 lok. B6, 02-784 Warsaw, Poland, with the assigned tax identification number (NIP): 5250002161, providing electronic services through the Website

• User - a natural person for whom the Administrator provides electronic services through the Website.

• Device - an electronic device together with software through which the User accesses the Website

• 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 relating to 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 processing in the future

• 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 - Data anonymisation is an irreversible process of operations on data that destroys/overwrites "personal data" making it impossible to identify or associate a given record with a specific user or natural person.

§2 Data Protection Officer

Pursuant to Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

In matters relating to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

• Internal Cookies - files placed and read from the User's Device by the Website's information system

• External Cookies - files placed and read from the User's Device by the information systems of External Websites. Scripts of External Websites that may place Cookies on Users' Devices have been deliberately placed on the Website through scripts and services made available and installed on the Website

• Session Cookies - files placed and read from the User's Device by the Website or External Websites during a single session of the given Device. After the session ends, the files are deleted from the User's Device.

• Persistent Cookies - files placed and read from the User's Device by the Website or External Websites 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 session ends.

§4 Data Storage Security

• Cookie storage and reading mechanisms - The mechanisms for storing, reading and exchanging data between Cookies saved on the User's Device and the Website are implemented through built-in web browser mechanisms and do not allow the retrieval of other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojan horses and other worms to the User's Device is also practically impossible.

• Internal Cookies - the Cookie files used by the Administrator are safe for Users' Devices and do not contain scripts, content or information that could threaten the security of personal data or the security of the Device used by the User.

• External Cookies - the Administrator takes all possible measures to verify and select Website partners in the context of User safety. The Administrator selects well-known, large partners with global public trust for cooperation. However, the Administrator 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 the licensed use by Scripts installed on the website, originating from External Websites, to the extent permitted by law. The list of partners is included in the further part of the Privacy Policy.

• Cookie management

  • The User may, at any time, independently change the settings regarding the saving, deleting and accessing data stored in Cookie files by any website

  • Information on how to disable Cookie files in the most popular computer browsers is available at: how to disable cookies or from one of the indicated providers:

    • Managing cookies in Chrome browser
    • Managing cookies in Opera browser
    • Managing cookies in FireFox browser
    • Managing cookies in Edge browser
    • Managing cookies in Safari browser
    • Managing cookies in Internet Explorer 11 browser

  • The User may at any time delete all previously saved Cookie files using the tools of the User's Device through which the User uses the Website's services.

• User-side threats - The Administrator uses all possible technical measures to ensure the security of data stored 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 their deletion as a result of the conscious or unconscious activity of the User, viruses, Trojan horses and other spyware that may or may have infected the User's Device. Users should follow internet safety guidelines to protect themselves against these threats.

• Personal data storage - The Administrator ensures that every effort is made to keep the personal data voluntarily provided by Users secure, that access to them is restricted and carried out in accordance with their purpose and processing objectives. The Administrator also ensures that every effort is made to protect the data held against loss, through the use of appropriate physical and organisational safeguards.

§5 Purposes for which Cookies are used

• Improving and facilitating access to the Website
• Personalisation of the Website for Users

§6 Purposes of personal data processing

Personal data voluntarily provided by Users are processed for one of the following purposes:

• Provision of electronic services:
  • Newsletter service (including sending advertising content with consent)
• Communication between the Administrator and Users regarding the Website and data protection
• Ensuring the legally justified interest of the Administrator

Data about Users collected anonymously and automatically are processed for one of the following purposes:

• Ensuring the legally justified interest of the Administrator

§7 External Website Cookies

The Administrator uses javascript scripts and web components of partners on the Website, which may place their own Cookie files on the User's Device. Please remember that in your browser settings you can decide which Cookie files are allowed to be used by individual websites. Below is a list of partners or their services implemented on the Website that may place Cookie files:

• Other services:
  • Google Maps

Services provided by third parties are beyond the control of the Administrator. These entities may at any time change their terms of service, privacy policies, purpose of data processing and the way they use Cookie files.

§8 Types of data collected

The Website collects data about Users. Some data is collected automatically and anonymously, and some data is personal data provided voluntarily by Users when registering for individual services offered by the Website.

Anonymous data collected automatically:

• IP address
• Browser type
• Screen resolution
• Approximate location
• Visited subpages of the website
• Time spent on a particular subpage of the website
• Operating system type
• Previous subpage address
• Referring page address
• Browser language
• Internet connection speed
• Internet service provider
• Demographic data (age, gender)

Data collected during registration:

• E-mail address
• IP address (collected automatically)

Data collected when subscribing to the Newsletter service

• First name / last name / nickname
• E-mail address
• IP address (collected automatically)

Some data (without identifying data) may be stored in Cookie files. Some data (without identifying data) may be transmitted to the statistical services 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 services provided are not transferred or sold to third parties.

Access to data (usually on the basis of a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to operate the website, i.e.:

• Hosting companies providing hosting or related services to the Administrator
• Companies through which the Newsletter service is provided
• Service and IT support companies performing maintenance or responsible for maintaining IT infrastructure

Entrusting the processing of personal data - Hosting, VPS or Dedicated Server Services

The Administrator uses the services of an external hosting, VPS or Dedicated Server provider to operate the website - Home.pl s.a.. All data collected and processed on the website is stored and processed in the service provider's infrastructure located in Poland. Access to data may occur as a result of maintenance work carried out by the service provider's personnel. Access to this data is regulated by an agreement concluded between the Administrator and the Service Provider.

Entrusting the processing of personal data - Website maintenance services

The Administrator uses the services of an external service provider for website maintenance - ClickFlow Kamil Stochel. The personnel of the indicated entity have access to data entered by users during registration and editing of the user account and/or data related to the Newsletter service. Access to this data is regulated by an agreement concluded between the Administrator and the Service Provider.

§10 Method of processing personal data

Personal data voluntarily provided by Users:

• 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. entering a comment or post), which will make the data available to anyone visiting the website.
• Personal data will not be used for automated decision-making (profiling).
• Personal data will not be sold to third parties.

Anonymous data (without personal data) collected automatically:

• Anonymous data (without personal data) will not 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 processing personal data

The Website collects and processes User data on the basis 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 (General Data Protection Regulation)
  • Art. 6(1)(a)
    the data subject has given consent to the processing of his or her 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 party or in order 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
• 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 Period of processing personal data

Personal data voluntarily provided by Users:

As a rule, the indicated personal data is stored only for the duration of the Service provision within the Website by the Administrator. They are deleted or anonymised within 30 days from the termination of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter, etc.)

An exception is a situation that requires safeguarding the legally justified purposes of further processing of such data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User's request for deletion, for no longer than 3 years in the event of a breach or suspected breach of the website's terms of service by the User

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, which does not constitute personal data, is stored by the Administrator for the purpose of maintaining website statistics for an indefinite period

§13 Users' rights related to personal data processing

The Website collects and processes User data on the basis of:

• Right of access to personal data
  Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator

• Right to rectification of personal data
  Users have the right to request the Administrator to immediately rectify personal data that is inaccurate and/or to complete incomplete personal data, exercised upon request submitted to the Administrator

• Right to erasure of personal data
  Users have the right to request the Administrator to immediately erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, data erasure consists of anonymising data that enables the identification of the User. The Administrator reserves the right to suspend the fulfilment of the request for data erasure in order to protect the legally justified interest of the Administrator (e.g. when the User has breached the Terms of Service or the data was obtained as a result of correspondence).
  In the case of the Newsletter service, the User has the option to independently delete their personal data using the link included in each e-mail message sent.

• Right to restriction of processing of personal data
  Users have the right to restrict the processing of personal data in cases indicated in Art. 18 of the GDPR, including challenging the accuracy of personal data, exercised upon request submitted to the Administrator

• Right to data portability
  Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used and machine-readable format, exercised upon request submitted to the Administrator

• Right to object to the processing of personal data
  Users have the right to object to the processing of their personal data in cases specified in Art. 21 of the GDPR, exercised upon request submitted to the Administrator

• Right to lodge a complaint
  Users have the right to lodge a complaint with a supervisory authority responsible for personal data protection.

§14 Administrator Contact Details

The Administrator can be contacted in one of the following ways

• Postal address - Spółdzielnia NPN, ul. Eugeniusza Romera 10 lok. B6, 02-784 Warsaw, Poland

• E-mail address - kontakt@npn.com.pl

• Telephone - +48225590923

• Contact form - available at: /kontakt

§15 Website Requirements

• Restricting the saving and access to Cookie files on the User's Device may result in the malfunction of some functions of the Website.

• The Administrator bears no responsibility for malfunctioning functions of the Website if the User restricts in any way the ability to save and read Cookie files.

§16 External Links

The Website - articles, posts, entries or User comments may contain links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated by them may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for content located outside the Website.

§17 Changes to the Privacy Policy

• The Administrator reserves the right to change this Privacy Policy at any time without the need to inform Users regarding the use of anonymous data or the use of Cookie files.

• The Administrator reserves the right to change this Privacy Policy at any time regarding the processing of Personal Data, of which Users with user accounts or subscribed to the Newsletter service will be informed via e-mail within 7 days of the change. Continued use of services means familiarisation with and acceptance of the introduced changes to the Privacy Policy. If the User does not agree with the introduced changes, they are obliged to delete their account from the Website or unsubscribe from the Newsletter service.

• Introduced changes to the Privacy Policy will be published on this subpage of the Website.

• Introduced changes take effect upon their publication.