PRIVACY POLICY
- General Provisions
This Privacy Policy (the “Policy”) sets out the principles governing the processing of personal data and other information in connection with the use of websites and individual web pages operated by Linemedia sp. z o.o. (“Linemedia”, the “Controller”, “we”, “us” or “our”).
This Policy applies to information processed when a user visits a relevant website or landing page, interacts with its elements, or uses links made available through it (collectively, the “Website”).
Certain pages of the Website are intended to provide users with information and the ability to access, via hyperlinks, external resources, including channels, groups, communities and other resources available through Telegram, WhatsApp or other third-party platforms.
This Policy applies to the extent that Linemedia acts as the controller of the relevant personal data under applicable data protection law.
With respect to users located in the European Union and the European Economic Area, personal data is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “General Data Protection Regulation” or “GDPR”), as well as other applicable EU and Member State data protection laws.
With respect to users in other jurisdictions, including countries in Africa, the mandatory provisions of the applicable data protection and privacy laws of the relevant jurisdiction shall apply to the extent that such laws govern the relevant processing activities.
This Policy applies to information processed when a user visits a relevant website or landing page, interacts with its elements, or uses links made available through it (collectively, the “Website”).
Certain pages of the Website are intended to provide users with information and the ability to access, via hyperlinks, external resources, including channels, groups, communities and other resources available through Telegram, WhatsApp or other third-party platforms.
This Policy applies to the extent that Linemedia acts as the controller of the relevant personal data under applicable data protection law.
With respect to users located in the European Union and the European Economic Area, personal data is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the “General Data Protection Regulation” or “GDPR”), as well as other applicable EU and Member State data protection laws.
With respect to users in other jurisdictions, including countries in Africa, the mandatory provisions of the applicable data protection and privacy laws of the relevant jurisdiction shall apply to the extent that such laws govern the relevant processing activities.
The controller responsible for the processing of personal data within the scope of the Website is:
Linemedia sp. z o.o.
ul. Józefa Ignacego Kraszewskiego 6
33-300 Nowy Sącz
Poland
KRS: 0000476294
NIP: 7343521044
REGON: 122904767
Contact for data protection matters:
iod@linemedia.com
Linemedia sp. z o.o.
ul. Józefa Ignacego Kraszewskiego 6
33-300 Nowy Sącz
Poland
KRS: 0000476294
NIP: 7343521044
REGON: 122904767
Contact for data protection matters:
iod@linemedia.com
When the Website is used, the Controller may process information automatically transmitted by the user's device, generated by the technical infrastructure of the Website, or obtained through analytics and advertising technologies used in connection with the Website.
Depending on the configuration of the particular Website, such information may include:
The actual scope of the information processed depends on the functionality of the particular Website and the technical, analytics and advertising solutions implemented on it.
Depending on the configuration of the particular Website, such information may include:
- IP address and other network identifiers;
- device type, model and technical characteristics;
- browser type and version;
- operating system;
- language, time zone and other technical settings;
- date, time and duration of the visit;
- information concerning requested and viewed pages;
- the URL of the page from which the user accessed the Website;
- information concerning the source of advertising or other traffic;
- information concerning the user's interactions with elements of the Website, including clicks on links made available through the Website;
- cookies, pixels and similar identifiers;
- information used for web analytics, statistics, attribution and conversion measurement;
- other technical information automatically generated in connection with the use of web resources.
The actual scope of the information processed depends on the functionality of the particular Website and the technical, analytics and advertising solutions implemented on it.
2. Data Controller
3. Categories of Data Processed
4. Purposes of Processing
The Controller may process the relevant data for the following purposes:
- ensuring the operation, availability and technical maintenance of the Website;
- maintaining information and technical security;
- detecting and preventing misuse of the Website, automated activity, fraud and other abusive conduct;
- diagnosing errors and optimizing technical infrastructure;
- obtaining statistical information regarding the use of the Website;
- analyzing Website audiences, traffic and user interactions;
- identifying traffic sources and characteristics;
- analyzing users' interactions with links made available through the Website;
- measuring conversions;
- evaluating and optimizing the effectiveness of advertising and marketing campaigns;
- improving the content, structure and functionality of the Website;
- complying with applicable legal obligations;
- establishing, exercising and defending the Controller's legal rights and legitimate interests.
5. Legal Bases for Processing
6. Cookies, Analytics and Advertising Technologies
7. Recipients of Data and Service Providers
8. Links to Telegram, WhatsApp and Other External Resources
9. International Data Transfers
10. Data Retention
11. Rights of Data Subjects
12. Data Security
13. Users Outside the EEA
14. Changes to this Policy
15. Contact Information
Where the GDPR applies to the relevant processing, the Controller processes personal data on the basis of one or more of the legal grounds provided for in Article 6 GDPR.
Depending on the nature and purpose of the processing, such legal grounds may include:
Consent of the data subject — Article 6(1)(a) GDPR — in particular where consent is required for the use of certain analytics, advertising or other non-essential technologies;
Compliance with a legal obligation — Article 6(1)(c) GDPR — where processing is necessary for compliance with a legal obligation to which the Controller is subject;
Legitimate interests of the Controller or a third party — Article 6(1)(f) GDPR — including, where applicable, maintaining the security and stability of the Website, preventing misuse, obtaining necessary statistical information, protecting the Controller's legal rights and legitimate interests, and improving the operation of the Website, provided that such interests are not overridden by the fundamental rights and freedoms of the data subject.
Where applicable law requires prior consent for storing information on a user's device or accessing information already stored on such device, the relevant technologies are used on the basis of such consent, unless consent is not required under applicable law.
Depending on the nature and purpose of the processing, such legal grounds may include:
Consent of the data subject — Article 6(1)(a) GDPR — in particular where consent is required for the use of certain analytics, advertising or other non-essential technologies;
Compliance with a legal obligation — Article 6(1)(c) GDPR — where processing is necessary for compliance with a legal obligation to which the Controller is subject;
Legitimate interests of the Controller or a third party — Article 6(1)(f) GDPR — including, where applicable, maintaining the security and stability of the Website, preventing misuse, obtaining necessary statistical information, protecting the Controller's legal rights and legitimate interests, and improving the operation of the Website, provided that such interests are not overridden by the fundamental rights and freedoms of the data subject.
Where applicable law requires prior consent for storing information on a user's device or accessing information already stored on such device, the relevant technologies are used on the basis of such consent, unless consent is not required under applicable law.
The Website may use cookies, pixels, local storage, software identifiers and other similar technologies that are necessary for the operation of the Website or used for analytics, statistical and advertising purposes.
Depending on their purpose, such technologies may be used to ensure the technical operation of the Website, retain settings, maintain security, measure traffic, analyze user interactions, identify traffic sources, record outbound interactions, measure conversions and assess the effectiveness of advertising campaigns.
For these purposes, the Controller may engage third-party providers of analytics, advertising and technological solutions. In connection with the use of such solutions, the relevant providers may receive certain technical information concerning a user's device and interaction with the Website.
Where the use of a particular technology is permitted under applicable law only with the user's consent, such technology will be used after the appropriate consent has been obtained.
Users may have the right to reject non-essential technologies or subsequently withdraw consent through the cookie preference management mechanism made available on the Website, where applicable.
Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
Depending on their purpose, such technologies may be used to ensure the technical operation of the Website, retain settings, maintain security, measure traffic, analyze user interactions, identify traffic sources, record outbound interactions, measure conversions and assess the effectiveness of advertising campaigns.
For these purposes, the Controller may engage third-party providers of analytics, advertising and technological solutions. In connection with the use of such solutions, the relevant providers may receive certain technical information concerning a user's device and interaction with the Website.
Where the use of a particular technology is permitted under applicable law only with the user's consent, such technology will be used after the appropriate consent has been obtained.
Users may have the right to reject non-essential technologies or subsequently withdraw consent through the cookie preference management mechanism made available on the Website, where applicable.
Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.
To the extent necessary for the purposes specified in this Policy, access to data may be provided to persons and entities providing services to the Controller or supplying the relevant technological infrastructure.
Such recipients may include providers of:
The scope of data made available to such recipients is limited to information necessary for the performance of the relevant functions, taking into account the nature of the contractual relationship and the requirements of applicable law.
The Controller may also disclose information to competent public authorities, courts or other authorized persons where such disclosure is required by applicable law, necessary to comply with a binding lawful request, or required for the establishment, exercise or defense of legal claims.
The Controller does not engage in the sale of users' personal data as an independent commercial activity.
Such recipients may include providers of:
- hosting and cloud infrastructure services;
- information technology and technical services;
- web analytics systems;
- advertising and marketing technologies;
- conversion measurement and attribution tools;
- information security and fraud prevention solutions;
- legal, audit and other professional services.
The scope of data made available to such recipients is limited to information necessary for the performance of the relevant functions, taking into account the nature of the contractual relationship and the requirements of applicable law.
The Controller may also disclose information to competent public authorities, courts or other authorized persons where such disclosure is required by applicable law, necessary to comply with a binding lawful request, or required for the establishment, exercise or defense of legal claims.
The Controller does not engage in the sale of users' personal data as an independent commercial activity.
The Website may contain hyperlinks to websites, applications, channels, groups, communities and other resources provided by third parties, including Telegram and WhatsApp.
By following such a hyperlink, the user leaves the Website and accesses the relevant external resource.
The processing of personal data carried out by the operator of an external resource for its own purposes and by means independently determined by such operator is governed by the terms of use, privacy policy and applicable laws relating to the relevant service.
Linemedia does not determine the purposes and means of independent personal data processing carried out by operators of such external services, except where otherwise arising from the factual circumstances of the relevant processing, the contractual relationship between the parties, or applicable legal requirements.
This Policy does not govern independent personal data processing activities carried out by third parties.
The inclusion of a hyperlink to an external resource does not mean that the Controller assumes the obligations of the relevant third party in relation to the processing of personal data.
By following such a hyperlink, the user leaves the Website and accesses the relevant external resource.
The processing of personal data carried out by the operator of an external resource for its own purposes and by means independently determined by such operator is governed by the terms of use, privacy policy and applicable laws relating to the relevant service.
Linemedia does not determine the purposes and means of independent personal data processing carried out by operators of such external services, except where otherwise arising from the factual circumstances of the relevant processing, the contractual relationship between the parties, or applicable legal requirements.
This Policy does not govern independent personal data processing activities carried out by third parties.
The inclusion of a hyperlink to an external resource does not mean that the Controller assumes the obligations of the relevant third party in relation to the processing of personal data.
Due to the use of international technical infrastructure and analytics, advertising, cloud and other services, personal data may be processed outside the country in which the user is located.
Where the GDPR applies to a transfer of personal data to a country outside the European Economic Area, the Controller ensures that an appropriate legal basis or safeguard for such transfer is available as required by applicable law.
Depending on the circumstances, such mechanism may include an adequacy decision adopted by the European Commission, Standard Contractual Clauses approved by the European Commission, or another transfer mechanism permitted under Chapter V of the GDPR.
Where an international transfer is subject to mandatory requirements of another applicable jurisdiction, the Controller will take such requirements into account to the extent applicable.
Where the GDPR applies to a transfer of personal data to a country outside the European Economic Area, the Controller ensures that an appropriate legal basis or safeguard for such transfer is available as required by applicable law.
Depending on the circumstances, such mechanism may include an adequacy decision adopted by the European Commission, Standard Contractual Clauses approved by the European Commission, or another transfer mechanism permitted under Chapter V of the GDPR.
Where an international transfer is subject to mandatory requirements of another applicable jurisdiction, the Controller will take such requirements into account to the extent applicable.
Personal data is processed and retained for no longer than is necessary to achieve the relevant purpose of processing, unless a longer retention period is required or permitted under applicable law.
When determining the applicable retention period, the Controller may take into account the nature and scope of the data, the purposes of processing, the technical characteristics of the systems used, applicable limitation periods, legal and regulatory obligations, as well as the need to maintain security and protect legitimate interests.
The retention period applicable to cookies and similar identifiers depends on the purpose of the relevant technology, its technical configuration and applicable legal requirements.
Once the relevant data is no longer required for the applicable purpose, it will be deleted, anonymized or otherwise processed in accordance with applicable law.
When determining the applicable retention period, the Controller may take into account the nature and scope of the data, the purposes of processing, the technical characteristics of the systems used, applicable limitation periods, legal and regulatory obligations, as well as the need to maintain security and protect legitimate interests.
The retention period applicable to cookies and similar identifiers depends on the purpose of the relevant technology, its technical configuration and applicable legal requirements.
Once the relevant data is no longer required for the applicable purpose, it will be deleted, anonymized or otherwise processed in accordance with applicable law.
In the circumstances and to the extent provided for under applicable law, a data subject may have the right to request that the Controller:
Where processing is based on legitimate interests pursuant to Article 6(1)(f) GDPR, the data subject has the right to object to such processing in the circumstances provided for in Article 21 GDPR.
Where processing is based on consent, the data subject may withdraw such consent at any time without affecting the lawfulness of processing carried out before its withdrawal.
The data subject also has the right to lodge a complaint with a competent data protection supervisory authority in accordance with applicable law.
Requests concerning the exercise of data protection rights or the processing of personal data may be submitted to:
iod@linemedia.com
Where permitted by law, the Controller may request information reasonably necessary to verify the identity of the person making the request and to prevent unauthorized disclosure of personal data to third parties.
- confirm whether personal data concerning the data subject is being processed and provide access to such data;
- rectify inaccurate or complete incomplete personal data;
- erase personal data;
- restrict the processing of personal data;
- provide personal data in a portable format, where the right to data portability applies;
- cease processing where the data subject has the right to object to such processing;
- give effect to the withdrawal of previously provided consent.
Where processing is based on legitimate interests pursuant to Article 6(1)(f) GDPR, the data subject has the right to object to such processing in the circumstances provided for in Article 21 GDPR.
Where processing is based on consent, the data subject may withdraw such consent at any time without affecting the lawfulness of processing carried out before its withdrawal.
The data subject also has the right to lodge a complaint with a competent data protection supervisory authority in accordance with applicable law.
Requests concerning the exercise of data protection rights or the processing of personal data may be submitted to:
iod@linemedia.com
Where permitted by law, the Controller may request information reasonably necessary to verify the identity of the person making the request and to prevent unauthorized disclosure of personal data to third parties.
The Controller implements appropriate technical and organizational measures designed to ensure a level of security appropriate to the nature and risks of the relevant processing.
Such measures are intended, in particular, to prevent unauthorized or unlawful access to personal data and its unauthorized alteration, disclosure, destruction, loss or other unlawful use.
Security measures may be reviewed and updated taking into account technological developments, the nature of processing and changes in the relevant risks.
Such measures are intended, in particular, to prevent unauthorized or unlawful access to personal data and its unauthorized alteration, disclosure, destruction, loss or other unlawful use.
Security measures may be reviewed and updated taking into account technological developments, the nature of processing and changes in the relevant risks.
Where the processing of a user's personal data is subject to the laws of a jurisdiction outside the European Economic Area, including the laws of an applicable African jurisdiction, the provisions of this Policy apply subject to the mandatory requirements of such legislation.
Where applicable local law grants data subjects additional rights or imposes additional obligations on the Controller, this Policy shall not be interpreted as limiting such rights or excluding such obligations.
Depending on the applicable jurisdiction, data subjects may have rights relating to access, rectification or deletion of personal data, restriction of or objection to processing, withdrawal of consent, complaints to a competent supervisory authority, and other rights established by the laws of the relevant jurisdiction.
Where applicable local law grants data subjects additional rights or imposes additional obligations on the Controller, this Policy shall not be interpreted as limiting such rights or excluding such obligations.
Depending on the applicable jurisdiction, data subjects may have rights relating to access, rectification or deletion of personal data, restriction of or objection to processing, withdrawal of consent, complaints to a competent supervisory authority, and other rights established by the laws of the relevant jurisdiction.
The Controller may amend this Policy from time to time, including as a result of changes to the functionality of the Website, technologies used, data processing activities, applicable legal requirements or the Controller's operations.
The current version of the Policy will be made available on the Website.
The date of the most recent update is indicated at the beginning of this Policy.
The current version of the Policy will be made available on the Website.
The date of the most recent update is indicated at the beginning of this Policy.
For any questions concerning this Policy, the processing of personal data or the exercise of data subject rights, please contact:
Linemedia sp. z o.o.
ul. Józefa Ignacego Kraszewskiego 6
33-300 Nowy Sącz
Poland
KRS: 0000476294
NIP: 7343521044
REGON: 122904767
Data protection contact:
iod@linemedia.com
Linemedia sp. z o.o.
ul. Józefa Ignacego Kraszewskiego 6
33-300 Nowy Sącz
Poland
KRS: 0000476294
NIP: 7343521044
REGON: 122904767
Data protection contact:
iod@linemedia.com
