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PRIVACY POLICY

§ 1

General Information

1. The operator of the website operating at www.toppartner.co and the controller of thepersonal data is: TOP PARTNER GLOBAL sp. z o.o. with its registered office in Warsaw atAleja Jana Pawła II 27, KRS: 0000927819, Tax Identification Number [NIP]: 527-297-48-07, REGON: 520240820, e-mail: toppartner.kontakt@gmail.com (hereinafter: the Operator).
2. Personal data shall be used in particular for the purposes of online chat, handling enquiriesvia a form, carrying out the requested services, presenting offers and other marketingmaterial, and informing about relevant changes.
3. The website performs functions to obtain information about users and their behaviour, in particular by means of voluntary data entered in forms, which are entered into the operator's systems, and by storing cookies (so-called "cookies") on terminal equipment.

§ 2

Personal data processing

1. The processing of personal data is carried out on the basis of the provisions of Regulation(EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on theprotection of natural persons with regard to the processing of personal data and on the freemovement of such data and repealing Directive 95/46/EC (General Data ProtectionRegulation) of 27 April 2016. (OJ.EU.L No.119), (hereinafter: GDPR), taking into account theprovisions of the Act on the Provision of Electronic Services and other generally applicablelaws.
2. The Controller of the personal data is the Operator.
3. The provision of personal data is voluntary; however, the refusal to provide data may resultin the impossibility to conclude a contract, provide services and otherwise cooperate.
4. Purpose period of personal data processing:
  1. marketing - until you withdraw your consent,
  2. the performance of the contract and the provision of services - for the duration of theprovision of the services or the performance of the contract,
  3. correspondence - for the duration of the correspondence and until the expiry of thelimitation period for any related claims,
  4. the establishment, investigation and defence of claims - until the expiry of thelimitation period,
  5. making settlements - until the expiry of the limitation period,
  6. the handling of requests, complaints, enquiries - for the duration of the handling anduntil the expiry of the limitation period for any related claims,
  7. to ensure network and information security,
  8. Release of data at the request of authorised entities - until the expiry of the limitationperiod for claims or the possibility of administrative penalties.
The legal basis for the processing of personal data is Article 6(1)(a), (b), (c), and (f) of GDPR.
6. Where the Operator processes personal data on the basis of consent, such consent may bewithdrawn at any time. It may result in the loss of access to a service performed on the basisof previously granted consent. The withdrawal of consent does not affect the lawfulness of theprocessing carried out by prior to its withdrawal.
7. The User has the following rights in relation to data processing:
  1. the right to access and obtain copies of their data,
  2. the right to rectify data,
  3. the right to delete data;
  4. the right to limit the processing of data;
  5. the right to object to the processing of data,
  6. the right to transfer of data,
  7. the right to lodge a complaint with the supervisory authority,
  8. the right to withdraw consent to data processing regulations.
8. The exercise of the rights referred to in paragraph 7 shall be carried out by contacting theController. When contacting at a distance, the Controller may request personal data to verifyidentity (Article 12(6) of GDPR).
9. Personal data may be transferred to entities acting on behalf of the Controller orperforming services for the Controller, in particular:
  1. providing legal services and advice on data protection,
  2. providing accounting services,
  3. providing tax services,
  4. providing a mailing service,
  5. providing marketing and analytical services,
  6. entities providing other services necessary for the Operator to provide electronicservices, authorised bodies and authorities.
10. As a general rule, personal data shall not be transferred to third countries or aninternational organisation outside the European Economic Area (hereinafter: EEA), unlessthis is necessary due to the fact that the Controller uses analytics or advertising servicesprovided by global providers, including in particular Google Ireland Limited, for the GoogleAds and Google Analytics services, and Meta Platforms Ireland Limited for the Facebook andInstagram services.In this case, the data shall be transferred on the basis of the standardcontractual data protection clauses adopted by the European Commission, which areavailable on the website of the legal acts of the European Union: Decision 2021/914 of 04June 2021
11. Service users may be subject to automated decision-making, including profiling for thepurposes of providing services and direct marketing. Profiling consists of automaticallyreading your interests and is only intended to better tailor the services provided to you. Theprofiling has an impact on the advertisements presented, but has no legal effect, nor is itbased on sensitive data.
12. The User has the right to lodge a complaint with the President of the Personal DataProtection Office ,ul. Stawki 2, 00-193 Warszawa.

§ 3

Operator's data protection methods

1. The operator uses various data protection mechanisms, including in particular:
  1. the login and entry points are protected at the transmission layer (SSL certificate),
  2. personal and login data entered on the website are encrypted on the user's computer and can only be read on the target server.
  3. personal data stored in the database are encrypted in such a way that only the Operator having the key can read them. This ensures that the data is protected in casethe database is stolen from the server,
  4. backups are made,
  5. the operator periodically changes its administrative passwords,
  6. in order to minimise the risk of unauthorised access to data, the Operator shall usecomplex passwords containing upper and lower case letters, digits and specialcharacters, not shorter than 8 characters.

§ 4

Hosting

1. The website is hosted on the servers of the operator: domeny.pl. Registration details of the hosting company: cyber_Folks S.A. with its registered office in Poznań, Franklin Roosevelt 22, 60-829 Poznań, entered in the National Court Register by the District Court Poznań - Nowe Miasto and Wilda in Poznań, 8th Commercial Division of the National Court Register under KRS No. 0000612359, REGON 364261632, NIP 7822622168, share capital PLN 225,541 fully paid up.
2. By visiting https://domeny.pl you can find out more about hosting and check the hosting company's privacy policy.

§ 5

Information in the forms

1. The website collects information voluntarily provided by the user, including personal datawhere provided.
2. The service records information about the connection parameters (time stamp, IPaddress).
3. The website, in some cases, may record information to help link the data in the form withthe e-mail address of the user completing the form. In this case.
4. The user's e-mail address appears inside the URL of the page containing the form.The data provided in the form shall be processed for the purpose resulting from the function of the specific form, e.g. to process a service request or sales contact, registration of services, etc. Each time, the context and description of the form clearly informs you what it is used for.

§ 6

Logi systemowe

1. The operator automatically creates security logs (system logs) and usage statistics whichcontain information about certain user behaviour. The data shall be used to administer thewebsite and to ensure that the hosting services provided are as efficient as possible.
2. The following are saved:
  1. resources specified by a URL identifier,
  2. the arrival time of the request from the user and the response to the user,
  3. the customer's device identifier,
  4. information about errors that occurred during the execution of the HTTP transaction,
  5. the URL of a page previously visited by the User (referer link), in the event that thewebsite was accessed via a link on another website,
  6. information about the User’s browser,
  7. information on the public IP network address,
  8. diagnostic information related to the process of self-ordering services via registrars onthe site in order to assess the correct positioning of site elements.
3. The above data shall be used solely for the purpose of administering the server and shallnot be associated with specific visitors to the website.

§ 7

Cookies

1. The website uses cookies (so-called "cookies").
2. Cookies are computer data, in particular text files, which are stored in the end device of thewebsite User and are intended for use on the Service website. Cookies usually contain thename of the website from which they come, the duration of their storage on the terminal anda unique number.
3. The entity that places cookies on the end device of the User and accesses them is the Operator.
4. The website uses two main types of cookies: session cookies and persistent cookies. “Session“ cookies are temporary files that are stored on the User's terminal equipment until they log off, leave the website or turn off the software (web browser). “Persistent" cookies are stored in the User's end device for the time specified in the parameters of the cookies or until they are deleted by the User
5. The operator uses cookies in particular for:
  1. the collection of static data via analytical tools, e.g. Google Analytics,
  2. the collection of information on user behaviour on the website, e.g. Google Analytics,
  3. presenting advertising tailored to users' preferences using an online advertising tool,
  4. the correct configuration of selected service functions
  5. to adapt the content of the website to your preferences and facilitate your use of thewebsite,
  6. maintaining a session after logging into the service,
  7. remember your chosen settings and personalise the interface,
  8. recognise users' devices and locate them and display a website tailored to their needs.
6. The web browser usually allows cookies to be stored on the user's terminal device by default, however, users of the website can change their settings in this respect. Your web browser allows you to delete cookies. It is also possible to block cookies automatically. For details, please refer to the help or documentation of your web browser.
7. The user should remember that limitation of the use of cookies may affect some of thefunctionalities available on the websites of the Service.
8. Cookies placed with the user's consent on his/her end device may also be used by entities cooperating with the Operator, in particular Google Ireland Limited, for Google Ads and Google Analytics services, and Meta Platforms Ireland Limited for Facebook and Instagram services.
9. The operator uses Google Analytics to analyse website traffic.
10. The Operator uses remarketing, which is an action by which advertising networks candisplay advertising messages to the user adapted to his/her behaviour on the website. Atechnical prerequisite for this is that cookies are enabled.
11. If you do not wish to receive cookies, you can change your browser settings or disable cookies by clicking on the "Cookie Settings" link in the footer of the website. It should be stipulated here that disabling cookies necessary for authentication processes, security, maintenance of user preferences may hinder, and in extreme cases may make it impossible to use the Operator's websites.
12. To manage your browser's cookie settings, please select your browser from the list below and follow the instructions:
  1. Microsoft Edge
  2. Microsoft Internet Explorer
  3. Google Chrome
  4. Mozilla Firefox
  5. Safari (macOS)
  6. Opera
  7. Brave
  8. Google Chrome (Android)
  9. Google Chrome (iOS iPhone)
  10. Mozilla Firefox Mobile (Android)
  11. Apple Safari (iOS iPhone)
  12. Samsung Internet (Mobile)
  13. Brave Mobile (Android)
  14. Windows Phone 7

§ 8

Changes of privacy policy

1. The operator reserves the right to make changes to the privacy policy, in particular if required by law or changes to the website, as well as to improve the operation of the website itself.
2. The current version of the privacy policy is effective as of 01.12.2022.