Privacy Policy

PRIVACY POLICY 

§ 1 General Provisions

1. This Privacy Policy concerns the rules for collecting and processing personal data of Users using the website available at: https://camel.expert particularly information about the purposes and grounds for processing personal data, as well as the rights granted to Users.
2. The administrator of the Users’ personal data is Markkon Spółka z ograniczoną odpowiedzialnością, based in Warsaw, ul. Jarosława Dąbrowskiego 84B, unit no. 18, 02-571 Warsaw, entered in the Register of Entrepreneurs kept by the District Court for the capital city of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under KRS number: 0000644840, NIP: 7123321917, REGON: 365758501. This means that the aforementioned company Markkon determines the purposes and means of processing the User’s personal data.
3. The Administrator limits the use and collection of information about Users to the level necessary to provide Users with the highest level of service.
4. Before using the website, the User should read the provisions of this Policy.

§ 2 CONTACT WITH THE ADMINISTRATOR

For any matters related to the protection of personal data, including the exercise of the rights granted to the User under the GDPR, you can contact the Administrator in the following ways:

1. In writing to the address: ul. Jarosława Dąbrowskiego 84B, unit no. 18, 02-571 Warsaw;
2. By email at: [email protected]

§3 GLOSSARY OF TERMS

1. This Privacy Policy uses the following definitions of the terms:
   • Administrator – Markkon Spółka z ograniczoną odpowiedzialnością, based in Warsaw, ul. Jarosława Dąbrowskiego 84B, unit no. 18, 02-571 Warsaw, entered in the Register of Entrepreneurs kept by the District Court for the capital city of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under KRS number: 0000644840, NIP: 7123321917, REGON: 365758501. (hereinafter also referred to as “Company” or “We”).
   • Personal data – any information related to the user that allows for their independent personal identification, or in combination with other available information such as an email address.
   • Contact form – an electronic service that allows direct contact with the CamelExpert service run by the Administrator. The service involves filling out a form by the User, providing their personal data to enable contact and possibly sending a response to their email address regarding questions or reported issues.
   • Inquiry form – a form that a registered User fills out to allow the Company to create a customized offer for the service desired by the User, specifying at least the price and scope of the service, as well as the rights and obligations of the future contract parties.
   • Account – a set of information resources marked with an individual login and password, where data about the User and their (possible) Order placed through the CamelExpert website are collected.
   • Processing – any type of activities and operations performed on the personal data of users.
   • Telecommunications law – the Act of July 16, 2004, Telecommunications Law.
   • GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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.
   • Service – the service provided electronically by the Administrator to the User, i.e., the contact form service.
   • UŚUDE – the Act of July 18, 2002, on the provision of electronic services.
   • User – any natural person visiting the website as well as contacting the Administrator through the contact form or any other provided communicator.

§ 4 SOURCE OF USER DATA

In most cases, the User provides their data to the Administrator themselves when contacting the Administrator through an available communication channel, following the Administrator’s profiles on social networks, or interacting with the content published by the Administrator. The Administrator may also obtain the User’s personal data from other authorized persons (attorneys, proxies) if they have appropriate authorization from the User. The scope of data depends on the services and functionalities the User utilizes. The scope of data processed concerning individual services is described in § 5 of the Privacy Policy. Additionally, some information about the User may be automatically collected by analytical tools or similar tracking technologies used on the website, such as Google Analytics.

§ 5 PURPOSES, GROUNDS, AND PERIOD OF DATA PROCESSING

The purpose of processing personal data by the Administrator is to enable the User to use the services and functionalities offered on the CamelExpert website. When using the contact form, it is required to provide data that allows the User to be identified, including contact details (i.e., in particular, first and last name, email address, phone number). Providing these data is voluntary but necessary to use the contact form and contact the Administrator. Over time and as the User uses the website’s functionalities, the Administrator will collect information about the User that has been provided voluntarily.

5.1. HANDLING CORRESPONDENCE

When contacting the Administrator via the contact form, email, letter, or phone, the User provides the Administrator with their personal data necessary for contact and response to the inquiry, in particular: email address, phone number, personal data contained in the message, depending on the form of contact. The User may also provide other data to facilitate contact or handling the inquiry.

The purpose of processing personal data is to enable the User to contact the Administrator on any matter related to the Administrator’s activities and respond to the sent message or reported telephone inquiry. The legal basis for processing the User’s personal data in this case will be Article 6(1)(f) of the GDPR (i.e., the legitimate interest of the Administrator in responding to messages or telephone inquiries).

Please be informed that the scope of processed data will vary depending on the type of matter you address to us. Data will be processed for the time necessary to handle your matter and provide a response. Providing data is voluntary, but failure to provide it may make it impossible to handle your matter. As a result, your message may be left unrecognized.

5.2. MARKETING ACTIVITIES

In connection with marketing activities, the Administrator may process information based on the Administrator’s legitimate interest or the legitimate interest of entities cooperating with the Administrator (Article 6(1)(f) of the GDPR) or based on the User’s consent (Article 6(1)(a) of the GDPR) to help us tailor advertisements and content to the User’s preferences and expectations, including displaying behavioral advertising. For this purpose, data such as the IP address, data from cookies, or information about the User’s activity on the website, including viewed products and User preferences in this regard, may be processed. Marketing activities may include, in particular:

• Displaying marketing content not tailored to the User’s preferences (so-called contextual advertising) – if personal data is used to display such advertising, its processing is based on the legitimate interest of the Administrator or a third party in promoting their own products or the activities of third parties (Article 6(1)(f) of the GDPR). Data will be processed until the User stops using the website.
• Displaying marketing content tailored to the User’s preferences based on viewed offers and User activity. Information is collected via cookies or similar technologies and used by the Administrator for marketing purposes based on the User’s prior consent for such activities (Article 6(1)(a) of the GDPR). In this case, data will be processed until the User withdraws their consent.
• Contacting Users for permitted marketing activities through the communication channel provided by the User. The legal basis for processing personal data is Article 6(1)(a) of the GDPR in conjunction with Article 10 of the Act on Electronic Services or Article 172 of the Telecommunications Law. In this case, data will be processed until the User withdraws their consent.

5.3. ANALYTICAL AND STATISTICAL ACTIVITIES

The Administrator conducts analytical and statistical activities using information collected through cookies and similar technologies (such as Google Analytics, HubSpot, Facebook Pixel, and other similar technologies) during User interaction. Collected information may be used for analyzing User activity on the website to improve functionalities and service quality. Data processing for analytical and statistical purposes collected through cookies and similar technologies depends on the User’s prior consent to store such information on their terminal device. Information collected through these technologies, including cookies, may include the User’s device IP address, date and time of visit, the type of operating system of the User’s terminal device, approximate location, type of web browser, time spent on the website, visited subpages, and other activities undertaken on the Administrator’s website. Usually, information collected and stored by cookies does not allow the identification of individual Users. In some cases, where this information allows for the identification of the User, data processing is based on the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR), which involves creating, reviewing, and analyzing statistics related to User activity or based on voluntarily given consent. The User can object to the processing of this information by disabling cookies themselves.

5.4. WEBSITE ADMINISTRATION – SERVER LOGS

Using the website involves sending queries to the server. Each query to the server is recorded in so-called server logs, which include records of certain parameters of Users accessing the website. Logs contain, in particular, data such as the IP address of the device, event time, information about the web browser, and information about the operating system used by the User. Data recorded in server logs are not associated with specific Users using the website and are used as an auxiliary material for administrative purposes. Moreover, their content is not disclosed to anyone except persons authorized to administer the server. The legal basis for processing these data is the legitimate interest of the Administrator in administering the website (Article 6(1)(f) of the GDPR). Data will be processed until an effective objection is made or the processing purpose is achieved. Providing the aforementioned personal data is voluntary but necessary to ensure the proper functioning of the website.

§ 6 Our Tasks

Below we present the purposes for which we use your personal data.

6.1. Catalog of Personal Data and Processing Period

Below we present the catalog of personal data that we collect and process, along with the processing period:

Whose data do we use?

• Persons who have used the contact form or registered on the CamelExpert service.

What types of data do we use?

• Depending on your activity and use of the contact form, we may process the following data:
  • First name and last name or nickname;
  • Data published by you in the contact form content;
  • Data provided by you in correspondence content, including email address, phone number;
  • Anonymous statistical data on website visitors.

Where do personal data come from?

• We receive personal data directly from you through your interaction during registration on the Service and by filling out the contact form. We collect them when you contact us via the contact form and during registration on the service. Additionally, we may obtain anonymous statistical data of website visitors through the functionalities provided by the Service.

6.2. Is providing data necessary?

Providing personal data by website visitors is voluntary and occurs mainly through registration and using the contact form. Failure to provide data will result in the inability to use all or part of the functionalities of the CamelExpert service and inability to contact the Administrator.

6.3 Retention Period of Personal Data

We inform you that data processed based on our legitimate interest will be processed until an effective objection is made or this interest ceases. Personal data obtained through correspondence will be stored for the time necessary to handle the submitted inquiry/request. Data processed to establish, assert, or defend against claims will be processed for a period equal to the statute of limitations for such claims (typically, this is a period of 3 years). Statistical data on website visitors will be processed for the duration of the availability of these data on the service, in accordance with applicable rules.

§ 7 DATA RECIPIENTS AND REFERENCES TO OTHER WEBSITES

1. The Administrator uses the services of external entities to whom Users’ data may be transferred, particularly including:
   1. Postal operators;
   2. Email service providers;
   3. Hosting providers and server administrators;
   4. Law firms, if necessary to ensure compliance with the law or to establish, exercise, or defend against claims;
   5. Entities providing ongoing support services;
   6. Specialized suppliers of IT, marketing, and analytical tools;
   7. Mailing system providers.
2. The User’s personal data may be made available to state authorities, law enforcement agencies (police, prosecutor’s office), and courts if such entities are authorized to access the data under legal provisions.
3. The Administrator ensures that it carefully selects the entities with which it cooperates or whose services it uses, and that such entities provide a high level of protection and security for personal data.

§ 8 TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES

1. Due to the fact that the Administrator uses analytical and marketing tools from external providers within the website, personal data collected through them (in whole or in part) may be stored on servers located worldwide, including in the United States.
2. The entities processing the personal data of Users outside the European Economic Area are:
   1. Meta Platforms, Inc – the operator of the social network service (Facebook), on which the Administrator’s fan page is maintained and the provider of the Pixel Meta marketing tool. More information on the data processing rules can be found in the service provider’s privacy policy, available at:
      • Facebook Privacy Policy
      • Meta Pixel
   2. Google – the provider of analytical tools such as Google Analytics. More information on the data processing rules can be found in the service provider’s privacy policy, available at:
      • Google Privacy Policy
      • Google Analytics Privacy
   3. HubSpot – the provider of the marketing tool used for marketing automation, website personalization, and CRM data integration. More information on the data processing rules can be found in the service provider’s privacy policy, available at:
      • HubSpot Privacy Policy
   4. Edrone Sp. z o.o. – the provider of the Edrone mailing system, used for sending newsletters and for marketing purposes in email, SMS, and social media campaigns initiated or indicated by the Administrator via the Edrone system. More information on the data processing rules can be found in the service provider’s privacy policy, available at:
      • Edrone Privacy Policy
3. The basis for the transfer of User data to third countries may be a decision by the European Commission stating an adequate level of protection (e.g., in the case of the United Kingdom, Israel, Japan). For the transfer of personal data to a third country for which the European Commission has not issued a decision stating an adequate level of protection (including the USA, Chile, Qatar, India), the Administrator will apply appropriate legal safeguards, contractual clauses ensuring an adequate level of protection, in accordance with the standard contractual clauses specified in the European Commission’s Implementing Decision (EU) 2021/914 of June 4, 2021, on standard contractual clauses for the transfer of personal data to third countries under Regulation (EU) 2016/679 of the European Parliament and of the Council. The basis for the data transfer may also be your consent to the transfer given during registration on the CamelExpert service and when filling out the contact form or inquiry form.
4. The User may obtain a copy of the data transferred to a third country from the Administrator.
5. At the same time, the Administrator informs that the services offered by Google are currently provided mainly by entities located within the European Union. However, considering the international nature of data flows within these platforms and the potential risk of data transfer to a third country, the User should review the privacy policies of these providers to receive up-to-date information regarding personal data protection.

§ 9 USER RIGHTS

To exercise the above rights, the User should submit a relevant request to the Administrator using the contact details provided in § 2 of the Privacy Policy. Complaints to the President of the Personal Data Protection Office can be submitted to the address: ul. Stawki 2, 00-193 Warsaw or via email at: [email protected].

§ 10 AUTOMATED DECISION-MAKING AND PROFILING

We profile Users of our website for advertising purposes. Profiling is a form of automatic use of personal data to evaluate selected characteristics of a person based on information collected about them. We collect information about the devices and software used by users of our website. We also obtain information about viewed advertisements and visited websites. These activities will not have any legal effects on the User or similarly significantly affect the User’s situation. The only consequence for the User will be the display or transmission of notifications, messages, or other informational or marketing activities conducted by an automated mechanism tailored to the User’s interests. If you opt-out (by blocking the possibility of storing our cookies on your device) from profiling, no negative consequences will occur. Advertisements and other marketing information will still be published, but they will be less tailored to the User.

§ 11 SECURITY AND LIABILITY PRINCIPLES

1. The Administrator has implemented and applies procedures for the protection of personal data and uses modern organizational and technical safeguards to ensure that the personal data collected and processed by the Administrator is conducted in accordance with the provisions of the GDPR, including to prevent accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure, or access, and all other unlawful forms of processing.
2. The Administrator also takes all actions to ensure that cooperating entities provide a guarantee of applying appropriate security measures whenever they process personal data on behalf of the Administrator.

§ 13 FINAL PROVISIONS

You can find the cookie policy at: [LINK]

Changes in the Privacy Policy may be influenced by the development of internet technology or changes in personal data protection law.

Changes to the Privacy Policy are effective from the date of their publication.