PRIVACY POLICY

 1.This Privacy Policy governs the processing of personal information collected through the www.eecom.eu website (the "Website").
 2.The owner of the Website and, at the same time, the data administrator is Przemysław Jóskowiak running the business activity under the name Stratego24 Przemysław Jóskowiak with registered office in Warsaw (00-545), Marszałkowska 58, registered in the Central Register of Business Activity and Information run by the Minister of Business and Technology, NIP: 9511918577, REGON: 017380452, hereinafter referred to as Stratego24.
 3.Personal data collected by Stratego24 through the Website are processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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), also known as GDPR.
 4.Stratego24 makes every effort to respect the privacy of Users visiting the Website.
§ 1 Type of data processed, purposes and legal basis
 1.Stratego24 collects information on natural persons performing a legal action not directly related to their business, natural persons conducting business or professional activity on their own behalf, and natural persons representing legal persons or organizational units not being legal persons but to which the law grants legal capacity, conducting business or professional activity on their own behalf, hereinafter collectively referred to as Users.
 2.Users' personal information is collected in case:
 a)placing an order on the Website, in order to execute the sales agreement. Legal basis: necessary to execute the sales agreement (Article 6(1)(b) of the GDPR).
 3.When placing an order on the Website, the User provides the following data:
 a)email address;
 b)address information:
 a.zip code and city;
 b.country (state);
 c.street including house/apartment number.
 c)name;
 d)phone number.
 4.In case of Entrepreneurs, the above scope of data is additionally extended by:
 a)the company of the Entrepreneur;
 b)NIP number.
 5.When using the Website, additional information may be collected, in particular: the IP address assigned to the User's computer or the external IP address of the Internet provider, domain name, browser type, access time, operating system type.
 6.Navigation data may also be collected from Users, including information about links and references they choose to click on or other actions taken on our Website. Legal basis - Legally justified interest (Article 6(1)(f) GDPR), consisting in facilitating the use of services provided electronically and improving the functionality of these services.
 7.In order to establish, assert and enforce claims, certain personal data provided by the User as part of the use of functionalities on the Website may be processed, such as: name, surname, data on the use of services, if the claims arise from the manner in which the User uses the services, other data necessary to prove the existence of the claim, including the extent of damage suffered. Legal basis - legitimate interest (Article 6(1)(f) of the RODO), consisting in the establishment, investigation and enforcement of claims and the defense against claims in proceedings before courts and other state authorities.
 8.Providing personal data to Stratego24 is voluntary, in connection with concluded sale agreements or provision of services via the Website, with the reservation, however, that failing to provide the data specified in the forms during the Registration process makes it impossible to register and set up a User Account, and in the case of placing an order without registering a User Account, it makes it impossible to place and carry out the User's order.
§ 2 To whom is the data shared or entrusted and how long is it stored?
 1.User's personal data is transferred to service providers used by Stratego24 in running the Website. Service providers to whom personal data is transferred, depending on contractual arrangements and circumstances, are either subject to Stratego24's instructions as to the purposes and means of processing such data (processors) or determine the purposes and means of processing themselves (controllers).
 a)Processors. Stratego24 uses suppliers who process personal data solely at the direction of Stratego24. These include, but are not limited to, providers of hosting services, accounting services, providers of marketing systems, systems to analyze traffic on the Website, systems to analyze the effectiveness of marketing campaigns;
 b)Administrators. Stratego24 uses providers who do not act solely on instructions and determine themselves the purposes and uses of Users' personal data. They provide electronic payment and banking services.
 2.Location. The Service Providers are primarily based in Poland and other European Economic Area (EEA) countries.
 3.Users' personal information is stored:
 a)If the basis for processing personal data is consent, then personal data of the User are processed by Stratego24 as long as the consent is not revoked, and after the consent is revoked, for a period of time corresponding to the statute of limitations for claims that Stratego24 may raise and that may be raised against it. Unless otherwise stipulated by a specific provision, the statute of limitations is six years, and for claims for periodic performance and claims related to the conduct of business activity - three years.
 b)If the basis for data processing is performance of a contract, then the User's personal data are processed by Stratego24 as long as it is necessary for performance of the contract, and after that time for a period corresponding to the period of limitation of claims. Unless a specific provision provides otherwise, the period of limitation is six years, and for claims for periodic performance and claims related to business activities - three years.
 4.Navigation data may be used to provide Users with a better service, to analyze statistical data and to customize the Website to Users' preferences, as well as to administer the Website.
 5.If requested, Stratego24 makes personal data available to authorized state authorities, in particular to organizational units of the Prosecutor's Office, the Police, the President of the Office for Personal Data Protection, the President of the Office for Competition and Consumer Protection, or the President of the Office of Electronic Communications.
§ 3 Mechanism of cookies, IP address
 1.The Website uses small files, called cookies. These are stored by Stratego24 on the Web Site visitor's end device if the Web browser permits. A cookie file usually contains the name of the domain it came from, its "expiration time" and an individual random number identifying the file. Information collected by means of files of this type helps to adjust products offered by Stratego24 to individual preferences and real needs of persons visiting the Website. They also make it possible to compile general statistics on visits to products presented on the Website.
 2.Stratego24 uses two types of cookies:
 a)Session cookies: when the session of a given browser ends or the computer is switched off, the stored information is deleted from the device memory. The mechanism of session cookies does not allow collecting any personal data or any confidential information from Users' computers.
 b)Persistent cookies: are stored in the memory of the User's terminal equipment and remain there until they are deleted or expire. The mechanism of persistent cookies does not allow collecting any personal data or any confidential information from the Users' computer.
 3.Stratego24 uses its own cookies for:
 a)authentication of the User in the Website and ensuring session of the User in the Website (after logging in), thanks to which the User does not have to re-enter his/her login and password on each subpage of the Website;
 b)analysis, research and audience audit, and in particular to create anonymous statistics that help to understand how Users use the Website, which allows to improve its structure and content.
 4.Stratego24 uses external cookies to:
 a)Collect general and anonymous statistical data using Google Analytics analytical tools (administrator of external cookies: Google Inc. based in the USA);
 b)Collect general and anonymous statistical data using LinkedIn analytical tools (administrator of external cookies: LinkedIn Inc. based in the USA);
 c)Collect general and anonymous statistical data using Google Ads analytical tools (administrator of external cookies: Google Inc. based in the USA);
 d)The collection of general and anonymous statistical data via analytical tools of the Facebook website (administrator of external cookies: Facebook Inc. with headquarters in the USA);
 e)Presenting the Certificate of Rzetelny Regulamin via internet service rzetelnyregulamin.pl (administrator of external cookies: Rzetelna Grupa sp. z o.o. based in Warsaw).
 5.The cookie mechanism is safe for the computers of Website Users. In particular, this way it is not possible for viruses or other unwanted software or malware to get into the computers of Users. Nevertheless, in their browsers Users have the possibility to limit or disable access of cookies to computers. If this option is used, the use of the Website will be possible, except for the functions that by their nature require cookies.
 6.Below we show you how to change the settings of popular web browsers regarding the use of cookies:
 a)Internet Explorer browser;
 b)Microsoft EDGE browser;
 c)Mozilla Firefox browser;
 d)Chrome browser;
 e)Safari browser;
 f)Opera browser.
 7.Stratego24 may collect IP addresses of Users. An IP address is a number assigned to the computer of a person visiting the Website by an Internet service provider. The IP number enables access to the Internet. In most cases, it is assigned to a computer dynamically, i.e., it changes each time it connects to the Internet. The IP address is used by Stratego24 in diagnosing technical problems with the server, creating statistical analyses (e.g. determining from which regions we record the most visits), as information useful in administering and improving the Website, as well as for security purposes and possible identification of server-overloading, unwanted automatic programmes for browsing the contents of the Website.
 8.The Website contains links and references to other websites. Stratego24 is not responsible for the privacy practices on those sites.
§ 4 Data subjects' rights
 1.The right to withdraw consent - legal basis: Article 7(3) of the GDPR.
 a)You have the right to withdraw any consent that you have given to Stratego24.
 b)Withdrawal of consent is effective from the time of withdrawal.
 c)Withdrawal of consent does not affect the processing performed by Stratego24 in accordance with the law prior to its withdrawal.
 d)Withdrawal of consent does not entail any negative consequences for the User, but it may prevent further use of services or functionalities that, in accordance with the law, Stratego24 may provide only with consent.
 2.Right to object to data processing - legal basis: article 21 of the GDPR.
 a)The User has the right to object at any time - for reasons related to his/her particular situation - to the processing of his/her personal data, including profiling, if Stratego24 processes his/her data on the basis of a legally justified interest, e.g. marketing Stratego24 products and services, keeping statistics on the use of particular functionalities of the Website and facilitating the use of the Website, as well as satisfaction surveys.
 b)Opting out in the form of an email from receiving marketing communications about products or services will constitute the User's objection to the processing of their personal data, including profiling for these purposes.
 c)If the User's objection proves to be justified and Stratego24 has no other legal basis for processing the personal data, the User's personal data will be deleted, to the processing of which the User has raised an objection.
 3.Right to erasure ("right to be forgotten") - legal basis: article 17 of the GDPR.
 a)You have the right to request deletion of all or some of your personal data.
 b)You have the right to request deletion of your personal information if:
 a.the personal data is no longer necessary for the purposes for which it was collected or for which it was processed;
 b.has withdrawn specific consent, to the extent that Personal Data was processed based on his or her consent;
 c.has objected to the use of its data for marketing purposes;
 d.personal data is processed unlawfully;
 e.personal data must be deleted in order to comply with a legal obligation under Union or Member State law to which Stratego24 is subject;
 f.personal data was collected in connection with the offering of information society services.
 c)Despite a request to delete personal data, in connection with filing an objection or withdrawing consent, Stratego24 may retain certain personal data to the extent that processing is necessary to establish, assert, or defend claims, as well as to comply with a legal obligation requiring processing under Union law or the law of a Member State to which Stratego24 is subject. This applies in particular to personal data such as: name, surname, e-mail address, which data is retained for the purpose of investigating complaints and claims relating to the use of Stratego24 services, or additionally home address / mailing address, order number, which data is retained for the purpose of investigating complaints and claims relating to concluded sales contracts or provision of services.
 4.The right to restrict data processing - legal basis: article 18 GDPR.
 a)The User has the right to request restriction of processing of his/her personal data. Submitting a request, until it is considered, prevents the use of certain functionalities or services, the use of which will involve the processing of data covered by the request. Stratego24 will not send any messages, including marketing messages.
 b)You have the right to request that we restrict the use of your personal data in the following cases:
 a.if it questions the correctness of its personal data - then Stratego24 limits its use for the time needed to verify the correctness of the data, but no longer than for 7 days;
 b.when the processing is unlawful and instead of erasing the data, the User requests the restriction of its use;
 c.when the personal data is no longer necessary for the purposes for which it was collected or used, but it is necessary for the User to establish, assert or defend a claim;
 d.when he/she raised an objection to the use of his/her data - then the restriction is made for a time necessary to consider whether, due to the particular situation, the protection of the interests, rights and freedoms of the User outweighs the interests pursued by the Administrator while processing the User's personal data.
 5.Right of access to data - legal basis: article 15 GDPR.
 a)You have the right to obtain confirmation from the Administrator as to whether it is processing Personal Data, and if it is, you have the right:
 a.gain access to your personal information;
 b.obtain information about the purposes of processing, the categories of personal data processed, the recipients or categories of recipients of such data, the intended period of storage of the User's data or the criteria for determining this period (when it is not possible to determine the intended period of data processing), the User's rights under the RODO and the right to lodge a complaint to the supervisory authority, the source of such data, automated decision-making, including profiling, and the safeguards applied in connection with the transfer of such data outside the European Union;
 c.obtain a copy of your personal information.
 6.Right to rectification of data - legal basis: article 16 GDPR.
 a)The User has the right to request the Administrator to promptly rectify personal data concerning him/her that is inaccurate. Taking into account the purposes of the processing, the User to whom the data pertains has the right to request the completion of incomplete personal data, including by providing an additional statement, by directing the request to the e-mail address in accordance with §6 of the Privacy Policy.
 7.Right to data portability - legal basis: article 20 GDPR.
 a)You have the right to receive your personal data that you have provided to the Administrator and then send it to another controller of your choice. The User also has the right to request that the personal data be sent by the Administrator directly to such controller, if technically possible. In this case, the Administrator will send the User's personal data in the form of a file in csv format, which is a commonly used, machine-readable format that allows the Administrator to send the received data to another controller.
 8.If the User has the right resulting from the above rights, Stratego24 fulfills the request or refuses to fulfill it immediately, but no later than within one month after receiving the request. However, if - due to the complexity of the request or the number of requests - Stratego24 will not be able to comply with the request within one month, it will comply within the next two months, informing the User, within one month of receiving the request, of the intended extension of the deadline and the reasons for it.
 9.The User may lodge complaints, inquiries and requests to the Administrator regarding the processing of his/her personal data and exercising his/her rights.
 10.You have the right to request Stratego24 to provide you with a copy of the standard contractual clauses by directing your request as indicated in §6 of the Privacy Policy.
 11.The User has the right to lodge a complaint with the President of the Office for the Protection of Personal Data, regarding the violation of their data protection rights or other rights granted under the GDPR.
§ 5 Security management - Password
 1.Stratego24 provides Users with a secure and encrypted connection when transferring personal data and when logging into the User's Account on the Website. Stratego24 uses an SSL certificate issued by one of the world's leading companies in security and encryption of data sent over the Internet.
 2.Stratego24 never sends any correspondence, including e-mail correspondence, requesting login credentials, and in particular the password to access the User's account.
§ 6 Changes to the Privacy Policy
 1.The Privacy Policy is subject to change, of which Stratego24 will inform Users 7 days in advance.
 2.For questions related to this Privacy Policy, please contact us at kontakt@eecom.eu.
 3.Date last modified: 15.10.2019 r.
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