GDPR

privacy policy

last update date: 16/10/2024

Subject and Purpose of the Policy – ​​What is the purpose of the Policy? Who does it apply to? Who is the personal data controller?

This document describes how the owner of the website www.trokentech.pl collects, uses and protects the personal data of the website Users, including the Online Store.

The owner of the website and the data controller is TrokenTech sp. z o. o. with its registered office at ul. Bardzka 60, 50-517 Wrocław, entered into the National Court Register – Register of Entrepreneurs under the KRS number 0000342475, registration court: District Court for Wrocław-Fabryczna, 6th Commercial Division of the National Court Register; Tax Identification Number (NIP) 8992684140; Regon (National Business Registry Number) 021122451 (hereinafter "we" or "us").

The information contained in the Privacy Policy applies to the Users of the website, i.e. visitors to our websites, including those who have subscribed to the Newsletter, those applying for employment law advertisements, those contacting us using the forms available on the website, and those who make purchases through the website store (customers, consumers).

By visiting the website www.trokentech.pl , subscribing to the Newsletter, applying for a job advertisement, contacting us using the forms available on the website, placing an order in the store, creating an account on the website and concluding a sales contract, you accept and consent to the practices described in this Policy.

Questions, comments and requests regarding this Privacy Policy are welcome and should be addressed to the data controller, i.e.:

• to the e-mail address: biuro@trokentech.pl ,
• by phone: +48 71 794 43 44,
• or in writing to the following address: ul. Bardzka 60, 50-517 Wrocław.

Categories of personal data, processing purposes, and legal bases – What personal data do we process and why? What are the legal bases?

1. Data necessary to place an order, create an account, and conclude a sales contract.

The person placing the order completes the appropriate form on the website, providing the following data: first name, last name, delivery/registered office/shipping address (street, building number, apartment number, postal code, city, province, country), telephone number and e-mail address; if the buyer is an entrepreneur, he/she also provides the company name and the Tax Identification Number.

You can place an order without registration, but also (optionally) by registering/logging in to the store.

By registering on the website, a buyer account is created. Registration requires the buyer to complete the appropriate electronic form available on the website, providing the required data. This data includes the data required to place an order, as listed above. Registration is voluntary.

Purpose : The provision of personal data by the buyer is necessary to place an order and conclude and execute a sales contract. Providing an email address and/or telephone number is necessary to confirm acceptance and fulfillment of the order.

Legal basis:

– Article 6(1)(b) of the GDPR – processing is necessary for the performance of a contract to which the data subject is a party, or to take steps at the request of the data subject before concluding a contract, i.e. acceptance and execution of an order, conclusion and execution of a sales contract;

– Article 6(1)(c) of the GDPR – processing is necessary to fulfil a legal obligation incumbent on the controller, including the one resulting from the Accounting Act, i.e. storing accounting documents relating to the performance of contracts;

– Article 6(1)(f) of the GDPR – processing is necessary for the purposes of legitimate interests pursued by the controller or by a third party, i.e. providing customers with information about the execution of the order, ongoing contact with the customer regarding the execution of the order, handling complaints, requests for withdrawal from the contract.

2. Data necessary to present an offer containing an investment discount (Wholesale Orders form).

To receive an offer with an investment discount, you can send us your phone number and city name using the dedicated form, "Wholesale Orders." The form is available on the Website. Submitting your personal data is voluntary.

Purpose : The data will be processed in order to present an offer containing an investment discount.

Legal basis : Article 6(1)(a) of the GDPR, i.e., the data subject has consented to the processing of their personal data. We also inform you that you may withdraw your consent at any time by sending an email to biuro@trokentech.pl . Such withdrawal of consent will not affect the legality of the processing prior to the withdrawal.

3. Newsletter data.

If you wish to receive our Newsletter, we collect and process your data, i.e. name and e-mail address.

Purpose : Data related to the Newsletter will be used to provide marketing information to promote products, the blog, the YouTube channel and the Facebook fanpage.

Legal basis : Article 6(1)(a) of the GDPR, i.e., the data subject has consented to the processing of their personal data for one or more specific purposes. We also inform you that you can withdraw your consent at any time by sending an email to biuro@trokentech.pl or clicking the deactivation link in each of our newsletters. Such withdrawal of consent will not affect the legality of the processing prior to the withdrawal.

You can read more about the Newsletter service in the Newsletter Regulations.

4. Data of job candidates.

By sending us a recruitment application, the candidate consents to the processing of his or her personal data in the recruitment documentation provided, including in the CV.

Purpose : We will process the candidate's data for the purpose of recruitment and, if consent is given, also during future recruitments.

Legal basis:

– Article 6, paragraph 1, letter c) of the GDPR – processing is necessary to fulfil the legal obligation incumbent on the controller, i.e. arising from the Labour Code – in terms of first name(s), last name, date of birth, contact details provided by the candidate, education, professional qualifications and previous employment history,

– Article 6(1)(b) of the GDPR – taking action at the request of the data subject before concluding a contract or to take action at the request of the data subject before concluding a contract,

– Article 6(1)(a) of the GDPR – consent of the data subject – if the application documents contain personal data beyond the scope specified in the Labor Code,

– Article 6(1)(a) of the GDPR – consent of the job candidate to the processing of data during future recruitment processes,

– Article 6, paragraph 1, letter a) of the GDPR – consent of the job candidate to the processing of his/her additional personal data not specified in the law (e.g. image, interests),

– Article 6(1)(f) of the GDPR – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, i.e. the establishment, exercise or defence against legal claims.

5. Data regarding the use of the Website.

In connection with your visit to our website, we collect the following information: browser data (e.g., type, version, language); operating system and interface data; referring website data (referrer URL); data about the websites you visit on our website; date and time of accessing our website; access status/HTTP status code, amount of data transferred, and Internet Protocol (IP) address. This data is collected in the form of cookies – you can read more about this in the cookie banner that appears during your first visit to the website. The same banner also appears after clicking the widget (the "safety pin" in the lower left corner of the page) cookie settings -> change your consent.

Purposes : Usage data will be used to provide access to the website, facilitate its use, and detect technical errors and/or errors in the transmission of electronic communications. The data will also be used for statistical purposes, i.e., to collect information about how users use our website.

Legal basis:

– Article 6(1)(f) of the GDPR – processing is necessary for the purposes of the legitimate interests pursued by the controller or a third party. These interests are intended to provide the User with access to the website as requested and to achieve other purposes specified above. The legal basis concerns the use of necessary cookies.

Article 6(1)(a) of the GDPR – the data subject has given consent. The legal basis concerns the use of statistical third-party cookies. During the first visit to the website, the User is presented with information about the use of cookies. Here, the User can choose which types of cookies they consent to. While using the Website – at any time – the User can also modify their consent by clicking the cookie widget appearing on every page (in the lower left corner) and then changing the settings in the banner that appears.

Retention periods – How long do we store personal data?

Customer personal data will be stored for accounting purposes for a maximum period of 5 years, counted from the end of the calendar year in which the tax payment deadline related to the contract concluded in the store expired. To the extent otherwise justified by the processing purposes, personal data will be stored for as long as a legal basis for processing exists, unless applicable law requires a longer retention period. At the end of the retention period, personal data will be deleted or anonymized.
If we process your personal data based on additional consents – provided, of course, that you provide them – we process them until you withdraw your previously granted consent. If we process personal data for direct marketing purposes, we process them until you object to their processing.
In summary, we store your data no longer than necessary to achieve the purposes for which it was collected, unless applicable law requires us to retain it longer.

Recipient categories and international transfers – Who do we send personal data to and where is it located?

We share the collected personal data of the customer with a selected carrier or intermediary handling shipments on our behalf. In the case of a customer who uses electronic payments or a payment card, we share the collected personal data of the customer with the selected entity handling these payments. We may also transfer data to suppliers to whom we commission services related to personal data processing, such as IT service providers or website operators. Such entities process data based on a data processing agreement concluded with them and only in accordance with our instructions.

Any access to Users' personal data is limited to those individuals/entities who need to access it to fulfill their professional responsibilities. We will also share Users' personal data with professional advisors, government authorities, and courts as required or permitted by applicable law.

The Google tools we use allow your personal data to be processed on a server in the United States. In these cases, Google may process your personal data outside the European Economic Area, but this is done based on an adequacy decision, the Data Privacy Framework, or on standard contractual clauses, provisions of a contract between us and Google that guarantee an adequate level of security for the processing of your personal data.

Cookies – how do we use them?

Like many other websites, we also use so-called "cookies." Cookies are small text files that are transferred from a website server to your hard drive. This automatically provides us with certain data, such as your IP address, browser used, operating system, and internet connection.
Based on the information contained in cookies, we can facilitate navigation and enable the correct display of our website. These files are not harmful to your device in any way and do not change its settings or the settings of any software installed on it.
The law states that cookies may be stored on the user's device if this is necessary for the website to function. For all other types of cookies, the Administrator requires the user's consent.

Necessary cookies are processed by the Administrator based on the legitimate interests of the Administrator and Users. Other cookies are processed based on the user's consent.

When accessing the website www.trokentech.pl , the user is presented with information about cookies (a banner at the bottom of the page). Here, the user is informed about the cookies we use on the Website and has the option to choose the types of cookies they consent to.

Furthermore, the user may withdraw their consent at any time or change their preferences by clicking the cookie widget located on each page (in the lower left corner) and then changing the settings in the banner that appears.
Furthermore, by default, web browsing software (browser) allows cookies on the user's device on which it is running. In most cases, you can configure this software yourself, including by forcing automatic blocking of cookies. Issues related to configuring how cookies are handled are located in the software's (internet browser's) settings. Please note that some features of our website may not function if you have disabled cookies. Detailed information about the possibilities and methods of handling cookies is available in the software's (internet browser's: Opera, Firefox, Internet Explorer, Chrome, Safari) settings. Under no circumstances will the data we collect be transferred to third parties without the user's consent.
Full and constantly updated information about the cookies used on the website can be found in the banner that appears during your first visit to the website. The same banner also appears after clicking on the widget (the "safety pin" in the lower left corner of the page) cookie settings -> change your consent.

Analytical and marketing tools – which ones do we use?

1. Thulium

The website uses software that ensures efficient management of contact with the User and other people interested in our activities for the User's convenience and to ensure the highest quality of customer service, i.e., a tool provided by Thulium. As part of the plug-in implemented on our website, the User can initiate contact with us in real time and leave their details, indicating that they request contact at a later date (in this case, you provide a telephone number and IP address, which determines the approximate location of the User). The User has the option of leaving a message, which is registered in the system as a notification (in this case, they provide their name, email address, and message content in the form). The tool is provided by Thulium sp. z o. o. The
legal basis for using the Thulium tool is Art. 6 sec. 1 letter a) of the GDPR, i.e. the consent of the data subject for the purpose of marketing TrokenTech sp. z o. o.'s products and services, as well as telephone contact and/or contact via email/SMS/MMS. We also inform you that you may withdraw your consent at any time by sending an email to biuro@trokentech.pl. Such withdrawal of consent will not affect the legality of processing based on consent before its withdrawal.

2. Trusted Shops

If the User has consented to submitting a review of a purchase during or after placing an order (Article 6, Section 1, Letter a of the GDPR), we will use the User's email address to send them an electronic invitation to evaluate the purchase made in our store. The review/rating is submitted via our review system. The User may withdraw their consent at any time by sending a message informing them of the withdrawal of consent to our email address: biuro@trokentech.pl . Alternatively, the User may also use the unsubscribe link included in the email inviting them to submit a review.

Review invitations are sent by our service provider Trusted Shops GmbH, Subbelrather Str. 15C, 50823 Cologne, Germany (Trusted Shops). As part of sending the invitations, we receive status information from Trusted Shops (e.g., whether the review invitation has been sent and whether it has reached the recipient). This is done in accordance with Article 6 (1) (f) of the GDPR to pursue our legitimate interest in receiving information about review invitations in order to be able to make optimizations based on this information, if necessary.

3. Google Ads

This is an advertising tool from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, that allows us to create ads that are valuable to users. Detailed information on how Google uses cookies to display ads and how to manage your settings is available at: https://policies.google.com/technologies/ads?hl=pl .
Details regarding data processing within Google Analytics can be found at the following link: https://support.google.com/analytics/answer/6004245?hl=pl .

4. Google Analytics

This is a set of tools from Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA, that allow us to collect statistical information about your use of the website, such as your IP address, device type, and browser type. We do this to understand, among other things, the number of users who use our website. This information is processed only in a way that does not directly identify anyone. Detailed information on privacy and terms of use can be found at: https://marketingplatform.google.com/about/analytics/terms/pl/ .

5. Microsoft Clarity

This analytical tool collects information about the behavior of Users and their end devices, in particular the device's IP address (recorded and stored in anonymized form), screen resolution, device type, information about the browser used by the user, and geolocation (country). Clarity stores this information in a pseudonymized User profile, retained for 1 year. This tool allows for the analysis of user behavior on the Website in order to improve its functionality. More information can be found in the Microsoft Privacy Policy: https://privacy.microsoft.com/pl-pl/privacystatement .

6. Google Tag Manager

Google Tag Manager is a tool used to manage tags and scripts on websites and social media profiles. It allows Google to collect data, such as information about how tags and services are used, as well as the tags themselves.
All data is processed in accordance with Google's privacy policy, available at: https://policies.google.com/privacy .

7. LinkedIn Insight Tag

This website uses the LinkedIn Insight Tag, an analytics tool provided by LinkedIn Corporation. The Insight Tag is a JavaScript code that tracks conversions and analyzes traffic on our website using cookies. It collects visit-related data such as URL, IP address, device type, browser, and timestamp. IP addresses are shortened or encrypted, and LinkedIn user IDs are deleted within seven days, rendering the data pseudonymous. This data is retained for a maximum of 90 days.

LinkedIn does not share direct personal data with the website operator, but provides anonymous reports on advertising performance and enables retargeting of visitors to our website.

More information about LinkedIn's privacy policy: https://www.linkedin.com/legal/privacy-policy .

8. Facebook Pixel

The website uses "Website Custom Audiences" pixels provided by Facebook. This means that these pixels are integrated with the website, enabling the display of targeted ads, optimizing their effectiveness, and measuring the reach of marketing activities. During a visit to the website, the Facebook pixel connects the user's browser to the Facebook server, storing a cookie, which allows for tracking visits based on IP address. If the user has a Facebook account, this information may be linked to their profile and used to display personalized ads, unless the user has opted out in their account settings.
As the website operator, we do not have access to the specific data transferred to Facebook or its precise use. Details on this matter are available in the Facebook Privacy Policy: https://www.facebook.com/about/privacy .

9. Use of YouTube videos

The website embeds videos from YouTube. Playing these videos involves the use of cookies by Google (Google Ireland Limited), the provider of the YouTube service. More information from Google about data protection at YouTube can be found at: https://policies.google.com/privacy?hl=en&gl=en .

10. MailerLite

MailerLite is a newsletter management tool that collects user behavior information to optimize email campaigns. Specifically, it collects data such as email address, email opening information, link clicks, the user's IP address (stored in anonymized form), device type, and browser used. The tool also tracks user location (country), allowing for analysis and content personalization. This data is stored in pseudonymized user profiles for up to one year. MailerLite is used to monitor campaign effectiveness and tailor content to audiences.

More information can be found in the MailerLite Privacy Policy: https://www.mailerlite.com/pl/legal/privacy-policy .

Data security – how do we protect personal data?

All Users' personal data obtained through our website are processed in a manner that ensures their security, in accordance with the provisions of generally applicable law, in particular with 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.

User rights – what rights do Users have and how can they exercise their rights?

The Website User has the right to:

• access to data and receive a copy thereof. You have the right to obtain confirmation from us as to whether or not we are processing your personal data, and if so, you have the right to:
  • access your personal data,
  • obtain information on the purposes of processing, the categories of personal data processed, the recipients or categories of recipients of these data, the planned period of data storage or the criteria for determining this period, the User’s rights under the GDPR and the right to lodge a complaint with a supervisory authority, the source of these data, automated decision-making, including profiling, and the safeguards applied in connection with the transfer of these data outside the European Union,
  • obtain a copy of your personal data.
• to rectify (amend) your data . You have the right to rectify and complete the personal data you have provided. You have the right to request that we rectify this data (if it is inaccurate) and complete it (if it is incomplete);

• to delete data (right to be forgotten) – If you believe there is no basis for us to process your data, you may request that we delete it. You have the right to request the deletion of your personal data if:
  • withdrew a specific consent to the extent that personal data were processed based on the User's consent,
  • the User's personal data are no longer necessary for the purposes for which they were collected or processed,
  • objected to the use of data for marketing purposes,
  • objected to the use of data for the purpose of maintaining statistics on the use of the website, and the objection was deemed justified,
  • personal data are processed unlawfully.

Despite your request to delete your personal data, in connection with your objection or withdrawal of consent, we may retain certain personal data to the extent necessary to establish, pursue, or defend legal claims. This applies in particular to personal data including: first name, last name, email address, and application history, which we retain for the purpose of handling complaints and claims related to your use of our services;

• data processing restrictions – You may request that we limit the processing of your personal data solely to storing it or performing actions agreed upon with you if you believe we have inaccurate data about you or we are processing it without justification, or you do not want us to delete it because you need it to establish, pursue, or defend legal claims, or for the duration of your objection to data processing. You have the right to request that we limit the use of your personal data in the following cases:
  • when you question the accuracy of your personal data – then we will limit their use for the time needed to verify the accuracy of your data,
  • when the processing of User data is unlawful and instead of deleting the data you request the restriction of its use,
  • when your personal data is no longer necessary for the purposes for which we collected or used it, but you need it to establish, pursue or defend legal claims,
  • when the User has objected to the use of his/her data – then the restriction takes place for the time needed to consider whether – due to the User’s specific situation – the protection of his/her interests, rights and freedoms outweighs the interests we pursue by processing the User’s personal data;
• object to the processing of your data for direct marketing purposes. If you exercise this right, we will cease processing your data for this purpose. If your objection proves to be justified and we have no other legal basis for processing your personal data, we will delete your data for the use of which you objected;
• File a complaint with the supervisory authority . You may submit complaints, inquiries, and requests to us regarding the processing of your personal data and the exercise of your rights. If you believe that we are processing your data unlawfully, you may file a complaint with the supervisory authority located at ul. Stawki 2 in Warsaw;
• Withdraw your consent to the processing of your personal data . Withdrawal of consent takes effect from the moment you withdraw your consent. Withdrawal of consent does not affect any processing we conducted lawfully prior to its withdrawal. Withdrawal of consent does not entail any negative consequences for you. However, it may prevent you from further use of services or functionalities that, according to the law, we can only provide with your consent.

To exercise your rights, please contact us by email at biuro@trokentech.pl .
If you submit a request, TrokenTech sp. z o. o. will make every effort to respond to your request as quickly as possible. However, it may not always be possible to fulfill your request. For example, the right to erasure cannot be fulfilled if the obligation to store data is based on legal provisions. You will be notified in writing or by email if your request has been processed.

Changes to this Privacy Policy

To ensure that our Policy consistently meets current statutory requirements, we reserve the right to make changes to it at any time. We recommend that you check this page frequently and refer to the date of the last update above.