1. General information

This policy applies to the website operating at the following URL: smart-solutions.pl

The website is operated and personal data is administered by Smart Solutions Sp. z o.o. with its registered office at ul. Techniczna 5, 05-270 Nadma, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS number 0000829669, NIP number 524-289-0000, REGON number 0000829669. Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS number 0000829669, NIP number 524-289-84-38.

Operator’s e-mail contact address: kontakt@smart-solutions.pl.
The Operator is the Administrator of personal data in relation to data provided voluntarily on the
Website.

Użytkownikiem jest każdy podmiot, który przegląda zawartość strony internetowej.

The Website uses personal data for the following purposes:

• Running a newsletter;
• Handling inquiries via the contact form
• Providing ordered services and products
• Presentation of offers or information on the website

The Service performs the functions of obtaining information about users and their behavior in the following ways:

• Through data voluntarily provided in forms, which is entered into the Operator’s systems;
• By filling out the contact form;
• By subscribing to the newsletter.;
• By storing cookies on the devices.

2. Personal data

The Website Administrator is the administrator of the User’s personal data within the meaning of the
General Data Protection Regulation (hereafter referred to as “GDPR”)

The User may provide their personal data to the Administrator using the forms available on the
Website and other solutions, such as social media profiles.

The legal basis for the processing of Users’ personal data is the voluntary, specific, informed, and
unambiguous consent of the User expressed by means of an appropriate form on the Website.

Newsletter subscription form:

Personal data provided to the Administrator by the User in the newsletter subscription form is
processed for the purpose of providing a newsletter service containing information about news and
selected offers. Providing personal data by the User is voluntary, but necessary for the User to
subscribe to and receive the newsletter.

Data processing is based on a contract (legal basis: Article
6(1)(b) of the GDPR) concluded using the newsletter subscription form. The User may terminate the
contract by unsubscribing according to the instructions provided in each newsletter or by sending a
relevant statement to the Administrator’s email address.

Contact form:
Personal data provided to the Administrator by the User via the contact form or in an email sent to
the Administrator’s address provided on the Website is processed for the purpose of responding to
the inquiry sent.

Providing personal data by the User is voluntary, but necessary for the User to
receive a response.

Data processing for this purpose is based on the legitimate interest pursued by
the Administrator (Art. 6(1)(f) of the GDPR). This data will be processed until the end of the
correspondence and for 3 years after its completion.

Personal data may also be processed in cases where the Administrator is authorized to process
personal data on the basis of legal provisions or for the purpose of performing a contract concluded
between the parties, as well as on the basis of a legitimate interest pursued by the Administrator.

3. Purpose of data use

The data provided by the User or collected automatically by the Administrator is used for the
following purposes:

• ensuring the proper functioning, configuration, and security of the Website;
• monitoring the status of sessions;
• analysis, research, and auditing of Website views in terms of marketing operations;
• performing tasks such as responding to inquiries via the Contact Form and sending
  newsletters;
• for statistical and marketing purposes.

4. Selected data protection methods implemented by the Operator

The Administrator guarantees the confidentiality of all personal data disclosed to them.

Personal data is gathered with due diligence and is appropriately protected against access by
unauthorized persons, and its processing is carried out in accordance with and under the conditions
specified in detail in:

• 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;
• Act of July 18, 2002 on the provision of electronic services;
• Act of May 10, 2018 on the protection of personal data.

Logging in places and entering personal data are protected in the transmission layer (SSL certificate). This ensures that the personal and login data entered on the site are encrypted on the user’s computer and can only be read on the target server.

User passwords are stored in encrypted form. The encryption function is one-way – it is not possible
to reverse its operation, which constitutes currently the modern standard in the field of user
password storage.

The Operator periodically changes its administrative passwords. In order to protect data, the Operator regularly creates security backup copies.

An important element of data protection is regular update of all software, used by the Operator to process personal data, which in particular means regular updates of software components.

5. Hosting

The website is hosted (technically maintained) on the operator’s servers: hostilia.pl

6. Rights and additional information on the use of User data

In certain situations, the Administrator has the right to transfer User data to other recipients if it is
necessary to perform the concluded contract or to fulfill the obligations incumbent on the
Administrator. This applies to such groups of recipients:

• Hosting company on a trust basis;
• Website operator;
• Authorized employees and associates who use the data to fulfill the Administrator’s purpose
  for the User;
• Companies providing marketing and emailing services to the Administrator.

Personal data is processed by the Administrator for no longer than is necessary to perform the
related activities specified in separate legal provisions.

The User has rights related to the processing of their personal data, including:

• the right to access data;
• the right to rectify data;
• the right to restrict data processing;
• the right to object to data processing;
• the right to erase data (the so-called right to be forgotten);
• the right to transfer data;
• the right to lodge a complaint with a supervisory authority in relation to the processing of
  personal data by the Administrator.

The User has the right to withdraw their consent at any time if the User has previously given it.

In order to exercise their rights, the User should send an appropriate request to the following e-mail
address: kontakt@smart-solutions.pl

Actions of the Administrator may be complained about to the President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw.
Providing personal data is voluntary, but necessary for the operation of the Website.

The User may be subject to automated decision-making, including profiling, for the purpose of
providing services under the concluded contract and for the purpose of direct marketing by the
Administrator.

The User’s personal data will not be transferred to recipients from third countries or international
organizations that do not provide an adequate level of protection. An adequate level of protection
must be confirmed by a relevant decision of the European Commission or another binding legal
instrument. This means that we do not transfer them outside the European Union. This means that we do not send them outside the European Union.

7. Information provided for in forms

The Website collects information provided voluntarily by the User, including personal data, if
provided.

Service may save information about connection parameters (time stamp, IP address).

Service, in some cases, may save information to facilitate the association of the data in the form with the e-mail address of the user completing the form. In this case, the e-mail address of the user appears inside the URL of the page containing the form.

The data provided in the form is processed for the purpose resulting from the function of a specific
form, e.g. to process a service request or commercial contact, register services, subscribe to a
newsletter, etc. Each time the context and description of the form clearly informs what it is used for.

8. Administrator logs

Information about User behavior on the website may be logged. This data is used to manage the site.

9. Relevant marketing techniques