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Privacy policy

Principles of personal data processing

Legal basis: 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 (General Data Protection Regulation / GDPR)

I. General provisions.

1. Any user contacting COMP SA via electronic tools, making use of websites as well as filling out contact forms on any website belonging to COMP SA based in Warsaw, at Jutrzenki 116, 02-230 Warsaw, submits and simultaneously entrusts their personal data and COMP SA becomes a temporary Administrator of such personal data, including data included in the contact form.
2. Personal data, included in contact forms as well as other entrusted personal data, requiring in accordance with GDPR, that the owner grants separate consent for their processing, will be deleted, unless the User authorizes COMP SA to process them for the purposes specified below, by clearly granting consent for processing such data. 

II. Scope of processing personal data.

3. After obtaining consent for processing the User’s basic data such as the data included in the contact forms i.e. name and surname, e-mail address, phone number, in the scope of establishing business relations and receiving business offers, COMP SA becomes the Administrator of such data and ensures its protection in accordance with GDPR regulations.
4. In order to make wider use of COMP SA IT services, as described in points a. and b. below, it is necessary to provide consent to the following:
a. passing on or sending commercial and marketing information by COMP SA and its business partners in any form indicated during the first processing or registration of data,
b. further passing on of personal data by COMP SA for processing solely for the purpose and scope specified in section 3 and 4a of these Principles.
5. Regardless of the provisions of these Principles, detailed regulations regarding data processing are specified in the Privacy Policy available at https://novitus.pl . Acceptance of these Principles means the User is familiar with and has accepted this Privacy Policy.

III. Principles of processing personal data.

6. Data may be sent beyond the European Economic Area to COMP SA business partners, specified at the following website: https://www.novitus.pl/pl/nasi-partnerzy.html, in order to obtain special offers.
7. Data will be retained for a period of mutual business operations and for a period of 3 years counted from the day a User’s activity is last noted in marketing activities and events organized online or offline. In the event of making purchases in COMP SA or providing services by COMP SA to the User, personal data will be processed for the period of expiration of the main amount payable defined in civil law regulations and for the period required by tax law regulations for storing invoices i.e. 5 years counting from the end of the year in which the tax liability occurred. The legal basis for these activities is article 6, section 1, item c and f of GDPR. This provision does not limit the User’s rights specified in section 8. 
8. The User is entitled to the following in relation to the processing of personal data:
a. the right to access their data and receive a copy of such data,
b. the right to rectify (correct) their data,
c. the right to remove data (if a User believes there is no basis to process their data, they may demand that we remove them),
d. the right to limit the processing of data (a User may demand, that we limit the processing of data solely to their storage or carrying out activities agreed with the User, if we have incorrect data or have no grounds to process them),
e. the right to lodge an objection to processing data (a User had the right to object to the processing of data based on a legally based interest; the User should specify the User’s particular situation, which according to the User explains why we should cease processing in the scope covered by the objection. We will cease to process the User’s data in this scope unless we demonstrate, that the basis for processing the data overrides the User’s rights or that the User’s data is required in order for us to establish, exert or defend claims),
f.  the right to transfer data (the User has the right to receive from us personal data provided to us on the basis of an agreement or consent, in a structured, commonly used and machine-readable format. The User may request such data be send directly to another entity),
g. the right to file a complaint to a supervisory authority (if the User ascertains, that we process data illegally, the User may file a complaint to the President of the Office for Personal Data Protection or other appropriate supervisory authority).
9. In order to exercise their rights, the User should send their demands to the following e-mail address: rodo@novitus.pl.

IV. Declarations.

While using electronic tools, websites and filling in contact forms, appropriately to the type of operations performed by the User, giving consent to the following clauses may be required:
1. I accept the Privacy Principles and Policy
YES / NO field
2. I consent to the processing of my personal data specified in the contact form in accordance with the above principles in the following scope:
a. establishing business relations, receiving business offers
I give my consent / I do not give my consent
b. receiving commercial and marketing information from COMP SA and its business partners
I give my consent / I do not give my consent
c. forwarding my personal data by COMP SA for processing solely for the purpose and scope specified in sections 3a and 3b
I give my consent / I do not give my consent

COMP S.A., 25 May 2018

Privacy and cookie files Policy
and detailed principles of processing personal data

Welcome!

If You are reading this, it is a clear sign, that You value your privacy. We understand this perfectly and that is why we have prepared this document, in which You will find the principles of processing personal data as well as using cookie files in relation to any marketing communication carried out by our company and the Novitus brand, via the following communication channels:
1. In relation to using websites operating independently or as sub-sites of the https://novitus.pl website as well as within the https://novitus.pl website itself.
2. The following websites are covered by this Privacy Policy:
a. https://novitus.pl
b. https://nano.novitus.pl
c. https://next.novitus.pl
d. https://sento.novitus.pl
e. https://soleo.novitus.pl
f. https://taxi-e.novitus.pl
g. https://gastrosfera.novitus.pl
h. https://online.novitus.pl
i. http://oprogramowanie.novitus.pl
j. https://kasawkantorze.pl
k. https://extranet.novitus.pl
l. https://novitusfirendsclub.pl
3. In relation to the use of any active contact forms available on the websites listed above.
4. In relation to newsletter subscription if it can be performed on any of the websites listed above.
In order to exercise Your rights resulting from GDPR or in case of any doubts related to the Privacy Policy, please submit Your request or question to the following e-mail address: rodo@novitus.pl. Please remember, that prior to carrying out Your rights we will have to properly identify You.

Personal data

We hereby inform, that the Administrator of Your personal data as defined by the personal data protection regulations is COMP SA based in Warsaw, at Jutrzenki 116, 02-230 Warsaw, entered into the registry of companies managed by the Regional Court for the capital city of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under the KRS no. 0000037706, company capital – PLN 14.795.470, REGON: 012499190, NIP: 5220001694
Correspondence address with regards to fiscal equipment and sales systems:
COMP SA, Nowy Sącz Division, NOVITUS – Sales Technology Center, Nawojowska Street 118, 33-300 Nowy Sącz.
The purpose, legal basis and period of processing personal data is specified in relations to each objective of processing data (see: description of each of the objectives for processing personal data listed below).

Rights.

We remind You, that GDPR grants You the following rights related to the protection and processing of Your personal data:
1. the right to access personal data,
2. the right to rectify personal data,
3. the right to remove personal data,
4. the right to limit the processing of personal data,
5. the right to submit an objection to the processing of personal data,
6. the right to transfer personal data,
7. the right to file a complaint to a supervisory authority,
8. the right to grant and to withdraw consent to the processing of personal data, if such consent was previously given.
The principles related to the use of the aforementioned rights have been described in detail in articles 16-21 of GDPR. We encourage You to familiarize Yourself with these regulations. On our part, we believe it is necessary to explain, that the aforementioned rights are not absolute and You will not be entitled to them in relation to all the areas of processing Your personal data. For Your convenience, within each of the descriptions of personal data processing operations, we have made efforts to point out the rights You are entitled to within those operations.
We emphasize, that You are always entitled to one of the rights listed above – if You believe we have violated the personal data protection regulations while processing Your personal data, You have the right to submit a complain to the supervisory authority (President of the Office for Personal Data Protection).
You may also always request that we provide You with information on the data we have about You and the purpose of its processing. All You have to do is send an e-mail to: rodo@novitus.pl
We have however made every effort to provide comprehensive information in this Privacy Policy. You may also use the e-mail address given above to ask any other questions related to the processing of Your personal data.

Security.

We guarantee the confidentiality of all personal data submitted to us. We ensure the undertaking of all security and personal data protection measures required by personal data protection regulations. Personal data is gathered with due diligence and appropriately protected against access by unauthorized persons.

We entrust the processing of personal data to the following entities:
1. Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA – in order to use Google services, especially Google Analytics,
2. FreshMail Sp. z o.o., Al. 29 Listopada 155 c, 31-406 Kraków – in order to use the mailing system which processes Your personal data if You signed up for the newsletter,
3. H88 S.A. based in Poznań, Franklina Roosevelta 22, 60-829 Poznań – in order to store personal data on a server,
4. Oktawave Sp. z o.o., ul. Domaniewska 44a (Platinium 5), 02-672 Warsaw – in order to store personal data on a server,
5. Rafhat Rafał Hatlaś, ul. Gorzkowska 3 lok. 12, 33-300 Nowy Sącz – in order to use IT support services, which may involve gaining access to Your personal data,
6. Investmag s.c., ul. Podlesie 3, 41-303 Dąbrowa Górnicza - in order to use IT support services, which may involve gaining access to Your personal data.
Your data will be transferred to the US as a result of using Google services. Appropriate security of Your data is ensured by an approved certification mechanism combined with enforceable obligations of the data receiver to appropriate security (Privacy Shield program).
All entities, which we entrust with the processing of personal data guarantee the use of appropriate means of security and personal data protection as required by law.

Purpose, activities and basis for processing

Newsletter.
If You wish to sign up for the newsletter, You have to give us Your e-mail address via the newsletter sign up form. Data submitted to us while signing up for the newsletter are used for the purpose of sending the newsletter and the legal basis for their processing is Your consent (article 6, section 1 letter a of GDPR) granted in the process of signing up for the newsletter.
The data is processed within the Freshmail mailing system and stored on a server provided by FreshMail Sp. z o.o., Al. 29 Listopada 155c, 31-406 Krakow.
The data will be processed for as long as the newsletter is sent out unless You unsubscribe from it earlier, which will result in removing Your personal data from the database.
You may rectify your data stored in the newsletter database at any time. You may also request their removal by unsubscribing from the newsletter. You also have the right to transfer data as specified in article 20 of GDPR.

E-mail contact.
Contacting us via electronic mail, including sending an inquiry via the contact form, You naturally give us Your e-mail address as the sender of the message. Furthermore, the text of the message can include additional personal data.
In this case, Your personal data is processed for the purpose of contacting You and the basis for processing is article 6 section 1 item a of GDPR, i.e. Your consent resulting from initiating contact with us. The legal basis for processing after the contact has ended is a justified reason in the form of correspondence archives for internal purposes (article 6 section 1 item f of GDPR).
The content of the correspondence may be archived and we are not able to clearly specify when it will be deleted. You have the right to request the presentation of the history of the correspondence carried out with us (if it is archived), as well as request its removal, unless its archivisation is justified due to our overriding interests e.g. protection against Your potential claims.

Cookie files and other tracking technologies.
Our website, similar to almost all Internet websites, uses cookie files in order to ensure you receive the best experience from using it. Cookies are small pieces of text, stored on Your end equipment (e.g. computer, tablet, smartphone), which may be read by our IT systems.
Cookies may be divided into our own cookies and third party cookies. Further details are provided below.

Consent to cookies.
During Your first visit to our website You will see information on the use of cookies together with a request for consent to the use of cookies. Managing cookie files is available from the level of Your browser settings, where you can define the principles of storing cookies on Your equipment or remove them altogether. Please remember, that turning off cookie files may cause problems with using the website as well as may other websites, which use cookies.
Our internet pages do not automatically gather any information aside from information stored in cookies. Cookie files are text files, which are stored on the user end equipment and are utilized while using out internet pages. Cookies usually contain the name of the website, from which they originate, the period of storing them on the end equipment and a unique number.

Cookie files are used for the following purposes:
a. Optimization of the use of websites; in particular these files allow the identification of the user equipment and proper presentation of the website, adjusted to the user’s individual needs;
b. Generating anonymous statistics, which help to understand how Users use websites, which in turn allows the improvement of their structure and content;
c. Maintaining user sessions (if prior logging is required), thanks to which the User does not have to repeat the logging procedure on every subpage of the website.
Our websites use two primary types of cookies: “session” (session cookies) and “persistent” (persistent cookies). “Session” cookies are temporary files, which are stored in the User end equipment until the moment of logging off, leaving the website or turning off the software (Internet browser). “Persistent cookies are stored in the User end equipment for a period defined in cookie file parameters or till the moment the User removes them. In many cases the Internet browser by default allows the storage of cookies on the User end equipment.
The Users of our websites may change their cookie file settings at any time. These settings may in particular be changed in such a way as to block the automatic support of cookie files in the browser settings or to inform the User each time a cookie is placed on the User’s equipment. Detailed information about the options and methods of handling cookie files are available in the browser settings. Cookies used by us in no way allow the identification of the User.

Third party cookies.
Our website similarly to most modern websites, uses functionalities provided by third parties, which involves using cookie files from third parties. The use of such types of cookie files is described below.
• Analysis and statistics. We use cookies to monitor website statistics, such as the number of website visitors, type of operating system and Internet browser used to view the website, time spent on the website, subpages visited, etc. We use Google Analytics for these functionalities, which involves using cookie files from the company Google LLC. The mechanism for managing cookies file settings allows You to decide whether You will allow Google Analytics to also use marketing functions or not.
• Marketing. We currently do not use any other marketing tools to profile website Users, such as Facebook Pixel, in order to send out personalized ads. If we activate such tools in the future, information on the changes made will be added to this Privacy Policy. We use Google AdWords remarketing tools. This involves using cookie files related to the Google AdWords service from the company Google LLC. You can decide whether or not we can use cookie files related to Google AdWords services, by changing Your Internet browser settings.
• Social media tools. We ensure the availability of social media functionalities, such as sharing content in social media and subscription to social media profiles. Using these functionalities involves using cookie files from social media administrators such as Facebook, Instagram, YouTube, Twitter, Google+, LindedIN. We post YouTube video recordings on our website. When You play such recordings, Google LLC cookie files are used related to the YouTube service.

Server Logs.
Using a website involves sending queries to a server, on which the website is stored. Every query directed to a server is stored in server logs.
Logs include Your IP address, the server date and time, information on the Internet browser and operation system You use. Logs are saved and stored on the server.
Data stored in server logs are not linked to specific people using the websites and are not used by us to provide Your identity.
Server logs constitute solely a support material for website administration and their content is not disclosed to anyone aside from the persons authorized to administer the server.

Special personal data processing principles related solely to the website:
http://oprogramowanie.novitus.pl
User account (relates solely to the http://oprogramowanie.novitus.pl website)
The process of setting up a User account involves providing an e-mail address, NIP number and defining an account password. Providing this data is voluntary but necessary to set up an account. You may provide further information by editing Your User profile, such as name and surname, invoicing address, phone number and correspondence address. Providing this data is completely voluntary.
Data entered by You related to the User account in processed solely in order to maintain the account and ensure You will be able to use it. Providing additional data in the user account has the purpose of placing orders easier by automatically filling in fields in the order form.
The legal basis for processing Your personal data from the User account is the realization of orders placed and issuing an invoice as well as filing the invoice in accounting records, which You conclude based on store regulations – article 6, section 1, items b and c of GDPR. 
Data collected in the User account is processed within the COMP S.A. system and stored on a server provided by COMP S.A.
Your data will be processed in relation to the account as long as You will have a User account. After deleting a User account, Your data will be deleted from the database, with the exception of information on orders placed.
You can gain access to Your personal data processed in relation to the account at any time by logging on Your User account. After logging to the account You can modify Your data at any time as well as delete them, with the exception of orders placed. You can also decide to delete Your account at any time.
In relation to data stored in Your User account, You also have the right to transfer data, as specified in article 20 of GDPR.
Orders (relates solely to the http://oprogramowanie.novitus.pl website)
When placing orders, You have to provide information necessary to carry out the order, i.e. name and surname, invoicing address, delivery address, e-mail address, phone number. Providing this data is voluntary but necessary to place an order.
Data submitted to us in relation to an order, is processed to carry out the order (article 6, section 1 item b of GDPR), issue an invoice (article 6, section 1, item c of GDPR), filing the invoice in our accounting records (article 6, section 1, item c of GDPR) and for archive and statistical purposes (article 6, section 1, item f of GDPR).
Data contained in orders placed through the shop are processed in the COMP S.A. system and stored on a server provided by COMP S.A.
If You have a User account, Your order will be visible in the order history for a given account.
Each order is documented by an invoice. Invoices are issued using the SAP system, administered by COMP S.A. Orders are also registered in our internal database for archive and statistical purposes.
Data on orders will be processes for a period necessary to carry out an order and then further until claims resulting from a concluded agreement expire. Furthermore, after this period, data may still be processed by us for statistical purposes. Please also remember, that we are required to store invoices with Your personal data for a period of 5 years from the end of the fiscal year, in which the fiscal obligation was created.
In the case of information on orders, You do not have the option of correcting this data after the order has been completed. You also cannot object to the processing of data or demand the data be removed until claims resulting from the concluded agreement have expired. Similarly, You cannot object to processing data and demand removal of data included on invoices. After claims resulting from a concluded agreement have expired You may object to the processing of Your data for statistical purposes as well as demand we remove Your data from our database.
In relation to data on orders You also have the right to transfer data as specified in article 20 of GDPR.
Complaints (relates solely to the http://oprogramowanie.novitus.pl website)
By submitting a complaint, You provide us with personal data included in the content of the complaint, which includes a name, surname, phone number and e-mail address.
Data provided in relation to submitting a complaint is used in order to carry out the complaint procedure (article 6, section 1, item c of GDPR).
Data will be processed by us for a period necessary to carry out the complaint procedure. Complaints may furthermore be archived for statistical purposes.
In case of data included in complaints You do not have the possibility to correct this data. You also cannot object to the processing of data or demand the data be removed until claims resulting from the concluded agreement have expired. After claims resulting from a concluded agreement have expired You may object to the processing of Your data for statistical purposes as well as demand we remove Your data from our database.

COMP S.A., 25 May 2018

 
 
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