DEFINITIONS

1. Administrator – Truck Care Sp. z o.o. in Warsaw (ul. Żwirki i Wigury 18a, 02-092 Warsaw), entered into the register of entrepreneurs maintained by the District Court for the Capital City of Warsaw in Warsaw, XIV Commercial Division of the National Court Register under KRS number 0000297980, with NIP 7393664142, REGON 280266382, BDO 000471572, share capital of PLN 3,520,000.00, fully paid up, and the status of a large entrepreneur within the meaning of Article 4(6) of the Act on counteracting excessive delays in commercial transactions.

2. Personal Data – information about an identified or identifiable natural person through one or more specific factors determining physical, physiological, genetic, mental, economic, cultural, or social identity, including device IP, location data, internet identifier, and information collected through cookies and other similar technologies.

3. Policy – this Privacy Policy.

4. GDPR – 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.

5. Service – the website operated by the Administrator at https://truckcare.pl.

6. User – any natural person visiting the Service or using one or more services or functionalities described in the Policy.

DATA PROCESSING IN CONNECTION WITH THE USE OF THE SERVICE

In connection with the User's use of the Service, the Administrator collects data to the extent necessary to provide individual offered services, as well as information about the User's activity on the Service. The following describes the detailed rules and purposes of processing Personal Data collected during the User's use of the Service.

PURPOSES AND LEGAL BASES FOR DATA PROCESSING ON THE SERVICE

USE OF THE SERVICE

1. Personal Data of all persons using the Service (including IP address or other identifiers and information collected through cookies or other similar technologies) who are not registered Users (i.e., persons who do not have a profile on the Service) are processed by the Administrator:

1.1. to provide services electronically in the scope of making content collected on the Service available to Users – then the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) GDPR);

1.2. for analytical and statistical purposes – then the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) GDPR), consisting in conducting analyses of Users' activity and their preferences to improve the functionalities used and services provided;

1.3. for the purpose of possible establishment and pursuit of claims or defense against claims – the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) GDPR), consisting in the protection of its rights;

1.4. for marketing purposes of the Administrator and other entities, in particular related to the presentation of behavioral advertising – the rules for processing Personal Data for marketing purposes are described in the MARKETING section.

2. User activity on the Service, including their Personal Data, is recorded in system logs (a special computer program used to store a chronological record containing information about events and actions related to the IT system used to provide services by the Administrator). The information collected in the logs is processed primarily for purposes related to the provision of services. The Administrator also processes it for technical and administrative purposes, to ensure the security of the IT system and its management, as well as for analytical and statistical purposes – in this respect, the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) GDPR).

CONTACT FORMS

1. The Administrator provides the possibility to contact them using electronic contact forms. Using the form requires providing Personal Data necessary to establish contact with the User and respond to the inquiry. The User may also provide other data to facilitate contact or handle the inquiry. Providing data marked as mandatory is required to accept and handle the inquiry, and failure to provide them results in the inability to handle it. Providing other data is voluntary.

2. Personal Data are processed:

2.1. to identify the sender and handle their inquiry sent through the provided form – the legal basis for processing is the necessity of processing for the performance of the service contract (Article 6(1)(b) GDPR); for data provided optionally, the legal basis for processing is consent (Article 6(1)(a) GDPR);

2.2. for analytical and statistical purposes – the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) GDPR), consisting in conducting statistics of inquiries submitted by Users through the Service to improve its functionality.

MARKETING

1. The Administrator processes Users' Personal Data for the purpose of conducting marketing activities, which may consist of:

1.1. displaying marketing content to the User that is not tailored to their preferences (contextual advertising);

1.2. displaying marketing content to the User that matches their interests (behavioral advertising);

1.3. sending email notifications about interesting offers or content, which in some cases contain commercial information (newsletter service);

1.4. conducting other types of activities related to direct marketing of goods and services (sending commercial information by electronic means and telemarketing activities).

2. To conduct marketing activities, the Administrator in some cases uses profiling. This means that through automated data processing, the Administrator evaluates selected factors concerning Users to analyze their behavior or create a forecast for the future. This allows for better matching of displayed content to the User's individual preferences and interests.

CONTEXTUAL ADVERTISING

The Administrator processes Users' Personal Data for marketing purposes in connection with directing contextual advertising to Users (i.e., advertising that is not tailored to the User's preferences). The processing of Personal Data then takes place in connection with the implementation of the Administrator's legitimate interest (Article 6(1)(f) GDPR).

BEHAVIORAL ADVERTISING

The Administrator and its trusted partners process Users' Personal Data, including Personal Data collected through cookies and other similar technologies, for marketing purposes in connection with directing behavioral advertising to Users (i.e., advertising that is tailored to the User's preferences). The processing of Personal Data then also includes User profiling. The Administrator cooperates in this regard with PressToRead sp. z o.o. and DataRokcs sp. z o.o. sp. k.

NEWSLETTER

1. The Administrator provides a newsletter service on the terms specified in the regulations to persons who have provided their email address for this purpose. Providing data is required to provide the newsletter service, and failure to provide them results in the inability to send it. This form of communication with the User may include profiling.

2. Personal Data are processed:

2.1. to provide the newsletter sending service – the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) GDPR);

2.2. in the case of directing marketing content to the User as part of the newsletter – the legal basis for processing, including using profiling, is the legitimate interest of the Administrator (Article 6(1)(f) GDPR) in connection with the expressed consent to receive the newsletter;

2.3. for analytical and statistical purposes – the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) GDPR), consisting in conducting analyses of Users' activity on the Service to improve the functionalities used;

2.4. for the purpose of possible establishment and pursuit of claims or defense against claims – the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) GDPR), consisting in the protection of its rights.

DIRECT MARKETING

1. The User's Personal Data may also be used by the Administrator to direct marketing content to them through various channels, i.e., via email, MMS/SMS, or telephone. Such activities are undertaken by the Administrator only if the User has given their consent, which they can withdraw at any time.

2. The Administrator may in some cases also conduct direct marketing via traditional mail. The User will be separately informed about the intention to conduct this type of marketing. The User has the right to object to this type of marketing.

SOCIAL MEDIA

The Administrator processes Personal Data of Users visiting the Administrator's profiles maintained on social media (Facebook, YouTube, Instagram, Twitter). These data are processed only in connection with maintaining the profile, including informing Users about the Administrator's activity and promoting various events, services, and products. The legal basis for processing Personal Data by the Administrator for this purpose is its legitimate interest (Article 6(1)(f) GDPR), consisting in promoting its own brand.

COOKIES AND SIMILAR TECHNOLOGIES

Cookies are small text files installed on the device of the User browsing the Service. Cookies collect information that facilitates the use of the website – e.g., by remembering the User's visits to the Service and their activities. More information can be found in the Cookies Policy.

MANAGING COOKIE SETTINGS

1. The use of cookies to collect data through them, including access to data stored on the User's device, requires obtaining the User's consent. This consent can be withdrawn at any time.

2. Permission is not required only for cookies whose use is necessary to provide a telecommunications service (data transmission to display content).

3. Withdrawal of consent to the use of cookies is possible through browser settings. Detailed information on this topic can be found at the following links:

- Internet Explorer: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies
- Mozilla Firefox: http://support.mozilla.org/pl/kb/ciasteczka
- Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
- Opera: http://help.opera.com/Windows/12.10/pl/cookies.html
- Safari: https://support.apple.com/kb/PH5042?locale=en-GB

4. The User can at any time verify the status of their current privacy settings for the browser used by using the tools available at the following links:

- http://www.youronlinechoices.com/pl/twojewybory
- http://optout.aboutads.info/?c=2&lang=EN

5. More information about cookies can be found in the Cookies Policy.

USER RIGHTS

1. The User has the right to access the content of their data and request their rectification, deletion, restriction of processing, the right to data portability, and the right to object to data processing, as well as the right to lodge a complaint with a supervisory authority dealing with the protection of Personal Data.

2. To the extent that the User's data are processed on the basis of consent, this consent can be withdrawn at any time by contacting the Administrator.

3. The User has the right to object to the processing of data for marketing purposes if the processing takes place in connection with the legitimate interest of the Administrator, and also – for reasons related to the User's particular situation – in other cases where the legal basis for data processing is the legitimate interest of the Administrator (e.g., in connection with the implementation of analytical and statistical purposes), by sending a request to the email address: daneosobowe@truckcare.com.pl using the request form HERE.

DATA RECIPIENTS

1. In connection with the provision of services, Personal Data will be disclosed to external entities, including in particular suppliers responsible for the maintenance of IT systems, entities such as banks and payment operators, entities providing accounting services, couriers (in connection with order fulfillment), marketing agencies (in the scope of marketing services), and entities related to the Administrator, including companies from its capital group.

2. If the User's consent is obtained, their data may also be made available to other entities for their own purposes, including marketing purposes.

3. The Administrator reserves the right to disclose selected information about the User to the relevant authorities or third parties who request such information, based on an appropriate legal basis and in accordance with applicable law.

TRANSFER OF DATA OUTSIDE THE EEA

1. The level of Personal Data protection outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Administrator transfers Personal Data outside the EEA only when it is necessary and with an adequate level of protection, primarily through:

1.1. cooperation with entities processing Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the finding of an adequate level of Personal Data protection;

1.2. application of standard contractual clauses issued by the European Commission;

1.3. application of binding corporate rules approved by the relevant supervisory authority;

2. The Administrator always informs about the intention to transfer Personal Data outside the EEA at the stage of their collection.

CONTACT DETAILS

1. Contact with the Administrator is possible via the Contact page or correspondence address: 02-092 Warsaw, ul. Żwirki i Wigury 18a.

2. The Administrator has appointed a Data Protection Officer - Inga Wietrzycka, who can be contacted via email: iod@truckcare.com.pl in any matter concerning the processing of Personal Data.

CHANGES TO THE PRIVACY POLICY

1. The Policy is continuously reviewed and updated as needed.

2. The current version of the Policy was adopted and is effective from 20.12.2023.