Privacy policy - Tofu Media

PRIVACY POLICY

GENERAL PROVISIONS
1. This privacy policy (“Privacy Policy”) defines the method of processing and securing personal data of users of the Internet website (“User”) available at the address [tofumedia.pl] (Website”), collected and processed in connection with the use of the Website, including the so called cookie files.
2. This Privacy Policy was adopted by the company Tofu Media Polska sp. z o.o. with its registered seat in Warsaw (address: Marszałkowska 18/3, 00-509 Warsaw, Poland), registered in the register of entrepreneurs of the National Court Register conducted by the District Court for the capital city of Warsaw in Warsaw, XII Commercial Department of the National Court Register under KRS no. 0000766069, Tax Identification Number (NIP): 6793179102, Business Registration Number (REGON): 382315070, with share capital in the amount of PLN 40.000,00, being the owner of the Website („ Website Owner”).
3. The Website Owner respects the privacy of the Website Users and assures that it is committed to respect the applicable law in the field of personal data protection.
4. The main purpose of this Privacy Policy is to ensure privacy security for the Website Users at a level at least equivalent to the standards set out in the applicable law, in particular (i) in the Regulation of the European Parliament and Council (EU) 2016/679 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 (“RODO” / “GDPR”), and (ii) in the Act of 18 July 2002 on electronic services (“Act”) and (iii) in the Act of 16 July 2004 on telecommunications law (“Telecommunications Law”).
5. The Website may contain links allowing the User to access directly websites other than the Website. With regard to such websites, the Website Owner reserves that it is not responsible for the privacy policy applied by the administrators of these websites.
6. The method and scope of collecting other data and information, not related to technical aspects of the Website’s operation, will be determined by separate arrangements – correspondingly to their purpose and will be published in the relevant form.
PROCESSING OF PERSONAL DATA
1. The administrator of personal data of the Website, collected and processed in connection with the use of the Website and in connection with the operation and functioning of the Website is the Website Owner, i.e. the company Tofu Media Polska sp. z o.o. with its registered seat in Warsaw (address: Marszałkowska 18/3, 00-509 Warsaw, Poland), registered in the register of entrepreneurs of the National Court Register conducted by the District Court for the capital city of Warsaw in Warsaw, XII Commercial Department of the National Court Register under KRS no. 0000766069, Tax Identification Number (NIP): 6793179102, Business Registration Number (REGON): 382315070, with share capital in the amount of PLN 40.000,00.
2. The personal data of the Users will be processed by the Website Owner for the following purposes only:
  1. for the purposes related to the application of functionalities of the Website, related to the use of the Website, and for the proper administration of the Website, including generation of relevant statistics. The personal data of the Website Users will be processed by the Website Owner pursuant to Art. 6 par. 1, letter f) of GDPR, i.e. for a legally justified purpose which shall be understood as technical access to the Website and monitoring its operation, optimization and adaptation of the Website’s functionalities to the needs and requirements of the Users and for the purpose of providing the Users with the possibility of using other interactive functions of the Website;
  2. for the purpose of providing the Website Users with access to dedicated e-mail addresses on the Website, pursuant to Art. 6 par. 1 letter f) of GDPR, for a legally justified purpose, which shall be understood as acceptance of an inquiry sent to the e-mail address provided on the Website (in particular in order to contact with the User in the event of submitting an offer of cooperation as part of the Website Owner’s business activity and management by the Website Owner of complaints about the Website’s operation) and responding to such an enquiry
  3. for marketing purposes, subject to a separate consent granted pursuant to Art. 6 par. 1 letter. a) or Art. 9 par. 2 letter a) of GDPR, including commercial information about the Website Owner’s activities sent by e-mail to the e-mail address or telephone number provided in the relevant form (“Newsletter”), provided that the User has expressed its consent to subscribe to the Newsletter and has agreed to the processing of his/her personal data for this purpose.
3. Personal data processed by the Website Owner do not include specific categories of personal data within the meaning of Art. 9 par. 1 of GDPR or data on convictions and violations of law within the meaning of Art. 10 of GDPR.
4. Personal data may be disclosed to:
  1. any entity from the capital group to which the Website Owner belongs,
  2. entities cooperating with the Website Owner in relations to the business activity conducted by the Website Owner,
  3. entities cooperating with the Website Owner in relation to: (i) activities undertaken on social networking websites and the use of plugins and other tools derived from these websites, (ii) the use of analytical tools and anonymized tracking of Users’ behavior, (iii) the use of advertising platforms for obtaining funds for the maintenance of websites, and
  4. other entities cooperating with the Website Owner, in order to ensure the proper operation of the Website, in accordance with the data processing agreements, in particular entities providing hosting services to the Website and services relating to provision and maintenance of the Website.
5. Personal data may be transferred to a third country, but the Website Owner will always ensure that Users’ personal data is transferred only to a third country for which the European Commission has made a decision stating that that country provides an adequate level of protection of personal data.
6. Personal data will be processed for a period not longer than it is necessary to achieve the purposes for which personal data was collected or until the date of withdrawal of consent to the processing of personal data in connection with sending the Newsletter or for the period required by law.
7. A data subject has the right to access their data and rectify, delete, restrict its processing, the right to transfer data or object to their processing, the right to withdraw consent at any time without affecting the legality of the data processing, performed on the basis of the subject’s consent before its withdrawal. A data subject has the right to complaint to the President of the Office for Personal Data Protection, if the processing of his/her personal data is contrary to the provisions of generally applicable law.
8. The Website Owner processes personal data in an automated manner, in particular in connection with (i) activities undertaken on social networking sites and the use of plugins and other tools from these websites, (ii) the use of analytical tools and anonymous tracking of Users’ behavior, (iii) the use of platforms advertising used to raise funds for maintaining websites.
9. The Website Owner makes every effort to protect the processing of personal data against any misuse, interference, loss, unauthorized access, modification or disclosure.
COOKIE FILES
1. Cookie files (so-called “cookies”) are IT data, in particular text files, which are stored in the equipment of the Website User and are related to the use of the Website. Cookie files usually contain the name of the website they originate from, their storage time on the User’s device and a unique number.
2. The entity that uploads cookie files on the Website User’s device and that obtains access to them is the Website Owner.
3. Cookie files are used for the purpose of:
  1. optimization and adaptation of the Website’s functionalities to the needs and requirements of the Users, in particular cookie files allow to recognize the User’s device and properly display the Website on the User’s device in a manner tailored to the User’s individual needs;
  2. generating relevant statistics on the use of the Website by the Users.
4. There are two types of cookie files that may be used for the Website’s operation:
  1. session cookies which are temporary files stored in the User’s device until the User loggs out, leaves the website or turns off the software (web browser), and
  2. persistent cookies that are stored on the User’s device for a period specified in the cookie files parameters or until they are deleted by the User.
5. The following types of cookies may be used as part of the Website’s operation:
  1. “necessary” cookie files, enabling the use of services available on the Website, e.g. authentication cookies used for services that require authentication on the Website;
  2. “security” cookie files used to ensure security, e.g. used to detect fraud related to authentication on the Website;
  3. “performance” cookies, enabling the collection of information on the use of the Website’s websites;
  4. “functional” cookies, enabling the “remembering” of the settings selected by the User and personalizing the User’s interface, e.g. in the scope of the selected language or region of the User’s origin, font size, website appearance, etc.
6. The software used to browse websites may, by default, allow the storage of cookies on the User’s device. The Website User may change the settings for cookies at any time. These settings can be changed in particular in such a way as to block the automatic management of cookies in the settings of the web browser or inform every time they are uploaded on the User’s device. Detailed information about the possibilities and ways of managing the cookie files are available in the settings of the web browser software.
7. Restrictions on the use of cookie files may affect some of the functionalities available on the Website.
8. Cookie files uploaded on the User’s end device may also be used by advertisers and other partners cooperating with the Website Owner.
USE OF SOCIAL NETWORK PLUGINS
1. The Website may contain integrated plugins for Facebook.com social networking site (“Facebook”) provided by the company Facebook Inc. (address: 1601 S. California Ave, Palo Alto, CA 94304, USA). Facebook plugins can be recognized by the dedicated Facebook logo on the Website, which is a hyperlink to the Website Owner’s fanpage on Facebook. Active pressing of the plugin, which is a hyperlink to the Website Owner’s fanpage on Facebook, will cause that a direct connection will be established between the User’s web browser installed on the User’s device and the Facebook server, and the Website Owner’s fanpage on Facebook will be displayed in the User’s web browser. As a result of such a redirection, the Website Owner does not collect or process the User’s personal data and the entity collecting and processing personal data will be the Facebook provider, in accordance with its privacy policy.
2. The Website may contain integrated plugins for the social networking site Instagram.com (“Instagram”), whose provider is Instagram LLC (address: 1601 Willow Road, Menlo Park, CA 94025, USA). Instagram plugins can be recognized by the dedicated Instagram logo on the Website, which is a hyperlink to the Website Owner’s fanpage on Instagram. Active pressing of the plugin, which is a hyperlink to the Website Owner’s fanpage on Instagram, will cause than a direct connection will be established between the User’s web browser installed on the User’s device and the Facebook server, and the Website Owner’s fanpage on Instagram will be displayed in the User’s web browser. As a result of such a redirection, the Website Owner does not collect or process the User’s personal data and the entity collecting and processing personal data will be the Instagram provider, in accordance with its privacy policy.
3. It is possible to embed on the Website films using the embed code of a given film placed on the Website Owner’s channel on You Tube (“You Tube”), whose provider is the company YouTube LLC (address: 901 Cherry Avenue, San Bruno, CA 94066, USA). Due to the above, in some of the Website’s tabs (e.g. in the Website’s multimedia library) it is possible to embed and use dedicated You Tube plugins (using embed code), which are a hyperlink to the videos placed on the Website Owner’s channel on YouTube. Active pressing of the dedicated plugin button, which is a command to play the film embedded in the appropriate tab of the Website, will cause than a direct connection will be established between the User’s web browser installed on the User’s device and the You Tube server. As a result of such a connection, the Website Owner does not collect or process the User’s personal data and the entity collecting and processing personal data will be the You Tube provider, in accordance with its privacy policy.
4. It is possible to embed on the Website films using the embed code of a given film placed on the Website Owner’s channel on Vimeo (“Vimeo”), whose provider is the company Vimeo LLC (address: 555 West 18th Street New York, NY 1001, USA). Due to the above, in some of the Website’s tabs (e.g. in the Website’s multimedia library) it is possible to embed and use dedicated Vimeo plugins (using embed code), which are a hyperlink to the videos placed on the Website Owner’s channel on Vimeo. Active pressing of the dedicated plugin button, which is a command to play the film embedded in the appropriate tab of the Website, will cause than a direct connection will be established between the User’s web browser installed on the User’s device and the Vimeo server. As a result of such a connection, the Website Owner does not collect or process the User’s personal data and the entity collecting and processing personal data will be the Vimeo provider, in accordance with its privacy policy.
CHANGES TO THE PRIVACY POLICY
1. The Website owner undertakes to review this Privacy Policy on a regular basis and change it when it proves necessary or advisable due to: new legal regulations, new guidelines from authorities responsible for supervising the processes of personal data protection, best practices applied in the area personal data security.
2. The Website Owner also reserves the right to change this Privacy Policy if there are any changes in technology, used to process personal data, and if there are changes to methods, purposes or legal grounds for processing of personal data by the Website Owner.
3. The revised Privacy Policy enters into force upon its publication on the Website.
CONTACT
1. We invite you to submit questions, comments and proposals regarding this privacy policy. Please send them in electronic form to the following e-mail address: RODO@tofumedia.pl.