PRIVACY POLICY PARENTEO

Please read this privacy policy carefully. The privacy policy defines the rules regarding the processing of personal data collected and processed when the User uses the
Parenteo Application .

• GENERAL PROVISIONS

1. This Application privacy policy is for informational purposes, which means that it does not constitute a source of obligations for the Application Service Users. The privacy policy primarily contains the rules regarding the processing of personal data by the Administrator in the Application, including the grounds, purposes and period of personal data processing and the rights of data subjects.

2. The administrator of personal data collected via the Application is PARENTEO SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with its registered office in Warsaw (registered office and delivery address: ul. Nowy Świat 33/13, 00-029 Warsaw), entered into the register of entrepreneurs of the National Court Register under the KRS number :0001075078; registry court where the company’s documentation is kept: District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register; share capital in the amount of: PLN 5,000.00; NIP 5252984694, REGON 527205524, e-mail address: kontakt@parenteo.pl – hereinafter referred to as the “ Administrator ” and is also the Service Provider of the Parenteo Application .

3. Personal data in the Application are processed by the Administrator in accordance with applicable law, in particular in accordance 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 freedom to flow of such data and repealing Directive 95/46/EC (General Data Protection Regulation) – hereinafter referred to as ” GDPR ” or ” GDPR Regulation „. The official text of the GDPR Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679 .

4. Using the Parenteo Application , including making purchases, is voluntary. Similarly, the provision of personal data by the Service User using the Parenteo Application is voluntary, subject to two exceptions: (1) concluding a contract – failure to provide, in the cases and to the extent indicated in the Parenteo Application and in the Regulations of the Parenteo Application and this privacy policy, personal data necessary to conclude agreements on the use of the Application or individual Electronic Services (e.g. Account registration, etc.) result in the Service User being unable to conclude the agreement and use the Application services. In such a case, providing personal data is a contractual requirement and if the data subject wants to use a given Electronic Service available in the Application, he or she is obliged to provide the required data. Each time, the scope of data required to use specific Application services is previously indicated in the Parenteo Application and in the Parenteo Application Regulations ; (2) statutory obligations of the Administrator – providing personal data is a statutory requirement resulting from generally applicable legal provisions imposing an obligation on the Administrator to process personal data (e.g. for the purpose of keeping accounting books) and failure to provide them will prevent the Administrator from performing these obligations.

5. The Administrator takes special care to protect the interests of persons whose personal data he processes, and in particular he is responsible and ensures that the data collected by him are: (1) processed in accordance with the law; (2) collected for specified lawful purposes and not subjected to further processing that is incompatible with those purposes; (3) substantively correct and adequate in relation to the purposes for which they are processed; (4) stored in a form enabling identification of data subjects for no longer than is necessary to achieve the purpose of processing, and (5) processed in a way that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organizational measures.

6. Taking into account the nature, scope, context and purposes of processing as well as the risk of violating the rights and freedoms of natural persons with varying probability and severity of threat, the Administrator implements appropriate technical and organizational measures to ensure that processing takes place in accordance with the GDPR Regulation and to be able to demonstrate this. These measures are reviewed and updated as necessary. The Administrator uses technical measures to prevent unauthorized persons from obtaining and modifying personal data sent electronically.

7. All words, expressions and acronyms appearing in this privacy policy and beginning with a capital letter (e.g. Electronic Service , User , Application ) should be understood in accordance with their definition contained in the Parenteo Application Regulations .

• BASIS OF DATA PROCESSING

1. The administrator is entitled to process personal data in cases where and to the extent that at least one of the following conditions is met: (1) the data subject has consented to the processing of his or her personal data for one or more specific purposes. ; (2) processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject before concluding the contract; (3) processing is necessary to fulfill the legal obligation imposed on the Administrator; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data , in particular when the data subject is a child.

2. The processing of personal data by the Administrator requires each time at least one of the grounds indicated in point. 2.1 privacy policy. The specific grounds for processing personal data of Parenteo Application Users by the Administrator are indicated in the next point of the privacy policy – in relation to the given purpose of processing personal data by the Administrator.

• PURPOSE, BASIS AND PERIOD OF DATA PROCESSING IN THE APPLICATION

1. Each time, the purpose, basis and period as well as the recipients of personal data processed by the Administrator result from the activities undertaken by a given Service Recipient in the Application.

2. The Administrator may process personal data in the Application for the following purposes, on the basis and
   during the periods indicated in the table below:

Purpose of data processing	Legal basis for data processing	Data storage period
Execution of the contract for the use of the Application and its Electronic Services or another contract or taking action at the request of the data subject before concluding the contract	Article 6(1) 1 letter b) GDPR Regulations (contract) – processing is necessary to perform the contract to which the data subject is a party or to take action at the request of the data subject before concluding the contract	The data is stored for the period necessary to perform, terminate or otherwise expire the concluded contract.
direct marketing	Article 6(1) 1 letter f) GDPR Regulations (legitimate interest of the administrator) – processing is necessary for purposes arising from the legitimate interests of the Administrator – consisting in taking care of the interests and good image of the Administrator and his Application	The data is stored for the duration of the legally justified interest pursued by the Administrator, but no longer than the period of limitation of the Administrator’s claims against the data subject in connection with the business activity conducted by the Administrator. The limitation period is determined by legal provisions, in particular the Civil Code (the basic limitation period for claims related to running a business is three years). The administrator may not process data for direct marketing purposes if the data subject expresses an effective objection in this regard.
Marketing (e.g. sending a newsletter)	Article 6(1) 1 letter a) GDPR Regulations (consent) – the data subject has consented to the processing of his or her personal data in order to receive marketing information from the Administrator	The data is stored until the data subject withdraws his or her consent to further processing of his or her data for this purpose.
Bookkeeping	Article 6(1) 1 letter c) GDPR Regulations (legal obligation) in connection with joke. 74 section 2 of the Accounting Act, i.e. of January 30, 2018 (Journal of Laws of 2018, item 395, as amended) – processing is necessary to fulfill the legal obligation imposed on the Administrator	The data is stored for the period required by law requiring the Administrator to store accounting books (5 years from the beginning of the year following the financial year to which the data relates).
Determining, pursuing or defending claims that may be raised by the Administrator or that may be raised against the Administrator	Article 6(1) 1 letter f) GDPR Regulations (legitimate interest of the administrator) – processing is necessary for the purposes arising from the legitimate interests of the Administrator – consisting in establishing, pursuing or defending claims that may be raised by the Administrator or that may be raised against the Administrator	The data is stored for the duration of the legally justified interest pursued by the Administrator, but no longer than the limitation period for claims that may be raised against the Administrator (the basic limitation period for claims against the Administrator is six years).
Using the Application and ensuring its proper operation	Article 6(1) 1 letter f) GDPR Regulations (legitimate interest of the administrator) – processing is necessary for the purposes arising from the legitimate interests of the Administrator – consisting in running and maintaining the Application	The data is stored for the duration of the legally justified interest pursued by the Administrator, but no longer than the period of limitation of the Administrator’s claims against the data subject in connection with the business activity conducted by the Administrator. The limitation period is determined by legal provisions, in particular the Civil Code (the basic limitation period for claims related to running a business is three years).
Keeping statistics and analyzing traffic in the Application	Article 6(1) 1 letter f) GDPR Regulations (legitimate interest of the administrator) – processing is necessary for the purposes arising from the legitimate interests of the Administrator – consisting in keeping statistics and analyzing traffic in the Application in order to improve the functioning of the Application	The data is stored for the duration of the legally justified interest pursued by the Administrator, but no longer than the period of limitation of the Administrator’s claims against the data subject in connection with the business activity conducted by the Administrator. The limitation period is determined by legal provisions, in particular the Civil Code (the basic limitation period for claims related to running a business is three years).

• RECIPIENTS OF DATA IN THE APPLICATION

1. For the proper functioning of the Parenteo Application , including the provision of Electronic Services, it is necessary for the Administrator to use the services of external entities (such as e.g. software supplier, payment processor). The Administrator only uses the services of such processing entities that provide sufficient guarantees of implementing appropriate technical and organizational measures so that the processing meets the requirements of the GDPR and protects the rights of data subjects.

2. Personal data may be transferred by the Administrator to a third country, and the Administrator ensures that in such a case it will be in accordance with the GDPR Regulation in relation to a country ensuring an adequate level of protection, and in the case of other countries – on the basis of standard data protection clauses, and the data subject has the opportunity to obtain a copy of his or her data. The Administrator transfers the collected personal data only in the case and to the extent necessary to achieve the given purpose of data processing in accordance with this privacy policy.

3. Data is not transferred by the Administrator in every case and not to all recipients or categories of recipients indicated in the privacy policy – the Administrator transfers data only when it is necessary to achieve a given purpose of personal data processing and only to the extent necessary to achieve it.

4. Personal data of Parenteo Application Service Recipients may be transferred to the following recipients or categories of recipients:

   1. entities handling electronic or payment card payments – in the case of a Service Recipient who purchases paid services in the Application (e.g. Subscription) and uses electronic or payment card payments for this purpose, the Administrator makes the collected personal data of the Service Recipient available to the selected entity handling the above payments in the Application on the Administrator’s order to the extent necessary to process payments made by the Service Recipient.

   2. providers of accounting, legal and advisory services providing the Administrator with accounting, legal or advisory support (in particular an accounting office, law firm or debt collection company) – the Administrator provides the User’s collected personal data to a selected supplier acting on its behalf only in the case and to the extent necessary to complete a given task. the purpose of data processing in accordance with this privacy policy.

   3. service providers supplying the Administrator with technical, IT and organizational solutions enabling the Administrator to run and maintain the Application and the provision of Electronic Services (in particular the supplier of computer software for running the Parenteo Application , the e-mail and hosting provider and the supplier of software for managing the company and providing technical assistance to the Administrator) – the Administrator makes the collected personal data of the User available to the selected supplier acting on its behalf only in the case and in to the extent necessary to achieve the given purpose of data processing in accordance with this privacy policy.

   4. providers of social plug-ins, scripts and other similar tools placed in the Application, enabling the Application to download content from the providers of the mentioned plug-ins (e.g. logging in using login details to a social networking site) and transmitting the visitor’s personal data to these providers , including:

1. MetaPlatforms​ Ireland Ltd. – The Administrator may use Facebook social plug-ins in the Application (e.g. logging in using Facebook login details) and therefore collects and shares personal data of the Service User using the Application to Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy principles available here: https://www.facebook.com/about/privacy/ (this data includes information about activities in the Application – including information about your device, websites visited, purchases, advertisements displayed and how you use services).

2. Google Ireland Ltd. – The Administrator may use Google plug-ins in the Application (e.g. logging in using Google login details) and therefore collects and shares personal data of the Service User using the Application to Google Ireland Ltd. (Gordon House, Barrow Street , Dublin 4, Ireland) to the extent and in accordance with the privacy principles available here: https://policies.google.com/privacy?hl=pl (this data includes information about activities in the Application – including information about the device, websites visited, purchases, displayed advertisements and how you use the services).

3. Apple Distribution International Ltd. – The Administrator may use the Apple plug-in in the Application to log in using an Apple ID account and therefore collects and shares personal data of the Service User using the Application to Apple Distribution International Ltd. ( Hollyhill Industrial Estate Hollyhill , Cork, Ireland) to the extent and in accordance with the privacy principles available here: https://www.apple.com/pl/legal/privacy/pl/ (this data includes information about activities in the Application – including information about the device, websites visited, purchases, advertisements displayed and how services are used).

• PROFILING IN THE APPLICATION

1. The GDPR requires the Administrator to provide information about automated decision-making, including profiling, as referred to in Art. 22 section 1 and 4 of the GDPR, and – at least in these cases – important information about the principles of their implementation, as well as the importance and expected consequences of such processing for the data subject. With this in mind, the Administrator provides information regarding possible profiling in this point of the privacy policy.

2. The Administrator may use profiling in the Application for direct marketing purposes, but decisions made on its basis by the Administrator do not concern the conclusion or refusal to conclude a contract (e.g. regarding the activation of the Subscription) or the possibility of using Electronic Services in the Application. The effect of using profiling may be, for example, reminding a given person about unfinished activities in the Application, granting a discount, sending an offer that may correspond to the interests or preferences of a given person or offering better conditions compared to the standard offer of the Application. Despite profiling, a given person can freely decide whether he or she wants to take advantage of, for example, a discount or offer obtained in this way.

3. Profiling in the Application involves the automatic analysis or forecast of a given person’s behavior within the Parenteo Application , e.g. by analyzing the previous history of activities or purchases in the Application. The condition for such profiling is that the Administrator has the personal data of a given person in order to be able to send him, for example, an offer or a discount.

4. The data subject has the right not to be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects concerning him or her or similarly significantly affects him or her.

• RIGHTS OF THE DATA SUBJECT

1. The right of access, rectification, restriction, deletion or transfer – the data subject has the right to request from the Administrator access to his or her personal data, rectification, deletion („right to be forgotten”) or limitation of processing and the right to object to processing, and also has the right to transfer his data. Detailed conditions for exercising the above-mentioned rights are indicated in Art. 15-21 of the GDPR Regulations.

2. The right to withdraw consent at any time – a person whose data is processed by the Administrator on the basis of consent (pursuant to Article 6(1)(a) or Art. 9 section 2 letter a) of the GDPR), has the right to withdraw consent at any time without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal.

3. The right to lodge a complaint with the supervisory authority – the person whose data is processed by the Administrator has the right to lodge a complaint with the supervisory authority in the manner and manner specified in the provisions of the GDPR Regulation and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Personal Data Protection Office.

4. The right to object – the data subject has the right to object at any time – for reasons related to his or her particular situation – to the processing of his or her personal data based on Art. 6 section 1 letter e) (public interest or tasks) or f) (legitimate interest of the administrator), including profiling based on these provisions. In such a case, the Administrator is no longer allowed to process this personal data, unless he demonstrates the existence of valid legally justified grounds for processing, overriding the interests, rights and freedoms of the data subject, or grounds for establishing, pursuing or defending claims.

5. The right to object to direct marketing – if personal data are processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of his or her personal data for the purposes of such marketing, including profiling, to the extent that what processing is related to such direct marketing.

6. In order to exercise the rights referred to in this point of the privacy policy, you can contact the Administrator by sending an appropriate message in writing or by e-mail to the Administrator’s address indicated at the beginning of the privacy policy.

• COOKIES AND ANALYTICS

1. 1. Cookies are small text information in the form of text files, sent by the server and saved on the side of the person visiting the website of the Application in the browser version (e.g. on the hard drive of a computer, laptop or on the memory card of a smartphone – depending on what device the visitor to the Application uses). Detailed information on cookies, as well as the history of their creation, can be found, among others, at: here: https://pl.wikipedia.org/wiki/HTTP_cookie .

   2. Cookies that may be sent by the Application website can be divided into different types, according to the following criteria :

Due to their supplier : own (created by the Administrator’s Application website) and belonging to third parties/entities (other than the Administrator)

Due to their storage period on the device of the person visiting the Application website : session cookies (stored until you leave the Application website or turn off your web browser) and permanent (stored for a specified period of time, defined by the parameters of each file, or until manually deleted)

Due to the purpose of their use : necessary (enabling the proper functioning of the Application website), functional/preferential (enabling the adaptation of the Application page to the preferences of the person visiting the website), analytical and performance (collecting information about how the Application website is used), marketing, advertising and social media (collecting information about a person visiting the Application website in order to display advertisements to that person, personalize them and conduct other marketing activities, including on websites separate from the Application website, such as social networking sites or other websites belonging to the same network advertising every Application)

1. The Administrator may process data contained in Cookies when visitors use the Application website for the following specific purposes:

Purposes of using cookies in the Administrator’s Application	Identification of Service Users as logged in to the Application and showing that they are logged in (necessary cookies)
	remembering data from completed forms or surveys (necessary and/or functional/preferential cookies)
	adapting the website content to the individual preferences of Service Users (e.g. regarding colors, font size, page layout) and optimizing the use of the Application pages (functional/preference cookies)
	keeping anonymous statistics showing how the Application website is used (analytical and performance cookies)
	displaying and rendering ads, limiting the number of ad views and ignoring ads that a given person does not want to see, measuring the effectiveness of ads, as well as personalizing ads, i.e. examining the behavioral characteristics of people visiting the Application through anonymous analysis of their activities (e.g. repeated visits to specific pages, keywords, etc.) in order to create their profile and provide them with advertisements tailored to their expected interests, also when they visit other websites in the advertising network of Google Ireland Ltd. (marketing, advertising and social cookies)

1. It is possible to check which Cookies are currently being sent by the Application website, regardless of the web browser, e.g. using the tools available at: https://www.cookiemetrix.pl or https://www.cookie-checker. com .

2. By default, most web browsers available on the market accept cookies. Everyone can define the conditions for the use of cookies using the settings of their own web browser. This means that you can, for example, partially limit (e.g. temporarily) or completely disable the possibility of saving Cookies – in the latter case, however, it may affect some functionalities of the Application.

3. Internet browser settings regarding Cookies are important from the point of view of consent to the use of Cookies by the Application website – in accordance with the regulations, such consent may also be expressed through the Internet browser settings. Detailed information on changing Cookie settings and deleting them yourself in the most popular web browsers is available in the browser’s help section and on the following websites (just click on the link):

in the Chrome browser 

in Firefox

in Internet Explorer 

in the Opera browser 

in Safari browser

in Microsoft Edge browser

1. AdMob services in the Application and Firebase Crashlytics provided by Google Ireland Limited (Gordon House, Barrow Street , Dublin 4, Ireland) . These services help the Administrator keep statistics, analyze traffic and monitor errors in the operation of the Application. The collected data is processed as part of the above services to generate statistics helpful in administering the Application, analyzing traffic in the Application or improving the quality of service and safety of people using the Application. This data is aggregated. Using the above services in the Application, the Administrator collects data such as the sources and medium of obtaining visitors to the Application and their behavior in the Application, information about the devices from which they visit the Application, IP address, geographical data and demographic data (age, gender) and interests.

2. Due to the possibility for the Administrator to use analytical and advertising services provided by Google Ireland Ltd. in the Application, the Administrator indicates that full information on the principles of processing data of persons visiting the Application by Google Ireland Ltd. (including data saved in Cookies) can be found in in the privacy policy of Google services at the following address: https://policies.google.com/technologies/partner-sites .

• FINAL PROVISIONS

The Application may contain links to other websites or applications. The Administrator encourages you to read the privacy policy established there after going to other websites. This privacy policy applies only to the Administrator Application.