Privacy Policy

The following Privacy Policy sets out the rules for recording and accessing data on Users' Devices using the Service for the purpose of providing electronic services by the Administrator and the rules for collecting and processing personal data of Users, which were provided by them personally and voluntarily through tools available in the Service.

§1 Definitions

  • Service - the internet service "Malatti" operating at https://malatti.com/
  • External Service - internet services of partners, service providers, or service recipients cooperating with the Administrator
  • Service / Data Administrator - The Administrator of the Service and Data Administrator (hereafter referred to as the Administrator) is AGTU Agnieszka Adamska, conducting business at: 00-732 Warsaw, ul. Czerska 18/172, with a tax identification number (NIP): 669-227-82-68, providing electronic services through the Service
  • User - a natural person for whom the Administrator provides electronic services via the Service.
  • Device - an electronic device along with software, through which the User gains access to the Service
  • Cookies - text data collected in the form of files placed on the User's Device
  • 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 (General Data Protection Regulation)
  • Personal data - means information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
  • Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • Restriction of processing - means marking stored personal data to limit their processing in the future
  • Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements
  • Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
  • Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
  • Pseudonymisation - means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
  • Anonymisation - Data anonymization is an irreversible process of data operation that destroys/overwrites "personal data" preventing identification or linking of a given record with a specific user or natural person.

§2 Data Protection Officer

According to Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

For matters related to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

  • Internal Cookies - files placed and read from the User's Device by the Service's IT system
  • External Cookies - files placed and read from the User's Device by IT systems of External Services. Scripts of External Services that may place Cookies on the User's Device have been deliberately placed in the Service through scripts and services made available and installed in the Service
  • Session Cookies - files placed and read from the User's Device by the Service during one session of a given Device. After the session ends, the files are removed from the User's Device.
  • Persistent Cookies - files placed and read from the User's Device by the Service until they are manually deleted. Files are not deleted automatically after the Device session ends unless the User's Device configuration is set to delete Cookie files after the Device session ends.

§4 Data storage security

  • Cookie storage and reading mechanisms - Storage, reading, and exchange of data between Cookies stored on the User's Device and the Service are carried out via built-in Internet browser mechanisms and do not allow for downloading other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojan horses, and other worms to the User's Device is also practically impossible.
  • Internal Cookies - Cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content, or information that may threaten the security of personal data or the security of the device used by the User.
  • External Cookies - The Administrator makes every possible effort to verify and select service partners in terms of User security. The Administrator chooses known, large partners with global social trust for cooperation. However, he does not have full control over the content of Cookies coming from external partners. The Administrator is not responsible for the security of these Cookies, their content, and their licensed use by the Scripts installed in the service coming from External Services, as far as the law allows. The list of partners is included in the further part of the Privacy Policy.
  • Cookie control
    • The User may at any time independently change the settings regarding the saving, deleting, and access to data stored by Cookies by each website.
    • Information on how to disable Cookies in the most popular computer browsers is available on the page: how to disable cookies or at one of the indicated providers:
      • Managing cookies in Chrome browser
      • Managing cookies in the Opera browser
      • Managing cookies in the FireFox browser
      • Managing cookies in the Edge browser
      • Managing cookies in the Safari browser
      • Managing cookies in the Internet Explorer 11 browser
    • The User may at any time delete any Cookies stored so far using the User's Device tools, through which the User uses the Service's services.
  • Threats on the User's side - The Administrator applies all possible technical measures to ensure the security of the data placed in Cookies. However, ensuring the security of this data depends on both parties, including the User's activity. The Administrator is not responsible for intercepting these data, impersonating the User's session, or their deletion, as a result of the User's conscious or unconscious activity, viruses, Trojan horses, and other spyware that may be or have been infected on the User's Device.
  • Storing personal data - The Administrator ensures that it makes every effort to ensure that the processed personal data voluntarily entered by Users are secure, access to them is limited and carried out in accordance with their intended use and processing purposes. The Administrator also ensures that it makes every effort to protect the data it possesses from loss, using appropriate physical and organizational safeguards.

§5 Purposes for which Cookies are used

  • Improvement and facilitation of access to the Service
  • Personalization of the Service for Users
  • Marketing, Remarketing on external services
  • Conducting statistics (users, number of visits, types of devices, link, etc.)
  • Providing social services

§6 Purposes of processing personal data

Personal data voluntarily provided by Users are processed for one of the following purposes:

  • Execution of electronic services:
  • Communication of the Administrator with Users on matters related to the Service and data protection
  • Ensuring the legally justified interest of the Administrator

Data on Users collected anonymously and automatically are processed for one of the following purposes:

  • Conducting statistics
  • Remarketing
  • Ensuring the legally justified interest of the Administrator

§7 Cookies of External Services

The Administrator in the Service uses javascript scripts and web components of partners who may place their own cookies on the User's Device. Remember that in your browser settings you can independently decide about the allowed cookies that can be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

  • Conducting statistics:
    • We use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
      More information on data processing within the Google Analytics service can be found here: https://support.google.com/analytics/answer/6004245
  • Marketing activities
    • For marketing activities, we use the Google Ads advertising program operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA.
      More information on data processing within the Google Ads service can be found here: https://policies.google.com/privacy
  • Other services:
    Google Maps

Services provided by third parties are beyond the control of the Administrator. These entities may at any time change their terms of service, privacy policies, purpose of data processing, and methods of using cookies.

§8 Types of collected data

The Service collects data about Users. Some data is collected automatically and anonymously, and some data are personal data voluntarily provided by Users while signing up for individual services offered by the Service.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Opened subpages of the service
  • Time spent on the relevant subpage of the service
  • Type of operating system
  • Address of the previous subpage
  • Referrer page address
  • Browser language
  • Internet connection speed
  • Internet service provider
  • Demographic data (age, gender)

Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to a statistical service provider.

§9 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or resold to third parties.

Access to data (most often based on a Data Processing Entrustment Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the service, such as:

  • Hosting companies providing hosting services or related services to the Administrator
  • Service and IT support companies performing maintenance or responsible for maintaining IT infrastructure

Data Processing Entrustment - Hosting, VPS or Dedicated Server Services

The Administrator, in order to run the service, uses the services of an external hosting provider, VPS, or Dedicated Servers - webd.pl All data collected and processed in the service are stored and processed in the provider's infrastructure located within the European Union. There is a possibility of access to data as a result of service works carried out by the provider's personnel. Access to these data is regulated by an agreement between the Administrator and the Service Provider.

§10 Method of processing personal data

Personal data voluntarily provided by Users:

  • Personal data will not be transferred outside the European Union unless they have been published as a result of individual action by the User (e.g., entering a comment or post), which will make the data available to every person visiting the service.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) will be transferred outside the European Union.
  • Anonymous data (without personal data) may be used for automated decision-making (profiling).
    Profiling of anonymous data (without personal data) does not have legal effects or similarly significantly affects the person whose data is subject to automated decision-making.
  • Anonymous data (without personal data) will not be resold to third parties.

§11 Legal bases for processing personal data

The Service collects and processes Users' data based on:

  • 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)
    • Article 6(1)(a)
      the data subject has consented to the processing of his or her personal data for one or more specific purposes
    • Article 6(1)(b)
      processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
    • Article 6(1)(f)
      processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
  • Act of 10 May 2018 on personal data protection (Journal of Laws 2018, item 1000)
  • Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No 171, item 1800)
  • Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No 24, item 83)

§12 Period of processing personal data

Personal data provided voluntarily by Users:

As a rule, the indicated personal data are stored only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized within 30 days from the end of the provision of services (e.g., deleting a registered user account, unsubscribing from the Newsletter list, etc.)

The exception is a situation that requires securing the legally justified purposes of further processing of these data by the Administrator. In such a case, the Administrator will store the indicated data, from the time of requesting their deletion by the User, no longer than for a period of 3 years in the case of violation or suspicion of violation of the service regulations by the User

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, are stored by the Administrator for the purpose of conducting site statistics for an indefinite period.

§13 User rights related to the processing of personal data

The Service collects and processes Users' data based on:

  • The right to access personal data
    Users have the right to access their personal data, implemented at the request submitted to the Administrator
  • The right to rectify personal data
    Users have the right to request the Administrator to immediately rectify incorrect personal data or / and to complete incomplete personal data, implemented at the request submitted to the Administrator
  • The right to delete personal data
    Users have the right to request the Administrator to immediately delete personal data, implemented at the request submitted to the Administrator In the case of user accounts, deletion of data involves the anonymization of data enabling the identification of the User. The Administrator reserves the right to suspend the execution of the data deletion request in order to protect the legally justified interest of the Administrator (e.g., when the User has committed a breach of the Regulations or data were obtained as a result of the conducted correspondence).
  • The right to restrict the processing of personal data
    Users have the right to restrict the processing of personal data in the cases indicated in Art. 18 of the GDPR, including questioning the accuracy of personal data, implemented at the request submitted to the Administrator
  • The right to data portability
    Users have the right to receive from the Administrator personal data concerning the User in a structured, commonly used, machine-readable format, implemented at the request submitted to the Administrator
  • The right to object to the processing of personal data
    Users have the right to object to the processing of their personal data in the cases specified in Art. 21 of the GDPR, implemented at the request submitted to the Administrator
  • The right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority dealing with the protection of personal data.

§14 Contact with the Administrator

You can contact the Administrator in one of the following ways

Postal address – 03-294 Warsaw, ul. Zielone Zacisze 1/395
Email address – malatti@malatti.com

§15 Service Requirements

  • Restricting the saving and access to Cookies on the User's Device may cause incorrect functioning of some functions of the Service.
  • The Administrator bears no responsibility for improperly functioning functions of the Service in case the User restricts in any way the ability to save and read Cookie files.

§16 External links

In the Service - articles, posts, entries, or comments of Users may contain links to external websites, with which the Service owner does not cooperate. These links and the pages or files indicated under them may be dangerous for your Device or pose a security threat to your data. The Administrator is not responsible for the content located outside the Service.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to change this Privacy Policy at any time without the need to inform Users regarding the use and utilization of anonymous data or the use of Cookies.
  • The Administrator reserves the right to change this Privacy Policy regarding the processing of Personal Data, about which it will inform Users with user accounts or subscribed to the newsletter service via email within 7 days from the change of provisions. Further use of the services means getting acquainted and accepting the introduced changes to the Privacy Policy. In the case where the User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
  • Introduced changes to the Privacy Policy will be published on this subpage of the Service.
  • Introduced changes take effect at the moment of their publication.