Website Privacy Policy

Noctiluca S.A (“Company”, “we” or “our”), based in Toruń, POLAND, Jurija Gagarina 7/41B, e-mail: sales@noctiluca.eu is the data controller in relation to the processing of your personal data as a website visitor at: www.noctiluca.eu (“Website”) or corresponding with us by telephone, email or otherwise.

In this policy, we inform you how we obtain, process and share the personal data that we store. Personal data means any information that can be used to identify an individual.

It is important to us that you feel safe with how we handle your personal data. We take measures to ensure that your personal data is protected and that the processing of your personal data is carried out in accordance with applicable data protection regulations and our internal policies and procedures.

FROM WHERE DO WE COLLECT YOUR PERSONAL DATA?

We may collect your personal data in the following ways:

• Personal data that you give to us by way of filling in forms on our Website or corresponding with us (contact details).

• Personal data that we collect or generate automatically, e.g. when you visit our Website, we will automatically collect personal data about you and your visit, including the internet protocol (IP) address used to connect your device to the internet and some other information such as your browser type and version, information about your device’s interaction with the website, including the pages you accessed and the links you clicked. Furthermore, our Website may also download cookies to your device.

WHEN AND WHY WE PROCESS YOUR PERSONAL DATA?

We process your personal data for the following purposes:

1) Answer your questions and handle feedback
Our Website provides functionality for the visitor to communicate with us by asking questions and provide feedback regarding our services and business. If you choose to contact us, we will process your personal data for the purposes of answering your questions and handling feedback from you.

2) Communicate business related information
If you sign up to subscribe newsletters, catalogues, press releases or similar information regarding the Company and its business, we will process your personal data for the purposes of providing the requested subscription or information to you. Scope of data may contain: identity details, contact details, professional information.

Where the communication is provided to you in your professional capacity or where the communication may be regarded as electronic direct marketing, the processing is necessary in order to fulfil our legitimate interest of providing you with the information you have requested.

Consent. Where the communication provided to you covers marketing information of our business partners, the processing is necessary in order to provide you with the subscription and information you have requested as well as to promote our brand and products to you.

Additionally, we may collect consent for electronic marketing in accordance with local law requirements. In such case, you may, at any time, withdraw your consent or object to the use of your data for electronic direct marketing, after which we will no longer process your data.

Your personal data is stored for this purpose until you unsubscribe from the information requested. After you have unsubscribed from communication from us, we will erase personal data processed for this purpose.

3) Evaluate the use and follow up on the use of our Website
In order to evaluate and follow-up on the use of our Website, we process your personal data, e.g. in connection with collection of visitor statistics on our Website. Processing conducted for the purpose set above may include the use of statistical and analytical cookies. Scope of data may contain: online identifiers, user generated information. Processing for the above-mentioned purpose may include the use of statistical and analytical cookies on the basis of our legitimate interest or other cookies based on your consent.

You may at any time, delete cookies that have been saved on your device by changing the settings in your web browser. In case you do not delete cookies by changing settings in your web browser, the cookies that are used for this purpose will be erased when your session has ended or, in case of persistent cookies, they will be erased in accordance with the expiration date for each cookie. Reports on an aggregated level which do not contain any personal data and statistics are stored until further notice or until they are deleted.

4) Provide relevant marketing and communication on our Website
We will collect and process your personal data in order for us and our advertising partners to provide you with relevant advertising and communication on our Website. Processing conducted for the purposes set above includes the use of marketing cookies based on your consent.

5) Comply with legal obligations
We process your personal data in order to comply with legal obligations, e.g. after receiving an access request from the data subject sent via the website regarding the ways in which we process personal data. Your personal data is kept for the period necessary to comply with each legal obligation. In principle, we store your personal data in relation to data subject access requests for as long as you have the right to bring an action against us.

6) Manage and protect our Website, services and related IT systems
We process your personal data to the extent necessary for the management and protection of our Website, our services and related IT systems, e.g. in the field of troubleshooting, backup, management of changes and system problems and in connection with possible IT incidents. Processing for the above-mentioned purposes includes the use of cookies and log-in data required for technical reasons processed by us as part of our legitimate interest. Cookies used for this purpose are not stored for more than 12 months.

RECIPIENTS THAT WE SHARE YOUR PERSONAL DATA WITH

Where necessary, we share your personal data with others. In order to fulfil the purposes of the processing of your personal data, we share personal data with service providers that we have engaged. These service providers provide IT services to us, such as Website and IT system hosting, maintenance and support service. The service providers may only process your personal data for these purposes and in accordance with our instructions and not for their own purposes. We are the data controller for the processing of personal data that the service providers carry out on our behalf.

In certain cases we share, if necessary, your personal data with other recipients for certain purposes e.g. when fulfilling legal obligations and handling and/or defending legal claims.

We may share data with our group companies or business partners and investors.. When we share your data with our advertising partners, we collect your consent in advance to send you marketing communications.

WHERE WE PROCESS PERSONAL DATA

We always strive to store and process personal data within the EU/EEA. However, some of our service providers may be located outside the EU/EEA and in such a case personal data will be processed outside the EU/EEA. In order to ensure that the personal data is protected we make sure that appropriate safeguards are in place in relation to the service providers which handle your personal outside the EU/EEA, e.g. by way of data transfer agreements (which include standard data protection clauses adopted by the EU Commission). If you have questions regarding the countries where your personal data is transferred and which safeguards we take to protect your personal data, or to request a copy of such safeguards and information, respectively, where they are available, please contact us at sales@noctiluca.eu

YOUR RIGHTS

Under data protection regulations, you have certain rights in relation to the processing of your personal data. We process your personal data to the extent necessary in order to fulfill your rights. You have the right to:

1) Access your personal data
You have the right to access personal data we process about you. You may request a copy of your personal data. We will provide you with it unless we have lawful reasons not to share this data or if sharing the data would adversely affect the rights and freedoms of others.

2) Update your personal data
Furthermore, you have the right to request that incorrect or incomplete personal data is corrected or completed.

3) Withdraw consent
To the extent we rely on your consent to process personal data you have the right to at any time with¬draw your consent. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

4) Object to the processing of personal data
You have the right to object to the processing of your personal data based on a legitimate interest for reasons which concern your particular situation. In such a situation, we will stop using your personal data where the processing is based on a legitimate interest, unless we can show that the interest over¬rides your privacy interest or that the use of your personal data is necessary in order to manage or defend legal claims.

5) Delete your personal data
Under certain circumstances you have the right to request that your personal data is deleted. However, we cannot delete your personal data if we for example are obligated under law to keep the data.

6) Restrict the use of your personal data
You have the right under certain circumstances to request that the processing of your personal data is restricted. If the processing of your personal data has been restricted we may only, besides storing the data, process your personal data with your consent, or in order to establish, exercise or defend legal claims or to defend rights of others.

7) Transfer your personal data (data portability)
Finally, you have the right to request a copy of the personal data that we store about you in a struc-tured, commonly used and machine-readable format (data portability). The right to data portability, compared to the right to access, only comprises such personal data you yourself have provided and which we process based on certain legal grounds, e.g. your consent.

SECURING YOUR PERSONAL INFORMATION

We take appropriate measures to ensure the security and confidentiality of the personal information we hold concerning you and to limit access to that information in order to safeguard that personal information from loss, interference, misuse, unauthorized access, disclosure, alteration or destruction.

Your personal data will not be subject to automatic decision making, including profiling related to automatic decision making.

RETENTION OF PERSONAL DATA

The Company endeavours to ensure that personal data are kept as current as possible and that irrelevant or excessive data are deleted or made anonymous as soon as reasonably practicable.

INFORMATION REGARDING COOKIES

The website uses the so-called cookie files (cookies). Cookies are simple, small files / IT data sent along with the subpages of this website and stored on the hard drive of a given User’s computer by a web browser for the proper use of our website. The information stored in cookies may be sent back to our servers during the next visit of the Website user or transferred to the relevant third parties. Cookies usually contain the name of the website they come from, the storage time on the end device and a unique number. Cookies are saved on the user’s device and sent by the user’s web browser to each time the user uses it.

The website also uses information contained in system logs (e.g. IP address).

The website uses the following types of cookies:

  • due to the lifetime of cookies:
    o session cookies – temporary files that are stored on the user’s end device until they leave the website or turn off the software (web browser);
    o persistent cookies – they are stored on the user’s end device for the time specified in the cookie file parameters or until they are deleted by the user;
  • due to the purpose for which cookies are used:
    o for “necessary” cookies, i.e. enabling the use of functionalities available on the Website
    o “performance” cookies, i.e. cookies that enable the collection of information on the use of the Website’s pages
    o “functional” cookies, ie enabling “remembering” the settings selected by the Website user, eg in the scope of the selected language.
    o “marketing” cookies, i.e. enabling advertising to be directed to you.
    o cookies used to monitor traffic, i.e. data analytics, including Google Analytics cookies (these are files used by the Google company to analyze the way you use the Website, to create statistics and reports on the functioning of the Website). Detailed information on the scope and principles of data collection in connection with this service can be found at the link.

Before using the Website, the user agrees to place cookies selected by the user on his end device by selecting which files he accepts and which do not, as part of the banner appearing on the website. The user can remove or block the installation of cookies by changing the settings of the web browser he uses.

Removal or blocking of cookies may affect the availability of website functionality, the correct display of the page and the loss of preferred settings of the website pages. “Necessary” cookies are essential for the website to function and cannot be turned off in the website system. Cookies placed on the website user’s end device may also be used by advertisers and partners cooperating with us.

AMENDMENTS TO THIS NOTICE

The Company may amend the provisions of this Policy. You will be informed accordingly about any changes or additions.

CONTACT

If you have any questions regarding the processing of your personal data, please do not hesitate to contact us. See below for contact details. If you are not satisfied with our response, you have the right to lodge a complaint with the relevant supervisory authority within your jurisdiction – the President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw.

sales@noctiluca.eu

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