Privacy policy

The following Privacy Policy defines the rules for storing and accessing data on Users' Devices using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing personal data of Users that have been provided by them personally and voluntarily through the tools available in the Service. The following Privacy Policy is an integral part of the Service Regulations, which define the rules, rights, and obligations of Users using the Service.

• Service – the online service “DTFtransfer.com” operating at https://dtftransfer.com
• External Service – online services of partners, service providers, or contractors cooperating with the Administrator
• Service/Data Administrator – The Administrator of the Service and the Data Administrator (hereinafter referred to as the Administrator) is DTFtransfer.com sp. z o.o., conducting business at Biechów 72B, 28-133 Pacanów, with a tax identification number (NIP): 655-198-57-79, providing electronic services through the Service.
• User – a natural person for whom the Administrator provides electronic services through the Service.
• Device – an electronic device with software through which the User accesses 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 April 27, 2016, on the protection of natural persons regarding 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, identification number, location data, online identifier, or one or more specific factors inherent to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
• Processing – means an operation or set of operations performed on personal data or sets of personal data, whether by automated or non-automated means, such as collection, recording, organization, 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 with the aim of limiting their processing in the future.
• Profiling – means any form of automated processing of personal data that consists of using personal data to evaluate certain personal aspects of 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 – the consent of the data subject means a voluntary, specific, informed, and unambiguous indication of the data subject's wishes, by which they, by a statement or a clear affirmative action, signify agreement to the processing of personal data relating to them.
• Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed.
• Pseudonymization – means the processing of personal data in such a way that the 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 organizational measures to ensure that it cannot be attributed to an identified or identifiable natural person.
• Anonymization – Anonymization of data is an irreversible process of operations on data that destroys/overwrites “personal data,” making identification or linking a given record to a specific user or natural person impossible.

Based on Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer. For matters concerning data processing, including personal data, please contact the Administrator directly.

• Internal Cookies – files placed and read from the User's Device by the IT system of the Service.
• External Cookies – files placed and read from the User's Device by the IT systems of External Services. External Service scripts that may place Cookies on Users' Devices have been intentionally placed in the Service through scripts and services provided and installed in the Service.
• Session Cookies – files placed and read from the User's Device by the Service during one session of the given Device. After the session ends, the files are deleted from the User's Device.
• Persistent Cookies – files placed and read from the User's Device by the Service until they are manually deleted. The files are not automatically deleted after the end of the Device's session unless the configuration of the User's Device is set to delete cookies after the Device's session ends.

• Mechanisms for storing and reading Cookies – The mechanisms for storing, reading, and exchanging data between Cookies saved on the User's Device and the Service are carried out through built-in mechanisms of web browsers and do not allow for the retrieval of 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, trojans, and other worms to the User's Device is also practically impossible.
• Internal Cookies – the Cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the Device used by the User.
• External Cookies – The Administrator takes all possible actions to verify and select service partners concerning User security. The Administrator chooses well-known, large partners with global social trust for cooperation. However, it does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the security of Cookies, their content, or licensed use by scripts installed in the service, provided by External Services, to the extent permitted by law. A list of partners is included later in the Privacy Policy.
• Cookie Control – The User can change the settings regarding the storage, deletion, and access to data stored in Cookies at any time through each website. Information on how to disable cookies in the most popular computer browsers can be found on the website: how to disable cookies or from one of the indicated providers:
  • Managing cookies in Chrome
  • Managing cookies in Opera
  • Managing cookies in Firefox
  • Managing cookies in Edge
  • Managing cookies in Safari
  • Managing cookies in Internet Explorer 11

The User can delete any Cookies saved so far using the tools of the User's Device through which the User uses the services of the Service at any time.

• User-side Threats – The Administrator uses all possible technical measures to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User's activities. The Administrator is not responsible for the interception of this data, session hijacking, or their deletion due to the conscious or unconscious activities of the User, viruses, trojans, and other spyware that the User's Device may be infected with or has been infected with. Users should follow safe internet use principles to protect themselves against these threats.
• Storage of Personal Data – The Administrator ensures that every effort is made to ensure that the personal data processed voluntarily provided by Users is secure, access to them is limited, and carried out in accordance with their intended purpose and processing goals. The Administrator also ensures that every effort is made to secure the data held against loss by applying appropriate physical and organizational safeguards.
• Password Storage – The Administrator declares that passwords are stored in an encrypted form, using the latest standards and guidelines in this area. Decryption of the passwords provided in the Service is practically impossible.

• Improving and facilitating access to the Service
• Personalizing the Service for Users
• Enabling Login to the service
• Marketing, Remarketing on external services
• Conducting statistics (users, visit counts, types of devices, connections, etc.)
• Serving multimedia services
• Providing social services

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

• Implementation of electronic services:
  • Services for registering and maintaining User accounts in the Service and functionalities related to them
  • Newsletter services (including sending advertising content with consent)
  • Services for sharing information about content placed in the Service on social networks or other websites.
  • Communication between the Administrator and Users regarding the Service and data protection
  • Ensuring the legitimate interests of the Administrator

Anonymously and automatically collected User data is processed for one of the following purposes:

• Conducting statistics
• Remarketing
• Ensuring the legitimate interests of the Administrator

The Administrator uses JavaScript scripts and web components of partners in the Service, who may place their own cookies on the User's Device. Remember that in your browser settings, you can decide which cookies are allowed by each website. Below is a list of partners or their services implemented in the Service that may place cookies:

• Multimedia services:
  • YouTube
• Social services / integrated: (Registration, Login, content sharing, communication, etc.):
  • Twitter
  • Facebook
  • LinkedIn
• Content sharing services:
  • WhatsApp
  • Instagram
• Conducting statistics:
  • Google Analytics
  • Facebook Analytics for Apps

The services provided by third parties are beyond the Administrator's control. These entities may change their service conditions, privacy policies, and cookie policies at any time.

The Service collects data about Users. Some data is collected automatically and anonymously, while some data consists of personal information voluntarily provided by Users when registering for specific services offered by the Service. The anonymously collected data includes:

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

Data collected during registration:

• First name / last name / nickname
• Username
• Email address
• Residential address
• Phone number
• IP address (automatically collected)
• Tax Identification Number (NIP)
• Other ordinary data

Data collected when signing up for the Newsletter:

• First name / last name / nickname
• Email address
• Residential address
• IP address (automatically collected)

Some data (excluding identifying information) may be stored in cookies. Some data (excluding identifying information) may be shared with the statistical service provider.

As a general rule, the only recipient of personal data provided by Users is the Administrator. The data collected in connection with the services provided are not transferred or sold to third parties. Access to data (most often based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary for operating the service, such as:

• Hosting companies providing hosting or related services to the Administrator
• Companies through which the Newsletter service is provided
• IT service and support companies performing maintenance or responsible for maintaining IT infrastructure
• Companies facilitating online payments for goods or services offered through the Service (in the case of purchasing transactions on the Service)
• Companies responsible for delivering physical products to Users (postal/courier services in the case of purchasing transactions on the Service)

Data Processing Assignment – Hosting Services, VPS, or Dedicated Servers
To operate the service, the Administrator uses the services of an external hosting provider, VPS, or Dedicated Servers – OVH sp. z o.o.. All data collected and processed on the service is stored and processed in the provider's infrastructure located within the European Union. Access to data may occur during maintenance work performed by the provider's staff. Access to this data is governed by the agreement between the Administrator and the Service Provider.

Data Processing Assignment – Website Service Management
To manage the service, the Administrator uses the services of an external service provider – Zoho Corporation Pvt. Ltd. The personnel of the mentioned entity have access to the data entered by users during registration and account editing and/or data related to the Newsletter service. Access to this data is governed by the agreement between the Administrator and the Service Provider.

Data Processing in the Case of Online Payments
In the case of online payment processing, all payment data is transmitted directly by the User to the payment provider – Blue Media S.A.. Selected data necessary for transaction completion is then transmitted by this entity to the Administrator. The transfer of data is governed by the agreement between the Administrator and the Service Provider.

Transfer of Personal Data – Courier Services
In the case of a transaction that requires the delivery of an item involved in the transaction via mail or courier, some personal data of individuals or data of individuals running a business is shared with the entity providing postal/courier services on behalf of the Administrator, chosen by the User. The transfer of this data is governed by the agreement between the Administrator and the Service Provider.

Personal data voluntarily provided by Users:

• Personal data will not be transferred outside the European Union, unless published as a result of an individual action by the User (e.g., posting a comment or entry), which will make the data accessible to anyone visiting the service.
• Personal data is used for automated decision-making (profiling). The profiling of personal data does not have legal effects or similarly significantly affect the person whose data is subject to automated decision-making.
• Personal data will not be sold 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). The profiling of anonymous data (without personal data) does not have legal effects or similarly significantly affect the person whose data is subject to automated decision-making.
• Anonymous data (without personal data) will not be sold to third parties.

The Service collects and processes Users' data based on:

1. Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals 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 given consent to the processing of their 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 a party or 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 legitimate interests pursued by the controller or by a third party.

1. Act of May 10, 2018, on the protection of personal data (Journal of Laws 2018, item 1000).
2. Act of July 16, 2004, Telecommunications Law (Journal of Laws 2004, No. 171, item 1800).
3. Act of February 4, 1994, on Copyright and Related Rights (Journal of Laws 1994, No. 24, item 83).

Personal data voluntarily provided by Users: As a general rule, the specified personal data is stored only for the duration of the Service provided by the Administrator within the Service. It is removed or anonymized within 30 days from the end of the service provision (e.g., deletion of the registered user account, unsubscribing from the Newsletter list, etc.). An exception applies to situations requiring the safeguarding of legitimate purposes for further processing of this data by the Administrator. In such cases, the Administrator will retain the specified data for no longer than three years from the time the User requests its deletion, in the event of a violation or suspicion of a violation of the service regulations by the User.

Anonymous data (without personal data) collected automatically: Anonymous statistical data, which does not constitute personal data, is retained by the Administrator for an indefinite period for the purpose of conducting service statistics.

The Service collects and processes Users' data based on:

1. Right of access to personal data: Users have the right to obtain access to their personal data, which can be requested from the Administrator.
2. Right to rectification of personal data: Users have the right to request the Administrator to promptly rectify any incorrect personal data and/or complete any incomplete personal data, which can be requested from the Administrator.
3. Right to erasure of personal data: Users have the right to request the Administrator to promptly erase their personal data, which can be requested from the Administrator. In the case of user accounts, data deletion involves the anonymization of data that can identify the User. The Administrator reserves the right to suspend the execution of the request for data deletion to protect the legitimate interests of the Administrator (e.g., if the User has violated the Terms and Conditions or if the data was obtained through correspondence). In the case of the Newsletter service, the User has the option to independently delete their personal data using the link provided in every email sent.
4. Right to restrict the processing of personal data: Users have the right to restrict the processing of their personal data in the cases specified in Article 18 of the GDPR, such as questioning the accuracy of the personal data, which can be requested from the Administrator.
5. Right to data portability: Users have the right to obtain from the Administrator their personal data in a structured, commonly used, and machine-readable format, which can be requested from the Administrator.
6. 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 Article 21 of the GDPR, which can be requested from the Administrator.
7. Right to lodge a complaint: Users have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data.

Users can contact the Administrator in one of the following ways:

• Postal address: DTFtransfer.com sp. z o.o., Biechów 72B, 28-133 Pacanów
• Email address: [email protected]
• Phone call: +48 882 510 444
• Contact form: available at: /kontakt

Limiting the storage and access to cookies on the User's Device may cause some features of the Service to function improperly. The Administrator is not liable for any malfunctioning features of the Service if the User restricts in any way the ability to store and read cookies.

The Service—articles, posts, entries, or comments from Users—may contain links to external websites with which the Owner of the Service does not cooperate. These links and the pages or files they refer to may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content found outside the Service.

The Administrator reserves the right to change this Privacy Policy at any time without the obligation to inform Users regarding the application and use of anonymous data or the use of cookies.

The Administrator also reserves the right to change this Privacy Policy concerning the processing of Personal Data, informing Users with user accounts or those subscribed to the newsletter via email within 7 days of the changes being made. Continued use of the services constitutes acceptance of the changes made to the Privacy Policy. If a User does not agree with the changes, they are required to delete their account from the Service or unsubscribe from the Newsletter service.

Changes to the Privacy Policy will be published on this subpage of the Service. The changes take effect upon publication.