1. General provisions

This personal data processing policy has been drawn up in accordance with the requirements of the General Data Protection Regulation (GDPR; Regulation (European Union) 2016/679, Polish: Rozporządzenie o ochronie danych osobowych (RODO) - hereinafter referred to as the Personal Data Protection Act) and defines the procedure for processing personal data and measures to ensure the security of personal data taken by MERSERPL Sp. z O.O. (hereinafter referred to as the Operator).

1.1. The Operator's most important goal and condition for carrying out its activities is to respect the rights and freedoms of individuals and citizens when processing their personal data, including the protection of the right to privacy and personal and family secrets.

1.2. This Operator's policy regarding the processing of personal data (hereinafter referred to as the Policy) applies to all information that the Operator may obtain about visitors to the website https://merserpl.com

2. Key terms used in the Policy

2.1. Automated processing of personal data – processing of personal data using computer technology.

2.2. Blocking of personal data – temporary suspension of the processing of personal data (except in cases where processing is necessary to clarify personal data).

2.3. Website – a collection of graphic and informational materials, as well as computer programs and databases that ensure their availability on the Internet at the network address https://merserpl.com

2.4. Personal data information system – a collection of personal data contained in databases and the information technology and technical means that ensure their processing.

2.5. Depersonalization of personal data – actions that make it impossible to determine, without the use of additional information, the ownership of personal data by a specific User or other subject of personal data.

2.6. Processing of personal data — any action (operation) or set of actions (operations) performed with or without the use of automation tools on personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.

2.7. Operator – a state body, municipal body, legal entity, or individual who, independently or jointly with other persons, organizes and/or carries out the processing of personal data, as well as determines the purposes of personal data processing, the composition of personal data to be processed, and the actions (operations) performed with personal data.

2.8. Personal data – any information relating directly or indirectly to a specific or identifiable user of the website https://merserpl.com.

2.9. Personal data authorised by the subject of personal data for distribution – personal data to which an unlimited circle of persons is granted access by the subject of personal data by giving consent to the processing of personal data authorised by the subject of personal data for distribution in accordance with the procedure provided for by the Personal Data Law (hereinafter referred to as personal data authorised for distribution).

2.10. User - any visitor to the website https://merserpl.com

2.11. Provision of personal data - actions aimed at disclosing personal data to a specific person or a specific group of persons.

2.12. Dissemination of personal data – any actions aimed at disclosing personal data to an indefinite group of persons (transfer of personal data) or at making personal data available to an unlimited group of persons, including the publication of personal data in the media, placement on information and telecommunications networks, or providing access to personal data in any other way.

2.13. Cross-border transfer of personal data – transfer of personal data to the territory of a foreign state to an authority of a foreign state, a foreign individual, or a foreign legal entity.

2.14. Destruction of personal data means any actions that result in the irretrievable destruction of personal data, making it impossible to further restore the content of personal data in the personal data information system and/or the destruction of physical media containing personal data.

3. Main rights and obligations of the Operator

3.1. The Operator has the right to:

receive from the subject of personal data reliable information and/or documents containing personal data;

in the event that the data subject withdraws their consent to the processing of personal data, the Operator has the right to continue processing personal data without the consent of the data subject if there are grounds specified in the Personal Data Law;

independently determine the composition and list of measures necessary and sufficient to ensure the fulfillment of the obligations provided for by the Personal Data Law and regulatory legal acts adopted in accordance with it, unless otherwise provided by the Personal Data Law or other laws.

3.2. The operator is obliged to:

provide the subject of personal data, at their request, with information concerning the processing of their personal data;

organise the processing of personal data in accordance with the procedure established by the current legislation of the Republic of Poland and the EU;

respond to inquiries and requests from personal data subjects and their legal representatives in accordance with the requirements of the Personal Data Protection Act;

provide the authorized body for the protection of the rights of personal data subjects with the necessary information at the request of that body;

publish or otherwise ensure unrestricted access to this Policy regarding the processing of personal data;

take legal, organizational, and technical measures to protect personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution of personal data, as well as from other unlawful actions in relation to personal data;

stop the transfer (distribution, provision, access) of personal data, stop processing and destroy personal data in the manner and in the cases provided for by the Personal Data Law;

perform other duties provided for by the Personal Data Law.

4. Basic rights and obligations of personal data subjects

4.1. Personal data subjects have the right to:

receive information regarding the processing of their personal data, except in cases provided for by law. The information shall be provided to the personal data subject by the Operator in an accessible form and shall not contain personal data relating to other personal data subjects, except where there are legitimate grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Law;

require the operator to clarify their personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained, or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect their rights;

to impose a condition of prior consent for the processing of personal data for the purpose of marketing goods, works, and services;

to withdraw consent to the processing of personal data;

to appeal to the authorized body for the protection of the rights of personal data subjects or in court against unlawful actions or inaction of the Operator in the processing of their personal data;

to exercise other rights provided for by the legislation of the Republic of Poland and the EU.

4.2. Personal data subjects are obliged to:

provide the Operator with accurate data about themselves;

inform the Operator about the clarification (update, change) of their personal data.

4.2. Subjects of personal data are obliged to:

provide the Operator with accurate data about themselves;

notify the Operator of any clarification (update, change) of their personal data.

4.3. Persons who have provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter's consent shall be liable in accordance with the laws of the Republic of Poland and the EU.

5. The Operator may process the following personal data of the User

5.1. Surname, first name, patronymic.

5.2. Email address.

5.3. Phone numbers.

5.4. The website also collects and processes anonymized data about visitors (including cookies) using internet statistics services (Facebook Pixel, Google Analytics, and others).

5.5. The above data is hereinafter referred to in this Policy as Personal Data.

5.6. The Operator does not process special categories of personal data relating to race, nationality, political views, religious or philosophical beliefs, or intimate life.

5.7. The processing of personal data permitted for distribution from among the special categories of personal data specified in the Personal Data Law is permitted if the prohibitions and conditions provided for in the Personal Data Law are observed.

5.8. The User's consent to the processing of personal data permitted for distribution is formalized separately from other consents to the processing of their personal data. In doing so, the conditions provided for, in particular, by the Personal Data Law are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.

5.8.1 The User shall provide the Operator with consent to the processing of personal data permitted for distribution directly.

5.8.2 The Operator shall be obliged, within three working days of receiving the specified consent from the User, to publish information about the conditions of processing, the existence of prohibitions and conditions for the processing of personal data authorised for distribution by an unlimited circle of persons.

5.8.3 The transfer (distribution, provision, access) of personal data authorised for distribution by the data subject must be terminated at any time at the request of the data subject. This request must include the surname, first name, patronymic (if any), contact information (telephone number, email address, or postal address) of the personal data subject, as well as a list of personal data whose processing is to be terminated. The personal data specified in this request may only be processed by the Operator to whom it is addressed.

5.8.4 Consent to the processing of personal data permitted for distribution shall cease to be valid from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.

6. Principles of personal data processing

6.1. Personal data processing is carried out on a lawful and fair basis.

6.2. Personal data processing is limited to achieving specific, predefined, and lawful purposes. Personal data processing that is incompatible with the purposes of personal data collection is not permitted.

6.3. It is not permitted to combine databases containing personal data that is processed for purposes that are incompatible with each other.

6.4. Only personal data that meets the purposes of its processing shall be processed.

6.5. The content and scope of the personal data processed shall correspond to the stated purposes of processing. The processing of personal data shall not be excessive in relation to the stated purposes of its processing.

6.6. When processing personal data, the accuracy, sufficiency, and, where necessary, relevance of the personal data in relation to the purposes of processing shall be ensured. The operator shall take the necessary measures and/or ensure that measures are taken to delete or correct incomplete or inaccurate data.

6.7. Personal data shall be stored in a form that allows the identification of the data subject for no longer than is necessary for the purposes of processing personal data, unless the storage period for personal data is established by law, contract, or by a party to which the data subject is a beneficiary or guarantor. The processed personal data shall be destroyed or anonymized upon achievement of the purposes of processing or in case of loss of necessity to achieve these purposes, unless otherwise provided by law.

7. Purposes of personal data processing

7.1. The purpose of processing the User's personal data:

informing the User by sending e-mails;

providing the User with access to services, information, and/or materials contained on the website https://merserpl.com

contacting the User for the purpose of providing advice.

7.2. The Operator also has the right to send the User notifications about new products and services, special offers, and various events. The User may always opt out of receiving informational messages by sending a letter to the Operator at info@merserpl.com with the subject line “Opt out of notifications about new products and services and special offers.”

7.3. Anonymized User data collected using Internet statistics services is used to collect information about User actions on the website and to improve the quality of the website and its content.

8. Legal grounds for the processing of personal data

8.1. The legal grounds for the processing of personal data by the Operator are:

General Data Protection Regulation (GDPR; Regulation (European Union) 2016/679, Polish: Rozporządzenie o ochronie danych osobowych (RODO));

other regulatory and legal acts in the field of personal data protection;

the consent of Users to the processing of their personal data, to the processing of personal data permitted for distribution.

8.2. The Operator processes the User's personal data only if it is filled in and/or sent by the User independently through special forms located on the website https://merserpl.com or sent to the Operator by e-mail. By filling out the appropriate forms and/or sending their personal data to the Operator, the User expresses their consent to this Policy.

8.3. The Operator processes anonymized data about the User if this is permitted in the User's browser settings (cookie storage is enabled).

8.4. The subject of personal data independently decides on the provision of their personal data and gives their consent freely, of their own will, and in their own interest.

9. Conditions for the processing of personal data

9.1. Personal data is processed with the consent of the data subject to the processing of their personal data.

9.2. The processing of personal data is necessary to achieve the objectives set out in an international agreement between the Republic of Poland and the EU or in law, to perform the functions, powers, and duties assigned to the operator by the legislation of the Republic of Poland and the EU.

9.3. The processing of personal data is necessary for the administration of justice, the enforcement of a court order, an act of another authority or official, subject to enforcement in accordance with the legislation of the Republic of Poland and the EU on enforcement proceedings.

9.4. The processing of personal data is necessary for the performance of a contract to which the data subject is a party or the beneficiary or guarantor, as well as for the conclusion of a contract on the initiative of the data subject or a contract under which the data subject will be the beneficiary or guarantor.

9.5. The processing of personal data is necessary for the exercise of the rights and legitimate interests of the operator or third parties, or for the achievement of socially significant goals, provided that this does not violate the rights and freedoms of the personal data subject.

9.6. Personal data is processed, access to which is provided by the personal data subject or at his request to an unlimited circle of persons (hereinafter referred to as publicly available personal data).

9.7. Personal data subject to publication or mandatory disclosure in accordance with the law is processed.

10. Procedure for the collection, storage, transfer, and other types of processing of personal data

The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary to fully comply with the requirements of current legislation in the field of personal data protection.

10.1. The Operator ensures the security of personal data and takes all possible measures to prevent access to personal data by unauthorized persons.

10.2. The User's personal data will never, under any circumstances, be transferred to third parties, except in cases related to the enforcement of applicable law or if the subject of the personal data has given consent to the Operator to transfer the data to a third party in order to fulfill obligations under a civil law contract.

10.3. If inaccuracies are found in personal data, the User may update them independently by sending a notification to the Operator's email address info@merserpl.com with the subject line “Update of personal data.”

10.4. The period for processing personal data is determined by the achievement of the purposes for which the personal data was collected, unless another period is provided for by contract or applicable law.

The User may withdraw their consent to the processing of personal data at any time by sending a notification to the Operator by email to the Operator's email address info@merserpl.com with the subject line “Withdrawal of consent to the processing of personal data.”

10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by those entities (Operators) in accordance with their User Agreement and Privacy Policy. The personal data subject and/or User is obliged to familiarize themselves with the specified documents in a timely manner. The Operator is not responsible for the actions of third parties, including the service providers specified in this clause.

10.6. Prohibitions established by the subject of personal data on the transfer (except for providing access), as well as on the processing or conditions of processing (except for obtaining access) of personal data permitted for distribution, do not apply in cases of processing personal data in the state, public, and other public interests defined by the legislation of the Republic of Poland and the EU.

10.7. When processing personal data, the operator ensures the confidentiality of personal data.

10.8. The operator shall store personal data in a form that allows the identification of the data subject for no longer than is necessary for the purposes of processing personal data, unless the period of storage of personal data is established by law, contract, or by the data subject as a party, beneficiary, or guarantor thereof.

10.9. The conditions for the termination of personal data processing may be the achievement of the purposes of personal data processing, the expiry of the consent of the personal data subject or the withdrawal of consent by the personal data subject, as well as the detection of unlawful personal data processing.

11. List of actions performed by the Operator with the personal data received

11.1. The Operator collects, records, systematizes, accumulates, stores, clarifies (updates, changes), extracts, uses, transfers (distributes, provides, accesses), anonymizes, blocks, deletes, and destroys personal data.

11.2. The Operator performs automated processing of personal data with the receipt and/or transfer of the received information via information and telecommunications networks or without such.

12. Cross-border transfer of personal data

12.1. Before starting the cross-border transfer of personal data, the Operator must make sure that the foreign country where the personal data is supposed to be transferred provides reliable protection of the rights of personal data subjects.

12.2. Cross-border transfer of personal data to foreign countries that do not meet the above requirements may only be carried out with the written consent of the personal data subject to the cross-border transfer of their personal data and/or the performance of a contract to which the personal data subject is a party.

13. Confidentiality of personal data

The Operator and other persons who have access to personal data are obliged not to disclose to third parties and not to distribute personal data without the consent of the personal data subject, unless otherwise provided by law.

14. Final provisions

14.1. The user may obtain any clarifications on issues of interest relating to the processing of their personal data by contacting the Operator by email at info@merserpl.com.

14.2. This document will reflect any changes in the Operator's personal data processing policy. The policy is valid indefinitely until it is replaced by a new version.

BASIC PROVISIONS FOR COLLECTING USER DATA ON THE WEBSITE