(valid as of 01.07.2022).
Table of contents
I. Introduction – contact information
II. Data protection laws
III. Principles of processing your personal data
IV. Users’ rights in connection with the processing of personal data
V. Security of personal data
VI. How we process your data
VII. Consent – withdrawal of consent
VIII. Data storage
IX. Data co-management and data recipients
X. Processing of data outside the EEA
XI. Data processing using cookies and other Internet technologies
XII. Changes to the Policy
XIII. Price lists
I. Introduction – contact information
This Privacy Policy contains information regarding the use (processing) by AUTO-BLAK Ltd, AUTO-BLAK Marcin Kozyra (“AUTO-BLAK”, “we”, “us”), of personal data of visitors to or users of the services provided by AUTO-BLAK through the websites of which AUTO-BLAK is the publisher and administrator (“Users”), unless a particular website (e.g. online store) has a dedicated privacy policy.
We respect the privacy of our Users and therefore provide this Privacy Policy so that each User knows to what extent her/his personal data is processed, including the ability to make an independent, informed and free decision about whether to use our Services.
Within the framework of this Privacy Policy, we have chosen to describe in general terms how and to what extent we collect Users’ personal data, for what purposes we use this data, to whom we share it, and how we protect it. In the Privacy Policy, you will also find information about what rights Users have under applicable data protection laws.
The policy is general in nature and presents the most important issues related to the processing of personal data. This Policy is detailed in the individual regulations or information clauses that the User will receive when personal data is collected from him/her on the occasion of particular services: e.g. newsletter subscriptions, forms, contests, promotional activities, events.
Additional or supplementary information on the processing of personal data by AUTO-BLAK can also be found in the contractual documentation or information clauses provided to our customers in connection with the use of maintenance services, participation in events organized by us, use of our cars.
To the extent that we use cookies or other data-collecting technologies on our websites, we provide more information in our Cookies Policy.
Administrator – contact information AUTO-BLAK:
AUTO-BLAK sp. z o.o. with registered office in Warsaw, 25A Farbiarska St., 02-862 REGON COURT FOR M.ST. WARSAW, XIV ECONOMIC DEPARTMENT OF THE NATIONAL REGISTER under the KRS number 0000083336, NIP 1230950444, REGON 017424391 (AUTO-BLAK).
and
AUTO-BLAK Marcin Kozyra ul. Modlińska 146, 03-170 Warsaw, NIP: 5251758783, REGON: 012672753
Website: https://auto-blak.pl/
E-mail: serwis@auto-blak.pl
AUTO-BLAK Data Protection Officer contact information:
E-mail: rodo@auto-blak.pl
Address: AUTO-BLAK Sp. z o.o. 25A Farbiarska Street, 02-862 Warsaw.
AUTO-BLAK Marcin Kozyra ul. Modlińska 146, 03-170 Warsaw
For more information regarding the co-administration of Users’ personal data, please see Section IX below.
II. Data protection laws
AUTO-BLAK’s Privacy Policy is based on the following provisions:
Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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) (Official Journal of the EU.L No. 119, p. 1) – otherwise known as “RODO”.
The Act of May 10, 2018 on the protection of personal data (Journal of Laws of 2018, item 1000)
the Act of July 16, 2004. Telecommunications Law (Journal of Laws of 2017, item 1907, as amended).
The Act of July 18, 2002 on the provision of electronic services (i.e. Journal of Laws of 2017, item 1219 as amended).
III. Principles of processing your personal data
We appreciate the trust that Users have placed in us. In processing Users’ personal data, we attach importance to ensuring that the data is processed in a safe, reliable, lawful and transparent manner for the User.
The following are the most important principles that guide us:
We collect personal data only to the minimum extent necessary to fulfill the purposes for which they are collected.
The purposes of collecting Users’ personal data are clearly defined, based on the law – we do not process data in a manner incompatible with these purposes.
We take care of the timeliness and correctness of Users’ personal data and respond promptly to any requests for rectification or updating of data.
We realize Users’ right to access and correct their personal data.
We also realize Users’ rights to erasure of personal data, withdrawal of consent, restriction of processing, data portability, the right to object to data processing, the right not to be subject to a decision based solely on automated data processing, including profiling.
We limit the storage of personal data in accordance with the law, only to the period necessary for the purposes for which they are collected, unless there are events that may extend the storage period.
We protect Users’ personal data from loss, unauthorized access, accidental loss or alteration, and other unlawful forms of processing.
If personal data is shared with other parties, it is done in a secure, contractually secured manner and in accordance with applicable laws.
IV. Users’ rights in connection with the processing of personal data
AUTO-BLAK shall exercise the rights of Users related to the processing of their personal data. These rights derive from the applicable legal provisions on personal data, in particular the RODO (Articles 16-21).
The User has the right to:
Withdraw consent to the processing of personal data at any time, if consent is the legal basis for data processing (see Section VII below),
The right to be informed how AUTO-BLAK processes their personal data
Access to the data: to receive confirmation from AUTO-BLAK as to whether and how their personal data is processed by AUTO-BLAK, and to have access to the data to the extent provided for in Article 15 of the RODO.
To rectify outdated or inaccurate personal data, as well as the right to have it supplemented if it is incomplete.
To object to the processing of your personal data on grounds related to your particular situation, if we process your personal data based on our legitimate interest (e.g., analytical, statistical, evidentiary, archival purposes), then in the event of your objection, we will have to stop processing your data, unless we demonstrate the existence of compelling legitimate grounds for the processing, which objectively should take precedence over your interests or are necessary for the establishment, assertion or defense of claims (e.g., evidentiary purposes, or in the case of a claim by/from AUTO-BLAK). You also have the right to object if the processing relates to direct marketing, including profiling (regardless of whether the legal basis for such processing is consent or our legitimate interest; in any case, your objection or withdrawal of consent in this regard will cause us to stop processing your data for these purposes).
Not to be subject to a decision that is based solely on automated processing, including profiling, and produces legal effects on a person or similarly materially affects a person (unless permitted by law, or is necessary for the performance of a contract, or is based on express consent; in the latter two cases, a person has the right to express his or her own position and to challenge that decision).
Erasure of personal data by AUTO-BLAK (“right to be forgotten”) consists, in principle, of requesting from the controller the immediate deletion of personal data concerning you; however, pursuant to Article 17 of the RODO, there are exceptions to this right ( in particular for the purposes of establishing, asserting or defending claims)
Restrict the processing of personal data, which in practical terms may involve temporarily blocking access to your data, or transferring the data to another system.
Data portability: you have the right to receive a copy of the personal data you have provided to us if the processing is based on your consent or under contract, only by automated means.
Submit a complaint to a supervisory authority – the President of the Office for Personal Data Protection.
You can send any requests regarding the processing of your personal data, including your rights, by email to: rodo@auto-blak.pl, or in writing to AUTO-BLAK Sp. z o.o. ul. Farbiarska 25A, 02-862 Warsaw and AUTO-BLAK Marcin Kozyra ul. Modlińska 146, 03-170 Warsaw
and you can contact our Data Protection Officer (in writing to the address of our registered office with the notation “IOD” or by writing to: rodo@auto-blak.pl).
In the case of a request for withdrawal of consent, see also Section VII .
Your requests will be fulfilled without undue delay, but no later than one month after receipt. This period may be extended due to the complexity of the request or the number of requests, for another two months, of which we will inform you. Until the request is fulfilled, however, it may happen that you receive information from us that you have opted out of by withdrawing your consent or expressing your objection.
To the extent that you direct your requests to AUTO-BLAK, we ask for your name and contact information (telephone number or e-mail address, in the case of written requests also your address). If the requests relate to the use of websites, we ask you to provide the website address or information about the service provided through our websites, as well as additional explanations of the reported request (in order to handle the request more efficiently). In order to process some requests, we may need further confirmation of your identity.
In order to run a personalized advertising campaign, AUTO-BLAK processes certain information about users’ online activities on this website. This information includes online identifiers (cookie IDs), information about the views of individual pages or subsites of the website, as well as timestamps and technical device and browser information. AUTO-BLAK contracts with its subcontractor, an advertising technology provider, to run advertising campaigns and personalize ads for users based on the above information. To the extent that this information constitutes “personal data” within the meaning of the RODO, AUTO-BLAK is the controller and the subcontractor is the processor.
V. Security of personal data
AUTO-BLAK takes technical and organizational measures to protect personal data from unlawful or unauthorized access or use, as well as from accidental destruction, loss or impairment of its integrity. The principle of ensuring security has guided us in the design of our IT infrastructure, the design of our standards and business practices. In particular, our security procedures include: access security, backup system, monitoring, review and maintenance, security incident management, risk analysis.
In ensuring the security of the personal data we process, we are committed to including:
confidentiality – we will protect the data from accidental disclosure to third parties,
integrity – we will protect data from unauthorized modification,
accessibility – we will ensure that authorized persons have access to your data if necessary.
Your personal data may be processed by third parties only if such entity undertakes to provide appropriate technical and organizational measures to ensure the security of the processing of personal data, as well as to maintain the confidentiality of such data. Any employee or associate of AUTO-BLAK who has access to personal data has the appropriate authorization and is obliged to maintain confidentiality.
The personal data you provide on our websites is encrypted and protected by an SSL certificate.
VI. How we process your data
For what purpose and on what basis do we process Users’ data?
AUTO-BLAK processes your personal data only for specific, explicit and legitimate purposes. We will not process your data in a manner incompatible with these purposes.
AUTO-BLAK will inform you of the purpose and the legal basis for processing your personal data in a separate communication each time.
The following are the different legal bases and the different purposes for which we may use personal data (it may be that within one data processing, the User’s data will be processed for different purposes and on different legal bases):
Consent as a legal basis – Consent can be given as a result of an active action by the User (e.g. leaving data and sending a form) or by having to check a checkbox (in both cases the basis is Article 6(1)(a) of the RODO).
In any case, the User may withdraw his/her consent, in the manner indicated in the information about the processing of personal data, as well as in Section VII below.
Consent provides a legal basis when, among other things:
Users voluntarily leave us their data and direct us to ask for an offer, test drive, service visit, request to contact our Information Center or our consultants,
They are asking to send car configurations,
give additional consent for the purpose of future marketing, consisting of: sending offers of products or services of AUTO-BLAK and other related automotive accessories, products and services, including profiling for the purposes of this marketing and conducting and analyzing surveys of: customer satisfaction, interest in the company, products and services of AUTO-BLAK,
– participate in a survey of satisfaction with the handling of an inquiry by our Information Center,
– take part in competitions.
Performance of a contract or actions to conclude a contract (Art. 6(1)(b) RODO)
The legal basis in the form of a contract or actions to conclude a contract applies when, among other things:
– we realize access to our websites and services provided electronically through them (e.g. contact forms);
Legitimate legitimate interests (except where your interests or fundamental rights and freedoms override our interests) (Article 6(1)(f) RODO):
We may process personal data on the basis of our legitimate interests consisting of, among other things:
– Handling inquiries other than for marketing information,
– To study the quality of service within the business,
– sending an invitation to a satisfaction survey of our Information Center’s handling of your inquiry (unless you contact us by phone, in which case we ask for your permission)
– Internal auditing and reporting,
– To ensure that AUTO-BLAK’s products or services are provided in accordance with the law and applicable standards.
– to carry out evidentiary purposes, archival purposes, and to secure information in case of legal need to prove facts, possible establishment, investigation or defense against claims;
– to carry out analytical and statistical purposes in order to ensure the quality of AUTO-BLAK’s products and services, to make better selection of products and services to meet customers’ needs, to optimize our products in general, to optimize our service processes, to build knowledge about our customers, to make sales and market analyses, to develop marketing or business strategies. In this case, the result of processing is aggregate data.
– In connection with the provision of electronic services and ensuring their security, handling of complaints, AUTO-BLAK may process Users’ data and exploitation data.
– The realization of Users’ rights, in particular the right to the accuracy of data, the right to withdraw consent, and the storage of Users’ requests and evidence of their service.
– Managing the sales and customer service process, setting standards for AUTO-BLAK customer service, ensuring attention to the quality of products and services, maintaining a central customer base, including potential customers.
If the User contacts AUTO-BLAK as an employee of corporate customers for ongoing matters, including the use of AUTO-BLAK products or services, interest in the offer to corporate customers, personal data will be processed under the legitimate interests of being able to be contacted on an ongoing basis as part of such business relationship.
In some cases, the basis for the processing of personal data may also be the protection of a person’s vital interests (the basis of Article 6(1)(d) of the RODO) or the fulfillment of a legal obligation lying with the controller (the basis of Article 6(1)(c) of the RODO).
To the extent to which we use cookies or other technologies on our websites and process personal data with them, we provide more information in the Cookies Policy .
Method of data collection
AUTO-BLAK collects personal data of Users when they fill out forms on our websites, contact the Hotline or Customer Service, address questions or messages via our social networks (we may then retain information that Users have voluntarily provided by writing or contacting AUTO-BLAK and automatically data contained in system logs and cookies (more on this in the Cookie Policy).
What data can we process and where do we get it from?
The personal data we write about may include a different range of data, depending on the category of the data subject and whether you are already our customer, a person potentially interested in our products or services, and the purpose for which the data is collected. If you are already our customer, in addition to the data you leave on the form or during your conversation with our Customer Service, we may also use data about you previously collected by AUTO-BLAK to the extent necessary to fulfill the purpose.
We will only process the necessary amount of data each time.
We may process such personal data as: identification data (e.g. name, surname), contact data (e.g. phone number, email address, home address), vehicle VIN number, car data, location data (only if you give your consent via a specially designated function of the website), data on your inquiries, orders, orders, complaints, data on the products or services you are interested in, and data on the products or services you are interested in. In case of business entities, data concerning your inquiries, orders, orders, complaints, data about your fleet, data about your contact person (position); recordings of conversations held with our AUTO-BLAK Customer Service, data related to use of chat rooms.
When using the AUTO-BLAK websites, the provision of personal data is voluntary, but often necessary in order to handle the User’s order or inquiry (such data elements are marked with a * symbol, e.g. first name, last name (in some cases), telephone number; regardless of this, the User may voluntarily leave additional data, e.g. e-mail address).
If you log in to our websites using social network credentials, e.g. Facebook, Google+ or others, you thereby agree to share your User data with us. This also applies to communicating with us via the Facebook chat box (after logging in), posted directly on our websites. Data includes, for example, name, email address, date of place and birth, location, and any information the User wishes to share.
If the User does not wish to leave his/her personal information through the websites, then he/she can contact our Information Center by phone or email, or on-site at the Customer Service Desk.
In connection with the use of our websites, we also collect data through cookies or other similar technologies (e.g. tags, pixels). The scope of data recorded in connection with the use of cookies is described in detail in the Cookie Policy.
As part of your use of our websites, personal information has been provided to us by you. If, as a User, you are also already a customer of ours or are in our central database as a potential customer. In the case of business entities, the data may come from publicly available records, and the personal data of contact persons at a corporate customer may also come from websites.
Children’s privacy
The forms collecting personal data within the service are addressed to adults. Accordingly, AUTO-BLAK does not knowingly process personal data of children under the age of 16. The consents given by Users are valid for persons over the age of 16. If you are under the age of 16, you should not provide us with any information. If we become aware that a person under the age of 16 has provided us with personal data without verifiable parental consent, we will not process such data.
VII. Consent – withdrawal of consent
In your relationship with the User, including in the services offered through the website consisting of providing commercial and marketing information, you may be asked to consent to the processing of your personal data for marketing purposes relating to AUTO-BLAK’s products or services, including electronic marketing, if it is your consent that may provide an appropriate legal basis for the processing of your personal data. Consent may also be given by a so-called “explicit action”, e.g. resulting from the fact that you voluntarily leave your data and request to be contacted or send an inquiry to the extent specified in the consent, or by ticking check-boxes.
In the case of the processing of Users’ data in connection with the submission of data in the framework of an inquiry for an offer, or a service visit, the User may withdraw his/her consent in this regard by informing the Information Center of the cancellation of further contact in this regard (loss of interest in the offer or service visit will be for us equivalent to the withdrawal of your consent).
For Users and Customers or Potential Customers of AUTO-BLAK, withdrawal of consents for future marketing purposes may be done at any time by using the withdrawal of consent form located on the website or by contacting AUTO-BLAK directly (contact details in Section I).
In other cases of consents obtained by AUTO-BLAK, you should follow the information indicated in the relevant information clauses or marketing correspondence.
The withdrawal of consent does not entail any negative consequences or unpleasantness – however, you must know that the withdrawal of consent may entail the inability to use services such as, for example, receiving responses, receiving offers or advertisements, invitations to events, open doors and technical reviews, for the provision of which we are required by law to obtain your consent.
Withdrawal of consent does not affect the lawfulness of the processing of personal data carried out on the basis of consent before its withdrawal.
A request for withdrawal of consent will be processed promptly. Once your request is fulfilled, we will stop processing your personal data for marketing purposes, including receiving marketing and commercial information by email and telephone. However, until your request is fulfilled, you may receive information from us that you have opted out of by withdrawing your consent, due to the time it takes for our systems to process your request.
If we hold Users’ data for other purposes (e.g., performance of a contract, service, proof of evidence, investigation of claims), we may continue to process them for these purposes on a different legal basis.
Regarding the management of consent to the installation and use of cookies, please refer to the Cookie Policy for more information.
VIII. Data storage
Data will be retained for as long as necessary to fulfill the purposes for which the data was collected. Where possible, we try to provide a concretized data retention period.
In the case of data processing based on consent, the data will be stored for the period of its validity, not more than 5 years (unless a shorter period is set) or until it is revoked.
In each case, however, the storage period may change, i.e. personal data may be kept longer if such an obligation arises from the law or it is necessary for the establishment, defense or assertion of claims (e.g. until the statute of limitations for claims, we may keep evidence of the consent given by the User), or shorter, e.g. in the case of fulfillment of a request for deletion of data.
The period of storage of personal data is determined in accordance with applicable law. The User has the right to obtain from us what is the planned and probable duration of storage of personal data.
Below we indicate the basic retention periods adopted for the indicated processes:
Request for quotation, Service appointment
For the period of time necessary to handle your request for a quotation, service visit, no longer than 6 months if you lose interest in the quotation, service visit and it does not materialize, or earlier if you withdraw your consent. If you complete the service visit, the retention period will be extended for a period appropriate for the duration of the continued business relationship and the duration of further processing of personal data, in connection with the contract and the statute of limitations for claims arising therefrom.
Submit a contact request
the period necessary for its service (no longer than 6 months if you abandon the call, lose interest in the offer, or earlier if you withdraw your consent; in the case of a complaint or guarantee – for the time necessary for its implementation and the statute of limitations for claims).
Future marketing (additional consents)
for the period during which those purposes arising from your consent remain valid, but no longer than 5 years from the last contact with you, and if you withdraw your consent then until you withdraw your consent
Provision of services by electronic means
For the duration of the contract
Other purposes based on legitimate interest
For the period of validity of these purposes or until you object, in any case no longer than 5 years, unless it is necessary to keep the data longer, when such obligation arises from the law or it is necessary to establish, defend or assert claims.
IX. Data co-management and data recipients
Co-administration
We would like to inform you that within the scope of joint purposes AUTO-BLAK Ltd. and AUTO-BLAK Marcin Kozyra carried out in the framework of joint processes or within the framework of a joint infrastructure, including the handling of requests for quotations, service visits, the execution of maintenance services, the sale of accessories and parts, the handling of complaints, warranties or claims, billing, reporting and internal auditing of the dealer network, customer service, maintenance of the customer database, quality control of customer service, your Data will be processed on a joint basis by AUTO-BLAK Ltd. and AUTO-BLAK Marcin Kozyra .
Each of the joint controllers may be involved in the processing of personal data of customers or potential customers at different stages and to varying degrees, sometimes pursuing their own individual objectives, which are closely interrelated. Ultimately, the common goal of AUTO-BLAK Ltd. and AUTO-BLAK Marcin Kozyra is to sell AUTO-BLAK products and services. Each of the joint controllers will be responsible in its own respect for the exercise of the rights of the data subjects, due to the fact that in addition to the common systems or platforms, customer or potential customer data may also be processed in independent processes or IT systems. Nevertheless, AUTO-BLAK can be contacted in any case.
To the extent that additional consent for future marketing purposes is received jointly for AUTO-BLAK Ltd. and AUTO-BLAK Marcin Kozyra , we inform you that in this respect they will be joint data controllers. In this case, requests for the exercise of rights and requests should be submitted to AUTO-BLAK directly.
Recipients of the data
In justified cases, your data may be made available to other data controllers if there is a valid legal basis for doing so (consent e.g. in the case of marketing, contract or legitimate interest), in particular in connection with the provision of IT services, or in the handling of complaints or claims; AUTO-BLAK in connection with the performance of a contract, the use of services, the performance of its own purposes in connection with the entity’s offering of insurance quotes.
We may also share your data with other recipients who are processors – providing services on our behalf and on our behalf, to whom we outsource activities that require processing in connection with the processing of personal data, in particular IT services, marketing services (marketing agencies, among others), market research, organization and execution of events, call centers, transportation, archiving, correspondence handling, auditors, professional advisors. In some cases, external entities providing services on our behalf may act as independent administrators, e.g., the Polish Post or other postal operators, payment transaction operators.
In justified cases, your data may also be made available to public administration bodies (e.g. prosecutor’s office, police, municipal police, government offices) and courts.
In terms of marketing purpose for the future, the recipients of your personal data as data processors may be entities also acting on behalf of and on behalf of AUTO-BLAK .
With regard to the transfer of data to data recipients in the use of cookies, you will find more information in the Cookies Policy.
We point out that in the event that the data recipients themselves and on their own behalf process personal data from the User, e.g. offer products and services through their own channels without AUTO-BLAK’s involvement, or perform services on their own behalf then they will become separate data controllers and to that extent bear their own responsibility for the processing of such personal data, not being subject to the terms of our Policy.
The Service may contain links to other websites of cooperating entities. When going to a third-party website, Users will be subject to the separate privacy and data protection policy for that website. Please refer to the privacy and data protection policies of the respective websites.
X. Processing of data outside the EEA
If, as part of the processing, your personal data will be transferred to recipients in third countries (outside the EEA), such as the United States, such transfers may take place on the basis of an adequacy decision taken by the European Commission, i.e. for organizations participating in the Privacy Shield program, or on the basis of standard contractual clauses in accordance with the European Commission’s decision, or on the basis of your explicit consent.
For more information in this regard, please contact our DPO.
XI. Data processing using cookies and other Internet technologies
In connection with the User’s use of the brand’s websites, AUTO-BLAK also collects data contained in system logs, cookies or uses other similar Internet technologies (e.g. codes, pixels, tags, plug-ins). For more information on the use of cookies and other Internet technologies, please see the Cookie Policy.
XII. Changes in Policy
AUTO-BLAK reserves the right to make changes to this policy, which may be due to the need to adapt to changes in legislation or applicable privacy standards, or to expand our offerings. Accordingly, AUTO-BLAK will inform of any changes with an appropriate announcement on its websites.
XIII. Price lists
Price lists and other information contained on the websites do not constitute a commercial offer. Due to emerging promotional campaigns, price changes are possible.
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