Privacy Policy

This Privacy Policy sets out the rules for storing and accessing data on the Devices of Users who use the Service for the purpose of the electronic services provided by the Controller, and the rules for collecting and processing Users' personal data, which they provided personally and voluntarily through the tools available in the Service.

This Privacy Policy is an integral part of the Terms of Service, which set out the rules, rights and obligations of Users of the Service.

§1 Definitions

  • Service - the "drinkify.pl" website operating at https://drinkify.pl

  • External service - websites of partners, service providers or service recipients cooperating with the Controller

  • Service / Data Controller - the Controller of the Service and the Data Controller (hereinafter the Controller) is a natural person providing electronic services through the Service

  • User - a natural person for whom the Controller 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 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 - any information relating to 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 - any operation or set of operations 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 - the marking of stored personal data with the aim of limiting their processing in the future

  • Profiling - 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 analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, 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 they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them

  • Personal data breach - 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 - 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 - the irreversible processing of data that destroys / overwrites "personal data", making it impossible to identify or link a given record to a specific user or natural person.

§2 Data Protection Officer

Pursuant to Art. 37 GDPR, the Controller has not appointed a Data Protection Officer.

In matters concerning the processing of data, including personal data, please contact the Controller directly.

§3 Types of Cookies

  • Internal cookies - files placed on and read from the User's Device by the Service's ICT system

  • External cookies - files placed on and read from the User's Device by the ICT systems of External services. Scripts of External services that may place cookies on Users' Devices have been knowingly placed in the Service through scripts and services made available and installed in the Service

  • Session cookies - files placed on and read from the User's Device by the Service during a single session of that Device. When the session ends, the files are deleted from the User's Device.

  • Persistent cookies - files placed on and read from the User's Device by the Service until they are deleted manually. The files are not deleted automatically when the Device session ends, unless the User's Device is configured to delete cookies at the end of the Device session.

§4 Data storage security

  • Cookie storage and reading mechanisms - The mechanisms for storing, reading and exchanging data between the Cookies saved on the User's Device and the Service are implemented through the built-in mechanisms of web browsers and do not allow other data to be collected from the User's Device or data of other websites the User has visited, including personal data or confidential information. Transferring viruses, trojans or other worms to the User's Device is also practically impossible.

  • Internal cookies - the cookies used by the Controller 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 the User uses.

  • External cookies - the Controller takes all possible steps to verify and select the Service's partners with Users' security in mind. The Controller selects well-known, large partners with global public trust. However, the Controller does not have full control over the content of cookies originating from external partners. To the extent permitted by law, the Controller is not responsible for the security of cookies, their content and their licence-compliant use by Scripts installed in the Service that originate from External services. The list of partners is provided further in this Privacy Policy.

  • Cookie control

  • Risks on the User's side - The Controller applies all possible technical measures to ensure the security of the data placed in Cookies. Note, however, that ensuring the security of this data depends on both parties, including the User's conduct. The Controller is not responsible for the interception of this data, impersonation of the User's session or its deletion as a result of the User's conscious or unconscious actions, viruses, trojans or other spyware with which the User's Device is or was infected. To protect themselves against these risks, Users should follow the principles of safe internet use.

  • Storage of personal data - The Controller declares that every effort is made to ensure that the personal data voluntarily entered by Users is secure, that access to it is restricted and carried out in accordance with its intended use and the purposes of processing. The Controller also declares that every effort is made to protect the data held against loss through appropriate physical and organisational safeguards.

  • Storage of passwords - The Controller declares that passwords are stored in encrypted form, using the latest standards and guidelines in this area. Decrypting account passwords provided in the Service is practically impossible.

§5 Purposes for which Cookies are used

  • Improving and facilitating access to the Service
  • Personalising the Service for Users
  • Enabling login to the Service
  • Keeping statistics (users, number of visits, types of devices, connection, etc.)

§6 Purposes of processing personal data

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

  • Provision of electronic services:
    • Registration and maintenance of the User's account in the Service and related functionality
    • Newsletter service (including sending advertising content with consent)
  • Communication between the Controller and Users in matters related to the Service and data protection
  • Ensuring the legitimate interest of the Controller

Data about Users collected anonymously and automatically is processed for one of the following purposes:

  • Keeping statistics
  • Ensuring the legitimate interest of the Controller

§7 Cookies of External services

In the Service the Controller uses JavaScript scripts and web components of partners that may place their own cookies on the User's Device. Remember that in your browser settings you can decide for yourself which cookies may be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

Services provided by third parties are beyond the Controller's control. These entities may at any time change their terms of service, privacy policies, purpose of data processing and the way they use cookies.

§8 Types of data collected

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

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Pages of the Service opened
  • Time spent on a given page of the Service
  • Operating system type
  • Address of the previous page
  • Referring page address
  • Browser language
  • Internet connection speed
  • Internet service provider
  • Demographic data (age, gender)

Data collected during registration:

  • Email address
  • IP address (collected automatically)

Data collected when subscribing to the Newsletter

  • Email address
  • IP address (collected automatically)

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

§9 Access to personal data by third parties

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

Access to the data (usually under a data processing agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the Service, i.e.:

  • Hosting companies providing hosting or related services to the Controller
  • Companies intermediating online payments for goods or services offered within the Service (when a purchase transaction is made in the Service)

Entrusting the processing of personal data - Hosting, VPS or Dedicated Server services

To run the Service, the Controller uses the services of an external hosting, VPS or dedicated server provider - OVH sp. z o.o.. All data collected and processed in the Service is stored and processed in the provider's infrastructure located outside the European Union. Access to the data is possible as a result of maintenance work carried out by the provider's staff. Access to this data is governed by the agreement between the Controller and the Provider.

Data processing for online payments

When an online payment is made, all payment data is provided by the User directly to the entity processing the payment - Stripe. Selected data necessary to complete the transaction is then passed on by that entity to the Controller. The transfer of data is governed by the agreement between the Controller and the Provider.

§10 How personal data is processed

Personal data voluntarily provided by Users:

  • Personal data is transferred outside the European Union. The transfer of data outside the EU results from the use of services of entities located outside the EU, or from publication as a result of the User's individual action (e.g. entering a comment or post), which makes the data available to anyone visiting the Service. Where personal data is transferred or its processing entrusted outside the EU, the data is processed under an agreement between the Controller and the Provider.
  • Personal data will not be used for automated decision-making (profiling).
  • 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) will not be used for automated decision-making (profiling).
  • Anonymous data (without personal data) will not be sold to third parties.

§11 Legal bases for processing personal data

The Service collects and processes Users' data on the basis of:

  • 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)
    • Art. 6(1)(a)the data subject has given consent to the processing of their personal data for one or more specific purposes
    • Art. 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
    • Art. 6(1)(f)processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
  • The Polish Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
  • The Polish Telecommunications Act of 16 July 2004 (Journal of Laws 2004 No. 171, item 1800)
  • The Polish 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 voluntarily provided by Users:

As a rule, the indicated personal data is stored only for the period during which the Controller provides the Service. It is deleted or anonymised within 30 days of the end of service provision (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation that requires securing the legally justified purposes of further processing of this data by the Controller. In such a situation the Controller will retain the indicated data, from the time the User requests its deletion, for no longer than 3 years in the event of a breach or suspected breach of the Service's terms by the User

Anonymous data (without personal data) collected automatically:

Anonymous statistical data that does not constitute personal data is stored by the Controller for the purpose of keeping Service statistics for an indefinite period

§13 Users' rights related to the processing of personal data

Users have the following rights:

  • Right of access to personal data Users have the right to obtain access to their personal data, exercised upon a request submitted to the Controller

  • Right to rectification of personal data Users have the right to request that the Controller promptly rectify inaccurate personal data and/or complete incomplete personal data, exercised upon a request submitted to the Controller

  • Right to erasure of personal data Users have the right to request that the Controller promptly erase their personal data, exercised upon a request submitted to the Controller. For user accounts, erasure consists of anonymising the data that makes it possible to identify the User. The Controller reserves the right to suspend the execution of an erasure request in order to protect the Controller's legitimate interest (e.g. when the User has breached the Terms or the data was obtained through correspondence). For the Newsletter service, the User can delete their personal data on their own using the link included in every email sent.

  • Right to restriction of processing of personal data Users have the right to restrict the processing of personal data in the cases indicated in Art. 18 GDPR, including contesting the accuracy of the personal data, exercised upon a request submitted to the Controller

  • Right to data portability Users have the right to receive from the Controller the personal data concerning the User in a structured, commonly used and machine-readable format, exercised upon a request submitted to the Controller

  • 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 GDPR, exercised upon a request submitted to the Controller

  • Right to lodge a complaint Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.

§14 Contacting the Controller

The Controller can be contacted in one of the following ways

§15 Service requirements

  • Restricting the saving of and access to Cookies on the User's Device may cause some functions of the Service to work incorrectly.

  • The Controller accepts no responsibility for Service functions that work incorrectly when the User restricts in any way the ability to save and read Cookies.

§16 External links

The Service - in articles, posts, entries or Users' comments - may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files they point to may be dangerous for your Device or pose a threat to the security of your data. The Controller is not responsible for content located outside the Service.

§17 Changes to the Privacy Policy

  • The Controller reserves the right to change this Privacy Policy at any time without having to inform Users, with regard to the use of anonymous data or the use of Cookies.

  • The Controller reserves the right to change this Privacy Policy at any time with regard to the processing of Personal Data, of which Users holding user accounts or subscribed to the newsletter service will be informed by email within 7 days of the change. Continued use of the services means that the User has read and accepted the changes to the Privacy Policy. If the User does not agree with the changes, they must delete their account from the Service or unsubscribe from the Newsletter service.

  • Changes to the Privacy Policy will be published on this page of the Service.

  • Changes take effect upon publication.