Privacy policy

The Privacy Policy set out below specifies the rules for saving and accessing data on Users' Devices used by the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users' personal data , which has been provided by them personally and voluntarily through the tools available on the Service.

§1 Definitions

1. Service - the website operating at https://arbalt.co.uk/
2. External Service - websites of partners, service providers or clients cooperating with the Administrator
3. Service / Data Administrator - the Administrator of the Service and the Data Administrator (hereinafter referred to as the Administrator) is Arbalt & Co, conducting business at: 8 Blanchard Close Woodley RG5 4XQ Poland, providing electronic services through the Service
4. User - a natural person for whom the Administrator provides electronic services through the Service.
5. Device - an electronic device together with software through which the User accesses the Service
6. Cookies - text data collected in the form of files placed on the User's Device
7. 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)
8. 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 and surname, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
9. Processing - means an operation or set of operations which is 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;
10. Restriction of processing - means the marking of stored personal data with the aim of limiting its future processing
11. Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal factors relating to a natural person, in particular to analyse or predict aspects concerning that natural person's work performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements
12. Consent - the data subject's consent means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
13. Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to, personal data transmitted, stored or otherwise processed
14. Pseudonymisation - means 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 is not attributed to an identified or identifiable natural person
15. Anonymisation - Data anonymisation is an irreversible process of data operations that destroys / overwrites "personal data", preventing identification of, or linking a given record to, a specific user or natural person.

§2 Data Protection Officer

1. Pursuant to Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.
2. In matters concerning data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

1. Internal Cookies - files placed and read from the User's Device by the ICT system of the Service
2. External Cookies - files placed 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 on the Service through scripts and services made available and installed on the Service
3. Session Cookies - files placed and read from the User's Device by the Service during one session of a given Device. After the session ends, the files are deleted from the User's Device.
4. 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 Device session ends unless the User's Device configuration is set to delete Cookies after the Device session ends.

§4 Data storage security

1. Cookie storage and reading mechanisms - 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 web browser mechanisms and do not allow any other data to be downloaded 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.
2. Internal Cookies - the Cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content or information that may threaten the security of personal data or the security of the Device used by the User.
3. External Cookies - the Administrator takes all possible actions to verify and select service partners in the context of Users' security. The Administrator selects well-known, large partners with global public trust for cooperation. However, the Administrator does not have full control over the content of Cookies originating from external partners. The Administrator shall not be liable, to the extent permitted by law, for the security of Cookies, their content, or their licensed use by Scripts installed on the Service and originating from External Services. The list of partners is included later in this Privacy Policy.
4. Cookie control
   1. The User may at any time independently change the settings regarding the saving, deletion and access to data stored in Cookies by this website using its built-in Cookie management module.
   2. At the same time, the user may use the global cookie disabling options in the most popular browsers:
      • Managing cookies in the Chrome browser
      • Managing cookies in the Opera browser
      • Managing cookies in the FireFox browser
      • Managing cookies in the Edge browser
      • Managing cookies in the Safari browser
      • Managing cookies in the Internet Explorer 11 browser
   3. The User may at any time delete all Cookies stored so far using the tools of the User's Device through which the User uses the Service.
5. Threats on the User's side - 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 such data depends on both parties, including the activity of the User. The Administrator is not responsible for interception of this data, impersonation of the User's session, or deletion of such data as a result of the User's conscious or unconscious activity, viruses, trojans and other spyware with which the User's Device may be or has been infected. To protect themselves against these threats, Users should follow the recommendations for safe use of the Internet.
6. Storage of personal data - the Administrator ensures that every effort is made to keep personal data processed and voluntarily entered by Users secure, that access to it is limited and carried out in accordance with its intended purpose and processing objectives. The Administrator also ensures that every effort is made to protect the data held against loss through the use of appropriate physical and organisational safeguards.

§5 Purposes for which Cookies are used

1. Improving and facilitating access to the Service
2. Personalisation of the Service for Users
3. Marketing, Remarketing in external services
4. Keeping statistics (users, number of visits, types of devices, connection, etc.)
5. Providing multimedia services
6. Providing social media services

§6 Purposes of personal data processing

1. Personal data voluntarily provided by Users is processed for one of the following purposes:
   1. Provision of electronic services:
      • Newsletter services (including sending advertising content with consent)
      • Services for sharing information about content posted on the Service on social networking services or other websites.
   2. Communication between the Administrator and Users in matters related to the Service and data protection
   3. Ensuring the Administrator's legitimate interest
2. Data about Users collected anonymously and automatically is processed for one of the following purposes:
   1. Keeping statistics
   2. Remarketing
   3. Ensuring the Administrator's legitimate interest

§7 Cookies of External Services

1. The Administrator uses javascript scripts and web components of partners within the Service, which may place their own cookies on the User's Device. Please remember that in your browser settings you can decide 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:

   1. Multimedia services:
      • YouTube
      • Vimeo
   2. Social / integrated services:
      (Registration, Login, content sharing, communication, etc.)
      • Twitter
      • Facebook
      • Google+
      • LinkedIn
   3. Newsletter services:
      • GetResponse
   4. Keeping statistics:
      • Google Analytics
      • Ahrefs
   5. Other services:
      • Google Maps
2. Services provided by third parties are beyond the Administrator's control. These entities may change their terms of service, privacy policies, data processing purposes and methods of using cookies at any time.

§8 Types of collected data

1. The Service collects data about Users. Some of the data is collected automatically and anonymously, while some of the data is personal data voluntarily provided by Users when signing up for individual services offered by the Service.
   1. Anonymous data collected automatically:
      • IP address
      • Browser type
      • Screen resolution
      • Approximate location
      • Opened subpages of the service
      • Time spent on a given subpage of the service
      • Type of operating system
      • Address of the previous subpage
      • Referring page address
      • Browser language
      • Internet connection speed
      • Internet service provider
   2. Data collected during registration:
      • First name / surname / nickname
      • Email address
      • Phone number
      • IP address (collected automatically)
      • Tax identification number (NIP)
      • National Court Register number (KRS)
      • REGON number
   3. Data collected when subscribing to the Newsletter service
      • First name / surname / nickname
      • Email address
      • IP address (collected automatically)
2. Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to a provider of statistical services.

§9 Access to personal data by third parties

1. As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the provided services is not transferred or resold to third parties.
2. Access to data (most often on the basis of a data processing agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to operate the service, i.e.:
   1. Hosting companies providing hosting or related services to the Administrator
   2. Companies through which the Newsletter service is provided
   3. IT service and support companies performing maintenance or responsible for maintaining the IT infrastructure
   4. Companies responsible for the Administrator's accounting (if paid Administrator Services are used)
   5. Companies responsible for delivering physical products to the User (postal / courier services when it is necessary to send information in writing)
3. Entrusting the processing of personal data:
   1. Newsletter - in order to provide the Newsletter service, the Administrator uses the services of a third party - the GetResponse service. Data entered in the newsletter subscription form is transferred, stored and processed in the external service of this provider.
      Please note that the indicated partner may modify the indicated privacy policy without the Administrator's consent.
   2. Hosting, VPS or Dedicated Server services - in order to operate the service, the Administrator uses the services of an external hosting, VPS or Dedicated Server provider - ABHOST Sp. z o.o. All data collected and processed in the service is stored and processed in the provider's infrastructure located within the borders of the European Union. There is a possibility of access to data as a result of service work carried out by the provider's personnel. Access to this data is governed by an agreement concluded between the Administrator and the Service Provider.
   3. Website maintenance services - in order to maintain the service, the Administrator uses the services of an external service provider - ABHOST Sp. z o.o. . Personnel of the indicated entity have access to data entered by users during registration and editing of the user account and/or data relating to the Newsletter service. Access to this data is governed by an agreement concluded between the Administrator and the Service Provider.
4. Transfer of personal data:
   1. Accounting services - in the event of concluding a transaction, part of the personal data of natural persons or data of natural persons conducting business activity is transferred to an entity providing accounting services to the Administrator. The transfer of this data is governed by the Act and the agreement concluded between the Administrator and the Service Provider.
   2. Courier services - in the event of concluding a transaction that requires transfer of the object to which the transaction related via post or courier, part of the personal data of natural persons or data of natural persons conducting business activity is transferred to an entity providing postal / courier services to the Administrator, selected by the User. The transfer of this data is governed by the agreement concluded between the Administrator and the Service Provider.

§10 Method of processing personal data

1. Personal data voluntarily provided by Users:
   1. Personal data will not be transferred outside the European Union unless it has been published as a result of an individual action by the User (e.g. entering a comment or post), which will make the data available to anyone visiting the service.
   2. Personal data will not be used for automated decision-making (profiling).
   3. Personal data will not be resold to third parties.
2. Anonymous data (without personal data) collected automatically:
   1. Anonymous data (without personal data) will be transferred outside the European Union.
   2. Anonymous data (without personal data) will not be used for automated decision-making (profiling).
   3. Anonymous data (without personal data) will not be resold to third parties.

§11 Legal bases for processing personal data

1. The Service collects and processes Users' data on the basis of:
   1. 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 his or her 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
   2. Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018 item 1000)
   3. Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171 item 1800)
   4. Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No. 24 item 83)

§12 Period of personal data processing

1. Personal data voluntarily provided by Users:

   As a rule, the indicated personal data is stored only for the period of providing the Service within the Service by the Administrator. It is deleted or anonymised within up to 30 days from the moment the provision of services ends (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

   An exception is a situation that requires securing the Administrator's legitimate purposes for further processing of this data. In such a situation, the Administrator will store the indicated data, from the time of the User's request for its deletion, for no longer than 3 years in the case of a breach or suspected breach of the provisions of the service regulations by the User

2. Anonymous data (without personal data) collected automatically:

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

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

1. The Service collects and processes Users' data on the basis of:
   1. Right of access to personal data - Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator
   2. Right to rectification of personal data - Users have the right to request that the Administrator immediately rectify personal data that is inaccurate and / or complete incomplete personal data, exercised upon request submitted to the Administrator
   3. Right to erasure of personal data - Users have the right to request that the Administrator immediately erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, erasure of data consists in anonymising data enabling identification of the User. The Administrator reserves the right to suspend implementation of the data erasure request in order to protect the Administrator's legitimate interest (e.g. when the User has breached the Terms and Conditions or the data has been obtained as a result of correspondence conducted).
      In the case of the Newsletter service, the User may independently delete his or her personal data using the link included in each email message sent.
   4. 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 challenging the accuracy of personal data, exercised upon request submitted to the Administrator
   5. Right to data portability - Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used, machine-readable format, exercised upon request submitted to 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 Art. 21 GDPR, exercised upon request submitted to the Administrator
   7. Right to lodge a complaint - Users have the right to lodge a complaint with the supervisory authority dealing with personal data protection.

§14 Contact details of the Administrator

1. The Administrator may be contacted in one of the following ways
   1. Postal address - 8 Blanchard Close Woodley RG5 4XQ Poland
   2. Email address - hello@arbalt.co.uk
   3. Telephone call - +44 7714775906
   4. Contact details - available at: https://arbalt.co.uk/#contact

§15 Service requirements

1. Restricting the saving and access to Cookies on the User's Device may result in incorrect operation of some functions of the Service.
2. The Administrator bears no responsibility whatsoever for incorrectly functioning features of the Service if the User restricts in any way the ability to save and read Cookies.

§16 External links

1. Within the Service - in articles, posts, entries or Users' comments - there may be links to external websites with which the Service Owner does not cooperate. These links and the websites or files indicated by them may be dangerous to your Device or may pose a threat to the security of your data. The Administrator is not responsible for content located outside the Service.

§17 Changes to the Privacy Policy

1. The Administrator reserves the right to change this Privacy Policy at any time without informing Users in the scope of using and processing anonymous data or using Cookies.
2. The Administrator reserves the right to change this Privacy Policy at any time with regard to the processing of Personal Data, of which Users with user accounts or subscribed to the newsletter service will be informed by email within 7 days from the change of the provisions. Continued use of the services means that the User has read and accepted the introduced changes to the Privacy Policy. If the User does not agree to the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
3. Any changes introduced to the Privacy Policy will be published on this subpage of the Service.
4. The introduced changes come into force upon their publication.