The following Privacy Policy defines the rules for storing and accessing data on Users' Devices using the Service for the purpose of providing electronic services by the Administrator and the rules for collecting and processing personal data of Users, which have been provided by them personally and voluntarily through tools available in the Service.

§1 Definitions

1. Service - the website operating at https://valdepaws.ch/
2. External Service - websites of partners, service providers, or recipients cooperating with the Administrator
3. Service Administrator / Data Administrator - The Administrator of the Service and the Administrator of Data (hereinafter referred to as the Administrator) is Katarzyna Biolley, conducting business at: Rue des Tieulls 11, 2206 Les Geneveys sur Coffrane, Switzerland, 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 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, 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
9. Processing - means any 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 their processing in the future
11. Profiling - means 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
12. Consent - consent of the data subject 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 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 are 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" making it impossible to identify or link a given record to a specific user or natural person.

§2 Data Protection Officer

1. Pursuant to Art. 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 Service's IT system
2. External Cookies - files placed and read from the User's Device by the IT systems of External Services. Scripts of External Services that may place Cookies on the User's Device have been deliberately placed in the Service through scripts and services made available and installed in the Service
3. Session Cookies - files placed and read from the User's Device by the Service during a single session of the Device. After the session ends, the files are removed 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 implemented through built-in web browser mechanisms and do not allow for the retrieval of other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojan horses, 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 could threaten the security of personal data or the security of the Device used by the User.
3. External Cookies - The Administrator makes every effort to verify and select service partners in terms of User security. The Administrator chooses well-known, large partners with global social trust. However, the Administrator does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the security of Cookies, their content, or their licensed use by scripts installed in the service, originating from External Services, to the extent permitted by law. The list of partners is included in the further part of the Privacy Policy.
4. Cookie Control
   1. The User can at any time independently change the settings for saving, deleting, and accessing data stored in Cookies by this website using the built-in Cookie management module.
   2. At the same time, the User can use the global option to disable Cookies 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 can at any time delete all Cookies saved to date using the tools of the User's Device through which the User uses the Service's services.
5. User-Side Risks - The Administrator uses all possible technical measures to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User's activities. The Administrator is not responsible for the interception of this data, impersonation of the User's session, or their deletion as a result of the User's conscious or unconscious activity, viruses, Trojan horses, and other spyware with which the User's Device may be or has been infected. Users should follow recommendations for safe internet use to protect themselves against these threats.
6. Personal Data Storage - The Administrator ensures that it makes every effort to ensure that the personal data voluntarily provided by Users is secure, access to it is limited, and carried out in accordance with their purpose and processing objectives. The Administrator also ensures that it makes every effort to protect the data it holds from loss through the use of appropriate physical and organisational safeguards.

§5 Purposes for Which Cookies Are Used

1. Streamlining and facilitating access to the Service
2. Personalising the Service for Users
3. Marketing, Remarketing on external services
4. Conducting statistics (users, number of visits, types of devices, connection, etc.)
5. Serving multimedia services
6. Providing social 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 in social media or other websites.
   2. Communication between the Administrator and Users regarding matters related to the Service and data protection
   3. Ensuring the legally justified interest of the Administrator
2. Data about Users collected anonymously and automatically is processed for one of the following purposes:
   1. Conducting statistics
   2. Remarketing
   3. Ensuring the legally justified interest of the Administrator

§7 Cookies of External Services

1. The Administrator uses javascript scripts and web components of partners in the Service, who may place their own cookies on the User's Device. Remember that in your browser settings, you can decide which cookies are allowed to 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. Conducting statistics:
      • Google Analytics
      • Ahrefs
   5. Other services:
      • Google Maps
2. Services provided by third parties are beyond the Administrator's control. These entities may at any time change their terms of service, privacy policies, purpose of data processing, and methods of using cookies.

§8 Types of Data Collected

1. The Service collects data about Users. Some data is collected automatically and anonymously, and some data is personal data provided voluntarily by Users when signing up for specific 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 the relevant 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 / last name / nickname
      • Email address
      • Phone number
      • IP address (collected automatically)
      • Tax Identification Number (NIP)
      • National Court Register number (KRS)
      • Business Identification Number (REGON)
   3. Data collected when subscribing to the Newsletter service
      • First name / last name / nickname
      • Email address
      • IP address (collected automatically)
2. Some data (without identifying information) may be stored in cookies. Some data (without identifying information) may be transferred to the statistics service provider.

§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 services provided are not transferred or resold to third parties.
2. Access to data (most often under a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the service, such as:
   1. Hosting companies providing hosting or related services for the Administrator
   2. Companies through which the Newsletter service is provided
   3. IT service and support companies performing maintenance or responsible for maintaining IT infrastructure
   4. Companies responsible for the Administrator's accounting (in case of using paid Administrator Services)
   5. Companies responsible for delivering physical products to the User (postal / courier services in case of need to send information in writing)
3. Entrusting the processing of personal data:
   1. Newsletter - To provide the Newsletter service, the Administrator uses the services of a third party - the GetResponse service. Data entered in the newsletter subscription form are transferred, stored, and processed in the external service of this provider.
      We inform you that the indicated partner may modify the indicated privacy policy without the Administrator's consent.
   2. Hosting, VPS, or Dedicated Server Services - 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 are 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 maintenance work performed by the provider's staff. Access to this data is regulated by the agreement between the Administrator and the Service Provider.
   3. Website operation services - To operate the service, the Administrator uses the services of an external provider - ABHOST Sp. z o.o.. The staff of the indicated entity has access to data entered by users during registration and account editing and/or data related to the Newsletter service. Access to this data is regulated by the agreement between the Administrator and the Service Provider.
4. Transfer of personal data:
   1. Accounting Services - In the case of a transaction, part of the personal data of natural persons or data of natural persons conducting business activity is transferred to the entity providing accounting services for the Administrator. The transfer of this data is regulated by the Law and the agreement between the Administrator and the Service Provider.
   2. Courier Services - In the case of a transaction that requires the transfer of the subject of the transaction by post or via courier, part of the personal data of natural persons or data of natural persons conducting business activity is transferred to the entity providing postal / courier services for the Administrator, chosen by the User. The transfer of this data is regulated by the agreement 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 they have 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 User 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 are stored only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymised within up to 30 days from the cessation of the service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.)

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

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

   Anonymous statistical data, not constituting personal data, are stored by the Administrator for the purpose of service statistics for an indefinite period.

§13 User Rights Related to the Processing of Personal Data

1. The Service collects and processes User 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 the Administrator to immediately rectify personal data that is incorrect or / and to complete incomplete personal data, exercised upon request submitted to the Administrator
   3. Right to erasure of personal data - Users have the right to request the Administrator to immediately erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, data deletion involves anonymising data enabling the identification of the User. The Administrator reserves the right to suspend the execution of the data deletion request to protect the legally justified interest of the Administrator (e.g., when the User has violated the Terms and Conditions or the data was obtained as a result of correspondence).
      In the case of the Newsletter service, the User can delete their personal data themselves using the link included in each email message.
   4. Right to restriction of processing - Users have the right to restrict the processing of personal data in the cases indicated in Art. 18 of the GDPR, e.g., questioning 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 them 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 of the 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 the protection of personal data.

§14 Contact to the Administrator

1. The Administrator can be contacted in one of the following ways:
   1. Postal address - Katarzyna Biolley, Rue des Tieulls 11, 2206 Les Geneveys sur Coffrane, Switzerland
   2. Email address - [email protected]​
   3. Phone call - +41795687712
   4. Contact form - available at: https:// valdepaws.ch/contacts#contact

§15 Service Requirements

1. Restricting the saving and access to Cookies on the User's Device may cause some functions of the Service to malfunction.
2. The Administrator is not responsible for malfunctioning Service functions if the User restricts in any way the possibility of saving and reading Cookies.

§16 External Links

1. In the Service - articles, posts, entries, or comments by Users, there may be links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated under them may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content 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 about it regarding the use and use of anonymous data or the use of Cookies.
2. The Administrator reserves the right to change this Privacy Policy at any time regarding the processing of Personal Data, about which Users with user accounts or subscribed to the newsletter service will be informed via email within 7 days of the changes. Continued use of the services means familiarisation and acceptance of the introduced changes to the Privacy Policy. If the User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
3. Introduced changes to the Privacy Policy will be published on this subpage of the Service.
4. Introduced changes come into force upon their publication.