Privacy Policy

The following Privacy Policy sets out the rules for storing and accessing data on Users’ Devices when using 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 have been provided by them personally and voluntarily via the tools available in the Service.

§1 Definitions

Service – the website “primewindow.eu” operating at the address https://primewindow.eu
External Service – the websites of partners, service providers, or service recipients cooperating with the Administrator
Service / Data Administrator – The Administrator of the Service and the Data Administrator (hereinafter referred to as the Administrator) is the company “Prime Window,” operating at the address: Permanent place of business activity: Silesian Voivodeship, Wodzisław County, Rydułtowy Municipality, Rydułtowy, ul. Adama Mickiewicza, No. 24, premises 16, 44-280, with the assigned tax identification number (NIP): 6472484451, providing electronic services via the Service
User – a natural person for whom the Administrator provides electronic services via the Service.
Device – an electronic device along with software, through which the User gains access to 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 – means 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 – 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;
Restriction of processing – means the marking of stored personal data with the aim of limiting their processing in the future
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
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
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
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
Anonymisation – Data anonymisation is an irreversible process of data operations that destroys / overwrites “personal data”, preventing the identification or linking of a given record with a specific user or natural person.

§2 Data Protection Officer

Pursuant to Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

In matters relating to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

Internal Cookies – files placed and read from the User’s Device by the ICT system of the Service
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 the User’s Devices have been consciously placed in the Service via scripts and services provided and installed in the Service
Session Cookies – files placed and read from the User’s Device by the Service or External Services during a single session of that Device. After the session ends, the files are deleted from the User’s Device.
Persistent Cookies – files placed and read from the User’s Device by the Service or External Services 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 Cookie files after the Device session ends

§4 Data Storage Security

Cookie Storage and Reading Mechanisms – The mechanisms for storing, reading, and exchanging data between the Cookie Files saved on the User’s Device and the Service are executed through the built-in mechanisms of web browsers 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 transmission of viruses, Trojan horses, and other malware to the User’s Device is also practically impossible.
Internal Cookies – The Cookie files 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.
External Cookies – The Administrator takes all possible steps to verify and select Service partners in the context of User safety. The Administrator selects known, large partners with global social trust for cooperation. However, the Administrator does not have full control over the content of Cookie files originating from external partners. The Administrator is not responsible for the security of Cookie files, their content, or their licensed use by Scripts installed in the Service originating from External Services, to the extent permitted by law. A list of partners is provided later in the Privacy Policy.
Cookie Control
- The User may, at any time, independently change the settings regarding the storing, deleting, and accessing of data saved in Cookies by any website
- Information on how to disable Cookies in the most popular computer browsers is available on the following website: how to disable cookies or from one of the indicated providers:
- The User may, at any time, delete all previously saved Cookie files using the tools of the User’s Device through which the User uses the services of the Service.
Threats on the User’s Side – The Administrator uses all possible technical means to ensure the security of the data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Administrator is not responsible for the interception of this data, impersonation of the User’s session, or their deletion, as a result of conscious or unconscious User activity, viruses, Trojan horses, and other spyware with which the User’s Device may be or has been infected. To protect against these threats, Users should follow the recommendations for safe internet use.
Storage of Personal Data – The Administrator ensures that all efforts are made to ensure that the personal data voluntarily entered by Users is secure, that access to it is restricted, and that it is processed in accordance with its purpose and processing goals. The Administrator also ensures that all efforts are made to protect the possessed data against its loss, by applying appropriate physical and organizational safeguards.

§5 Purposes for which Cookie files are used

Improving and facilitating access to the Service
Personalisation of the Service for Users
Enabling login to the service
Marketing, Remarketing on external services
Ad serving services
Keeping statistics (users, number of visits, types of devices, connection, etc.)
Provision of social services
Provision of social services

§6 Purposes of Personal Data Processing

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

Execution of electronic services:
- Registration and maintenance services for the User account in the Service and related functionalities
- Newsletter Services (including the transmission of advertising content with consent)
- Services for sharing information about content placed in the Service on social media or other websites.
Communication between the Administrator and Users in matters related to the Service and data protection
Ensuring the Administrator’s legitimate interest

User data collected anonymously and automatically is processed for one of the following purposes:

Keeping statistics
Remarketing
Serving advertisements tailored to User preferences
Ensuring the Administrator’s legitimate interest

§7 External Service Cookies

The Administrator uses javascript scripts and web components of partners in the Service, who may place their own cookie files on the User’s Device. Remember that you can independently decide on the allowed cookie files that may be used by individual websites in your browser settings. Below is a list of partners or their services implemented in the Service that may place cookie files:

Multimedia services:
Social / integrated services: (Registration, Login, content sharing, communication, etc.)
- Facebook
Usługi Newslettera:
- MailChimp
Ad serving and affiliate network services:
- Google Adsense
Statistical analysis:
- Google Analytics

Services provided by third parties are outside the Administrator’s control. These entities may change their terms of service, privacy policies, data processing purposes, and methods of using cookie files at any time.

§8 Types of Data Collected

The Service collects User data. Part of the data is collected automatically and anonymously, and part of the data consists of personal data provided voluntarily by Users when subscribing to individual services offered by the Service.

Anonymous data collected automatically:

Adress IP
Approximate location
Screen resolution
Approximate location
Subpages of the service being opened
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
Demographic data (age, gender)

Data collected during registration:

First name / last name / nickname
Login
E-mail address
IP address (collected automatically)

Data collected during subscription to the Newsletter service

First name / last name / nickname
E-mail address
IP address (collected automatically)

Some data (without identifying data) may be stored in cookie files. Some data (without identifying data) may be transferred to the provider of statistical services.

§9 Access to personal data by third parties

As a rule, the sole recipient of personal data provided by Users is the Administrator. Data collected within the scope of services rendered is neither transferred nor resold to third parties.

Access to data (most often based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary for running the Service, namely:

Hosting companies providing hosting or related services to the Administrator
Companies through which the Newsletter service is provided

Entrustment of personal data processing – Newsletter

In order to provide the Newsletter service, the Administrator uses the services of a third-party entity – the MailChimp service. Data entered in the newsletter subscription form is transferred, stored, and processed in the external service of this provider.

We inform you that the indicated partner may modify the specified privacy policy without the Administrator’s consent.

Entrustment of personal data processing – Hosting, VPS, or Dedicated Server Services

The Administrator uses the services of an external provider of hosting, VPS, or Dedicated Servers to run the Service – SEOHOST Sp. z o.o. . All data collected and processed in the service is stored and processed within the service provider’s infrastructure located within the borders of the European Union. Access to the data may occur due to maintenance work carried out by the service provider’s personnel. Access to this data is regulated by an agreement concluded between the Administrator and the Service Provider.

§10 Method of Personal Data Processing

Personal data provided voluntarily by Users:

Personal data will not be transferred outside the European Union, unless they have been published as a result of the User’s individual action (e.g., entering a comment or post), which will make the data available to every person visiting the service.
Personal data will not be used for automated decision-making (profiling).
Personal data will not be resold 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 resold to third parties.

§11 Legal Bases for Personal Data Processing

The Service collects and processes User data based on:

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 administrator or by a third party
Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018 item 1000)
Act of 16 July 2004 – Telecommunications Law (Journal of Laws 2004 No. 171 item 1800)
Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24 item 83)

§12 Personal Data Processing Period

Personal data provided voluntarily by Users:

As a rule, the indicated personal data are stored only for the duration of the Service provision within the Service by the Administrator. They are deleted or anonymized within 30 days from the moment the service provision ends (e.g., deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception applies where the situation requires safeguarding the Administrator’s legitimate interests for the 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 their deletion, for no longer than 3 years in the event of a breach or suspected breach of the service regulations by the User

Anonymous data (without personal data) collected automatically:

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

§13 User Rights related to Personal Data Processing

The Service collects and processes User data based on:

Right of access to personal data
Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator
Right to rectification of personal data
Users have the right to demand the Administrator to immediately rectify personal data that is inaccurate or / and to complete incomplete personal data, exercised upon request submitted to the Administrator
Right to erasure of personal data
Users have the right to demand the Administrator to immediately erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, data erasure involves the anonymisation of data allowing the identification of the User. The Administrator reserves the right to withhold the fulfillment of the erasure request in order to protect the Administrator’s legitimate interest (e.g., when the User has breached the Regulations or data was obtained as a result of ongoing correspondence).
In the case of the Newsletter service, the User has the option to independently delete their personal data by using the link placed in every e-mail message sent.
Right to restriction of personal data processing
Users have the right to restrict the processing of personal data in cases specified in Article 18 of the GDPR, including questioning the accuracy of the personal data, exercised upon request submitted to the Administrator
Right to data portability
Users have the right to receive from the Administrator the personal data concerning the User in a structured, commonly used and machine-readable format, exercised upon request submitted to the Administrator
Right to object to the processing of personal data
Users have the right to object to the processing of their personal data in cases specified in Article 21 of the GDPR, exercised upon request submitted to the Administrator
Right to lodge a complaint
Users have the right to lodge a complaint with the supervisory authority dealing with personal data protection.

§14 Contact Information of the Administrator

The Administrator can be contacted in one of the following ways

Address – Prime Window, Permanent place of business activity: Silesian Voivodeship, Wodzisław County, Rydułtowy Municipality, Rydułtowy, ul. Adama Mickiewicza, No. 24, premises 16, 44-280
E-mail address– info@primewindow.eu
Contact form – available at: /contact

§15 Service Requirements

Restricting the storage and access to Cookie files on the User’s Device may cause incorrect functioning of some Service features.
The Administrator bears no responsibility for the incorrect functioning of the Service features if the User restricts the possibility of storing and reading Cookie files in any way.

§16 External Links

In the Service – within articles, posts, entries, or User comments – there may be links to external websites with which the Service Owner does not cooperate. These links, as well as the pages or files indicated under them, may be dangerous to your Device or pose a threat to the security of your data. The Administrator bears no responsibility for content located outside the Service.

§17 Changes to the Privacy Policy

The Administrator reserves the right to change this Privacy Policy at any time without the need to inform Users about it, regarding the application and use of anonymous data or the use of Cookie files.
The Administrator reserves the right to change this Privacy Policy in the scope of Personal Data processing, about which Users having user accounts or subscribed to the newsletter service will be informed via electronic mail within 7 days from the change of the provisions. Further use of the services implies reading and acceptance of the introduced changes to the Privacy Policy. In the event that 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.
The introduced changes to the Privacy Policy will be published on this subpage of the Service.
The introduced changes come into force upon their publication.