[General Provisions]

The Privacy Policy defines the rules of processing and protection of personal data of individuals using the Website available at https://allintraders.com, hereinafter referred to as Data. The Privacy Policy is an appendix to and an integral part of the Regulations, and all terms used herein have the meaning defined in the Regulations.

Data is information about an identified or identifiable natural person to whom the data relates, i.e. one who can be identified directly or indirectly, in particular on the basis of characteristics such as name, identification number, location data, Internet identifier or one or more characteristics that define the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person.

The administrator of the Data is ALLin Traders P.S.A, with its registered office in Katowice at Al. Wojciecha Korfantego 138A, 40-156, entered in the register of the National Court Register by the District Court of Katowice-Wschód, VIII Economic Division of the National Court Register under the KRS number: 0000943197, with the tax identification number NIP: 6343005951, with equity capital: PLN 184,751.99, e-mail: support@allintraders.pl

The Data Controller has appointed a Data Inspector, who can be contacted in writing at the Data Controller's registered office address or via e-mail: iod@allintraders.pl.

The Data Controller declares that the Data is processed in accordance with the regulations contained in the 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), hereinafter referred to as RODO and the Act of May 10, 2018 on the protection of personal data, regulations amending or replacing these acts, executive regulations and any other generally applicable laws.

Data processing as defined in the Privacy Policy means an operation or set of operations performed on Data or sets of Data in an automated or non-automated manner, such as collecting, capturing, organizing, structuring, storing, adapting or modifying, downloading, viewing.

[Data Source]

Sources of Data include information obtained directly from Data Subjects, in particular in the course of Registration, Logging in, placing Orders, entering into Contracts or Fee-based Agreements, providing information via the Website or communicating with Data Subjects, as well as information obtained from/to:

state authorities, public registers and other publicly available sources - names and surnames, genders, dates of birth, identification numbers (including PESEL, NIP, REGON and other numbers in the relevant registers of foreign entities), e-mail addresses, telephone numbers, fax numbers, business, residence and mailing addresses (street, house number, city with postal code), website address,

Payment processors - names, genders, email addresses, financial transaction data (e.g., account numbers, credit or payment cards, other unique identifiers), Internet providers - location data, Internet identifiers (IP addresses), types of Internet browsers, devices and systems used by the Data Subject, the sites the Data Subject accesses and the actions he/she takes on them, the content of cookies.

[Purposes and Grounds for Processing Data]

The use of the Website by the Data Subject is tantamount to the Data Subject's awareness that his/her Data may be processed for the following purposes and on the following grounds:

Responding to inquiries from Data subjects and storing data in cookies, collecting Data from websites and mobile applications - based on the consent of the Data subject,

to take action at the request of the Data Subject prior to the conclusion of a Contract or a Paid Contract and for the purpose of their performance, in particular:

to provide services electronically through the Website, including enabling Registration, Logging in, placing Orders, entering into Contracts or Paid Contracts, providing information through the Website, smooth running and operation of the Website and ensuring the security of its use, creating, maintaining and managing an Account, including providing Account maintenance and resolving technical problems, executing an Order, settling a transaction, including issuing an invoice, amendment, termination or cancellation of an Agreement or Paid Contract, communication with Data Subjects, including processing of requests, complaints and other letters addressed by Data Subjects to the Data Controller, fulfillment of legal obligations incumbent on the Data Controller, in particular the fulfillment of accounting, tax, financial, and archival obligations arising from legitimate interests pursued by the Data Controller or third parties, indicated in para. 10-12 below, including for the purpose of: establishing, asserting or protecting the Data Controller's claims (evidentiary), protecting against claims of Data Subjects (evidentiary), direct marketing of the Data Controller's own services, including matching them against needs, i.e. profiling, indirect marketing of services of third parties cooperating with the Data Controller, e.g. in the form of discount coupons, including matching them on a needs basis, i.e. profiling, satisfaction surveys of Data Subjects, determining the quality of service and the level of satisfaction of Data Subjects, analytical, statistical and management, including internal management, statistical and research reporting and analysis aimed at developing and improving the services provided by the Data Controller, conducting internal audits and inspections, implementing business controls, managing operations of acquisitions, mergers, divisions, transformations.

[Data Scope].

Processed data may include first and last names, genders, dates of birth, companies, identification numbers (including but not limited to PESEL, NIP, REGON and other numbers in relevant registers of foreign entities), e-mail addresses, telephone numbers, fax numbers, business, residential and mailing addresses (street, house number, city with postal code), financial transaction data (including but not limited to. account numbers, credit or payment card numbers, other unique identifiers), location data, Internet identifiers (IP addresses), types of Internet browsers, devices and systems used by the Data Subject, the pages the Data Subject accesses and the actions he/she takes on them, the contents of cookies and other personal data voluntarily provided by the Data Subject on the Website, including through interactive forms or surveys or in the course of contacting the Data Controller.

[Voluntariness of Data].

Except as absolutely and universally required by law, the provision of Data by the Data Subject is voluntary, however, refusal to do so shall be tantamount to the inability to Register, Login, place Orders, enter into Contracts or Fee-based Agreements, provide information via the Website or communicate with Data Subjects.

[Data Recipients]

The Data Administrator reserves the right to disclose the Data to competent authorities, including courts, government and local government administration bodies, pre-trial investigation bodies, enforcement bodies and other legal protection authorities, business information bureau, debt buyers, entities participating in the processes of acquisition, mergers, divisions, transformations of business entities with the participation of the Data Administrator, based on the relevant legal basis, in accordance with the provisions of generally applicable law.

The Data Controller reserves the right to entrust the processing of Data to third parties providing to the Data Controller, in particular, hosting services, management of the Website, including in the process of servicing Data subjects, transportation services (including postal operators, persons conducting postal or courier activities that are not postal operators), payment intermediation (including banks and payment institutions), information technology, equipment repair, marketing, collection of opinions about the Products, consulting, accounting, tax, financial, debt collection, legal, archiving and destruction, storage of records, and moreover loss adjustment (including contractors for loss adjustment services).

The Data Controller reserves the right to entrust the processing of Data to third parties providing to it or directly to Data Subjects the services necessary for the use of the Website, including Registration, Logging in, placing Orders, entering into Contracts or Fee-based Agreements, providing information through the Website or communicating with Data Subjects, including for the purpose of processing complaints.

Data may be processed on the territory of Poland, a member state of the European Union (EU), on the territory of a signatory to the Agreement on the European Economic Area (EEA). The Data may also be processed outside the EEA, including by international organizations, through their transfer by the Data Controller, but only if it is necessary to achieve the purposes set out in paragraph 8 above, and the transfer and processing of the Data outside the EEA are covered by an appropriate, adequate to the principles provided for in the RODO, degree of protection recognized by a decision of the European Commission. The Data Controller shall inform about the intention to transfer Data outside the EEA at the stage of collection.

[Data Retention Periods].

Data will be stored by the Data Controller for as long as there is a legal basis for its processing, unless generally applicable laws would require longer storage. Thus, the Data will be kept by the Data Controller for the following periods:

until revocation of consent by the Data Subject - where processing is based on the consent given,

until an objection is lodged - if the processing is necessary for purposes arising from the legitimate interests pursued by the Administrator, subject to paragraph 19 above,

until the expiration of obligations under the Contract or Paid Contract and claims for their performance - in case their processing is necessary for the performance of the Contract or Paid Contract or to take action at the request of the Data Subject prior to the conclusion of the Contract or Paid Contract,

until the expiration of the Data Controller's obligations under generally applicable laws,

until the expiration, including the statute of limitations, of the rights, claims or obligations of the Data Controller and the Data Subject - where their processing is necessary for purposes arising from the legitimate interests pursued by the Data Controller.

At the end of the retention period, the Data will be deleted or anonymized.

[Data Profiling].

Data will also be processed by automated means, including profiling for which information about the Data Subject's activities on the Website, including concluded Contracts or Paid Contracts or socio-demographic data, will be used in order to tailor marketing information to the Data Subject's individual preferences.

[Rights and Obligations of Data Subjects].

The Data Subject has the right to request from the Data Controller:

access to personal data and send a copy of the complete Data and information about the processing of the Data,

rectify the Data by indicating incorrect or outdated data,

deletion of Data, with the Data Controller having the right to refuse this deletion in cases specified by generally applicable law,

transfer of Data by the preparation and transmission by the Data Controller of the designated Data to another controller or to the Data Subject in a structured, commonly used machine-readable format,

limitation of Data processing.

The Data Subject also has the right to object, at any time, to the processing of Data on the basis of legitimate interests pursued by the Data Controller, including to profiling on this basis, on grounds related to his or her particular situation, which shall be binding on the Data Controller, unless he or she demonstrates the existence of valid legitimate grounds for processing overriding the interests, rights and freedoms of the Data Subject, or grounds for establishing, asserting or defending claims.

If the Data is processed for the purposes of direct marketing of the Data Controller, the Data Subject has the right to object at any time to the processing of such Data for such marketing, including profiling, to the extent that the processing is related to such direct marketing.

In the case of processing of Data by the Data Controller on the basis of the consent of the Data subject, the consent may be revoked at any time, and such revocation shall not affect the legality of the processing performed on the basis of the consent before its revocation (future effect).

The Data Subject shall exercise the rights referred to in paragraphs 18-21 above, in particular by sending an appropriate request by email to ido@allintraders.pl, together with his/her name and surname, by telephone at +48 699 224 191 or in person at the Data Controller's office.

If the Data Subject also posts any Data of other individuals on the Website, he or she may do so only on the condition that he or she does not violate generally applicable laws and the personal rights of such individuals.

The Data Subject shall be entitled to use Data and content provided by other persons on the Website during and in connection with the use of the Website and with their consent in a manner consistent with generally applicable laws, unless he/she obtains consent from such persons to process their Data and content to the extent and for the purpose provided for in the Privacy Policy and beyond the use of the Website.

The Data Subject also has the right to lodge a complaint with a supervisory authority, in particular in the Member State of his or her habitual residence, his or her place of work or the place where the alleged violation was committed, if he or she considers that the processing of the Data violates the provisions of the RODO. The supervisory authority in Poland is the President of the Office for Personal Data Protection.

[Data Security].

The Data Controller uses technical and organizational measures to protect the Data from accidental or intentional manipulation, loss, destruction or access by unauthorized persons. When Data is collected and processed, information is transferred in encrypted form to prevent its misuse by third parties. The security measures used by the Data Controller are continuously revised and adapted to the development of technology.

In order to provide Data Subjects with a high level of Data security, the Data Controller shall apply measures to ensure:

The ability to continuously ensure the confidentiality, integrity, availability and resilience of processing systems and services, the ability to quickly restore Data availability and access in the event of a physical or technical incident, regularly test, measure and evaluate the effectiveness of technical and organizational measures to ensure processing security.

[Use of cookies].

Cookies are small text files that are locally stored in the intermediate memory of the web browser on the computer of the person to whom the Personal Information relates, from which the website was visited.

Cookies allow identification of the web browser, in order to optimize the content offered by the site and simplify the use of this site. This data is not used to personally identify the person who visited the website.

The use of cookies is based on the Cookie Policy, which is attached to the Privacy Policy.

[Final Provisions]

In matters not regulated in the Privacy Policy, the provisions of the law on Data processing, including the RODO, shall apply.

The Data Controller reserves the right at any time to amend or supplement the Privacy Policy resulting in changes to important provisions for important reasons, in particular:

issuance of a decision by a court of general jurisdiction or issuance of a decision by a state authority resulting in the need to change the Privacy Policy,

a change in generally applicable laws, a significant change in the market situation with respect to the activities carried out by the Data Controller,

improvement by the Data Controller of the security, functionality or level of protection of the Data,

to extend or improve the functionality of the Website or to discontinue the provision of certain functionalities within the Website,

changes in the subject matter of the Data Controller's business (its expansion or restriction), in accordance with these causes or effects of the changes. Amendments shall not deprive Data Subjects of their acquired rights and shall have effect for the future, i.e. from the date of their introduction. A person who does not agree with the change of the Privacy Policy may stop using the Website at any time.