PRIVACY AND COOKIE POLICY

Version 1 dated 01.06.2024

1. General Principles of Our Privacy Policy

1. Ksnbiz Sp. z o.o. places special emphasis on the privacy and security of personal data of users of the website operated at https://raccoontraffic.com/ and other ADO services (hereinafter referred to as: the service). In this regard, we are guided in particular by the principles arising from the following laws and regulations issued on their basis:
   
   1. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (hereinafter referred to as: GDPR);
   2. the Act of 10 May 2018 on the protection of personal data (Journal of Laws of 2018, item 1000, hereinafter referred to as: UODO);
   3. the Act of 18 July 2002 on the provision of electronic services (Journal of Laws 2017, item 1219, as amended, hereinafter referred to as: UŚUD);
   4. the Act of 16 July 2004 – Telecommunications Law (Journal of Laws No. 171, item 1800, as amended, hereinafter referred to as: Pr.tel).
2. The controller of the personal data of persons using the Service is Ksnbiz Sp. z o.o., with its registered office in Gliwice at 10 Dunikowskiego Street, 44-100, registered in the Register of Employers of the National Court Register kept by the District Court in Gliwice, 10th Commercial Division of the National Court Register under number 0000713252, NIP 6312677767.
3. The privacy policy specifies, among others:
   
   1. the scope and manner of processing personal data of users of the Service (hereinafter also referred to as: Client),
   2. the possibilities of accessing this data,
   3. how this data is used,
   4. the policy on the use of cookies in the Service.

2. Ways of Collecting Data About the User

1. We are committed to tailoring our services to the user’s situation as best as possible and facilitating contact with us. For this purpose, we collect various data about the user. However, we only collect and process the data that the user provides to us (with the exception of data collected automatically in certain situations using cookies and login data, as mentioned below).
2. In line with the practice adopted by most websites, we store HTTP requests directed to our servers. Browsed resources are identified by URLs. The exact list of information stored in the web server logs is as follows:
   
   1. the public IP address of the computer from which the request came (this can be the user’s computer directly);
   2. the client’s station name – identification realized by the HTTP protocol if possible;
   3. the time the request arrived;
   4. the first line of the HTTP request;
   5. the HTTP response code;
   6. the number of bytes sent by the server;
   7. the URL of the previously visited page (referrer link) – if the transition to the ADO Site was via a link (affiliation);
   8. information about the user’s browser;
   9. information about errors that occurred during the HTTP transaction.
3. The basis for processing the User’s personal data is their consent to the processing of their personal data. Consent can only be given voluntarily by the User, by filling out the appropriate contact form on the Administrator’s services or in another way, i.e., by selecting the option to send a summary to an email or subscribe to the newsletter. The data provided in the form is processed for the purposes specified in the consent, i.e.
   
   1. Consent to the processing of personal data for the Administrator’s marketing purposes, including Client profiling;
   2. Consent to receive commercial information and offers from the Administrator;
   3. Consent to share the Client’s email address with the Administrator’s business partners to receive commercial information about new offers, promotions, services;
   4. Consent to receive the newsletter;
   5. Consent to the processing of the Client’s phone number for direct marketing purposes.
4. The consent given by the user for the processing of their personal data is entirely voluntary, conscious, explicit, and confirmed by the User. The Administrator uses an opt-in policy to obtain consents, which means that only checking the checkbox constitutes the User’s consent to the specified content.
5. Personal data is also processed based on Article 6(1)(f) GDPR for contact purposes not related to the provision of services by the Administrator on its own behalf or on behalf of Business Partners, to respond to inquiries, as well as for archival and statistical purposes, which constitutes a legitimate interest of the Administrator.
6. In connection with the processing of personal data, the User has the right to:
   
   1. request access to their personal data from the Administrator,
   2. request the rectification of their personal data from the Administrator,
   3. request the deletion of their personal data from the Administrator,
   4. request the restriction of processing of their personal data from the Administrator,
   5. withdraw consent to the processing of personal data at any time, which does not affect the processing of personal data between the giving of consent and its withdrawal,
   6. data portability,
   7. file a complaint with the supervisory authority – the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw.
   8. In the case of processing personal data based on Article 6(1)(f) GDPR, you have the right to object to the processing of personal data.
7. To exercise the above rights, please send an email to iod@raccoontraffic.com, containing the following data: email address or phone number and the content of the request, e.g., data deletion or change – in this case, please specify the new email address to which the newsletter service should be provided.

3. Profiling

1. In the process of providing services, we make decisions in an automated manner based on the data we have about you, including the information you provided in the form and stored in the web server log files. Based on this information, we assign you a personal profile relevant from the perspective of offering you services provided by our partners. These decisions are made automatically based on the scoring model we have developed. Automatically made decisions affect the selection of products offered to you.
2. Profiling means processing personal data involving the use of your personal data to assess certain aspects of you, particularly to analyze your economic situation, preferences, interests, and location. We profile you for purposes related to our business, i.e., offering you insurance if you are a driver, selecting a leasing offer tailored to your preferences.
3. Automated decision-making for the direct marketing of the Administrator’s services and those of the Administrator’s business partners is necessary for the proper conduct of the Administrator’s business. Automated decision-making for marketing purposes mentioned above is carried out solely based on your consent.
4. If you disagree with our assessment made in this way, you may report it in the form mentioned in point 2.6 above.

4. Scope of Data Collected About the User via the Service and Its Use

1. The scope of data processing depends on the extent of consent given by the User, whereas, as noted, for full service realization, the User should express all consents.
2. In the case of consent to the processing of personal data, the user should provide data enabling identification and contact, i.e., at least the first name, last name, email address, and phone number. At the stage of filling out the contact form, the Administrator does not require other personal data.
3. For certain products and services, it may be necessary to provide more detailed personal data. In such a case, the purposes of processing will be indicated during the User’s phone conversation with the Administrator’s consultant or simultaneously with the appropriate form used to register the relevant personal data by the User.
4. The Administrator hereby informs the User that the following tracking technologies are used to track the User’s actions within the Website:
   
   1. Facebook, Twitter, Google, LinkedIn, Pinterest, go.pl conversion pixel – for managing advertisements on the above-mentioned services of the Administrator and conducting marketing, remarketing, and retargeting activities.
5. The Administrator collects data provided by the User to present the user with offers of financial products (in particular, loans and credits, products aimed at debt restructuring, insurance, and investment products). Therefore, the customer’s personal data may be used, in particular, for the following purposes:
   
   1. verifying the User’s identity, including by phone call;
   2. presenting an offer of a specific product or service of the ADO’s business partner;
   3. establishing contact with the User directly by the ADO’s business partner;
   4. exercising the rights of data subjects;
   5. marketing activities, including via electronic communication means, including analyzing users’ behavior and needs, market analysis;
   6. sending newsletters or SMS messages, or sending summaries, after obtaining the appropriate consent;
   7. creating user databases;
   8. improving our offer and the content of the Website;
   9. other purposes specified in this privacy policy.
6. The Administrator may, under the conditions specified in Article 28 of the GDPR, entrust their processing to third parties without the user’s separate consent.
7. The User acknowledges that their personal data may also be transferred to authorized state authorities in connection with proceedings conducted by them, upon their request and after meeting the conditions confirming the necessity of obtaining this data from the Administrator.

5. Rules Governing the Use of Cookies

1. The user’s use of the Service may involve saving and storing cookies on the user’s computer (or another device that enables access to the Service, such as a smartphone). Cookies are text-numeric files that allow the use of various website functions, e.g., collecting information about how a given site is used, enabling the user’s session state to be saved, or allowing the adjustment and optimization of displayed content to their preferences.
2. Within the Service, two main types of cookies are used: „session” cookies and „persistent” cookies. „Session” cookies are temporary files stored in the user’s end device until logging out, leaving the website, or turning off the software (web browser). „Persistent” cookies are stored in the user’s end device for the time specified in the cookie parameters or until the user deletes them.
3. Cookies are sent and can be stored on the user’s computer in a way that allows access to them for the following purposes:
   
   1. adapting the content posted on the Service to the user’s individual preferences and needs (profiling, see above);
   2. statistical purposes regarding activity on the Service pages (e.g., information about users’ geographical location, frequency of using our services, interest and demographic data reports) to better understand how users use the Service and improve its content, e.g., Google Analytics, Brand24.pl;
   3. behavioral advertising, contextual advertising, and remarketing, e.g., Google AdWords, Google AdSense, advertising using affiliate marketing technology;
   4. Saving or using cookies does not cause configuration changes in the user’s computer or the software installed on that computer.
   5. The user can define the conditions for storing or accessing cookies via the settings of the software installed on the telecommunications end device they use.
   6. Most web browsers by default allow cookies to be saved on the user’s device. The user can block the option to save cookies or give consent for their saving on their computer at any time by changing the settings in the web browser, advertising settings, mobile application advertising settings, and any other available methods.
   7. The cookie management instruction is available on the page http://wszystkoociasteczkach.pl/ in Polish and on the page http://www.allaboutcookies.org/manage-cookies/ in English. However, disabling the saving of cookies may hinder the use of the Service, particularly by limiting or disabling some of the Service’s functions. Therefore, it is recommended to consent to the use of cookies by the browser.
   8. At the same time, we inform you that if the user’s browser accepts cookies, the user consents to the use of these cookies in accordance with Polish law, in particular Article 173 of the Telecommunications Act. In particular, the content of cookies may be transferred to advertisers and partners cooperating with ADO in the scope of services offered on the Service pages or advertised through it.
   9. The user can delete the installed cookies at any time by using the appropriate option in the browser they are using. When browsing the Service in incognito mode, all cookies installed during the visit to the Service are automatically deleted after closing the browser. Details should be sought from the browser software provider or in the „help” section in the browser menu.
   10. Cookies are also placed on the User’s phone and may be used by advertisers and partners cooperating with the Service operator.

6. Measures to Protect Personal Data

1. Information about the user is processed by the Administrator with appropriate technical and organizational measures meeting the requirements of Polish law, as indicated in the introduction of this Policy. These measures are primarily aimed at securing users’ personal data from unauthorized access. In particular, only authorized persons (employees and contractors of Ksnbiz Sp. z o.o.) have access to users’ personal data, who are obliged to keep this data confidential.
2. The Administrator stores personal data until consent for personal data processing is withdrawn or for the time necessary to achieve the purpose for which consent was obtained, particularly for the duration of the service or contract and for the period during which claims related to the Company’s activities can be pursued, but no longer than for 3 years from the date of obtaining your personal data.
3. Additionally, data may be stored for purposes of preventing abuse and fraud, for statistical and archival purposes for 10 years from the date of the contract termination or the event causing the need for such processing.
4. Simultaneously, to ensure accountability, the Administrator will store data for the period during which the Administrator is obliged to keep data or documents containing it to document compliance with legal requirements, including enabling control of their fulfillment by public authorities.
5. Your personal data will not be transferred outside the European Economic Area.
6. Personal data may also be shared with entities providing IT, legal, audit, accounting, postal, and courier services to the extent necessary to ensure proper service delivery and state authorities in connection with proceedings conducted by them under applicable law, and entities to whom we are obliged to disclose them under applicable law.

7. Policy Changes

1. The expansion or change in the scope or content of the services we provide, as well as changes in legal regulations, may necessitate changes to the Privacy Policy. In such a situation, we will inform the user about the changes in the „Privacy Policy” section. Along with the change in the version of the Privacy Policy, the date indicating the day of its implementation and the signature indicating the given version of the Policy will appear. No change will negatively affect the fundamental right of the User to control the data processed by us.

8. Contact with the Service Administrator

1. We make every effort to enable users to report any comments, suggestions, tips, and objections regarding our adopted data processing policy. A customer service department employee is responsible for contacting you. Please send any issues related to the content of this Policy to the email address: support@raccoontraffic.com.
2. In fulfilling the regulation of Article 13(1)(b) of the GDPR, the Administrator indicates that a Data Protection Officer has been appointed, with whom interested Users can contact in writing at the Administrator’s address or by email at: iod@raccoontraffic.com.