What you will find in this document?

Information about the protection of your personal data, and also about your rights. 

We have divided the privacy policy into four parts:

1. explanation of terms used in the Privacy Policy, information about our contact details and your rights;
2. detailed information about the processing of your personal data; we have provided information separately for each form you can fill out on our website,
3. information about the processing of your data on our social media profiles,
4. information about cookies and the processing of personal data related to them.

Content

Section I – General Provisions 2

Administrator 2

Terms Used in the Privacy Policy 2

Your Rights Regarding Personal Data 2

Right to Object 2

Complaint to the Head of the Personal Data Protection Authority 3

Personal Data Security and Potential Threats 3

Questions Regarding the Policy 3

Section II – Information Related to the Processing of Your Personal Data When Completing Specific Forms or Contacting Us 3

Contacting Us by Phone 3

Registration on Our Service and Purchases 4

Purchases Without Registration on Our Service 6

Providing Your Opinion on Products and Services 9

Section III – Our Social Media Profiles 9

Using Our Social Media Profiles 9

Section IV – Information About Cookies and the Processing of Personal Data Related to Them 12

Visiting Our Service Website 12

What Are Cookies and Why Do We Use Them?? 12

Types of Cookies 15

How to Delete Cookies 15

How to Block Cookies 15

Impact of Browser Settings Changes on the Use of the Service 16

Internal Cookies 16

Appendix No. 1 – List of Cookies Used : 16

Section I – General Provisions

Administrator

1. We, Roll Club sp. z o.o., a company registered in Warsaw, are the controller of your personal data. In the following sections of this Privacy Policy, we will refer to ourselves in the first person or as the “Controller”.
2. Our registration documents are kept by the District Court in Warsaw, 13th Commercial Division of the National Court Register. We are registered in the Register of Entrepreneurs of the National Court Register under the number KRS 0001094055. Our Tax Identification Number (NIP) is 5214061415. Our share capital amounts to PLN 5,000 (fully paid up). Our official documents contain the most important information about us, such as our financial statements and Articles of Association.
3. How You Can Contact Us:
   1. By post: ul. Rodzin Hiszpańskich 8, unit ID 1.04, 02-685 Warsaw, Poland, 
   2. By email: rollclubwawa@gmail.com,
   3. By phone: +48 698 420 157. 

Definitions Used in the Privacy Policy

1. If you see any of the terms listed below, beginning with a capital letter, in this Privacy Policy, you should understand them according to the following definitions: 

1. “Service” – the website whose main page is located at www.kler.eu,
2. “Policy” – this document, i.e. the Privacy Policy you are currently reading,
3. “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, repealing Directive 95/46/EC. The text of the GDPR can be found  here,
4. “Social Media” – the social networking sites TikTok, Instagram, and YouTube.

Your Rights Regarding Personal Data

1. We process your personal data, and therefore you have the following rights:

1. Right of access – you have the right to access your personal data, 
2. Right to rectification – you may correct or update your personal data,
3. Right to erasure (“right to be forgotten”) – you may request the deletion of your personal data where permitted under the GDPR,
4. Right to restriction of processing – you have the right to restrict the processing of your personal data within the limits set out in the GDPR.

1. In Sections II–IV of this Policy, you will find information about additional rights. In certain situations, you may have further options available to you.
2. Would you like to exercise your rights or learn more about them? Please contact us. Our contact details can be found in Section 3 of this Privacy Policy.

Right to object

1. Once you have provided us with your personal data, or if we have collected it ourselves, you may exercise your right to object. You are entitled to this right in two situations, when we process your personal data:

1. for the purposes of direct marketing – you do not need to justify such an objection;
2. based on our other legitimate interests – such an objection requires justification, arising from your particular situation. Please write to us and explain why, in your view, we should not process your data in this case.

1. Would you like to exercise your right to object? Please contact us. Our contact details can be found in Section 3 of this Privacy Policy.

Complaint to the President of the Personal Data Protection Office

• If you believe that we are processing your personal data unlawfully, you may lodge a complaint with the competent supervisory authority. In Poland, this authority is the President of the Personal Data Protection Office, whose website is available at the following address: https://uodo.gov.pl/ 

Personal data security and threats

1. We use the technical measures required by the applicable personal data protection regulations to prevent unauthorised persons from accessing or altering personal data transmitted electronically, that is, within our Website.
2. It should be noted that specific risks associated with the use of websites such as ours include:

1. malicious software (malware) , 
2. spyware,
3. phishing attempts carried out by impersonating trusted individuals or entities (so-called phishing), 
4. and hacker activities aimed at breaching IT systems.

We take the necessary measures to protect the Website and the data processed on it from such threats. Please also remember to follow basic security rules on your own. 

For example: install and regularly update antivirus software; do not click on suspicious links or open attachments in messages from unknown sources; always verify the sender’s email address and the website address from which you access our Website. Pay attention to whether they contain spelling mistakes or do not correspond to the brand or company mentioned in the message.

Questions Regarding the Policy 

1. If you have any questions regarding this Policy, please let us know. Our contact details can be found in Section 3 of this Policy.

Section II – Information Related to the Processing of Your Personal Data in Individual Forms and When Contacting Us

Contacting Us by Phone

1. If you choose this method of communication, please note the following:

1. For what purpose, on what legal basis, and for how long do we process your personal data?

1. What rights do you have?

They are described in Sections 5–10 of this Policy.

1. Are you required to provide us with your data?

Providing your data is voluntary. However, without your contact details, we may not be able to resolve your inquiry. 

1. With whom may we share your data?

1. providers of IT tools used by the Controller
2. providers of email services

1. Do we transfer your personal data outside the European Economic Area?

No.

Реєстрація на Веб-сайті та покупки

1. If you register on the Website, please note the following:

1. For what purpose and on what legal basis do we process your personal data?

1. Right to withdraw consent.

You may withdraw your consent to receive commercial information at any time. However, this will not affect any processing carried out before your withdrawal. 

1. What rights do you have?

We have described them in Sections 5–10 of the Policy. You may also exercise the right to data portability in accordance with the provisions of the GDPR.  

1. Do you have to provide us with your data?

1. Providing your data is voluntary. However, submitting your data is a condition for concluding an agreement with us regarding registration on the Website and individual sales contracts concluded through the Website. Without providing your data, it will not be possible to conclude a contract with us.
2. Without providing them, you will not be able to receive commercial information from us during telephone conversations.

1. With whom will we share your data?

1. entities hosting (storing) the Website and personal data on our behalf,
2. accounting offices or law firms,
3. payment operators available on the Website,
4. providers of IT tools used by the Administrator,
5. providers of email services.
6. providers of web traffic analysis tools, 
7. providers of marketing tools, 
8. entities involved in conducting promotional and marketing activities,
9. entities involved in the delivery of orders.

1. Do we transfer your personal data outside the European Economic Area?

Your data may be transferred outside the European Economic Area, in particular to Ukraine, based on Standard Contractual Clauses.

Purchases without registration on the Website

1. If you purchase products on the Website without registration, please note the following:

1. For what purpose, on what legal basis, and for what period do we process your personal data?

1. Right to withdraw consent.

You may withdraw your consent to receive commercial information at any time. However, this will not affect any processing carried out before your withdrawal.

1. What rights do you have?

We have described them in Sections 5–10 of the Policy. You may also exercise the right to data portability in accordance with the provisions of the GDPR.  

1. Are you required to provide us with your data?
   1. Providing your data is voluntary. However, submitting your data is a condition for concluding individual sales contracts with us through the Website. Without providing your data, you will not be able to conclude a contract with us.
   2. Without providing your data, you will also not be able to receive commercial information from us during telephone conversations.

1. With whom will we share your data?

1. entities hosting (storing) the Website and personal data on our behalf,
2. accounting offices or law firms,
3. payment operators available on the Website,
4. providers of IT tools used by the Administrator,
5. пproviders of email services,
6. providers of web traffic analysis tools, 
7. providers of marketing tools, 
8. entities involved in conducting promotional and marketing activities,
9. entities involved in the delivery of orders.

1. Do we transfer your personal data outside the European Economic Area?

Your data may be transferred outside the European Economic Area, in particular to Ukraine, based on Standard Contractual Clauses.

Providing feedback on products and services

1. If you wish to provide your opinion regarding the products and services we offer, please note the following:

1. For what purpose and on what legal basis do we process your personal data?

1. What rights do you have?

We have described them in Sections 5–10 of the Policy.

1. Are you required to provide us with your data?

Providing your data is voluntary. However, without providing your data, you will not be able to leave a review on the Website.

1. With whom will we share your data?
   1. entities hosting (storing) the Website and personal data on our behalf,
   2. providers of IT tools used by the Administrator,
   3. providers of email services.

1. Do we transfer your personal data outside the European Economic Area?

Your data may be transferred outside the European Economic Area, in particular to Ukraine, based on Standard Contractual Clauses.

Section III – Our social media profiles

Use of our social media profiles

1. If you use our social media profile, please note the following:

1. For what purpose and on what legal basis do we process your personal data?

1. How long will we process your data? 

For the time necessary to carry out the actions described above, i.e., responding to your messages, engaging in discussions on social media, achieving the aforementioned marketing and statistical purposes, handling claims and defending against them, as well as for the time necessary to detect and prevent abuses. However, we will not process your personal data longer than you object to.

1. What rights do you have? 

We have described them in Sections 5–10 of the Policy. 

1. Are you required to provide us with your data?

Providing your data is voluntary. However, according to social media policies, we will see your name or nickname and profile picture if you write to us or comment on our posts. 

1. With whom will we share your data?
   1. Social media providers.

1. Do we transfer your personal data outside the European Economic Area?  

Your personal data will be transferred to the United States based on the European Commission’s decision of 10 July 2023, issued pursuant to the Regulation of the European Parliament and of the Council (EU) establishing an adequate level of personal data protection provided by the EU–US data protection framework. 

1. Will automated decisions, including profiling, be made based on your data?

No.

1. Information on joint data control with Meta Platforms Ireland Limited: 

1. The Controller and Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) are joint controllers of your data pursuant to Article 26 of the GDPR for processing data for statistical and advertising purposes.
2. Joint control includes collective data analysis to display statistics on the activity of users on the Administrator’s fan page.
3. esponsibilities of Meta Platforms Ireland Limited for processing your data for these purposes:
   • Ensuring a legal basis for data processing to obtain website statistics
   • Ensuring the rights of data subjects
   • Notifying the supervisory authority of breaches and informing affected individuals about incidents
   • Implementing appropriate technical and organizational measures to ensure the security of your data

1. Scope of the Administrator’s responsibility for processing your data:
   • Ensuring a legal basis for processing data for statistical purposes; 
   • Fulfilling obligations to provide information within the scope of the purposes pursued by the Administrator.
2. Meta Platforms Ireland Limited will provide data subjects access to the main content of the website statistics application (Article 26(2) GDPR) through the data contained in the website statistics, which can be accessed from all websites.

The lead supervisory authority for joint data processing is Ireland – the Data Protection Commission (notwithstanding Article 55(2) GDPR, where applicable).

1. Detailed information regarding the agreements between the controllers is available at: https://www.facebook.com/legal/terms/page_controller_addendum
2. Given that part of the IT infrastructure of Meta Platforms Ireland Limited is located in the United States, Facebook/Instagram user data may be transferred to a third country (i.e., the USA). The European Commission has not issued a decision confirming that the United States ensures an adequate level of data protection; however, Meta Platforms Ireland Limited states that the data transfer complies with GDPR requirements, in particular through the use of Standard Contractual Clauses. 
3. More information about the processing of personal data by Meta Platforms Ireland Limited and data protection measures can be found at: https://www.facebook.com/privacy/explanation. 

Section IV – Information about cookies and the processing of personal data related to them

Accessing the Website

1. Accessing the Website involves our processing of the information contained in cookies in accordance with the principles described below.

What are cookies and why do we use them?

1. The Website uses cookies – small text files stored on your device (e.g., computer, tablet, smartphone). The Website can read cookies. Want to learn more about cookies? Visit Wikipedia at the following address.

1. For what purpose and on what legal basis do we process your personal data? 

1. Right to withdraw consent 

You can withdraw your consent to the use of cookies (except for necessary cookies) at any time. Withdrawing your consent does not affect the lawfulness of data processing based on consent before its withdrawal.  

1. How long will we process your data?   

1. Until you withdraw your consent for a specific purpose. Withdrawing your consent does not affect the lawfulness of processing based on consent given before its withdrawal.  
2. In the case of so-called necessary cookies, your data will be processed for the time required to perform the actions described above, i.e., ensuring the proper functioning of the Website, including maintaining your session, managing your consent for the use of cookies, and ensuring the security of the Website and preventing abuse.  

Detailed information about the duration of individual cookies can be found in Appendix 1.

1. What rights do you have?   

We have described them in Sections 5–10 of the Policy.     

1. Are you required to provide us with your data?  

1. Providing personal data processed through so-called essential cookies is necessary.   
2. Providing personal data processed through cookies other than essential ones is voluntary, and not providing such data does not have any negative consequences.

1. Who will we share your data with?  

1. social media providers, 
2. advertising network operators,  
3. providers of marketing tools,  
4. providers of content planning and distribution tools,  
5. providers of analytical and statistical tools.

1. Will we transfer your personal data outside the European Economic Area?   

Your personal data will be transferred to the United States in accordance with the European Commission decision of 10 July 2023, issued pursuant to Regulation (EU) No 107/2023 of the European Parliament and of the Council, establishing the level of personal data protection ensured by the data protection framework between the EU and the US. You can obtain a copy of the personal data we transfer outside the European Economic Area at any time. To do so, please contact us. You can find our contact details in §1, Section 3 of the Policy.

  Types of cookies

1. There are several types of cookies on the Website:
   1. session cookies, which remain in your web browser’s memory until you close it, 
   2. temporary cookies, which remain in your browser’s memory until a specified time expires. You can delete these cookies manually at any time,
   3. persistent cookies, which remain in your web browser’s memory until you delete them, 
   4. зthird-party cookies, which come from external tool providers on our Website.
2. A complete list of cookies and their duration can be found in the cookie declaration below.

How to delete cookies

1. You can delete cookies after we have stored them. To do this, you can use the relevant functions of your web browser, programs designed for this purpose, or the appropriate tools available in your operating system.
2. Below you will find information on how to delete cookies in the most popular web browsers:

1. Firefox: https://support.mozilla.org/pl/kb/usuwanie-ciasteczek-i-danych-stron-firefox
2. Opera: http://help.opera.com/Linux/9.60/pl/cookies.html
3. Edge: https://support.microsoft.com/pl-pl/microsoft-edge/usuwanie-plik%C3%B3w-cookie-w-przegl%C4%85darce-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
4. Chrome: http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
5. Safari: http://support.apple.com/kb/HT1677?viewlocale=pl_PL

How to block cookies 

1. You can configure your web browser to prevent cookies from being stored on your computer, phone, or tablet. You can also use appropriate browser extensions or programs for this purpose.  
2. Information on how to block cookies in the most popular web browsers can be found at the following links: 

1. Firefox: https://support.mozilla.org/pl/kb/blokowanie-ciasteczek 
2. Opera: https://help.opera.com/pl/latest/web-preferences/ 
3. Edge: https://support.microsoft.com/pl-pl/microsoft-edge/usuwanie-plików-cookie-w-przeglądarce-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09 
4. Chrome:https://support.google.com/chrome/answer/95647?co=GENIE.Platform%3DAndroid&hl=pl 
5. Safari: https://support.apple.com/pl-pl/HT201265

Impact of changing browser settings on the use of the Website

1. Changing your browser configuration to prevent or limit the storage of cookies may restrict the functionality of the Website. Deleting cookies while using the service may have similar consequences. This means that some of our services will be unavailable without cookies; for example, you may not be able to log in to the Website or make a purchase.

Third-party cookies

1. Cookies placed on your computer, phone, or tablet may come from other service providers. You can delete them yourself. We have described how to do this in Sections 23–24 of the Policy. These cookies are stored on your device for varying periods of time, depending on the cookie. The current list of cookie providers can be found in Appendix 1. 

Appendix No. 1 – List of Cookies Used:

Necessary Cookies

Functional cookies

Cookies used for statistical purposes

Cookies used for marketing purposes