VOLTRUSH Privacy Policy
This document ("Privacy Policy") aims to describe in detail the rules for the processing of personal data of persons using ("Users") the services ("Services") provided by VOLTRUSH Sp. z o.o., with its registered office at ul. Belzacka 176/178, 97-300 Piotrków Trybunalski, entered in the National Court Register under number 0001172024, NIP: 7712937818, REGON: 541681231 ("VOLTRUSH") when using the VOLTRUSH website and mobile application ("Platform").
The priority is to ensure the confidentiality of the information provided. By using the Platform, the User confirms that they have read, understood and agree to the terms and conditions of this Privacy Policy.
If you do not agree to its provisions, it is recommended that you refrain from using the Platform.
If you have any questions regarding the processing of personal data, please contact us via the contact form at http://voltrush.pl/contact.
1. Administrator
The controller of Users' personal data processed on the Platform is VOLTRUSH Sp. z o.o., with its registered office at ul. Belzacka 176/178, 97-300 Piotrków Trybunalski, entered in the National Court Register under number 0001172024, NIP: 7712937818, REGON: 541681231.
2. Voluntary nature
The provision of data by the User is voluntary, but necessary to use the Services offered by VOLTRUSH.
3. Legal basis for the processing of personal data
The legal basis for the processing of personal data may be:
a) Consent (Article 6(1)(a) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016),
if the User gives their consent in the form of a clear statement made via the Platform;
b) Contractual obligations (Article 6(1)(b) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016),
where processing is necessary for the performance of a contract concluded on the basis of the terms and conditions available at: https://www.voltrush.pl/regulamin-uslug("Terms and Conditions"), to which the User is a party, or to take action at the User's request prior to entering into a contract;
c) Legal obligation (Article 6(1)(c) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016),
where processing is necessary for compliance with a legal obligation to which the Controller is subject.
d) Legitimate interest (Article 6(1)(f) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016),
where processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the fundamental rights and freedoms of the User requiring the protection of personal data.
4. Types of data
The data processed by the Controller in connection with the User's use of the Platform may include the following categories:
a) first and last name;
b) e-mail address;
In some cases, when using the VOLTRUSH website, information may be stored to facilitate the linking of data in the form completed by the User with their e-mail address. In such cases, the User's e-mail address will be visible to the Administrator in the URL of the page containing the form.
c) age;
Information about the User's age will be processed in order to verify the possibility of concluding a contract on the basis of the Terms and Conditions and the possible need to obtain the consent of the legal guardian of a minor who is over 13 years of age for the processing of their personal data for the purpose of concluding such a contract. Data concerning the User's age is provided directly by the User to VOLTRUSH.
d) mobile phone number;
e) location data;
f) payment and transaction data, such as bank account number, credit or debit card details;
Payment data is sent in an encrypted form using SSL/TLS protocol and PKI system. The entity providing online payment services is Autopay S.A.
The administrator does not process other payment data and is not responsible for any issues related to the payment process.
g) data concerning the use of the Services;
The Administrator, in the scope of operating the Platform, uses the services of external providers who are responsible for managing and analysing data obtained during the use of the Platform by Users. The VOLTRUSH website is hosted on the servers of an external operator – home.pl sp. z o.o. with its registered office in Szczecin.
Data concerning use may be collected by external providers automatically during use of the Platform. This may include information such as the User's device Internet Protocol address (e.g. IP address), browser type, browser version, websites visited and the time and date of visits to those websites, time spent on those websites, unique device identifiers and other diagnostic data.
This information, as well as data regarding the type of device, its identifier, and operating system, may also be collected automatically when using the Platform via a mobile device.
h) Administrator logs
Information about certain User behaviours is logged at the server level. This data is used solely for the purpose of administering the VOLTRUSH website and to ensure the most efficient provision of hosting services. The resources viewed are identified by their URL addresses. In addition, information such as the following may be recorded:
* the time of receipt of a query via the form available on the Platform,
* the time of sending a response by the Administrator, the so-called User station name – identification performed by the HTTP protocol,
* information about errors that occurred during the execution of HTTP transactions,
* the URL of the page previously visited by the User (referrer link) –
if the transition to the VOLTRUSH website took place via
a link,
* information about the User's browser,
* information about the IP address.
The above data does not enable the identification of specific Users of the VOLTRUSH website
.
5. Analytics
The process of collecting and analysing data on the use of the Platform is carried out with the help of external providers in order to understand the behaviour of Users, their preferences and interactions on the Platform. The Administrator uses statistical analysis of website traffic through the Google Analytics tool provided by Google Inc. based in the USA. This entity is not a recipient of users' personal data, as only anonymised information is transferred to it. However, the above-mentioned tool is based on the use of cookies on the User's end device. With regard to information about the User's preferences collected by Google Inc., the User may view and edit information resulting from cookies using the tool: https://www.google.com/ads/preferences/.
6. Profiling and automated decision-making
Acceptance of this Privacy Policy by granting VOLTRUSH consent to the processing of personal data applies in particular to:
a) Profiling
Automatic technological tools may be used to analyse and evaluate certain characteristics of personal data for profiling purposes. Profiling involves the processing of Users' personal data, including preferences, behaviour, location, interactions and interests. Profiled data is used to improve the Services and tailor the offer to better meet the needs and preferences of Users.
b) Automated decision-making
Automated decision-making refers to the process of making decisions based solely on automated processing, including profiling. These decisions may have legal or other similar effects. They may include recommendations, content personalisation and targeted marketing.
In connection with the profiling and automated decision-making process, the User has the right to:
* object to decisions based solely on automated processing, including profiling, if they have legal or similar effects,
* obtain human intervention in the decision-making process,
* express their opinion and appeal against decisions made in an automated manner.
7. Purposes of data processing
The Controller may collect, store and use Users' data solely for the following purposes:
a) providing services and managing the Platform,
b) monitoring the use of the Platform and providing information about it,
c) performing contracts concluded with Users,
d) contacting Users via e-mail, telephone calls, text messages or other equivalent forms of electronic communication in order to provide information about updates or information messages related to the functionalities of the Services provided, including security updates, when necessary or justified,
e) providing information about news, offers and other information related to the services, unless the User expressly indicates that they do not wish to receive
the indicated information,
f) personalising the Services and providing them in a manner more tailored to the needs of Users,
g) handling and managing forms and enquiries sent to the Administrator by Users,
h) taking actions aimed at improving the quality of the Services,
i) adapting advertising services and managing business processes, conducting consumer research and planning new services,
j) ensuring the best possible customer service and addressing related issues,
k) carrying out mergers, sales of assets, restructuring, reorganization, liquidation or other sales or transfers of part or all of the assets, as part of the business, as well as part of bankruptcy or liquidation proceedings, in which the personal data stored by the Administrator is part of the transferred assets,
l) for other purposes, such as data analysis, identification of usage trends, determining the effectiveness of promotional campaigns, and evaluating and improving services, products and marketing activities.
8. Collection, storage and use of personal data
a) Data collection
User data is collected from the moment of:
* consent is given – consent is deemed to have been given when the "I accept" button appears on the banner referring to this Privacy Policy, displayed on the Platform
* conclusion of an agreement with VOLTRUSH on the basis of the Terms and Conditions;
b) Data storage
All collected data is stored in the cloud. This service is provided by external providers – VOLTRUSH partners.
9. Cookies and other tracking technologies
The website uses cookies, which are IT data, in particular small text files, saved and stored on the User's end device. Cookies are intended for use on websites and usually contain the name of the website they come from, the time they are stored on the end device and a unique identifier.
The entity placing cookies on the user's end device and accessing them is the Administrator.
a) Purposes of using cookies
Cookies are used for the following purposes:
* to maintain the User's session (after logging in), so that the User does not have to re-enter their login and password on every subpage of the Website;
* to achieve marketing objectives, including the use of remarketing techniques, as described in point e) of this section 9 of the Privacy Policy.
b) Types of cookies
The Platform uses two basic types of cookies:
* session cookies – temporary files that are stored on the User's end device until they log out, leave the website or close their web browser;
* persistent cookies – files stored on the User's end device for the time specified in their parameters or until they are deleted by the User.
c) Managing cookies
Software used for browsing websites (web browser) usually allows cookies to be stored on the User's end device by default. The User may change their browser settings regarding cookies at any time, in particular to restrict their use or disable them completely.
Detailed information on the possibilities and methods of handling cookies is available in the settings or documentation of each web browser. Restricting the use of cookies may affect some of the functionalities available on the VOLTRUSH website.
d) Third-party cookies
Cookies placed on the User's end device may also be used by third parties cooperating with the Administrator, in particular by:
* Google (Google LLC based in the USA),
* Meta Platforms, Inc. (USA),
* X Corp. (formerly Twitter Inc., USA).
e) Cookies in remarketing techniques
External providers cooperating with the Administrator may use cookies and other tracking technologies on the Platform, in particular in remarketing techniques, used without transferring personal data. The Administrator uses marketing tools, including the Meta pixel (Facebook), which enables the display of tailored advertising content to Users on websites belonging to Meta Platforms, Inc. The use of this technology means that the above-mentioned entity receives information that the user has visited the Administrator's Website.
Data processing is based on cookies or other similar technologies stored on the user's end device. The Administrator does not transfer any additional personal data to Meta Platforms, Inc. other than the information collected automatically via the pixel, while Meta Platforms, Inc. processes this data as a separate administrator, in accordance with its own privacy policy.
10. User Rights
As part of the personal data processing process, the User has the right to:
a) obtain confirmation as to whether their personal data is being collected and/or processed,
b) request disclosure of the data that the Controller collects, uses and/or otherwise processes,
c) request that the Controller provide a list of external providers to whom the User's data is transferred,
d) request the deletion of personal data obtained in specific circumstances, e.g. when the original purpose of obtaining personal data ceases to exist,
e) request the rectification or updating of personal data if any inaccuracies are noticed,
f) object to the processing of personal data for specific purposes,
g) withdraw your consent at any time by sending an appropriate statement,
h) request the restriction of the processing of personal data,
i) request the transfer of a copy of personal data collected by the Controller to other entities. In such a case, the request must be clear and voluntary.
Once the copy has been provided, the Controller is not responsible for the processing of data by another entity. This Privacy Policy is binding only in relation to data processed by the Controller,
j) lodge a complaint about the processing of personal data with a supervisory authority. Within the EU, a complaint may be lodged with the local data protection authority,
k) request that the Administrator cease sending messages related to the service via mobile phone or email address,
In order to exercise the above rights, the User should contact the Administrator via the contact form at http://voltrush.pl/contact.
11. Recipients of Personal Data
Users' personal data may be disclosed to the following categories of recipients for the purposes specified in this Privacy Policy:
a) Service Providers
The Controller may share personal data with external providers with whom it cooperates in the provision of Services, such as IT providers, payment operators, service and marketing entities. These providers are required to protect the data and may only use it for strictly defined purposes, in accordance with the provisions of the Privacy Policy.
b) Business partners
The Administrator has the right to cooperate with its business partners in order to offer joint services or promotions. In such cases, Users' personal data may be shared with these partners, but only for the purposes specified in the Privacy Policy.
c) Affiliated entities
Personal data may be shared with entities affiliated with the Administrator (such as subsidiaries or branches) for business purposes, including to improve services and perform relevant analyses.
d) Authorities
The Administrator has the right to disclose Users' personal data if necessary to comply with legal obligations, in response to legal requests and to protect the interests of the Administrator.
e) Authorised Users
Personal data may be accessible to authorised Administrator personnel for purposes justified by the nature of their activities and in accordance with the Privacy Policy.
f) Anonymised Data
The Administrator has the right to disclose anonymised, non-identifying data for the purposes of analysis, research and marketing.
g) Other recipients
With the express written consent of the User, the Administrator has the right to disclose personal data to other recipients for the purposes for which consent has been given.
The list of recipients of personal data is maintained by the Administrator and is available to Users upon request via the contact form at http://voltrush.pl/contact.
The Administrator declares that all external recipients maintain appropriate security measures to protect the confidentiality, integrity and security of Users' data.
The Administrator also declares that it does not sell, rent or exchange Users' personal data to external parties for marketing purposes.
Some recipients may be located outside Poland or the European Economic Area (EEA). In such cases, appropriate safeguards will be put in place to protect Users' personal data in accordance with applicable data protection laws.
12. Third parties
When using the Services, Users may encounter links to websites, online services or mobile applications of third parties that are not affiliated with the Administrator and that may connect to other websites, services or applications.
The Administrator is not liable for any damage caused by the use of such third-party websites, services or applications. This Privacy Policy applies only within the Administrator's organisation.
We encourage you to review the policies of third parties each time and to contact the Administrator directly for information about their activities.
13. Data Transfer
All processed data is stored in the cloud as part of the services provided by external suppliers.
However, User Data may be transferred outside the EEA for the purposes and in the cases specified in this Privacy Policy.
The Controller takes all possible measures to comply with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and to guarantee Users adequate protection. In particular, the Administrator provides appropriate Standard Contractual Clauses, which are recognised as a legitimate method of ensuring data protection when transferring data to third countries. These clauses are approved by the European Commission and will be included in agreements between data exporters and data importers in third countries.
Acceptance of the terms of this Privacy Policy prior to the transfer of data will constitute consent to such transfer.
No information will be transferred to any organisation or third country until adequate safeguards for the protection of personal data have been guaranteed.
14. Period of Storage of Personal Data
Except where required or permitted by law for a longer retention period, Users' personal data will only be retained for as long as necessary to fulfil the purposes set out in this Privacy Policy or until any claims become time-barred.
The Controller may also store data for the purpose of conducting internal analyses. – such data will not be stored by the Controller for a period
longer than 3 years.
15. Obligations of the Administrator
The Administrator is obliged to fulfil the following obligations:
a) processing only data that is adequate, relevant and necessary in relation to the purposes set out in this Privacy Policy;
b) take all steps to ensure that personal data which are inaccurate are erased or rectified without delay;
c) erasing personal data without undue delay if:
* it is no longer necessary in relation to the purposes set out in this Privacy Policy,
* the User has withdrawn the consent on which the processing was based and there is no other legal basis for processing their data,
* the User has objected to the processing and there are no legitimate grounds for processing,
* the personal data has been unlawfully processed,
* the personal data must be erased in accordance with a legal obligation;
d) to notify Users whose personal data has been disclosed of any rectification, erasure or restriction of processing, unless this is impossible or involves disproportionate effort;
e) to process personal data in a manner that ensures appropriate security, including protection against unauthorised or unlawful access and against accidental loss, destruction or damage, using appropriate technical or organisational measures;
f) not to process any information without the User's consent;
g) if consent is given in a document that also covers other matters, the request for consent to the processing of data by the Controller shall be presented in a manner that is clearly distinguishable from those other matters;
h) notify Users of the transfer of personal data to a third country (outside the EU and EEA or a territory that has concluded a data protection equivalence agreement) and ensure that the transfer is carried out using Standard Contractual Clauses approved by the European Commission;
i) implementing technical and organisational measures, such as pseudonymisation and encryption of personal data, to ensure an adequate level of data security;
j) in the event of a personal data breach that could result in a risk to the rights and freedoms of natural persons, the Controller is obliged to notify Users of such a breach;
k) where there is a reasonable suspicion that a personal data breach will result in a high risk to the rights and freedoms of natural persons, the Controller shall immediately notify Users of the personal data breach, unless the conditions specified in Article 34(3) of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) apply.
16. Minors
The services provided by the Administrator are intended for persons over the age of 16.
In accordance with the VOLTRUSH Terms and Conditions, minors over the age of 13 may use the Services, but only with the express consent of their legal guardian. It is permissible for a legal guardian to confirm the statement of a person under the age of 16 who has accepted the provisions of the Terms and Conditions and the Privacy Policy. In the absence of an appropriate statement from a legal guardian, VOLTRUSH does not process the data of minors.
VOLTRUSH may, in the event of reasonable doubts as to the age of the User, request confirmation of reaching the age of 13 and verification of the consent of the legal representative to the processing of personal data.
If VOLTRUSH processes the personal data of a minor as a result of the concealment of their true age, at the request of the legal guardian, all data collected by VOLTRUSH will be deleted immediately after such information is obtained and will not be further processed.
The administrator shall make every effort to correctly verify the age of Users and whether the legal guardian has given or approved consent to the processing of the minor's data.
17. Updates and Changes
The Administrator reserves the right to modify or change the content of this Privacy Policy at any time.
The latest version of the Privacy Policy is available at: https://www.voltrush.pl/polityka-prywatnosci
In the event of changes to the processing of personal data, they will be communicated to Users via the VOLTRUSH Application and a message on the Website.
Continued use of the Platform after changes to the Privacy Policy have been made will be treated as consent to such changes.