§ 1



The Administrator of the personal data collected via the website is HB PREMIUM SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ SPÓŁKA KOMANDYTOWA, entered in the Register of Entrepreneurs by the District Court for the Capital City of Warsaw in Warsaw, XIV Commercial Division of the National Court Register under KRS number: 0000632920, place of business and address for service: 5/64 Generała Grochowskiego Street, 05-500 Piaseczno, NIP: 5223069557, REGON: 365208309, electronic mail address (e-mail):, phone number: +48 603 053 534, hereinafter referred to as "Administrator" and being at the same time "Service Provider".
The personal data collected by the Administrator through the website are processed in accordance with 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), hereinafter referred to as RODO/GDPR.
Any words or phrases capitalized in the contents of this Privacy Policy shall be understood as defined in the Terms of Service of the website.


§ 2


PURPOSE OF PROCESSING AND LEGAL BASIS. The administrator processes the personal data of the Service Users of the Website in the case of: subscribing to the Newsletter in order to send commercial information by electronic means. Personal data are processed upon separate consent, on the basis of Article 6(1)(a) RODO/ GDPR the use of the Contact Form, in order to send a message to the Administrator, on the basis of Article 6(1)(f) RODO/ GDPR (legitimate interest of the entrepreneur).
THE TYPE OF PERSONAL DATA PROCESSED. The Service Recipient provides, in the case of:
Newsletter:     name and surname,    e-mail address.
Contact form:   name,       e-mail address
PERIOD OF ARCHIVING OF PERSONAL DATA. Customers' personal data is stored by the Administrator: where processing is based on the performance of a contract, for as long as is necessary for the performance of the contract and thereafter for a period corresponding to the period of limitation of claims. Unless otherwise provided by a specific regulation, the period of limitation shall be six years, and for claims for periodic performance and claims related to the conduct of business activity - three years.

in the case where the basis for data processing is consent, for as long as the consent is not revoked, and after the revocation of consent for a period of time corresponding to the period of limitation of claims which the Administrator can raise and which can be raised against him. 

Unless otherwise provided by a specific provision, the limitation period shall be six years, and three years for claims for periodic performance and claims relating to the conduct of business activities.
When using the Website, additional information may be collected, in particular: the IP address assigned to the Client's computer or the external IP address of the Internet provider, domain name, browser type, access time, operating system type.
Upon separate consent, pursuant to Article 6(1)(a) of the RODO/ GDPR, data may also be processed to send commercial information by electronic means or to make telephone calls for the purpose of direct marketing - respectively, in connection with Article 10(2) of the Act of 18 July 2002 on the provision of services by electronic means or Article 172(1) of the Act of 16 July 2004 - Telecommunications Law, including those directed by profiling, provided that the Customer has given the appropriate consent. We may also collect navigational data from you, including information about the links and references you choose to click on or other actions you take on the Site. The legal basis for this type of activity is the legitimate interest of the Administrator (Article 6 (1) (f) of the /RODO/GDPR), consisting in facilitating the use of services provided electronically and improving the functionality of these services. The provision of personal data by the Customer is voluntary. The administrator takes special care to protect the interests of data subjects, and in particular ensures that the data collected by him are: processed lawfully, collected for specified, legitimate purposes and not further processed in a way incompatible with those purposes, substantively correct and adequate in relation to the purposes for which they are processed and kept in a form which permits identification of data subjects for no longer than is necessary to achieve the purpose of the processing.


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The Service Recipients' personal data are transferred to the service providers used by the Administrator to run the Website, in particular to: accounting office, hosting providers,
software providers that enable business operations, entities providing the mailing system,
software provider needed to run the website. Service providers referred to in point 1 of this paragraph to which personal data are transferred, depending on contractual arrangements and circumstances, or are subject to the Administrator's instructions as to the purposes and methods of processing this data (processors) or independently define the purposes and methods of their processing (administrators). Customers' personal data is stored exclusively in the European Economic Area (EEA), subject to §5 point 5 and §6 of the Privacy Policy.


§ 4



The data subject shall have the right of access to the content of his/her personal data and the right to rectification, erasure, restriction of processing, the right to data portability, the right to object, the right to withdraw consent at any time without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal.

Legal grounds for the Customer's request:
Access to data - Article 15 of the RODO/GDPR
Rectification of data - Article 16 RODO/ GDPR..
Erasure of data (so-called right to be forgotten) - Article 17 RODO/ GDPR
Restriction of processing - Article 18 RODO/GDPR
Data portability - Article 20 RODO/GDPR.
Objection - Article 21 RODO/GDPR
Withdrawal of consent - Article 7 sec.3 RODO/GDPR.
n order to exercise the rights referred to in point 2, you can send an appropriate e-mail to the following address:
If the Client makes a claim under the above rights, the Administrator shall either comply with the claim or refuse to comply with it immediately, but no later than within one month of receiving it. However, if due to the complexity of the request or the number of requests, the Administrator is unable to comply with the request within one month, it shall comply with the request within a further two months by informing the Service Recipient in advance, within one month of receiving the request, of the intended extension of the time limit and the reasons for it. If it is found that the processing of personal data violates the provisions of the GDPR, the data subject has the right to lodge a complaint with the President of the Personal Data Protection Office.


§ 5



The Administrator's website uses "cookies".
The installation of "cookies" is necessary for the proper provision of services on the Website. Cookies contain information necessary for the proper functioning of the website, and they also give the possibility to develop general statistics on website visits. The website uses two types of "cookies": "session" and "permanent"."Session" cookies are temporary files that are stored on the Customer's end device until logging out (leaving the page). 
"Permanent" cookies are stored in the final device of the Customer for the time specified in the parameters of the cookies or until they are deleted by the Customer. The Administrator uses its own cookies to better understand how visitors interact with the content of the site.
The cookies collect information about the use of the website by the Client, the type of website from which the Client was redirected, the number of visits and the time of the Client's visit to the website. This information does not record specific personal data of the Service Recipient, but is used to compile statistics on the use of the website.
The Administrator uses external cookies to collect general and anonymous statistical data via Google Analytics analytical tools (administrator of external cookies: Google Inc. based in the USA). Cookies may also be used by advertising networks, in particular Google, to display advertisements tailored to the Client's use of the Website. For this purpose, they may store information about the Client's navigation path or time spent on a given page. The Customer shall be entitled to decide on the access of cookies to his/her computer by selecting them in advance in his/her browser window.  Detailed information on the possibility and methods of using cookies is available in the software (browser) settings.


§ 6



The website uses the so-called social plug-ins ("plug-ins") of social networks. By displaying the, website containing such a plug, the Service Recipient's browser will establish a direct connection with the Facebook, Instagram, Pinterest and YouTube servers.The content of the plug-in is transmitted by the respective service provider directly to the user's browser and integrated into the website. Thanks to this integration, service providers receive information that the Client's browser has displayed the website www., even if the Client does not have a profile with the service provider or is not currently logged in with him. This information (including the Client's IP address) is sent by the browser directly to the provider's server (some servers are located in the USA) and stored there. If the Client logs into one of these social networks, the service provider will be able to directly associate the visit to with the Client's profile in the given social network. If the user uses the plug-in , e.g. by clicking on the "Like" button or the "Share" button, the corresponding information will also be transmitted directly to the server of the respective service provider and stored there. The purpose and scope of data collection and its further processing and use by service providers, as well as the possibility of contact and the rights of the Client in this regard and the possibility to make settings to ensure the protection of the Client's privacy are described in the service providers' privacy policies:

If the Customer does not want the social networks to assign the data collected during visits to www. directly to his or her profile on a given website, he or she must log out of that website before visiting www. The Customer may also prevent plug-ins from being loaded on the website altogether by using appropriate browser extensions, e.g. blocking scripts with "NoScript". The Administrator uses remarketing tools, i.e. Google Ads, on its website, which involves the use of Google LLC cookies related to the Google Ads service. As part of the mechanism for managing cookie settings, the Customer has the option to decide whether the Service Provider will be able to use Google Ads (administrator of external cookies: Google Inc. based in the USA) in relation to him.


§ 7



The administrator uses technical and organizational measures to ensure protection of the processed personal data appropriate to the threats and categories of data protected, and in particular, protects the data against unauthorized disclosure, removal by an unauthorized person, processing in violation of applicable laws and change, loss, damage or destruction.The administrator provides appropriate technical measures to prevent the acquisition and modification by unauthorized persons of personal data sent electronically. In matters not covered by this Privacy Policy, the provisions of the GDPR and other relevant provisions of Polish law shall apply accordingly.

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