Privacy Policy

TABLE OF CONTENTS

1. Introduction – contact details
2. Provisions of the law on the protection of personal data
3. Principles of processing your personal data
4. Users' rights in relation to the processing of personal data
5. Security of personal data
6. How we process your data
7. Consent – withdrawal of consent
8. Data storage
9. Data recipients sharing data with other entities
10. Data processing using cookies and other Internet technologies
11. Changes to the Policy
12. Pricing

Introduction – contact details

The Privacy Policy is a set of general rules regarding the use (processing) by EBS Sp. z o.o. of personal data of persons visiting or using the services provided by the company. We respect the privacy of customers and Users of our applications, therefore we provide this Privacy Policy so that everyone knows to what extent their personal data is processed, including the ability to independently, consciously and freely decide whether to use our services. As part of this Privacy Policy, we have decided to indicate how and to what extent we collect personal data of customers and Users, for what purposes we use this data, with whom we share it and how we protect it. In the Privacy Policy, the User will find information about the rights of our customers and Users in accordance with the applicable provisions on the protection of personal data. The policy is generally of a general nature and presents only relevant issues related to the processing of personal data. This policy is detailed by individual regulations and information clauses that the User will receive at the time of collecting personal data from him on the occasion of individual services, subscriptions (newsletter), contact forms (product presentation, contact request, inquiry), competitions, promotional campaigns, events).

This Privacy Policy describes how the Active web application ("Site" or "we") collects, uses and discloses your personal information when you visit or make a purchase on the Site.

The administrator of personal data is the Seller EBS Sp. z o.o. with its registered office in Warsaw at Bronisława Czecha 59, registered in the District Court for the Capital City of Warsaw, XIII Commercial Division of the National Court Register under KRS number 0000051806, NIP number 522-010-06-28, represented by: Justyna Wronka – Proxy of the Management Board (on the basis of ebs Sp. z o.o. authorization.  of 01.07.2020 issued by Tomasz Lauda – Vice-President of the Management Board and Krzysztof Stalewski – President of the Management Board).

Page: www.ebssmart.com

E-mail Contact: rodo@ebssmart.com

Contact of the traditional post: Bronisława Czecha 59, 00-950 Warsaw

Contact details of the Data Protection Officer:

Andrzej Marek Kisiel, PhD, e-mail contact: iod@ebssmart.com

Provisions of the law on the protection of personal data

The Privacy Policy of EBS Sp. z o.o. refers to the following provisions of law:

• 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) (OJ L No. 119, p. 1) – otherwise known as "GDPR",
• Act of 16 July 2004 Telecommunications Law (i.e. Journal of Laws of 2017, item 1907, as amended)
• Act of 18 July 2002 on the provision of electronic services (i.e. Journal of Laws of 2017, item 1219, as amended)

Principles of processing your personal data

We appreciate the trust that our customers and users of our software have placed in us. As part of the processing of personal data, we attach importance to the fact that these data are processed in a safe, reliable, lawful and transparent manner. Providing personal data is voluntary and necessary to identify the Customer and the possibility of placing and executing orders.

We would like to indicate the most important principles that guide us:

• we collect personal data only to the minimum extent necessary to achieve the purposes for which they are collected.
• the purposes of collecting personal data are clearly defined, based on legal provisions – we do not process data in a way inconsistent with these purposes.
• we care about the timeliness and correctness of personal data and immediately respond to any requests for rectification or updating of data.
• we exercise the right to access their personal data and correct them.
• we also exercise the rights to delete personal data, withdraw consent, limit processing, to transfer data, the right to object to data processing, the right not to be subject to a decision based solely on automated data processing, including profiling.
• we limit the storage of personal data in accordance with the law, only to the period necessary to achieve the purposes for which they are collected, unless there are events that may extend the period of data storage.
• we protect personal data against loss, unauthorized access, accidental loss or alteration and other unlawful forms of processing.
• if personal data is made available to other entities, it takes place in a secure, contractually secured manner and in accordance with applicable law.

Rights of Customers and Users in connection with the processing of personal data

Rights of the data subject:

1. the right to access the content of your personal data, i.e. the right to obtain confirmation whether the Administrator processes data and information regarding such processing,
2. the right to rectify data if the data processed by the Administrator are incorrect or incomplete,
3. the right to request the Administrator to delete data,
4. the right to request the Administrator to limit the processing of data,
5. the right to transfer data, i.e. the right to receive personal data provided to the Administrator and send them to another administrator,
6. the right to object to the processing of data on the basis of the legitimate legal interest of the Administrator or to the processing for the purpose of marketing own products and services,
7. the right to withdraw consent at any time (without affecting the lawfulness of processing based on consent before its withdrawal),
8. the right to lodge a complaint with a supervisory authority.

The rights listed in points 1-7 above can be exercised, among others, through contact channels.

Security of personal data

Privacy protection of the individual profile

As part of having the ActiveGuard hardware service and the ActiveView software service, we care about protecting the privacy of Users and Customers when using the software platform. The customer will create an individual profile protected by an individualized username and access password. The products used by the Customer can be assigned to an individual profile. The System processes the information provided by the Products using the GSM network in accordance with the Customer's needs and the functionalities of the System.  The legitimate interest of the administrator is to adjust the content of the Website to your needs, ensure the security of these services, as well as their continuous improvement.

How we process your data

The e-mail address is required to ensure the functionality of the ActiveView system. The lack of consent of the user to enter this data into the ActiveView system prevents the functioning of the service. Omitting certain data as part of account registration may contribute to reducing the functionality of the service. The User is responsible for maintaining the confidentiality of his data in the form of a password and login. Please enter your password when creating an account on the Website, which will not be easy to guess by outsiders. In order to ensure security, e-mail addresses are particularly protected data. After creating an account on the Website, the User cannot personally change the e-mail address, so please register those e-mail addresses that are actually used by you. In special cases justifying the need to change the e-mail address (login), please contact the Customer Service Center. The Website uses technical and organizational measures aimed at the best possible protection of collected personal data against unauthorized access or improper use by unauthorized persons. The technical measures used are modernized along with the development of technology, needs, as well as available security methods – in order for these efforts to be effective, the User must also take care of the security of his data.

Consent – withdrawal of consent

Each person has the right to withdraw consent at any time (without affecting the lawfulness of processing that was carried out on the basis of consent before its withdrawal) by:

1. Sending a statement on termination of the contract to the e-mail address: rodo@ebssmart.com
2. Sending a written statement on the termination of the contract to the Seller's address: Warsaw, Bronisława Czecha Street.

After receiving the application within 48 hours of receiving the application justified by technical reasons, the Organizer deletes the account from the contact database.

Data storage

With regard to ActiveView services, your data will be processed for the period in which these services will be provided and, sometimes, after the end of their provision, but only if it is allowed or required in the light of applicable law, e.g. processing for statistical, billing or redress purposes. In this case, the data will be processed for the period necessary to achieve such purposes. The period for which personal data will be stored:

1. Personal data processed on the basis of consent will be stored until its withdrawal.
2. Personal data processed in order to perform the contract will be stored until the order is completed, and after the expiry of the period necessary for after-sales customer service.
3. Personal data processed on the basis of the legitimate interest of the administrator will be stored:
   1. until an objection is lodged,
   2. in the case of a complaint procedure, for the period necessary to close the proceedings.

In application backups, data in various forms are stored for a period of X months.

Data recipients sharing data with other entities

Personal data will not be used for decisions based on automated processing, including profiling, referred to in Article 22(1) of the GDPR. Personal data will not be transferred to a third country or an international organization.

Data processing using cookies and other Internet technologies

Personal data will be processed by the Administrator:

• on the basis of consent, Article 6 (1) (a) of the GDPR for the purpose of multiple execution of orders;
• in order to perform the contract, Article 6(1)(b) of the GDPR in the case of a single execution of the order;
• on the basis of the legitimate interest of the administrator, Article 6(1)(f) of the GDPR in order to:
  3. marketing of the Administrator's products and services,
  4. pursuing or securing claims (in the case of filing a complaint).

The account is created by the Data Administrator. collects Users' personal data when they fill out forms on our websites, contact the Helpline or Customer Service Office, direct questions or messages using our social networking sites (we may then retain information that Users voluntarily provided by writing or contacting EBS Sp. z o.o. and automatically data contained in system logs and cookies As part of running various EBS Sp. z o.o. websites.  may collect various personal data, the provision of which is voluntary, but often necessary to handle the User's order or inquiry using online forms. In this case, providing data by you is voluntary, but necessary to provide such a service (in any case, with your consent expressed by leaving data and sending a form).

As part of the platform's functionality, the administrator processes the following personal data:

1. Surname and first name of the Subscriber / company name,
2. Name and surname of the contact person,
3. E-mail address,
4. Subscriber / company address,
5. Telephone number
6. Tin
7. customer ID from the accounting system
8. Correspondence address of the applicant (in the case of filing a complaint),
9. IP address.

Your data may be transferred to entities processing personal data at the request of the administrator m.in IT service providers, marketing agencies – such entities process data on the basis of an agreement with the administrator and only in accordance with the administrator's instructions. Data in anonymized form could be transferred as model data for simulation and creation of other services. Please be advised that on our websites we use the third-party tools described below related to analytics, behavioral advertising (based on interests), remarketing, measurement of the results of advertising campaigns. To the extent that on the basis of the User's activity on our websites and their subpages, what the User clicks, what he visits, displays, what he is interested in being on the Internet (search history), which are saved m.in. in cookies or in connection with other technologies that we use on our websites, anonymous or pseudonymized user profiles are created for the purposes of behavioral advertising. Pseudonymisation means that data or identification features are replaced by artificial identifiers (pseudonyms). On this basis, the User may automatically receive marketing information tailored to the User's preferences, behavior or profile in the form of behavioral advertising, i.e. advertising displayed on the User's device based on his interests. Data related to the search history is collected and analyzed anonymously. As part of behavioral advertising, EBS does not use personal data that would point directly to a specific User. Our goal is to develop an advertising offer that will be attractive and beneficial to the User, therefore, as part of behavioral advertising, the User may primarily see information about products or services that he has already viewed or checked on our sites.

Changes to the Policy

ActiveView services and features will expand over time. This means, m.in, that in the future the Administrator may make changes to this document. The announcement of changes will take place in such a way that the Administrator will place information about changes on the Website. With each change, a new version of the document will appear with a new date. Any changes that are the most important from the point of view of the User and the Customer will be appropriately highlighted. Any changes introduced do not affect the basic principle: the Administrator does not share or transfer against the law to third parties any personal data held as part of the ActiveView personal database. In the event of doubts or contradictions between the information clause and the consents granted by the User or the Customer, regardless of the above provisions, the consents granted by the Users or Customers are the basis for undertaking and determining the scope of activities by the Administrator. This document is for informational purposes.

Pricing

Price lists and other information contained on the websites do not constitute a commercial offer. Due to the emerging promotional campaigns, it is possible to change the prices presented on the websites and in price lists. Any binding agreements regarding the specifications of ActiveView are made on a case-by-case basis in an individual agreement concluded by the parties.