PRIVACY POLICY

Chapter 1

General provisions

1. Implementing the provisions of the Act of July 18, 2002 on the provision of services by electronic means (Journal of Laws of 2002, No. 144, item 1204, as amended) TRSO Sp. z o. o. introduces this Privacy Policy, specifying in particular the types and scope of services provided electronically, the conditions for the provision of these services, including technical requirements and prohibitions on the provision of illegal content, the conditions for concluding and terminating contracts for the provision of electronic services, the conditions for sending commercial information and the procedure complaint.

2. Agreeing to comply with this policy when starting the service, using the website or placing an order by e-mail is tantamount to full acceptance of the terms of the privacy policy without the need to prepare a separate agreement.

Chapter 2

Types and scope of services provided electronically

1. The Service Provider provides services electronically, in particular:

» “newsletter” – information bulletin

» preparing commercial offers via e-mail,

2. The Service Provider also provides services on the basis of separate contracts, the subject of which is the provision of services electronically.

Chapter 3

Terms of provision of electronic services.

1. TRSO sp. z o. o. provides services to the Service Recipient within the scope and under the conditions specified in this policy or an individual offer, if one has been submitted and accepted by the Service Recipient.

2. The service recipient undertakes to comply with this policy.

3. TRSO sp. z o. o. also provides services on the basis of separate contracts, the subject of which is the provision of services electronically:

» Causing disruption or overload of the IT systems of the Service Provider or other entities directly or indirectly involved in the provision of electronic services,

» They violate the rights of third parties, generally accepted social norms or are inconsistent with generally applicable laws.

» The Service Recipient is obliged to comply with the prohibition of abusing electronic means of communication and not to provide the following content via or to the Service Provider’s IT systems:

4. TRSO sp. z o. o. reserves the right to carry out maintenance works on the IT system that may cause difficulties or prevent the Service Users from using the services. The dates of the works and their expected duration will be published on the website before the works begin.

5. In special cases affecting the security or stability of the ICT system, TRSO sp. z o. o. has the right to temporarily discontinue or limit the provision of services, without prior notice, and to carry out maintenance works aimed at restoring the security and stability of the ICT system.

6. TRSO sp. z o. o. provides Service Users with a communication secret called “telecommunications secrecy”, which includes information transmitted on the public Internet, data relating to and entered by Service Users only within the IT system of TRSO sp. z o. o. and only in the case where the information covered by “telecommunications secrecy” are not generally public or their disclosure is not necessary for the proper provision of the service to which they concern. Information covered by “telecommunications secrecy” may be disclosed only in cases specified in the contract or in legal provisions.

7. Information covered by “telecommunications secrecy” may be processed by TRSO sp. z o. o. only if its processing is the subject of the service provided to Service Users, is necessary for its proper performance or supervision of the proper operation of the Service Provider’s IT system.

8. Access to information on changes regarding the method and scope of services provided by TRSO sp. z o. o. and to information required to be provided to the Service User under Article 6 of the Act on Providing Services by Electronic Means will be provided by TRSO sp. z o. o. via the website and/or via e-mail information.

Chapter 4

Personal data protection

Introductory information

1. Respecting the right to privacy of persons who have entrusted TRSO sp. z o. o. (hereinafter referred to as “TRSO”) with their personal data, we would like to declare that we process the acquired data in accordance with national and European legal provisions and in conditions ensuring their security, i.e. their confidentiality, availability, integrity and accountability of activities carried out. In order to ensure the transparency of our processing processes, we present the principles of personal data protection applicable at TRSO, established under the 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 in on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as “GDPR”)

2. The Personal Data Administrator (ADO), i.e. the entity deciding on the purposes and means of processing personal data, is TRSO sp. z o. o. with its registered office in 24-100 Puławy, Polesie 36. In matters related to the processing of your personal data, you can contact us also by e-mail at the following e-mail address: kontakt@trso.pl

3. If you use websites belonging to TRSO, your personal data collected using cookies may be processed , in accordance with the Cookies Policy contained in this document.

Categories of persons whose data are processed and data acquisition

1. TRSO sp. z o. o. is a company offering a wide range of packaging products and comprehensive advisory services in the selection of optimal packaging

2. TRSO processes personal data of natural persons who:

a. are entrepreneurs whose data comes from publicly available sources, including public registers (including the Register of Entrepreneurs of the National Court Register and the Central Registration and Information on Economic Activity) (“Entrepreneurs”);

b. are potential customers, contractors or suppliers of TRSO, because, for example, they have provided TRSO with contact details in connection with the services and products offered by this Company (“Potential Customers”);

c. are customers, contractors or suppliers of TRSO (“Customers”);

d. act as persons authorized to represent legal persons or other organizational units (“Representatives”);

e. are a party to applications, complaints, complaints or other letters addressed to the Company (“Complainant”);

f. may be recipients of marketing correspondence in accordance with applicable law;

3. The processing of personal data of particular categories of persons whose data is processed may concern, in particular:

a. E-mail addresses,

b. Names and surnames,

c. Logins and passwords,

d. Telephone numbers,

e. Fax numbers,

f. Company names,

g. NIP numbers,

h. Company addresses,

i. Alternative delivery address,

Purposes and grounds for processing personal data

In carrying out our business functions, we process personal data for the following purposes:

Conclusion and performance of the contract. art. 6 section 1 letter b and letter f GDPR;

processing is necessary to perform the contract,

processing is necessary for the purposes of legitimate interests pursued by the administrator for the duration of the contract, and after the end of its validity until the expiry of the statutory limitation periods for claims arising from it.

Consideration of complaints and complaints, or other letters addressed to TRSO. art. 6 section 1 letter b and letter f GDPR;

processing is necessary to perform the contract,

processing is necessary for the purposes of legitimate interests pursued by the administrator for 1 year after the expiry of the warranty or settlement of the complaint.

Pursuing claims or defending against legal claims Art. 6 section 1 letter f GDPR

processing is necessary for the purposes of the legitimate interests pursued by the administrator – pursuing claims and defending against claims for the duration of the contract, and after the end of its validity until the expiry of the statutory limitation periods for claims arising therefrom, taking into account the duration of any proceedings, i.e. until the time of their final conclusion, and in the case of enforcement proceedings, until the final satisfaction of the claims pursued.

Archiving documents, i.e. contracts and settlement documents, Art. 6 section 1 letter c GDPR

processing is necessary to fulfill the legal obligation imposed on the ADO for the periods specified by law, and if they are not indicated for specific documents, for the time when their storage is within the legally justified purpose of the administrator regulated by the time of possible redress.

Conducting marketing activities without the use of electronic means of communication Art. 6 section 1 letter f GDPR

processing is necessary for the purposes of the legally justified interests of the Personal Data Protection Officer until you raise an objection, i.e. you show us in any way that you do not want to stay in contact with us and receive information about the activities we undertake.

Conducting marketing activities using electronic means of communication Art. 6 section 1 letter f GDPR

processing is necessary for the purposes of the legally justified interests of the ADO until you raise an objection or withdraw your consent, i.e. you show us in any way that you do not want to stay in contact with us and receive information about the activities we undertake, and due to other applicable regulations, in particular the Telecommunications Law and the Act on the provision of electronic services, these activities are carried out only on the basis of the consents obtained.

Fulfillment of legal obligations arising from Polish and EU law. Art. 6 section 1 letter c GDPR

processing is necessary to fulfill the legal obligation imposed on the ADO until the obligation expires

Maintaining a contact form on the website art. 6 section 1 letter b GDPR

processing is necessary for the performance of a contract to which the data subject is a party for the duration of the contract, and after its termination until the expiry of the statutory limitation periods for claims arising therefrom.

Data recipients

1. In connection with the activities of TRSO Sp. z o. o. will disclose your personal data to the following entities:

a. state authorities or other entities authorized under the law,

b. entities supporting us in our activities on our behalf, in particular: suppliers of external ICT systems supporting our activities, entities auditing our activities, entities providing accounting, advisory or legal services and entities cooperating with TRSO sp. z o. o. as part of marketing campaigns, such entities will process data on the basis of an agreement with TRSO Sp. z o. o. and solely in accordance with its instructions – to provide these services;

c. banks if it is necessary to conduct settlements,

d. employees and collaborators acting under authorization to provide work or services;

e. courier or postal companies – to deliver parcels,

f. external services – to perform the ordered service,

g. entities purchasing receivables to settle any debts, and others – in order to otherwise support our business,

2. However, despite our efforts, it may turn out that the above list does not represent all the types of external entities cooperating with us. This is due to the fact that some of our cooperating external entities often use their subcontractors. If you want to learn more about our external cooperating entities, please contact us at kontakt@trso.pl.

Rights related to the processing of personal data

1. In connection with the processing of personal data, you have – on the principles set out in the provisions on the protection of personal data, including the provisions of the GDPR – certain rights, including:

a) the right to access data – you have the right to obtain confirmation from TRSO as to whether your personal data is being processed, as well as regarding certain other information (e.g. regarding the purposes of processing, as well as the categories of processed personal data about your personal data) . You also have the right to access your personal data in the form of obtaining a copy of your personal data. This serves to make you aware and to be able to check how TRSO uses your personal data. TRSO may refuse to provide a copy of personal data in a situation where it could negatively affect the rights of another person;

b) the right to rectify data – you have the right to request TRSO to immediately correct your personal data if it is incorrect or incomplete (e.g. when TRSO processes your incorrect name and surname or address); for this purpose, you may provide an additional declaration;

c) the right to delete data (also known as the “right to be forgotten”) – it allows you to request the deletion of your personal data if, for example, the data was used unlawfully or if your consent was withdrawn (in a situation where it is the only basis for processing your data). However, the “right to be forgotten” does not constitute an absolute right to have your personal data deleted, as there are certain exceptions to it, e.g. where TRSO needs to continue to use the data to establish, pursue or defend legal claims or to fulfill an obligation legal;

d) the right to limit processing – you have the right to stop TRSO from further using your personal data if, for example, TRSO is in the process of assessing a request to rectify your data. If the processing of personal data is limited, TRSO may continue to store your personal data, but may no longer actively use it (e.g. to perform the contract);

e) the right to transfer data – you have the right to receive and re-use certain personal data for your own purposes with other entities (which are separate data controllers). This right applies only to your personal data that you have provided to us and which we process (automatically) with your consent or for the purpose of performing a contract. In this case, we will provide you with a copy of your personal data in a structured, commonly used and machine-readable format, or (where technically possible) we may send your data directly to another data controller. The Company may refuse to exercise these rights in a situation where it could negatively affect the rights of another person.

2. To the extent that the basis for the processing of your personal data is the implementation of legally justified interests, you have the right to object to the processing of this data, in particular in connection with their processing for direct marketing purposes. However, TRSO may continue to process personal data if it can demonstrate valid and legitimate grounds for processing that override your interests, rights and freedoms, or if it is necessary to establish, pursue or defend claims. If you object to the processing of your personal data for direct marketing purposes, we will no longer process your personal data for such purposes.

3. To the extent that consent is the basis for the processing of your personal data, you have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal

4. You have the right to lodge a complaint with the body supervising compliance with the provisions on personal data protection (the Inspector General for Personal Data Protection or the successor of this body – the President of the Office for Personal Data Protection).

How do we protect your personal data?

1. We are aware that your personal data is confidential. We maintain confidentiality, security and protect your personal data in accordance with applicable law, including the provisions of the GDPR, as well as our internal policies and instructions.

2. We have implemented technological and operational security measures to protect your personal data against loss, misuse, unauthorized modification or destruction. Such measures include, but are not limited to: use, encryption, appropriate management processes regarding access rights and other technical and organizational measures to ensure proper protection of your personal data. These measures ensure an appropriate level of security in relation to the risks inherent in the nature of the personal data to be protected.

3. However, we would like to point out that if you submit information over the Internet, it cannot be guaranteed that it is 100% secure.

4. For all payments we collect from you online, we use a recognized, secure online payment system.

Is providing personal data mandatory?

Providing data is necessary to conclude contracts and settle the business activity conducted and for TRSO sp. z o. o. to comply with legal requirements. In the remaining scope (in particular for the purpose of processing data by TRSO sp. z o. o. for marketing purposes), providing data is voluntary.

Transfer of data to third countries

The data will be processed within the European Economic Area, which means that, as a rule, we do not transfer data to third countries. However, in certain situations, data may be transferred to a third country, in particular when the transfer is necessary for the performance of a contract between the data subject and the controller or for the implementation of pre-contractual measures taken at the request of the data subject, as well as when the transfer is necessary for the conclusion or performance of a contract concluded in the interest of the data subject, between the controller and another natural or legal person.

Moreover, there may be situations where the basic business data of an employee/collaborator of TRSO Sp. z o. o. (such as: name and surname, position, business telephone number and e-mail address) may be transferred to third countries. The necessity to transfer data to third countries is conditional on the performance of the contract between TRSO Sp. z o. o. and the employee/collaborator whose personal data is transferred. The transfer of personal data of an employee/collaborator to a third country applies to persons who will perform activities for a client or potential client from a third country.

Processing of personal data in an automated manner

Personal data will not be processed in an automated manner (including in the form of profiling) in such a way that as a result of such automated processing any decisions could be made, other legal effects would be caused or it would otherwise significantly affect our clients, contractors and their employees/co-workers.

Chapter 5

Consent to the processing of personal data

1. The Service Recipient hereby consents to the processing of his personal data by TRSO Sp. z o. o. indicated in Chapter 4 point 6 of this policy, for the needs of the Service Provider’s activities specified in Chapter 4 point 3.

2. Personal data will be processed in accordance with the principles set out in Chapter 4 of this privacy policy.

3. Consent is voluntary, but in some cases the lack of consent prevents the provision of services.

Chapter 6

Conditions for concluding and terminating contracts

1. The service recipient may at any time unsubscribe from receiving offers or modify their settings by direct contact by e-mail or telephone.

2. Resignation referred to in point 1 is tantamount to termination of the contract for the provision of electronic services.

Chapter 7

Complaint procedure

1. Complaints may be submitted for:

a. Failure to meet the deadline specified in the contract for starting the provision of electronic services to the Service User due to TRSO’s fault,

b. Failure to perform, improper performance of services electronically or incorrect settlement thereof.

2. The complaint must be in writing under pain of nullity.

3. Complaints may be submitted within 30 days from the date on which the service was performed or was to be performed.

4. A complaint regarding non-performance or improper performance of a service must include in particular its subject and the circumstances justifying it.

5. TRSO will consider the complaint within 14 days from the date of its submission. If the complaint cannot be considered within this time, the Service Provider shall notify the complainant in writing within this period of the reasons for the delay and the expected date of consideration of the complaint.

6. If the terms of the complaint procedure are violated, the complaint may not be accepted.

Chapter 8

Transitional and final provisions

1. In matters not covered by this privacy policy, the provisions of the Civil Code (Journal of Laws of 1964, No. 16, item 93, as amended ) , the Act on the provision of electronic services (Journal of Laws of 2002, No. 144, item 1204, as amended) and other provisions of generally applicable law.

2. The competent court to resolve disputes arising from this privacy policy is the common court competent for the registered office of TRSO.

COOKIES POLICY

This Policy applies to ” cookies ” and applies to websites operated by TRSO Sp. z o. o. (hereinafter referred to as: “websites”).

What are cookies ?

” Cookies ” should be understood as IT data, in particular text files, stored on end-user devices (such as computers, tablets, smartphones, etc.). These files allow you to recognize the user’s device and properly display a website tailored to his or her individual preferences. Cookies are used to recognize the browser during the validity period of a given cookie. Cookies have many uses: they can be used to remember a customer’s ID on a retailer’s website, the current content of a shopping cart, or for statistical or advertising purposes . ” Cookies ” usually contain the name of the website they come from, their storage time on the end device and a unique number.

What do we use cookies for ” ?

Cookies are used to adapt the content of websites to user preferences and optimize the use of websites. They are also used to create anonymous, aggregated statistics that help understand how the user uses websites, which allows improving their structure and content, excluding personal identification of the user.

TRSO is always looking for innovative and effective solutions to improve customer experience on the website www.trso.pl and offers high-quality services. Therefore, TRSO may use cookies to personalize your searches and increase your browsing speed, remembering choices such as language preferences and creating anonymous statistics. Some cookies may require your prior consent (i.e. advertising cookies ) before the cookie is installed on your device.

What cookies do we use?

Session and persistent cookies .

The first of them (session) are temporary files that remain on the user’s device until logging out of the website or turning off the software (web browser). Persistent files remain on the user’s device for the time specified in the cookie parameters or until they are manually deleted by the user.

Cookies used by the website operator ‘s partners, including in particular website users, are subject to their own privacy policy.

Functional cookies _

These ” cookies ” make it possible to improve and speed up navigation on the website by remembering user choices. These ” cookies ” enable in particular:

– Remembering browser display preferences (language used, operating system, etc.) and adapting the website presentation during visits, in accordance with the user’s hardware and software,

– Storing information regarding, for example, the completed form or the requested service (subscribed services, basket contents);

– Implementation of security measures on our website.

“Performance (recipient) cookies “

These cookies allow us to determine the number of visits and traffic sources in order to measure and improve the performance of our website. They also help us determine which pages are visited most/least often and assess how users navigate the site. If you do not accept these cookies, we will not be informed about your visit to our website.

Targeting

These cookies may be activated on our website by our advertising partners. They may be used by these companies to create profiles of your interests and to deliver targeted advertising on other sites so that we can display advertising based on your preferences. If you do not accept these cookies, you will see random advertisements.

How to disable cookies on your computer?

• Apple Safari browser: “Privacy” section in the “Preferences” menu, “Cookies and other website data” tab;

• Google Chrome browser: “Privacy” section in the “Settings” menu, “Content Settings” subsection, “Cookies and Site Data” tab;

• Microsoft Internet Explorer: “Tools” menu, “Internet Options” tab, then “General”, then “Browsing history”, then “Settings”, “Temporary Internet files and history settings”, and finally “Browse files “;

• Mozilla Firefox browser : “Tools” menu, “Options” section, “Privacy” subsection, dedicated “Delete specific cookies” function.

You can also set certain cookies via the Network Advertising website Initiative or your web browser to block or be warned about the installation of any cookie. The next steps are different for each browser, but instructions can be found in the “Help” menu. Browser settings can be made independently on each device you use to access our Site.

How to disable cookies on your smartphone or tablet?

You can uninstall or delete cookies as follows

• Android browser: “Privacy & security” section in the “Settings” menu, from which you can access “Clear cache”, “Clear passwords”, “Clear all cookies”, “Clear form data” and “Clear passwords” . You can also set these features not to save cookies .

• Google Chrome Browser : In the “Settings” menu, in the “Advanced Options” category, then “Clear browsing data” and then the data you want to delete.

• Apple Browser iOS 8: Select “Settings”, then in the “Safari” tab select “Block cookies” and select one of the options: “Always allow, Only allow websites you visit, Do not allow currently open sites, or Always block.” On iOS 7 or earlier, you can select “Never for third-party sites and advertisers”

Please note that uninstalling or blocking cookies used on the Sites may affect or even prevent your use of the Sites.