The following Privacy Policy shall set out: the rules for saving and accessing data on Users’ Devices using the Website for the purpose of providing electronic services by the Administrator; the rules for collecting and processing Users’ personal data that have been provided by them personally and voluntarily by means of the tools available on the Website.

§1 Definitions

  • Website - The website “asdsystems.eu” operating at https://asdsystems.eu
  • External website - Websites of partners, service providers, or recipients cooperating with the Administrator
  • Website/Data Administrator - The Website Administrator and the Data Administrator (hereinafter referred to as the Administrator) is ASD SYSTEMS POLSKA Sp. Z o. O. Sp. k. operating at the address: ul. Sobieskiego 105, 43-300 Bielsko-Biała, with the following tax identification number (NIP): 547-220-95-66, KRS number: 0000760274, providing electronic services via the Website
  • User - A natural person for whom the Administrator provides services electronically via the Website.
  • Device - An electronic device with software through which the User gains access to the Website.
  • Cookies - Text data collected in the form of files placed on the User’s Device.
  • GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (general regulation on the protection of data).
  • Personal data - Information about an identified or identifiable natural person (“data subject”); an identifiable natural person is a person who can be identified directly or indirectly, in particular on the basis of an identifier such as given name and/or surname, identification number, location data, internet identifier, one or more specific physical, physiological, genetic, and mental factors, and the economic, cultural, or social identity of a natural person.
  • Processing - An operation or a set of operations performed on personal data or sets of personal data in an automated or non-automated manner, such as collecting, recording, organising, storing, adapting or modifying, downloading, viewing, using, disclosing by sending, distributing or another type of sharing, matching or combining, limiting, deleting, or destroying.
  • Restriction of processing - Marking stored personal data with the aim of limiting their processing in the future.
  • Profiling - Any form of automated processing of personal data, which consists of the use of personal data to evaluate certain personal factors of a natural person, in particular to analyse or forecast aspects related to the effects of a natural person’s work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movement.
  • Consent - Consent of the data subject means a voluntary, specific, informed, and unambiguous demonstration of the will of the data subject, in the form of a statement or a clear affirmative action, to allow the processing of personal data that concerns them.
  • Breach of personal data protection - A breach of security leading to accidental or unlawful destruction, loss, modification, unauthorised disclosure, or unauthorised access to personal data transmitted, stored, or otherwise processed.
  • Pseudonymisation - Processing of personal data in such a way that they can no longer be assigned to a specific data subject without additional information, provided that such additional information is kept separately and is subject to technical and organisational measures that prevent their being attributed to an identified or identifiable natural person.
  • Anonymisation - An irreversible process of data operations that destroys/overwrites “personal data”, making it impossible to identify or associate a given record with a specific user or natural person.

§2 Data Protection Inspector

Pursuant to Art. 37 of the GDPR, the Administrator has not appointed the Data Protection Officer.

In matters relating to the processing of data, including personal data, please contact the Administrator directly.

§3 Types of Cookies

  • Internal Cookies - Files uploaded and read from the User’s Device by the Website’s IT system.
  • External cookies - Files placed and read from the User’s Device by the ICT systems of external websites. The scripts of external websites that may place cookies on the User’s Devices have been consciously placed on the Website through scripts and services made available and installed on the Website.
  • Session Cookies - Files placed and read from the User’s Device by the Website during one session of a given Device. After the session ends, the files are removed from the User’s Device.
  • Persistent cookies - Files uploaded and read from the User’s Device by the Website until they are manually deleted. The files are not deleted automatically at the end of the session on the Device, unless the configuration of the User’s Device is set to the Cookie deletion mode after the end of the Device session.

§4 Data storage security

  • Mechanisms for storing and reading Cookie files - Mechanisms for storing, reading, and exchanging data between Cookies saved on the User’s Device and the Website are implemented through the built-in mechanisms of web browsers and do not allow the collection of other data from the User’s Device or data of other websites visited by the User, including personal data or confidential information. It is also practically impossible to transfer viruses, Trojan horses, and other worms to the User’s Device.
  • Internal cookies - Cookie files used by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that may threaten the security of personal data or the security of the Device used by the User.
  • External cookies - The Administrator takes all possible actions to verify and select website partners in the context of Users’ safety. The administrator selects well-known, large partners with global social trust for cooperation. However, it does not have full control over the content of Cookie files from external partners. The Administrator shall not be responsible for the security of Cookie files, their content, and their use in accordance with the license by the Scripts installed on the website, coming from external websites, to the extent permitted by law. The list of partners is provided further in the Privacy Policy.
  • Cookie control
    • The user may at any time independently change the settings for saving, deleting, and accessing the data of saved cookies by each website.
    • Information on disabling cookies in the most popular computer browsers is available on the website: disabling cookies or at one of the following providers:
      • Managing cookies in Chrome
      • Managing cookies in Opera 
      • Managing cookies in Firefox 
      • Managing cookies in Edge 
      • Managing cookies in Safari 
      • Managing cookies in Internet Explorer 11
    • The User may at any time delete any Cookie files saved so far using the User’s Device tools on the Device through which the User uses the Website’s services.
  • Threats on the part of the User - The Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Administrator is not responsible for intercepting this data, impersonating the User’s session, or removing them as a result of the User’s conscious or unconscious activity, viruses, Trojan horses, and other spyware which may have infected the User’s Device. In order to protect themselves against these threats, Users should follow the recommendations of safe internet use.
  • Storage of personal data - The Administrator ensures that it makes every effort to provide that: (1) the processed personal data entered voluntarily by Users are safe; and (2) that access to them is limited and carried out in accordance with their intended use and processing purposes. The administrator also ensures that it makes every effort to protect its data against loss by using appropriate physical and organisational safeguards.

§5 Purposes of Cookies

  • Improving and facilitating access to the Website
  • Personalisation of the Website for Users
  • Marketing, Remarketing on external websites
  • Keeping statistics (users, number of visits, types of devices, connection, etc.)
  • Provision of multimedia services
  • Provision of social networking services

§6 Purposes of personal data processing

Personal data voluntarily provided by Users are processed for one of the following purposes:

  • Implementation of electronic services:
    • Services of sharing information about the content posted on the Website on social networks or other websites.
  • Administrator’s communication with Users on matters related to the Website and data protection
  • Ensuring the legitimate interests of the Administrator

Data concerning Users collected anonymously and automatically are processed for one of the following purposes:

  • Keeping statistics
  • Remarketing
  • Ensuring the legitimate interests of the Administrator

§7 Cookies of external websites

The Website administrator uses JavaScript scripts and web components of partners who may place their own cookies on the User’s Device. Remember that Users can decide about the allowed cookies that can be used by individual websites in Users’ Device browser settings. Below is a list of partners and their services implemented on the Website, who may place cookies:

Services provided by third parties are beyond the Administrator’s control. These entities may at any time change their terms of service, privacy policy, the purpose of data processing, and the methods of using cookies.

§8 Types of collected data

The website collects data about Users. Some data is collected automatically and anonymously, while other data is personal and provided voluntarily by Users when subscribing to individual Website services.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Open website subpages 
  • Time spent on relevant website subpage 
  • Type of operating system
  • Address of previous subpage
  • Address of referring party
  • Browser language
  • Internet connection speed
  • Internet Service Provider
  • Demographics (age, gender)

Data collected during registration:

  • Given name/surname/nickname
  • Login
  • E-mail address
  • IP address (collected automatically)
  • NIP number
  • KRS number
  • REGON number

Data collected when subscribing to the Newsletter service:

  • Given name/surname/nickname
  • E-mail address
  • IP address (collected automatically)

Part of the data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to the statistical service provider.

§9 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users shall be the Administrator. Data collected as part of the services provided are not transferred or sold to third parties.

Access to data (most often on the basis of the Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the website, i.e.:

  • Hosting companies that provide hosting or related services to the Administrator

Entrusting the processing of personal data - Hosting Services, VPS, or Dedicated Servers

In order to run the website, the Administrator uses the services of an external hosting provider, VPS, or Dedicated Servers - HitMe.pl Marek Bajerski. All data collected and processed on the website is stored and processed in the service provider’s infrastructure located in Poland. It is possible to access the data as a result of service work carried out by the service provider’s staff. Access to this data shall be governed by the contract concluded between the Administrator and the Service Provider.

§10 Method of processing personal data

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union unless it has been published as a result of an individual action of the User (e.g., entering a comment or entry), which will make the data available to every website visitor.
  • Personal data shall not be used for automated decision-making (profiling).
  • Personal data shall not be sold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) shall be transferred outside the European Union.
  • Anonymous data (without personal data) shall not be used for automated decision-making (profiling).
  • Anonymous data (without personal data) shall not be sold to third parties.

§11 Legal basis for the processing of personal data

The website collects and processes Users’ data on the basis of:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (general regulation on data protection)
    • art. 6 section 1 letter a
      the data subject has consented to the processing of its personal data for one or more specific purposes
    • art. 6 section 1 letter b
      processing is necessary for the performance of a contract to which the data subject is party, or to take steps at the request of the data subject prior to entering into a contract
    • art. 6 section 1 letter f
      processing is necessary for the purposes of the legitimate interests pursued by the administrator or by a third party
  • Act of May 10, 2018, on the protection of personal data (Journal of Laws of 2018, item 1000)
  • Act of July 16, 2004, Telecommunications Act (Journal of Laws of 2004, No. 171, item 1800)
  • Act of February 4, 1994, on copyright and related rights (Journal of Laws 1994 No. 24 item 83)

§12 Personal data processing period

Personal data provided voluntarily by Users:

As a rule, the indicated personal data shall be stored only for the period of providing the Service on the Website by the Administrator. Personal data shall be deleted or anonymised within 30 days from the end of the provision of services (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.)

The exception is the situation that requires securing the legitimate purposes of further processing of this data by the Administrator. In such an instance, the Administrator shall store the indicated data, from the time the User requests their removal, for no longer than a period of 3 years in the event of a breach or suspected breach of the provisions of the website regulations by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, are stored by the Administrator in order to keep website statistics for an indefinite period.

§13 User rights related to the processing of personal data

The website collects and processes Users’ data on the basis of:

  • The right of access 
    Users have the right to access their personal data, carried out at the request submitted to the Administrator.
  • The right to rectification
    Users have the right to request the Administrator immediately correct personal data that is incorrect and/or supplement incomplete personal data, carried out at the request submitted to the Administrator.
  • The right to erasure
    Users have the right to request the Administrator delete their personal data immediately, upon a request submitted to the Administrator. In the case of user accounts, the deletion of data consists of the anonymisation of data enabling the User’s identification. The Administrator reserves the right to suspend the execution of the request to delete data in order to protect the legitimate interests of the Administrator (e.g., when the User has violated the Regulations or the data was obtained as a result of correspondence).
    In the case of the Newsletter service, the User has the option of removing its personal data itself by using the link in each e-mail sent.
  • The right to restrict processing
    Users have the right to limit the processing of personal data in the cases specified in art. 18 GDPR, including questioning the correctness of personal data, carried out at the request submitted to the Administrator.
  • The right to data portability
    Users have the right to obtain from the Administrator personal data regarding the User in a structured, commonly used machine-readable format, implemented at the request submitted to the Administrator.
  • The right to object to processing of personal data
    Users have the right to object to the processing of their personal data in the cases specified in art. 21 of the GDPR, implemented at the request of the Administrator.
  • The right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory body dealing with the protection of personal data.

§14 Administrator contact details

The Administrator can be contacted in one of the following ways:

  • Postal address - ASD SYSTEMS POLSKA Sp. z o. o. Sp. k., ul. Sobieskiego 105, 43-300 Bielsko-Biała
  • E-mail address - kontakt@asdsystems.pl
  • Telephone - +48 33 444 0000
  • Contact form - available at: /contact

§15 Website requirements

  • Restricting the saving and access to Cookie files on the User’s Device may cause some functions of the Website to malfunction.
  • The Administrator shall not bear any responsibility for incorrectly operating functions of the Website if the User restricts the possibility of saving and reading cookie files in any way.

§16 External links

The articles, posts, entries, or comments of Users on the Website may contain links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated under them may be dangerous for your Device or pose a threat to the security of your data. The Administrator shall not be responsible for the content outside the Website.

§17 Changes in the Privacy Policy

  • The Administrator shall reserve the right to change this Privacy Policy at any time without informing Users in regard to the application and use of anonymous data or the use of cookies.
  • The Administrator shall reserve the right to change this Privacy Policy in any way regarding the processing of Personal Data, of which it will inform Users who have user accounts or have subscribed to the newsletter service via e-mail within 7 days of changing the records. By continuing to use the services, you express that you have read and accepted the changes to the Privacy Policy. In the event that the User does not agree with the introduced changes, it is obliged to delete its account from the Website or unsubscribe from the Newsletter service.
  • The changes made to the Privacy Policy shall be published on this subpage of the Website.
  • The introduced changes shall come into force upon their publication.

The website uses cookies to provide services in accordance with the Privacy Policy. You can define the conditions for storing or accessing cookies in your browser or service configuration.