General Provisions

1. This Policy explains how we collect, use, and process your personal data in connection with your use of our website. It also provides information about cookies and other tools we use.

Processing of Personal Data

1. The controller of your personal data is Torus sp. z o.o., with its registered office in Gdańsk (postal code: 80-309), al. Grunwaldzka 413.
2. While you use our website, we collect in particular: IP addresses, URL addresses, information about your website behavior, clicks on website elements, dates and times of visits, the name of your Internet service provider, information about your operating system, and the type and version of your browser.
3. We collect your personal data through: cookies accepted by you and the use of the Google Analytics analytical tool.
4. Your personal data is processed in order to enable you to use the full functionality of our website, for analytical purposes to improve the quality of displayed content, and for the development, repair, or testing of various website functionalities. The legal basis for processing is your consent (Article 6(1)(a) of the GDPR).
5. Your personal data may also be processed by us for the purpose of establishing, pursuing, or defending against claims related to the use of the website or the processing of your personal data – as such processing is necessary for the purposes of our legitimate interest (Article 6(1)(f) of the GDPR), which is the ability to establish, pursue, or defend against such claims.
6. Your personal data will be processed by us for various periods, depending on the purpose:
   – for the use of our website, analytical purposes, quality improvement, development, repair, or testing – until you close your web browser (so-called session cookies) or until you delete cookies from your browsing history (so-called persistent cookies);
   – for the establishment, pursuit, or defense against claims related to your use of the website or the processing of your personal data – until the limitation period for such claims expires, or until the defense against such claims is completed, or until you lodge an objection as described below.
7. Your personal data may be transferred to recipients processing data on our behalf, such as entities providing:
   – archiving services,
   – IT and new technology services,
   – marketing, communication, and analytical services (including satisfaction and preference surveys),
   – electronic support services,
   – consulting services.
8. Data may also be disclosed to entities authorized to obtain it under applicable law, including law enforcement agencies, tax authorities, or other public bodies and institutions acting under separate legal provisions.
9. The data will not be used for automated decision-making, including profiling.
10. Personal data may be transferred to a third country in connection with the use of cookies originating from companies based in the United States. In relation to the transfer of your data outside the EEA, we have ensured that data recipients provide a high level of data protection. These guarantees result from participation in the “Privacy Shield” program established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-U.S. Privacy Shield, pursuant to Article 45(1) of the GDPR.

Your Rights Regarding the Processing of Personal Data

1. Providing personal data in connection with your consent is always voluntary, and failure to provide it (refusal or withdrawal of consent) will not result in any negative consequences for you, but may make it difficult or even impossible to use our website (for technical reasons).
2. You have the right to access your personal data processed by us and to receive a copy of such data.
3. You have the right to request the rectification (correction or completion), restriction of processing, or erasure of your personal data.
4. If justified by your particular situation, you have the right to object to the processing of your data for the purpose of establishing, pursuing, or defending against claims.
5. You have the right to request the transfer of your data that we process, meaning you may receive it in a structured, commonly used, machine-readable format and have the right to transmit that data to another controller. Where technically feasible, you may also request that we transfer the data directly to another controller.
6. You have the right to lodge a complaint with the President of the Personal Data Protection Office if you believe that the processing of your personal data violates data protection regulations.
7. If you have accepted cookies, you also have the right to withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing carried out prior to the withdrawal. Detailed information on the processing of your personal data in connection with cookie acceptance can be found here.

To exercise the above rights, you may contact us:
• by email: dane.osobowe@torus.pl
• in writing, by sending correspondence to: Torus sp. z o.o., al. Grunwaldzka 413, 80-309 Gdańsk, with the note “Personal Data Protection”.