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Privacy policy

Privacy Policy

This Privacy Policy defines the rules for storing and accessing data on Users’ Devices using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing the personal data of Users that have been provided by them personally and voluntarily through the tools available on the Service.

This Privacy Policy is an integral part of the Service Regulations, which specify the rules, rights, and obligations of Users using the Service.

§1 Definitions

  • Service – the website “JakNapisac.com” operating at https://www.jaknapisac.com/
  • External Service – internet services of partners, service providers, or service recipients cooperating with the Administrator
  • Service Administrator / Data Administrator – The Service Administrator and Data Administrator (hereinafter referred to as the Administrator) is NTN Publisher, operating at the following address: ul. Stefana Batorego 18/108, 02-591 Warsaw, with a tax identification number (NIP): 125 152 55 80, providing electronic services through the Service.
  • User – a natural person for whom the Administrator provides electronic services through the Service.
  • Device – an electronic device along with software through which the User gains access to the Service.
  • Cookies – text data collected in the form of files placed on the User’s Device.
  • GDPR – General Data Protection 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).
  • Personal Data – means information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person.
  • Processing – means an operation or set of operations that are performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, or otherwise making available, alignment, or combination, restriction, erasure, or destruction.
  • Restriction of Processing – means marking stored personal data with the aim of limiting their processing in the future.
  • Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
  • Consent – consent of the data subject means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
  • Personal Data Breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
  • Pseudonymization – means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
  • Anonymization – Data anonymization is an irreversible process of data operations that destroy/overwrite “personal data,” making it impossible to identify or link a specific record to a particular user or individual.

§2 Data Protection Officer

Based on Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

For matters related to the processing of data, including personal data, please contact the Administrator directly.

§3 Types of Cookie Files

  • Internal Cookies – files placed and read from the User’s Device by the teleinformation system of the Service.
  • External Cookies – files placed and read from the User’s Device by the teleinformation systems of external Services. Scripts of external Services that may place Cookie files on the User’s Device have been consciously placed in the Service through scripts and services made available and installed on the Service.
  • Session Cookies – files placed and read from the User’s Device by the Service during one session of a given Device. After the session ends, the files are deleted from the User’s Device.
  • Persistent Cookies – files placed and read from the User’s Device by the Service until manually deleted. The files are not automatically deleted after the Device’s session ends unless the User’s Device is configured to delete Cookie files after the Device’s session ends.

§4 Data Storage Security

  • Mechanisms for storing and reading Cookie files – The mechanisms for storing, reading, and exchanging data between Cookie files saved on the User’s Device and the Service are carried out through built-in mechanisms of web browsers and do not allow the retrieval of other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. It is also practically impossible to transfer viruses, trojans, and other malware to the User’s Device.
  • Internal Cookies – The Cookie files used by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the User’s Device.
  • External Cookies – The Administrator makes every effort to verify and select service partners with the security of Users in mind. The Administrator collaborates with well-known, large partners with a global social trust. However, the Administrator does not have full control over the content of Cookie files originating from external partners. For the security of Cookie files, their content, and the use of scripts installed in the service by external service providers, the Administrator is not responsible to the extent permitted by law. The list of partners is included in the later part of the Privacy Policy.
  • Cookie Control

  • User-Side Threats – The Administrator takes 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 the interception of this data, impersonation of the User’s session, or their deletion due to the conscious or unconscious activity of the User, viruses, trojans, and other spyware that may or may have been infected with the User’s Device. To protect against these threats, Users should follow the rules of using the Internet.
  • Storage of Personal Data – The Administrator ensures that every effort is made to process personal data voluntarily provided by Users securely, with limited access and in accordance with their purpose and processing objectives. The Administrator also ensures that every effort is made to secure the data held against loss through the use of appropriate physical and organizational security measures.

§5 Purposes for Using Cookie Files

Purposes:

  • Improving and facilitating access to the Service
  • Personalizing the Service for Users
  • Enabling logging into the service
  • Marketing and Remarketing on external services
  • Ad serving services
  • Affiliate services
  • Collecting statistics (users, visit counts, device types, connections, etc.)
  • Serving multimedia services
  • Providing social services

How will Google use data on our website?

  • Google uses the information provided on websites and applications to provide and improve services, manage them, develop new services, measure the effectiveness of advertisements, protect against fraud and abuse, and personalize the content and ads displayed on Google and on the websites and applications of our partners.
  • Visit Google’s Privacy & Terms site / https://policies.google.com/technologies/partner-sites for current information.

How does Google personalize ads? How can I edit settings?

How can you control information collected by Google?

§6 Purposes of Personal Data Processing

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

  • Provision of electronic services:
    • Service registration and maintenance of User accounts in the Service and related functionalities
    • Service for commenting/liking entries on the Service without the need to register
    • Service for sharing information about the content placed in the Service on social media or other websites.
  • Communication by the Administrator with Users regarding matters related to the Service and data protection
  • Ensuring the legitimate interests of the Administrator

Anonymous data collected about Users, automatically and anonymously, are processed for one of the following purposes:

  • Statistics gathering
  • Remarketing
  • Serving advertisements tailored to Users’ preferences
  • Affiliate program support
  • Ensuring the legitimate interests of the Administrator

§7 Cookies of External Services

In the Service, the Administrator uses JavaScript scripts and web components of partners who may place their own cookies on the User’s Device. Remember that in your browser settings, you can decide which cookies are allowed to be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, privacy policies, data processing purposes, and ways of using cookies at any time.

§8 Types of Collected Data

The Service collects data about Users. Some data are collected automatically and anonymously, while some data are personal data provided voluntarily by Users when registering for specific services offered by the Service.

Automatically Collected Anonymous Data:

  • IP Address
  • Browser Type
  • Screen Resolution
  • Approximate Location
  • Subpages opened on the website
  • Time spent on a specific page of the website
  • Operating System Type
  • Previous Page Address
  • Referring Page Address
  • Browser Language
  • Internet Connection Speed
  • Internet Service Provider

Data Collected During Registration:

  • First Name / Last Name / Nickname
  • Username
  • Email Address
  • IP Address (collected automatically)

Data Collected When Adding a Comment

  • First Name and Last Name / Nickname
  • Email Address
  • Website Address
  • IP Address (collected automatically)

Some data (without identifying information) may be stored in cookies. Some data (without identifying information) may be transferred to a statistical service provider.

§9 Access to Personal Data by Third Parties

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

Entities responsible for maintaining the infrastructure and services necessary for running the service may have access to the data (usually based on a data processing agreement), including:

  • Hosting companies providing hosting or related services for the Administrator

Data Processing Agreement – Hosting, VPS, or Dedicated Servers Services

For the purpose of running the service, the Administrator uses the services of an external hosting, VPS, or dedicated servers provider – cyber_Folks S.A. All data collected and processed on the service is stored and processed within the infrastructure of the service provider located in Poland. There is a possibility of data access due to service work carried out by the service provider’s personnel. Access to this data is regulated by the agreement between the Administrator and the service provider.

§10 Method of Personal Data Processing

Personal data voluntarily provided by Users:

  • Personal data will not be transferred outside the European Union, unless they have been published as a result of individual User actions (e.g., posting a comment or entry), making the data available to anyone visiting the service.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be sold to third parties.

Anonymous data (without personal information) collected automatically:

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

    §11 Legal Bases for Processing Personal Data

    The service collects and processes User data based on:

    • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
      • Art. 6(1)(a)
        the data subject has given consent to the processing of his or her personal data for one or more specific purposes
      • Art. 6(1)(b)
        processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
      • Art. 6(1)(f)
        processing is necessary for the purposes of the legitimate interests pursued by the data controller or by a third party
    • Act of 10 May 2018 on personal data protection (Journal of Laws of 2018, item 1000)
    • Act of 16 July 2004 – Telecommunications Law (Journal of Laws of 2004, No. 171, item 1800)
    • Act of 4 February 1994 on copyright and related rights (Journal of Laws of 1994, No. 24, item 83)

    §12 Period of Personal Data Processing

    Personal data voluntarily provided by Users:

    As a rule, the specified personal data is stored only for the duration of the Service provided by the Administrator. They are deleted or anonymized within 30 days from the end of the provision of services (e.g., deleting a registered user account, unsubscribing from the newsletter, etc.)

    An exception is a situation that requires securing the legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will retain the specified data, from the moment the User requests their deletion, but not longer than for a period of 3 years in the event of a violation or suspicion of a User’s violation of the service regulations.

    Anonymous data (without personal information) collected automatically:

    Anonymous statistical data, which do not constitute personal data, are stored by the Administrator for an indefinite period to maintain service statistics.

    §13 User Rights Related to Personal Data Processing

    The service collects and processes User data based on:

    • Right of access to personal data
      Users have the right to access their personal data, exercised upon a request submitted to the Administrator.
    • Right to rectify personal data
      Users have the right to request the Administrator to promptly rectify personal data that are inaccurate or incomplete, exercised upon a request submitted to the Administrator.
    • Right to erasure of personal data
      Users have the right to request the Administrator to promptly erase personal data, exercised upon a request submitted to the Administrator. In the case of user accounts, data erasure involves anonymizing data that could identify the User. The Administrator reserves the right to delay data erasure requests to protect the legitimate interests of the Administrator (e.g., when a User has violated the Terms and Conditions or data has been obtained through ongoing correspondence). In the case of the Newsletter service, Users have the option to delete their personal data by using the link provided in each email.
    • Right to restrict processing of personal data
      Users have the right to restrict the processing of personal data in cases specified in Article 18 of the GDPR, including questioning the accuracy of personal data, exercised upon a request submitted to the Administrator.
    • Right to data portability
      Users have the right to receive from the Administrator the personal data concerning the User in a structured, commonly used, and machine-readable format, exercised upon a request submitted to the Administrator.
    • Right to object to the processing of personal data
      Users have the right to object to the processing of their personal data in cases specified in Article 21 of the GDPR, exercised upon a request submitted to the Administrator.
    • Right to lodge a complaint
      Users have the right to lodge a complaint with the supervisory authority responsible for data protection.

    §14 Contact with the Administrator

    You can contact the Administrator in one of the following ways:

    • Mailing address – 18/108 Stefan Batorego Street, 02-591 Warsaw
    • Email address – contact@jaknapisac.com

    §15 Service Requirements

    • Limiting the storage and access to Cookie files on the User’s Device may cause some Service features to malfunction.
    • The Administrator shall not be responsible for the malfunctioning of Service features in case the User limits the ability to store and read Cookie files in any way.

    §16 External Links

    In the Service – articles, posts, entries, or User comments may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated on them may be hazardous to your Device or pose a threat to the security of your data. The Administrator is not responsible for content located outside the Service.

    §17 Changes in the Privacy Policy

    • The Administrator reserves the right to change this Privacy Policy at any time without informing Users regarding the application and use of anonymous data or the use of Cookie files.
    • The Administrator reserves the right to change this Privacy Policy concerning the processing of Personal Data, and will inform Users with user accounts or subscribed to the newsletter by email within 7 days of the change. Continued use of the services signifies acknowledgment and acceptance of the introduced changes to the Privacy Policy. If a User does not agree with the changes, they are obligated to delete their account from the Service or unsubscribe from the Newsletter service.
    • The introduced changes to the Privacy Policy will be published on this subpage of the Service.
    • The introduced changes come into effect at the moment of their publication.