Privacy Policy
Privacy Policy – Company/Business The following Privacy Policy sets out the rules for recording and accessing data on Users’ Devices using the Website for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users’ personal data that they have provided personally and voluntarily through the tools available on the Website.
The following Privacy Policy is an integral part of the Website Terms and Conditions, which set out the rules, rights, and obligations of Users using the Website.
§1 Definitions
Website – the website https://smartdealfusion.com operating at the address https://smartdealfusion.com
External Service – internet services of partners, service providers, or service recipients cooperating with the Administrator.
Service/Data Administrator – the Administrator of the Service and the Data Administrator (hereinafter referred to as the Administrator) is the company SafeYourLife IZABELA DRYLIE conducting business at the address: Jesionowa 3, 76-200 Słupsk, with the assigned tax identification number (NIP): 6040248270, with the assigned KRS number: , providing electronic services via the Website.
User – a natural person for whom the Administrator provides electronic services via the Website.
Device – an electronic device along 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.
RODO – 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, 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 any operation or set of operations which is performed on personal data or on 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 the marking of 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 – means the consent of the data subject which means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.
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 way that the 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 – Anonymization of data is an irreversible process of data operations that destroys or overwrites “personal data” to prevent identification or association of a given record with a specific user or natural person.
§2 Data Protection Officer
Based on Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.
For matters regarding data processing, including personal data, please contact the Administrator directly.
§3 Types of Cookies
Internal Cookies – files placed and read from the User’s Device by the ICT system of the Website.
External Cookies – files placed and read from the User’s Device by the ICT systems of external services. Scripts of external services that may place Cookies on the User’s Device 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 deleted from the User’s Device.
Persistent Cookies – files placed and read from the User’s Device by the Website until they are manually deleted. The files are not deleted automatically after the session ends unless the User’s Device configuration is set to the cookie deletion mode after the 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 Website are implemented through built-in web browser mechanisms and do not allow for downloading 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, Trojan horses, and other worms to the User’s Device. Internal Cookies – The cookies 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 service partners in the context of User safety. The Administrator selects well-known, large partners with global social trust for cooperation. However, the Administrator does not have full control over the content of cookies from external partners. The Administrator is not responsible for the security of cookies, their content, or their lawful use by Scripts installed on the service, originating from external services, to the extent permitted by law. A list of partners is included later in this Privacy Policy.
The User can change the settings for saving, deleting, and accessing data stored in cookies by any website at any time.
Cookie Control
Information on how to disable cookies in the most popular computer browsers is available on the page: how to disable cookies or from one of the indicated 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 can delete all cookies saved so far at any time using the tools of the User’s Device, through which the User uses the Website’s services.
User-Side Threats – The Administrator takes all possible technical measures to ensure the security of data placed in cookies. However, it should be noted that the security of these data depends on both parties, including the User’s activity. The Administrator is not responsible for the interception of these data, impersonation of the User’s session, or their deletion as a result of conscious or unconscious User activity, viruses, Trojan horses, and other spyware that may infect the User’s Device. Users should follow the principles of safe network use to protect against these threats.
Personal Data Storage – The Administrator ensures that all efforts are made to ensure that the personal data voluntarily provided by Users are safe, access to them is limited, and realized in accordance with their purpose and processing objectives. The Administrator also ensures that all efforts are made to secure the data held against loss by using appropriate physical and organizational security measures.
Password Storage – The Administrator states that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. Decryption of passwords provided in the Service for account access is practically impossible.
§5 Purposes for which cookies are used
- Improving and facilitating access to the Website
- Personalizing the Website for Users
- Enabling Login to the website
- Marketing, Remarketing in external services
- Advertising services
- Affiliate services
- Conducting statistics (users, number of visits, types of devices, connections, etc.)
§6 Purposes of processing personal data
Personal data voluntarily provided by Users are processed for one of the following purposes:
Provision of electronic services:
- Services for registration and maintenance of User accounts on the Website and functionalities related to them.
- Communication between the Administrator and Users regarding the Website and data protection.
- Ensuring the legitimate interest of the Administrator.
Data about Users collected anonymously and automatically is processed for one of the following purposes:
- Conducting statistics
- Remarketing
- Serving advertisements tailored to Users’ preferences
- Handling affiliate programs
- Ensuring the legitimate interest of the Administrator
§7 Cookies of external services
The Administrator uses JavaScript scripts and web components of partners on the Website, who may place their own cookies on the User’s Device. Remember that in your browser settings, you can decide on the permitted cookies that may be used by individual websites. Below is a list of partners or their services implemented on the Website, which may place cookies:
Advertising services and affiliate networks:
- Google Adsense
Statistics management:
- Google Analytics
- WordPress Stats (Automattic Inc.)
- Facebook Analytics for Apps
Other services:
- Google Maps
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 methods of using cookies at any time.
§8 Types of data collected
The Website collects data about Users. Some data is collected automatically and anonymously, and some data is personal data voluntarily provided by Users during registration for individual services offered by the Website.
Anonymously collected data automatically:
- IP address
- Browser type
- Screen resolution
- Approximate location
- Opened subpages of the website
- Time spent on the appropriate subpage of the website
- Type of operating system
- Address of the previous subpage
- Referrer page address
- Browser language
- Internet connection speed
- Internet service provider
Data collected during registration:
- First name / last name / pseudonym
- Login
- Email address
- IP address (collected automatically)
Data collected during subscription to the Newsletter service:
- Email address
Data collected when adding a comment:
Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to a statistical service provider.
- First name and last name / pseudonym
- Email address
- Website address
- IP address (collected automatically)
§9 Access to personal data by third parties
As a rule, the only recipient of personal data provided by Users is the Administrator. The data collected as part of the services provided are not transferred or sold to third parties.
Access to the data (usually based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to operate the website, such as:
- Hosting companies providing hosting or related services for the Administrator
- Companies intermediating online payments for goods or services offered on the Website (if transactions are made on the Website)
- Companies responsible for delivering physical products to the User (postal / courier services if transactions are made on the Website)
Data Processing Agreement – Hosting Services, VPS, or Dedicated Servers
The Administrator uses the services of an external hosting, VPS, or Dedicated Servers provider – LH.pl sp. z o.o. https://www.lh.pl/pomoc/polityka-prywatnosci/. All data collected and processed on the website is stored and processed in the service provider’s infrastructure located in Poland. Access to the data may occur as a result of maintenance work carried out by the service provider’s personnel. Access to this data is regulated by an agreement between the Administrator and the Service Provider.
Data Processing in the Case of Online Payments
For online payments, all payment data is provided directly by the User to the payment entity – https://stripe.com/en-pl/privacy Stripe. The selected data necessary for the transaction is then transferred by this entity to the Administrator. The transfer of data is regulated by an agreement between the Administrator and the Service Provider.
Transfer of Personal Data – Courier Services
In the case of a transaction that requires the transfer of an item related to the transaction, through the post or via courier, some personal data of natural persons or data of natural persons conducting business activity are transferred to the entity providing postal / courier services to the Administrator, chosen by the User. The transfer of this data is regulated by an agreement between the Administrator and the Service Provider.
§10 Method of processing personal data
Personal data will not be transferred outside the European Union unless published as a result of an individual User’s action (e.g., entering a comment or post), making the data available to anyone visiting the website.
Personal data will not be used for automated decision-making (profiling).
Personal data will not be sold to third parties.
Anonymous data (without personal data) collected automatically:
- Anonymous data (without personal data) will be transferred outside the European Union.
- Anonymous data (without personal data) will not be used for automated decision-making (profiling).
- Anonymous data (without personal data) will not be sold to third parties.
§11 Legal basis for the processing of personal data
The Website collects and processes Users’ 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 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)
Article 6, paragraph 1, letter a
- The data subject has given consent to the processing of their personal data for one or more specific purposes.
Article 6, paragraph 1, letter b
- Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract.
Article 6, paragraph 1, letter f
- Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party.
- Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)
- Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171 item 1800)
- Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No. 24 item 83)
§12 Period for processing personal data
Personal data voluntarily provided by Users: As a rule, the specified personal data is stored only for the period of service provision on the Website by the Administrator. They are deleted or anonymized within 30 days from the end of service provision (e.g., deletion of 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 case, the Administrator will store the specified data from the time of the User’s request for their deletion, for no longer than 3 years in the event of a breach or suspicion of a breach of the Website’s terms and conditions by the User.
Anonymous data (without personal data) collected automatically: Anonymous statistical data, not constituting personal data, are stored by the Administrator for the purpose of maintaining website statistics for an indefinite period.
§13 Users’ rights related to the processing of personal data
The Website collects and processes Users’ data based on:
Right of access to personal data Users have the right to access their personal data, which is implemented upon request submitted to the Administrator.
Right to rectify personal data Users have the right to request the Administrator to immediately rectify personal data that is incorrect or to complete incomplete personal data, which is implemented upon request submitted to the Administrator.
Right to delete personal data Users have the right to request the Administrator to immediately delete their personal data, which is implemented upon request submitted to the Administrator. In the case of user accounts, data deletion involves anonymizing data that identifies the User. The Administrator reserves the right to withhold the request to delete data in order to protect the legally justified interest of the Administrator (e.g., if the User has violated the Terms and Conditions or the data has been obtained as a result of correspondence).
In the case of the Newsletter service, the User can delete their personal data using the link included in each email sent.
Right to restrict the processing of personal data Users have the right to restrict the processing of their personal data in cases indicated in Article 18 of the GDPR, including challenging the correctness of personal data, which is implemented upon request submitted to the Administrator.
Right to data portability Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used, machine-readable format, which is implemented upon 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, which is implemented upon request submitted to the Administrator.
Right to lodge a complaint
Users have the right to lodge a complaint with the supervisory authority dealing with the protection of personal data.
§14 Contacting the Administrator
You can contact the Administrator in one of the following ways:
- Email address: smartdealfusion@gmail.com
- Telephone call: +48732777809
§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 is not responsible for any malfunctioning functions of the Website if the User in any way restricts the ability to save and read Cookie files.
§16 External Links
In the Website – articles, posts, entries, or User comments may contain links to external websites that the Website Owner does not cooperate with. These links and the pages or files indicated by them may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content outside the Website.
§17 Changes to the Privacy Policy
The Administrator reserves the right to change this Privacy Policy at any time without informing Users about it in terms of the application and use of anonymous data or the use of Cookie files.
The Administrator reserves the right to change this Privacy Policy regarding the processing of Personal Data, which will be communicated to Users with user accounts or subscribed to the newsletter service via email within 7 days of the changes. Continued use of the services means that you have read and accepted the introduced changes to the Privacy Policy. If the User does not agree with the changes introduced, they are obliged to delete their account from the Website or unsubscribe from the Newsletter service.
Changes introduced in the Privacy Policy will be published on this subpage of the Website.
Changes introduced come into force upon their publication.