Policy

General information
1. The Operator of contentic.io websites and Administrator of personal data is AUDE sp. z o.o. based in Warsaw (02-620), ul.
Puławska 118A, KRS 0000216511, REGON 015796792, NIP 5252306020, e-mail: biuro@aude.pl.
2. The portal obtains information about the Users and their behavior in the following way:
a. Voluntary information provided in: newsletter registration form, inquiries to the Administrator, and order forms;
b. By storing cookies on User’s end device.
3. Personal data collected by the Administrator are processed in accordance with the provisions of 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 on the free movement of such data and the repealing Directive 95/46/EC (General Data
Protection Regulation), the Electronic Services Act of 18 July 2002 (Dz. U. of 2017 r., item 1219, as amended), and the
Telecommunication Law of 16 July 2004 (Dz. U. of 2017, item 1907, as amended).
4. The personal data Administrator makes all efforts to make sure the processing of personal data respects the privacy of data
owners, and specifically asserts that all statutory means have been taken to secure the personal data collections.
5. The Administrator shall, with due diligence, apply adequate technical means, including programming and organizational, to
provide security for the processed data relevant to hazard and category of data being protected, in particular protects
personal details from sharing to unauthorized users, disclosure, loss or damage, unauthorized modification, z należytą
starannością dobiera i stosuje odpowiednie środki techniczne, w tym o charakterze programistycznym i organizacyjnym,
zapewniające ochronę przetwarzanych danych odpowiednią do zagrożeń oraz kategorii danych objętych ochroną, w
szczególności zabezpiecza dane przed ich udostępnieniem osobom nieupoważnionym, ujawnieniem, utraceniem i zniszczeniem,
nieuprawnioną modyfikacją, as well as against unlawful processing of the data.
6. The website may include hyperlinks to other websites. The Administrator will not be held responsible for the personal data
protection policy used by those websites. The Administrator undertakes to ensure with due diligence that the Users are aware
of using a different website not belonging to the Administrator after using a hyperlink.

Personal data processing extent, purpose and legal basis
1. The website collects information sent voluntarily by Users in: newsletter registration forms, inquiries to the Administrator, and
in order forms.
2. In addition, the website may store information about connection parameters, such as IP address, proxy server, name of session,
device, operating system and browser of the User, online or mobile services providers location and name for technical and
administrative purposes, for executing a contract whose data owner is one of the signing parties (based on article 6 item 1
letter b GDPR) or to generate collective and statistical information (e.g. about the region from which the connection comes),
which do not allow to identify the User, as well as for security reasons.
3. Personal details of website Users, who did not fill in any form on the website, are not provided to third parties, unless the User
agreed to this or the obligation to make available collected information arises from compliance with applicable law. Personal
details of website Users who filled in one of the forms on the website may be provided to the following categories of
recipients:
a. IT systems and services providers to the Administrator;
b. Marketing agencies and other entities providing services for the Administrator, necessary for maintaining the website
and ongoing contact with customers etc.;
c. Accounting office employed by the Administrator;
d. Post operators or carriers for delivery purposes;
e. Public organs, institutions and third parties authorized to demand access to personal data on the basis of mandatory
provisions of law.
4. Users data is processed with regard to:
a. Answering enquiries by Users sent via contact form (data scope: name, email address) – due to the fact that
processing is necessary to take up actions on the request of the data owner, prior to signing agreement (article 6
istem 1 letter b GDPR);
b. Sending electronic newsletter by the Administrator and sending information about products, services, promotions
and competitions organized by the Administrator (scope of data: name, email address) – permission provided (article
6 item 1 letter a GDPR);
c. Signing and executing a contract one party of which is the User, in particular issuing a VAT invoice, delivering goods,
processing complaint (scope of data: name, email address, postal address, phone number, company name, NIP,
REGON, bank account number) – due to the fact that the processing is necessary to execute a contract in which one
of the parties is the data owner (article 6 item 1 letter b GDPR);
d. Pursuing claims (scope of data: name, email address, postal address, phone number, company name, NIP, REGON,
bank account number, other data necessary to prove the claim or defend rights) – in accordance with article 6 item
1 letter f GDPR;

e. Direct marketing (scope of data: name, email address and information about User’s activity recorded and stores via
cookies) – in accordance with article 6 item 1 letter f GDPR, i.e. due to the fact that the processing is necessary for
the purposes resulting from legally justified interests of the Administrator or by a third party;
f. Fulfilling legal obligations incumbent on the Administrator resulting from business activity (scope of data: name,
email address, postal address and all other data obtained from the User) – in accordance with article 6 item 1 letter
c GDPR, i.e. due to the fact that the processing is necessary to fulfill legal obligations by the Administrator;
g. Sending commercial information via email in accordance with article 10 item 2 Act on Electronic Services from 18
July 2002 (scope of data: name, email address) – on the basis permission provided;
h. Using telecommunication terminal devices and automated calling systems for direct marketing purposes in
accordance with article 172 of Telecommunications Law of 16 July 2004 (scope of data: name, email address) – on
the basis of permission provided.

5. In the process of data transfer due to sending newsletter application forms, enquiries to the Administrator and placing orders,
the User receives information mentioned in article 13 item 1 and 2 of GDPR and can agree to the storing and processing of
personal details by the Administrator, in the way and for the purposes described in applicable agreement provisions and in this
here document. Providing personal details by User is voluntary, but it is necessary to:
a. Answering User’s enquiries send via contact form, and the lack of such data will result in the impossibility to service such
enquiries by the Administrator;
b. Sending a newsletter, and the lack of such data will result in the impossibility of receiving a newsletter from the Administrator;
c. Executing a contract, and the lack of such data will result in the impossibility of signing a contract with the Administrator.
1. The User will be held responsible for providing false personal data.
2. The Administrator does not process User personal data with automated decision making tools, including profiling.
3. The personal data will be processed:
a. Throughout the time of correspondence initiated by an enquiry sent by User via contact form – and three months following the
correspondence;
b. Until withdrawing an agreement for, or placing an objection to, data processing – in cases of User personal data processing on
the basis of a separate agreement to receive a newsletter or on the basis of article 6 item 1 letter e or f GDPR, including for
direct marketing purposes;
c. Throughout the time necessary to execute a sales agreement, and also after its execution due to the fact the parties can make
use of their rights resulting from the agreement, and also due to possible claims – until expiry date of User’s claims towards
the Administrator;
d. Throughout the lifespan of cookies stored on User’s devices – in the case of processing of data of a User browsing through the
website content.
1. The Administrator also stores Users personal details when it is necessary to comply with legal obligations, to settle disputes,
execute User’s obligations resulting from the agreements signed, for security reasons and to prevent fraud and misuse – until
expiry date of claims towards the User.

Cookies policy
1. When using the website, cookie files are used, which are computer data, in particular text files stored on website User’s end
device, developed for using the website. Cookies normally include the name of the website they come from, time of storing
them on the end device, and their unique number.
2. Cookies used by the Administrator are safe for the User’s devices.
3. The Administrator uses the following cookie types:
a. Session cookies – temporary files, which are stored in User’s end device until closing the session of a given internet
browser, when the information stored in permanently removed from the device’s memory;
b. Persistent cookies – these are stored in the User’s end device for the time determined in cookie files parameters or
until they are deleted by the User. Closing an online browser session or shutting down the end device does not result
in deleting them from the User’s device.
4. The Administrator uses cookies for the following purposes:
a. Adjusting website content for the User’s preferences and website use optimization; in particular, the files allow to
recognize the User’s device and display the website in a way adjusted to their individual needs;
b. Creating statistics, which allow to understand how website Users are using it, helping to improve the website
structure and content;
c. Allowing to store information about the ways of using the website;
d. Enabling memorizing the settings chosen by User and personalizing the User’s interface, e.g. with reference to the
language or region chosen, font size, look of the website etc.;
e. Enabling to provide advertising content to Users which is more aligned with their interests.
5. The Administrator hereby notifies, that in many cases the software used for browsing websites (internet browser) allows for
storing cookies by default on the User’s end device. Website Users may at any time change their cookie settings. In particular,
the settings can be changed in order to block automatic servicing of cookie files in internet browser settings, or to notify each
time about storing them on the website User’s device. Detailed information about possibilities and ways of servicing cookie

files is available in the settings of the software used by the User (in “Help” section in browser’s menu, e.g. Internet Explorer,
Edge, Chrome, Firefox, Opera).
6. The website Operator hereby informs that limited use of cookie files may impact some functions available of the website. For
this reason it is recommended to use software with the cookie service on.
7. In case the User did not switch off cookie files storage in the browser menu, it is assumed the User agrees to cookie files being
stored on his or her end device.

User rights
1. The Administrator secures to All Users the execution of the rights described in point 2 below. Users can execute their rights by
sending a request via email to: biuro@aude.pl.
2. User has the right to:
a. Access data – in accordance with article 15 of GDPR;
b. Data correction/update – in accordance with article 16 of GDPR;
c. Remove the data – in accordance with article 17 of GDPR;
d. Limit the data processing – in accordance with article 18 of GDPR;
e. Transfer data – in accordance with article 20 of GDPR;
f. Oppose the data processing – in accordance with article 21 of GDPR;
g. Withdraw consent in any moment; consent withdrawal does not impact the legality of the processing made on the basis of the
consent prior to its withdrawal – in accordance with article 7 item 3 of GDPR;
h. Place a complaint to the supervising organ, i.e. President of Personal Data Protection Office – in accordance with article 77 of
GDPR.
1. The Administrator processes the incoming requests as soon as possible, but not later than a month from the date of receiving
the request. If, however, due to a complex character of the request or the number of requests, the Administrator is not able to
process the User’s request within the above mentioned time, it will be processed in the following two months and the User
shall be notified by the Administrator about the planned extension of the processing time.
2. The Administrator notifies about data correction, deletion or processing rights limitation made on the request of the User all
recipients to whom the personal data was disclosed, unless it turns out impossible or would involve disproportionate efforts.

Changes to privacy policy
1. The Administrator has the right to change this here document, about which the User shall be notified in a way allowing for
getting acquainted with the changes before they come to force, e.g. by posting information on the service’s main website, and
in the case of serious changes also by sending information onto the email address provided by the User.
2. In case of objections on part of the User regarding the changes, the User may request the Administrator to remove his or her
personal data and stop using the service. Further use of the service after notifying about the changes is considered a consent
for storing, using and making available User’s personal data in accordance with the updated document.
Privacy policy does not limit any User rights resulting from the provisions of generally applicable law.