Privacy Policy
The following Privacy Policy defines the rules for storing and accessing data on Users’ Devices used to provide electronic services by the Administrator as well as the rules for collecting and processing Users’ personal data, which has been provided by them personally and voluntarily through the tools available in the Service.
This Privacy Policy is an integral part of the Service Terms and Conditions, which defines the rules, rights, and obligations of Users using the Service.
§1 Definitions
- Service – the website “thermal-baths-krakow.com” operating at www.thermal-baths-krakow.com
- External Service – internet services of partners, service providers, or service recipients cooperating with the Administrator
- Service Administrator / Data Administrator – The Administrator of the Service and Data Administrator (hereinafter Administrator) is the company ETOURS SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, operating at: ul. Hoża 86/410, 00-682 Warsaw, with tax identification number (NIP): 7011180825, providing services electronically through the Service
- User – a natural person for whom the Administrator provides electronic services through the Service
- Device – an electronic device 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 – 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 any information relating to 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 to 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 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
- Pseudonymisation – 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 destroys/overwrites “personal data” making it impossible to identify or link a given record with a specific user or natural person
§2 Data Protection Officer
Based on Article 37 of GDPR, the Administrator has not appointed a Data Protection Officer.
For matters concerning 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 Service’s IT system
- External Cookies – files placed and read from the User’s Device by IT systems of External Services. Scripts of External Services that may place Cookie files on Users’ Devices have been consciously placed in the Service through scripts and services made available and installed in the Service
- Session Cookies – files placed and read from the User’s Device by the Service during one session of the Device. After ending the session, the files are deleted from the User’s Device
- Persistent Cookies – files placed and read from the User’s Device by the Service until their manual deletion. Files are not deleted automatically after the end of the Device session unless the User’s Device configuration is set to delete Cookie files after the end of the Device session
§4 Data Storage Security
- Cookie Storage and Reading Mechanisms – The mechanisms for storing, reading, and exchanging data between Cookie files saved on the User’s Device and the Service are implemented through built-in web browser mechanisms and do not allow for 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. The transfer of viruses, Trojan horses, and other malware to the User’s Device is also practically impossible.
- Internal Cookies – 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 Device used by the User.
- External Cookies – The Administrator takes all possible actions to verify and select Service partners in terms of User security. The Administrator selects known, large partners with global social trust for cooperation. However, they do not have full control over the content of Cookie files from external partners. For the security of Cookie files, their content, and their use in accordance with the license by Scripts installed in the service originating from External Services, the Administrator bears no responsibility to the extent permitted by law. The list of partners is included in the further part of the Privacy Policy.
- Cookie Control
- The User can, at any time, independently change the settings regarding saving, deleting, and accessing data from saved Cookie files for any website
- Information about how to disable Cookie files in the most popular computer browsers is available at: how to disable cookies or from one of the indicated providers:
- The User can at any time delete all stored Cookie files using the tools of the User’s Device through which the User uses the Services
- Cookie Control
- User-side Risks – The Administrator applies 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 activities. The Administrator is not responsible for the interception of this data, impersonation of the User’s session, or their deletion, as a result of the conscious or unconscious activity of the User, viruses, Trojan horses, and other spyware that the User’s Device may be or was infected with. Users should protect themselves against these threats by following safe internet usage principles.
- Storage of Personal Data – The Administrator ensures that they make every effort to ensure that personal data processed voluntarily by Users is secure, access to it is limited and carried out in accordance with their purpose and processing objectives. The Administrator also ensures that they make every effort to secure the possessed data against loss by using appropriate physical and organizational safeguards.
§5 Purposes for Which Cookie Files are Used
- Improvement and facilitation of Service access
- Service personalization for Users
- Enabling login to the service
- Marketing, Remarketing in external services
- Advertising serving services
- Affiliate services
- Conducting statistics (users, number of visits, types of devices, connections, etc.)
- Serving multimedia services
- Providing social services
§6 Purposes of Personal Data Processing
Personal data voluntarily provided by Users is processed for one of the following purposes:
- Implementation of electronic services:
- User account registration and maintenance services in the Service and related functionalities
- Newsletter services (including sending advertising content with consent)
- Services for sharing information about content placed in the Service on social networks or other websites
- Administrator’s communication with Users regarding Service-related matters and data protection
- Ensuring the Administrator’s legally justified interest
- Implementation of regular and private tours purchased through the portal www.thermal-baths-krakow.com
- Implementation of electronic services:
Data about Users collected anonymously and automatically is processed for one of the following purposes:
- Conducting statistics
- Remarketing
- Serving advertisements tailored to User preferences
- Managing affiliate programs
- Ensuring the Administrator’s legally justified interest
§7 External Services’ Cookie Files
The Administrator uses javascript scripts and web components from partners in the Service, who may place their own cookie files on the User’s Device. Please note that in your browser settings, you can decide which cookie files are allowed to be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookie files:
- Multimedia services:
- Social services / combined:
(Registration, Login, content sharing, communication, etc.) - Newsletter services:
- Advertising serving services and affiliate networks:
- Statistics:
- Other services:
Services provided by third parties are beyond the Administrator’s control. These entities may at any time change their terms of service, privacy policies, purpose of data processing, and how they use cookie files.
§8 Types of Collected Data
The Service collects data about Users. Some data is collected automatically and anonymously, while some data is personal data provided voluntarily by Users when signing up for various services offered by the Service.
Anonymous data collected automatically:
- IP address
- Browser type
- Screen resolution
- Approximate location
- Opened service subpages
- Time spent on respective service subpages
- Operating system type
- Previous subpage address
- Referring site address
- Browser language
- Internet connection speed
- Internet service provider
- Demographic data (age, gender)
Data collected during registration:
- First name / last name / nickname
- Email address
- Date of birth / age
- Phone number
- IP address (collected automatically)
- Tax identification number (NIP)
- National Court Register number (KRS)
Data collected during Newsletter subscription:
- First name / last name / nickname
- Email address
- IP address (collected automatically)
Data collected when adding a comment:
- First and last name / nickname
- Email address
- Website address
- IP address (collected automatically)
Some data (without identifying information) may be stored in cookie files. Some data (without identifying information) may be transferred to the statistics service provider.
§9 Access to Personal Data by Third Parties
- As a rule, the Administrator is the sole recipient of personal data provided by Users. Data collected as part of the provided services is not transferred or resold to third parties. Access to data (most often based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to operate the service, i.e.:
- Hosting companies providing hosting or related services for the Administrator
- Companies through which the Newsletter service is provided
- Companies intermediating in online payments for goods or services offered within the Service (in case of purchase transactions in the Service)
- Personal Data Processing Entrustment – Newsletter
The Administrator, in order to provide the Newsletter service, uses the services of a third party – MailChimp service. Data entered in the newsletter subscription form is transferred, stored, and processed in this service provider’s external service.
Please note that the indicated partner may modify their privacy policy without the Administrator’s consent.Personal Data Processing Entrustment – Hosting, VPS, or Dedicated Server Services
The Administrator uses the services of an external hosting, VPS, or Dedicated Server provider – OVH sp. z o.o. for operating the service. All data collected and processed in the service is stored and processed in the service provider’s infrastructure located in Poland. There is a possibility of access to data due to 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 Case of Online Payments
In the case of online payment processing, all payment data is transferred directly by the User to the payment processing entity. Selected data necessary for transaction processing 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.
- As a rule, the Administrator is the sole recipient of personal data provided by Users. Data collected as part of the provided services is not transferred or resold to third parties. Access to data (most often based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to operate the service, i.e.:
§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 individual User action (e.g., adding a comment or post), which will make the data available to anyone visiting the service.
- Personal data is used for automated decision-making (profiling).
Profiling of personal data does not produce legal effects or similarly significantly affect the person whose data is subject to automated decision-making. - Personal data will not be resold 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) may be used for automated decision-making (profiling).
Profiling of anonymous data (without personal data) does not produce legal effects or similarly significantly affect the person whose data is subject to automated decision-making. - Anonymous data (without personal data) will not be resold to third parties.
§11 Legal Basis for Personal Data Processing
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 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(1)(a)
the data subject has given consent to the processing of their personal data for one or more specific purposes - Article 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 - Article 6(1)(f)
processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
- Article 6(1)(a)
- Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
- Telecommunications Law Act of 16 July 2004 (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 of Personal Data Processing
Personal data provided voluntarily by Users:
As a rule, the indicated personal data is stored only for the period of Service provision within the Service by the Administrator. They are deleted or anonymized within 30 days from the termination of services (e.g., deletion of registered user account, unsubscription from the Newsletter list, etc.)
An exception is a situation that requires securing legally justified purposes for further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time the User requests their deletion, for no longer than 3 years in case of violation or suspected violation of the Service terms by the User
Anonymous data (without personal data) collected automatically:
Anonymous statistical data, not constituting personal data, is stored by the Administrator for the purpose of maintaining service statistics for an indefinite period
§13 Users’ Rights Related to Personal Data Processing
Users have the following rights:
- Right of access to personal data
Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator - Right to rectification of personal data
Users have the right to request from the Administrator immediate rectification of personal data which is incorrect and/or completion of incomplete personal data, exercised upon request submitted to the Administrator - Right to erasure of personal data
Users have the right to request from the Administrator immediate erasure of personal data, exercised upon request submitted to the Administrator. For user accounts, data erasure consists of anonymizing data that enables User identification. The Administrator reserves the right to suspend the execution of data erasure request to protect the Administrator’s legally justified interest (e.g., when the User has violated the Terms of Service or the data was obtained through correspondence).
For the Newsletter service, the User has the ability to independently delete their personal data using the link included in each sent email message. - Right to restriction of processing
Users have the right to restriction of processing of personal data in cases specified in Article 18 of GDPR, including questioning the accuracy of personal data, exercised 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 and machine-readable format, exercised upon request submitted to the Administrator - Right to object to processing
Users have the right to object to processing of their personal data in cases specified in Article 21 of GDPR, exercised 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 personal data protection.
§14 Contact with the Administrator
You can contact the Administrator in one of the following ways:
- Postal address – ETOURS SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ, ul. Hoża 86/410, 00-682 Warsaw
- Email address – [email protected]
§15 Service Requirements
- Limiting the saving and access to Cookie files on the User’s Device may cause some Service functions to malfunction.
- The Administrator bears no responsibility for malfunctioning Service features in cases where the User has limited in any way the ability to save and read Cookie files.
§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 they point to may be dangerous for your Device or pose a security threat to your data. The Administrator is not responsible for content located outside the Service.
§17 Changes to the Privacy Policy
- The Administrator reserves the right to make any changes to this Privacy Policy without the need to inform Users about it in terms of the use and application of anonymous data or the use of Cookie files.
- The Administrator reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, about which it will inform Users who have user accounts or are subscribed to the newsletter service, via email within 7 days of the change in provisions. Continued use of the services means familiarization with and acceptance of the introduced changes to the Privacy Policy. In the event that the User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
- Changes introduced to the Privacy Policy will be published on this Service subpage.
- The introduced changes come into effect at the moment of their publication.