Privacy and cookies policy

The administrator of your personal data is the Association of the Carpathian Euroregion Poland, pl. Jana Kilińskiego 2, 35-005 Rzeszów, NIP: 813-32-05-337

As part of the implementation of personal data protection in my organization, a decision was made not to appoint a personal data protection officer due to the fact that it is not obligatory. In matters related to the protection of personal data and broadly understood privacy, please contact the following e-mail address: sekretariat@karpacki.pl

Depending on the purpose, we may process the following information:

• first name and last name,
• e-mail adress,
• Phone number,
• IP address,
• approximate location,
• the content of comments / opinions added on the website.

The scope of processed data has been precisely described in relation to each processing purpose. Information in this regard can be found in the further part of this policy.

What's more, tools were used that collect a lot of information about you related to the use of the karpacki.pl website. It includes the following information in particular:

• information about the operating system and web browser,
• subpages viewed,
• time spent on the site,
• transitions between individual subpages,
• clicks on individual links,
• the source from which you go to the page,
• the age range you are in,
• Your gender
• Your approximate location limited to the town.
• Your interests based on your online activity.

This information is referred to in the remainder of this privacy policy as "Anonymous Information".

Anonymous Information by itself is not, in our opinion, personal data, as it does not allow your identification and we do not match it with typical personal data collected about you. Nevertheless, taking into account the rigorous jurisprudence of the Court of Justice of the European Union and divided opinions among lawyers, as a precautionary measure in the event that Anonymous Information is assigned the nature of personal data, this privacy policy also provides detailed explanations of the processing of such information.

As Anonymous Information is collected by external tools we use (the tools are discussed in detail in the further part of the privacy policy), Anonymous Information is also processed by tool providers in accordance with their regulations and privacy policies.

Anonymous Information is also used by the providers of individual tools to provide and improve services, manage them, develop new services, measure the effectiveness of advertisements, protect against fraud and abuse, as well as personalize the content and advertisements displayed on individual websites, sites and applications.

In most cases, you pass them on yourself. This happens when:

• you register as an event participant,
• you subscribe to the newsletter,
• you add a comment / opinion,
• you contact us via e-mail,
• you follow social media profiles or interact with content posted on social media.

In addition, some information may be automatically collected by the tools we use:

• the website and newsletter system mechanisms collect your IP address,
• the newsletter system mechanism collects information about your activity in relation to the content sent to you as part of the newsletter, such as opening messages, clicking on links, etc.,
• external tools using cookies (the tools are described in detail in the further part of the privacy policy) collect Anonymous Information related to your activities on the website.

We care about the security of personal data. We have analyzed the risks associated with individual data processing processes, and then implemented appropriate security and personal data protection measures. We monitor the condition of the technical infrastructure on an ongoing basis, train the team, review the procedures applied and introduce necessary improvements. If you have any questions regarding personal data, please contact us at sekretariat@karpacki.pl

The individual purposes have also been assigned the appropriate legal basis for the processing:

• user account service - art. 6 sec. 1 lit. b GDPR,
• newsletter service - art. 6 sec. 1 lit. a and art. 6 sec. 1 lit. f GDPR,
• comment handling - art. 6 sec. 1 lit. f GDPR,
• correspondence handling - art. 6 sec. 1 lit. f GDPR,
• creating an archive for the possible need to defend, establish or pursue claims - art. 6 sec. 1 lit. f GDPR,
• creating groups of recipients on Facebook - art. 6 sec. 1 lit. f GDPR,
• social media service - art. 6 sec. 1 lit. f GDPR,
• analysis and statistics using only Anonymous Information - art. 6 sec. 1 lit. f GDPR,
• own marketing using only Anonymous Information - art. 6 sec. 1 lit. f GDPR,
• ensuring the functioning of the YouTube player and social plugins using only Anonymous Information - art. 6 sec. 1 lit. f GDPR.

User account - details
The user account is set up exclusively by the Association of the Carpathian Euroregion Poland. As part of editing account data, you can provide data such as the name of the institution, name and surname, address, tax identification number, telephone number, e-mail address. At any time, it is possible to modify the information about you provided in connection with the registration of the account.

The data provided in connection with the creation of an account are processed in order to provide the service by electronic means, consisting in ensuring the possibility of using the user account. This service is provided on the basis of an agreement concluded on the terms described in the regulations, which means that in this respect the legal basis for the processing of personal data is art. 6 sec. 1 lit. b GDPR.

Newsletter - details
By subscribing to the newsletter, you provide your name and e-mail address. Providing data is voluntary, but necessary to subscribe to the newsletter.

The data provided in connection with the subscription to the newsletter is used to send the newsletter, and the legal basis for their processing is the consent (Article 6 (1) (a) of the GDPR) expressed when subscribing to the newsletter.

The information collected automatically by the mailing system is processed based on the legitimate interest of the Association (Article 6 (1) (f) of the GDPR) consisting in the analysis of the behavior of newsletter subscribers in order to optimize mailing activities.

It is possible to unsubscribe from the newsletter at any time by clicking on the dedicated link in each message sent as part of the newsletter or by contacting the e-mail address: sekretariat@karpacki.pl.

Despite unsubscribing from the newsletter, the data will still be stored in the database in order to identify the returning subscriber and possible defense of claims related to sending the newsletter, in particular to demonstrate the consent to receive the newsletter and the moment of its withdrawal, which is a legitimate interest in question. in art. 6 sec. 1 lit. f GDPR.

At any time, it is possible to modify the data provided for the purpose of receiving the newsletter by contacting the following e-mail address: sekretariat@karpacki.pl .

Comments / opinions - details
When adding a comment, it is necessary to provide at least the username that will be assigned to the comment (the name may contain personal data, such as name or surname) and the e-mail address. Providing this data is voluntary, but necessary to add a comment.

The legal basis for the processing of your personal data in the case of the comment system is the legitimate interest referred to in art. 6 sec. 1 lit. f GDPR, which in this case consists in handling the comment system.

Correspondence handling - details
By contacting via e-mail, the personal data contained in the correspondence is naturally provided, in particular the e-mail address and name and surname. Providing data is voluntary, but necessary to make contact.

In this case, your data is processed in order to contact you, and the basis for processing is art. 6 sec. 1 lit. f GDPR, i.e. a legitimate interest. The legal basis for processing after the end of contact is also a legitimate interest in the form of archiving correspondence for the purpose of ensuring the possibility of proving certain facts in the future (Article 6 (1) (f) of the GDPR).

The content of the correspondence may be archived and we are not able to clearly determine when it will be deleted. You have the right to request a correspondence history, as well as request its removal, unless its archiving is justified due to overriding interests, e.g. defense against potential claims.

Archive - details
As part of the description of the individual purposes of personal data processing, the dates for the storage of personal data have been indicated. These terms are often related to the archiving of specific data for the purpose of ensuring the possibility of proving certain facts in the future, the aforementioned correspondence, defense, establishing or pursuing claims. In this regard, we rely on the legitimate interest referred to in art. 6 sec. 1 lit. f GDPR.

Social media - details
If you follow the profiles of the Carpathian Euroregion Poland Association on social networks or interact with the content we publish on social media, publicly available data from the social profile will be naturally made available. However, they are processed only within a given social networking site and only for the purpose of operating a given social networking site, which is a legitimate interest referred to in art. 6 sec. 1 lit. f GDPR.

The use of social networking sites is subject to the regulations and privacy policies of the administrators of these sites, and these administrators provide you, fully independently and independently, services by electronic means.

Analysis and statistics - details
We conduct analytical and statistical activities using the tools described in detail in the further part of the privacy policy. As part of the analytical tools, we only have access to Anonymous Information.

As mentioned before, Anonymous Information itself is not, in our opinion, personal data, as it does not allow your identification and is not compared with typical, collected personal data. Nevertheless, taking into account the rigorous jurisprudence of the Court of Justice of the European Union and divided opinions among lawyers, as a precautionary measure in the event that Anonymous Information is assigned the nature of personal data, this privacy policy also provides detailed explanations of the processing of such information.

We base the processing of Anonymous Information on the legitimate interest referred to in art. 6 sec. 1 lit. f GDPR. The legitimate interest lies in the creation, review and analysis of statistics related to user activity on the website in order to draw conclusions that allow for the subsequent optimization of the website.

We are unable to provide access to Anonymous Information about you, as we cannot assign any of the Anonymous Information to any specific user. From the level of external tools, we only have access to a set of statistics and information not assigned to specific people.

However, you can object to the processing of Anonymous Information about you by turning off external tool cookies in your browser settings.

Own marketing - details
We conduct marketing activities using external tools described in detail in the further part of the privacy policy. As part of the marketing tools, we only have access to Anonymous Information.

As mentioned before, Anonymous Information in itself is not, in my opinion, personal data, because it does not allow your identification and we do not compare it with typical, collected personal data. Nevertheless, taking into account the rigorous jurisprudence of the Court of Justice of the European Union and divided opinions among lawyers, as a precautionary measure in the event that Anonymous Information is assigned the nature of personal data, this privacy policy also provides detailed explanations of the processing of such information.

We base the processing of Anonymous Information on the legitimate interest referred to in art. 6 sec. 1 lit. f GDPR. The legitimate interest consists in creating Non-Standard Audience Groups based on Anonymous Information and targeting advertisements based on Anonymous Information, which are part of the marketing of own products and services.

We are unable to provide you with access to Anonymous Information about you, as we cannot assign any of the Anonymous Information to any particular user. From the level of external tools, we only have access to a set of statistics and information not assigned to specific people.

However, you can object to the processing of Anonymous Information about you by turning off external tool cookies in your browser settings.

Additional tools - details
We embed YouTube videos on the website, and we use social plugins. All these tools process Anonymous Information.

As mentioned before, Anonymous Information in itself is not, in my opinion, personal data, because it does not allow your identification and we do not compare it with typical, collected personal data. Nevertheless, taking into account the rigorous jurisprudence of the Court of Justice of the European Union and divided opinions among lawyers, as a precautionary measure in the event that Anonymous Information is assigned the nature of personal data, this privacy policy also provides detailed explanations of the processing of such information.

We base the processing of Anonymous Information on the legitimate interest referred to in art. 6 sec. 1 lit. f GDPR. The legitimate interest consists in creating Non-Standard Audience Groups based on Anonymous Information and targeting advertisements based on Anonymous Information, which are part of the marketing of own products and services.

We are unable to provide you with access to Anonymous Information about you, as we cannot assign any of the Anonymous Information to any particular user. From the level of external tools, we only have access to a set of statistics and information not assigned to specific people.

However, you can object to the processing of Anonymous Information about you by turning off external tool cookies in your browser settings.

The data storage periods have been indicated separately for each processing purpose. This information is included in the details devoted to each separate processing purpose.

External service providers that are involved in the processing of personal data are:

• the hosting provider that stores the data on the server,
• cloud computing service provider in which files that may contain your personal data are stored,
• provider of the mailing system in which your data is stored, if you are a subscriber to the newsletter,
• an entity providing maintenance services that gains access to data, if the technical works carried out relate to areas in which personal data are located,
• other subcontractors who gain access to data, if the scope of their activities requires such access.

All entities mentioned above process data on the basis of concluded personal data processing agreements and guarantee an adequate level of personal data protection.

If necessary, your data may be made available to a legal advisor or attorney bound by professional secrecy. The need may arise from the need to use legal assistance that requires access to your personal data.

In addition, if necessary, personal data may be made available to entities, bodies or institutions authorized to obtain access to data on the basis of legal provisions, such as the police, security services, courts, prosecutor's offices.

Moreover, when it comes to Anonymous Information, the providers of tools or plugins that collect Anonymous Information have access to it. The providers of these tools are independent administrators of the data collected in them and may share this data on the terms specified by them in their own regulations and privacy policies, over which I have no influence.

Yes, part of the processing of personal data may involve their transfer to third countries.

I transfer personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular in the USA. The providers of these tools guarantee an adequate level of protection of personal data through appropriate compliance mechanisms provided for by the GDPR, in particular through the use of standard contractual clauses.

We use external tools that may collect Anonymous Information. This has been mentioned several times under this policy, including in response to a previous question. The providers of these tools often use servers located all over the world, in particular in the United States of America (USA), to store the collected information.

By using certain tools, I can, for example, target personalized ads to you based on your previous activities on the website. I am talking about the so-called behavioral advertising.

As part of the tools we use, we only have access to Anonymous Information. This information is stored on the servers of the suppliers of individual tools, and these servers can most often be located all over the world.

The GDPR grants the following potential rights related to the processing of your personal data:

• the right to access your data and receive a copy of it,
• the right to rectify (correct) your data,
• the right to delete data (if in your opinion there are no grounds for your data to be processed, you can request their deletion),
• the right to limit data processing (you can request that the processing of data be limited only to their storage or performance of activities agreed with you, if, in your opinion, I have incorrect data or I process it unjustifiably),
• the right to object to the processing of data (you have the right to object to the processing of data on the basis of a legitimate interest; you should indicate a special situation that, in your opinion, justifies the cessation of the processing covered by the objection; I will stop processing your data for these purposes, unless I demonstrate that the grounds for processing data override your rights or that your data is necessary for me to establish, assert or defend claims),
• the right to transfer data (you have the right to receive, in a structured, commonly used, machine-readable format, personal data that you provided on the basis of a contract or your consent; you can have the data sent directly to another entity),
• the right to withdraw consent to the processing of personal data, if you have previously given such consent,
• the right to lodge a complaint to the supervisory body (if you find that I am processing your data unlawfully, you can lodge a complaint with the President of the Personal Data Protection Office or another competent supervisory authority).

The rules related to the implementation of the above-mentioned rights are described in detail in Art. 16 - 21 GDPR. I encourage you to read these regulations. The above-mentioned rights are not absolute and you will not be entitled to all activities related to the processing of your personal data.

If you believe that the processing of your personal data has resulted in a breach of the provisions on the protection of personal data, you have the option to lodge a complaint with the supervisory body (the President of the Office for Personal Data Protection).

You can also always request to provide you with information about what data we have about you and for what purposes we process it. All you need to do is send a message to sekretariat@karpacki.pl . However, we make every effort to ensure that the information you are interested in is comprehensively presented in this privacy policy. You can also use the e-mail address provided above if you have any questions related to the processing of your personal data.

The karpacki.pl website, like almost all other websites, uses cookies.

Cookies are small text information stored on your end device (e.g. computer, tablet, smartphone) that can be read by my ICT system (own cookies) or ICT systems of third parties (third party cookies). In cookies, specific information can be saved and stored, to which ICT systems can then access for specific purposes.

Some of the cookies used are deleted after the end of the web browser session, i.e. after closing it (so-called session cookies). Other cookies are stored on your end device and make it possible to recognize your browser the next time you visit the website (persistent cookies).

If you want to learn more about cookies as such, you can see, for example , this material .

I use cookies on the basis of your consent, except when cookies are necessary for the proper provision of electronic services to you.

Within the scope of your consent to cookies, we accept the variant according to which you express such consent through the settings of your web browser or additional software supporting the management of cookies. We assume that you agree to all cookies used by us that are not blocked by your browser or any additional software you use.

Remember that disabling or limiting the use of cookies may prevent you from using some of the functions available on the website and cause difficulties in using the website, as well as many other websites that use cookies. For example, if you block cookies from social plug-ins, buttons, widgets and social functions implemented on the website may not be available.

Yes, you can manage cookie settings within your web browser. You can block all or selected cookies. You can also block cookies from specific websites. You can also delete previously saved cookies and other website and plug-in data at any time.

Web browsers also offer the option of using incognito mode. You can use it if you do not want information about visited pages and downloaded files to be saved in your browsing and download history. Cookies created in incognito mode are deleted when all incognito windows are closed.

There are also browser plug-ins to control cookies, such as Ghostery. The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc.

In addition, there are tools available on the Internet that allow you to control certain types of cookies, in particular for collective management of behavioral advertising settings.

Remember that disabling or limiting the use of cookies may prevent you from using some of the functions available on the website and cause difficulties in using the website, as well as from many other websites that use cookies. For example, if you block cookies from social plug-ins, buttons, widgets and social functions implemented on my website may not be available.

Own cookies are used to ensure the proper functioning of individual website mechanisms, such as the correct submission of forms visible on the website, support for newsletter forms, etc.

The website uses the following third party cookies:

• Google Analytics,
• Google Ads,
• Facebook Custom Audiences,
• Facebook Connect and other social plugins,
• YouTube.

Details on individual third party cookies are described below.

Google Analytics - details
We use the Google Analytics tool provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. We carry out activities in this area based on the legitimate interest of creating statistics and analyzing them in order to optimize the website.

In order to use Google Analytics, a special Google Analytics tracking code has been implemented in the website code. The tracking code uses Google LLC cookies for the Google Analytics service. You can block the Google Analytics tracking code at any time by installing the browser add-on provided by Google.

Google Analytics automatically collects information about your use of the website. The information collected in this way is most often transferred to Google servers, which may be located all over the world and stored there.

Due to the activated IP anonymization, your IP address is shortened before forwarding. Only in exceptional cases is the full IP address sent to Google servers and shortened there. The anonymized IP address provided by your browser as part of Google Analytics is, as a rule, not combined with other Google data.

As part of Google Analytics, we only have access to Anonymous Information.

Google Analytics and Google Analytics 360 services have been certified by the independent security standard ISO 27001. ISO 27001 is one of the most recognized standards in the world and certifies compliance with the relevant requirements by systems that support Google Analytics and Google Analytics 360.

Google Ads - details
We can use remarketing functions available as part of the Google AdWords system operated by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. We carry out activities in this area based on the legitimate interest of marketing our own products or services.

When visiting the karpacki.pl website, a Google cookie remarketing file is automatically left on your device, which collects information about your activity on the website. Thanks to the information collected in this way, we are able to display advertisements to you within the Google network depending on your behavior on the website. For example, if you display a product, information about this fact will be recorded by the remarketing cookie file, which will allow us to send you an advertisement related to this issue or any other that we deem appropriate. This advertisement will be displayed within the Google network while using the Internet, browsing other websites, etc.

When using Google Ads, we only use Anonymous Information.

By using Google AdWords, we can only define advertising recipients. On this basis, Google decides when and how to present the advertisement.

Further processing of the information takes place only if you have given consent to Google to link your browsing history with your account and to use the information from your Google account to personalize the ads displayed on websites. In this case, Google will use your data to create and define lists of target groups for remarketing purposes on various devices. To this end, Google combines the temporarily collected information with other data it holds to form target groups.

If you don't want to receive personalized ads, you can manage your ad settings right on the Google side: adssettings.google.com .

Facebook Custom Audiences - details

As part of the Facebook Ads advertising system provided by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA, we may use Custom Audience Groups to target targeted advertising messages to specific groups of users. We carry out activities in this area based on the legitimate interest of marketing our own products or services.

In order to target personalized ads in terms of your behavior on the website, Facebook has been implemented as part of the Pixel website, which automatically collects information about the use of the website. The information collected in this way is most often transferred to Facebook servers, which may be located all over the world, in particular in the United States of America (USA).

The information collected as part of Facebook's Pixel is anonymous, i.e. it does not allow for identification. Depending on the activity on the website, you can reach a specific group of recipients, but we do not identify individual people belonging to these groups in any way.

Facebook Pixel can track and record, among others your following behaviors:

displaying the content of a specific page,
filling out a specific form, e.g. subscribing to the newsletter.
However, we would like to inform you that Facebook may combine the collected information with other information collected about you as part of your use of Facebook and use it for its own purposes, including marketing. Such Facebook activities are no longer dependent on us, and you can search for information about them directly in Facebook's privacy policy. You can also manage your privacy settings from your Facebook account.

Facebook Connect and other social plugins - details
My website uses plugins, buttons and other social tools, hereinafter collectively referred to as "plugins", provided by social networks such as Facebook, Instagram, LinkedIn, and Twitter.

When displaying a website containing a plug-in of a given social networking site, your browser sends information about the visit to the administrator of that social networking site. Since the plug-in is a part of the social networking site embedded in the page, the browser sends information about the request to download the content of the social networking site to the page.

The plugins collect information such as: user ID, visited website, date and time, and other information about the web browser.

Social network administrators use some of this information to personalize the viewing conditions of the website.

The information collected by plugins may also be used by administrators of social networking sites for their own purposes, such as e.g. improving their own products, creating user profiles, analyzing and optimizing their own activities, targeting ads. I have no real influence on how the information collected by the plugins is then used by the administrators of social networking sites. You can look for details in this regard in the regulations and privacy policies of individual social networking sites.

Social network plugins collect and transmit information to the administrators of these websites even when you browse the karpacki.pl website without being logged in to your account on the social network. However, then the browser sends a more limited set of information.

If you have logged in to one of the social networking sites, the website administrator will be able to directly assign a visit to the karpacki.pl website to your profile on a given social networking site.

If you do not want social networks to assign the data collected during visits directly to your profile on a given website, you must log out of this website before visiting the website. You can also completely prevent loading of plugins on the website by using appropriate extensions for your browser, e.g. blocking scripts.

In addition, the use of some plugins may involve the publication of certain information within your social profiles. For example, information about clicking the "Like" button may be available on your Facebook timeline. Of course, if you share some content on your social media using plugins embedded on my website, this sharing will naturally be visible in your profile.

As for the details related to the processing of information collected by plugins by social network administrators, in particular about the purpose and scope of data collection and their further processing and use by administrators, as well as the possibility of contact and your rights in this regard and the possibility of making settings to protect your privacy, you can find everything in the privacy policies of individual service providers:

• Facebook,
• Twitter,
• LinkedIn,
• Instagram.

YouTube - details
YouTube widgets are embedded on the karpacki.pl website, allowing you to play the recordings available on YouTube directly from the website. YouTube is operated by Google LLC.

Videos are embedded on the website in the privacy protection mode. Based on the information provided by YouTube, this means that no cookies are stored on your device, and Google does not collect any information about you until you play the recording.

When you play the recording, YouTube saves cookies on your device and receives information that you have played the recording from a specific website, even if you do not have a Google account or are not currently logged in. If you have logged in to your Google account, this service provider will be able to directly assign a visit to the karpacki.pl website to your account. The purpose and scope of data collection and their further processing and use by Google, as well as the possibility of contact and your rights in this regard and the possibility of making settings to protect your privacy are described in the Google privacy policy.

If you do not want Google to assign the data collected during video playback directly to your profile, you must log out of your account before playing the video. You can also completely prevent loading of plugins on the website by using appropriate extensions for your browser, e.g. blocking scripts.

The information collected as part of cookies related to YouTube videos embedded on websites is used by Google to ensure the proper and safe functioning of the widget, to analyze and optimize the services provided by YouTube, as well as for personalization and advertising purposes.

Remember that while playing the recordings available on YouTube, you are using the services provided electronically by Google LLC. Google LLC is an independent, independent entity providing electronic services to you.

Yes, we use Google Analytics, Google AdWords and Facebook Custom Audiences, which collect information about your activity on the karpacki.pl website. These tools are described in detail in the third party cookie question.

We can use Facebook Ads and Google Ads, in which we can target specific target groups defined on the basis of various criteria such as age, gender, interests, profession, job, activities previously undertaken on our website. These tools are described in detail in the third party cookie question.

The answer to this question can be found when describing individual tools, behavioral advertising, consent to cookies, etc. However, for your convenience, we have collected this information once again in one place. Below you will find a list of options for managing your privacy.

• cookie settings in the web browser,
• browser plugins supporting the management of cookies, e.g. Ghostery,
• additional cookie management software,
• incognito mode in a web browser,
• behavioral advertising settings, e.g. youronlinechoices.com,
• Google Analytics Opt-out: tools.google.com/dlpage/gaoptout ,
• Google Ads Settings: adssettings.google.com/ ,
• Facebook Ads Settings: facebook.com/ads/settings .

Using the website involves sending queries to the server on which the website is stored. Each query directed to the server is saved in the server logs. Logs include IP address, server date and time, information about the web browser and operating system you use. Logs are saved and stored on the server.

The data stored in the server logs are not associated with specific people using the website and are not used for identification purposes. The server logs are only auxiliary material used to administer the website, and their content is not disclosed to anyone except those authorized to administer the server.

Yes, we can modify this privacy policy, in particular due to technological changes and changes in the law.