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Privacy policy

WRPA Limited Liability Company (hereinafter referred to as the Administrator) shall ensure that the data entrusted to it are processed in compliance with the requirements of generally applicable law, in particular Regulation (EU) 2016/679 of the European Parliament and of the European Council of April 27, 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 (Journal of Laws of the EU.L.2016.119.1) – hereinafter referred to as GDPR.
This Privacy Policy sets out the rules for the processing and protection of Users’ personal data. The Administrator assures that its overriding goal is to ensure that persons using the Auction Portal (hereinafter: the Portal) have their privacy protected at a level that is at least equivalent to the requirements imposed by applicable laws, and in particular by the provisions of the GDPR and by the Act of July 18, 2002 on the provision of electronic services (consolidated text, Journal of Laws of 2020, item 344).
The Administrator shall ensure that the data are processed only to the extent necessary for the indicated purpose and only for the period for which it is necessary.
Any person using the Portal in any way accepts all the rules contained in this Privacy Policy.

1. Definitions
Administrator – WRPA Limited Liability Company, Al. Racławickie 33/26a,, 20-049 Lublin; e-mail address: info@golebie.in.lublin.pl
User – any natural person visiting the Portal or using one or more services or functionalities described in the Policy.
Personal Data – all information about a natural person identified or identifiable by one or more specific factors determining physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, Internet identifier and information collected through cookies and other similar technology.
Policy – this Privacy Policy.
Terms and Conditions – the rules and regulations of the Portal.
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.
Auction Portal (hereinafter: Portal) – a sales platform operated by the Administrator at golebie.in.lublin.pl.
Profile – a place on the Portal available to the User, where the User enters his/her data, manages it and publishes it in accordance with the privacy settings chosen by the User.
Anonymization – irreversible processing of personal data in such a way that it cannot be attributed to a specific person….

2. Data processing in connection with the use of the site
1. The Administrator shall collect the data of the User using the Portal to the extent necessary to provide the services offered, as well as information about the User’s activity on the Portal.
2. The Administrator processes the personal data of all persons using the Portal, including those who do not have their own profile on the Portal. Personal data processed in this regard includes, among others, IP address or other identifiers and information collected through cookies or other similar technologies. The User’s activity on the Portal, including his/her personal data, is recorded in system logs.

3. Registration on the Portal
To register on the Auction Portal, the User must provide the data necessary to create and operate a Profile. In order to facilitate operation, the User may provide additional data, thereby consenting to their processing. Such data can be deleted at any time. Provision of data marked as mandatory is required to create and operate the Profile, and failure to provide such data will result in the inability to create the Profile. Provision of other data is voluntary.

4. Purposes and legal basis of data processing on the Portal
1. Personal data shall be processed:
a) for the purpose of providing services related to the operation and maintenance of Profiles on the Auction Portal covering the provision of content collected on the platform, as well as the provision of contact forms – the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) of the GDPR), and in the scope of data provided optionally – the legal basis for processing is consent (Article 6(1)(a) of the GDPR);
b) for analytical and statistical purposes – the legal basis for processing is the legitimate
Administrator’s interest (Article 6(1)(f) GDPR) consisting of conducting analysis of the activity of Portal Users and the way they use the Profile, as well as their preferences in order to improve the applied functionalities;
c) for the purpose of handling complaints – the legal basis for processing is the necessity of processing for the performance of the agreement (Article 6(1)(b) GDPR);
d) for the purpose of possibly establishing and asserting claims or defending against them – the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the DPA) in protecting your rights;
e) for the Administrator’s marketing purposes, consisting of informing the User about the current offer and new functionalities of the Portal.

2. Marketing activities may consist of:
a) display of marketing content (advertising). The Administrator processes personal data for marketing purposes in connection with directing advertising to the User that is not tailored to the User’s preferences. The processing of personal data for this purpose is carried out in connection with the Administrator’s legitimate interest. The Administrator processes personal data, including personal data collected through cookies and other similar technologies for marketing purposes in connection with directing to the User advertising that is tailored to the User’s preferences. Such processing also includes its profiling. It consists in automatic processing of Users’ data in order to evaluate selected factors concerning individuals, analyze their behavior or create a forecast for the future. The use of personal data collected in this way for marketing purposes is carried out on the basis of the Administrator’s legitimate interest and only on the condition that the User has consented to the use of cookies. Consent to the use of cookies can be given by appropriate configuration of the browser, and can be withdrawn at any time, in particular by clearing the history of cookies and disabling cookies in the browser settings;

b) directing e-mail notifications of offers or content, which in some cases contain commercial information (Newsletter service). The Administrator provides the Newsletter service to persons who have provided their e-mail address. Provision of data is required in order to provide the Newsletter service, and failure to do so results in the inability to send the Newsletter. Personal data in this case are processed:
 – for the purpose of providing Newsletter dispatch services – the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) GDPR), in the case of directing marketing content to the User within the Newsletter – the legal basis for processing, including profiling, is the legitimate interest of the Administrator (Article 6(1)(f) GDPR) in connection with the consent to receive the Newsletter;
 – for analytical and statistical purposes – the legal basis of processing is the legitimate interest of the Administrator (Article 6(1)(f) GDPR) consisting in guiding the analysis of the User’s activity on the Portal in order to improve the applied functionalities;
– for the purpose of possible establishment, investigation or defense against claims – the legal basis for processing is the legitimate interest of the Administrator;
 – sending commercial information by electronic means. The Administrator may direct marketing information to the User through various channels, i.e. e-mail, SMS. The User’s personal data will be processed for the purpose of sending such information, and the basis of data processing is the legitimate interest of the Administrator to send marketing information within the limits of the consent granted by the User (direct marketing). The User has the right to object to the processing of data for direct marketing purposes, including profiling. The data will be kept for this purpose for the duration of the Administrator’s legitimate interest, unless the User objects to receiving marketing information.

5. Internet auctions
1. User’s participation in an online auction on the Portal involves the processing of his/her personal data. Provision of data marked as mandatory is required in order to process the auction, and failure to provide such data will result in the auction not being completed. Provision of other data is voluntary.
2. Personal data shall be processed:
a) for the purpose of handling the online auction—the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) GDPR); with regard to the data provided optionally, the legal basis for processing is consent (Article 6(1)(a) GDPR);
b) for the purpose of fulfilling statutory obligations incumbent on the Administrator, arising in particular from tax and accounting regulations—the legal basis for processing is a legal obligation (Article 6(1)(c) GDPR);
c) for analytical and statistical purposes – the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) GDPR) consisting of conducting analyses of Users’ activity on the Portal, as well as their shopping preferences in order to improve the functionalities used;
d) for the purpose of possible establishment and investigation of claims or defense against them—the legal basis of the processing is the legitimate interest of the Administrator (Article 6(1)(f) of the DPA) to protect your rights.

6. Contact forms
1. The Administrator shall provide the possibility to contact it using electronic contact forms. Using the form requires providing personal data necessary to contact the User and respond to the inquiry. The User may also provide other data to facilitate contact or handling of the inquiry. Provision of data marked as mandatory is required in order to accept and service the inquiry, and failure to provide such data will result in the impossibility of service. Provision of other data is voluntary.

2. Personal data shall be processed:
a) for the purpose of identifying the sender and handling his/her inquiry sent via the form provided – the legal basis for processing is the necessity of processing for the performance of the service contract (Article 6(1)(b) GDPR);
b) for analytical and statistical purposes – the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) GDPR) consisting of guiding the statistics of queries submitted by Users via the Portal in order to improve its functionality.

7. Social networks
The Administrator processes personal data of Users visiting the Administrator’s profiles maintained on social media (Facebook, YouTube, Instagram, Twitter, Google +,Pinterest). The data is processed exclusively in connection with the running of the profile, including for the purpose of informing Users about the Administrator’s activities and promoting various events, services and products, as well as for the purpose of communicating with users through the functionalities available on social media. The legal basis for the Administrator’s processing of personal data for this purpose is its legitimate interest (Article 6(1)(f) GDPR) in promoting its own brand and building and maintaining a brand-related community.

8. Cookies and similar technology
1. The Portal uses cookies.
2. Cookies (so-called “cookies”) are computer data, in particular text files, which are stored on the Portal User’s terminal equipment and are intended for use on the Portal website. Cookies usually contain the name of the website they come from, the time they are stored on the end device and a unique number.
3. The entity placing cookies on the Portal User’s end device and accessing them is the Administrator.
4. Cookies are used for the following purposes:
a) creating statistics that help to understand how Portal Users use the website, which allows to improve its structure and content;
b) maintaining a session of the Portal User (after logging in), thanks to which the User does not have to re-enter his/her login and password on each sub-page of the Portal;
c) to retain information about service referrals for the referral program;
d) to determine the User’s profile in order to display customized materials to the User on advertising networks, in particular the Google network.
5. The Portal uses two main types of cookies: “session” (session cookies) and “permanent” (persistent cookies). “Session” cookies are temporary files that are stored on the User’s final device until the User logs out, leaves the website or shuts down the software (web browser). “Permanent” cookies are stored on the User’s end device for the time specified in the parameters of the cookies or until they are deleted by the User.
6. Web browsing software (web browser) usually allows the storage of cookies on the User’s final device by default. Users of the Website may change their settings in this regard. The web browser makes it possible to delete cookies. It is also possible to automatically block cookies Detailed information on this subject is contained in the help or documentation of the Internet browser.
7. Restrictions on the use of cookies may affect certain functionalities available on the Website of the Portal.
8. Cookies placed on the Portal User’s end device may also be used by entities cooperating with the Portal operator, in particular, this applies to companies: Google (Google Inc. based in the USA), Facebook (Facebook Inc. based in the USA), Twitter (Twitter Inc. based in the USA).

9. The Operator uses Google Analytics and Universal Analytics provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) to analyze traffic on the Portal. (10) The Operator uses remarketing, i.e. activities by which advertising networks can display advertising messages to the User that are tailored to the User’s behavior on the Auction Portal. A technological prerequisite for such activities is the handling of cookies.
10. With regard to information about User preferences collected by the Google advertising network, the User may view and edit information resulting from cookies using the tool: https://www.google.com/ads/preferences/.

9. User rights
1. Users shall have the following rights:
a) the right to access the content of the data and to request its rectification,
b) the right to delete data,
c) the right to restrict their processing,
d) the right to data portability,
e) the right to object to the processing of data,
f) the right to withdraw consent – if the data are processed on the basis of consent, the data subject has the right to withdraw it at any time, which, however, does not affect the lawfulness of processing carried out before the withdrawal of such consent,
(g) right to complain – if the processing of personal data is deemed to violate the provisions of the GDPR or other data protection laws, the data subject may file a complaint with the President of the Office for Personal Data Protection.

(2) A request for the exercise of the rights of data subjects, can be submitted:
(a) in writing to the address: WRPA Limited Liability Company, Al. Racławickie 33/26a, 20-049 Lublin,
b) by e-mail to: info@golebie.in.lublin.pl

10. Period of personal data processing
1) The Administrator will store personal data for as long as the User has a Profile on the Auction Portal or until he/she withdraws consent to the processing of personal data that he/she has placed on his/her Profile after registration. This is necessary both for the proper provision of the services specified in the Terms and Conditions and for marketing purposes.
2) After deletion of the Profile or withdrawal of consent for data processing by the User, the Administrator will cease processing the data. In such a case, the data will be irreversibly deleted, or it will be anonymized, with the proviso, however, that part of the data (name, surname, e-mail address, Profile history and information about granted consents) will be processed by the Administrator for the period necessary to establish, investigate or defend against possible claims.

11. Recipients of data
1) In connection with the implementation of the services, personal data will be disclosed to external entities, including in particular suppliers responsible for the operation of IT systems, entities providing accounting services, legal services, couriers (in connection with the handling of auctions), marketing agencies (for marketing services)
2) The Administrator reserves the right to disclose selected information concerning the User to the competent authorities or third parties who make a request for such information, based on the relevant legal basis and in accordance with the provisions of the applicable law.
12. Security of personal data
1) The Administrator shall conduct a risk analysis on an ongoing basis to ensure that personal data is processed by the Administrator in a secure manner. Data shall be accessed only by authorized persons and only to the extent necessary due to the tasks they perform. The Administrator shall ensure that all operations on personal data are recorded and performed only by authorized employees and associates.
2) The Administrator shall take all necessary measures to ensure that also its subcontractors and other cooperating entities provide a guarantee of the application of appropriate security measures whenever they process personal data on behalf of the Administrator.
13. Change of privacy policy
The Policy is reviewed on an ongoing basis and updated as necessary. The Administrator will inform Users of any changes via the Portal or email.