Privacy Policy

The following Privacy Policy defines the rules for storing and accessing data on Users' Devices using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users' personal data, which have been provided by them personally and voluntarily through the tools available in the Service.

§1 Definitions  Service – the „alpinoac.pl” website operating at https://alpinoac.pl/  External Service – websites of partners, service providers or 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 „Motovision Sp. z o.o.”, operating at: Grabskiego 8 75-209 Koszalin, with Tax Identification Number (NIP): 6692491826, with KRS number: 0000947540, providing electronic services 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 accesses 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, organisation, 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 analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements  Consent – consent of the data subject 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, unauthorised 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person  Anonymisation – Anonymisation of data is an irreversible process of data operations that destroys / overwrites „personal data” making it impossible to identify or link a given record to a specific user or natural person.

§2 Data Protection Officer The Administrator has appointed a Data Protection Officer, Marta Kościelna. The Officer can be contacted via e-mail: [email protected], by phone at +48 94 3 420 430 or in writing to: Grabskiego 8, 75-209 Koszalin.

The Data Protection Officer can be contacted in all matters concerning the processing of personal data. §3 Types of Cookies  Internal Cookies – files placed and read from the User's Device by the Service's ICT system  External Cookies – files placed and read from the User's Device by the ICT systems of External Services. Scripts of External Services, which may place Cookies 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 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 Service until they are manually deleted. Files are not automatically deleted after the end of the Device session unless the User's Device configuration is set to delete Cookie files after the Device session ends. §4 Data Storage Security  Cookie storage and reading mechanisms – The mechanisms for storing, reading, and exchanging data between Cookies saved on the User's Device and the Service 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. Transferring viruses, Trojan horses, and other worms to the User's Device is also practically impossible.  Internal Cookies – The 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 the context of User security. The Administrator chooses well-known, large partners with global social trust for cooperation. However, the Administrator does not have full control over the content of Cookie files originating from external partners. The Administrator is not responsible for the security of Cookie files, their content, and their license-compliant use by the Scripts installed in the service, originating from External Services, to the extent permitted by law. A list of partners is provided later in 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 by any website.  Information on how to disable Cookie files 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 browser  Managing cookies in Opera browser  Managing cookies in FireFox browser  Managing cookies in Edge browser  Managing cookies in Safari browser  Managing cookies in Internet Explorer 11 browser  The User can, at any time, delete all saved Cookie files using the tools of the User's Device, through which the User uses the Service's services.

 User-side threats – 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 activity. The Administrator is not responsible for the interception of this data, impersonation of the User's session, or its deletion, as a result of conscious or unconscious User activity, viruses, Trojan horses, and other spyware that may have infected or is infecting the User's Device. Users, in order to protect themselves from these threats, should adhere to the principles of safe internet use.  Storage of personal data – The Administrator ensures that all efforts are made to ensure that personal data voluntarily entered by Users is secure, access to it is restricted, and processed in accordance with its purpose and processing goals. The Administrator also ensures that all efforts are made to protect the data held from loss, by applying appropriate physical and organizational safeguards.

 Password storage – The Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. Decryption of account access passwords provided in the Service is practically impossible. §5 Purposes for which Cookie files are used  Improving and facilitating access to the Service  Personalizing the Service for Users  Enabling Login to the service  Marketing, Remarketing in external services  Conducting statistics (users, number of visits, types of devices, connection, etc.)  Serving multimedia services  Providing social services §6 Purposes of personal data processing Personal data voluntarily provided by Users are processed for one of the following purposes:  Provision 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 media or other websites.

 Communication between the Administrator and Users regarding the Service and data protection  Ensuring the Administrator's legitimate interest User data collected anonymously and automatically is processed for one of the following purposes:  Conducting statistics  Remarketing  Ensuring the Administrator's legitimate interest §7 External Service Cookies

The Administrator uses javascript scripts and web components of partners in the Service, who may place their own cookie files on the User's Device. Remember 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:  YouTube  Social / connected services: (Registration, Login, content sharing, communication, etc.)

 Facebook  Google+  Newsletter services:  GetResponse  Statistics:  Google Analytics  Other services:  Google Maps

Services provided by third parties are beyond the Administrator's control. These entities may change their terms of service, privacy policies, data processing purpose, and cookie usage methods at any time. §8 Types of data collected The Service 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 Service. Anonymous data collected automatically:  IP address  Browser type  Screen resolution  Approximate location

 Subpages opened on the service  Time spent on the respective subpage of the service  Operating system type  Previous subpage address  Referring page address  Browser language  Internet connection speed  Internet service provider  Demographic data (age, gender) Data collected during registration:  First name / last name / pseudonym  Login  E-mail address  Residential address  IP address (collected automatically) Data collected when subscribing to the Newsletter service  First name / last name / pseudonym  E-mail address  IP address (collected automatically) Data collected when adding a comment  First and last name / pseudonym  E-mail address  Website address  IP address (collected automatically) Some data (without identifying data) may be stored in cookie files. Some data (without identifying data) may be transferred to a statistical service provider. §9 Access to personal data by third parties

As a rule, the sole recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided is not transferred or sold 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 for operating the service, i.e.: Entrustment of personal data processing – Newsletter To provide the Newsletter service, the Administrator uses the services of a third party – the GetResponse service. Data entered in the newsletter subscription form is transferred, stored, and processed in the external service of this provider. Please be informed that the indicated partner may modify the stated privacy policy without the Administrator's consent. §10 Method of personal data processing Personal data voluntarily provided by Users:  Personal data will not be transferred outside the European Union, unless it has been published as a result of an individual User action (e.g., entering a comment or post), which will make the data available to anyone visiting the service.  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 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)

 Art. 6(1)(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes  Art. 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  Art. 6(1)(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 personal data protection (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 of personal data processing Personal data voluntarily provided by Users: As a rule, the indicated personal data is stored only for the period of providing the Service within the Service 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 list, etc.) An exception is a situation that requires securing the legitimate purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User's request for their deletion, for no longer than 3 years in the event of a violation or suspected violation of the service regulations 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 conducting service statistics indefinitely. §13 User rights related to personal data processing The Service collects and processes User data based on:  Right of access to personal data

Users have the right to obtain access to their personal data, exercised upon a 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 that is inaccurate or / and completion of incomplete personal data, exercised upon a 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 a request submitted to the Administrator. In the case of user accounts, data erasure involves anonymizing data that allows for User identification. The Administrator reserves the right to suspend the fulfillment of a data erasure request to protect the Administrator's legitimate interest (e.g., when the User has violated the Regulations or data was obtained as a result of ongoing correspondence). In the case of the Newsletter service, the User can independently delete their personal data using the link included in each e-mail message sent.  Right to restriction of personal data processing Users have the right to restrict the processing of personal data in cases specified in Art. 18 GDPR, including contesting the accuracy of personal data, exercised upon a request submitted to the Administrator  Right to data portability Users have the right to receive from the Administrator, personal data concerning the User in a structured, commonly used, machine-readable format, exercised upon a request submitted to the Administrator  Right to object to personal data processing Users have the right to object to the processing of their personal data in cases specified in Art. 21 GDPR, exercised upon a request submitted to the Administrator  Right to lodge a complaint Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection. §14 Contact to the Administrator The Administrator can be contacted in one of the following ways

 Postal address – Motovision Sp. z o.o., Grabskiego 8 75-209 Koszalin  E-mail address – [email protected]  Phone call – +48 94 3 420 430  Contact form – available at: alpinoac.eu/kontakt §15 Service Requirements  Restricting the saving and access to Cookie files on the User's Device may cause some Service functions to operate incorrectly.  The Administrator bears no responsibility for incorrectly functioning Service features if the User in any way restricts the ability to save and read Cookie files. §16 External Links In the Service – in articles, posts, entries, or User comments, there may be links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated under them may be dangerous for Your Device or pose a threat to the security of 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 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 Users with user accounts or subscribed to the newsletter service will be informed via email within 7 days of the changes. 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.  Introduced changes to the Privacy Policy will be published on this subpage of the Service.  Introduced changes come into effect upon their publication.