The following privacy policy applies to the use of our online offering at www.safort-consulting.com (hereinafter referred to as "Website"). We place great importance on data protection. The collection and processing of your personal data are carried out in compliance with the applicable data protection regulations, particularly the General Data Protection Regulation (GDPR).

1. Data Controller

The data controller responsible for the collection, processing, and use of your personal data within the meaning of Art. 4 No. 7 GDPR is

Safort Spółka z Ograniczoną Odpowiedzialnością

Managing Directors: Olga Hadwiger, Ulf P. Hadwiger

ul. Księcia Józefa Poniatowskiego 2 /6
50-326 Wrocław
Poland

Phone: +48 784 500 560
Mobile: +48 784 500 643
Email: info@safort-consuting.com

If you wish to object to the collection, processing, or use of your data by us in accordance with these data protection regulations as a whole or for individual measures, you may address your objection to the data controller.

You can save and print this privacy policy at any time.

2. General Purposes of Processing

We use personal data for the purpose of operating the Website and our online store www.safort-consulting.com.

3. Data We Use and Why

3.1 Hosting

The hosting services we use serve to provide the following services: infrastructure and platform services, computing capacity, storage space, and database services, security services, and technical maintenance services, which we use for the purpose of operating the Website.

In this context, we or our hosting provider process inventory data, contact data, content data, contract data, usage data, meta and communication data from customers, interested parties, and visitors to this Website based on our legitimate interests in an efficient and secure provision of our Website in accordance with Art. 6 para. 1 sentence 1 f) GDPR in conjunction with Art. 28 GDPR.

3.2 Access Data

We collect information about you when you use this Website. We automatically collect information about your usage behavior and your interaction with us and register data about your computer or mobile device. We collect, store, and use data about every access to our Website (so-called server log files). Access data includes:

• Name and URL of the retrieved file

• Date and time of retrieval

• Transferred data volume

• Notification of successful retrieval (HTTP response code)

• Browser type and browser version

• Operating system

• Referrer URL (i.e., the previously visited page)

• Websites accessed by the user’s system via our Website

• Internet service provider of the user

• IP address and the requesting provider

We use this log data without assignment to your person or other profiling for statistical evaluations for the purpose of operating, securing, and optimizing our Website, as well as for anonymous recording of the number of visitors to our Website (traffic), and for the scope and type of use of our Website and services, as well as for billing purposes to measure the number of clicks received from cooperation partners. Based on this information, we can provide personalized and location-based content, analyze traffic, troubleshoot, and improve our services.

This is also our legitimate interest according to Art. 6 para. 1 sentence 1 f) GDPR.

We reserve the right to subsequently check the log data if there is a justified suspicion of illegal use based on concrete indications. IP addresses are stored in log files for a limited period if this is necessary for security purposes or for the provision of services or billing of a service, e.g., if you use one of our offers. After the order process has been canceled or after payment has been received, we delete the IP address if it is no longer necessary for security purposes. We also store IP addresses if we have a specific suspicion of a crime related to the use of our Website. Additionally, we store the date of your last visit as part of your account (e.g., during registration, login, clicking on links, etc.).

3.3 Cookies

We use so-called session cookies to optimize our Website. A session cookie is a small text file that is sent by the respective servers when visiting a website and is temporarily stored on your hard drive. This file as such contains a so-called session ID, with which various requests of your browser can be assigned to the joint session. This allows your computer to be recognized when you return to our Website. These cookies are deleted after you close your browser. For example, they are used to allow you to use the shopping cart function across several pages.

We also use a small extent of persistent cookies (also small text files that are stored on your device) that remain on your device and allow us to recognize your browser on your next visit. These cookies are stored on your hard drive and delete themselves after the specified time. Their lifespan ranges from 1 month to 10 years. This way, we can present our offer to you in a more user-friendly, effective, and secure manner and, for example, display information tailored to your interests on the site.

Our legitimate interest in the use of cookies according to Art. 6 para. 1 sentence 1 f) GDPR is to make our Website more user-friendly, effective, and secure.

The following data and information are stored in the cookies:

• Log-in information

• Language settings

• Entered search terms

• Information on the number of visits to our Website and the use of individual functions of our online presence

When activating the cookie, it is assigned an identification number and a reference to your personal data is not made. Your name, IP address, or similar data that would allow the cookie to be assigned to you are not placed in the cookie. On the basis of cookie technology, we only receive pseudonymized information, for example, about which pages of our shop were visited, which products were viewed, etc.

You can configure your browser in such a way that you are informed in advance about the setting of cookies and can decide on a case-by-case basis whether to exclude the acceptance of cookies in certain cases or in general, or that cookies are completely prevented. This may limit the functionality of the Website.

3.4 Data to Fulfill Our Contractual Obligations

We process personal data that we need to fulfill our contractual obligations, such as name, address, email address, ordered products, billing, and payment data. The collection of this data is necessary for the conclusion of the contract. The data will be deleted after the expiration of warranty periods and statutory retention periods. Data that is linked to a user account (see below) will remain in any case for the duration of the management of this account.

The legal basis for the processing of this data is Art. 6 para. 1 sentence 1 b) GDPR, as this data is required so that we can fulfill our contractual obligations to you.

3.5 User Account

You can create a user account on our Website. If you wish to do so, we need the personal data requested during login. When logging in later, only your email or username and the password you have chosen are required. For new registration, we collect master data (e.g., name, address), communication data (e.g., email address), and payment data (bank details) as well as access data (username and password). To ensure your proper registration and prevent unauthorized registrations by third parties, you will receive an activation link via email after registration to activate your account. Only after successful registration, we store the data transmitted by you permanently in our system.

You can have a user account that has been created deleted by us at any time, without any costs other than the transmission costs according to the base rates. A message in text form to the contact data mentioned under item 1 (e.g., email, fax, letter) is sufficient for this. We will then delete your stored personal data unless we still need to store them for processing orders or due to statutory retention obligations.

The legal basis for processing this data is your consent in accordance with Art. 6 para. 1 sentence 1 a) GDPR.

3.6 Newsletter

To sign up for the newsletter, the data requested in the registration process is required. The registration for the newsletter will be logged. After registering, you will receive a message to the specified email address in which you will be asked to confirm the registration ("Double Opt-in"). This is necessary so that third parties cannot register with your email address.

You can revoke your consent to receive the newsletter at any time and thus unsubscribe from the newsletter.

We store the registration data as long as they are required for sending the newsletter. The logging of the registration and the email address are stored as long as there is an interest in proving the original consent, usually for the limitation periods for civil claims, which is a maximum of three years. The legal basis for sending the newsletter is your consent in accordance with Art. 6 para. 1 sentence 1 a) in conjunction with Art. 7 GDPR in conjunction with § 7 para. 2 no. 3 UWG. The legal basis for logging the registration is our legitimate interest in proving that the dispatch was made with your consent.

You can cancel the registration at any time without incurring any costs other than the transmission costs according to the base rates. A message in text form to the contact data mentioned under item 1 (e.g., email, fax, letter) is sufficient for this. You will also find a cancellation link in each newsletter.

3.7 Product Recommendations

We will send you product recommendations by email regularly, regardless of the newsletter. In this way, we provide you with information about products from our offering that you may be interested in based on your recent purchases of goods or services from us. In doing so, we strictly adhere to the statutory requirements. You can object to this at any time without incurring any costs other than the transmission costs according to the base rates. A message in text form to the contact data mentioned under item 1 (e.g., email, fax, letter) is sufficient for this. You will also find an unsubscribe link in each email.

The legal basis for this is the statutory permission according to Art. 6 para. 1 sentence 1 f) GDPR in conjunction with § 7 para. 3 UWG.

3.8 Email Contact

When you contact us (e.g., via contact form or email), we process your details to handle the inquiry and in case follow-up questions arise. If the data processing is carried out for the execution of pre-contractual measures, which take place on your inquiry, or if you are already our customer, for the execution of the contract, the legal basis for this data processing is Art. 6 para. 1 sentence 1 b) GDPR.

Further personal data will only be processed if you consent to it (Art. 6 para. 1 sentence 1 a) GDPR) or we have a legitimate interest in processing your data (Art. 6 para. 1 sentence 1 f) GDPR). A legitimate interest lies, for example, in responding to your email.

4. Google Analytics

We use Google Analytics, a web analysis service of Google Inc. ("Google"). Google Analytics uses so-called "cookies," text files that are stored on your computer and that allow an analysis of your use of the Website. The information generated by the cookie about the use of this Website by the site visitors is generally transmitted to a Google server in the USA and stored there.

This is also our legitimate interest in accordance with Art. 6 para. 1 sentence 1 f) GDPR.

Google has submitted to the Privacy Shield agreement between the European Union and the USA and is certified. As a result, Google is committed to complying with the standards and regulations of European data protection law. Further information can be found in the entry linked below: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active.

We have activated IP anonymization on this Website (anonymizeIp). This means that your IP address will be truncated by Google within member states of the European Union or in other contracting states to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Website, compile reports on Website activities, and provide us with other services related to Website usage and internet usage.

The IP address transmitted by your browser as part of Google Analytics will not be merged with other data from Google. You can prevent the storage of cookies by setting your browser software accordingly; however, we would like to point out that in this case, you may not be able to use all the functions of this Website to their full extent.

You can also prevent the collection of data generated by the cookie and related to your use of the Website (including your IP address) from being sent to Google and the processing of this data by Google by downloading and installing the browser plugin available at the following link: http://tools.google.com/dlpage/gaoptout?hl=en.

As an alternative to the browser plugin or within browsers on mobile devices, you can click on the following link to set an opt-out cookie that will prevent future data collection by Google Analytics within this Website (this opt-out cookie only works in this browser and only for this domain. If you delete your cookies in this browser, you will need to click this link again): [Disable Google Analytics].

5. Storage Duration

Unless specifically stated, we store personal data only as long as it is necessary to fulfill the pursued purposes.

In some cases, the legislator provides for the retention of personal data, such as in tax or commercial law. In these cases, the data is stored by us solely for these legal purposes, but it is not processed otherwise and is deleted after the legal retention period has expired.

6. Your Rights as a Data Subject

Under the applicable laws, you have various rights regarding your personal data. If you wish to exercise these rights, please address your request by email or post, clearly identifying yourself, to the address mentioned in item 1.

Below is an overview of your rights:

6.1 Right to Confirmation and Information

You have the right to receive clear information about the processing of your personal data.

Specifically: You have the right to obtain confirmation from us at any time as to whether personal data concerning you is being processed. If this is the case, you have the right to obtain free information from us about the personal data stored about you together with a copy of this data. Additionally, there is a right to the following information:

1. the processing purposes;

2. the categories of personal data that are processed;

3. the recipients or categories of recipients to whom the personal data has been or will be disclosed, especially recipients in third countries or international organizations;

4. if possible, the planned duration for which the personal data will be stored, or, if this is not possible, the criteria for determining this duration;

5. the existence of a right to rectification or deletion of your personal data or to restrict processing by the controller or a right to object to such processing;

6. the existence of a right to lodge a complaint with a supervisory authority;

7. if the personal data is not collected from you, any available information about the source of the data;

8. the existence of automated decision-making, including profiling, in accordance with Art. 22 para. 1 and 4 GDPR, and – at least in these cases – meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for you.

If personal data is transferred to a third country or an international organization, you have the right to be informed about the appropriate safeguards in accordance with Art. 46 GDPR in connection with the transfer.

6.2 Right to Rectification

You have the right to request the rectification and, if necessary, the completion of personal data concerning you.

Specifically: You have the right to demand that we correct any incorrect personal data concerning you without delay. Considering the purposes of the processing, you have the right to request the completion of incomplete personal data, including by means of a supplementary statement.

6.3 Right to Erasure ("Right to be Forgotten")

In a number of cases, we are required to delete personal data concerning you.

Specifically: In accordance with Art. 17 para. 1 GDPR, you have the right to request that we delete personal data concerning you without undue delay, and we are obliged to delete personal data without undue delay where one of the following grounds applies:

1. The personal data is no longer necessary for the purposes for which it was collected or otherwise processed.

2. You withdraw your consent on which the processing is based according to Art. 6 para. 1 sentence 1 a) GDPR or Art. 9 para. 2 a) GDPR, and there is no other legal basis for the processing.

3. You object to the processing in accordance with Art. 21 para. 1 GDPR, and there are no overriding legitimate grounds for the processing, or you object to the processing in accordance with Art. 21 para. 2 GDPR.

4. The personal data has been unlawfully processed.

5. The deletion of the personal data is necessary to comply with a legal obligation under Union or Member State law to which we are subject.

6. The personal data has been collected in relation to the offer of information society services in accordance with Art. 8 para. 1 GDPR.

If we have made the personal data public and are obliged to delete it in accordance with Art. 17 para. 1 GDPR, we shall take reasonable steps, including technical measures, considering the available technology and the cost of implementation, to inform controllers who are processing the personal data that you have requested the erasure of any links to, or copies or replications of, such personal data.

6.4 Right to Restriction of Processing

In a number of cases, you are entitled to request that we restrict the processing of your personal data.

Specifically: You have the right to request that we restrict processing if one of the following conditions is met:

1. the accuracy of the personal data is contested by you, for a period enabling us to verify the accuracy of the personal data;

2. the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of its use instead;

3. we no longer need the personal data for the purposes of processing, but you require the data for the establishment, exercise, or defense of legal claims; or

4. you have objected to processing in accordance with Art. 21 para. 1 GDPR pending the verification whether our legitimate grounds override yours.

6.5 Right to Data Portability

You have the right to receive, transmit, or have us transmit your personal data in a machine-readable format.

Specifically: You have the right to receive the personal data concerning you that you have provided to us in a structured, commonly used, and machine-readable format, and you have the right to transmit that data to another controller without hindrance from us, provided that

1. the processing is based on consent in accordance with Art. 6 para. 1 sentence 1 a) GDPR or Art. 9 para. 2 a) GDPR or on a contract in accordance with Art. 6 para. 1 sentence 1 b) GDPR; and

2. the processing is carried out by automated means.

When exercising your right to data portability in accordance with para. 1, you have the right to have the personal data transmitted directly from us to another controller, where technically feasible.

6.6 Right to Object

You have the right to object to the lawful processing of your personal data by us if this is based on your particular situation and our interests in the processing do not prevail.

Specifically: You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you which is based on Art. 6 para. 1 sentence 1 e) or f) GDPR; this also applies to profiling based on these provisions. We will no longer process the personal data unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights, and freedoms or for the establishment, exercise, or defense of legal claims.

Where personal data is processed by us for direct marketing purposes, you have the right to object at any time to the processing of personal data concerning you for such marketing; this also applies to profiling to the extent that it is related to such direct marketing.

You have the right to object, on grounds relating to your particular situation, to the processing of personal data concerning you for scientific or historical research purposes or for statistical purposes in accordance with Art. 89 para. 1 GDPR unless the processing is necessary for the performance of a task carried out for reasons of public interest.

6.7 Automated Decisions, Including Profiling

You have the right not to be subject to a decision based solely on automated processing – including profiling – that produces legal effects concerning you or similarly significantly affects you.

No automated decision-making based on the collected personal data takes place.

6.8 Right to Withdraw Consent Under Data Protection Law

You have the right to withdraw your consent to the processing of personal data at any time.

6.9 Right to Lodge a Complaint with a Supervisory Authority

You have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your residence, your place of work, or the place of the alleged infringement, if you consider that the processing of personal data concerning you is unlawful.

7. Data Security

We strive to ensure the security of your data within the framework of applicable data protection laws and technical possibilities to the maximum extent.

Your personal data is transmitted to us in encrypted form. This applies to your orders and also to the customer login. We use the SSL (Secure Socket Layer) encryption system, but we point out that data transmission over the Internet (e.g., when communicating by email) may have security vulnerabilities. A complete protection of the data against access by third parties is not possible.

To secure your data, we maintain technical and organizational security measures in accordance with Art. 32 GDPR, which we continuously adapt to the state of the art.

We do not guarantee that our offer will be available at certain times; disruptions, interruptions, or failures cannot be excluded. The servers we use are regularly and carefully backed up.

8. Disclosure of Data to Third Parties, No Data Transfer to Non-EU Countries

In principle, we only use your personal data within our company.

If and to the extent that we involve third parties in the fulfillment of contracts (such as logistics service providers), they only receive personal data to the extent that the transmission is necessary for the corresponding service.

In the event that we outsource certain parts of the data processing ("order processing"), we contractually oblige the processor to only use personal data in accordance with the requirements of data protection laws and to ensure the protection of the rights of the data subject.

A data transfer to entities or persons outside the EU outside of the case mentioned in this declaration in item 4 does not take place and is not planned.

9. Data Protection Officer

If you have any further questions or concerns about data protection, please contact our data protection officer:

Olga Hadwiger
Phone: +48 784 500 560
Mobile: +48 784 500 643
Email: info@safort-consulting.com