Privacy Policy
§1 Definitions
Service – the “GTO Global” online service operating at https://gto.global
External Service – online services of partners, service providers, or service recipients cooperating with the Controller
Service / Data Controller – the entity acting as both the Controller of the Service and the Data Controller (hereinafter the “Controller”) is “GTO Global sp. z o.o.”, conducting business activity at: 3 Maja 22 / 2C, 40-096 Katowice, Poland, Tax Identification Number (NIP): 6343029638, KRS Number: 0001062586, providing services by electronic means via the Service
User – a natural person to whom the Controller provides services by electronic means through the Service
Device – an electronic device with software through which the User accesses the Service
Cookies – textual 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 – the data subject’s consent means any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, 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 – the anonymisation of data is an irreversible process of data operations that destroys/overwrites “personal data” in a manner that renders it impossible to identify or associate a given record with a specific User or natural person
§2 Data Protection Officer
Pursuant to Article 37 of the GDPR, the Controller has not appointed a Data Protection Officer. Matters regarding data processing, including personal data, shall be addressed directly to the Controller.
§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 the User’s Device, have been deliberately included in the Service via scripts and services provided and installed within the Service
Session Cookies – files placed and read from the User’s Device by the Service during a single 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. These files are not automatically deleted after the Device session ends unless the User’s Device configuration is set to delete Cookies upon ending the Device session
§4 Data Storage Security
Mechanisms for the storage and retrieval of Cookies – The mechanisms for storing, retrieving, and exchanging data between Cookies stored on the User’s Device and the Service are executed via built-in mechanisms of web browsers and do not permit the retrieval of other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojan horses, or other malware to the User’s Device is practically impossible.
Internal Cookies – Cookies applied by the Controller are safe for Users’ Devices and do not contain scripts, content, or information that could compromise the security of personal data or the security of the Device used by the User.
External Cookies – The Controller takes all possible measures to verify and select partners of the Service in the context of User security. The Controller cooperates with well-known, large partners enjoying global public trust. However, the Controller does not possess full control over the content of Cookies originating from external partners. To the extent permitted by law, the Controller bears no responsibility for the security of Cookies, their contents, or their use in accordance with licensing by Scripts originating from External Services and installed within the Service. The list of partners is provided later in this Privacy Policy.
Control of Cookies – The User may, at any time, independently change the settings concerning the saving, deletion, and access to data of stored Cookies by any website.
Information on how to disable Cookies in the most popular desktop browsers is available on the website: 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 may, at any time, delete all Cookies stored thus far by using the tools of the User’s Device through which the User uses the Service’s services.
User-side risks – The Controller applies all possible technical measures to ensure the security of data placed in Cookies. However, it must be noted that the security of such data depends on both parties, including the actions of the User. The Controller shall not be liable for the interception of such data, impersonation of the User’s session, or their deletion resulting from the deliberate or inadvertent activity of the User, viruses, Trojan horses, or spyware which may or may have infected the User’s Device. To protect themselves against such risks, Users should observe the principles of safe use of the internet.
Storage of personal data – The Controller ensures that it undertakes all efforts to ensure that the processed personal data voluntarily provided by Users are secure, access to such data is restricted, and the data are used in accordance with their intended purpose and processing objectives. The Controller also ensures that it undertakes all efforts to protect the held data from loss through the application of appropriate physical and organisational safeguards.
Storage of passwords – The Controller declares that passwords are stored in encrypted form using the most current standards and guidelines in this field. Decryption of passwords provided in the Service for account access is practically impossible.
§5 Purposes of Using Cookies
- Enhancement and facilitation of access to the Service
- Personalisation of the Service for Users
- Enabling login to the Service
- Marketing, remarketing in external services
- Advertisement serving services
- Affiliate services
- Compilation of statistics (users, number of visits, types of devices, connections, etc.)
- Provision of multimedia services
- Provision of social networking 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:
- Services of registration and maintenance of the User’s account in the Service and functionalities related thereto
- Newsletter services (including transmission of advertising content with consent)
- Services for sharing information about content placed in the Service on social media platforms or other websites
- Communication of the Controller with Users regarding the Service and data protection matters
- Ensuring the legitimate interest of the Controller
User data collected anonymously and automatically are processed for one of the following purposes:
- Compilation of statistics
- Remarketing
- Serving advertisements tailored to Users’ preferences
- Management of affiliate programs
- Ensuring the legitimate interest of the Controller
Within the Service, the Controller uses JavaScript scripts and web components of partners who may place their own cookies on the User’s Device. Please note that in the settings of your browser you may independently determine which cookies are permitted to be used by particular websites. Below is a list of partners or their services implemented in the Service which may place cookies:
- Multimedia services:
- Social / Integrated services (Registration, Login, content sharing, communication, etc.):
- Content sharing services:
- Newsletter services:
- Advertising and affiliate network services:
- Statistics services:
- Other services:
The services provided by third parties are outside the Controller’s control. These entities may at any time change their terms of service, privacy policies, purposes of data processing, and the methods of use of cookies.
§8 Types of Data Collected
The Service collects data concerning Users. Some data are collected automatically and anonymously, while other data are personal data voluntarily provided by Users during the registration for specific services offered by the Service.
Anonymous data collected automatically:
IP address
Browser type
Screen resolution
Approximate location
Visited subpages of the Service
Time spent on specific subpages of the Service
Type of operating system
Address of the previous subpage
Referring page address
Browser language
Internet connection speed
Internet service provider
Demographic data (age, gender)
Data collected during registration:
First name / last name / pseudonym
Username
Email address
Telephone number
IP address (collected automatically)
Tax Identification Number (NIP)
Data collected during newsletter subscription:
First name / last name / pseudonym
Email address
IP address (collected automatically)
Data collected when posting a comment:
First name and last name / pseudonym
Email address
Website address
IP address (collected automatically)
Some data (excluding identifying data) may be stored in cookies. Some data (excluding identifying data) may be transmitted to a provider of statistical services.
§9 Access to Personal Data by Third Parties
As a rule, the sole recipient of the personal data provided by Users is the Controller. Data collected as part of the services rendered are not transferred or sold to third parties. Access to data (most often on the basis of a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary for the operation of the Service, i.e.:
Hosting companies providing hosting or related services to the Controller
Companies intermediating in online payments for goods or services offered within the Service (in the case of a purchase transaction carried out within the Service)
Companies responsible for the Controller’s accounting services (in the case of a purchase transaction carried out within the Service)
Outsourcing of Personal Data Processing – Newsletter
In order to provide the Newsletter service, the Controller uses the services of third-party providers – Freshmail, MailChimp, Mailerlite, SendPulse. Data entered in the newsletter subscription form are transferred, stored, and processed within the external service of said provider. It is hereby stated that the specified partner may modify its privacy policy without the Controller’s consent.
Outsourcing of Personal Data Processing – Hosting, VPS, or Dedicated Server Services
In order to operate the Service, the Controller uses the services of an external provider of hosting, VPS, or Dedicated Server infrastructure –
Data Processing in the Case of Online Payments
In the event of online payments, all payment data are transmitted directly by the User to the entity executing the payment –
Transfer of Personal Data – Accounting Services
In the event of a transaction, part of the personal data of natural persons or data of natural persons conducting economic activity is transferred to an entity providing accounting services to the Controller. The transfer of such data is governed by the applicable Act … and the agreement concluded between the Controller and the Service Provider.
§10 Manner of Personal Data Processing
Personal data voluntarily provided by Users:
Personal data shall not be transferred outside the European Union unless published as a result of an individual action of the User (e.g. by posting a comment or entry), making the data available to anyone visiting the Service
Personal data shall not be used for automated decision-making (profiling)
Personal data shall not be sold to third parties
Anonymous data (non-personal data) collected automatically:
Anonymous data (non-personal data) shall be transferred outside the European Union
Anonymous data (non-personal data) shall not be used for automated decision-making (profiling)
Anonymous data (non-personal data) shall not be sold to third parties
§11 Legal Grounds for the Processing of Personal Data
The Service collects and processes Users’ data based on the following:
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
Article 6(1)(a): the data subject has given consent to the processing of his or her personal data for one or more specific purposes
Article 6(1)(b): processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
Article 6(1)(c): processing is necessary for compliance with a legal obligation to which the Controller is subject
Article 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 the Protection of Personal Data (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 Duration of Personal Data Processing
Personal data voluntarily provided by Users:
As a rule, such personal data are stored solely for the duration of the provision of the Service by the Controller. They are deleted or anonymised within a period not exceeding 30 days from the termination of the service (e.g., deletion of the registered User account, unsubscribing from the Newsletter, etc.).
An exception shall apply in circumstances that require the safeguarding of legally justified purposes for the continued processing of such data by the Controller. In such cases, the Controller may retain the specified data, from the moment of the User’s deletion request, for no longer than 3 years in the event of a breach or suspected breach of the Terms of Service by the User.
Anonymous data (non-personal data) collected automatically:
Anonymous statistical data not constituting personal data are stored by the Controller for the purpose of Service statistics for an indefinite period.
§13 Rights of Users in Connection with the Processing of Personal Data
The Service collects and processes Users’ data based on:
Right of access to personal data
Users have the right to obtain access to their personal data, exercised upon request submitted to the Controller.
Right to rectification of personal data
Users have the right to request from the Controller without undue delay the rectification of inaccurate personal data and/or the completion of incomplete personal data, exercised upon request submitted to the Controller.
Right to erasure of personal data
Users have the right to request from the Controller the immediate erasure of personal data, exercised upon request submitted to the Controller. In the case of user accounts, the erasure of data consists of anonymising the data enabling the identification of the User. The Controller reserves the right to suspend the execution of a deletion request in order to protect the legitimate interest of the Controller (e.g., if the User has breached the Terms of Service or the data was obtained as a result of ongoing correspondence). For the Newsletter service, the User has the possibility to independently remove their personal data by using the link included in every email message.
Right to restriction of personal data processing
Users have the right to restrict the processing of their personal data in the circumstances specified in Article 18 of the GDPR, including contesting the accuracy of the personal data, exercised upon request submitted to the Controller.
Right to data portability
Users have the right to obtain from the Controller their personal data in a structured, commonly used, and machine-readable format, exercised upon request submitted to the Controller.
Right to object to personal data processing
Users have the right to object to the processing of their personal data in cases specified in Article 21 of the GDPR, exercised upon request submitted to the Controller.
Right to lodge a complaint
Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.
§14 Contact with the Controller
The Controller may be contacted in one of the following ways:
Postal address: GTO Global, 3 Maja 22 / 2C, 40-096 Katowice, Poland
Email address: contact.pl@gto.global
Telephone contact: +48 32 600 79 19
§15 Service Requirements
Restrictions on the saving and access to Cookies on the User’s Device may result in the improper functioning of certain functionalities of the Service.
The Controller bears no liability for improperly functioning features of the Service in the event that the User restricts the possibility of saving and reading Cookies in any manner.
§16 External Links
Within the Service – in articles, posts, entries, or comments by Users – references to external websites may be present, with which the Owner of the Service does not cooperate. These links, as well as the websites or files they refer to, may be dangerous for your Device or pose a threat to the security of your data.
The Controller shall not be held liable for content located outside the Service.
§17 Amendments to the Privacy Policy
The Controller reserves the right to amend this Privacy Policy at any time without the obligation to notify Users with regard to the use and processing of anonymous data or the use of Cookies.
The Controller reserves the right to amend this Privacy Policy in the scope of the processing of Personal Data, of which Users possessing user accounts or subscribed to the newsletter service shall be informed via email within 7 days of the change.
Continued use of the services shall constitute acknowledgment and acceptance of the amendments made to the Privacy Policy. In the event that the User does not agree to the introduced amendments, the User is obliged to delete their account from the Service or unsubscribe from the Newsletter service.
Amendments to the Privacy Policy shall be published on this subpage of the Service.
Amendments shall enter into force upon their publication.
