What does this document contain?

Information about the protection of your personal data, including your rights.

The policy is divided into three parts:

1. explanation of concepts used in the Policy, information about our contact data and your rights;

2. detailed information about the processing of your personal data; information is given separately in respect of each form that you can fill in on our website,

3. information about cookie files.

Table of contents

Part I – General provisions

§ 1 Controller

1. Your personal data is controlled by Polcom Modular Sp. z o.o. Further in this Privacy Policy, we refer to ourselves in the first person or as the ‘Controller’.

2. Our registration files are kept by the District Court for Gdańsk – Północ w Gdańsku, VIII Commercial Division of the National Court Register, under reference number 0000747253, Tax Identification Number: 7010850809, REGON number 381223093. The Controller’s share capital amounts to PLN 5 005 100,00. Our files contain the most important information about us, e.g. financial statements or the articles of association of our company.

3. You can contact us:

   1. by post: Polcom Modular Sp. z o.o., Topole 68, 89-600 Chojnice, Poland; or

   2. by phone: +48 52 398 51 07.

§ 2 Definitions used in the Privacy Policy

If you notice below any of the following concepts written with a capital letter, they should be interpreted in accordance with the following definitions:

1. ‘Website’ – the website at https://polcomgroup.com/and its subpages,

2. ‘Policy’ – this document, namely the privacy policy you’re reading now,

3. ‘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. The text of GDPR can be found here.

§ 3 Protection of personal data

1. We will process any personal data that you enter on the Website or that we collect about you while you use the Website in accordance with the GDPR, as the data Controller.

2. We apply the technical measures required by data protection regulations to prevent unauthorised persons from collecting and modifying personal data sent electronically, i.e. within the framework of our Website.

§ 4 Your rights with regards to personal data

1. We process your personal data, and therefore:

1. 1. you have the right to access your personal data,

   2. you have the right to rectify your data,

   3. you have the right to demand the erasure of your personal data where enabled by the GDPR,

   4. you have the right to restrict the processing of your data, to the extent specified in GDPR.

2. The second part of the Policy contains information about your additional rights, as you will have additional options when filling in certain forms.

3. Do you want to exercise your rights or learn more about them? Contact us. Our contact data can be found in § 1 subsection 3 of the Policy.

§ 5 Right to object

1. After you provide us with your personal data, you may exercise your right to object. You have the right to object in two situations, where we process your personal data:

1. 1. for the purposes of direct marketing – no justification is needed for such an objection;

   2. based on our other legitimate interest; objection in this case requires justification based on your particular situation. You need to inform us why we should not process your personal data.

2. Do you want to exercise your right to object? Contact us. Our contact data can be found in § 1 subsection 3 of the Policy.

§ 6 Complaint to a supervisory authority

If you believe that we are processing your personal data contrary to regulations, you may submit a complaint to a supervisory authority. The supervisory authority in Poland is the President of the Personal Data Protection Office.

§ 7 Questions concerning the Policy and its location

1. If you have any questions concerning the Policy, don’t hesitate to contact us.

2. The Policy can be found at https://polcom.qa.kambu.pl/privacy-policy/ and in our head office.

Part II – information concerning the processing of your personal data while contacting us

§ 8 Contact form

If you are using that function of our Website, take note of the following issues:

1. Why do we need your data, why do we process it?

   To answer your message and to resolve your issue.

2. What are your rights?
   You can find them in § 4 and 5 of the Policy.

3. Are you required to provide us with your data?
   Providing your data is voluntary. However, if you do not provide your contact data, we may not be able to resolve your issue.

4. What is the legal basis for our processing of your data?
   Article 6(1f) of GDPR, namely our legitimate interests.

5. What is our legitimate interest?
   To resolve your issue, answer your message.

6. Who will we provide with your data?

1. 1. Entities providing us with hosting services in respect of the Website or personal data.

   2. Suppliers of marketing and analytics tools.

   3. Postal and courier service providers.

   4. Other entities from Polcom group.

7. How long will we process your data?
   We will process your data for the time required to resolve your issue. Depending on the type of the issue, we may also process your data for the period required to demonstrate that we did resolve your issue, i.e. until any potential related claims become statute-barred.

8. Will your personal data be transferred outside the European Economic Area?
   Yes, Your data may be transferred outside the European Economic Area, as we are a part of international Polcom Group. We may also outsource the performance of individual services and tasks to selected service providers established outside the European Economic Area (third countries), in particular, IT service providers. If, therefore, the transfer of your data outside the European Economic Area is necessary, it will take place on the legal basis provided for in the GDPR. You may obtain further information and receive copies of the relevant security measures at any time.

Part III – information on cookies

§ 9 What are cookies and why do we use them

1. Our Website uses cookies, small text files kept on your end device (e.g. computer, tablet, smartphone). Cookies may be read by the Website. Want to know more about cookies? Check this Wikipedia article.

2. We keep cookies on your computer, telephone or tablet and access information stored in therein for the following purposes:

   1. Website configuration and ensuring its full functionality, by:

      1. adjusting the content of the Website pages to your preferences and optimizing the use of the Website pages. In particular, these files allow you to recognize the basic parameters of your User device and properly display the website, tailored to your individual needs;

      2. remembering the settings and personalisation of the interface you have chosen, e.g. the language or region you are from, the font size, the look of the website, etc;

   2. Statistics to understand how you interact with websites by collecting and reporting information anonymously;

   3. ensuring security and reliability of the Website.

§ 10 Types of cookies

Several types of cookies are used on the Website:

1. session cookies, which stay in your browser’s cache until you close it,

2. permanent cookies, which stay in your browser’s cache until you delete them or expiry date,

3. external cookies that originate in the suppliers of analytics tools used on our Website.

§ 11 How to delete cookies

1. You can configure your browser so as to prevent it from storing cookies on your computer, telephone or tablet.

2. You can delete cookies after they are saved by the Website. To do so, you may use the suitable function of your browser, software made specially for this purpose or suitable tools available as part of your operating system.

3. Methods of deleting cookies using the most popular browsers can be found at the below links:

• Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox,

• Opera: http://help.opera.com/Linux/9.60/pl/cookies.html,

• Internet Explorer: https://support.microsoft.com/en-us/help/278835/how-to-delete-cookie-files-in-internet-explorer;

• Chrome:https://support.google.com/accounts/answer/32050?co=GENIE.Platform%3DDesktop&hl=en;

• Safari: https://support.apple.com/en-gb/HT201265;

§ 12 Effects of changing browser settings on using the Website

Changing your browser settings so as to prevent or restrict the storage of cookies may limit the functionality of the Website. Deleting cookies while using the service may lead to similar effects. This means that some of our services will not be available without cookies, e.g. you will not be able to use the contact form.

§ 13 External cookies

1. Cookies stored on your computer, telephone or tablet may originate with other service providers. If, therefore, the transfer of your data outside the European Economic Area is necessary, it will take place on the legal basis provided for in the GDPR.

2. We use the services of:

   1. Google Analytics, provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA),

3. You can block the operation of Google Analytics. To do so, install this browser plugin provided by Google Inc., available here: https://tools.google.com/dlpage/gaoptout?hl=en-GB.

§ 14 Profiling

1. Your profile as a user of the website may be created using information about you stored in cookies, based on personal aspects relating to you, such as preferences or interests.
2. Based on your profile created using analytical tools, we will not make automated decisions concerning you that would produce legal effects or affecting you in a similar manner.

September 21, 2020