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Privacy policy

Please read the privacy policy of the Defro website

Privacy policy

In order to ensure transparency and reliability of the personal data processing processes carried out by our Company, below we present the personal data protection principles applicable at Defro R. Dziubeła spółka komandytowa with its registered office in Ruda Strawczyńska, established in accordance with 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 – hereinafter referred to as GDPR (OJ EU L No. 119, p. 1).

In our activities, we attach great importance to issues related to the processing of personal data and information protection, not only because such an obligation is imposed on us by legal provisions, but primarily because we respect the right to privacy and believe that it is one of one of the most important elements of good cooperation and building trust and a good image of our company.

Spis treści

1. Administrator danych

The administrator of personal data is the company DEFRO R. Dziubeła Spółka komandytowa with its registered office in Ruda Strawczyńska 103 A, 26-067 Strawczyn, NIP 9591968493 – hereinafter referred to as DEFRO. The administrator is the entity that decides on the goals
and means of processing personal data.

In all matters related to the processing of your personal data, you can contact us by post to the address indicated above, as well as by sending e-mail correspondence to the data protection officer (IOD) appointed in our company – iod@defro.pl

2. What data we process

In accordance with the accepted practice of most websites, we store HTTP queries directed to our server. Browsed resources are identified by URL addresses. The exact list of information stored in the web server log files is as follows:

  • public IP address of the computer from which the query came (it can be directly the user’s computer)
  • name of the client station – identification carried out via the HTTP protocol, if possible,
  • username provided during the authorization process,
  • query arrival time,
  • first line of the HTTP request,
  • HTTP response code,
  • the number of bytes sent by the server,
  • URL address of the page previously visited by the user (referrer link) – if the website www.defro.pl was accessed via a link,
  • information about the user’s browser,
  • information about errors that occurred during the HTTP transaction.
  • In addition, we process the following data obtained directly from the website user:
  • name, surname, e-mail address, telephone number in the case of persons contacting via electronic forms, sending inquiries, completing a heat pump selection questionnaire or ordering a heat recovery plan;
  • data allowing identification of your equipment in the case of service requests;
  • data regarding the property/building, type of heating used, number of inhabitants – in the case of using a survey regarding the selection of a heat pump or heat recovery;
  • data provided if the user decides to communicate via chat;

In addition, we process the following data obtained directly from the website user:

  • name, surname, e-mail address, telephone number in the case of persons contacting via electronic forms, sending inquiries, completing a heat pump selection questionnaire or ordering a heat recovery plan;
  • data allowing identification of your equipment in the case of service requests;
  • data regarding the property/building, type of heating used, number of inhabitants – in the case of using a survey regarding the selection of a heat pump or heat recovery;
  • data provided if the user decides to communicate via chat;

3. Purpose of data processing

DEFRO is one of the largest central heating boilers in Europe. for solid fuels. In connection with the implementation of our business purpose, we process personal data for the following purposes:

PURPOSE OF PROCESSINGLEGAL BASIS AND STORAGE PERIOD OF PERSONAL DATACZAS PRZECHOWYWANIA
Activities aimed at concluding and implementing a contract with a client or contractor, within the scope of the administrator’s activities, including for the purpose of conducting authorization and product training
If data is collected for purposes related to the performance of a specific contract, the Administrator provides the data subject with detailed information regarding the processing of his or her personal data at the time of concluding the contract.
art. 6 section 1 letter b GDPR
(concerning clients/contractors);
art. 6 section 1 letter f GDPR
(concerning people cooperating with us on behalf of the client/contractor).
(the Administrator’s legitimate interest is considered to be the need to contact clients/employees/collaborators of clients and contractors in connection with actions taken to conclude the contract or its implementation, including contact with the training participant in order to provide organizational information about the training and post-training materials)
Personal data will be processed until the contract is performed and after its completion for purposes related to:
a. pursuing claims in connection with the performance of the contract (i.e., in principle, for a maximum period of 6 years from the date of completion of the contract),
b. performance of obligations arising from legal provisions, in particular tax and accounting provisions (i.e., as a rule, for 5 years, counting from the end of the calendar year in which the tax payment deadline expired),
c. data for marketing purposes: until you raise an objection, i.e. you show us in any way that you do not want to stay in contact with us or receive information about the activities we undertake, or until the limitation period for claims expires
Preparing projects of a heat recovery plan or heat pump selection
(initiated by the website user)
art. 6 section 1 letter a GDPRUntil consent is withdrawn, no longer than 12 months
Consent may be withdrawn free of charge at any time via e-mail biuro@defro.pl.
Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal
Establishing, pursuing and defending against such claimsart. 6 section 1 letter f GDPR
(the legitimate interest pursued by the Administrator is considered to be taking actions to pursue and defend against claims – in this respect, data of the client/contractor, their employees and associates are collected to the extent necessary to pursue or defend against claims.
art. 6 section 1 letter f GDPR
(the legitimate interest pursued by the Administrator is considered to be taking actions to pursue and defend against claims – in this respect, data of the client/contractor, their employees and associates are collected to the extent necessary to pursue or defend against claims.
Archiving documents relating to concluded contracts, including settlement documentsart. 6 section 1 letter c and f GDPRUntil DEFRO fulfills individual legal obligations related to the storage of documents, as specified in individual legal provisions. In relation to documents the storage of which is not expressly specified in legal provisions, for the time possible to pursue claims in accordance with the legitimate interest of the Administrator.
Conducting settlements, accounting and financial reporting.art. 6 section 1 letter c GDPRFor the period until the expiry of the data storage obligations arising from legal provisions, in particular the storage of accounting documents (in principle, for 5 years after the year in which the legal event that obliged to issue an accounting document occurred).
Conducting marketing activities without the use of electronic means of communication, as referred to in the Act on the provision of electronic services and the Telecommunications Law.art. 6 section 1 letter f GDPR
(legally justified interest is considered to be conducting marketing activities promoting Defro products and services)
Until the objection referred to in Art. 21 GDPR and indicate to us in any way that you no longer wish to receive such information.
Conducting marketing activities using electronic means of communication referred to in the Act on the provision of electronic services and the Telecommunications Law, in particular via e-mail, SMS, direct telephone contact, as well as sending a newsletter to contractorsart. 6 section 1 letter f GDPR
In the case of marketing using a telephone number or e-mail address, the administrator will obtain consent for the communication channel in accordance with the Act on the provision of electronic services or the Telecommunications Law.
(conducting promotional marketing activities is considered a legitimate interest
Until you object, i.e. you show us in any way that you do not want to stay in contact with us or receive information about the actions we take, or until the limitation period for claims expires.
Conducting communication in traditional and electronic formart. 6 section 1 letter f GDPR – the legitimate interest of the administrator is considered to be conducting research to assess the quality of services provided, researching the market and needs.For the period necessary to settle the matter/response or longer in the event of potential claims, for the limitation period specified by law, in particular the Civil Code, or for other purposes resulting from the implementation of our legitimate interests. In each case, the longer period of storage of personal data is decisive.
Conducting recruitment processesart. 6 section 1 letter a and c GDPR
regarding candidates for employees
art. 6(1)(a) a and b GDPR
regarding candidates for collaborators)
Until the recruitment process for a specific position is completed, and if the candidate consents to the processing of his or her data for the purposes of other recruitment processes – no longer than 12 months.
Video monitoring at DEFRO
to ensure the safety of persons and property and maintain information security.
art. 6 section 1 letter c and f GDPR
Conducting access control for people staying at the Defro headquarters is our legitimate interest, and in the case of employees, it results from the law (Article 222 of the Labor Code).
Fixed image recordings are stored for a maximum period of time. up to 3 months or submitting a justified objection. The exception are cases where the recording constitutes evidence in proceedings conducted by law enforcement/judicial authorities (in such a case, until the final conclusion of such proceedings or until an objection is raised).
Contact via contact formsart. 6 section 1 letter f GDPR
(the legitimate interest of the administrator is the proper service of our clients, including enabling contact with Defro)
Personal data in the form of a conversation recording are processed:
for purposes related to servicing customers and interested parties via the hotline, if the Administrator provides such a service – the legal basis for processing is the necessity of processing to provide the service (Article 6(1)(b) of the GDPR);
in order to monitor the quality of service and verify the work of consultants operating the hotline, as well as for analytical and statistical purposes – the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR) consisting in ensuring the highest possible quality of service for customers and customers, as well as the work of consultants and conducting statistical analyzes of telephone communication.
For the period necessary to respond or longer in the event of potential claims, for the limitation period specified by law, in particular the Civil Code, or for other purposes resulting from the implementation of our legitimate interests. In each case, the longer period of storage of personal data is decisive.
Conducting telephone contact
Calls directed to the headquarters telephone number and the service hotline number are recorded – appropriate information is provided at the beginning of the conversation. The recordings are available only to the Administrator’s employees and people operating the Administrator’s hotline
art. 6 section 1 letter f GDPR
(the legitimate interest of the administrator is the proper service of our clients, including enabling contact with Defro)
Personal data in the form of a conversation recording are processed:
for purposes related to servicing customers and interested parties via the hotline, if the Administrator provides such a service – the legal basis for processing is the necessity of processing to provide the service (Article 6(1)(b) of the GDPR);
in order to monitor the quality of service and verify the work of consultants operating the hotline, as well as for analytical and statistical purposes – the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) of the GDPR) consisting in ensuring the highest possible quality of service for customers and customers, as well as the work of consultants and conducting statistical analyzes of telephone communication.
until the matter is resolved

For a period of 6 months counted from the month following the month in which the recording was recorded or until the objection is raised. The exception is cases where the recording constitutes evidence
in proceedings conducted by law enforcement/judicial authorities
(in such a case, until the final conclusion of such proceedings).
Chat
(concerning your personal data that you provide via the Chat located on the website www.defro.pl)
handling inquiries via chat – legal basis: art. 6 section 1 letter f GDPR,
(the legitimate interest pursued by the Administrator is considered to be proper service and enabling contact with clients/contractors and potential clients and providing them with the requested information),
depending on the content of the communication, taking action at your request before concluding an appropriate contract – legal basis: Art. 6 section 1 letter b GDPR, i.e. the necessity to take action before concluding a contract;
As a rule, we will process your data until communication with you ends or we will store it longer in case of potential claims, for the period of limitation specified by law, in particular the Civil Code, or for other purposes resulting from the implementation of our legitimate interests. In each case, the longer period of storage of Personal Data is decisive.
Cookie processingart. 6 section 1 letter f GDPR
(legitimate interest is considered to be enabling the operation of basic website functions and adapting the content of websites to the needs of users, including for marketing and statistical purposes, optimizing the use of websites).
The data is processed for the periods indicated in the Cookie Policy or until an objection to data processing is raised.
For purposes related to initiating and maintaining business contacts
(e.g. exchanging business cards, sending special greetings, exchanging information, including personal data, at industry events and business meetings)
art. 6 section 1 letter f GDPR
(the legitimate interest of the administrator is the creation of a network of contacts in connection with the business activity conducted)
Until the objection referred to in Art. 21 GDPR and indicate to us in any way that you no longer wish to receive such information.

INFORMATION ON THE OPPORTUNITY OR OBLIGATION TO PROVIDE DATA
Providing personal data, depending on the purpose of processing, may be a statutory or contractual requirement or a condition for concluding a contract. To the extent that you want to use DEFRO’s services, providing data will be necessary to conclude a contract and for us to fulfill our legal obligations. The consequence of not providing data is the inability to conclude a contract. For all other purposes, providing them is voluntary. The consequence of not providing data will be that DEFRO will not be able to take appropriate actions to the extent that you have not agreed to provide data.

3. Data recipients

DEFRO may disclose your data:

  • business entities and natural persons conducting business activities cooperating with and supporting DEFRO in the scope of services provided to customers – in particular in the field of maintenance, assembly, delivery, courier and hosting services,
  • business entities cooperating with DEFRO in the field of consulting, financial and legal services, including law firms, auditing companies, training and consulting companies, as well as recruitment agencies;
  • business entities supporting DEFRO in the scope of their business activities, in particular suppliers of external ICT systems, entities cooperating in marketing campaigns;
  • banks in terms of settlements;

Personal data may also be transferred to state authorities and other authorized bodies pursuant to applicable legal provisions and to the extent indicated in the legal provisions.

4. Transfer of data to third countries

DEFRO processes data only within the European Union and European Economic Area countries. It does not transfer them to third countries. However, due to the data processing technology used by Microsoft Ireland Operations Limited with its registered office in Dublin, which is the processor for Defro, your personal data may be processed outside the EEA, and such operations are based on Standard Contractual Clauses, developed on the basis of a decision of the Commission European Union of 4 June 2021 (2021/914).

5. Processing of personal data in an automated manner

Personal data will not be processed in an automated manner, and will not be subject to profiling as referred to in the GDPR.

6. Rights of data subjects regarding data processing

In connection with the processing of your personal data, you have the following rights:

  • the right to access your data and receive a copy thereof in accordance with Art. 15 GDPR;
  • the right to rectify (correct) your data in accordance with Art. 16 GDPR;
  • the right to delete personal data in accordance with Art. 17 GDPR;
  • the right to restrict data processing in accordance with Art. 18 GDPR;
  • the right to object to the processing of personal data, in accordance with Art. 21 GDPR;
  • the right to withdraw consent at any time when your data is processed on the basis of consent, and its withdrawal does not affect the lawfulness of processing based on consent before its withdrawal.

The scope of each of these rights and the situations in which you can exercise them result from legal provisions. Which rights you can exercise will depend on the legal basis and purpose of our processing of your personal data.

In addition, the person whose data is processed by DEFRO has the right to lodge a complaint with the supervisory authority, which in Poland is the President of the Personal Data Protection Office. More information about the Personal Data Protection Office and how to submit a complaint can be found at: www.uodo.gov.pl

8. Processing of children’s personal data

Our website is not intended for children under 16 years of age.

9. Do we want to process special categories of data?

We do not want, therefore we ask our Users to be careful when sharing their personal data, in particular never to provide special categories of data, e.g. regarding health condition, racial origin, political views and others mentioned in Art. 9 GDPR.

10. Security

The internet will never be a completely safe place. However, we make every effort to ensure that your personal data is properly secured in our systems. We have implemented a number of solutions to ensure the security of your data.Here are some examples:

  • We use data encryption, firewalls and anti-virus software.
  • We monitor IT systems on an ongoing basis and apply security procedures.
  • We have also implemented a procedure in the event of a personal data protection breach.

We will inform you about any event related to the processing of your data if we determine that it causes a high risk of violating your rights and freedoms.

11. Why do we use video monitoring at our headquarters

If you decide to visit us at our headquarters, please note that it is covered by a video monitoring system (both the external area and the interior of the buildings). Monitoring is used on the basis of generally applicable law to protect property and ensure safety. The source of data are records from surveillance system cameras located inside and outside the building. Monitoring data will be processed for the period and to the extent required by generally applicable law.

The recipients of registered personal data will only be entities authorized to obtain personal data under the law.

Your right to access your data is limited due to the risk of violating the rights and freedoms of other people recorded by the surveillance system cameras.

12. Cookie mechanism. Links to other sites

Some areas and functions of the Website may use cookies, i.e. text files saved on the computer of a person visiting the Website, identifying it in a way necessary to enable certain operations. Cookies are used, among other things, to remember the data necessary to log in the user. The condition for cookies to work is their acceptance and not deleting them from the disk.

Detailed information about cookies can be found in the Cookie Policy.

13. Change of privacy policy.

This version was last updated on November 2, 2023. We may change this Policy from time to time, and we will inform you about it by updating this section.

The Website Administrator reserves the right to change the above privacy policy at any time and place, and undertakes to immediately publish the new privacy policy on the Website. We also maintain previous versions of this Privacy Policy in an archive for users to review.

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