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Privacy policy

Please read the privacy policy of the Defro website

Privacy policy

To ensure transparency and reliability in the personal data processing activities carried out by our Company, below we present the rules of personal data protection applicable at Defro R. Dziubeła limited partnership, located 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 GDPR (OJ EU L No. 119, p. 1).

In our operations, we attach great importance to matters related to personal data processing and information security, not only because such obligations arise from legal regulations, but also because we respect the right to privacy. We believe this is one of the most important elements of good cooperation, building trust, and maintaining a positive image of our company.

Spis treści

1. Administrator danych

The controller of personal data is DEFRO R. Dziubeła limited partnership, based in Ruda Strawczyńska, ul. Powiatowa 111A, 26-067 Strawczyn, NIP 9591968493 – hereinafter DEFRO.
The Controller is the entity that decides about the purposes and means of personal data processing.

For all matters related to the processing of your personal data, you may contact us in writing at the above address or via email by writing to our appointed Data Protection Officer (DPO) – iod@defro.pl.

2. What data we process

In line with the standard practices of most websites, we store HTTP requests sent to our server. The viewed resources are identified via URL addresses. The list of information stored in web server log files includes:

  • public IP address of the computer from which the request was sent,
  • client station name – if identifiable via HTTP protocol,
  • username provided during authorization,
  • time the request was received,
  • first line of the HTTP request,
  • HTTP response code,
  • number of bytes sent by the server,
  • URL of the previously visited page (referrer link),
  • browser information,
  • information about errors that occurred in connection with HTTP transactions.

Additionally, we process the following data provided directly by website users:

  • first name, last name, email address, phone number – for individuals contacting us via online forms, sending inquiries, completing the heat pump selection form, or ordering a ventilation recovery plan,
  • data enabling identification of owned equipment – in service requests,
  • information related to property/building, heating type, number of residents – when completing the heat pump or ventilation selection form,
  • data provided via chat communication on the website.

3. Purpose of data processing

DEFRO is one of the largest manufacturers of solid-fuel heating boilers in Europe. To achieve our business objectives, we process personal data for the following purposes:

PURPOSE OF PROCESSINGLEGAL BASIS AND STORAGE PERIOD OF PERSONAL DATASTORAGE PERIOD
Activities aimed at concluding and performing a contract with a client or contractor, within the scope of the Administrator’s activities, including 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 their 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 persons cooperating with us on behalf of the client/contractor).
(The Administrator’s legitimate interest is considered to be the need to contact clients/employees/associates of clients and contractors in connection with actions taken to conclude or perform the contract, including contacting the training participant to provide organizational information and post-training materials.)
Personal data will be processed until the contract is performed, and afterwards for purposes related to:
a. pursuing claims related to the performance of the contract (as a rule, for a maximum of 6 years from the date of completion of the contract),
b. fulfilling obligations under legal provisions, in particular tax and accounting regulations (as a rule, for 5 years from the end of the calendar year in which the tax payment deadline expired),
c. data processed for marketing purposes: until you raise an objection, i.e., you inform us in any way that you do not wish to remain in contact with us or receive information about our activities, or until the limitation period for claims expires.
Preparing heat recovery plan projects 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 at biuro@defro.pl.
Withdrawal of consent does not affect the lawfulness of processing based on consent prior to its withdrawal.
Establishing, pursuing and defending against claimsArt. 6 section 1 letter f GDPR
(The legitimate interest pursued by the Administrator is the undertaking of 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 the undertaking of 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 related 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 respective legal provisions. For documents not specifically covered by law, data is stored for the period necessary to pursue claims, in accordance with the Administrator’s legitimate interest.
Conducting settlements, accounting and financial reportingArt. 6 section 1 letter c GDPRFor the period required by legal obligations regarding data storage, in particular the storage of accounting documents (generally for 5 years after the year in which the legal event requiring issuance of an accounting document occurred).
Conducting marketing activities without the use of electronic communication means as defined in the Act on the Provision of Electronic Services and the Telecommunications LawArt. 6 section 1 letter f GDPR
(a legitimate interest is considered to be conducting marketing activities promoting DEFRO products and services)
Until the objection referred to in Art. 21 GDPR is raised and you inform us in any way that you no longer wish to receive such information.
Conducting marketing activities using electronic communication means 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 newsletters 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 inform us in any way that you do not wish to remain in contact with us or receive information about our activities, 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, as well as researching the market and user needs.For the period necessary to resolve the matter/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 data storage period applies.
Conducting recruitment processesArt. 6 section 1 letter a and c GDPR
(regarding candidates for employment)
Art. 6 section 1 letter a and b GDPR
(regarding candidates for cooperation)
Until the recruitment process for a specific position is completed, and if the candidate consents to their data being used for future recruitment processes – no longer than 12 months.
Video monitoring at DEFRO
to ensure the safety of people and property and maintain information security
Art. 6 section 1 letter c and f GDPR
Conducting access control for persons present at the DEFRO headquarters is our legitimate interest, and for employees results from legal provisions (Art. 222 of the Labor Code).
Video recordings are stored for a maximum of 3 months or until a justified objection is submitted. Exceptions apply when the recording constitutes evidence in proceedings conducted by law enforcement or judicial authorities (in such cases, storage continues 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 proper service of our clients, including enabling contact with DEFRO)
Personal data in the form of recorded conversations are processed:
for purposes related to customer service via the hotline, if such service is provided – the legal basis is the necessity to perform the service (Art. 6 section 1 letter b GDPR);
to monitor service quality and verify consultant performance, and for analytical and statistical purposes – the legal basis is the legitimate interest of the Administrator (Art. 6 section 1 letter f GDPR), which is ensuring the highest possible quality of customer service and conducting statistical analyses of telephone communication.
For the period necessary to respond, or longer in the case 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 storage period applies.
Conducting telephone contact
Calls directed to the headquarters’ telephone number and the service hotline are recorded – appropriate information is provided at the beginning of the call. Recordings are accessible only to the Administrator’s employees and hotline operators.
Art. 6 section 1 letter f GDPR
(the Administrator’s legitimate interest is proper customer service, including enabling contact with DEFRO)
Conversation recordings are processed:
for purposes related to servicing customers and interested parties via the hotline – legal basis: Art. 6 section 1 letter b GDPR;
for monitoring service quality, consultant verification, analytical and statistical purposes – legal basis: Art. 6 section 1 letter f GDPR.
Until the matter is resolved.

Recordings are stored for 6 months from the month following the date of recording or until an objection is raised. Exceptions apply when the recording constitutes evidence in law enforcement/judicial proceedings (stored until the final conclusion of such proceedings).
Chat
(concerning your personal data provided via the chat located on www.defro.pl)
Handling inquiries via chat – legal basis: Art. 6 section 1 letter f GDPR,
(the Administrator’s legitimate interest is proper service and enabling contact with clients, contractors and potential clients),
Depending on the communication content, actions taken at your request prior to concluding a contract – legal basis: Art. 6 section 1 letter b GDPR.
As a rule, we process your data until communication ends, or we store it longer in case 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 storage period applies.
Cookie processingArt. 6 section 1 letter f GDPR
(the legitimate interest is enabling basic website functionalities and adapting website content to user needs, including for marketing and statistical purposes, optimizing website use).
Data is processed for the periods indicated in the Cookie Policy or until an objection is raised.
For purposes related to initiating and maintaining business contacts
(e.g., exchanging business cards, sending greetings, exchanging information at industry events and business meetings)
Art. 6 section 1 letter f GDPR
(the Administrator’s legitimate interest is creating a network of contacts for business purposes)
Until the objection referred to in Art. 21 GDPR is raised and you inform us in any way that you no longer wish to receive such information.

INFORMATION ON THE POSSIBILITY OR OBLIGATION TO PROVIDE DATA
Depending on the purpose of processing, providing personal data may be a statutory or contractual requirement or a condition for concluding a contract. To the extent that you wish to use DEFRO’s services, providing data is necessary to conclude a contract and for us to fulfill our legal obligations. Failure to provide data will make it impossible to conclude the contract. For all other purposes, providing data is voluntary. The consequence of not providing data is that DEFRO will not be able to take appropriate actions within the scope for which you have not provided the required data.

3. Data recipients

DEFRO may disclose your personal data to:

  • state authorities when required by law.
  • business partners providing services for DEFRO (installation, service, delivery, IT, hosting),
  • consulting, financial, legal, auditing, training, and recruitment companies,
  • marketing service providers and IT system providers,
  • banks for settlement purposes,

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 is not processed automatically nor used for profiling.

6. Rights of data subjects regarding data processing

You have the following rights under GDPR:

  • right of access (Art. 15),
  • right to rectification (Art. 16),
  • right to erasure (Art. 17),
  • right to restriction (Art. 18),
  • right to object (Art. 21),
  • right to withdraw consent at any time (when processing is based on consent).

You also have the right to lodge a complaint with the President of the Polish Data Protection Authority (UODO): www.uodo.gov.pl 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 process special-category data and ask users not to provide such information (e.g., health data, political opinions, racial origin, etc.).

10. Security

Although the Internet can never be entirely secure, we take numerous measures to protect your personal data, including:

  • notifying affected individuals when required by law.
  • encryption, firewalls, antivirus software,
  • ongoing IT monitoring and security procedures,
  • procedures for handling personal data breaches,

11. Why do we use video monitoring at our headquarters

Our premises are monitored (indoors and outdoors) to protect property, ensure safety, and protect information. Monitoring is used in accordance with legal regulations.

Recordings are retained for up to 3 months unless they serve as evidence in legal proceedings.

Access to footage is limited and may be restricted to protect the rights and freedoms of other individuals captured by the cameras.

12. Cookie mechanism. Links to other sites

Some areas and functions of the website use cookies—text files stored on your device to enable certain features (e.g., login functionality).

Details are available 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.

Have more questions?

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