The following Privacy Policy defines the rules for storing and accessing data on the devices of Users using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing personal data of Users provided by them personally and voluntarily through tools available on the Service. This Privacy Policy is an integral part of the Service Regulations, which define the rules, rights, and obligations of Users using the Service.
§1 Definitions
- Service – the website “loopus.pl” operating at https://loopus.pl/.
- External Service – websites of partners, service providers, or recipients cooperating with the Administrator.
- Service Administrator / Data Administrator – The administrator of the Service and the Data Administrator (hereinafter referred to as the Administrator) is the company “Loopus sp. z o.o.”, conducting business at the address: ul. Mangalia 4 lok.418, 02-758 Warsaw, with the assigned tax identification number (NIP): 7582382982, with the assigned National Court Register (KRS) number: 0000949249, providing electronic services through the Service.
- User – a natural person for whom the Administrator provides electronic services through the Service.
- Device – an electronic device with software through which the User accesses the Service.
- Cookies – text 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 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 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, organization, 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 analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
- Consent – consent of the data subject 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, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
- Pseudonymization – 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- Anonymization – Anonymization of data is an irreversible process of operations on data that destroys / overwrites “personal data,” preventing identification or linkage of a specific record to a particular user or individual.
§2 Data Protection Officer
Based on Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer. For matters concerning the processing of data, including personal data, please contact the Administrator directly.
§3 Types of Cookies
- Internal cookies – files placed and read from the User’s Device by the IT system of the Service.
- External cookies – files placed and read from the User’s Device by the IT systems of external Services. Scripts of external Services, which may place Cookies files on the User’s Device, have been intentionally placed on the Service through scripts and services provided and installed on the Service.
- Session cookies – files placed and read from the User’s Device by the Service during one session of that 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. The files are not automatically deleted after the end of the Device session unless the User’s Device configuration is set to delete cookie files after the end of the Device session.
§4 Data Storage Security
- Mechanisms of storing and reading Cookie files – Mechanisms of storing, reading, and exchanging data between Cookie Files saved on the User’s Device and the Service are implemented through built-in mechanisms of web browsers and do not allow for retrieving other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, trojans, and other worms to the User’s Device is also practically impossible.
- Internal Cookies – Cookies applied by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the Device used by the User.
- External Cookies – The Administrator takes all possible actions to verify and select service partners regarding the security of Users. The Administrator selects well-known, large partners with global social trust for cooperation. However, the Administrator does not have complete control over the content of Cookie files from external partners. The Administrator does not bear responsibility for the security of Cookie files, their content, and their use in accordance with the license by the scripts installed on the Service from external Services to the extent permitted by law. The list of partners is included further in the Privacy Policy.
- Cookie Control
- The User can at any time independently change settings regarding the storage, deletion, and access to data saved in Cookie files by any website.
- Information on how to disable Cookie files in the most popular computer browsers is available on the website: how to disable cookies or from one of the indicated providers:
§ Managing cookie files in Chrome browser
§ Managing cookie files in Opera browser
§ Managing cookie files in Firefox browser
§ Managing cookie files in Edge browser
§ Managing cookie files in Safari browser
§ Managing cookie files in Internet Explorer 11 browser
The User can delete all Cookie files saved so far at any time using the tools of the User’s Device through which the User uses the services of the Service.
- User-Side Threats – The Administrator employs all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both sides, including the User’s activities. The Administrator is not responsible for the interception of this data, the impersonation of the User’s session, or their deletion, as a result of conscious or unconscious actions of the User, viruses, trojans, and other spyware with which the User’s Device may be or has been infected. To protect against these threats, Users should follow internet usage recommendations.
- Personal Data Storage – The Administrator ensures that all efforts are made to ensure that voluntarily provided personal data by Users are safe, access to them is limited, and processing is carried out in accordance with their purpose and processing objectives. The Administrator also ensures that all efforts are made to secure the data held against loss, through the application of appropriate physical and organizational security measures.
- Password Storage – The Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this area. Decryption of passwords provided in the Service for accountaccess is practically impossible.
§5 Purposes for which Cookie Files are Used
- Improving and facilitating access to the Service;
- Personalizing the Service for Users;
- Enabling login to the Service;
- Marketing, remarketing on external services;
- Ad serving services;
- Affiliate services;
- Conducting statistics (users, number of visits, types of devices, bandwidth, etc.);
- Providing multimedia services;
- Providing social 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:
- User account registration and maintenance services in the Service and related functionalities.
- Newsletter services (including sending advertising content with consent).
- Commenting / liking posts in the Service without the need for registration.
- Sharing information about content placed in the Service on social media or other websites.
- Communication of the Administrator with Users regarding matters related to the Service and data protection.
- Ensuring the Administrator’s legitimate interest.
Anonymously and automatically collected data about Users are processed for one of the following purposes:
- Conducting statistics;
- Remarketing;
- Serving ads tailored to Users’ preferences;
- Affiliate program support;
- Ensuring the Administrator’s legitimate interest.
§7 External Services Cookie Files
The Administrator in the Service uses javascript scripts and web components of partners who may place their own cookie files on the User’s Device. Remember that in your browser settings, you can decide which cookie files are allowed to be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookie files:
- Multimedia services:
- Social services / connections:
(Registration, login, content sharing, communication, etc.) - Newsletter services:
- Ad serving services and affiliate networks:
- Conducting statistics:
- Other services:
Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, privacy policies, purposes of data processing, and methods of using cookie files at any time.
§8 Types of Data Collected
The Service collects data about Users. Some data is collected automatically and anonymously, while some data are personal data voluntarily provided by Users during registration for specific services offered by the Service.
Automatically collected anonymous data:
- IP address;
- Browser type;
- Screen resolution;
- Approximate location;
- Visited subpages of the service;
- Time spent on specific subpages of the service;
- Operating system type;
- Previous page address;
- Referring page address;
- Browser language;
- Internet connection speed;
- Internet service provider.
Data collected during registration:
- First name / last name / pseudonym;
- Username;
- Email address;
- IP address (collected automatically).
Data collected during Newsletter subscription:
- First name / last name / pseudonym;
- Email address;
- IP address (collected automatically).
Data collected during comment submission:
- First name and last name / pseudonym;
- Email address;
- Website address;
- IP address (collected automatically).
Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to a statistical service provider.
§9 Access to Personal Data by Third Parties
As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or sold to third parties.
Entities responsible for maintaining the infrastructure and services necessary for operating the service may have access to data (usually based on a Data Processing Agreement), including:
- Hosting companies providing hosting services or related services for the Administrator.
- Companies through which the Newsletter service is provided.
- Service and IT support companies performing maintenance or responsible for maintaining IT infrastructure.
Data Processing Agreement – Newsletter
In order to provide the Newsletter service, the Administrator uses the services of a third party – MailChimp service. Data entered in the newsletter subscription form is transferred, stored, and processed on the external service of this provider.
Please note that the mentioned partner may modify the indicated privacy policy without the Administrator’s consent.
Data Processing Agreement – Hosting Services, VPS, or Dedicated Servers
In order to operate the service, the Administrator uses the services of an external hosting provider, VPS, or Dedicated Servers – Zenbox sp. z o.o.. Personnel of the specified entity have access to data entered by users during registration and account editing and/or data related to the Newsletter service. Access to this data is regulated by an agreement between the Administrator and the Service Provider.
§10 Method of Processing Personal Data
Personal data voluntarily provided by Users:
- Personal data will not be transferred outside the European Union unless published due to individual User action (e.g., commenting or posting), making the data available to anyone visiting the service.
- Personal data will not be used for automated decision-making (profiling).
- Personal data will not be sold to third parties.
Automatically collected anonymous data (without personal data):
- Automatically collected anonymous data (without personal data) may be transferred outside the European Union.
- Automatically collected anonymous data (without personal data) will not be used for automated decision-making (profiling).
- Automatically collected anonymous data (without personal data) will not be sold to third parties.
§11 Legal Basis for Processing Personal Data
The Service collects and processes user data based on:
- 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 their 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)(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 of 2018, item 1000).
- Act of 16 July 2004 Telecommunications Law (Journal of Laws of 2004, No. 171, item 1800).
- Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws of 1994, No. 24, item 83).
§12 Period of Processing Personal Data
Personal data voluntarily provided by Users:
As a rule, the indicated personal data are stored only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized within 30 days from the end of service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter list, etc.).
An exception is a situation that requires securing the legitimate purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data until the User requests their deletion, no longer than for a period of 3 years in the event of a breach or suspicion of a breach of the provisions of the service regulations by the User.
Anonymously collected data (without personal data):
Anonymous statistical data, not constituting personal data, are stored by the Administrator for an indefinite period for the purpose of maintaining service statistics.
§13 User Rights Related to Personal Data Processing
The Service collects and processes user 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 Administrator.
• Right to rectify personal data
Users have the right to request the Administrator to promptly correct personal data that are inaccurate or incomplete, exercised upon request submitted to the Administrator.
• Right to erasure of personal data
Users have the right to request the Administrator to promptly erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, data deletion involves anonymizing data that allow identification of the User. The Administrator reserves the right to suspend the implementation of the data deletion request in order to protect the legitimate interests of the Administrator (e.g., if the User has breached the Service Regulations or the data were obtained as a result of ongoing correspondence). In the case of the Newsletter service, the User has the option to independently delete their personal data using the link provided in each email message.
• Right to restrict processing of personal data
Users have the right to restrict processing of personal data in cases specified in Article 18 of the GDPR, including questioning the accuracy of personal data, exercised upon request submitted to the Administrator.
• Right to data portability
Users have the right to receive from the Administrator personal data concerning them in a structured, commonly used, and machine-readable format, exercised upon request submitted to the Administrator.
• Right to object to processing of personal data
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 Administrator.
• Right to lodge a complaint
Users have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data.
§14 Administrator Contact
The Administrator can be contacted in one of the following ways:
- Postal address – Loopus sp. z o.o., ul. Mangalia 4 lok.418, 02-758 Warsaw
- Email address – gerard.kostera@loopus.pl
- Phone call – +48 536 130 078
- Contact form – available at: https://loopus.pl/kontakt/
§15 Service Requirements
- Limiting the storage and access to Cookie files on the User’s Device may result in the improper functioning of some Service features.
- The Administrator bears no responsibility for the malfunction of Service features if the User restricts the ability to save and read Cookie files in any way.
§16 External Links
In the Service – articles, posts, entries, or user comments may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated beneath them may be dangerous for your Device or pose a threat to the security of your data. The Administrator bears no responsibility for content located outside the Service.
§17 Changes to the Privacy Policy
- The Administrator reserves the right to change this Privacy Policy at any time without the need to inform Users regarding the application and use of anonymous data or the use of Cookie files.
- The Administrator reserves the right to change this Privacy Policy regarding the processing of Personal Data, which will be communicated to Users with user accounts or subscribed to the newsletter service, via email within 7 days of the change. Further use of the services signifies acceptance and acknowledgment of the introduced changes to the Privacy Policy. In the event that the User disagrees with the changes made, they are obliged to delete their account from the Service or unsubscribe from the newsletter service.
- The introduced changes to the Privacy Policy will be published on this subpage of the Service.
- The introduced changes come into effect upon their publication.