Privacy policy

The following Privacy Policy sets out the rules for storing and accessing data on the Devices of Users using the Website for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users' personal data, which has been provided by them personally and voluntarily through the tools available on the Website.

§1 Definitions

  1. Website - the website operating at https://monikagrabowska.com

  2. External Website - websites of partners, service providers or service recipients cooperating with the Administrator

  3. Website/Data Administrator - The Website Administrator and Data Administrator (hereinafter the Administrator) is the company "Monika Grabowska", operating at: Gurteen Kilsheelan Clonmel Tipperary E91NP78 Ireland, providing services electronically via the Website

  4. User - a natural person for whom the Administrator provides services electronically via the Website.

  5. Device - an electronic device with software through which the User accesses the Website

  6. Cookies - text data collected in the form of files placed on the User's Device

  7. 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)

  8. 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

  9. Processing - means any operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organising, structuring, storage, adapting or altering, retrieving, consulting, using, disclosing by transmission, dissemination or otherwise making available, aligning or combining, restricting, erasing or destroying;

  10. Restriction of processing - means marking stored personal data with the aim of limiting its future processing

  11. 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

  12. Consent - the 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

  13. 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

  14. 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

  15. Anonymisation - Data anonymisation is an irreversible process of operations on data that destroys/overwrites “personal data”, making it impossible to identify or link a given record to a specific user or natural person.

§2 Data Protection Officer

  1. Pursuant to Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

  2. In matters relating to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

  1. Internal cookies - files placed on and read from the User's Device by the Website's ICT system

  2. External cookies - files placed on and read from the User's Device by the ICT systems of external websites. Scripts of external websites that may place cookies on the User's Devices have been deliberately placed on the Website through scripts and services made available and installed on the Website

  3. Session cookies - files placed on and read from the User's Device by the Website during a single session of a given Device. After the session ends, the files are deleted from the User's Device.

  4. Persistent cookies - files placed on and read from the User's Device by the Website until they are manually deleted. The files are not automatically deleted after the Device session ends unless the User's Device is configured to delete cookies after the Device session ends.

§4 Data storage security

  1. Cookie storage and reading mechanisms - The mechanisms for storing, reading and exchanging data between Cookies saved on the User's Device and the Website are implemented through built-in web browser mechanisms and do not allow 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 and other worms to the User's Device is also practically impossible.

  2. Internal cookies - the cookies used 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.

  3. External cookies - The Administrator takes all possible measures to verify and select website partners in the context of User security. The Administrator selects well-known, large partners with global public trust for cooperation. However, it does not have full control over the content of cookies from external partners. To the extent permitted by law, the Administrator is not responsible for the security of such cookies, their content or their use in accordance with the licence by scripts installed on the Website originating from external websites. The list of partners is provided later in this Privacy Policy.

  4. Cookie control

  1. The User may, at any time, independently change the settings for saving, deleting and accessing data stored in cookies by this website using the built-in cookie management module.

  2. At the same time, the User can use global cookie disabling in the most popular browsers:

  1. The User may delete all cookies saved to date at any time using the tools of the User's Device through which the User uses the Website's services.

  1. Threats on the User's side - The Administrator uses all possible technical measures to ensure the security of data stored in cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User's actions. The Administrator is not responsible for the interception of this data, impersonation of the User's session or its deletion as a result of conscious or unconscious activity of the User, viruses, Trojan horses and other spyware that may infect or have infected the User's Device. To protect themselves against these threats, Users should follow recommendations for safe use of the network.

  2. Storage of personal data - The Administrator ensures that it makes every effort to ensure that the personal data voluntarily entered by Users is secure, that access to it is restricted and carried out in accordance with its intended purpose and processing objectives. The Administrator also ensures that it makes every effort to protect the data it holds against loss by applying appropriate physical and organisational safeguards.

§5 Purposes for which cookies are used

  1. Improving and facilitating access to the Website

  2. Personalising the Website for Users

  3. Marketing, remarketing on external websites

  4. Keeping statistics (users, number of visits, types of devices, connection, etc.)

  5. Providing multimedia services

  6. Provision of social services

§6 Purposes of personal data processing

  1. Personal data voluntarily provided by Users is processed for one of the following purposes:

  1. Provision of electronic services:

  • Newsletter services (including sending advertising content with consent)

  • Services for sharing information about content posted on the Website on social media or other websites.

  1. Communication between the Administrator and Users on matters related to the Website and data protection

  2. Ensuring the Administrator's legitimate interest

  1. User data collected anonymously and automatically is processed for one of the following purposes:

  1. Keeping statistics

  2. Remarketing

  3. Ensuring the legitimate interests of the Administrator

§7 Cookies of external websites

  1. The Administrator uses JavaScript scripts and web components from partners who may place their own cookies on the User's Device. Please note that in your browser settings you can decide which cookies may be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

  1. Multimedia services:

  1. Social / integrated services:
    (Registration, Login, content sharing, communication, etc.)

  1. Newsletter services:

  1. Statistics:

  1. Other services:

  1. 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 cookies at any time.

§8 Types of data collected

  1. The Website collects data about Users. Some data is collected automatically and anonymously, and some data is personal data provided voluntarily by Users when signing up for individual services offered by the Website.

  1. Anonymous data collected automatically:

  • IP address

  • Browser type

  • Screen resolution

  • Approximate location

  • Subpages of the Website opened

  • Time spent on a particular subpage of the Website

  • Type of operating system

  • Address of the previous subpage

  • Address of the referring page

  • Browser language

  • Internet connection speed

  • Internet service provider

  1. Data collected during registration:

  • First name / surname / nickname

  • E-mail address

  • Telephone number

  • IP address (collected automatically)

  • Tax identification number (NIP)

  • National Court Register number (KRS)

  • Statistical identification number (REGON)

  1. Data collected when subscribing to the Newsletter service

  • First name / surname / nickname

  • Email address

  • IP address (collected automatically)

  1. 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

  1. As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided is not transferred or resold to third parties.

  2. 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 to operate the website, i.e.:

  1. Hosting companies providing hosting or related services to the Administrator

  2. Companies through which the Newsletter service is provided

  3. Service and IT support companies performing maintenance or responsible for maintaining the IT infrastructure

  4. Companies responsible for the Administrator's accounting (in the case of using the Administrator's paid Services)

  5. Companies responsible for delivering physical products to the User (postal / courier services in the event of a need to send written information)

  1. Entrusting the processing of personal data:

  1. Newsletter - In order to provide the Newsletter service, the Administrator uses the services of a third party - the GetResponse service. The data entered in the newsletter subscription form is transferred, stored and processed on the external website of this service provider.
    Please be advised that the indicated partner may modify the indicated privacy policy without the consent of the Administrator.

  2. Hosting, VPS or Dedicated Server Services - In order to operate the website, the Administrator uses the services of an external hosting, VPS or Dedicated Server provider - ALFA BRAVO Sp. z o.o. All data collected and processed on the Website is stored and processed in the service provider's infrastructure located within the European Union. It is possible to access the data as a result of maintenance work carried out by the service provider's staff. Access to this data is regulated by an agreement between the Administrator and the Service Provider.

  3. Website maintenance services - The Administrator uses the services of an external service provider to maintain the website - ALFA BRAVO Sp. z o.o. . The staff of the indicated entity has access to data entered by users during registration and editing of user accounts and/or data related to the Newsletter service. Access to this data is regulated by an agreement concluded between the Administrator and the Service Provider.

  1. Transfer of personal data:

  1. Accounting Services - In the event of a transaction, some of the personal data of natural persons or data of natural persons conducting business activity is transferred to the entity providing accounting services to the Administrator. The transfer of this data is regulated by the Act and the agreement concluded between the Administrator and the Service Provider.

  2. Courier Services - In the event of a transaction that requires the transfer of the item to which the transaction relates by post or courier, some of the personal data of natural persons or data of natural persons conducting business activity is transferred to the entity providing postal / courier services to the Administrator, selected by the User. The transfer of this data is governed by an agreement between the Administrator and the Service Provider.

§10 Method of processing personal data

  1. Personal data provided voluntarily by Users:

  1. Personal data will not be transferred outside the European Union, unless it has been published as a result of an individual action by the User (e.g. entering a comment or post), which will make the data available to anyone visiting the website.

  2. Personal data will not be used for automated decision-making (profiling).

  3. Personal data will not be resold to third parties.

  1. Anonymous data (without personal data) collected automatically:

  1. Anonymous data (without personal data) will be transferred outside the European Union.

  2. Anonymous data (without personal data) will not be used for automated decision-making (profiling).

  3. Anonymous data (without personal data) will not be resold to third parties.

§11 Legal basis for the processing of personal data

  1. The Website collects and processes User data on the basis of:

  1. 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 specified 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

  1. Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)

  2. Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171 item 1800)

  3. Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No. 24, item 83)

§12 Period of personal data processing

  1. Personal data provided voluntarily by Users:
    As a rule, the personal data provided is stored only for the period of providing the Service within the Website by the Administrator. It is deleted or anonymised within 30 days of the end of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter, etc.).
    An exception is a situation that requires the protection of legitimate purposes for further processing of such data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User's request for its deletion, for no longer than 3 years in the event of a violation or suspected violation of the Website's terms and conditions by the User

  2. Anonymous data (without personal data) collected automatically:
    Anonymous statistical data, which does not constitute personal data, is stored by the Administrator for the purpose of maintaining Website statistics for an indefinite period of time

§13 Users' rights related to the processing of personal data

  1. The Website collects and processes User data on the basis of:

  1. Right of access to personal data - Users have the right to access their personal data, exercised upon request submitted to the Administrator

  2. Right to rectify personal data - Users have the right to request the Administrator to immediately rectify personal data that is incorrect and/or to complete incomplete personal data, upon request submitted to the Administrator

  3. Right to erasure of personal data - Users have the right to request the Administrator to immediately erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, the deletion of data consists in anonymising data that enables identification of the User. The Administrator reserves the right to suspend the execution of a request to delete data in order to protect the Administrator's legitimate interests (e.g. when the User has violated the Terms and Conditions or the data has been obtained as a result of correspondence).
    In the case of the Newsletter service, the User has the option to delete their personal data themselves using the link provided in each e-mail message.

  4. Right to restrict the processing of personal data - Users have the right to restrict the processing of personal data in the cases specified in Article 18 of the GDPR, including questioning the accuracy of personal data, exercised upon request submitted to the Administrator

  5. Right to data portability - Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used, machine-readable format, upon request submitted to the Administrator

  6. Right to object to the processing of personal data - Users have the right to object to the processing of their personal data in the cases specified in Article 21 of the GDPR, exercised upon request submitted to the Administrator

  7. Right to lodge a complaint - Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.

§14 Contact details of the Administrator

  1. The Administrator can be contacted in one of the following ways

  1. Postal address - Monika Grabowska, Gurteen Kilsheelan Clonmel Tipperary E91NP78 Ireland

  2. Email address - [email protected]

  3. Telephone number - +353 863590470

  4. Contact form - available at: https://monikagrabowska.com/contact-me

§15 Website requirements

  1. Restricting the storage of and access to cookies on the User's Device may cause some of the Website's functions to malfunction.

  2. The Administrator shall not be liable for any malfunctioning of the Website's functions if the User restricts in any way the ability to save and read cookies.

§16 External links

  1. The Website — articles, posts, entries or comments by Users — may contain links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated therein may be dangerous for your Device or pose a threat to the security of your data. The Administrator shall not be liable for content outside the Website.

§17 Changes to the Privacy Policy

  1. The Administrator reserves the right to change this Privacy Policy at any time without informing Users in respect of the use of anonymous data or the use of cookies.

  2. The Administrator reserves the right to change this Privacy Policy regarding the processing of Personal Data, of which it will inform Users who have user accounts or are subscribed to the Newsletter service by email within 7 days of the change. Continued use of the services means that you have read and accepted the changes to the Privacy Policy. If you do not agree with the changes, you are required to delete your account from the Website or unsubscribe from the Newsletter service.

  3. Changes to the Privacy Policy will be published on this subpage of the Website.

  4. The changes shall come into force upon their publication.