Table of Contents
- Categories of Personal Data We May Process
- Other Information
- Sensitive Personal Data
- Children
- How We Collect Information
- Purposes of Processing
- Legal Bases for Processing
- Disclosure to Third Parties
- International Data Transfers
- Data Security
- Data Accuracy, Minimisation and Retention
- Your Rights
- Contact Details
- Changes to This Privacy Policy
Before using this website, you should carefully read this Privacy Policy document. By using this website, you agree to this Privacy Policy; otherwise, you must immediately leave the website.
Effective as of 1 March 2021
This Policy explains how we may process your data. This Policy may be amended or updated from time to time, therefore please check it regularly for updates.
The company Primatech S.C., hereinafter referred to as Primatech S.C., its other affiliated entities and subsidiaries (hereinafter referred to as “Primatech S.C.”, the “Website”, “us”, “our” or “we”) own, operate or provide access to several interactive websites, mobile and connected applications and other interactive online features and services, including but not limited to emails, newsletters, chat areas, forums, communities, sweepstakes and contests (hereinafter referred to as the “Services”).
This Privacy Policy applies to all information about you collected by Primatech S.C. through and in connection with the Services, regardless of how such information is collected or stored, and describes, among other things, the types of information collected about you when you interact with the Services, how your information may be used, when your information may be disclosed, how you may control the use and disclosure of your information, and how your information is protected.
Unless otherwise stated in this Privacy Policy, Primatech S.C. is the data controller (as that term is used under the EU General Data Protection Regulation “GDPR”), which means that we decide how and why the information you provide to us is processed. This Policy may be amended or updated to reflect changes in our information processing practices or changes in applicable law.
This Privacy Policy covers information collected through the following websites:
www.sinaloa-spa.pl and any other subdomain of sinaloa-spa.pl
We may process: your personal data (e.g. name and surname); demographic data (e.g. age); your contact details (e.g. address); records of your consents; purchase details; your employer’s data (where applicable); information about your interactions with our content or advertisements; and any views or opinions you provide to us.
We may also process information about you arising from your use of our Services (e.g. the type of device you use, your Internet service provider, etc.), including your interactions with content and advertisements within the Services.
“Personal Data” means any information relating to an identified or identifiable individual.
“Processing” means any operation or set of operations performed on Personal Data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
Categories of Personal Data We May Process
Personal Data: your name and surname; username or login details; password; areas or topics of interest; and photographs (if you or another user posts a photograph in the Service).
Demographic Information: gender; age/date of birth; nationality; salutation; job title; company information; education; professional experience and other professional information; and language preferences.
Contact Data: postal address; telephone and/or mobile number; email address; and your public social media handles or profiles.
Consent Records: records of all consents you have provided, together with the date and time, method of consent and related information (e.g. subject matter of consent).
Location Information: data describing the precise geographic location of a device (“Precise Location Data”).
Purchase and Payment Details: records of purchases and prices; invoice records; payment records; billing address; payment method; cardholder or account holder name; payment amount; and payment due date.
Employer Data: if you contact us as an employee, your employer’s contact details (including name, address, phone number and email address), as appropriate.
Views and Opinions: any views or opinions you or other users choose to submit to us or publicly post about us on social media platforms or within the Services, including forums.
Other Information
We also collect other types of information from you or other sources, referred to in this Policy as “Other Information”, which may include:
Usage data and aggregated statistical information
Browsing history, including websites visited before and after interacting with the Services
Searches and interactions with e-commerce features
Approximate location information derived from IP addresses (“GeoIP Data”)
Device identifiers
Advertising identifiers (e.g. IDFA, Google Advertising ID)
Internet Protocol (IP) address
Internet connection details (ISP, mobile carrier, Wi-Fi, SSID, IMSI, IMEI)
Information collected through cookies, pixels, JavaScript, tags and similar technologies (“Online Data”)
Device type, settings and software
Log files and clickstream data
Web beacons and pixel tags
Local shared objects (e.g. Flash cookies, HTML5 storage)
Mobile analytics data
In certain circumstances, some of this Other Information may constitute Personal Data. Personal Data together with Other Information are referred to as “User Information”.
Sensitive Personal Data
We do not seek to collect or otherwise process your sensitive personal data. Where processing of sensitive personal data is necessary for a legitimate purpose, it is carried out in accordance with applicable law.
We do not process data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health data, sex life, criminal convictions or offences, or any other data considered sensitive under GDPR (“Sensitive Personal Data”), unless required by law and based on one of the following legal grounds:
Compliance with law
Crime detection and prevention
Establishment, exercise or defence of legal claims
Explicit consent
Children
The Services are not intended for children, particularly those under the age of 13. No person under 13 should provide any personal data or use public discussion areas. Persons under 18 may not make purchases through the Services. If we become aware that we have collected personal data from a child under 13, we will delete such information immediately.
How We Collect Information
We may collect User Information directly from you, through your use of the Services, from public sources, from third parties (e.g. social media platforms), or create it through your interactions with us. Primatech S.C. is not responsible for personal data you voluntarily disclose in public areas of the Services.
Purposes of Processing
We may process User Information for purposes including:
Providing and improving Services
Communication
Advertising and marketing
Audience engagement analysis
Lead generation
IT administration and security
Financial management
Surveys and research
Legal compliance
Protection of rights and safety
Legal Bases for Processing
We process Personal Data based on one or more of the following legal grounds:
Consent
Contractual necessity
Legal obligation
Vital interests
Legitimate interests
Disclosure to Third Parties
We may disclose User Information to:
Legal and regulatory authorities
Advisors and auditors
Service providers and processors
Business partners and affiliates
Advertisers and analytics providers
Event sponsors
Potential acquirers
All disclosures are made in accordance with applicable law and subject to appropriate safeguards.
International Data Transfers
We may transfer Personal Data outside the EEA using appropriate safeguards, including Standard Contractual Clauses. Primatech S.C. participates in Privacy Shield–related frameworks where applicable and complies with GDPR requirements.
Data Security
We implement appropriate technical and organisational measures to protect User Information. However, no internet transmission is completely secure and data is transmitted at your own risk.
Data Accuracy, Minimisation and Retention
We take reasonable steps to ensure data accuracy, limit processing to what is necessary, and retain data only as long as required for the purposes described. Online Data related to behavioural advertising is retained for no more than 180 days.
Your Rights
Depending on your jurisdiction (especially within the EU), you may have rights including access, rectification, erasure, restriction, objection, data portability and withdrawal of consent. Requests can be made via our DSAR portal.
Contact Details
Primatech S.C.
ul. Górna 2A
42-262 Kolonia Poczesna
POLAND
Phone: +48 786 101 105
Email (Data Protection Officer): info@sinaloa-spa.pl
If you have unresolved concerns, you may contact the EU Online Dispute Resolution platform at:
http://ec.europa.eu/consumers/odr/
Changes to This Privacy Policy
We may update this Privacy Policy from time to time. All changes become effective upon publication.