Privacy Policy

This document governs the Privacy and Cookies Policy for the website, provided at https://esmart.com.pl/en/home/, owned by Smart Solution Sp. z o.o. ul. Międzyrzecka 6, 43-225 Wola.

§1 Administrator of personal data

1.1 The administrator of your personal data is Smart Solution Sp. z o.o. ul. Międzyrzecka 6, 43-225 Wola, NIP: 6381809338
REGON: 243471027, (hereinafter referred to as the Administrator”).

1.2 Administrator’s contact information:

Mailing address: Ul. Międzyrzecka 6, 43-225 Wola

E-mail address: biuro@esmart.com.pl

Phone: +48 883 380 666

1.3 Pursuant to Article 37 of the RODO, the Data Controller has not appointed a Data Protection Officer (DPO) and performs data protection duties independently.

§2 Definitions

Administrator – Personal Data Controller, the entity that decides the purposes and means of processing personal data

Personal data – is information about natural persons, it concerns an identified or identifiable person directly or indirectly; personal data are, in particular, an identification number, factors identifying physical, physiological, mental, economic, cultural or social characteristics

RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC

Privacy and Cookies Policy – this document hereinafter referred to as the “Policy”

Service – the Internet service operated by the Administrator at https://esmart.com.pl/en/home/.

Service User – any natural person visiting the Service or using at least one service performed by the Administrator or a function of the Service

Cookies – “cookies” in Polish, are small pieces of information in the form of a text string placed or read by the Website in the Internet browser used by the User

JDG Entrepreneurs – natural persons conducting business on the basis of entry in the Central Register and Information on Business Activity

§3 General provisions

3.1 The Administrator collects data of the Users of the service located at https://esmart.com.pl/en/home/.

3.2 The type of data collected by the Administrator depends on the service offered by the Administrator, which is used by the User.

3.3 Personal data will be processed by the Administrator in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council 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, referred to as the General Data Protection Regulation, hereinafter referred to as “RODO”.

3.4 Provision of any personal data is voluntary and at the User’s discretion. However, in some cases, the provision of certain personal data is necessary to meet the User’s expectations in using the services offered by the Administrator.

3.5 The services offered by the Administrator within the Service are offered to persons who are at least 18 years of age. Accordingly, the Administrator does not knowingly process the personal data of children.

§4 Purpose, basis and duration of data processing

4.1 Contact form

4.1.1 Whose data are subject to processing?

Data of persons who contact via the contact form.

4.1.2 What data are subject to processing?

first and last name

e-mail address

4.1.3 What is the purpose of data processing?

To identify the contacting User and to answer the question asked.

4.1.4 What is the legal basis for data processing?

Legitimate interest – Article 6(1)(f) of the RODO.

4.1.5 What is the data storage period?

Until the expiration of the statute of limitations for claims.

4.1.6 Is it necessary to provide data?

Provision of data is voluntary, but necessary for verification of the User.

§5 Entrusting and sharing personal data

In connection with its operations, the Administrator may disclose personal data to the following entities if necessary for the purposes of processing:

Companies providing services or IT solutions,

Public authorities, receiving data in connection with the execution of the Administrator’s legal obligations,

Companies providing marketing activities,

Employees and associates.

§6 Entitlements of the Service User

6.1 In connection with the processing of personal data, the User has the related rights:

6.1.1 the right to access the content of his/her data – the User has the right to obtain information regarding the personal data stored by the Administrator about him/her, including a copy of such data.

6.1.2 right to rectify (amend) your data – You have the right to request rectification of your personal data that is incorrect or incomplete.

6.1.3 right to erasure – The User has the right to request the erasure of his/her personal data stored by the Administrator in the following cases: (a)the User’s personal data are no longer necessary for the purposes for which they were collected,(b)the User has withdrawn the consent on which the processing is based and there is no other legal basis for the processing,(c)the User has objected to the processing and there are no overriding legitimate grounds for the processing or the objection relates to the processing for direct marketing purposes,(d)the User’s personal data have been processed unlawfully,(e) the personal data must be erased in order to comply with a legal obligation under Union or national law.


6.1.4 The right to withdraw consent to the processing of personal data for marketing purposes at any time – You have the right to withdraw your consent to the processing of personal data at any time. The withdrawal of consent to processing will not affect the lawfulness of the processing that was performed before its withdrawal.
6.1.5 Right to restrict processing – The User has the right to request that the processing of his/her personal data be restricted in the following cases:(a) the User questions the correctness of the personal data, for a period of time allowing the Administrator to verify the correctness of the data,(b) the processing is unlawful and the User objects to the deletion of the personal data, requesting instead a restriction on its use,(c)the Administrator no longer needs the personal data for the purposes of processing, but they are necessary for the User to establish, assert or defend claims,(d)the User has raised an objection under Art. 21(1) RODO against the processing – until it is determined whether the legitimate grounds on the part of the Administrator override the grounds for the objection.
6.1.6 right to object to data processing (objection due to special situation) – if the User’s personal data is processed on the basis of the legitimate interest of the Administrator, the User has the right to object at any time to the processing, in accordance with Article 21 of the RODO.
6.1.7 right to data portability – The User has the right to receive in a structured, commonly used machine-readable format the personal data concerning him/her which he/she has provided to the Administrator, and has the right to send this personal data to another Administrator without hindrance from the Administrator to whom the personal data was provided, if the processing is based on consent and by automated means.
6.1.8 The right to lodge a complaint to the supervisory authority, i.e. the President of the Office for Personal Data Protection.
6.2 If you wish to exercise the rights listed in Section 6.1 of the Policy, please contact us at the Administrator’s contact information.

§7 Transfers of personal data to third countries

As a rule, your personal data will not be transferred outside the European Economic Area.

§8 Cookie Policy

8.1 Purpose of using cookies

8.1.1 The Administrator does not collect any information automatically, except for the information contained in cookies.

8.1.2 Cookies are used in a number of ways.

8.1.3 Cookies are used for functional, content personalization, statistical, analytical and marketing purposes.

8.2 Types of cookies:

8.2.1 The Site uses the following types of cookies:

“session cookies”, which are deleted from the computer’s hard drive when the session of a given browser ends or the computer or mobile device is turned off

“persistent cookies”, which are stored in the memory of the computer, or mobile device until they are manually deleted by the User through the appropriate tools in the web browser or expire

“third-party cookies”, are information placed by the scripts of other websites.

8.2.2 The Service uses the following types of cookies:
“indispensable”, enabling the use of services available within the Service,
“performance”, making it possible to collect information on how the Website is used,
“functional”, making it possible to “remember” the User’s selected settings and personalize the User’s interface, e.g. with regard to the selected language or region,
“advertising”, making it possible to provide Users with advertising content more tailored to their interests.
8.3 Management of cookies:
8.3.1 Most often, your browser settings will allow cookies and other information to be placed on your end device by default. If the User does not agree to the saving of these files, it is necessary to change the browser settings accordingly. It is possible to disable their storage for all connections from a particular browser or for a specific site, as well as to delete them. How you manage your files depends on the software you use. The current file management policy can be found in the settings of the web browser used.
8.3.2 For information on how to manage cookies on a cell phone, please refer to the User’s Guide of the particular phone.
8.3.3 Consent to the processing of cookies is voluntary. However, please note that restrictions on their use may hinder or prevent the use of some of the functionality of the website maintained at: [insert website address].
8.4 Google Analytics
The website uses Google Analytics, a web analytics service. Its provider is Google Inc., 1600 Amphitheatre Parkway Mountain View, CA 94043, USA. Google Analytics uses so-called “cookies”, text files that are stored on your computer and enable analysis of your use of the website.
Google Analytics cookies are saved on the basis of Article 6(1)(f) of the Regulation on the Protection of Personal Data (RODO). The Administrator has a legitimate interest in analyzing user behavior both to optimize its online offering and its advertising.
Google’s privacy policy, the User of the Website can read at: https://policies.google.com/privacy?hl=pl

If the Service User does not want his/her information to be collected in this way, he/she can, for example, change his/her browser settings.

The Administrator informs that in this case the Service User’s data is subject to transfer outside the European Economic Area.

§9 Data security

9.1 The User’s personal data is stored and protected with due diligence, in accordance with the Administrator’s implemented internal procedures. The Administrator processes information about the User using appropriate technical and organizational measures that meet the requirements of generally applicable laws, in particular the regulations on personal data protection. These measures are primarily aimed at securing the Users’ personal data from access by unauthorized persons.

9.2 In particular, access to Users’ personal data is allowed only to authorized persons who are obliged to keep such data confidential, or to entities entrusted with the processing of personal data under a separate data entrustment agreement.

§10 Final provisions

10.1 The Administrator reserves the right to change this Privacy and Cookies Policy. In such case, its updated version will be published in this location.

10.2 To the extent not governed by this Privacy Policy, the provisions of data protection regulations shall apply.

10.3 This Privacy Policy is effective as of 19.03.2024r.