Privacy Policy www.REMOtrade.com

§1. Introduction

The administrator of personal data collected in accordance with this Policy is REMOtrade limited liability company with registered office in Poland in Gdańsk (80-219) at al. Zwycięstwa 13 a with Tax ID: 9571162864, registered in the District Court Gdańsk-Północ in Gdańsk, VII Commercial Division of the National Court Register under KRS number: 0001056167. Contact details: e-mail: rodo@REMOtrade.com

§2. Definitions

For the purpose of this Policy the following definitions apply:

Administrator / REMO – means REMOtrade limited liability company with registered office in Poland in Gdańsk (80-219) at al. Zwycięstwa 13 a with Tax ID: 9571162864, registered in the District Court Gdańsk-Północ in Gdańsk, VII Commercial Division of the National Court Register under KRS number: 0001056167.
Personal data – means information about an identified or identifiable natural person. An identifiable natural person is a person who can be directly or indirectly identified, in particular on the basis of an identifier such as name, identification number, location data, internet identifier or one or more specific factors determining physical, physiological, genetic, psychological, economic, cultural or social identity of a natural person.
Personal Data Processing – means an operation or set of operations performed on Personal Data or Personal Data Sets in an automated or non-automated manner, such as collecting, recording, organizing, ordering, storing, adapting or modifying, downloading, browsing, using, disclosing by sending, distribution or other type of sharing, matching or combining, limiting, deleting or destroying.
Regulation or GDPR – means 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).
Website – means Internet service run by REMO at: REMOtrade.com
User, Users – means any person who uses the services offered by the Website.

§3. The scope of Personal data collection

REMO makes every effort to ensure that Personal Data is processed in accordance with applicable law and that it is protected against loss, destruction, disclosure, unauthorized access or improper use. REMO guarantees the confidentiality of all data provided to it by taking effective security measures and protecting Personal Data.

§4. The purpose of Personal data processing

Each time, the purpose, scope and recipients of Personal Data processed by REMO arise from the consent of the User or the regulations of law and are further specified as a result of actions taken by the Website or within other channels of communication with the User.
Possible purposes of collecting and processing Users’ Personal Data by REMO:
1. Providing services electronically in the scope of providing Users with content published on the Website:
  1. The legal basis for data processing is Article 6 par. 1 letter b GDPR (necessity to perform the contract for the provision of electronic services).
2. Security of claims:
  1. In order to determine, settle and enforce claims, REMO may process some of the Personal Data provided by the User, in particular the name and surname, contact details (e-mail address, telephone number), data concerning the use of Website’s services and other data that shall be necessary to prove the existence of the claim, its execution and defense against claims in proceedings before courts and other state authorities.
  2. The legal basis for data processing is Article 6 par. 1 letter f GDPR, ie the legitimate interest of REMO. Data in this respect are processed for the statutory limitation period of claims.
  3. However, data processing shall only include their storage, with the exclusion of any other operations on these data, subject to different duties of REMO indicated in the applicable regulations or imposed on REMO by the authorized bodies.
3. Creating statistics on the use of the Website’s and profiling:
  1. REMO monitors the quality of services it provides to fulfill the expectations of the Users. For this purpose, statistics of the use of particular functions and subpages of the Website are carried out by the use of internal analytical tools, as well as statistical tools provided by partners providing analytical services.
  2. The User of the Website can agree to processing their personal data for advertising purposes, market research and research on the behaviour and preference of the Users. The results of the research will be used in order to improve the quality of the services provided by the Website. The lack of agreement has no influence on the rights and obligations of the user.
  3. In order to accomplish this goal, data about User’s activity on the Website are processed (e.g. websites and subpages of the Website visited by the User, the amount of time spent on the website, the User’s IP address, location, device ID and data about the browser and operating system used by the User).
  4. The Administrator, for the purpose of developing the services offered, may, in some cases, utilize profiling. Profiling involves an automated data processing process that utilizes User data to assess selected factors characteristic of the User for the purpose of analyzing their behavior or creating forecasts for the future. Through this, the Administrator can better tailor the services offered to the individual preferences and interests of the User.
  5. Thanks to this technology, the Administrator can not only present the User with personalized advertisements but also primarily showcase offers that best meet the User’s needs among the available options. The information collected and stored in cookies may persist beyond the browser session, allowing, for example, their use during the User’s subsequent visits.
  6. The legal basis for data processing is Article 6 par. 1 letter a GDPR, meaning the User’s consent.
4. Marketing:
  1. The Controller processes Users’ Personal Data in order to carry out marketing activities, which may include:
    - displaying to the Users marketing content corresponding to their interests (behavioral advertising);
    - conducting other types of analytical and statistical activities as well as activities related to direct marketing of services (sending commercial information electronically).
  2. Such actions are undertaken by the Administrator only when the User has given prior consent. The User can withdraw the granted consent at any time.
5. Communication:
  1. The Administrator may communicate with the User by means of system information, notifications, e-mail, messages in social media channels, chat tools on the Website, by phone or conventionally via letters.
  2. The User may, at any time, contact the Administrator directly by sending a relevant message in writing, by e-mail to the Administrator’s address indicated at the beginning of the Policy, by telephone at the telephone number indicated at the beginning of the Policy and via chat tools on the
  3. The Administrator shall store the correspondence with the User for statistical purposes and for the best and quickest response to appearing inquiries, as well as in the scope of complaint settlements and possible decisions on administrative interventions in the indicated account. The addresses and data collected in this manner shall not be used for communication with the User for purposes other than execution of the order.
  4. When the User contacts the Administrator in order to perform certain actions (eg submit a complaint), the Administrator may ask the User again to provide data, including personal data, e.g. in the form of name, surname, e-mail address, etc., to confirm the identity of the User and allow return contact in a given case. The above applies to the same data, including personal data, which were previously provided by the User, and on which processing the User consented. Providing this data is not mandatory but may be necessary to perform actions or obtain information that shall interest the User.

§5. Cookies

The Controller declares that they process the data regarding the connection of the User’s end devices with the technical infrastructure of the Website and use “Cookies”. This data is aggregate and anonymous – it does not contain features that identify specific natural persons.
Cookies are IT data, in particular text files sent by REMO to Users’ end devices and stored there. Cookies can only be read by REMO.
During the User’s visit to the Website, data regarding the visit may be automatically collected, in the form of the domain name of the website from which the User was redirected to the Website, browser type, operating system type, IP address, User ID, other information transmitted via the http protocol. In addition, REMO may process operational data or information about the location of the device with which the Website is accessed.
Cookies allow REMO, among others, to ensure the proper functioning of the Website, improve the speed and security of using the Website pages, improve the functions used by the User and use marketing tools.
Please be informed that restricting the use of cookies may affect some of the functionalities available on the Website or prevent the use of the Website.
REMO declares that the use of cookies by REMO does not change the configuration of Users’ end devices or the software installed on their devices.
The Controller uses necessary, performance, personalization, functionality and advertising Cookies.
The Controller uses the necessary Cookies mainly to provide Website Users with services and functionalities that they want to use. Necessary Cookies may be installed via the Website by the Controller. These cookies are necessary for the Website to function and cannot be turned off. They are usually set only in response to actions taken by the User and boil down to asking for services, such as setting privacy preferences, logging in or filling out forms. They also include the basic (not user-specific) visit count, which is needed for the provision of services by REMO. You can set your browser to block or warn you about these cookies, but some parts of the site will then not work. These Cookies do not store any personal data of the User. The legal basis for data processing in connection with the use of necessary Cookies is the necessity to perform the Contract (Art. 6(1)(a) of GDPR).
The Controller uses functional Cookies to remember and adapt the Website to the User’s choices. These Cookies enable greater functionality and personalization of the services provided. They can be set up by REMO or by external suppliers whose services have been added to our websites. An example of such increased functionality is the chat available on the Website. If the User does not allow the use of these Cookies, some or all of these services may not function properly. The processing of data related to the use of functional Cookies requires the User’s consent. Such consent may be withdrawn at any time in the Website settings.
The Controller uses performance and personalization Cookies to obtain information on the number of visits and traffic sources on the Website. These files are processed in order to improve the performance of the Website, to develop, test and improve the services provided, and to test new products and functionalities, as well as to solve related problems. These files are aggregated and are not intended to determine the User’s identity. They help to determine which pages of the Website are the most and least popular. They also help to define the User’s behavior in order to provide them with relevant and personalized content. Such files may be installed through the Website by the Controller and by its partners. The legal basis for data processing in connection with the use of analytical Cookies is the legitimate interest of the Controller (Art. 6(1)(a) of GDPR) consisting in ensuring the highest quality of services provided through the Website.
The Controller also uses advertising Cookies, which allow them to adjust the displayed content to the User’s interests through the Website. These files can be used to build a profile of the User’s interests and display relevant advertisements on other websites. They do not directly store personal data, but rely on the unique identification of the User’s browser and internet hardware. If the User does not allow the use of these Cookies, they experience less targeted advertising. Such files may be installed through the Website by the Controller and by its trusted partners. The legal basis for data processing in connection with the use of advertising Cookies is consent (Art. 6(1)(a) of GDPR). Such consent may be withdrawn at any time in the Website settings.
The Controller also processes the personal data of Users visiting profiles run in social media (Facebook, YouTube, Instagram, LinkedIn). This data is processed only in connection with maintaining a profile: to inform Users about the activity of REMO and to promote various types of events, services and products. The legal basis for the processing of personal data by the Controller is the consent of the User (Art. 6(1) (a) of GDPR)).
The User may consent to the use of Cookies in Cookie Settings. By using the “Accept All” or “Customize” buttons, the User may grant appropriate consents and manage their preferences.
The User may withdraw the consent granted at any time.

§6. Possible recipients of Users’ Personal Data

For the purpose of providing services and ongoing support, User data may be transferred for processing to specialized entities. The data may be shared in particular with:
1. IT service providers,
2. marketing agencies, marketing partners and suppliers of marketing platforms,
3. cloud service providers,
4. service providers in the scope of data analysis,
5. consultants, lawyers, accountants and other professional service providers,
6. entities associated with the Administrator personally and by capital, which help him to provide our services or perform data processing tasks on our behalf
  – where such entities process data on the basis of the contract concluded with the Administrator and only in accordance with his instructions.
The Administrator also makes Users’ data available to authorized state authorities, if they turn to the Administrator in connection with the tasks they perform. These may include, in particular, organizational units of the prosecutor’s office, the Police, the President of the Office for Personal Data Protection, the President of the Office of Competition and Consumer Protection or the President of the Office of Electronic Communications.

§7. Transmission of data to third countries (outside the European Economic Area)

When the Controller uses tools supporting their ongoing business, personal data, if necessary and with an adequate level of protection, may be transferred outside the European Economic Area (EEA). If such a situation occurs, the Personal Data will be transferred only to those recipients who guarantee the highest data protection and security by means of, among others,
1. use of standard contractual clauses issued by the European Commission,
2. application of binding corporate rules approved by the competent supervisory authority,
3. cooperation with entities processing personal data in countries for which an appropriate decision of the European Commission has been issued regarding the assurance of an adequate level of protection of Personal Data.
The Controller’s Trusted Partners are usually based in the countries of the European Economic Area (EEA) or in Switzerland, recognized as a country that meets an adequate level of personal data protection. Some of the Controller’s trusted partners, e.g. Google or Facebook, are based outside the EEA. In connection with the User’s transfer of data outside the EEA, the Controller verifies trusted partners to guarantee a high level of protection of personal data. Such guarantees result in particular from the obligation to use standard contractual clauses adopted by the Commission (EU), in accordance with the wording of Art. 46(2) of GDPR.
The User has the right to request that the Controller provide copies of standard contractual clauses by sending an inquiry to the following address: rodo@REMOtrade.com

§8. The period of storage of personal data

The Administrator guarantees that Personal Data will be stored only for the time that is necessary to achieve the purposes for which the data was collected.
The data will be stored as long as they are needed to provide services by Administrator to Users.
The period of storage of Personal Data is determined individually and depends on the nature of the data, the reason for its collection and processing. After this time, the data is deleted or anonymized in such a way that it is impossible to determine the identity of the User.
Personal data will be processed until there is a basis for their processing, i.e.:
1. in the case of granting consent until its withdrawal, restriction or other actions on the part of the User limiting this consent,
2. in the case when the data is necessary for the performance of the contract, for the duration of its performance and until the limitation of claims under this contract expires (3 years or 6 years). The beginning of the period is counted from the date of maturity of the claim,
3. if the basis for data processing is the legitimate interest of the Controller, until the User submits an effective objection,
4. for tax and accounting purposes to the extent and for a period consistent with applicable regulations.

§9. Viewing and correcting of stored Personal Data

In relation to the processing of Personal Data by the Administrator, the Users have the following rights:
1. the right to request access to, to rectify, delete or limit processing of Personal Data,
2. the right to object to the processing of Personal Data,
3. the right to transfer Personal Data,
4. the right to withdraw consent to the processing of Personal Data for a specific purpose, if the User previously gave such consent,
5. the right to lodge a complaint to the supervisory authority in connection with the processing of the User’s Personal Data by the Administrator.
The above mentioned rights Users may excercise in accordance with the rules described in art. 16 – 21 GDPR, by sending a message to the e-mail address: rodo@REMOtrade.com
All received applications will be treated with special attention and implemented in the shortest possible time. In the case of some applications (of complex nature or concerning the processing of data subject to specific legal regulations) the execution time may be longer, however, in each case, within one month the User shall be informed about the actions taken by the Administrator in order to complete the application. By providing answers and in order to ensure that the Administrator properly implements the application, the Administrator reserves the right to verify the User’s identity.

§10. Security

The Administrator uses technical and organizational measures to ensure the protection of Personal Data processed in accordance with the risks and categories of data protected, in particular, protects data against unauthorized access, unauthorized removal, processing in violation of applicable laws and change, loss, damage or destruction, such as:
1. securing the set of data against the unauthorized access,
2. SSL certificate on the Website, where users’ data are provided.

§11. Final provisions

In matters related to this Privacy Policy please contact us at: rodo@REMOtrade.com
REMO reserves the right to change the Policy in the future – this may happen, among others for the following important reasons:
1. changes in the binding provisions, in particular regarding the protection of Personal Data, telecommunications law, services provided electronically and regulating consumer rights, affecting the rights and obligations of the User;
2. development of functionalities or electronic services dictated by the progress of Internet technology, including the application / implementation of new technological or technical solutions affecting the scope of the Policy.
In case of change of the Policy, the new version shall be published on the website www.REMOtrade.com. The new version of the Privacy Policy enters into force on the day of its publication.
In case of any doubts or contradictions between the Policy and the consents granted by the User, regardless of the provisions of the Policy, the basis for taking and determining the scope of activities by the Administrator are consents voluntarily granted by the User or provisions of law.
In the scope not regulated in the Privacy Policy, the provisions of the GDPR and the mandatory provisions of law in force on the territory of the Republic of Poland shall apply.
The Privacy Policy was drawn up in three language versions: Polish, and English. In the event of any discrepancy between the language versions, the Polish language version shall prevail.
The Polish court having jurisdiction over the REMO seat shall investigate any disputes arising out of or in connection with this Privacy Policy, if the exclusive jurisdiction does not apply.
The Website may contain links to other websites. REMO advises that after going to other websites, you should read the privacy policy set out there. This Policy applies only to the indicated activities of REMO.
The Policy comes into effect on the day 01.12.2023.