The following Privacy Policy defines the rules for recording and accessing data on Users’ Devices using the Service for the purpose of providing electronic services by the Administrator and the rules for collecting and processing Users’ personal data that have been provided by them personally and voluntarily through tools available in the Service.

The following Privacy Policy is an integral part of the Service Regulations, which defines the rules, rights, and obligations of Users using the Service.

§1 Definitions

• Service – the internet service “DeCure” operating at https://decure.com.pl

• External Service – websites of partners, service providers, or service recipients cooperating with the Administrator

• Service / Data Administrator – The Service Administrator and Data Administrator (hereinafter referred to as the Administrator) is the company “DE CURE MEDICAL RESEARCH SP. Z O.O.”, operating at: ul. JANA CZECZOTA 31/— 02-607 WARSAW, with the assigned tax identification number (NIP): 5213856957, and KRS number: 0000769463, providing services electronically through the Service

• User – a natural person for whom the Administrator provides services electronically through the Service.

• Device – an electronic device with software through which the User gains access to 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 about 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 to 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 – Data anonymization is an irreversible process of operations on data that destroys/overwrites “personal data” making it impossible to identify or associate a given record with a specific user or natural person.

§2 Data Protection Officer

Based on Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

For matters related to data processing, 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 Service’s IT system

• External Cookies – files placed and read from the User’s Device by IT systems of External Services. Scripts of External Services that may place Cookies on Users’ Devices have been consciously placed in the Service through scripts and services made available and installed in the Service

• Session Cookies – files placed and read from the User’s Device by the Service or External Services during one session of a given 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 or External Services until they are manually deleted. The files are not automatically deleted after the Device session ends unless the User’s Device configuration is set to delete Cookie files after the Device session ends.

§4 Data Storage Security

• Cookie Storage and Reading Mechanisms – The mechanisms for 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 that the User has visited, including personal data or confidential information. The transfer of viruses, Trojan horses, and other worms to the User’s Device is also practically impossible.

• Internal Cookies – Cookie files 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.

• External Cookies – The Administrator takes all possible actions to verify and select service partners in the context of User security. The Administrator selects well-known, large partners with global social trust. However, he does not have full control over the content of Cookie files from external partners. For the security of Cookie files, their content, and their use in accordance with the license by Scripts installed in the service, originating from External Services, the Administrator is not responsible to the extent permitted by law. The list of partners is included in the further part of the Privacy Policy.

• Cookie Control

  • The User can, at any time, independently change the settings regarding saving, deleting, and accessing data from Cookie files for each website

  • Information on how to disable cookies in the most popular computer browsers is available at: how to disable cookies or from one of the indicated providers:

    • Managing cookies in Chrome browser
    • Managing cookies in Opera browser
    • Managing cookies in FireFox browser
    • Managing cookies in Edge browser
    • Managing cookies in Safari browser
    • Managing cookies in Internet Explorer 11 browser

  • The User can at any time delete all Cookie files saved so far using the tools of the User’s Device, through which the User uses the Service’s services.

• User-side threats – The Administrator takes all possible technical measures to ensure the security of data stored in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activities. The Administrator is not responsible for the interception of this data, impersonation of the User’s session, or their deletion, as a result of conscious or unconscious activity of the User, viruses, Trojan horses, and other spyware that may be or have been infecting the User’s Device. Users should follow the principles that increase their cybersecurity to protect themselves against these threats.

• Storage of personal data – The Administrator ensures that he makes every effort to ensure that personal data voluntarily provided by Users is secure, access to it is limited and carried out in accordance with its purpose and processing objectives. The Administrator also ensures that he makes every effort to secure the data he possesses against loss, by applying appropriate physical and organizational safeguards.

§5 Purposes for which Cookies are Used

• Improving and facilitating access to the Service
• Personalization of the Service for Users
• Marketing, Remarketing in external services
• Conducting statistics (users, number of visits, types of devices, connection, etc.)
• Serving multimedia services
• Providing social services

§6 Purposes of Personal Data Processing

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

• Provision of electronic services:
  • Newsletter service (including sending advertising content with consent)
  • Services for sharing information about content placed in the Service on social networks or other websites.
• Communication between the Controller and Users regarding matters related to the Service and data protection
• Ensuring the Controller’s legitimate interest

Data about Users collected anonymously and automatically is processed for one of the following purposes:

• Conducting statistics
• Remarketing
• Ensuring the Controller’s legitimate interest

§7 External Services’ Cookies

The Administrator uses javascript scripts and web components of partners in the Service, who may place their own cookie files on the User’s Device. Remember that in your browser settings you can decide for yourself about the allowed cookies that can be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

• Multimedia services:
  • YouTube
  • Vimeo
• Social / combined services:
  (Registration, Login, content sharing, communication, etc.)
  
  • Twitter
  • Facebook
• Newsletter services:
  • Mailerlite
• Conducting statistics:
  • Google Analytics
• Other services:
  • Google Maps

Services provided by third parties are beyond the Administrator’s control. These entities may at any time change their terms of service, privacy policies, purpose of data processing, and ways of using cookies.

§8 Types of Collected Data

The Service 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 various services offered by the Service.

Anonymous data collected automatically:

• IP Address
• Browser type
• Screen resolution
• Approximate location
• Opened subpages of the service
• Time spent on a specific subpage of the service
• Type of operating system
• Previous subpage address
• Referring page address
• Browser language
• Internet connection speed
• Internet service provider

Data collected during registration:

• Name / surname / pseudonym
• Email address
• IP address (collected automatically)

Data collected during Newsletter subscription

• Name / surname / pseudonym
• Email address
• IP address (collected automatically)

Data collected when adding a comment

• Name and surname / pseudonym
• Email address
• IP address (collected automatically)

Some data (without identifying data) may be stored in cookie files. Some data (without identifying data) may be transferred to the provider of statistical services.

§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 is not transferred or resold to third parties.

Access to data (most often based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the service, i.e.:

• Hosting companies providing hosting or related services to the Controller
• Companies through which the Newsletter service is provided

Entrusting personal data processing – Newsletter

To provide the Newsletter service, the Administrator uses the services of a third party – the Mailerlite service. Data entered in the newsletter subscription form is transferred, stored, and processed in the external service of this provider.

Please note that the indicated partner may modify the specified privacy policy without the Administrator’s consent.

Entrusting personal data processing – Hosting, VPS or Dedicated Servers Services

The Administrator uses the services of an external hosting, VPS or Dedicated Servers provider to run the service – EMERGE IT Support Sp. z o.o. . All data collected and processed in the service is stored and processed in the service provider’s infrastructure located within the European Union borders. There is a possibility of access to the data as a result of maintenance work carried out by the service provider’s personnel. Access to this data is regulated by an agreement between the Administrator and the Service Provider.

§10 Method of Processing Personal Data

Personal data provided voluntarily by Users:

• Personal data will not be transferred outside the European Union, unless it has been published as a result of individual User action (e.g., entering a comment or post), which will make the data available to anyone visiting the service.
• Personal data will not be used for automated decision-making (profiling).
• Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

• Anonymous data (without personal data) will be transferred outside the European Union.
• Anonymous data (without personal data) will not be used for automated decision-making (profiling).
• Anonymous data (without personal data) will not be resold 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 2018, item 1000)
• Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)
• Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24, item 83)

§12 Period of Processing Personal Data

Personal data provided voluntarily by Users:

As a rule, the indicated personal data is stored only for the period of providing the Service within the Service by the Administrator. It is deleted or anonymized within 30 days from the moment of termination of services (e.g., deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

The exception is a situation that requires securing legally justified purposes for further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of requesting their deletion by the User, for no longer than 3 years in the case of violation or suspected violation of the service regulations by the User

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, is stored by the Administrator for the purpose of maintaining service statistics for an indefinite period

§13 Users’ Rights Related to the Processing of Personal Data

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, implemented at the request submitted to the Administrator

• Right to rectify personal data
  Users have the right to request the Administrator to immediately rectify personal data that is incorrect and/or complete incomplete personal data, implemented at the request submitted to the Administrator

• Right to erasure of personal data
  Users have the right to request the Administrator to immediately delete personal data, implemented at the request submitted to the Administrator. In the case of user accounts, data deletion consists of anonymizing data enabling User identification. The Administrator reserves the right to suspend the implementation of the data deletion request in order to protect the Administrator’s legitimate interest (e.g., when the User has violated the Regulations or the data was obtained as a result of correspondence).
  In the case of the Newsletter service, the User has the possibility to independently delete their personal data using the link included in each sent e-mail message.

• Right to restriction of processing of personal data
  Users have the right to restrict the processing of personal data in cases indicated in art. 18 GDPR, including questioning the correctness of personal data, implemented at the request submitted to the Administrator

• Right to data portability
  Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used and machine-readable format, implemented at the request submitted to the Administrator

• Right to object to the processing of personal data
  Users have the right to object to the processing of their personal data in cases specified in art. 21 GDPR, implemented at the request submitted to the Administrator

• Right to lodge a complaint
  Users have the right to lodge a complaint with the supervisory authority dealing with the protection of personal data.

§14 Contact to the Administrator

You can contact the Administrator in one of the following ways

• Postal address – DE CURE MEDICAL RESEARCH SP. Z O.O., ul. JANA CZECZOTA 31/— 02-607 WARSAW

• Email address – kontakt@decure.com.pl

• Contact form – available at: https://decure.com.pl/kontakt/

§15 Service Requirements

• Limiting the saving and access to Cookie files on the User’s Device may cause some functions of the Service to malfunction.

• The Administrator bears no responsibility for improperly functioning features of the Service in the event that the User restricts in any way the ability to save and read Cookie files.

§16 External Links

In the Service – articles, posts, entries or User comments, there may be links to external websites with which the Service Owner does not cooperate. These links and the pages or files they point to may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for content located outside the Service.

§17 Changes to the Privacy Policy

• The Administrator reserves the right to change this Privacy Policy without the need to inform Users about it in the scope of using and utilizing anonymous data or using Cookie files.

• The Administrator reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, and will inform Users who have user accounts or are subscribed to the newsletter service via email within 7 days of the change. Continued use of the services indicates acknowledgment and acceptance of the introduced changes to the Privacy Policy. If a User does not agree with the introduced changes, they are obligated to delete their account from the Service or unsubscribe from the Newsletter service.

• Any changes made to the Privacy Policy will be published on this subpage of the Service.

• The introduced changes take effect upon their publication.