1. General Provisions
1.1. This Privacy and Cookie Policy (hereinafter referred to as the “Policy”) contains information regarding the processing of personal data of individuals (hereinafter referred to as “Users”) using the website available at www.kylko.com (hereinafter referred to as the “Website”).
1.2. The purpose of this Privacy Policy is to allow Users to understand the actions taken by the controller with regard to personal data collected through or in connection with the Website, as well as to inform Users of their rights and the rules governing the use of cookies.
2. Personal Data Controller
The controller of personal data, i.e., the entity responsible for processing it in accordance with the law, is Kylko sp. z o.o., with its registered office in Hyżne, address: Hyżne 624, 36-024 Hyżne, entered into the National Court Register under number KRS 0001058153, NIP (Tax Identification Number): 813-390-36-56, e-mail: hello@Kylko.com, being the owner of the Website (hereinafter referred to as the “Controller” or “Kylko”).
3. Scope of Personal Data Processing
3.1. The Controller processes User data for the following purposes:
- to respond to a message sent via the contact form: email address, name, and the content of the message;
- to respond to a message sent by email or by phone: contact details and the content of the message;
- to send commercial information as part of the Newsletter service ordered by the User: email address, name, IP address, and timestamp of subscription.
3.2. In connection with the provision of electronic services, the Controller also processes online identifiers: User IP addresses and cookie identifiers, as well as device data and geolocation data. IP addresses are logged in so-called server log files. After each visit, the IP address contained in this data is immediately anonymized, as soon as it is no longer necessary to retain the record for maintaining the functionality of the respective webpage.
4. Purposes and Legal Basis of Data Processing
4.1. The Controller processes personal data for purposes related to the operation of the Website, depending on the services used by the User:
- User support.
We process data in order to respond to messages sent via the contact form, received by email or phone – in this case, the legal basis for data processing is our legitimate interest. Providing personal data is voluntary but necessary to respond to a message received.
- Newsletter subscription.
We process data to send commercial information within the scope of the Newsletter service ordered by the User, including information on promotions, offer updates, and other marketing information about our products and services – the legal basis for processing is your consent and our legitimate interest in direct marketing. Providing personal data is voluntary but necessary to receive information at your request.
- Data protection requests.
We process data to handle your request concerning data protection – in this case, the legal basis is our legal obligation to address such requests. Providing personal data is voluntary but necessary to process your request.
4.2. If the Controller obtains your personal data via contact methods other than forms available on the Website, the data will be processed for the purpose of correspondence handling – in this case, the legal basis is the Controller’s legitimate interest. Providing personal data is voluntary.
5. Disclosure of Personal Data
Personal data may be disclosed to:
- technical service providers,
- IT tool suppliers and support services,
- hosting providers,
- consultants, legal firms,
- marketing service providers – in the case of marketing communications, including providers of tools used to send marketing information, advertising agencies, and partners assisting with ad campaigns.
Apart from the above, we do not disclose your personal data to third parties unless we are required to do so by authorized authorities under applicable laws and regulations.
6. Cookies and Other Technologies
6.1. Like nearly all websites, our Website uses cookies. Accepting cookies is not required to use the Website. However, please note that some functionalities may be limited if cookies are not accepted. During your first visit to the Website, you will be shown information regarding our use of cookies. With a dedicated tool, you can manage cookie settings directly on the Website. You can also change your cookie settings in your browser or delete cookies entirely. Browsers handle cookies differently; use your browser’s help menu to learn how to manage cookies.
6.2. Cookies are small text files stored on your end device (e.g., computer, tablet, smartphone), which may be read by our IT system (first-party cookies) or by third-party systems (third-party cookies). We use our own cookies to ensure the Website functions properly.
6.3. There are two types of cookies:
- session cookies – deleted after closing the browser,
- persistent cookies – stored for a longer period or permanently. These allow us to tailor the Website to the User’s preferences.
6.4. We use three categories of cookies:
- Essential (functional) cookies:
Necessary to provide optimal navigation and Website functionality (e.g., faster page load times), to remember User data and settings (so they don’t need to be re-entered), and to personalize the Website to User preferences. Without essential cookies, the Website cannot function properly or may only work in a limited way.
- Statistical cookies:
Used to analyze how Users interact with the Website (e.g., which areas are accessed, page loading speeds, and whether errors occur). These cookies contain only anonymous or pseudonymized information and are used solely to optimize the Website, gather User preference data, and measure advertising effectiveness. These can be blocked without affecting Website navigation or usability.
- Marketing cookies:
Used to tailor personalized advertising to User preferences (retargeting), to show ads again to Users who have visited the Website (remarketing), and to study preferences of groups or individual Users. These can also be blocked without affecting navigation or Website usability, though personalized ads will no longer be displayed.
6.5. The Service stores HTTP requests directed to the Administrator’s server. The browsed resources are identified via URLs. The detailed list of data stored in the server log files includes:
- the public IP address of the computer from which the request originated (e.g., the User’s computer),
- the name of the client station – identification performed by the HTTP protocol, if possible,
- the username provided during the authorization process,
- the time the request was received,
- the first line of the HTTP request,
- the HTTP response code,
- the number of bytes sent by the server,
- the URL of the page previously visited by the User (referrer link) – if the User accessed the Website through a link,
- information about the User’s browser,
- information about errors that occurred during the HTTP transaction.
6.6. The data listed in section 7.5 above are not used to identify specific individuals, except for Users to the extent that they use functionalities of the Website.
6.7. Log files are stored by Kylko for the time necessary to administer the Website. Kylko also uses the log files for statistical purposes; however, the generated statistics do not contain any identifying features of individuals visiting the Website and may be retained for a period of up to 26 months.
6.8. In addition, the Website uses cookies in the following ways:
- Google Analytics:
We use the Google Analytics tool. Our actions in this regard are based on our legitimate interest in creating statistics and analyzing them to optimize the functioning of the Website. Google Analytics automatically collects information about how you use the Website. The data collected in this way are usually transmitted to a Google server in the United States and stored there. Google Analytics uses cookie technology to assess the use of the Website, enabling us to analyze traffic sources and how visitors interact with the Website. Google collects data on its servers obtained from placing cookies on user devices and uses this information to compile reports and provide other services related to internet traffic and usage. Google may also share this information with third parties if required to do so by law or if such third parties process the information on Google’s behalf. However, according to Kylko’s configuration, the User’s IP address is anonymized (masked). The IP anonymization feature available in Analytics replaces the last octet of the User’s IPv4 address and the last 80 bits of IPv6 addresses with zeros shortly after being sent to Google Analytics. These data are never combined with data provided via contact forms available on the Website. Only in exceptional cases is the full IP address transmitted to a Google server in the USA and anonymized there.
Users can prevent the data from being recorded via Google Analytics by downloading and installing the plugin available at: https://tools.google.com.
If you are interested in more details regarding data processing within Google Analytics, we encourage you to read Google’s explanations.
- Facebook Pixel:
We use marketing tools available within the Facebook platform. These tools allow us to display ads to you on Facebook. Our actions in this regard are based on our legitimate interest in marketing our own products or services. The Facebook Pixel automatically collects information about your use of our Website, such as which pages you visited. The collected information is usually sent to a Facebook server in the United States and stored there. Facebook may use cookies, web beacons, and similar technologies to collect or receive information from the website and use it for measurement services and ad targeting. Importantly, the information collected through this service is anonymous — we cannot identify you personally. We only know what actions you took on our Website.
However, we point out that Facebook may link this information with other data about you that it has collected as part of your use of Facebook, and use it for its own purposes, including marketing. Such Facebook activities are not controlled by us. You can find more information directly in Facebook’s privacy policy: https://www.facebook.com/privacy/explanation.
You can also manage your privacy settings from your Facebook account. Additionally, within the cookie settings available on our Website, you can choose whether you consent to the use of Facebook Pixel. You can disable the collection and use of information for ad targeting purposes by using the following tools:
http://www.aboutads.info/choices
http://www.youronlinechoices.eu
- Social Plugins: Facebook, Instagram, YouTube, Pinterest:
Our Website uses social plugins provided by platforms such as Facebook, Instagram, YouTube, and Pinterest. When Kylko creates a business profile on a social media platform, it receives statistical data about that profile.
Using these features may involve the use of cookies from the respective social media platform providers. When you visit our Website, your browser establishes a direct connection to the servers of these social platforms. The content of the plugin is transmitted directly by the provider to your browser and integrated into the Website. Through this integration, the social platform provider receives information that your browser has displayed our Website. This information (including your IP address) is transmitted by your browser directly to the provider’s server and stored there.
If you are logged into one of the social media platforms, the provider can associate your visit to our Website with your profile on that platform. If you do not want social platforms to associate data collected during your visit to our Website directly with your profile, you must log out of those platforms before visiting our Website.
You can also completely block the loading of plugins using appropriate browser extensions, such as script blockers.
7. Retention Period of Personal Data
7.1. We retain your personal data for as long as necessary for the purposes outlined in this Policy, particularly to fulfill our contractual and legal obligations. We may also store it for other purposes if permitted by law, including for the defense of our rights or the pursuit of claims, but no longer than the applicable statute of limitations.
7.2. With respect to data obtained through the contact form on the “Contact” page or via other forms of communication available on the Website or in this Policy, we will retain personal data for the period necessary to respond or conduct correspondence, but no longer than 12 months.
7.3. In the case of data obtained via the Newsletter service, we retain such data until you unsubscribe from the service.
7.4. We also retain personal data for the period necessary to fulfill and demonstrate compliance with legal obligations in order to enable verification by public authorities.
8. Security of Personal Data Processing
8.1. Kylko is committed to ensuring the protection of personal data of Users of the Website.
8.2. Kylko ensures the security of Users’ personal data by implementing appropriate technical and organizational measures designed to prevent accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access to personal data that is transmitted, stored, or otherwise processed.
8.3. The Website uses encrypted data transmission (SSL).
9. Processing of Children’s Personal Data
The Website is intended for individuals who are at least 16 years old. Therefore, Kylko does not knowingly process personal data of children under the age of 16.
10. Your Rights Regarding the Processing of Personal Data
10.1. You have the right to access your personal data at any time. You may also request that your data be rectified, erased, or that its processing be restricted.
10.2. In the case of data you provided to us based on your consent and that we process using IT systems, you have the right to receive it in a structured, machine-readable format or request that we transmit it directly to another controller.
10.3. If you have given your consent for the processing of personal data, you may withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing carried out based on consent before its withdrawal.
10.4. You also have the right to lodge a complaint with the President of the Personal Data Protection Office if you believe that the processing of your personal data violates the law.
11. Right to Object to the Processing of Your Personal Data
11.1. If we process your personal data based on our legitimate interests, you have the right to object to such processing on grounds relating to your particular situation.
11.2. Additionally, if we process your data for direct marketing purposes, you have the right to object at any time to such processing, including profiling related to direct marketing.
12. Automated Decision-Making and Profiling
Users’ personal data may be processed by automated means – we may use profiling to assess certain information about Users, including to analyze or predict preferences related to the use of the Website. However, this will not produce legal effects or similarly significantly affect Users.
13. Transfer of Personal Data to Third Countries and International Organizations
We do not transfer Users’ personal data to countries outside the European Economic Area (third countries) or to international organizations.
14. Final Provisions
14.1. The principles outlined in this Policy have been drawn up and comply with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and the Polish Personal Data Protection Act of 10 May 2018.
14.2. The Controller reserves the right to amend this Privacy Policy.
14.3. If you have any questions or concerns regarding the processing of personal data, we encourage you to contact us. You may also send us an email if you wish to exercise your rights to information, data deletion, or other data protection rights in accordance with Articles 15–22 of the GDPR, including the withdrawal of consent for marketing purposes or unsubscribing from the Newsletter.
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