GDPR

PRIVACY POLICY

version valid as of May the 4^th 2025

WHAT IS A PRIVACY POLICY?

We would like to familiarize you with the details concerning the processing of your personal data by us in order to provide you with complete knowledge and comfort in using our website.

Due to the fact that we ourselves operate in the internet industry, we know how important is protecting your personal data. Therefore, we take special care to protect your privacy and information you provide.

We carefully select and apply proper technical means, especially those of a programming and organizational nature, ensuring the protection of processed personal data. Our website takes advantage of encrypted data transmission (SSL), which ensures the protection of your identifying data.

In our Privacy Policy you will find the most important information concerning the processing of your personal data by us. We kindly ask you to read it and we promise that it will not take more than a few minutes.

Who is the administrator of the website www.primeo.co?

The administrator of the website is Michał Pniewski, conducting business activity under the name PRIMEO MICHAŁ PNIEWSKI, entered into the Register of Entrepreneurs of the Central Registration And Information On Business kept by the minister responsible for economy at ul. Zagnańska 78a/LU3, 25-528 Kielce, NIP 6572547754, REGON 260198443 (i.e.: us).

PERSONAL DATA

What legal act regulates the processing of your personal data?

Your personal data is collected and processed by us in accordance with the provisions of Regulation of the European Parliament and of the Council (EU) 2016/679 of 27.04.2016 on the protection of individuals with regard to the processing of personal data and on the free flow of such data and repeal of Directive 95/46/EC (general regulation on data protection) (OJ UE L 119, p. 1), commonly known as: GDPR. In the extent not regulated by the GDPR, the processing of personal data is regulated by the Personal Data Protection Act of May 10, 2018.

Who is the controller of your personal data?

The controller of your personal data is Michał Pniewski, conducting business activity under the name PRIMEO MICHAŁ PNIEWSKI, entered into the register of entrepreneurs of the Central Registration And Information On Business kept by the minister responsible for economy at ul. Zagnańska 78a/LU3, 25-528 Kielce, NIP 6572547754, REGON 260198443, e-mail: biuro@primeo.pl, phone: +48 412 412 450.

In matters concerning your personal data, you can contact us via:

• e-mail: biuro@primeo.pl,
• traditional mail: ul. Zagnańska 78a/LU3, 25-528 Kielce,
• telephone number: +48 412 412 450.

HOW DO WE PROCESS THE PERSONAL DATA YOU PROVIDE TO US?

What personal data do we process and for what purposes do we do it?

At our website we offer you many different services, for the purposes of which we process various personal data on the basis of different legal bases.

Voluntarily providing personal data

The provision of the required personal data by you is voluntary, but is a condition for us to provide services to you (e.g. sending a newsletter).

Personal data recipients

You can find the current list of entities to whom we disclose your personal data here.

Automated decision making (including profiling)

We do not make automated decisions concerning you and we do not use profiling.

Will we transfer your personal data outside the EEA or to an international organization?

In order to use Google tools, your personal data may be transferred to the United States, where Google LLC servers are located.

Google LLC is listed as a participant in the Data Privacy Framework (link: https://www.dataprivacyframework.gov/s/participant-search) and therefore the protection of personal data is adequate in relation to the regulations applicable in the European Union, in accordance with Commission Implementing Decision (EU) C(2023) 4745 of 10 July 2023 on the adequate level of protection of personal data in accordance with the EU-US Data Privacy Framework (link: https://eur-lex.europa.eu/legal-content/PL/TXT/PDF/?uri=CELEX:32023D1795&qid=1710923455391).

In order to use Facebook tools, your personal data may be transferred to the United States, where Meta Platforms Inc. servers are located.

Meta Platforms Inc. is listed as a Data Privacy Framework participant (link: https://www.dataprivacyframework.gov/s/participant-search) and therefore the protection of personal data is adequate in relation to the regulations applicable in the European Union, in accordance with Commission Implementing Decision (EU) C(2023) 4745 of 10 July 2023 on the adequate level of protection of personal data under the EU-US Data Privacy Framework (link: https://eur-lex.europa.eu/legal-content/PL/TXT/PDF/?uri=CELEX:32023D1795&qid=1710923455391).

In order to use the Hotjar statistical tool, your personal data may be transferred to the United States. In accordance with the designated tool's privacy policy, Hotjar has taken appropriate safeguards to ensure that your personal data remains protected and requires third-party service providers and partners to also have appropriate safeguards in place. For more information, see Hotjar's Privacy Policy at the following link: https://www.hotjar.com/legal/policies/privacy/.

In order to use Tawk.to's tools, your personal data may be transferred to the United States, where Tawk.to Inc. servers are located.

Tawk.to Inc. is listed as a Data Privacy Framework participant (link: https://www.dataprivacyframework.gov/s/participant-search) and therefore the protection of personal data is adequate in relation to the regulations applicable in the European Union, in accordance with Commission Implementing Decision (EU) C(2023) 4745 of 10 July 2023 on the adequate level of protection of personal data in accordance with the EU-US Data Privacy Framework (link: https://eur-lex.europa.eu/legal-content/PL/TXT/PDF/?uri=CELEX:32023D1795&qid=1710923455391).

WHAT RIGHTS DO YOU HAVE IN REGARDS TO THE PROCESSING OF YOUR DATA BY US?

Under GDPR you are entitled to:

• request access to your personal data,
• request rectifying your personal data,
• request removing your personal data,
• request limiting the processing of your personal data,
• object the processing of personal data;
• request the transfer of your personal data.

If you make any of the above-mentioned requests to us, we will inform you without undue delay - and in any case within one month of receipt of the request - of the action taken in relation to your request.

If necessary, we may extend the one-month period by a further two months due to the complexity of the request or the number of requests.

In any event, we will inform you within one month of receipt of the request of the extension and give you the reasons for the delay.

The right to access personal data (Art. 15 GDPR)

You have the right to be informed whether we process your personal data. If we process your personal data then you have the right to:

• access your personal data;
• be informed about the purposes of the processing, the categories of personal data processed, the recipients or categories of recipients of that data, the intended period of storage of your data or the criteria for determining that period, your rights under the GDPR and your right to lodge a complaint with the President of the Data Protection Authority, the source of that data, automated decision-making, including profiling, and the safeguards applied in connection with the transfer of that data outside the European Union;
• obtain a copy of your personal data.

If you wish to request access to your personal data please submit your request to: biuro@primeo.pl.

The right to rectify personal data (Art. 16 GDPR)

If your personal data is inaccurate you have the right to request us to rectify your personal data immediately. You also have the right to request that we complete your personal data. If you wish to request the rectification or completion of your personal data, please submit your request to: biuro@primeo.pl.

The right to erasure of personal data (Art. 17 of the GDPR)

You have the right to request the deletion of your personal data when:

• your personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
• you have withdrawn your consent in the scope in which your personal data had been processed;
• your personal data was processed against the law;
• you have objected to having your personal data processed for the purposes of direct marketing, including profiling, in the scope in which the processing of personal data is associated with direct marketing;
• you have objected to the processing of your personal data in connection with processing necessary for the performance of a task carried out in the public interest or processing necessary for the purposes of the legitimate interests pursued by us or a third party.

Despite your request for deletion of your personal data, we may continue to process your data for the establishment, investigation or defence of claims of which you will be informed.

If you wish to request the deletion of your personal data, please submit your request to: biuro@primeo.pl.

The right to submit a request to limit the processing of personal data (Art. 18 of the GDPR)

You have the right to have the processing of your personal data limited if:

• you question the accuracy of your personal data; in which case we will restrict the processing of your personal data for a period of time to allow us to check the accuracy of the data;
• the processing of your data is unlawful, and instead of deleting your personal data, you request the restriction of the processing of your personal data;
• your personal data is no longer necessary for the purposes of processing, but it is still required to determine, claim or protect your claims;
• you have objected to the processing of your personal data - until we determine whether our legitimate interests override the grounds for your objection.

If you wish to request a restriction of the processing of your personal data, please submit your request to: biuro@primeo.pl.

The right to object to the processing of personal data (Art. 21 of the GDPR)

You have the right to file an objection regarding the processing of your personal data at any time if:

• you have objected to having your personal data processed in association with processing necessary for completion of a task implemented in the public interest or processing necessary for the purposes resulting from legally justified interests implemented by the Controller of personal data or by a third party;
• processing for the purpose of direct marketing.

If you wish to object to the processing of your personal data, please submit your request to: biuro@primeo.pl.

The right to request the transfer of personal data (Art. 20 of the GDPR)

You have the right to receive your personal data from us in a structured, commonly used machine-readable format and to send it to another controller.

By default, we will provide you with your personal data in CSV format. If you prefer to have your data made available to you in a different format, please indicate your preferred format in your request. Where possible, we will endeavour to make your data available to you in your preferred format.

You can also request that we send your personal data directly to another controller (if technically possible).

If you wish to request the transfer of your personal data, please submit your request to: biuro@primeo.pl.

Can you withdraw your consent to the processing of personal data?

You can withdraw your consent to the processing of your personal data at any time. The withdrawal of your consent to the processing of your personal data does not affect the lawfulness of the processing carried out by us on the basis of your consent before its withdrawal.

If you wish to withdraw your consent to the processing of your personal data, please submit your request to: biuro@primeo.pl.

Complaint to the supervisory authority

If you believe that the processing of your personal data violates the GDPR, you have the right to submit a complaint to the supervisory authority, in particular in the Member State of your habitual residence, your place of work, or the place of the alleged violation.

In Poland, the supervisory authority for GDPR is the President of the Office of Personal Data Protection, which, as of 25 May 2018, superseded the GIODO.

For more information, see here.

Cookies

General information

When browsing the websites of the Website, cookie files, hereinafter "Cookies", i.e. small textual information which is stored on your terminal equipment in connection with the use of the Website, are used. The purpose of using Cookies is to ensure proper functioning of the Website.

Cookies allow for identification of the software you use and for matching the Website to your individual needs.

Cookies usually include the name of the domain they originate from, the time of storing them in the device and the assigned value.

Safety

The Cookies we use are safe for your devices. In particular, it is impossible for Cookies to transfer viruses or other unwanted or malicious software to your device.

Types of Cookies

We use two types of Cookies:

• Session Cookies: are stored on your device and remain there until ending the session of a given browser. The stored information is then deleted from your device. The mechanism of session Cookies does not allow collecting any personal data or any confidential information from your device.
• Persistent Cookies: are stored on your device and remain there until they are deleted. Ending the session of a given browser or turning off the device does not delete them from your device. The mechanism of persistent Cookies does not allow collecting any personal data or any confidential information from your device.

Goals

We also take advantage of Cookies of external entities for the following purposes:

• the configuration of the Website;
• creating statistics that help to understand how users use websites, which allows improving their structure and content through Google Analytics analytical tools, the administrator of which is Google Ireland Ltd. based in Ireland, the Google Privacy Policy is available at the following link: https://policies.google.com/privacy?fg=1;
• determine your profile in order to display tailored material to you on advertising networks, using the Google Ads online advertising tool administered by Google Ireland Ltd. based in Ireland, Google's privacy policy is available at the following link: https://policies.google.com/privacy?fg=1;
• the collection of information about User behaviour using the Facebook Pixel tool, whose administrator is Meta Platforms Ireland Limited, based in Ireland, Facebook's privacy policy is available at the following link: https://www.facebook.com/help/cookies/;
• the operation of Google's tools for researching user behaviour, defining user profiles via the Google Tag Manager tool, whose controller is Google Ireland Ltd. based in Ireland, Google's privacy policy is available at the following links http://www.google.com/intl/pl/policies/privacy/;
• the use of chat via the Tawk.to instant messaging service, the administrator of which is Tawk.to Inc, based in the USA. Tawk.to's privacy policy can be found at the following link: https://www.tawk.to/privacy-policy/;
• the creation of statistics and content performance and, through the Hotjar tools, whose controller is Hotjar Ltd, based in Malta, Hotjar's Privacy Policy is available at the following link: https://www.hotjar.com/legal/policies/privacy/.

In order to understand the principles of using Cookies we also recommend reading the privacy policies of the above-mentioned companies.

Cookie files may be used by advertising networks, especially by Google, to display advertisements matching your preferences. For that purpose, information concerning the manner in which you browsing the Internet or time of browsing the website may be recorded.

In order to browse and edit information regarding your preferences collected by Google, you may use the following tool: https://www.google.com/ads/preferences/

With the use of a browser or service configuration, you can change Cookie settings by defining the conditions for storing Cookies and for accessing your device through Cookies independently and at any time. You may change the settings to block automatic handling of Cookies in the web browser settings or notifying you whenever Cookies are saved on your device. Detailed information concerning the possibility and methods of handling Cookies can be found in the settings of your software (web browser).

Files to download

• Current list of entities to whom we disclose your personal data.
• Cookie Policy.