1. General Information

1. This Privacy Policy applies to the website available at tobtom.com.
2. The website operator and the controller of personal data is Tobtom Mixing Systems sp. z o.o., ul. Madalińskiego 4, 47-133 Piotrówka, Poland.
3. The controller can be contacted by e-mail at: biuro@tobtom.com.
4. The Controller processes personal data voluntarily provided by users through the website.
5. Personal data may be processed for the purpose of responding to enquiries and providing information about the Controller’s products and services.
6. The website collects information about users and their activity:
   • through data voluntarily entered into forms,
   • through cookies stored on users’ devices.

2. Data Security Measures

1. Areas of the website where personal data or login credentials are entered are protected using encrypted transmission (SSL/TLS). This helps protect information transmitted between the user’s device and the website server.
2. The Controller applies appropriate technical and organisational measures to protect personal data against unauthorised access, loss, alteration or disclosure.
3. Administrative access to the website and systems used to process data is protected by appropriate authentication measures.
4. The Controller performs backups where appropriate and takes reasonable measures to maintain the security and availability of the systems used to process personal data.
5. Software and website components used for data processing are regularly updated in order to reduce security risks.

3. Hosting

1. The website is hosted on servers provided by SEOHOST.
2. The hosting provider may maintain server logs in order to ensure the proper operation, security and technical reliability of the hosting infrastructure.
3. Server logs may contain technical information relating to connections with the website, such as the IP address, date and time of the request, information about the web browser and operating system, and other technical data necessary for server operation and security.

4. Purposes and Legal Bases for Processing Personal Data

1. Personal data may be processed for the following purposes:
   • responding to enquiries submitted via the website, e-mail or other communication channels,
   • preparing and presenting commercial offers,
   • taking steps at the request of a potential customer prior to entering into a contract,
   • concluding and performing contracts,
   • fulfilling legal, accounting and tax obligations,
   • establishing, pursuing or defending legal claims,
   • ensuring the security and proper operation of the website,
   • analysing website traffic and statistics, where the user has given the required consent.
2. Depending on the purpose, personal data is processed on the basis of:
   • Article 6(1)(a) GDPR – consent,
   • Article 6(1)(b) GDPR – taking steps prior to entering into a contract or performance of a contract,
   • Article 6(1)(c) GDPR – compliance with a legal obligation,
   • Article 6(1)(f) GDPR – the Controller’s legitimate interests, including communication with customers and business partners, protection against claims and ensuring website security.

5. Recipients of Personal Data

1. Personal data may be disclosed to entities cooperating with the Controller where this is necessary for the operation of the website or the conduct of the Controller’s business activities.
2. Such recipients may include, in particular:
   • hosting and IT service providers,
   • providers of e-mail and communication services,
   • accounting, legal and advisory service providers,
   • entities providing technical support and maintenance services,
   • providers of website analytics services,
   • public authorities or other authorised entities where disclosure is required by applicable law.
3. Personal data is disclosed only to the extent necessary for the relevant purpose and in accordance with applicable data protection laws.

6. Data Retention Period

1. Personal data is retained only for as long as necessary to achieve the purpose for which it was collected.
2. In particular:
   • data processed in connection with enquiries and commercial correspondence may be retained for the period necessary to handle the enquiry and for a reasonable period thereafter,
   • data related to contracts and business transactions may be retained for the duration of the contract and subsequently for the period required by applicable tax, accounting and other legal obligations,
   • data necessary for the establishment, exercise or defence of legal claims may be retained until the relevant limitation periods have expired,
   • data processed on the basis of consent may be processed until the consent is withdrawn, unless another legal basis for further processing applies.
3. After the applicable retention period has expired, personal data will be deleted or anonymised, unless its further retention is required by law.

7. Rights of Data Subjects

1. In accordance with the GDPR, individuals whose personal data is processed have the right, where applicable, to:
   • access their personal data,
   • rectify inaccurate or incomplete personal data,
   • request the erasure of personal data,
   • request restriction of processing,
   • object to the processing of personal data,
   • receive and transfer their personal data (data portability),
   • withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before its withdrawal.
2. Requests concerning personal data may be submitted to: biuro@tobtom.com.
3. Data subjects also have the right to lodge a complaint with the competent supervisory authority. In Poland, the supervisory authority is the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych – UODO).

8. Cookies

1. The website uses cookies, which are small text files stored on the user’s device.
2. Cookies may be used to:
   • ensure the proper functioning of the website,
   • remember user preferences,
   • improve website security,
   • collect statistical information about the use of the website,
   • analyse website traffic and performance.
3. Cookies necessary for the proper functioning of the website may be used without the user’s consent where permitted by applicable law.
4. Non-essential cookies, including analytics cookies, are used only after obtaining the user’s consent where such consent is required.
5. Users can manage their cookie preferences through the cookie consent mechanism available on the website and through their web browser settings.
6. Restricting or disabling certain cookies may affect the functionality of some parts of the website.

9. Google Analytics

1. The website uses Google Analytics, a web analytics service provided by Google, to obtain statistical information about the use of the website.
2. Google Analytics may collect information such as:
   • information about the user’s device and browser,
   • approximate location derived from technical data,
   • information about pages visited and interactions with the website,
   • date and time of visits,
   • other technical and statistical information relating to website usage.
3. Google Analytics is activated only where the user has provided the required consent to analytics cookies or similar technologies.
4. The user may withdraw or change their consent at any time using the cookie consent settings available on the website.
5. Further information on how Google processes data is available in Google’s privacy documentation.

10. Transfer of Personal Data Outside the European Economic Area

1. In connection with the use of certain service providers, including Google services, personal data may be transferred outside the European Economic Area (EEA).
2. Where personal data is transferred to a country outside the EEA, the Controller ensures that appropriate safeguards required by the GDPR are applied, where applicable.
3. Such safeguards may include, in particular, an adequacy decision issued by the European Commission or appropriate contractual safeguards, such as Standard Contractual Clauses.
4. Information concerning international data transfers by individual service providers is available in their respective privacy policies and data protection documentation.

11. Contact Forms and Electronic Communication

1. When a user contacts the Controller via a contact form, e-mail or other electronic communication channel, the Controller may process the personal data provided by the user in order to respond to the enquiry and conduct further correspondence.
2. Depending on the nature of the enquiry, the data processed may include, in particular:
   • name and surname,
   • company name,
   • e-mail address,
   • telephone number,
   • information contained in the message or enquiry.
3. Providing personal data is voluntary; however, failure to provide data necessary to handle an enquiry may make it impossible for the Controller to respond or provide the requested information.
4. Users should not provide personal data that is not necessary for the purpose of their enquiry.

12. Automated Decision-Making and Profiling

1. Personal data collected through the website is not used by the Controller to make decisions based solely on automated processing that produce legal effects or similarly significantly affect users.
2. The Controller does not use personal data collected through the website for automated profiling for such purposes.
3. Statistical and analytical tools, including Google Analytics, may be used to analyse general website usage and user interactions, subject to the user’s cookie and privacy preferences.

13. Changes to this Privacy Policy

1. The Controller may update this Privacy Policy where necessary, in particular due to changes in applicable law, technologies used on the website or the manner in which personal data is processed.
2. The current version of the Privacy Policy will always be available on the website.
3. Any significant changes to this Privacy Policy will be communicated in an appropriate manner through the website.

14. Contact

For any questions concerning this Privacy Policy or the processing of personal data, please contact:

Tobtom Mixing Systems sp. z o.o.
ul. Madalińskiego 4
47-133 Piotrówka
Poland
E-mail: biuro@tobtom.com