Privacy Policy

New Approach

EN
EN PL

1. Data Protection Overview

General Information

The Privacy Policy of New Approach sp. z o.o. regarding the processing of personal data.

Data protection has always been treated as one of the most important aspects of the activity of New Approach Sp. z o.o. with its registered office at ul. Ostrobramska 75C, 04-175 Warsaw, registered by the District Court for the Capital City of Warsaw in Warsaw, XIV Economic Department of the National Court Register under the KRS number 0000694329, NIP 1182153134, REGON 368262960 (hereinafter: "New Approach"). Our goal is also to properly inform you about matters related to the processing of personal data, especially in relation to the provisions of data protection law, including 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 ("GDPR"). This Privacy Policy also reflects other generally applicable Polish legal provisions in the area of personal data protection.

The following information will provide you with an easy-to-navigate overview of what happens to your personal data when you visit this website. The term "personal data" includes all data that can be used to identify you personally. For detailed information on data protection, please refer to our Data Protection Statement, which is included below this text.

Data Registration on This Website

Who is responsible for data registration on this website (i.e., the "controller")?

The data on this website is processed by the website operator, whose contact details are available in the "Information about the responsible website (referred to as the "controller" in the GDPR)" section of this Privacy Policy.

How do we register your data?

We collect your data as a result of you providing it to us. This may include information that you enter into our contact form, for example.

Other data is recorded automatically by our IT systems or after you have given your consent to their registration when visiting the website. This data primarily comprises technical information (e.g., internet browser, operating system, or time of page access). This information is recorded automatically when you visit this website.

For what purposes do we use your data?

Some of the information is generated to ensure the proper provision of services on the website. Other data may be used to analyze your usage patterns.

What rights do you have regarding your data?

You have the right to obtain information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand the correction or deletion of this data. If you have consented to data processing, you have the possibility to revoke this consent at any time, affecting all future data processing. Additionally, you have the right to demand the restriction of the processing of your data under certain circumstances. Furthermore, you have the right to lodge a complaint with the competent supervisory authority.

Please do not hesitate to contact us at any time if you have questions about this or any other data protection issue.

Analytical Tools and Tools Provided by Third Parties

It is possible that your browsing patterns will be subject to statistical analysis when you visit this website. Such analyses are carried out primarily with what we refer to as analytics programs.

For detailed information on these analytics programs, please refer to our Data Protection Statement below.

2. Hosting

External Hosting

This website is hosted by an external service provider (host). Personal data collected on this website is stored on the host's servers. This may include, but is not limited to, IP addresses, contact requests, metadata and communications, contract information, contact names, access to the website, and other data generated through the website.

Hosting is used to fulfill the contract with our potential and existing clients (Art. 6(1)(b) GDPR) and in the interest of ensuring the safe, fast, and efficient provision of our online services by a professional provider (Art. 6(1)(f) GDPR).

Our hosting will process your data only to the extent necessary to fulfill its obligations arising from the contract and in accordance with our instructions regarding such data.

We use the following hosting service:

Home.pl Spółka Akcyjna Address: ul. Zbożowa 4, 70-653 Szczecin, Poland

3. General Information and Mandatory Information

Data Protection

The operators of this website and its subpages take the protection of your personal data very seriously. Therefore, we treat your personal data as confidential information and in accordance with the applicable data protection regulations and this Data Protection Statement.

By using this website, various personal information will be collected. Personal data includes data that can be used to identify you personally. This Data Protection Statement explains what data we collect and what we use it for. It also explains how and for what purpose this data is collected.

Information about the Responsible Party (referred to as "controller" in the GDPR)

How to contact our data protection team:

We have appointed a data protection officer. This is a person you can contact for all matters relating to the processing of personal data and the exercise of rights related to data processing. You can contact the data protection officer via email: biuro@icdo.pl

Important Note Regarding Data Transfers to the USA

Some of the tools we use on this website may store your personal data in the United States. We will explain why we do this and how it affects you at the beginning of this Data Protection Statement.

Data transfers to the USA are based on the so-called adequacy decision of the European Commission. Participation in the so-called "Privacy Shield" provides particularly suitable data protection. Privacy Shield is an agreement between Europe and the USA aimed at ensuring compliance with European data protection standards.

You have the right to receive, at any time and free of charge, information about your personal data, its source and recipients, and the purposes of data processing, as well as the right to correct, block, or delete this data. You can contact us at any time if you have questions about this or other issues related to personal data. You also have the right to lodge a complaint with the competent supervisory authority.

Analytical Tools and Tools Provided by Third Parties

When you visit this website, your browsing patterns may be subject to statistical analysis. Such analyses are primarily conducted using analytical programs.

For detailed information about these analytical programs, please refer to this Data Protection Statement.

Option to Withdraw Consent for Data Processing

Many data processing operations require your express consent. You can withdraw your consent at any time. All you need to do is send us an appropriate email notification. Withdrawal of consent does not affect the lawfulness of data processing that occurred before its withdrawal.

Right to Lodge a Complaint with the Competent Supervisory Authority

In the event of a breach of data protection regulations, you have the right to lodge a complaint with the competent supervisory authority. The supervisory authority responsible for data protection matters is the data protection officer of the national country in which our company is headquartered. In Poland, this is the General Inspector for Personal Data Protection (GIODO).

Right to Data Portability

You have the right to have data that we process on the basis of your consent or in fulfillment of a contract transferred to you or to a third party in a structured, commonly used, and machine-readable format. If you request the direct transfer of data to another responsible person, this will be done if it is technically feasible.

SSL or TLS Encryption

For security reasons and to protect the transmission of confidential content such as orders or inquiries that you send to us as the operator of the site, this site uses SSL or TLS encryption. You can recognize an encrypted connection in your browser's address bar when it changes from "http://" to "https://" and the lock icon is displayed in your browser's address bar. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties.

Data Encryption

This website uses SSL or TLS encryption to ensure the confidentiality of personal information and other data transmitted via forms on this site. You can recognize an encrypted connection by the change in the URL from "http://" to "https://" and the lock symbol in your browser's address bar. If data encryption is enabled, the data you transmit cannot be read by third parties.

Information, Blocking, Deletion

Under the applicable legal regulations, you have the right to receive information at any time about your stored personal data, its origin and recipients, and the purpose of data processing, as well as the right to correct, block, or delete this data. You can contact us at any time using the address provided in our legal notice if you have further questions about personal data.

Objection to Promotional Emails

In accordance with applicable legal provisions, we do not allow the use of our contact information for promotional purposes unless explicitly consented to. This information may not be disclosed to third parties for promotional purposes without your explicit consent.

4. Data Storage on This Website

Cookies

Our websites and partner websites use so-called "cookies." Cookies are small text files that do not cause any damage to your device. They are used to make our offer more user-friendly, effective, and secure. Most of the cookies we use are so-called "session cookies." They are automatically deleted after your visit. Other cookies remain stored on your device until you delete them. These cookies allow us to recognize your browser on your next visit.

You can configure your browser to inform you about the use of cookies and allow cookies only in specific cases. You can also exclude the acceptance of cookies in certain cases or in general. You can also activate the automatic deletion of cookies when closing your browser. Disabling cookies may limit the functionality of this website.

Server Log Files

The provider of the pages automatically collects and stores information in server log files that your browser automatically transmits to us. These are:

  • Browser type and browser version
  • Operating system used
  • Referrer URL
  • Adres URL strony, którą odwiedziłeś
  • Host name of the accessing computer
  • Time of the server request
  • IP address

These data will not be combined with data from other sources. The basis for data processing is Art. 6(1)(b) GDPR, which allows the processing of data to fulfill a contract or for pre-contractual measures.

5. Analysis Tools and Third-Party Tools

Our Social Media Presence

Data Processing through Social Networks

We maintain publicly accessible profiles on social networks. Below you will find information about the individual social networks we use. Social networks such as Facebook, Twitter, etc. can generally analyze your user behavior comprehensively if you visit their website or a website with integrated social media content (e.g., like buttons or banner ads). When you visit our sites on social media, numerous data processing operations related to data protection are triggered. Detailed information:

If you are logged into your social media account and visit our site, the operator of the social media platform can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged into your account or do not have an account with the respective social media platform. In such cases, this data is collected, for example, via cookies stored on your device or by recording your IP address.

Using the data collected in this way, operators of social media platforms can create user profiles in which your preferences and interests are stored. This allows targeted advertising to be displayed within and outside the social media presence. If you have an account with the respective social network, interest-based advertising can be displayed on any device you are logged into or have previously logged into.

It should also be noted that we cannot track all data processing operations on social media platforms. Depending on the provider, operators of these platforms may conduct additional data processing operations. Detailed information can be found in the terms of use and privacy policy of the respective social media platforms.

Legal Basis

Our presence on social media aims to ensure the broadest possible online presence. This constitutes a legitimate interest within the meaning of Article 6(1)(f) of the GDPR. The analysis processes initiated by social networks may be based on various legal grounds, which must be specified by the operators of these networks (e.g., consent within the meaning of Article 6(1)(a) of the GDPR).

Responsibility and Enforcement of Rights

If you visit one of our pages on social media platforms (e.g., on Facebook), we share responsibility with the operator of the respective social media platform for the data processing operations triggered during this visit. In principle, you can assert your rights (i.e., the right to information, rectification, erasure, restriction of processing, data portability, and the right to lodge a complaint) against us as well as against the operator of the relevant social media platform (e.g., Facebook).

However, it should be noted that despite the shared responsibility with operators of social media platforms, we do not have full control over the data processing operations carried out by these platforms. Our possibilities are determined by the policies of the respective provider company.

Individual Social Media Platforms

Facebook
We have a profile on Facebook. The service provider for this platform is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. According to Facebook's statement, the collected data may also be transferred to the USA and other third countries. You can adjust the advertising settings in your user account yourself. Click on the following link and log in: https://www.facebook.com/privacy/policy/?entry_point=facebook_help_center_ig_data_policy_redirect&locale=pl_PL. The transfer of data to the USA is based on the Standard Contractual Clauses (SCC) of the European Commission. Detailed information can be found here: https://www.facebook.com/privacy/policies/data_privacy_framework/. Detailed information on Facebook's privacy policy can be found here: https://www.facebook.com/business/gdpr.

Instagram
We have a profile on Instagram. The service provider for this platform is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. According to Facebook's statement, the collected data may also be transferred to the USA and other third countries. You can adjust the advertising settings in your user account yourself. Click on the following link and log in: https://privacycenter.instagram.com/policy/?entry_point=ig_help_center_data_policy_redirect. The transfer of data to the USA is based on the Standard Contractual Clauses (SCC) of the European Commission. Detailed information can be found here: https://www.facebook.com/privacy/policies/data_privacy_framework/. Detailed information on Facebook's privacy policy can be found here: https://www.facebook.com/business/gdpr.

TikTok
We have a profile on TikTok. The service provider for this platform is TikTok Technology Limited, an Irish company ("TikTok Ireland"), and TikTok Information Technologies UK Limited ("TikTok UK"), a British company. TikTok uses advertising cookies. If you want to disable TikTok's advertising cookies, use the following link: https://www.tiktok.com/legal/page/global/tiktok-website-cookies-policy/pl . We ensure the transfer of data outside the EEA, the UK, and Switzerland is subject to the appropriate level of protection based on decisions of adequacy. These are decisions of the European Commission issued pursuant to Article 45 of the GDPR (or equivalent decisions under other provisions), in which it recognizes that a given country provides an adequate level of data protection. User information, as described in the "What information do we collect" section, is transferred to certain countries based on decisions establishing an appropriate level of protection for those countries listed here; or Standard Contractual Clauses. The European Commission has approved the contractual clauses under Article 46 of the GDPR, which allow EEA companies to transfer data outside the EEA. These clauses (and their approved equivalents for the UK and Switzerland) are called standard contractual clauses. We rely on standard contractual clauses to transfer information described in the "What information do we collect" section to certain entities in our Corporate Group (as described here: https://www.tiktok.com/legal/page/eea/transferee-countries/pl ) and third-party websites in countries without a decision establishing an appropriate level of protection. Detailed information on how we process your personal data can be found in TikTok's privacy policy TikTok Privacy Policy.

LinkedIn
We have a profile on LinkedIn. The service provider for this platform is LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies. If you want to disable LinkedIn's advertising cookies, use the following link: https://pl.linkedin.com/legal/cookie-policy? . The transfer of data to the USA is based on the Standard Contractual Clauses (SCC) of the European Commission. Detailed information can be found here: https://pl.linkedin.com/legal/california-privacy-disclosure? Detailed information can be found here: Polityka prywatności LinkedIn .

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6. Correspondence

Contact Forms and Email Messages If you send us inquiries via contact forms or email messages, your data, along with the contact details provided by you in the inquiry form or message, will be stored by us for the purpose of processing the inquiry and for any follow-up questions. We do not share this data without your consent. The legal basis for processing data transmitted via contact forms or in email messages is Art. 6(1)(b) GDPR, which allows the processing of data to perform a contract or pre-contractual measures. The purpose of processing your contact details is solely to process your inquiry. They remain stored with us until you request their deletion, revoke your consent to their storage, or there is no longer a need for their storage for other reasons (e.g., after processing your inquiry). Legal retention periods, in particular, remain unaffected.

7. Plugins and Tools

YouTube
Our website uses plugins from the YouTube service, which is operated by Google. The operator of the site is YouTube, LLC, 901 Cherry Ave., San Bruno, CA 94066, USA. If you visit one of our pages equipped with a YouTube plugin, a connection to the YouTube servers is established. The YouTube server is informed about which of our pages you have visited. If you are logged into your YouTube account, YouTube allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your YouTube account. YouTube is used to attract attention to our online offers. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. More information about how user data is handled can be found in YouTube's privacy policy at: https://policies.google.com/privacy?hl=pl.

Instagram
Our website uses plugins from the Instagram service, which is operated by Meta. The operator of the site is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. If you visit one of our pages equipped with an Instagram plugin, a connection to the Instagram servers is established. The Instagram server is informed about which of our pages you have visited. If you are logged into your Instagram account, Instagram allows you to associate your browsing behavior directly with your personal profile. You can prevent this by logging out of your Instagram account. Instagram is used to attract attention to our online offers. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. More information about how user data is handled can be found in Instagram's privacy policy at: https://www.facebook.com/business/gdpr.

LinkedIn
Nasza strona internetowa korzysta z wtyczek serwisu LinkedIn, które jest zarządzane przez LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Irlandia.. Jeśli odwiedzasz jedną z naszych stron wyposażonych w wtyczkę LinkedIn, zostanie ustanowione połączenie z serwerami LinkedIn. Serwer LinkedIn otrzymuje informację, które z naszych stron odwiedziłeś. Jeśli jesteś zalogowany do swojego konta LinkedIn, LinkedIn pozwala Ci przypisać Twoje zachowanie przeglądania bezpośrednio do Twojego osobistego profilu. Możesz to uniemożliwić, wylogowując się ze swojego konta LinkedIn. LinkedIn jest używane w celu przyciągnięcia uwagi do naszej oferty online. Stanowi to uzasadniony interes w rozumieniu art. 6 ust. 1 lit. f RODO. Więcej informacji na temat przetwarzania danych użytkowników można znaleźć w polityce prywatności LinkedIn pod adresem: https://pl.linkedin.com/legal/privacy-policy?.

TikTok
Nasza strona internetowa korzysta z wtyczek serwisu TikTok, które jest zarządzane przez TikTok Technology Limited, spółka irlandzka („TikTok Ireland”), oraz TikTok Information Technologies UK Limited („TikTok UK”), spółka brytyjska Jeśli odwiedzasz jedną z naszych stron wyposażonych w wtyczkę TikTok, zostanie ustanowione połączenie z serwerami TikTok. Serwer TikTok otrzymuje informację, które z naszych stron odwiedziłeś. Jeśli jesteś zalogowany do swojego konta TikTok, TikTok pozwala Ci przypisać Twoje zachowanie przeglądania bezpośrednio do Twojego osobistego profilu. Możesz to uniemożliwić, wylogowując się ze swojego konta TikTok. TikTok jest używane w celu przyciągnięcia uwagi do naszej oferty online. Stanowi to uzasadniony interes w rozumieniu art. 6 ust. 1 lit. f RODO. Więcej informacji na temat przetwarzania danych użytkowników można znaleźć w polityce prywatności TikTok pod adresem: https://www.tiktok.com/legal/page/eea/privacy-policy/pl

Google Web Fonts

This site uses so-called "Web Fonts" provided by Google for uniform font display. When you call up a page, your browser loads the required fonts into its cache to display texts and fonts correctly. For this purpose, your browser uses Google servers, usually located in the USA. During this process, Google is informed about your visit to our website. The use of Google Web Fonts serves a uniform and appealing display of our online offers. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. If your browser does not support web fonts, a standard font will be used by your computer. More information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google's privacy policy: https://policies.google.com/privacy?hl=pl.

Google Maps

This website uses the Google Maps service via the API interface. The service provider for Google Maps is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. To use the Google Maps features, your information, including your IP address, is transmitted to Google servers in the United States and stored there. Google is able to track your activity using Google Maps connected to your Google account. The use of Google Maps service serves the uniform display of our online offers and facilitates the location of places indicated by us on the website. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. More information about how user data is processed can be found in Google's privacy policy: https://policies.google.com/privacy?hl=pl.

Google Analytics

This website uses the Google Analytics service. The service provider for Google Analytics is Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. To use Google Analytics features, your information, including your IP address, is transmitted to Google servers in the United States and stored there. Google is able to track your activity using connected accounts with your Google account. The use of Google Analytics service serves the uniform display of our online offers and facilitates the location of places indicated by us on the website. This constitutes a legitimate interest within the meaning of Article 6(1)(f) GDPR. More information about how user data is processed can be found in Google's privacy policy: https://support.google.com/analytics/topic/2919631?hl=pl&ref_topic=1008008

8. Privacy Policy and Data Security

Privacy Policy and Data Security

Privacy protection is very important to us. This Privacy Statement provides information about the types of personal data we collect and how we use it. The use of our website is generally possible without providing personal data. If we collect any personal data on our website (such as name, email address, or IP address), this is always done on a voluntary basis to the extent possible. This data will not be disclosed to third parties without your explicit consent. Please note that transmitting data over the internet (e.g., in email communication) may have security vulnerabilities. Complete protection of data from access by third parties is not possible.

General Information

The responsible operator of this website is: New Approach Sp. z o.o. with its registered office at Ostrobramska 75C, 04-175 Warsaw, registered by the District Court for the Capital City of Warsaw in Warsaw, XIV Economic Department of the National Court Register, under KRS number 0000694329, NIP 1182153134, REGON 368262960. The responsible operator is a natural or legal person who independently or jointly with others decides on the purposes and means of processing personal data (e.g., name, email address, etc.).

Important Data Protection Tips

Below are some practical data protection tips that can be applied in your daily activities, both online and offline:

  • Secure your passwords: Make sure your passwords are strong and unique. Avoid using the same passwords for different online accounts. You can also use a password manager to easily manage your login credentials.
  • Be cautious with personal data: Limit sharing your personal data online. Do not share it on public platforms unless absolutely necessary.
  • Update your software: Regularly update your software, including operating systems, web browsers, and applications. Updates often contain security patches that help protect your data.
  • Use security mechanisms: Enable security mechanisms such as two-factor authentication where possible. This is an additional layer of protection for your online accounts.
  • Consider using a VPN: Using a virtual private network (VPN) can further secure your internet connections, especially when using public Wi-Fi networks.

More Information

Więcej informacji na temat plików cookies i podobnych technologii znajdziesz też pod linkiem wszystkoociasteczkach.pl oraz youronlinechoices.com.

9. Binding Legal Provisions

Based on the General Data Protection Regulation (GDPR) approved on April 27, 2016, by the European Parliament and the Council of the European Union (EU Official Journal L 119 of May 4, 2016, p. 1), and relevant national data protection laws, this statement defines the rights and obligations regarding data protection.