general information
ECOTRAX, based in Kornice, is one of Europe’s leading producers of window and door joinery.
In this presentation of our privacy policy, we would like to introduce you to the processing of personal data when using the site
HTTPS://ECOTRAX.EU/, indicating the systems we use, and specifying the mechanisms for processing personal data.
The information contained in this document will also apply to other areas of ECOTRAX activity (see table of contents)
ECOTRAX LTD 48 Vitosha Blvd., ground floor, Sofia 1000, Bulgaria SIR: 0000586067 is the administrator of personal data, as defined in the Regulation of the European Parliament and of the Council of the EU number 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and the free movement of such data and the repeal of the Directive 95/46/WE (referred to as “GDPR” or “General Data Protection Regulation”).
Contact details to contact the DPO
If you have any doubts about the processing of your personal data, write to the designated Data Protection Officer, available at: info@ecotrax.eu
Other contact address with the DPO:
ECOTRAX LTD
Data Protection Officer
48 Vitosha Blvd., ground floor, Sofia 1000, Bulgaria
Principles for processing personal data
The administrator makes every effort to ensure that the personal data it processes comply with the principles of:
1. Transparency – strictly related to the disclosure obligation imposed on the administrator.
2. Reliability – were treated in accordance with the principles of the fundamental legal order.
3. Legality – the administrator processes the data in accordance with the legislation and on the basis of the consent granted.
4. Objective – the administrator processes the data according to a specific, explicit and legally justified objective.
5. Data Minimization – the data we collect is adequate, relevant, and limited to achieve the intended purpose of the treatment.
6. Accuracy – we only collect correct data, which we try to update if inaccurate or incomplete.
7. Storage restrictions – we do not store data for longer than necessary.
8. Integrity and Confidentiality – We process data securely, protecting it from loss, destruction or damage.
9. Accountability – the law requires us to follow all of the above rules.
recipients of the data
The administrator shall provide personal data to the entities that process it at its request on the basis of a data processing mandate agreement. These recipients include, among others, suppliers of IT systems and services, marketing agencies, companies implementing marketing campaigns (e-mail address, newsletter), and companies managing databases of e-mail addresses, service subcontractors and entities authorized to obtain data on the basis of the law, that is, the courts, law enforcement. However, these authorities are required to submit an application based on an appropriate legal basis.
We also provide data on the basis of a contract to entrust the processing of personal data to personal and property insurance companies in accordance with the specified legal basis.
Right of access to personal data
The data subject, in accordance with the Regulation of the European Parliament and of the Council of the EU 2016/679, has the following rights:
1. Right of rectification – the administrator is required to immediately correct the data of the data subject.
2. Right to delete data – the administrator is obliged to immediately delete the data of the data subject at the request of that person.
3. Right to limit processing – the administrator shall limit processing at the request of the data subject in the cases specified by art. 18 GDPR
4. Right of transfer – the data subject has the right to transfer personal data to another administrator in the event of an event and in accordance with art. 20 GDPR.
5. Right to object – the data subject has the right to apply to the administrator to object to the data processing protocol concerning them in accordance with art. 21 RODO
If the data subject considers that the aforementioned rights guaranteed by Regulation (EU) 2016/679 have been violated, he has the right to lodge a complaint with the President of the Office for the Protection of Personal Data in electronic form (interactive form) or traditional (alternative form) in accordance with the procedures described on the Office’s website (uodo.gov.pl).
Lawfulness of the processing of personal data
The administrator shall process the data in accordance with the applicable law and the legal bases relating to the processing of personal data in accordance with art. 6 GDPR, determining the lawfulness of the treatment in so far as one of the following conditions is met:
a.i.1. The data subject has consented to the processing of his personal data for one or more specific purposes.
a.i.2. The processing is necessary for the performance of the contract for which the data subject is a party or to take measures (at the request of the data subject) before concluding the contract.
a.i.3. Processing is necessary in order to comply with the administrator’s legal obligation.
a.i.4. Treatment is necessary to protect the vital interests of the person concerned or another natural person.
a.i.5. The processing is necessary for the performance of a task performed in the public interest or in the exercise of the public authority vested in the administrator.
a.i.6. Processing is necessary for legitimate interests pursued by the administrator or by a third party, with the exception of (...).
Duration of processing of personal data on the basis of user consent
If the basis of processing is consent, the data will be processed until the consent is revoked, and after revocation of the consent for a period corresponding to the limitation period for claims that may be raised by ECOTRAX and may be opposed to it.
Duration of processing of personal data (as part of the image)
Surveillance (image) recordings will be processed by the employer only for the purposes for which they were collected and stored, for a period not exceeding 3 months from the date of registration, (if the image recordings constitute evidence in legal proceedings, the period of storage of the recordings is extended until the final conclusion of the proceedings).
Personal data from surveillance recordings are stored on the company’s servers supervised by the IT department.
Duration of processing of personal data in the context of recruitment
Personal data for the purpose of the recruitment process will be kept for a period of 12 months from the receipt of these data.( CV ).
Personal data (as part of the image) related to the marketing process such as photos on the website, social networks, promotional material will be kept for a period of 6 months from the end of the employment relationship.
Conduct of marketing activities, including
1- sending of printed information materials (catalogues, brochures, flyers, etc.);
2- sending invitations, thanks, etc.;
3- sending advertising gadgets.
Legal basis: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 and the law of 10 May 2018 on the protection of personal data.
1- sending of advertising messages known as newsletters including promotional offers, information on new products in the offer as well as changes to the commercial offer etc.
Legal basis: The law of 18 July 2002 on the provision of services by electronic means.
1- telephone contact with natural or legal persons in the context of potential collaboration, collection of information on the quality of products manufactured, requests for advertising materials, etc.
2- Publication of contact details of customer sales outlets on the ECOTRAX website
Legal basis: Law of 16 July 2004 on Telecommunications, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, art. 6 sec. 1 letter.
Profilage – Google Analytics, Google Tag Manager, Google Ads
We would also like to inform you that the ECOTRAX website uses «Google Analytics» and «Google Tag Manager», made available by Google LLC, with its address 1600 Amphitheatre Parkway, Mountain View, CA, 94043 in the United States. The tool is used to analyze website statistics.
More information on HTTPS://POLICIES.GOOGLE.COM/PRIVACY? HL=PL
The administrator uses the Google Ads tool for profiling for direct marketing purposes, that is to create a business offer based on a specific user’s “profile”.
The other tools mentioned above are used only for statistical and analytical purposes as well as to allow more efficient customer access to the services and products offered by ECOTRAX
The user can control the information collected by the Google tools via the "Ad Settings" sub-page, the "My Activity" tab in the Google account settings, by installing additional blocking modules from Google Analytics or via the “incognito mode” available for web browsers – HTTPS://POLICIES.GOOGLE.COM/TECHNOLOGIES/PARTNER-SITES
Please note that your personal data is profiled by the administrator using dedicated tools to implement marketing activities. This means that automated processing of personal data is used to evaluate and analyze selected factors about you. As a result, your personal profile is created on the basis of which the content transmitted is adapted to individual preferences, attitudes and behaviours, in a way that is appropriate to your area of interest. Please note that data is not processed for automated decision-making that could affect your rights.
Purpose of the data collected:
- Marketing of ECOTRAX products and services on the basis of the personal profile created (behavioural advertising);
- Remarketing and behavioural targeting;
- Analysis of the effectiveness of marketing actions (advertising campaigns);
- Automatic personalization of the marketing content provided
- Advertising to selected groups of recipients
Please note that we use third-party tools to analyze your profile. The objectives pursued by the entities are strictly defined by the administrator. Please note that we may transfer your personal data to the entity that automatically sends marketing messages to us.
You have the right to object to profiling.
"Profiling" - means any form of automated processing of personal data, which consists in the use of personal data to assess certain personal factors of a natural person, In particular, to analyse or forecast aspects related to the effects of work, the economic situation of a natural person, the situation, health, personal preferences, interests, reliability, behaviour, location or travel
"Tool" - a hardware or software tool by which your personal data is collected
Cookies
Cookies are small files saved and stored on the user’s local computer or on another device when visiting websites on the Internet.
The cookie files contain computer data, including text files that are stored on the User’s device of the Site and are intended for navigation on the websites. Cookies are most often used to optimize and customize the process of using websites. They are also used to collect statistical data to identify how users use websites. This will improve the structure and content of the website in the future.
ECOTRAX processes the data contained in «cookies» when visitors use the website https://ecotrax.eu/ (or www.ecotrax.eu/) for the following purposes:
- to store data from completed contact and recruitment forms,
- to keep anonymous statistics showing the use of the website,
- to adapt the content of the website to individual user preferences,
- to remember the user’s choice regarding whether or not to consent to the processing of the user’s personal data.
Cookies are stored for a defined period of time, which is determined by a parameter contained in the cookie file. The user can enable or disable cookies in the settings of the web browser he uses. It can also remove cookies from its device continuously by using the option «cleaning user data» (cache, cookies, history, etc.), which is provided by each of the Web browsers. The use of «private mode» in web browsing programs also prevents the storage of cookies on the user’s device.
By default, web browsers allow cookies to be saved. The user can configure the browser to block the automatic acceptance of «cookies» or to obtain information each time a file is sent to the user’s device. Information about the use of cookies and possible configurations are available in the browser settings.
For «cookies», the administrator has provided for a period of 14 months of data storage, that is to say information about cookies and user identifiers. After this period, in the absence of access to the registered website, user-specific cookies will be deleted from the Google Analytics database. Each new activity (site access) will re-record the information and renew the 14-month data storage period. Deleting the data will not affect the overall reports generated in the GA by the administrator for information purposes.
Collecting information about users in the service
ECOTRAX uses Google Analytics, the Universal Analytics services provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). These services help the personal data administrator to analyze user traffic on the website. The data collected is processed in the framework of the above services in an anonymous manner, which prevents the identification of the user. This data is aggregated and anonymous, meaning that it does not contain features to identify visitors to the website. The whole mechanism is based on a JavaScript code placed on the website, which collects relevant data about the user when he browses the website and then sends it to Google Analytics.
The administrator, using the above services, collects data such as:
- sources and means of access to the website,
- unique advertising identifier of the user,
- user behaviour on the website (for example, session duration, open subpages),
- information on devices and browsers used by visitors to the site,
- IP and domain
- geographical data, e,
- demographic data (age, sex).
For more information on the rules with which GA collects and processes personal data, please visit: HTTPS://WWW.GOOGLE.COM/INTL/PL/POLICIES/PRIVACY/PARTNERS/ and HTTPS://WWW.SUPPORT.GOOGLE.COM/ANALYTICS/ANSWER/6004245
Google Analytics also supports an optional browser add-on that, when installed and enabled, disables GA measurements on all user-viewed pages – HTTPS://TOOLS.GOOGLE.COM/DLPAGE/GAOPTOUT/
The administrator uses the Google Maps service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). The above service allows you to display interactive maps directly on the website and use the map function. If the user activates the appropriate Google function, he can receive information about his current position (GPS signal from the user’s device) If the recipient is simultaneously logged into his account in the Google system, the above data is directly associated with this account. Google stores the above data as usage profiles and uses them for advertising, market research and/or website design purposes based on demand. The recipient has the right to object to the creation of such user profiles, yet you must contact Google to exercise this right.
The administrator uses the Google Tag Manager service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). This solution allows, among other things, to quickly and easily update the tracking codes and the associated code extracts, «tags», on the site. The administrator uses tools, for example, to count the completion of predetermined “tasks” on the website – such as sending a form, uploading a file, or using a search engine. The data thus obtained do not allow the identification of specific people, but only allow a more detailed analysis of the traffic and the recognition of the behavior of users on the site.
Google Inc. has received a certificate confirming that it processes the data in accordance with the requirements of the EU-US Privacy Shield – HTTPS://WWW.PRIVACYSHIELD.GOV/PARTICIPANT.ON the website.
The administrator uses the Facebook Plug-in. Facebook is managed by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). The appropriate code fragment placed in the site information links the ECOTRAX Facebook profile to website entries redirected from Facebook. By integrating the plug-in, the service provider is informed that the user’s browser has called the appropriate page, even if the user does not have a profile or is not currently logged in. This information (including the IP address) is transferred directly from the browser to the server and stored there. If the user is connected to the service offered by Facebook, their visit to the site can be assigned to the user’s profile. The purpose and extent of the data collection and the subsequent processing and use of the data by the provider can be found on Facebook.
The collection and recording of personal data is for reporting purposes only. The data is processed electronically using an ICT system with encrypted access to the data via SSL.
The administrator uses the “Google Ads” tool to profile website users and use the anonymous data obtained (for example, opening specific subpages, filling out the contact form, etc.) for remarketing purposes. This solution makes it possible to establish closer contact with users who have visited the ECOTRAX website by broadcasting selected advertisements more accurately in terms of content, when browsing other sites or using the Google search engine. This allows the administrator to more effectively encourage advertisement recipients to purchase the products offered. The user has the option to disable custom data collection. More information on ad customization and settings can be found at – HTTPS://POLICIES.GOOGLE.COM/TECHNOLOGIES/PARTNER-SITES
Fastcall www. Web
The administrator uses a "fastcall" form provided by TOMOES (Marrakech). The use of the form is completely voluntary and optional. The contact information provided (first and last name/company name, telephone number) will be used by the telecommunications system to establish a telephone connection between the Administrator’s relevant business unit and the customer’s number.
Final provisions, changes to the privacy policy
The Administrator reserves the right to make changes to this policy.