Privacy Policy

This English version is a translation provided for information only. The legally binding version is the Polish original.

This Privacy Policy sets out the rules for storing and accessing data on the Devices of Users using the Website for the purpose of the provision of services by electronic means by the Controller, as well as the rules for collecting and processing the personal data of Users which they have provided personally and voluntarily through the tools available on the Website.

This Privacy Policy is an integral part of the Website Terms, which set out the rules, rights and obligations of Users using the Website.

§1 Definitions

• Website - the "Carsproject.pl" website operating at https://carsproject.pl
• External website - websites of partners, service providers or service users cooperating with the Controller
• Website / Data Controller - the Controller of the Website and the Data Controller (hereinafter the Controller) is "SEAPROJECT Sp. z o.o.", conducting business at: BOLESŁAWA KRZYWOUSTEGO 4, 81-035 GDYNIA, with tax identification number (NIP): 5882423187, with KRS number: 0000650760, providing services by electronic means through the Website
• User - a natural person to whom the Controller provides services by electronic means through the Website.
• Device - an electronic device together with its software through which the User accesses the Website
• Cookies - text data collected in the form of files placed on the User's Device
• GDPR - 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 (General Data Protection Regulation)
• Personal data - means any information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
• Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
• Restriction of processing - means the marking of stored personal data with the aim of limiting their processing in the future
• Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements
• Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
• Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
• Pseudonymisation - means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
• Anonymisation - Data anonymisation is an irreversible process of operations on data which destroys / overwrites "personal data", making it impossible to identify or link a given record to a specific user or natural person.

§2 Data Protection Officer

Pursuant to Article 37 GDPR, the Controller has not appointed a Data Protection Officer.

In matters concerning data processing, including personal data, please contact the Controller directly.

§3 Types of Cookies

• First-party cookies - files placed on and read from the User's Device by the Website's ICT system
• Third-party cookies - files placed on and read from the User's Device by the ICT systems of External websites. Scripts of External websites that may place Cookies on Users' Devices have been deliberately placed on the Website through scripts and services made available and installed on the Website
• Session cookies - files placed on and read from the User's Device by the Website during a single session of a given Device. When the session ends, the files are deleted from the User's Device.
• Persistent cookies - files placed on and read from the User's Device by the Website until they are deleted manually. The files are not deleted automatically when the Device session ends, unless the User's Device is configured to delete Cookies at the end of the Device session.

§4 Security of data storage

• Mechanisms for storing and reading Cookies - The mechanisms for storing, reading and exchanging data between the Cookies saved on the User's Device and the Website are implemented through the built-in mechanisms of web browsers and do not allow other data to be retrieved from the User's Device or data of other websites visited by the User, including personal data or confidential information. Transferring viruses, Trojan horses or other worms to the User's Device is also practically impossible.
• First-party cookies - the Cookies used by the Controller are safe for Users' Devices and do not contain scripts, content or information that could threaten the security of personal data or the security of the Device used by the User.
• Third-party cookies - the Controller takes all possible steps to verify and select the website's partners with regard to Users' security. The Controller chooses well-known, large partners enjoying global public trust to cooperate with. However, it does not have full control over the content of Cookies originating from external partners. To the extent permitted by law, the Controller accepts no liability for the security of Cookies, their content or their licence-compliant use by Scripts installed on the website originating from External websites. A list of partners is provided later in this Privacy Policy.
• Control of Cookies
• The User may at any time change, on their own, the settings for the saving, deletion and access to data of Cookies saved by any website
• Information on how to disable Cookies in the most popular desktop browsers is available on the page: how to disable cookies, or from one of the following providers:
• Managing cookies in the Chrome browser
• Managing cookies in the Opera browser
• Managing cookies in the FireFox browser
• Managing cookies in the Edge browser
• Managing cookies in the Safari browser
• Managing cookies in the Internet Explorer 11 browser
• The User may at any time delete all Cookies saved so far using the tools of the User's Device through which the User uses the Website's services.
• Threats on the User's side - The Controller uses all possible technical measures to ensure the security of the data placed in Cookies. It should be noted, however, that ensuring the security of these data depends on both parties, including the User's activity. The Controller accepts no liability for the interception of these data, the impersonation of the User's session or their deletion as a result of the conscious or unconscious activity of the User, viruses, Trojan horses or other spyware with which the User's Device may be or may have been infected. To protect themselves against these threats, Users should follow the rules for using the internet.
• Storage of personal data - The Controller ensures that it makes every effort to keep the processed personal data entered voluntarily by Users secure, and to ensure that access to them is restricted and exercised in accordance with their intended use and the purposes of processing. The Controller also ensures that it makes every effort to protect the data it holds against loss by applying appropriate physical and organisational safeguards.

§5 Purposes for which Cookies are used

• Remembering the User's decision in the consent banner (the “carsproject-cookie” entry in browser storage, a strictly necessary cookie)
• Maintaining the session in the online booking panel so that the selected dates, car and extras are not lost between steps (PHP session cookie, strictly necessary)
• Keeping statistics on visits, telephone clicks and booking progress — only with the User's consent (Google Analytics 4 through Google Tag Manager)
• Displaying Google Maps with pick-up points and the head office — the map loads after consent or after clicking “Show map”; Google may then save its own cookies
• Marketing and remarketing (Google Ads, Meta pixels for Facebook and Instagram, matching ads to interests) — only with separate “Marketing” consent in the banner; without it, advertising scripts are not loaded
• The Website does not use cookies for affiliate programmes.

§6 Purposes of processing personal data

Personal data provided voluntarily by Users are processed for one of the following purposes:

Data about Users collected anonymously and automatically are processed for one of the following purposes:

• Provision of electronic services:
• Services for sharing information about content published on the Website on social networks or other websites.
• Communication between the Controller and Users in matters relating to the Website and data protection
• Pursuing the Controller's legitimate interest
• Keeping statistics on visits and website effectiveness (with “Statistics” consent)
• Remarketing and serving interest-based advertising in Google Ads, Facebook and Instagram (with “Marketing” consent)
• Pursuing the Controller's legitimate interest

§7 Cookies of External websites

On the Website, the Controller uses JavaScript scripts and web components of partners who may place their own cookies on the User's Device. Remember that in your browser settings you can decide yourself which cookies may be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

Services provided by third parties are beyond the Controller's control. These entities may at any time change their terms of service, privacy policies, purpose of data processing and the way they use cookies.

• Script management: Google Tag Manager — loads the tools below in accordance with the decision made in the banner (Google consent mode, Consent Mode v2)
• Statistics (with “Statistics” consent):
• Google Analytics 4 — statistics of visits and events (service identifier G-Y6XQ31K7Y0)
• Marketing (with “Marketing” consent; tools on this list may be enabled without amending this Policy):
• Google Ads — conversion measurement and remarketing
• Meta (Facebook, Instagram) — pixel and remarketing
• Maps (loaded after consent or after clicking “Show map”):
• Google Maps — pick-up points and the head office on the location and contact pages
• Links to social media profiles (Facebook, Instagram) do not in themselves save cookies until the User goes to the social network's website.
• The RentCarSoft booking system (the cloud from which the panel retrieves the price list and to which the booking request is sent) does not save cookies in the User's browser — it communicates with the Website's server.

§8 Types of data collected

The Website collects data about Users. Some data are collected automatically, after the User's consent, in pseudonymised form (Google Analytics 4 assigns the browser a random identifier which the Controller does not link to booking data), and some are personal data provided voluntarily in the booking form.

Data collected automatically after consent:

Data collected during registration:

Data collected when signing up for the Newsletter service

Data collected when adding a comment

Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to the provider of statistical services.

• IP address
• Browser type
• Screen resolution
• Approximate location
• Subpages of the website opened
• Time spent on the relevant subpage of the website
• Operating system
• Address of the previous subpage
• Referring page address
• Browser language
• Internet connection speed
• Internet service provider
• Clicks on the telephone number, e-mail and social media profiles, and online booking progress (step, car model, number of days, amount, extras, errors) — without the booking number
• With “Marketing” consent: advertising identifiers, offers viewed, approximate demographic data (age, gender, interests)
• First name / surname / nickname
• E-mail address
• Telephone number
• IP address (collected automatically)
• NIP (tax identification) number
• Other ordinary data
• E-mail address
• IP address (collected automatically)

§9 Access to personal data by third parties

As a rule, the only recipient of the personal data provided by Users is the Controller. Data collected in the course of the services provided are not transferred or resold to third parties.

Access to the data (most often on the basis of a data processing agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the website, i.e.:

Entrusting the processing of personal data - Hosting, VPS or Dedicated Server services

To run the website, the Controller uses the services of an external provider of hosting, VPS or Dedicated Servers - HitMe.pl – Marek Bajersk. All data collected and processed on the website are stored and processed in the service provider's infrastructure located in Poland. The data may be accessed as a result of maintenance work carried out by the service provider's staff. Access to these data is governed by an agreement concluded between the Controller and the Service Provider.

• Hosting companies providing hosting or related services to the Controller

§10 How personal data are processed

Personal data provided voluntarily by Users:

Statistical data (pseudonymised) collected automatically after consent:

• Personal data will not be transferred outside the European Union, unless they have been published as a result of an individual action by the User (e.g. posting a comment or entry), which will make the data available to anyone visiting the website.
• Personal data will not be used for automated decision-making (profiling).
• Personal data will not be resold to third parties.
• Statistical data may be processed by Google also outside the European Union, on the basis of the European Commission's adequacy decision (Data Privacy Framework) and standard contractual clauses.
• Statistical data will not be used for automated decision-making (profiling).
• Statistical data will not be resold to third parties.

§11 Legal bases for processing personal data

The Website collects and processes Users' data on the basis of:

• 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 (General Data Protection Regulation)
• Article 6(1)(a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes
• Article 6(1)(b) processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
• Article 6(1)(f) processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
• Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
• Act of 12 July 2024 – Electronic Communications Law (Journal of Laws 2024, item 1221) — rules on storing cookies and consent to them
• Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24, item 83)

§12 Period of processing personal data

Personal data provided voluntarily by Users:

As a rule, the personal data indicated are stored only for the period during which the Service is provided by the Controller on the Website. They are deleted or anonymised within 30 days of the end of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation that requires the protection of legitimate purposes of further processing of these data by the Controller. In such a situation, the Controller will store the data indicated, from the time the User requests their deletion, for no longer than 3 years in the event of a breach or suspected breach of the provisions of the website terms by the User

Statistical data collected automatically after consent:

Statistical data in Google Analytics 4 are stored for 14 months from the last visit, after which Google deletes them. The Controller keeps aggregate reports (without identifiers) for an indefinite period. Advertising data of Google Ads and Meta are stored by their operators in accordance with their own policies (usually up to 24 months). Consent for each category can be withdrawn at any time using the “Cookie settings” link in the footer.

§13 Users' rights relating to the processing of personal data

The Website collects and processes Users' data on the basis of:

• Right of access to personal data Users have the right to obtain access to their personal data, exercised upon a request submitted to the Controller
• Right to rectification of personal data Users have the right to obtain from the Controller without undue delay the rectification of inaccurate personal data and / or the completion of incomplete personal data, exercised upon a request submitted to the Controller
• Right to erasure of personal data Users have the right to obtain from the Controller the erasure of personal data without undue delay, exercised upon a request submitted to the Controller In the case of user accounts, erasure of data consists in the anonymisation of data enabling the User to be identified. The Controller reserves the right to suspend the execution of a request for erasure of data in order to protect the Controller's legitimate interest (e.g. where the User has breached the Terms or the data were obtained as a result of correspondence). In the case of the Newsletter service, the User can delete their personal data themselves using the link included in each e-mail message sent.
• Right to restriction of processing of personal data Users have the right to restriction of processing of personal data in the cases indicated in Article 18 GDPR, including where the accuracy of the personal data is contested, exercised upon a request submitted to the Controller
• Right to data portability Users have the right to receive from the Controller the personal data concerning the User in a structured, commonly used and machine-readable format, exercised upon a request submitted to the Controller
• Right to object to the processing of personal data Users have the right to object to the processing of their personal data in the cases specified in Article 21 GDPR, exercised upon a request submitted to the Controller
• Right to lodge a complaint Users have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data.

§14 Contacting the Controller

The Controller can be contacted in one of the following ways

• Postal address - SEAPROJECT Sp. z o.o., BOLESŁAWA KRZYWOUSTEGO 4, 81-035 GDYNIA
• E-mail address - [email protected]
• Telephone - +48 515 405 005
• Contact form - available at: carsproject.pl/kontakt

§15 Website requirements

• Restricting the saving of and access to Cookies on the User's Device may cause some functions of the Website to work incorrectly.
• The Controller accepts no liability for functions of the Website that do not work correctly where the User restricts in any way the ability to save and read Cookies.

§16 External links

The Website — articles, posts, entries or Users' comments — may contain links to external websites with which the Website Owner does not cooperate. These links, and the pages or files they point to, may be dangerous for your Device or pose a threat to the security of your data. The Controller accepts no liability for content located outside the Website.

§17 Changes to the Privacy Policy

• The Controller reserves the right to change this Privacy Policy at will, without having to inform Users, with regard to the use and exploitation of anonymous data or the use of Cookies.
• The Controller reserves the right to change this Privacy Policy at will with regard to the processing of Personal Data, of which it will inform Users who have user accounts or are subscribed to the newsletter service by e-mail within 7 days of the change. Continued use of the services means that the changes to the Privacy Policy have been read and accepted. If the User does not agree with the changes, they are obliged to delete their account from the Website or unsubscribe from the Newsletter service.
• Changes made to the Privacy Policy will be published on this subpage of the Website.
• Changes made take effect upon their publication.