PRIVACY POLICY

I. General Provisions

1. This Privacy Policy defines the manner of collecting, processing, and storing personal data necessary to provide electronic services via the website available at www.travelogiczero.com (hereinafter referred to as the “Service”).

2. The administrator of the Users' personal data is cyber_Folks S.A., with its registered office at ul. Wierzbięcice 1B, 61-569 Poznań, Poland (hereinafter referred to as the “Administrator”).

3. Personal data is processed in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation – GDPR).

4. The data collected by the Administrator shall be:
– processed lawfully,
– processed for specific, legitimate purposes and not further processed in a manner incompatible with those purposes,
– factually correct and adequate in relation to the purposes for which they are processed,
– stored no longer than necessary to achieve the purposes of the processing.

II. Purpose and Legal Basis for Data Processing

1. The Administrator processes personal data necessary to provide and improve services available through the Service and its specific functionalities.

2. Personal data will be processed for the following purposes:

a. Account registration, user identity verification, and execution of a service agreement via electronic means in accordance with the Act of 18 July 2002 on the provision of electronic services – based on the acceptance of the Terms of Use (Art. 6(1)(b) GDPR);

b. Communication with the User to provide necessary information and build a trustworthy relationship – which constitutes the legitimate interest of the Administrator (Art. 6(1)(f) GDPR);

c. Promotion of the Administrator’s products and/or services, and those of its Partners, through marketing messages (newsletter), provided the User has given consent to receive such emails (Art. 6(1)(a) GDPR);

d. Providing access to industry-related updates, provided the User has consented to receiving such emails (Art. 6(1)(a) GDPR);

e. Analytical and statistical purposes, based on the legitimate interest of the Administrator to assess user activity and preferences to optimize services and website functionalities (Art. 6(1)(f) GDPR);

f. Establishing or defending against claims, based on the legitimate interest of the Administrator to protect its rights (Art. 6(1)(f) GDPR).

3. In each of the above cases, providing personal data is voluntary, but necessary to enter into an agreement or access certain Service functionalities.

III. Data Retention Period

1. Personal data will be processed for as long as the User maintains an active account on the Service, and thereafter for the period necessary to comply with legal obligations or assert or defend against legal claims — no longer than 3 years from the termination of the service agreement.

2. Data processed on the basis of consent will be processed until the consent is withdrawn. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

IV. Data Processing Information

1. Depending on the processing purpose, personal data may be disclosed to:

a. entities affiliated with the Administrator,
b. entities cooperating with the Administrator,
c. subcontractors, in particular providers of selected IT systems and solutions,
d. entities handling online payments,
e. postal and courier service providers,
f. law firms.

2. The personal data processed by the Administrator will not / may be transferred outside the European Economic Area or to international organizations.

V. User Rights

1. The User has the right to:

- access their personal data,

- rectify inaccurate data,

- request data erasure,

- restrict data processing,

- request data portability,

- object to processing based on the legitimate interest of the Administrator,

- withdraw consent at any time, without affecting the lawfulness of processing carried out before the withdrawal.

2. The User has the right to lodge a complaint with the President of the Personal Data Protection Office (UODO) if they believe their rights or freedoms have been violated.

3. No automated decision-making, including profiling, is carried out in the course of processing personal data.

VI. Final Provisions

1. The Administrator reserves the right to make changes to this Privacy Policy, while ensuring that the rights of Users arising from this document will not be limited.

2. Users will be informed of any changes to the Privacy Policy via a notice published on the Service