www.voneogroup.com
The owner of the website at https://voneogroup.com/ (hereinafter the “Website”) and, at the same time, the controller of personal data is VONEO Group Spółka z ograniczoną odpowiedzialnością Sp. k. with its registered office at ul. Wigury 20, 64-400 Międzychód, Poland, NIP (Polish tax identification number): 5951455352 (hereinafter the “Controller”).
The Controller can be contacted quickly and efficiently at the Controller’s registered office, i.e. the address given above, and by email at: rodo@voneogroup.com.
Out of respect for your privacy and to ensure that you know how your personal data is processed, we set out below the key information on the use of cookies and similar technologies on the Website.
1. What are cookies?
Cookies are small files that are placed on your computer or other device when you visit websites. They are used to improve the functioning or performance of websites, and to provide information to website owners.
2. For what purpose does the Controller use cookies?
We use the following categories of cookies:
- session cookies: remain on the user’s device until the user leaves the website or closes the software (web browser);
- persistent cookies: remain on the device for the period specified in the cookie’s parameters or until they are manually deleted by the user;
- persistent storage entries: information stored in the browser’s local storage which, unlike cookies, has no defined expiry date. It remains on the device until it is deleted by the user in the browser settings, deleted by the script that stored it, or deleted by the browser in accordance with its settings.
Having regard to the purpose for which they are used, the Controller may use two types of cookies:
- strictly necessary cookies: we use strictly necessary cookies for the purpose and to the extent necessary for the website to display correctly, on the basis of our legitimate interest. Their purpose is to ensure basic functions such as security, network management and accessibility, and to remember your cookie settings. They are placed on the end device by default. The user can disable them by changing the browser settings; however, disabling them may prevent the website from functioning properly;
- optional cookies – processed in order to collect information about user activity on the Website. You can accept or reject them according to your preferences in the cookie banner. The use of optional cookies is based on the user’s consent.
We use the following types of cookies:
- first-party cookies: are set directly by the website you are visiting;
- third-party cookies: are placed by a script from another domain.
As part of the optional cookies, we use:
- analytics cookies – collect information on how users use the website, e.g. which pages they visit most often, whether they receive error messages and how they arrived at our website;
- advertising cookies – used to promote the Controller’s services. This type of cookie is used to make the advertising content displayed more relevant and tailored to the user’s preferences, and to measure the effectiveness of advertisements;
- functional cookies – cookies that help to improve the performance and functionality of the website. They store and retrieve information in order to provide users with the services or information they request, e.g. they remember the language version of the Website selected by the user.
3. Which cookies do we use?
| Cookie name | Provider | Type | Purpose | Retention |
|---|---|---|---|---|
| Analytics cookies | ||||
| _ga | Google Analytics | first party | Used by Google Analytics to identify and track individual sessions on your device. | 1 year |
| _ga_xxxxxxxxxx | Google Analytics | first party | The name of this cookie is associated with Google Universal Analytics – a significant update to Google’s more commonly used analytics tool. This cookie is used to distinguish unique users by assigning them a randomly generated number that serves as a client identifier. It is included in each page request on the site and is used to calculate visitor, session and campaign data for analytics reports. By default, it expires after 2 years, although site owners can change this setting. For more information on how Google processes your personal data, see the Google page dedicated to https://business.safety.google/privacy/. | 1 year |
| Advertising cookies | ||||
| _fbp | Meta Pixel | first party | Used by Facebook to deliver a series of advertising products, such as real-time bidding by third-party advertisers. | 2 months |
| lastExternalReferrer | Meta Pixel | first party (local storage) | Stores the address of the external page from which the user arrived at the Website, for the purpose of measuring the effectiveness of advertisements. | persistent |
| lastExternalReferrerTime | Meta Pixel | first party (local storage) | Stores the time of entry to the Website from an external page, for the purpose of measuring the effectiveness of advertisements. | persistent |
| Functional cookies | ||||
| wpEmojiSettingsSupports | own (WordPress system) | first party (session storage) | Stores information on whether the browser supports emoji so that the content of the Website is displayed correctly. | session |
| pll_language | own cookie (Polylang plugin) | first party | The name of this cookie is associated with the Polylang plugin for WordPress-based websites. This cookie stores the user’s language preferences, which enables multilingual websites to function. If it is set as a persistent cookie (or has the default validity period of 1 year), it should be classified as a functional cookie rather than a strictly necessary one. | 1 year |
4. Controlling and deleting cookies
You can give, refuse or withdraw consent to optional cookies at any time in the cookie banner displayed on the Website. You can change your cookie settings at any time using the “Cookie settings” link in the footer of the Website. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Most browsers allow you to accept or reject all cookies. The user can manage the storage of cookies in the browser settings. Please note, however, that blocking all cookies may cause difficulties in the operation of the Website or make it impossible to use some of its functionalities. Managing and deleting cookies differs depending on the browser used. Detailed information on managing cookies can be obtained by using the Help function in your browser or by visiting the website https://allaboutcookies.org/ which explains how to control and delete cookies in most browsers. You can also find information on managing cookies directly on the websites of the individual web browsers:
- Google Chrome,
- Microsoft Edge,
- Mozilla Firefox,
- Opera,
- Apple Safari,
- Brave.
5. Operating data
Even if no cookies are installed, the website administrator may have access to data characterising the way in which the Website is used (“operating data”), which may in particular include:
- the IP address assigned to your device or the external IP address of your internet service provider,
- domain name,
- browser type,
- time of access,
- type of operating system.
In order to ensure the highest possible quality of the website, we occasionally analyse log files to determine which pages are visited most frequently. We may also collect navigation data, including information about the links you choose to click, or about other actions you take on the Website. In this respect, the legal basis is our legitimate interest (Article 6(1)(f) GDPR), consisting in facilitating the use of services provided by electronic means and improving the functionality of those services. Operating data is not combined with information such as your first name and surname, email address or other data that would allow the website visitor to be easily identified.
6. Tracking pixels
We also use tracking pixels. A pixel is a piece of software code that allows a pixel-sized image to be embedded on a page. It makes it possible to track your behaviour on the Website. The pixel may operate in conjunction with first-party or third-party cookies and with the storage of information in the browser’s local storage. The pixel is activated only after consent to advertising cookies has been given; the browser will then automatically establish a connection with the pixel provider’s server. Events recorded by the pixel may additionally be sent to Meta directly from the Website’s server, to the extent covered by your consent. Further processing of the data collected by the pixel takes place on the terms set by the pixel provider, as indicated in section 7.
7. Third-party provider technologies
On the Website we use services and tools provided by third-party providers. We use them mainly to provide services via the Website and for purposes related to analytics, advertising activities (including those based on your preferences) and remarketing. A list of the providers whose services and tools we use is set out in the table above. Below we present in detail selected providers and their services:
1) Google Tag Manager
Google Tag Manager is used to manage the scripts (tags) run on the Website, including the scripts of the analytics and advertising tools described below. The tool itself does not store cookies; it runs the scripts of other providers only in accordance with your consent settings in the cookie banner. Provider: Google Ireland Limited, Google Building, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. For more information on how the provider processes data, see the following link: https://policies.google.com/privacy.
2) Google Analytics
we use the Google Analytics tool to collect data on user interactions with our Website. This information is analysed in order to produce statistics on the operation of the Website and to better tailor our offer to users’ needs. Provider: Google Ireland Limited, Google Building, Gordon House, 4 Barrow St, Dublin, D04 E5W5, Ireland. For more information on how the provider processes data, see the following link: https://support.google.com/analytics/answer/6004245.
3) Meta Pixel
Meta Pixel allows us to measure the effectiveness of the Controller’s advertisements displayed on Meta services (Facebook, Instagram) and to target advertisements at people who have visited the Website (remarketing). With regard to the collection of data on the Website and its transmission to Meta, the Controller and Meta Platforms Ireland Limited are joint controllers; the essence of their arrangement is available in Meta’s joint controllership document, at the link indicated below. Meta is solely responsible, as a separate controller, for further processing of the data after it has received it. Data may be transferred to Meta Platforms, Inc. in the United States. Provider: Meta Platforms Ireland Limited, 6 Serpentine Ave, Dublin, D04 H0C9, Ireland. For more information on how the provider processes data, see the following link: https://www.facebook.com/privacy/explanation/.
4) Microsoft Clarity
Microsoft Clarity records how the Website is used (clicks, scrolling, cursor movement) and on that basis creates heat maps and session recordings, which are used to analyse the usability of the Website. The tool is activated after consent to analytics cookies has been given. Provider: Microsoft Ireland Operations Limited, One Microsoft Place, South County Business Park, Carmanhall And Leopardstown, Dublin, D18 P521, Ireland. For more information on how the provider processes data, see the following link: https://privacy.microsoft.com/pl-pl/privacystatement.
5) Social media
On the Website we include links to our profiles on social networking sites (Facebook, LinkedIn). When you click such a link, the social networking site may use that information, as a controller of personal data, to create or update your profile, regardless of whether or not you are a user of that site. Data obtained in this way may be used by the social networking site, for example, for advertising purposes, market research, monitoring your behaviour or designing its own website. If you would like to find out more about any of the services provided by a third-party provider, please contact us by writing to: rodo@voneogroup.com.
8. Protection of personal data
Information obtained through the cookie mechanism and operating data may, in certain exceptional situations, constitute personal data within the meaning of the GDPR. Where the information indicated above is classified as personal data, the controller of that personal data is the Controller. Even where there is doubt as to whether a particular category of information constitutes personal data, the Controller implements mechanisms to protect that information as if it were personal data. The processing of the above categories of data to the extent necessary for the correct display of the website (strictly necessary cookies) is based on the so-called legitimate interest of the Controller (Article 6(1)(f) GDPR). For this purpose, log files may occasionally be analysed in order to:
- determine which browsers are used by persons visiting the Website,
- determine which tabs or subpages of the Website are visited or viewed most or least often,
- establish whether the Website contains any errors,
- prevent unauthorised access to the Website,
- prevent the distribution of malicious code,
- stop “denial of service” attacks,
- prevent damage to computer systems and electronic communication systems.
In the cases of processing of your personal data described above, you have the right to object. Recipients of data within this scope may include entities providing IT services to the Controller. The processing of data in connection with optional cookies (analytics, advertising and functional) and tracking pixels is based on your consent (Article 6(1)(a) GDPR). Consent to the storage of information on your end device and to access to such information is also required by the provisions of the Act – Electronic Communications Law (Prawo komunikacji elektronicznej). You may withdraw your consent at any time in the manner described in section 4; withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal. The providers of the tools indicated in section 7 may transfer data to the USA. In the case of providers certified under the EU-U.S. Data Privacy Framework, the basis for the transfer is Commission Implementing Decision (EU) 2023/1795 of 10 July 2023, and in all other cases it is the standard contractual clauses adopted by Commission Implementing Decision (EU) 2021/914. You can obtain a copy of the safeguards applied by contacting the Controller.
9. Deletion of operating data and of data obtained through the cookie mechanism
The retention period for cookies, i.e. the period after which they will be deleted, has been set out above. If, in the course of providing the services described above, we obtain your personal data, it will be deleted or anonymised no later than upon expiry of the limitation period for potential claims relating to the use of the Website, or earlier if you lodge an effective objection.