Privacy and Cookies Policy

If you have arrived here, it is a reliable sign that you value your privacy. We understand this very well, which is why we are providing you with a document in which you will find, in one place, the rules for the processing of personal data and the use of cookies and other tracking technologies in connection with the functioning of the b2b.eltap.pl website.

Some formal information to start with: the website administrator is ELTAP Spółka z ograniczoną odpowiedzialnością Sp.k., Mroczeń nr 203, 63-604 Baranów, entered in the National Court Register by the District Court Poznań - Nowe Miasto and Wilda in Poznań, IX Economic Division of the National Court Register, under KRS no.: 0000819333, NIP[TIN]: 6192050823, REGON: 385100074.

This Privacy Policy has been structured in the form of questions and answers. The choice of this form was dictated by the concern for clarity and legibility of the information presented to you. Below, you will find a table of contents of the document corresponding to the questions which we answer ono by one below. 1. Who is the controller of personal data? 2. Who can you contact about your personal data? 3. For what purposes do we process your personal data? 4. What information do we have on you? 5. What is 'Anonymous Information'? 6. How did we obtain your personal data? 7. Are your data safe? 8. How long will we keep your personal data? 9. Who are the recipients of your personal data? 10. Do we transfer your data to third countries? 11. Do we use profiling? Do we make automated decisions based on your personal data? 12. What rights do you have in relation to the processing of your personal data? 13. Do we use cookies and what are they actually? 14. On what basis do we use cookies? 15. Can you disable cookies? 16. For what purposes do we use our own cookies? 17. What third-party cookies are used? 18. Do we track your behaviour undertaken within our website? 19. Do we target you with targeted ads? 20. How can you manage your privacy? 21. Is there anything else you should know? 22. Is this Privacy Policy subject to change? 23. Annex: List of tools that use cookies

If you have any concerns about the Privacy Policy, you can contact us at any time by sending an email to office@eltap.com.

1: Who is the controller of your personal data?

The controller of your personal data is ELTAP Spółka z ograniczoną odpowiedzialnością Sp.k., Mroczeń nr 203, 63-604 Baranów, registered by the National Court Register by the District Court Poznań - Nowe Miasto and Wilda in Poznań, IX Economic Division of the National Court Register, under KRS number: 0000819333, NIP[TIN]: 6192050823, REGON: 385100074.

2: Who can you contact regarding the processing of your personal data?

As part of the implementation of a data protection system in our organisation, we have decided to not to appoint a Data Protection Officer due to the fact that it is not mandatory in our situation. For matters relating to data protection and privacy more broadly, you can contact the following email address office@eltap.com.

3: For what purposes do we process your personal data?

There are more than just one target. Below you will find a list of them, along with a more detailed discussion. We have also assigned the respective legal bases for processing to the various purposes:

Purpose of processing Discussion of the purpose of processing Legal basis

Order processing and contract handling When placing an order, you will need to provide the data necessary to process your order: e-mail address, full name, invoice details. In addition, the system used to handle the order process saves your IP number, which you used to place the order. Each order is saved in a database, which means that your personal data assigned to the order is also accompanied by order-related information such as the date and time of the order, order ID, transaction ID, subject of the order, price, method and date of payment. In connection with the conclusion of a contract, we also process your personal data in order to perform the services provided for in the contract that has been concluded. The extent of this data depends on which personal data are needed to perform the contract. When we receive your data in the performance of a contract, e.g. from an entity that employs you, we base such processing on a legitimate interest, which in this case is to ensure the efficient and effective processing of the concluded contract. In this case, we may process your identifying and contact data.

Article 6(1)(b) GDPR, Article 6(1)(f) GDPR

Handling complaints or withdrawals If you make a complaint or withdraw from the v=contract, you provide the personal data contained in the body of the complaint or withdrawal statement, which includes your name, home address, telephone number, e-mail address, bank account number. The provision of data is voluntary, but necessary to make a complaint or withdraw from the contract. Article 6(1)(c) GDPR, Article 6(1)(b) GDPR

Chat support We use LiveChat on our website. In doing so, we provide you with the opportunity to communicate with us via chat, relying on our legitimate interest in doing so. The processing of your personal data is necessary to provide you with customer support.

Article 6(1)(f) GDPR

Correspondence handling When you contact us by e-mail or via the contact forms, you naturally provide your personal data contained in the contents of the correspondence, in particular your e-mail address and your name. The provision of data is voluntary, but necessary in order to make contact. In this case, we rely on our legitimate interest in providing you with the opportunity to make contact.

Article 6(1)(f) GDPR

Fulfilment of tax and accounting obligations In connection with the performance of the contract, we also fulfil various tax and accounting obligations, in particular the issuing of an invoice, the inclusion of the invoice in our accounting records, the retention of records, etc. In order to issue an invoice, we process data such as name, company, business address, Tax Identification Number, among others. The provision of data required by tax law is necessary to fulfil the obligations indicated. Article 6(1)(c) of the GDPR in relation to the relevant tax law provisions

Creation of an archive We may create archives for the purposes of our operations: both in traditional and digital form. The archives include any personal data that we have processed in connection with you, so the scope of the archives may vary depending on what data has come to us. In this case, we rely on our legitimate interest in organising and structuring the personal data media.

Article 6(1)(f) GDPR

Defence, establishment or enforcement of claims The use of our website, as well as the conclusion of a contract with us, may give rise to certain claims on our side or yours in the future. Accordingly, we are entitled to process personal data for the purpose of defending, establishing or asserting claims. As part of this purpose, we may process any personal data that is related to the claim in question, so the extent of the processing may vary depending on what the claim relates to. In this case, we rely on our legitimate interest to protect our interests in this regard.

Article 6(1)(f) GDPR

Social media handling If you follow our social media profiles or interact with the contents that we publish on social media, we naturally see your data that is publicly available in your social media profile. We process this data only within the respective social network and only for the purpose of operating the respective social network, which is our legitimate interest. Your use of social media sites is subject to the rules and privacy policies of the administrators of those sites, and those administrators provide electronic services to you, fully independently and autonomously of us.

Article 6(1)(f) GDPR

Analysis and statistics using only Anonymous Information We carry out analytical and statistical activities using tools provided by external providers. As part of the analytical tools, we only have access to Anonymous Information. We base the processing of Anonymous Information on our legitimate interest to create, view and analyse statistics related to user activity on the website in order to draw conclusions for the subsequent optimisation of the website. From the tools level, we only have access to a set of statistics and information not assigned to specific individuals. For details on third-party supplier tools, please see the section on the tools we use.

Article 6(1)(f) GDPR

Own marketing using only Anonymous Information We carry out marketing activities using our own tools or those provided by external providers. As part of the marketing tools, we have access to your personal data or Anonymous Information, depending on the type of activities implemented. We base the processing of your personal data and Anonymous Information on our legitimate interest in carrying out marketing activities for the purpose of marketing our own products and services. In the case of external tools, we have access mainly to a set of statistics and information not assigned to specific people.. For details on third-party supplier tools, please see the section on the tools we use.

Article 6(1)(f) GDPR

Ensurance of the functioning of media players, social plug-ins and comments using only Anonymous Information On the website, we embed videos from external services, use social plug-ins and a comment handling system. All of these tools process Anonymous Information. We base the processing of Anonymous Information on our legitimate interest, which in this case is to provide the use of additional functionalities on the website – a media player, social plugins, commenting system. We do not have access to other information from the tools, nor do we need this information for anything - Anonymous Information is only processed so that media players, comments and social plug-ins can function. For details on third-party supplier tools, please see the section on the tools we use.

Article 6(1)(f) GDPR

Implementation of data protection obligations As a data controller, we are obliged to comply with data protection obligations. Accordingly, we may process your personal data, insofar as this is necessary for the performance of these obligations (e.g. when processing your request concerning your personal data). The extent of the data depends on what data we need to fulfil the obligation and prove compliance with the GDPR. Furthermore, in this case we also rely on our legitimate interest in securing the data necessary to demonstrate accountability.

Article 6(1)(c) GDPR, Article 6(1)(f) GDPR

4: What information do we have about you?

We have described the scope of the processing precisely for each processing purpose. Information in this regard can be found above in section 3 of the Privacy Policy.

5: What is "Anonymous Information"?

We use tools that collect a range of information about you related to your use of our website. This includes, in particular, the following information: ● information about the operating system and web browser, ● subpages viewed, ● time spent on the site, ● transitions between individual sub-pages, ● clicks on individual links, ● the source from which you go to the page, ● the age range you are in, ● your gender, ● your approximate location limited to the respective locality. ● your interests as determined by your online activity.

This information is referred to in this Privacy Policy as "Anonymous Information".

Anonymous Information by itself does not, in our view, have the character of personal data, as it does not allow us to identify you and we do not collate it with the typical personal data we collect about you. Nevertheless, given the strict jurisprudence of the Court of Justice of the European Union and the divided opinions among lawyers, as a precaution, in case the character of personal data is attributed to Anonymous Information, in the Privacy Policy we have also included detailed explanations regarding the processing of this information.

The processing of Anonymous Information allows us to provide you with the functionality available on the website. In addition, Anonymous Information is used for analytical and statistical purposes as well as for marketing purposes (e.g. creation of Custom Audience Groups on Facebook, setting up, targeting and directing of ads).

Anonymous information is also processed by tool providers under the terms of their terms of service and privacy policies. It may be used by these providers to provide, improve and manage our services, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, and personalise the content and advertising displayed on individual services, websites and applications. Please see the section on the tools we use for more detailed information related to this.

6: How did we obtain your personal data?

In most cases, you provide them to us yourself. For example, this is the case when you contact us by e-mail and also when you use the functionalities available on the website or on external services (e.g. social networks). In addition, some information about you may be automatically collected by the tools we use. Please see the section on the tools we use for details of the third-party providers' tools.

Furthermore, in exceptional cases, we may also obtain your personal data from other sources, e.g. when the entity that employs you indicates your data to us as a contact person for contractual matters, or when you represent an entity that enters into a contract with us.

7: Are your data safe?

We care about the security of your personal data. We analyse the risks involved in the various processes of processing your data and then implement appropriate security and personal data protection measures. We monitor the state of the technical infrastructure on an ongoing basis, train our staff, look at the procedures in place and make the necessary improvements.

8: How long will we keep your personal data?

We process your personal data for as long as it is justified within the framework of a given purpose for processing your personal data, and therefore processing periods vary depending on the purpose. Please note that the termination of the processing of your data for one purpose does not necessarily lead to the complete erasure or destruction of your personal data, as the same set of data may be processed for another purpose, for the period of time indicated for that purpose. Complete erasure or destruction of data occurs when we have completed all purposes and in other cases indicated in the GDPR.

Below you will find a description of the processing periods: ● Correspondence handling - Data relating to correspondence handling will be processed for the duration of the correspondence between us; ● Archive - Data related to the archive will be processed until the information contained in the archive is no longer relevant; ● Determination, investigation and defence of claims - Data related to claims will be processed until the claims expire, whereby the period of limitation for claims may vary according to the applicable law (e.g. for businesses it may be 3 years and for consumers 6 years); ● Social media - Data related to audience groups will be processed until you opt out of interacting with us on social media; ● Analytics and statistics - Data related to analytics and statistics will be processed until they are no longer relevant or you successfully object; ● Marketing activities - Data related to self-marketing will be processed until they are no longer relevant or you successfully object; ● Organisation of promotional campaigns - We process data related to the organisation of promotional campaigns for the time necessary to carry out the promotional campaign;
● Ancillary tools - Data related to ancillary tools will be processed until they are no longer useful or you successfully object; ● Data Protection Obligations - Data relating to personal data protection will be processed until they are no longer relevant, you have successfully lodged an objection or the expiry of the limitation period of our liability as data controller.

Where we process your personal data on the basis of consent you have given, you may withdraw such consent at any time: either by your action or by contacting us at the contact details provided. Please note that withdrawal of consent does not affect the lawfulness of the processing that had been carried out on the basis of consent prior to its withdrawal.

9: Who are the recipients of your personal data?

We would venture to say that modern business cannot do without services provided by third parties. We also make use of such services. Some of these services involve the processing of your personal data. Third-party service providers that are involved in the processing of your personal data are: ● Hosting provider that stores data on the server; ● Cloud computing service provider where files that may contain your personal data are stored; ● Provider of the mailing system in which your data are stored if you are a newsletter subscriber; ● Provider of the CRM system in which we store your data to improve the customer service process and for archiving purposes; ● Provider of the invoicing system in which your data are stored for invoicing purposes; ● Accounting office that processes your data visible on invoices; ● Maintenance provider who gains access to the data if the technical work carried out relates to areas where personal data are held; ● Other subcontractors who gain access to the data if the scope of their activities requires such access.

If the need arises, your data may be shared with a legal advisor or lawyer bound by professional secrecy. The need may arise from a legal need requiring access to your personal data.

Your personal data may also be forwarded to the tax authorities to the extent necessary for the fulfilment of tax and accounting obligations. This includes, in particular, all declarations, reports, statements and other accounting documents containing your personal data.

In addition, if necessary, your personal data may be made available to entities, authorities or institutions entitled to access the data under the law, such as police, security services, courts, public prosecutors' offices.

Your data is made available to courier companies to the extent necessary to deliver the order. These companies become independent controllers of your personal data.

Furthermore, when it comes to Anonymous Information, the providers of the tools or plug-ins that collect Anonymous Information have access to it. The providers of these tools are their own controllers of the data collected by them and may share this data under the provisions they set out in their own terms and conditions and privacy policies, over which we have no control.

10: Do we transfer your data to third countries or international organisations?

Yes, part of the processing of your personal data may involve transfers to third countries.

We transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular in the USA. The same may happen in the case of Anonymous Information. The providers of these tools guarantee an adequate level of protection of personal data through the relevant compliance mechanisms provided for by the GDPR, in particular through the use of standard contractual clauses.

11: Do we use profiling? Do we make automated decisions based on your personal data?

We do not make decisions to you that are based solely on automated processing, including profiling, that would produce legal effects or similarly materially affect you. Yes, we do use tools that may take certain actions depending on the information collected through tracking mechanisms, but we consider that these actions do not materially affect you as they do not differentiate your situation as a customer, do not affect the terms of the contract you may enter into with us, etc.

Using certain tools, we can, for example, target you with personalised ads based on your previous activities on the website or suggest products that may be of interest to you. This is known as behavioural advertising. We encourage you to learn more about behavioural advertising, particularly with regard to privacy issues. You will find detailed information, including the possibility of managing your settings with regard to behavioural advertising, here.

12: What rights do you have in relation to the processing of your personal data?

The GDPR grants you the following potential rights in relation to the processing of your personal data: ● The right to access and receive a copy of your data; ● The right to rectification (amendment) of your data; ● The right to erasure (if, in your opinion, there are no grounds for us to process your data, you can request that we erase it); ● The right to restrict processing (you can request that we restrict processing to only storing your data or carrying out activities agreed with you if, in your opinion, we have inaccurate data or are processing it unduly); ● The right to object to processing (you have the right to object to processing on the basis of a legitimate interest; you should indicate the particular situation which you think justifies us stopping the processing covered by the objection; we will stop processing your data for these purposes unless we demonstrate that the grounds for our processing override your rights or that your data are necessary for us to establish, assert or defend our claims); ● The right to data portability (you have the right to receive from us in a structured, commonly used machine-readable format the personal data you have provided to us on the basis of a contract or your consent; you can have this data sent directly to another entity); ● The right to withdraw your consent to the processing of your personal data if you have previously given such consent; ● The right to lodge a complaint with a supervisory authority (if you find that we are processing your data unlawfully, you may lodge a complaint to the President of the Office for Personal Data Protection or any other competent supervisory authority).

The rules related to the exercise of the rights indicated above are described in detail in Articles 16-21 of the GDPR. We encourage you to familiarise yourself with these provisions. For our part, we consider it necessary to explain to you that the rights indicated above are not absolute and you will not be entitled to them in relation to all processing activities of your personal data.

We emphasise that one of the rights indicated above is always available to you: if you consider that we have violated data protection regulations in the processing of your personal data, you have the possibility to lodge a complaint with a supervisory authority (the President of the Office for Personal Data Protection).

13: Do we use cookies and what are they actually?

Our website, like almost all other websites, uses cookies. Cookies are small textual files stored on your terminal device (e.g. computer, tablet, smartphone) that can be read by our ICT system (first-party cookies) or by third-party ICT systems (third-party cookies). Specific information can be recorded and stored in cookies, which can then be accessed by ICT systems for specific purposes.

Some of the cookies we use are deleted when your browser session ends, i.e. when you close your browser (so-called session cookies). Other cookies are stored on your terminal device and enable your browser to be recognised the next time you visit the website (persistent cookies).

If If you want to learn more about cookies as such, you can read, for example, this material.

14: On what basis do we use cookies?

We use cookies on the basis of your consent, except where cookies are necessary for the proper provision of an electronic service to you. Cookies that are not necessary for the correct provision of the electronic service remain blocked until you have given your consent to the use of cookies. When you visit the website for the first time, we display a message asking for your consent together with the possibility to manage cookies, i.e. to decide which cookies you agree to and which you want to block.

15: Can you disable cookies?

Yes, you can manage your cookie settings within your web browser. You can block all or selected cookies. You can also block cookies for specific sites. You can also delete previously saved cookies and other site and plug-in data at any time.

Web browsers also offer the option of incognito mode. You can use this if you do not want information about pages visited and files downloaded to be saved in your browsing and download history. Cookies created in incognito mode are deleted when you close all windows in this mode.

Browser plug-ins are also available to control cookies, such as Ghostery. The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc.

In addition, there are tools available on the internet to control certain types of cookies, in particular to collectively manage behavioural advertising settings.

We also give you the possibility to control your cookies directly from our website. We have implemented a special mechanism for managing cookies that allows you to block those cookies that you do not wish.

Please note that disabling or restricting cookies may prevent you from using some of the features available on our website and may cause difficulties in using the website, as well as many other websites that use cookies. For example, if you block social media plug-in cookies, the buttons, widgets and social features implemented on my website may not be available to you.

16: For what purposes do we use our own cookies?

First-party cookies are used to ensure the correct functioning of the various mechanisms of our own website, such as the correct transmission of the forms visible on the website, the handling of newsletter forms, etc.

First-party cookies also store information about the cookie settings you have defined via our own cookie management mechanism.

17: What third-party cookies are used?

A list of tools that require the use of cookies and a description of the cookies used can be found in the Appendix to this Privacy Policy.

18: Do we track your behaviour undertaken on our website?

Yes, we use tools from third-party providers that involve the collection of information about your activities on our website. These tools are described in detail in the Appendix to this Privacy Policy.

19: Do we target you with targeted ads?

Yes, we use third-party vendor tools where we can target advertising to specific target groups defined based on various criteria such as age, gender, interests, profession, job, activities previously undertaken on our sites. These tools are described in detail in the Appendix to this Privacy Policy.

20: How can you manage your privacy?

The answer to this question can be found in many places in this Privacy Policy where we describe individual tools, behavioural advertising, consent to cookies, etc. Nevertheless, we have once again gathered this information in one place for your convenience. Below you will find a list of options for managing your privacy. ● cookie settings within your internet browser; ● browser plug-ins supporting cookie management, e.g. Ghostery; ● additional cookie management software; ● incognito mode in the web browser; ● behavioural advertising settings, e.g. youronlinechoices.com; ● the mechanism for managing cookies from our website; ● Google Analytics Opt-out: https://tools.google.com/dlpage/gaoptout; ● Google Ads Settings: https://adssettings.google.com/;

21: Is there anything else you should know?

As you can see, the topics of personal data processing, the use of cookies and the management of privacy in general are quite complex. We have done our best to ensure that this document provides you with the most far-reaching knowledge on the issues that are important to you. If anything is unclear to you, you would like to find out more or simply discuss your privacy, please email us at: office@eltap.com.

22: Is this Privacy Policy subject to change?

Yes, we may modify this Privacy Policy, in particular due to changes in technology and changes in legislation. If we have your email address, you will receive an email about any changes to the Privacy Policy. In addition, all archived versions of the Privacy Policy are linked below.

Annex to the Privacy Policy

LIST OF TOOLS THAT USE COOKIES

Name of the tool Description of operation and cookies

Google Tag Manager We use the Google Tag Manager tool provided by the U.S. company Google LLC to manage tags and script loading within the website. Google Tag Manager, as a tool by itself, does not collect any information beyond that necessary for its proper operation, but is responsible for loading the other scripts described below.

Google Analytics We use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. In order to use Google Analytics, we have implemented a special Google Analytics tracking code in the code of the website. The tracking code uses cookies from Google LLC concerning the Google Analytics service. You can block the Google Analytics tracking code at any time by installing a browser add-on provided by Google. Google Analytics automatically collects information about your use of the website. The information collected in this way is usually transmitted to and stored on Google servers, which may be located around the world. Due to the IP address anonymisation that we have activated, your IP address is shortened before being passed on. Only in exceptional cases is the full IP address transmitted to Google's servers and only shortened there. The anonymised IP address transmitted by your browser within the scope of Google Analytics is generally not combined with other Google data. We emphasise that within Google Analytics we only have access to Anonymous Information. Google Analytics and Google Analytics 360 services have been certified to the independent security standard ISO 27001. ISO 27001 is one of the most widely recognised standards in the world and certifies that the systems operating Google Analytics and Google Analytics 360 meet the relevant requirements. If you are interested in the details related to Google's use of data from sites and applications that use Google services, I encourage you to read this information.

Google Merchant Center We use the functions available as part of the Google Merchant Center service provided by the US company Google LLC. When you visit our website, a Google device is automatically left on your device which collects information about your activity on our website. Merchant Center is a tool for uploading product data and shop information. It also allows them to be made available in product advertisements and other Google services. This means that you may see banners displaying information about our products and prices as you access various websites. This helps us to run personalised product campaigns so that we reach an audience that is actually interested in our goods. If you do not wish to receive personalised ads, you can manage your ad settings directly on the Google website: https://adssettings.google.com/. If you are interested in details related to Google's use of data from sites and applications that use Google services, we encourage you to read this information.

LiveChat To support the customer in the purchasing process, we have installed a plug-in on our platform for chatting with customers. We use the LiveChat solution, which is provided by LiveChat, Inc. based at 101 Arch Street, 8th Floor, Boston MA 02110, United States of America. The chat provider uses cookies, which are automatically stored during your use of the tool. The cookies enable a quick confirmation of the identity of the users and make the use of the chat much easier and more widely available. Cookies are used by LiveChat, Inc. for the sole purpose of personalising a specific user.

Please refer to the solution provider's documents for details on how LiveChat processes your personal data: • Terms of Use: https://www.livechat.com/legal/terms-of-use/ • GDPR: https://www.livechat.com/legal/gdpr-faq/ • Privacy Policy: https://www.livechat.com/legal/privacy-policy/

Microsoft Clarity We use the Microsoft Clarity tool to better understand your needs and to optimise our website for your user experience. The tool is provided by Microsoft Corporation. Microsoft Clarity records every visitor to our site and enables us to play a video of their movement around our site, as well as generate so-called heat maps.

While using Microsoft Clarity tools we do not have access to information that allows us to your

identification, as Microsoft Clarity does not record the process of filling in the forms intended for the transfer of personal data. In order to use Microsoft Clarity, we have implemented a special Microsoft Clarity tracking code in the code of our website. The tracking code uses cookies from Microsoft Corporation. The information collected through cookies is stored by Microsoft as part of a pseudonymous user profile. Neither Microsoft nor we use this information to identify you. If you are interested in details related to data processing within Microsoft Clarity, we encourage you to read these explanations.

SALESmanago SALESmanago is a Customer Engagement platform for effective online marketing and is provided by Benhauer Sp. z o.o. with its registered office in Kraków, Grzegórzecka 21 Street, registered in the register of entrepreneurs kept by the XI Economic Department of the National Court Register of the District Court for Kraków-Śródmieście in Kraków under the number 0000523346, REGON 122334666, NIP[TIN] 6762447754. SALESmanago uses cookies to collect information about consent to web push, data about visits (e.g. information about the first visit to the shop's website), as well as information about forms displayed on the website. Data from cookies is stored for a period of between one and ten years. Please refer to the solution provider's documents for detailed information on the rules for processing your personal data within SALESmanago: · Terms of Use: SALESmanago Terms and Conditions - SALESmanago - Customer Engagement Platform for ambitious eCommerce marketing teams · Privacy Policy: Privacy policy - SALESmanago - Customer Engagement Platform for ambitious eCommerce marketing teams