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Privacy Policy

The following Privacy Policy sets out the principles for storing and accessing data on Users’ Devices using the Service for the provision of electronic services by the Administrator and the principles for collecting and processing Users’ personal data that have been provided by them personally and voluntarily through the tools available in the Service.

§1 Definitions

  • Service – the “nuromed.pl” website operating at https://nuromed.pl.
  • External Service – websites of partners, service providers, or recipients cooperating with the Administrator.
  • Service/Data Administrator – the Service Administrator and Data Administrator (hereinafter Administrator) is the company “Nuromed sp. z o.o.” operating at the address: ul. DREWNOWSKA 62/5A 91-002 ŁÓDŹ, with the tax identification number (NIP): 7262703344, providing services electronically via the Service.
  • User – a natural person for whom the Administrator provides services electronically via the Service.
  • Device – an electronic device along with software through which the User gains access to the Service.
  • 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 information about 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 an 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, organization, 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 analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements.
  • Consent – the data subject’s consent 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, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed.
  • Pseudonymization – 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
  • Anonymization – Data anonymization is an irreversible process of data operations that destroys or overwrites “personal data” making it impossible to identify or associate a given record with a specific user or natural person.

§2 Data Protection Officer

Pursuant to Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer.

For matters relating to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

  • Internal Cookies – files placed and read from the User’s Device by the Service’s IT system.
  • External Cookies – files placed and read from the User’s Device by IT systems of external services. The scripts of external services that may place cookies on the User’s Device were deliberately placed in the Service through the scripts and services provided and installed in the Service.
  • Session Cookies – files placed and read from the User’s Device by the Service during one session of that Device. After the session ends, the files are deleted from the User’s Device.
  • Persistent Cookies – files placed and read from the User’s Device by the Service until they are manually deleted. These files are not deleted automatically after the end of the Device session unless the User’s Device configuration is set to delete cookies after the end of the Device session.

§4 Data Storage Security

  • Mechanisms for storing and reading Cookies – The mechanisms for storing, reading, and exchanging data between Cookies stored on the User’s Device and the Service are implemented through built-in web browser mechanisms and do not allow the collection of other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, trojans, and other worms to the User’s Device is also practically impossible.
  • Internal Cookies – the Cookies used by the Administrator 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.
  • External Cookies – The Administrator takes all possible actions to verify and select the service partners in the context of user security. The Administrator selects well-known, large partners with global social trust for cooperation. However, he does not have full control over the content of Cookies coming from external partners. For the security of the Cookie files, their content, and the licensed use by the installed scripts in the service, coming from external services, the Administrator is not responsible as far as the law allows. The list of partners is included in the further part of the Privacy Policy.
  • Cookie Control – The User can independently change the settings for saving, deleting, and accessing the data of saved cookies by any website at any time. Information on how to disable cookies in the most popular computer browsers is available on the website:
    • 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 Internet Explorer 11

The User can delete all cookies saved so far using the tools of the User’s Device through which the User uses the services of the Service at any time.

  • User Threats – The Administrator uses all possible technical measures to ensure the security of the data placed in cookies. However, it should be noted that ensuring the security of these data depends on both parties, including the activity of the User. The Administrator is not responsible for intercepting these data, impersonating the User’s session, or their deletion as a result of the User’s conscious or unconscious activity, viruses, trojans, and other spyware that may infect or have infected the User’s Device. Users should follow principles that increase their cybersecurity to protect against these threats.
  • Personal Data Storage – The Administrator ensures that he makes every effort to ensure that the processed personal data voluntarily entered by Users are secure, and access to them is limited and carried out in accordance with their intended purpose and processing goals. The Administrator also ensures that he makes every effort to secure the possessed data against loss by applying appropriate physical and organizational security measures.

§5 Purposes for Using Cookies

  • To improve and facilitate access to the Service.
  • Personalizing the Service for Users.
  • Conducting statistics (users, number of visits, types of devices, connections, etc.).

§6 Purposes of Personal Data Processing

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

  • Provision of electronic services:
    • Communication between the Administrator and Users regarding the Service and data protection.
    • Ensuring the legally justified interest of the Administrator.
  • Data about Users collected anonymously and automatically are processed for one of the following purposes:
    • Conducting statistics.
    • Ensuring the legally justified interest of the Administrator.

§7 External Service Cookies

The Administrator uses JavaScript scripts and web components of partners in the Service who may place their cookies on the User’s Device. Remember that you can decide about the allowed cookies that can be used by individual websites in your browser settings. Below is a list of partners or their services implemented in the Service, which may place cookies:

  • Conducting statistics:
    • Google Analytics
  • Other services:
    • Google Maps

Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, privacy policies, data processing purposes, and cookie usage methods at any time.

§8 Types of Collected Data

The Service collects data about Users. Some data are collected automatically and anonymously, and some data are personal data provided voluntarily by Users during registration for services offered by the Service.

  • Anonymous data collected automatically:

    • IP address
    • Browser type
    • Screen resolution
    • Approximate location
    • Open subpages of the service
    • Time spent on the relevant subpage of the service
    • Type of operating system
    • Previous subpage address
    • Referring page address
    • Browser language
    • Internet connection speed
    • Internet service provider
    • Demographic data (age, gender)

  • Data collected during registration:

    • First name / last name / nickname
    • Email address
    • Phone number
    • IP address (collected automatically)

  • Data collected when signing up for the Newsletter:

    • Email address

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

§9 Access to Personal Data by Third Parties

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

Access to data (usually based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the service, such as:

  • Hosting companies providing hosting or related services for the Administrator.

Data Processing Delegation – Hosting Services, VPS, or Dedicated Servers

The Administrator uses the services of an external hosting provider, VPS, or Dedicated Servers – LH sp. z o.o. All data collected and processed in the service are stored and processed in the provider’s infrastructure located in Poland. There is a possibility of data access as a result of maintenance work performed by the provider’s staff. Access to these data is regulated by the agreement concluded between the Administrator and the Service Provider.

§10 Methods of Personal Data Processing

  • Personal Data Provided Voluntarily by Users:

    • Personal data will not be transferred outside the European Union unless published as a result of individual User activities (e.g., entering a comment or post), making the data available to any person visiting the service.
    • Personal data will not be used for automated decision-making (profiling).
    • Personal data will not be resold to third parties.

  • Anonymous Data Collected Automatically:

    • Anonymous data (without personal data) will be transferred outside the European Union.
    • Anonymous data (without personal data) will not be used for automated decision-making (profiling).
    • Anonymous data (without personal data) will not be resold to third parties.

§11 Legal Bases for Personal Data Processing

The Service collects and processes Users’ data based on:

  • 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):

    • Art. 6 sec. 1 lit. a – the data subject has given consent to the processing of his or her personal data for one or more specific purposes.
    • Art. 6 sec. 1 lit. b – processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract.
    • Art. 6 sec. 1 lit. 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 16 July 2004 – Telecommunications Law (Journal of Laws 2004 No. 171, item 1800).

  • Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24, item 83).

§12 Personal Data Processing Period

  • Personal data provided voluntarily by Users:

    • As a rule, the indicated personal data are stored only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized within 30 days from the end of the provision of services (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.).
    • An exception is a situation that requires securing legally justified goals of further processing of these data by the Administrator. In such a case, the Administrator will store the indicated data, from the time of the request for their deletion by the User, for no longer than 3 years in the event of a violation or suspicion of a violation of the service regulations by the User.

  • Anonymous data (without personal data) collected automatically:

    • Anonymous statistical data, which do not constitute personal data, are stored by the Administrator for the purpose of service statistics for an indefinite period.

§13 Users’ Rights Related to Personal Data Processing

The Service collects and processes Users’ data based on:

  • Right of access to personal data:

    • Users have the right to obtain access to their personal data, which is realized upon request submitted to the Administrator.

  • Right to rectification of personal data:

    • Users have the right to request the Administrator to immediately correct personal data that is incorrect and/or complete incomplete personal data, which is realized upon request submitted to the Administrator.

  • Right to erasure of personal data:

    • Users have the right to request the Administrator to immediately delete personal data, which is realized upon request submitted to the Administrator. In the case of user accounts, the deletion of data involves the anonymization of data that enables the identification of the User. The Administrator reserves the right to withhold the execution of the data deletion request to protect the legally justified interest of the Administrator (e.g., when the User has violated the Regulations or the data was obtained as a result of correspondence conducted).
    • In the case of the Newsletter service, the User can independently delete their personal data using the link provided in each email message.

  • Right to restrict the processing of personal data:

    • Users have the right to restrict the processing of personal data in the cases specified in Art. 18 GDPR, including questioning the correctness of personal data, which is realized upon request submitted to the Administrator.

  • Right to data portability:

    • Users have the right to obtain from the Administrator the personal data concerning them in a structured, commonly used, and machine-readable format, which is realized upon request submitted to the Administrator.

  • 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 Art. 21 GDPR, which is realized upon request submitted to the Administrator.

  • Right to lodge a complaint:

    • Users have the right to lodge a complaint with the supervisory authority dealing with personal data protection.

§14 Contact with the Administrator

The Administrator can be contacted in one of the following ways:

  • Postal address – Nuromed sp. z o.o., ul. DREWNOWSKA 62/5A 91-002 ŁÓDŹ
  • Email address – biuro@nuromed.pl
  • Contact form – available at: nuromed.pl/#formularz

§15 Service Requirements

  • Restricting the saving and access to cookies on the User’s Device may cause some functions of the Service to malfunction.
  • The Administrator is not responsible for improperly functioning Service functions if the User in any way restricts the ability to save and read cookies.

§16 External Links

  • In the Service – articles, posts, entries, or user comments may contain links to external sites with which the Service Owner does not cooperate. These links and the sites or files indicated by them may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content found outside the Service.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to change this Privacy Policy at any time without the need to inform Users about it in the context of the use and application of anonymous data or the use of cookies.
  • The Administrator reserves the right to change this Privacy Policy in terms of personal data processing, of which it will inform Users who have user accounts or are subscribed to the newsletter service via email within 7 days of the changes being made. Continued use of the services means reading and accepting the introduced changes to the Privacy Policy. If the User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter.
  • The introduced changes to the Privacy Policy will be published on this subpage of the Service.
  • The introduced changes take effect upon their publication.

Privacy Policy