Privacy Policy

§1 General information

1. administrator - the administrator of personal data is Richter Motors Poland Sp. z o.o.
2. personal data - information about a natural person identified or identifiable through one or more specific factors determining physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data location, internet identifier, and information collected through cookies and other similar technology.
3. Policy - this Privacy Policy.
4. the DPA - Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27. 2016 on the protection of natural persons in relation to the processing of personal data and on the on the free flow of such data and repealing Directive 95/46/EC.
5. service - the website operated by the Administrator at www.richtermotors.com and auctions.richtermotors.com
6. User - any natural person visiting the Service or using one or more of the services or functionalities described in the Policy.

§2 Data processing in connection with the use of the Site

1. In connection with the User's use of the Website, the Administrator collects data to the extent necessary to provide the individual services offered, as well as information about the User's activity on the Site.
2. The following describes in detail the principles and purposes of processing Personal Data collected during the User's use of the Website.

§3 Purposes and legal basis of processing in the Service and use of the Service.

1. Personal Data of all persons using the Service (including IP address or other identifiers and information collected through cookies or other similar technologies), and who are not registered Users (i.e. persons who do not have a profile on the Service), are processed by the Administrator:
   1. in order to provide services electronically in the scope of providing Users with access to content collected in the Service - then the legal basis for processing is the necessity of processing for the performance of the contract (legal basis for processing: Article 6(1)(B) RODO);
   2. for analytical and statistical purposes - then the legal basis of processing is the legally legitimate interest of the Administrator (legal basis for processing: Article 6(1)(F) RODO), consisting in conducting analysis of Users' activities, as well as their preferences in order to improve functionalities used and services provided;
   3. for the purpose of possible establishment and investigation of claims or defense against claims - the legal basis for processing is legal basis for processing is the legitimate interest of the Administrator (legal basis processing: Article 6(1)(F) of the RODO), consisting in the protection of its rights;
2. the User's activity on the Service, including his/her Personal Data, is recorded in logs system logs (a special computer program used to store a chronological record containing information about events and activities that relate to the IT system used to provide services by the Administrator). The information collected in the logs information is processed primarily for purposes related to the provision of services. The Administrator also processes them for technical, administrative purposes, for the purposes of ensuring the security of the IT system and the management of this system, as well as for analytical and statistical purposes - in this regard, the legal basis for processing is the legally legitimate interest of the Administrator (legal basis for processing: Article 6(1)(F) RODO).

§4 Mechanisms and methods of data processing and registration on the Website

1. Persons who register on the Website are asked to provide the data necessary to creation and operation of the account. In order to facilitate operation, the User may, using the functionalities made available to him/her within his/her account, provide additional data. Such data can be deleted at any time. Provision of data marked as mandatory is required in order to create and operate an account, and their failure to do so will result in the inability to create an account. account. Provision of other data is voluntary.
2. Personal data are processed:
   1. in order to provide services related to the maintenance and operation of an account on the Website - the legal basis for processing is the legal basis for processing is the necessity of processing to perform the contract (legal basis processing: Article 6(1)(b) of the RODO);
   2. for analytical and statistical purposes - the legal basis of processing is the legally legitimate interest of the Administrator (legal basis for processing: Article 6(1)(f) RODO), consisting in conducting analyses of Users' activity on the Site and the way they use their account, as well as Users' preferences in order to improve the functionalities used;
   3. for the purpose of possible establishment and investigation of claims or defense against claims - the legal basis for processing is the legitimate interest of the Administrator (legal basis for processing: Article 6(1)(f) RODO), consisting in the protection of its rights;
   4. for marketing purposes of the Administrator and other entities - the principles of processing Personal Data for marketing purposes are described in the MARKETING section.
3. If a User posts any Personal Data of other persons (including their name, address, telephone number or e-mail address) on the Website, he/she may do so only under the condition that he/she does not violate the laws and personal rights of such persons.

§5 Placing orders

1. Placing an order (e.g. purchase of goods or services - if the Administrator provides such a possibility) by a User of the Website involves processing of his/her Personal Data. Provision of data marked as mandatory is required in order to accept and process the order, and failure to provide such data will result in the order not being processed. Provision of other data is optional.
2. Personal Data shall be processed:
   1. for the purpose of carrying out the order placed - the legal basis for processing is the necessity of processing for the performance of the contract (legal basis for processing: Article 6(1)(b) of the RODO);
   2. in order to carry out statutory obligations incumbent on the Administrator, arising in particular from tax and accounting regulations - the legal basis for processing is a legal obligation (legal basis for processing: Article 6(1)(c) RODO);
   3. for analytical and statistical purposes - the legal basis for processing is the legitimate interest of the Administrator (legal basis for processing: Article 6(1)(f) RODO), consisting of conducting analysis of Users' activity on the Website, as well as Users' shopping preferences in order to improve the functionalities used;
   4. for the purpose of possible establishment and investigation of claims or defense against claims - the legal basis for processing is the legitimate interest of the Administrator (legal basis for processing: Article 6(1)(f) RODO), consisting in the protection of its rights.

§6 Contact via form

1. The Administrator shall provide the possibility to contact the Administrator using electronic contact forms. Using the form requires the User to provide Personal Data necessary to contact the User and respond to the inquiry. The User may also provide other data in order to facilitate contact or service the inquiry. Provision of data marked as mandatory is required in order to accept and service the inquiry, and failure to provide such data will result in the impossibility of service. Provision of other data is voluntary.
2. Personal data are processed in order to identify the sender and handle his/her inquiry sent through the form provided - the legal basis for processing is the necessity of processing for the performance of the service contract (legal basis for processing: Article 6(1)(B) RODO).

§7 Marketing

1. The Administrator processes Users' Personal Data in order to carry out marketing activities, which may consist in:
   1. displaying marketing content to the User that is not tailored to the User's preferences (contextual advertising);
   2. targeting e-mail notifications of interesting offers or content, which in some cases contain commercial information (newsletter service);
   3. conducting other types of activities related to direct marketing of goods and services (sending commercial information by e-mail and telemarketing activities).
2. In order to carry out marketing activities, the Administrator in some cases uses profiling. This means that through automatic data processing, the Administrator, creates a profile of the User and, based on the collected information, evaluates selected factors about Users (e.g. e-mail address, order history, type of device, technology used, frequency of visits, vehicle model) in order to analyze their behavior as buyers or create a purchase forecast for the future. This allows us to better tailor the content displayed to the individual preferences and interests of the User.
3. The Administrator processes Users' Personal Data for marketing purposes in connection with directing contextual advertising (i.e. advertising that is not tailored to the User's preferences) to Users. The processing of Personal Data then takes place in connection with the realization of the Administrator's legitimate interest (legal basis for processing: Article 6(1)(f) RODO).

§8 Newsletter

1. The Administrator shall provide the newsletter service on the terms and conditions specified in the regulations to persons who have provided their e-mail address for this purpose. Provision of data is required in order to provide the newsletter service, and failure to do so will result in the inability to send the auctions. This form of communication with the User may include profiling. This means that through automatic data processing, the Administrator, creates a profile of the User and, based on the collected information, evaluates selected factors about Users (e.g. e-mail address, order history, type of device, technology used, frequency of visits) in order to analyze their behavior as buyers or create a purchase forecast for the future. This allows it to better tailor the content sent to the individual preferences and interests of the User.
2. Personal data is processed:
   1. for the purpose of providing the newsletter mailing service - the legal basis for processing is the necessity of processing for the performance of the contract (legal basis for processing: Article 6(1)(b) RODO);
   2. for directing marketing content to the User as part of the newsletter - the legal basis for processing, including using profiling, is the legitimate interest of the Administrator (legal basis for processing: Article 6(1)(f) RODO) in connection with the consent to receive the newsletter;
   3. for analytical and statistical purposes - the legal basis for processing is the legitimate interest of the Administrator, (legal basis for processing: Article 6 (1) (f) RODO), consisting of conducting analysis of Users' activity in the Service in order to improve the applied functionalities;
   4. for the purpose of possible establishment and investigation of claims or defense against claims - the legal basis for processing is the legitimate interest of the Administrator, (legal basis for processing: Article 6(1)(f) RODO), consisting of the protection of its rights.

§9 Direct marketing

1. The User's personal data may also be used by the Administrator to direct marketing content to the User through various channels, i.e. via email, MMS / SMS or telephone. Such activities are undertaken by the Administrator only if the User has given his/her consent, which can be withdrawn at any time.
2. The Administrator may, in some cases, also carry out direct marketing via snail mail. With respect to this type of marketing, the User has the right to object.

§10 Social networks

1. The Administrator processes Personal Data of Users visiting the Administrator's profiles maintained on social media (Facebook, YouTube, Instagram, Twitter, Pinterest, TikTok). The data is processed exclusively in connection with the operation of the profile, including for the purpose of informing Users about the Administrator's activities and promoting various events, services and products. 2.The legal basis for the Administrator's processing of Personal Data for this purpose is its legitimate interest (legal basis for processing: Article 6(1)(f) of the RODO), which is to promote its own business.

§11 Posting comments

1. The Administrator provides the possibility of posting comments on the Website. Providing data in the fields marked as "required field" is voluntary, but failure to do so will result in the inability to post a comment. Data publicly visible to all Users are: nickname User.
2. Personal data is processed for the purpose of publishing a comment within the functionalities provided by the Administrator - the legal basis for processing is the necessity of processing to provide the service (legal basis for processing: Article 6(1)(b) RODO).

§12 Cookies

1. Cookies are small text files installed on the User's device when browsing the Website. Cookies collect information to facilitate the use of the website - e.g. by remembering the User's visits to the Website and actions performed by him.
2. The Administrator uses so-called service cookies primarily to provide the User with services provided electronically and to improve the quality of these services. In this regard, the Administrator and other entities providing analytical and statistical services to the Administrator use cookies, storing information or accessing information already stored in the User's telecommunications terminal equipment (computer, telephone)
3. Cookies used for this purpose include:
   1. user input cookies for the duration of the session (session ID);
   2. authentication cookies used for services requiring authentication for the duration of the session (authentication cookies);
   3. security cookies, such as those used to detect authentication abuse (user centric security cookies);
   4. multimedia player session cookies (e.g. flash player cookies), for the duration of the session (multimedia player session cookies);
   5. persistent user interface customization cookies for the duration of the session or slightly longer (user interface customization cookies).

§13 Analytical and marketing tools used by Administrator's Partners.

1. The Administrator and its Partners apply various solutions and tools used for analytical and marketing purposes. Below you will find basic information about these tools. Detailed information in this regard, on the other hand, can be found in the privacy policy of the respective partner.
2. Google Analytics cookies are cookies used by Google to analyze your use of the Website, to create statistics and reports on the functioning of the Website. Google does not use the collected data to identify the User, nor does it combine this information to enable identification. Detailed information about the scope and principles of data collection in connection with this service can be found at the following link: https://www.google.com/intl/pl/policies/privacy/partners.
3. Google Ads is a tool that allows measuring the effectiveness of advertising campaigns implemented by the Administrator, allowing analytics of such data as keywords or number of unique users. The Google Ads platform also allows us to display our ads to people who have visited the Service in the past. Information on Google's data processing for the above service is available at the following link: https://policies.google.com/technologies/ads?hl=pl
4. Facebook Pixels is a tool for measuring the effectiveness of advertising campaigns implemented by the Administrator on Facebook. The tool allows for advanced data analytics to optimize the Administrator's activities also using other tools offered by Facebook. Detailed information on data processing by Facebook can be found at this link: https://pl-pl.facebook.com/help/443357099140264?helpref=about_content
5. HotJar is a tool that allows the Administrator to conduct analysis of User activity on the Service, such as through surveys or satisfaction surveys, and by anonymously collecting information about clicks on particular places on the Service. The tool does not allow for User identification. Detailed information about the data collected through HotJar and how to deactivate User monitoring is available at the following link: https://www.hotjar.com/privacy
6. DoubleClick is a tool that allows measuring the effectiveness of advertising campaigns implemented by the Administrator (Google Ads campaigns) and analytics of its results.
7. YouLead is a marketing automation tool.
8. Google Tag Manager is a tool that allows the Administrator to conduct analysis of User activity by enabling management of other analytical or marketing tools used by the Administrator.
9. Twitter Ads is a tool that allows us to measure the effectiveness of advertising campaigns implemented by the Administrator by allowing analytics such as keywords or number of unique users. The Twitter Ads platform also allows us to display our ads to people who have visited the Service in the past. Information on Twitter's data processing for the above service is available at the following link: https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
10. You Tube Ads is a tool that allows measuring the effectiveness of advertising campaigns carried out by the Administrator, allowing analytics such as keywords or number of unique users. The Google Ads platform also allows us to display our ads to people who have visited the Service in the past. Information on Google's data processing for the above service is available at the following link: https://policies.google.com/technologies/ads?hl=pl
11. The User may at any time withdraw consent to the use of cookies to collect data through them, including accessing data stored on the User's device.
12. Consent is not required only in the case of cookies, the use of which is necessary for the provision of telecommunications service (data transmission to display content).
13. Withdrawal of consent for the use of cookies is possible through browser settings. Detailed information on this subject can be found at the following links:
    1. Internet Explorer: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies
    2. Mozilla Firefox: http://support.mozilla.org/pl/kb/ciasteczka
    3. Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
    4. Opera: http://help.opera.com/Windows/12.10/pl/cookies.html
    5. Safari: https://support.apple.com/kb/PH5042?locale=en-GB
14. The user may at any time verify the status of his/her current privacy settings for the browser used using the tools available at the following links:
    1. http://www.youronlinechoices.com/pl/twojewybory
    2. http://optout.aboutads.info/?c=2&lang=EN

§14 Period of personal data processing

1. The period of data processing by the Administrator depends on the type of service provided and the purpose of processing. As a rule, data shall be processed for the duration of the service provided or the execution of the order, until the withdrawal of the consent given or the filing of an effective objection to data processing in cases where the legal basis for data processing is the legitimate interest of the Administrator.
2. The period of data processing may be extended in cases where the processing is necessary for the establishment and assertion of possible claims or defense against claims, and thereafter only in the case and to the extent required by law. After the expiration of the processing period, the data shall be irreversibly deleted or anonymized.

§15 User's rights

1. The User shall have the right to access the content of the data and to request rectification, erasure, restriction of processing, the right to data portability and the right to object to the processing of the data, as well as the right to lodge a complaint with the supervisory authority for the protection of Personal Data.
2. To the extent that the User's data is processed on the basis of consent, this consent may be withdrawn at any time by contacting the Administrator or using the functionalities provided on the Website.
3. The User has the right to object to the processing of data for marketing purposes, if the processing is carried out in connection with the legitimate interest of the Administrator, and also - for reasons related to the User's particular situation - in other cases where the legal basis for data processing is the Administrator's legitimate interest (e.g. in connection with the implementation of analytical and statistical purposes).
4. In order to withdraw your consent, you may contact us by sending an email to: g.kucza@richtermotors.com

§16 Recipients of data

1. In connection with the performance of services, Personal Data will be disclosed to external entities, including in particular suppliers responsible for the operation of IT systems, entities such as banks and payment operators, entities providing accounting services, couriers (in connection with the execution of the order) and entities affiliated with the Administrator and marketing agencies.
2. If a comment is added to the Website, the User's nickname or abbreviated username will be made public along with the content of the comment.

§17 Transfer of Data outside the EEA

1. The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Administrator transfers Personal Data outside the EEA only when necessary and with an adequate level of protection, primarily by:
   1. cooperating with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the determination of an adequate level of protection for Personal Data;
   2. applying standard contractual clauses issued by the European Commission;
   3. application of binding corporate rules approved by the relevant supervisory authority;
   4. in the case of transfer of data to the US, cooperation with entities participating in the Privacy Shield program (Privacy Shield), approved by a decision of the European Commission.
2. The Administrator shall always inform about the intention to transfer Personal Data outside the EEA at the stage of collection.

§18 Security of personal data

1. The Administrator shall, on an ongoing basis, conduct a risk analysis to ensure that Personal Data is processed by the Administrator in a secure manner - ensuring, first and foremost, that only authorized persons have access to the data and only to the extent necessary for their tasks. The Administrator shall ensure that all operations on Personal Data are recorded and performed only by authorized employees and associates.
2. The Administrator shall take all necessary measures to ensure that also its subcontractors and other cooperating entities guarantee the application of appropriate security measures whenever they process Personal Data on behalf of the Administrator.

§19 Terms of Service

1. Contact with the Administrator is possible via e-mail address g.kucza@richtermotors.com or mailing address 41 Gliwicka Street, 44-171 Taciszów, Gliwice.
2. The Administrator has appointed a Personal Data Protection Inspector in the person of Grzegorz Kucza, with whom you can contact via e-mail g.kucza@richtermotors.com or by correspondence to the Administrator's address with the note "Personal Data Protection Inspector" in any matter concerning the processing of Personal Data.
3. You have the right to access the content of your data and the right to rectify, erase, restrict processing, the right to data portability, the right to object (e.g. if your data are processed on the basis of your consent, or for marketing purposes or sharing your data); you have the right to withdraw your consent at any time. In order to withdraw your consent, please send an e-mail to g.kucza@richtermotors.com. Your provision of personal data is fully voluntary. Failure to provide personal data will result in the inability to fully perform the obligations assumed by the name of the company under the contracts concluded with you.

§20 Change of privacy policy

1. The Policy shall be continuously reviewed and, if necessary, updated before the administrator.
2. the current version of the Policy was adopted and is effective 24.09.2022