Privacy policy

2. Scope of the Policy 

This Policy applies to personal data processed by TME in connection with the use of the Website, including in particular when:

• browsing content available on the Website, 

• using the contact form or other contact channels provided on the Website, 

• using cookies and similar technologies, 

• using specific categories of cookies upon granting appropriate consent, 

• analyzing traffic and user behavior on the Website.

3. Types of data we may process

In connection with the use of the Website, the Controller may process in particular:

•  identification and contact data voluntarily provided by the user, such as name, surname, email address, phone number, and message content, 

• technical data related to the device and browser, 

•  operational and statistical data, such as:

•  IP address, 

•  online identifiers, 

•  device type, 

•  browser type and version, 

•  operating system, 

•  language settings, 

•  source of access to the Website, 

•  page views, 

•  time spent on the Website, 

•  navigation paths within the Website, 

•  events related to user activity on the Website.

The scope of data depends on how the Website is used and on the privacy settings selected by the user, including consents given for the use of cookies.

4. Purposes and legal bases for data processing

1. Handling correspondence and responding to inquiries

If a user contacts the Controller via the contact form, email, or otherwise, data is processed in order to:

• respond to the inquiry, 

• handle the request, 

• conduct further correspondence related to the matter. 

Legal basis:
Article 6(1)(f) GDPR – the Controller’s legitimate interest in handling communication and responding to inquiries.
Where the message concerns entering into or performing a contract, Article 6(1)(b) GDPR may also apply.

2. Ensuring proper operation and security of the Website

Technical data and automatically collected information may be processed in order to:

• ensure proper functioning of the Website, 

• maintain service continuity and security, 

• detect abuse, unauthorized access attempts, and security incidents, 

• create technical and diagnostic logs.

Legal basis:
Article 6(1)(f) GDPR – legitimate interest of the Controller in ensuring security, integrity, and proper functioning of the Website.

3. Statistics and analysis of Website usage

In connection with the use of analytical tools based on cookies or similar technologies, the Controller may analyze how the Website is used in order to:

•  measure the number of visits, 

• assess the popularity of content and sections, 

• analyze traffic sources, 

• improve the structure, functionality, and content of the Website, 

• develop the Website in line with users’ actual interests.

 This may involve the use of analytical tools such as Google Tag Manager and Google Analytics 4.  

Legal basis:

where cookies or similar technologies requiring consent are used: Article 6(1)(a) GDPR – user consent, 

for limited internal analytics not requiring consent: Article 6(1)(f) GDPR – legitimate interest in developing and optimizing the Website.

4. Establishing, exercising, or defending legal claims

Data may also be processed for the purpose of establishing, exercising, or defending legal claims.

Legal basis:
Article 6(1)(f) GDPR – legitimate interest of the Controller.

5. Information about statistical data of visitors

To develop the Website in line with users’ needs, we may collect statistical information regarding the use of poweredby.tme.eu.

Statistical data may include:

• number of users visiting the Website, 

• number of visits and page views, 

• visited subpages, 

• sequence of viewed content, 

• approximate location based on IP address, 

• duration of visits, 

• device, browser, and operating system type, 

• traffic sources (e.g. direct, search engine, referral, campaign), 

• user interaction data. 

This data is used solely to:

• analyze Website traffic, 

• measure the effectiveness of published content, 

• optimize Website performance, 

• improve user experience, 

• plan further development of the Website. 

Where statistical data is collected via analytical cookies or similar technologies, such tools are activated only after obtaining user consent via the cookie consent management platform.

Users may at any time:

• give consent, 

• refuse consent, 

• change preferences, 

• withdraw consent. 

Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

6. Cookies and similar technologies

The Website uses cookies and similar technologies such as local storage, pixel tags, analytical scripts, and other technologies enabling the storage and reading of information on the user’s device.

The following categories of cookies may be used:

a) Necessary

Required for proper operation of the Website and provision of basic functionalities. These do not require user consent where strictly necessary.

b) Preference

Allow remembering user choices and adjusting the Website accordingly (e.g. language settings).

c) Statistical

Enable collection of information about how the Website is used (e.g. number of visits, traffic sources, user behavior) to improve the Website.

d) Marketing

May be used to tailor promotional content, measure effectiveness, and integrate external services.

7. Data recipients

Personal data may be shared with entities cooperating with the Controller, in particular:

• IT and hosting service providers, 

• entities maintaining or developing the Website, 

• providers of analytical and technological tools, 

• providers of cookie consent management systems, 

• entities supporting communication and Website operations, 

• authorized public authorities where required by law. 

These entities process data under appropriate agreements and only in accordance with the Controller’s instructions or as independent controllers where applicable.

8. Transfers outside the European Economic Area

Due to the use of certain analytical, technological, or cloud tools (including Google Tag Manager and Google Analytics 4 provided by Google LLC), data may be transferred outside the EEA.

In such cases, the Controller ensures appropriate safeguards required by law, including:

• adequacy decisions, 

• standard contractual clauses, 

• other GDPR-compliant safeguards. 

In the case of Google LLC, data transfers are based on an adequacy decision of the European Commission under the EU–US Data Privacy Framework.

9. Data retention period

Personal data is retained for the period necessary to fulfill the purpose for which it was collected and thereafter as required by law or to protect legal claims.

As a rule:

• correspondence data – for the duration of handling the case and limitation period, 

• technical/security data – as justified by security needs, 

• consent-based data – until withdrawal of consent or loss of purpose, 

• statistical data – according to tool configuration or until consent withdrawal.

10. User rights

Users have the right to:

• access their data, 

• rectify data, 

• erase data, 

• restrict processing, 

• object to processing based on Article 6(1)(f) GDPR, 

• withdraw consent at any time, 

• lodge a complaint with the competent data protection authority.

11. Voluntary provision of data

Providing personal data is voluntary but may be necessary to:

• submit a form, 

• receive a response, 

• use certain Website functionalities. 

Failure to provide data may prevent handling the request.

12. Changes to the Privacy Policy

The Controller may update this Policy in particular due to:

• changes in Website functionality, 

• technological changes, 

• implementation of new tools, 

• changes in legal requirements. 

The current version is always available on the Website.

13. Contact for Privacy Matters

For matters related to personal data processing and privacy, you may contact the Controller at:

Transfer Multisort Elektronik Sp. z o.o.

ul. Ustronna 41, 93-350 Łódź, Poland

e-mail: dpo@tme.pl

For matters related to the Poweredby initiative, you may also contact us at:
poweredby@tme.eu