- This Privacy Policy describes how Elion Trade sp. z o.o. with its registered office in Warsaw (“Elion”, “we”, “our” or “us”) collects and uses your personal data in connection with the Website and the Services.
- Elion provides the Website and the Services subject to the Terms of Service.
- This Privacy Policy consists of two parts:
• Privacy Notice – which describes how we collect and user your personal data in connection with your use of the Website and the Services;
• Cookie Notice – which describes how cookies and similar technologies are used in connection with your use of the Website and the Services.
- We use the following definitions in this Privacy Policy:
• Controller, processor, processing and other terms relating to personal data not defined here have the meaning as defined in Article 4 of the GDPR.
• Elion – Elion Trade Sp. z o.o., a limited liability company established under the laws of Poland with its registered office in Warsaw, address: Kłobucka Street 8B/86, 02-699 Warsaw, Poland, entered in the Register of Entrepreneurs of the National Court Register under KRS no. 0000496738, whose registration documentation is kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, tax ID number (VAT-PL): 7962963923, REGON: 147082308.
• GDPR – General Data Protection Regulation 2016/679 of 27 April 2016.
• Personal data – information about identified or identifiable natural person as defined in Article 4(1) of the GDPR.
• Privacy Policy – this Privacy Policy.
• Terms of Service – Terms of Service for the Website and the Services available at www.eliontrade.com/terms-of-service - All terms not defined in this Privacy Policy shall have the meaning as defined in the Terms of Service or in the GDPR.
The Privacy Policy shall be reviewed on an ongoing basis and updated as necessary. The current version of the Privacy Policy has been adopted and is effective as of 18.06.2024.
- 1. Privacy notice
- 1.1. Controller and contact details
- We, Elion, are the controller of your personal data to the extent this Privacy Policy applies. You can contact us by email at: contact@eliontrade.com or in writing to our registered address: Kłobucka Street 8B/86, 02-699 Warsaw.
- 1.2. Purpose and legal basis of processing
- We collect and process your personal data in connection with your use of the Website and the Services. As a general rule, we collect your personal data directly from you and from your devices. Generally speaking, we process your personal data to the extent necessary to provide the Services, ensure smooth operation of the Website or for other legitimate purposes. You can find the description of such purposes and legal grounds for processing in greater detail below.
- 1.2.1. Use of the Website
- We process your personal data, such as your IP address or other online identifiers, for the purpose of rendering electronic services within the scope of providing Users with access to the contents collected on the Website. The legal basis for such processing is the necessity of processing for performance of a contract (Article 6(1)(b) GDPR).
- 1.2.2. Contact Form
- We process your personal data provided by you in the Contact Form for the purpose of identifying the User and handling the inquiry sent via the Contact Form. The legal basis for processing is the necessity of processing for the purposes of performance of a contract (Article 6(1)(b) of the GDPR). As regards data provided optionally, the legal basis for processing is your consent (Article 6(1)(a) of the GDPR).
- 1.2.3. Data Processing Services
- We process your personal data provided by you via the Contact Form for the purpose of performing Data Processing Services. This may include creating your profile as a Client. We share your personal data with our partners in connection with the Data Processing Services (please consult Section 1.4 for more details). The legal basis for processing is the necessity of processing for the purposes of performance of a contract (Article 6(1)(b) of the GDPR).
- 1.2.4. Marketing
- We process your personal data provided by you for the purpose of sending e-mail notifications or text messages about interesting offers or content, which in some cases contain commercial information (sending information about offers, products and services).
- 1.2.5. Security
- We process your personal data to ensure the security of the Website and our ICT systems and to manage them. For example, we record some of your personal information in a system logs (special computer program used for storing a chronological record containing information about events and actions related to the ICT Systems used for rendering Services us). The legal basis of the processing is our legitimate interest (Article 6(1)(f) GDPR), which consists of our need to ensure security and safety of our ICT systems used in connection with the Website and the Services.
- 1.2.6. Analysis
- We process your personal data for analytical and statistical purposes. The legal basis for such processing is our legitimate interest (Article 6(1)(f) GDPR), which consists of conducting analyses of the User activity, as well as of the User preferences in order to improve functionalities and services provided by us.
- 1.2.7. Legal rights
- We may process your personal data, if necessary, to establish and assert claims or to defend against claims. The legal basis for such processing is our legitimate interest (Article 6(1)(f) GDPR), which consist of the protection of our legal rights.
- 1.3. Data storage
- The duration of data processing by us depends on the type of Service provided and the purpose of processing. As a general rule, the data is processed for the duration of the Service provision or until the withdrawal of the expressed consent or filing an effective objection to data processing in cases where the legal basis of data processing is our legitimate interest.
The duration of data processing may be extended if the processing is necessary to establish and assert possible claims or to defend against claims, and thereafter only in the case and to the extent required by law. After the end of the processing timespan, the data is irreversibly deleted or anonymized. - 1.4. Data recipients
- In connection with the provision of services, the Personal Data will be disclosed to external entities, including providers responsible for the operation of ICT Systems and entities such as marketing agencies (within the scope of marketing services) or external professional consultants, for example lawyers.
In connection with the Data Processing Services your personal data may be disclosed to our partners and clients. We share your personal data because it is necessary for the performance of our contract with you under Terms of Service, i.e. without sharing your personal data the Data Processing Services would be impossible to provide. You have a right to stop using Data Processing Services. Please consult Section 5 of the Terms of Service for more details on how to resign from these Services.
If you resign from the Data Processing Services, we will not be sharing your personal data with our partners. Please note, however, that personal data shared before such resignation may still be processed by third parties, such as our partners, as separate and independent controllers subject to the rules set out by them. We are not responsible for the privacy policies and practices of such third parties. You can obtain more information about the third parties with whom we share your personal data by contacting us. Please refer to Section 1.7 of this Privacy Notice for more details on your right to information.
Please note that we may store some of your personal data when there is another legal basis for such use of your data, for example when retention of your data is our legal duty under the applicable law.
We reserve the right to disclose selected information concerning the User to competent authorities or third parties, who will submit a request for such information on the basis of an appropriate legal basis and in accordance with the provisions of the law in force. - 1.5. Data transfers outside the EEA
- The level of protection for the Personal Data outside the European Economic Area (EEA) differs from that provided by the EU law. For this reason, we transfer your personal data outside the EEA only when necessary and with an adequate level of protection, primarily by cooperating with processors of the personal data in countries for which there has been a relevant European Commission decision finding an adequate level of protection for the Personal Data. Alternatively, we may use the standard contractual clauses issued by the European Commission. If you want to learn more about these safeguards, obtain a copy of them or learn where they have been made available, contact us (please consult Section 1.1 above).
- 1.6. Requirement to provide personal data
- In some cases, provision of your personal data is mandatory by law or necessary in order to carry out your request or to perform a contract we have with you. If you fail to provide us with your personal data in such situations, we may not be able to carry out your request, perform a contract with you (or enter into it) or comply with the law. In some cases, this may mean that we will terminate the contract or stop our engagement with you. In other cases, provision of your personal data is voluntary. If you fail to provide us with your personal data in such situations, we may not be able to carry out your request or achieve our goal. For example, if you do not fill in the fields of our questionnaire that are marked as optional, we will not be able to process them.
- 1.7. Your rights
- You have the right to withdraw your consent to the processing of your personal data. You can do this at any time. If you withdraw consent, we will stop using your personal data if the basis for processing is consent. The withdrawal of consent does not affect the lawfulness of the processing of your data on the basis of consent before its withdrawal. The right to withdraw consent applies only to the extent that your personal data is processed on the basis of consent.
You have the right to object to the processing of your personal data on the basis of our or a third party's legitimate interest (for example, when we process your personal data for marketing purposes). You can do so at any time. If you object, we will stop using your personal data when the basis for processing is our legitimate interest. In exceptional circumstances, we may continue to use your data despite your objection (this does not apply to objections to processing for direct marketing purposes). In order to do so, we must demonstrate the existence of valid legitimate grounds for processing that override your interests, rights and freedoms, or grounds for establishing, asserting or defending claims.
You also 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 dealing with the protection of the personal data (President of the of Personal Data Protection Office with its seat in Warsaw, Poland). - 2. Cookie notice
- 2.1. What are cookies?
- Cookies are small text files installed on the User’s device. Cookies collect information facilitating the use of a website, e.g. by remembering User information such as logins or language preferences. On the Website, we use our own files, which are installed directly by the Website. Third party cookies, which are cookies from a domain other than the domain of the site the User is visiting are also used, primarily for analytics and advertising activities.
In general, information used in connection with cookies is personal data. In such cases, the Privacy Policy applies to such personal data.
There are also other technologies similar to cookies, for example HTML5 local storage, Local Shared Objects or tracking pixels. In general, where we refer to cookies in this Cookie Notice, we also mean such technologies. - 2.2. What types of cookies are used?
- Cookies that may be installed on your devices are controlled by us or by the third parties. Below you can find a summary on the types of cookies that are used in connection with the Website and the Services. If you want to obtain more information on the specific cookies in this category, i.e. the names of specific cookies, an overview of the functioning thereof, or the validity or origin thereof, you should consult our cookie management platform available here.
- 2.1.1. Necessary cookies
- We process your personal data provided by you for the purpose of proper functioning of the Website. Such files are installed specifically for the purpose of recalling login sessions, as well as for the purposes of setting privacy options. The legal basis for personal data processing in connection with the application of the necessary cookies is the necessity of processing for the purposes of performance of a contract (Article 6(1)(b) of the GDPR).
- 2.3. How long are the cookies used?
- The duration for which the cookies are used depends on their type and purpose. In general, there are two main types of cookies: session cookies and persistent cookies. Session cookies expire at the end of a given session. Persistent cookies are stored for a longer period of time on your device. They don’t expire at the end of a given session. The maximum period after which our cookies expire is 12 months.
- 2.4. Your rights
- You can manage cookies through your Internet browser, for example by removing all or some cookies from your device or by blocking them. Please note that this may cause the Website or the Services to not work properly or at all. To manage cookies through your Internet browser, you should consult instructions provided by the provider of such a browser. For example, you can find some of such instructions for relevant Internet browsers listed below:
• Internet Explorer: https://support.microsoft.com/en-us/windows/delete-and-manage-cookies-168dab11-0753-043d-7c16-ede5947fc64d
• Microsoft Edge: https://support.microsoft.com/en-us/microsoft-edge/delete-cookies-in-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
• Chrome: https://support.google.com/chrome/answer/95647?hl=en&co=GENIE.Platform%3DDesktop
• Safari: https://support.apple.com/guide/safari/manage-cookies-sfri11471/mac
• Firefox: https://support.mozilla.org/en-US/kb/clear-cookies-and-site-data-firefox
• Opera: https://www.opera.com/pl/use-cases/clean-browser-and-remove-trackers - Where your personal data is used in connection with cookies, you have the rights described in the Privacy Policy and can exercise them accordingly. Please consult Section 1.7 of the Privacy Policy for more details.