Privacy Policy

Privacy Policy

The following Privacy Policy sets forth the rules for storing and accessing data on the Devices of Users using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing the personal data of Users provided by them personally and voluntarily through the tools available on the Service.

The following Privacy Policy is an integral part of the Terms of Service, which sets forth the rules, rights and obligations of Users using the Service.

§1 Definitions

  • Service – the website of “V.I.P Home España” operating at https://viphomees.com
  • External service – websites of partners, service providers or service recipients cooperating with the Administrator
  • Administrator of the Service / Data – The Administrator of the Service and the Administrator of the Data (hereinafter the Administrator) is the company “V.I.P Home España”, doing business at: , providing electronic services through the Service
  • User – a natural person for whom the Administrator provides electronic services through the Service.
  • Device – an electronic device with software through which the User accesses the Site
  • Cookies – text data collected in the form of files placed on the User’s Device.
  • RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (General Data Protection Regulation)
  • Personal information – 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 the natural person
  • Processing – means an operation or set of operations performed on personal data or sets of personal data in an automated or non-automated manner, such as collecting, recording, organizing, structuring, storing, adapting or modifying, retrieving, viewing, using, disclosing by transmission, dissemination or otherwise making available, matching or linking, limiting, erasing or destroying;
  • Restriction of processing – means the marking of stored personal data in order to limit its future processing
  • Profiling – means any form of automated processing of personal data that involves the use of personal data to evaluate certain personal factors of an individual, in particular to analyze or forecast aspects of that individual’s performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movement
  • Consent – consent of the data subject means a voluntary, specific, informed and unequivocal demonstration of will by which the data subject, in the form of a statement or explicit affirmative action, consents to the processing of personal data concerning him or her
  • Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, modification, unauthorized disclosure of or unauthorized access to personal data transmitted, stored or otherwise processed
  • Pseudonymization – means the processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and is covered by technical and organizational measures that prevent its attribution to an identified or identifiable natural person
  • Anonymization – Data anonymization is an irreversible process of data operations that destroys / overwrites “personal data” making it impossible to identify, or link, a particular record to a specific user or individual.

§2 Data Protection Officer

Based on Art. 37 RODO, the Administrator has not appointed a Data Protection Officer.

For matters concerning data processing, including personal data, contact the Administrator directly.

§3 Types of Cookies.

  • Internal cookies – files placed and read from the User’s Device by the Service’s data communications system
  • External cookies – files placed and read from the User’s Device by data communications systems of external Services. Scripts of External Services that may place Cookies on User Devices have been knowingly placed on the Website through scripts and services made available and installed on the Website
  • Session cookies – files placed and read from the User’s Device by the Service during a single session of a given Device. When 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. The files are not deleted automatically after the end of the Device session unless the configuration of the User’s Device 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 Website are implemented through the built-in mechanisms of web browsers and do not allow the collection of other data from the User’s Device or data of other websites visited by the User, including personal data or confidential information. It is also virtually impossible to transfer viruses, Trojan horses and other worms to the User Device.
  • Internal cookies – the cookies used by the Administrator are safe for the Users’ Devices and do not contain scripts, content or information that may compromise the security of personal data or the security of the Device used by the User.
  • External cookies – the Administrator takes all possible measures to verify and select service partners in the context of Users’ security. The administrator selects well-known, large partners with global public trust to work with. However, it does not have full control over the content of cookies from external partners. The Administrator is not responsible for the security of Cookies, their content and their use in accordance with the license by the Scripts installed on the site, coming from External Services, as far as the law allows. A list of partners is provided later in the Privacy Policy.
  • Cookie control
  • Threats on the part of the User – The Administrator uses all possible technical measures to ensure the security of data placed in cookies. However, it should be noted that ensuring the security of this data depends on both parties including the User’s activities. The Administrator is not responsible for the interception of this data, impersonation of the User’s session or its deletion, as a result of the User’s conscious or unconscious activity, viruses, Trojan horses and other spyware with which the User’s device may be or has been infected. In order to protect themselves from these dangers, users should follow the rules for using the Internet.
  • Storage of personal data – The Administrator ensures that it makes every effort to ensure that the processed personal data entered voluntarily by Users is secure, access to it is limited and carried out in accordance with its purpose and the purposes of processing. The administrator also ensures that it makes every effort to secure the data it holds from loss, through the use of appropriate physical as well as organizational safeguards.

§5 Purposes for which cookies are used

  • Streamline and facilitate access to the Service
  • Personalization of the Service for Users
  • Marketing, Remarketing in External Services
  • Ad serving services
  • Affiliate services
  • Keeping statistics (users, number of visits, types of devices, link, etc.).
  • Serving multimedia services
  • Providing community services

§6 Purposes of personal data processing

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

  • Realization of electronic services:
    • Newsletter services (including sending advertising content with permission)
    • Services for commenting / liking posts on the Service without registering
    • Services for sharing information about the content posted on the Site on social networks or other sites.
  • Administrator’s communication with Users on matters related to the Service and data protection
  • To ensure the legitimate interest of the Administrator

Data about Users collected anonymously and automatically is processed for one of the following purposes:

  • Keeping statistics
  • Remarketing
  • Serving ads tailored to Users’ preferences
  • Support for affiliate programs
  • To ensure the legitimate interest of the Administrator

§7 Cookies of External Services

The Administrator on the Website uses javascript and web components of partners that may place their own cookies on the User’s Device. Remember that in your browser settings you can decide for yourself about the allowed cookies that can be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

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

§8 Types of data collected

The service collects data on Users. Part of the data is collected automatically and anonymously, and part of the data is personal data voluntarily provided by Users when signing up for particular services offered by the Service.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Openable subpages of the website
  • Time spent on the relevant subpage of the website
  • Type of operating system
  • Previous subpage address
  • Address of the referring page
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected during registration:

  • First name / last name / nickname
  • Login
  • E-mail address
  • IP address (collected automatically)

Data collected when signing up for the Newsletter service

  • First name / last name / nickname
  • E-mail address
  • IP address (collected automatically)

Data collected when adding a comment

  • Name / nickname
  • E-mail address
  • Web address
  • IP address (collected automatically)

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

§9 Access to personal data by third parties

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

Access to the data (most often on the basis of a Data Processing Entrustment Agreement) may have entities, responsible for maintaining the infrastructure and services necessary to run the service, i.e.:

  • Hosting companies, providing hosting or related services to the Administrator
  • Companies through which the Newsletter service is provided

Entrustment of personal data processing – Newsletter

Administrator in order to provide the Newsletter service, uses the services of a third party – MailChimp service , . The data entered in the newsletter subscription form is transmitted, stored and processed in the third-party service of this service provider.

Please be informed that the indicated partner may modify the indicated privacy policy without the consent of the Administrator.

Entrustment of personal data processing – Hosting, VPS or Dedicated Server Services

In order to run the site, the Administrator uses a third-party hosting provider, VPS or Dedicated Servers -. OVH sp. z o.o.. All data collected and processed on the site is stored and processed in the service provider’s infrastructure located in Poland. It is possible to access the data as a result of maintenance work performed by the service provider’s personnel. Access to this data is governed by an agreement between the Administrator and the Service Provider.

§10 Method of processing personal data

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless published as a result of an individual action by the User (e.g., entering a comment or entry), which will make the data available to any visitor to the site.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be resold to third parties.

Anonymous data (no personal information) collected automatically:

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

§11 Legal grounds for processing personal data

The Service collects and processes Users’ data on the basis of:

  • Regulation of the European Parliament and of the Council (EU) 2016/679 of April 27, 2016. on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (General Data Protection Regulation)
    • Art. 6 paragraph. 1(a)
      the data subject has consented to the processing of his/her personal data for one or more specified purposes
    • Art. 6 paragraph. 1(b)
      processing is necessary for the performance of a contract to which the data subject is a party, or to take action at the request of the data subject prior to entering into a contract
    • Art. 6 paragraph. 1(f)
      processing is necessary for the purposes of legitimate interests pursued by the controller or by a third party
  • Law of May 10, 2018. On the protection of personal data (Journal of Laws 2018 item 1000)
  • Law of July 16, 2004. Telecommunications Law (Dz.U. 2004 No. 171 item 1800)
  • Law of February 4, 1994. On Copyright and Related Rights (Journal of Laws 1994 No. 24 item 83)

§12 Period of personal data processing

Personal data provided voluntarily by Users:

As a rule, the personal data indicated are kept only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized up to 30 days after termination of services (e.g. deletion of registered user account, unsubscribing from Newsletter list, etc.).

The exception is the situation that requires securing the legitimate purposes of further processing of such data by the Administrator. In such a situation, the Administrator will keep the indicated data, from the time of the request for deletion by the User, no longer than for a period of 3 years in case of violation or suspected violation of the provisions of the regulations of the service by the User

Anonymous data (no personal information) 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 of time

§13 Users’ rights related to the processing of personal data

The Service collects and processes Users’ data on the basis of:

  • Right of access to personal data
    Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator
  • Right to rectify personal data
    Users have the right to request the Administrator to promptly rectify personal data that is incorrect and/or to complete incomplete personal data, exercised upon request submitted to the Administrator
  • The right to delete personal data
    Users have the right to request from the Administrator the immediate deletion of personal data, realized upon request submitted to the Administrator In the case of user accounts, deletion of data consists in anonymization of data allowing identification of the User. The Administrator reserves the right to suspend the execution of a request for deletion of data in order to protect the legitimate interest of the Administrator (e.g. when the User has committed a violation of the Terms of Use or the data was obtained as a result of ongoing correspondence).
    In the case of the Newsletter service, the User has the option of deleting his/her personal data himself/herself by using the link included in each e-mail message sent.
  • The right to restrict the processing of personal data
    Users have the right to restrict the processing of personal data in the cases indicated in Art. 18 RODO, among other things. questioning the correctness of personal data, carried out upon request submitted to the Administrator
  • Right to portability of personal data
    Users have the right to obtain from the Administrator, personal data concerning the User in a structured, commonly used machine-readable format, executed upon request submitted to the Administrator
  • The 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 RODO, carried out upon request made to the Administrator
  • The right to file a complaint
    Users have the right to lodge a complaint with the data protection supervisory authority.

§14 Contact to the Administrator

The Administrator can be contacted in one of the following ways

  • Email address – info@viphomees.com
  • Phone call – +48 577 723 538
  • Contact form – available at: /contract

§15 Service Requirements

  • Restricting the storage of and access to Cookies on the User’s Device may result in the malfunction of some features of the Website.
  • The Administrator shall not be held responsible for malfunctioning functions of the Website in case the User restricts in any way the ability to save and read Cookie files.

§16 External links

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

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to change this Privacy Policy at any time without notifying Users regarding the use and application of anonymized data or the use of cookies.
  • The Administrator reserves the right to change this Privacy Policy at any time with regard to the processing of Personal Data, of which it will inform Users with user accounts or subscribed to the newsletter service, via e-mail within 7 days of the change in records. Continued use of the services implies that you have read and accept the changes made to the Privacy Policy. In the event that the User does not agree with the changes, he/she is obliged to delete his/her account from the Service or unsubscribe from the Newsletter service.
  • Changes made to the Privacy Policy will be published on this subpage of the Website.
  • The changes made shall take effect upon publication.