Privacy policy

This Privacy Policy applies to the principles of data processing in connection with website use.

§ 1. Personal data administrator

This Privacy Policy applies to data processing rules in connection with using the website (“Website”) and contacting the website owner through it.

The administrator of personal data within the meaning of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27/04/2016 on the protection of individuals about the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC ( General Data Protection Regulation), from now on referred to as “GDPR,” is Clebre SA with its registered office in Olsztyn, ul. Artyleryjska 3K, 10-165 Olsztyn, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court in Olsztyn, 8th Commercial Division of the National Court Register under KRS number 0000593607, NIP: 7010532653, REGON: 363340134, with a share capital of PLN 161,800.00, from now on referred to as “Administrator.”

The User’s data is processed in compliance with the security rules required by the provisions of the GDPR and other legal acts in force in Poland.

§ 2. Purposes and legal grounds for data collection

Based on Article. 6 sec. one lit. a) GDPR, i.e., based on the consent granted, the data will be processed for marketing purposes, including sending a newsletter or information about the Administrator’s and its partners’ promotions, products, and offers.

Based on Article. 6 sec. one lit. f) GDPR, in connection with the so-called Administrator’s legitimate interest, which is maintaining contact with Users, establishing and pursuing claims, and defending the Administrator’s rights, as well as developing and improving the quality of services provided by the Administrator and conducting direct marketing activities, personal data will be processed for the following purposes:

ensuring contact – the data provided by the User to contact the Administrator will be processed to answer the questions asked, including to provide information about their activities and about the products and services they offer, at the request of interested persons,

correct display of websites managed by the Administrator and visited by Users, as well as their adaptation and improvement,

conducting direct marketing activities,

keeping statistics and making analyses to improve the quality of products and services provided by the Administrator,

determination, investigation, and defense of claims; it should be noted that the Administrator is entitled to pursue claims for business activity and must also be ready to fend off any claims against him, which allows the Administrator to process personal data also for this purpose,

statistical, archival, and ensuring accountability (showing the Administrator’s fulfillment of obligations under the law).

§ 3. Data transfer

By applicable law, the Administrator may transfer Users’ data to entities processing them on his behalf, the so-called data recipients. They may be entities dealing with IT services and providing the Administrator with IT tools, dealing with management and entering data into databases, intermediaries in the implementation of marketing campaigns, entities participating in the performance of contracts (subcontractors, entities providing postal and courier services, companies dealing with the settlement of online transactions ), as well as providing consulting services (e.g., accounting, legal). By the law, data may be transferred based on applicable law, e.g., to courts or law enforcement authorities – of course, only if they make a request based on an appropriate legal basis.

Suppose the Administrator transfers data to entities based in countries outside the European Economic Area. In that case, he will require that these entities guarantee a high level of personal data protection and compliance with European data protection standards and that they conclude appropriate agreements based on model contractual clauses on the security of data adopted by the European Commission.

§ 4. Data retention

Depending on the case, the Administrator processes Users’ data for different periods. Based on Article. 6 sec. one lit. f) the data is stored for the time necessary to establish, pursue or defend claims – until the claims expire (this also applies to services provided free of charge) or until a practical objection is raised. Some data may be stored longer until there is a legal obligation or for analytical or archival purposes. In other cases of data processing under art. six sec. One lit. f) the data listed in § 2 of this Privacy Policy are processed until a practical objection is raised or until the Administrator deletes them.

When the User agrees to data processing for marketing purposes, the data will be processed for the duration of the Administrator’s possession of products and services addressed to the persons whose data are processed or until the consent is withdrawn.

The data will be periodically checked for validity; if found to be outdated, they will be updated or deleted by the Administrator.

At the same time, to comply with the so-called accountability, the data will be stored for the period in which the Administrator is obliged to keep the data or documents containing them to document the fulfillment of legal requirements, including to enable control of their dignity by public authorities.

§ 5. Rights of the data subject

Each User has the right to access and correct or rectify their data.

The User also has the right to delete, transfer, limit processing, lodge, and link to the President’s Personal Data Protection.

If the proc Presidentessing is based on the User’s consent, he has the right to withdraw it at any time without affecting the lawfulness of the processing, which was made based on consent before its withdrawal.

The User has the right to object to the processing of their data when their processing is based on legitimate interest or for statistical purposes. The objection is justified by the situation in which the User has found himself.

In the case of data processing under art. six sec. One lit. f) GDPR to conduct direct marketing activities, the User may object to such processing at any time.

The User can make any changes in the scope of his data by sending an appropriate declaration of will to the Administrator’s address

The Administrator reserves the right to refuse to delete data if their retention is necessary to pursue claims or in the event of other valid legitimate grounds for the processing, overriding the interests, rights, and freedoms of the data subject or if required by applicable law.

§ 6. Voluntary provision of data

Personal data was provided to the Administrator by the User voluntarily. Please remember that the Administrator did not oblige you to provide any data; providing them is not a statutory obligation.

However, personal data may be necessary to enable the use of the Administrator’s website and to contact you. Failure to provide data may result in, i.a., inability to use the website, answer the question asked via the contact form, and send the newsletter.

§ 7. Security and protection of personal data

The Administrator declares that it processes Users’ data by the provisions of the GDPR and that it applies technical and organizational measures to ensure the protection of processed data appropriate to the threats and categories of data protected, and in particular, protects Users’ data against disclosure to unauthorized persons, loss or damage.

The administrator monitors the adequacy of the data security applied to the identified threats. If necessary, the Administrator implements additional measures to increase data security.

Only authorized employees or associates of the Administrator and authorized persons handling who have been granted appropriate authorizations have direct access to personal data collected by the Administrator.

The Administrator also takes all necessary actions to ensure that its subcontractors and other cooperating entities guarantee the application of appropriate security measures whenever they process personal data at the request of the Administrator.

§ 8. Disclaimer

This Privacy Policy does not cover any information regarding services, goods, or websites belonging to entities other than the Administrator, also if information or links to other websites were posted on the website commercially, as a guest, on a reciprocal basis, or for purposes not serving commercial effect.

The Administrator is not responsible for the actions or omissions of Users, as a result of which the Administrator processes the personal data provided by them in the manner specified in this Privacy Policy.

§ 9. Contact

Any additional questions related to data protection can be sent by e-mail to or by traditional mail to the address indicated in § 1 section 2 of this Privacy Policy.

§ 10. Changes to the Privacy Policy

The data administrator reserves the right to change the Privacy Policy if required by law or changes introduced at The Data Administrator will notify the Users about the relevant changes and the date of their entry into force by posting a message on the Website.

§ 11. Cookies policy

An integral part of this Privacy Policy is the cookie policy.

The website does not automatically collect information except in cookie files.

Cookie files (so-called “cookies”) are IT data, in particular in the form of text files stored in the Website User’s end device and intended for using the Website’s websites. Cookies usually contain the name of the Website they come from, their storage time on the end device, and a unique number.

The entity placing cookies on the Website User’s end device, accessing them, and administering the data contained therein is the Administrator (Clebre SA).

Cookies are used to:

a) adapting the content of the Website pages to the User’s preferences and optimizing the use of websites; in particular, these files allow to recognize of the Website User’s device and correctly display the Website, tailored to his individual needs;

b) creating statistics and analyses that help to understand how Website Users use websites, which allows for improving their structure and content;

c) maintaining the Website User’s session, thanks to which the User’s device is recognized when revisiting the Website.

  1. The Website uses two basic types of cookies: “session” (session cookies) and “permanent” (persistent cookies). Session cookies are temporary files stored on the User’s end device until logging out, leaving the Website, or turning off the software (web browser). “Permanent” cookies are stored on the User’s end device for the time specified in the cookie file parameters or until the User deletes them.
  2. The following types of cookies are used on the Website:

a) “necessary” cookies, enabling the use of services available on the Website, e.g., authentication cookies used for services requiring authentication on the Website;

b) cookies used to ensure security, e.g., used to detect abuses in the field of authentication within the Website;

c) “functional” cookies, enabling “remembering” the settings selected by the User and personalizing the User’s interface, e.g., in terms of the chosen language or region from which the User comes, font size, website appearance, etc.;

d) “analytical” cookies, helping to determine how Users use the Website, which allows for analyzing Users’ behavior to take steps to improve the efficiency and convenience of using the Website. The Administrator uses them for statistical purposes to check how often the Website is visited and what actions users take. These data are used to optimize and develop the Website.

  1. The Website uses cookies that do not come from the Administrator. They are used to improve the Website and increase the number of functions available on the Website, thanks to which the User can use the Website more diversely. Their suppliers regulate the rules of using services provided by third parties and the privacy rules related to cookies from these entities. These rules may change occasionally, and the Administrator does not influence their content. It is recommended that the User read the privacy rules of the providers of individual services and cookies. Below is a list of cookie file providers used on the Website,

– Google Analytics i Google Tag Manager,

– Facebook,

– LinkedIn,

– Twitter.

  1. In many cases, the software used for browsing websites (web browser) allows cookies to be stored on the User’s end device by default. Detailed information on the possibilities and ways of handling cookies are available in the software (web browser) settings or on the grounds of the device used to browse the Website by the User. Website users may change their cookie settings at any time. These settings can be changed in such a way as to block the automatic handling of cookies in the web browser settings or inform about each time they are placed on the Website User’s device.
  2. The Administrator informs that restrictions on the use of cookies may affect some of the functionalities available on the Website’s websites.
  3. Advertisers and partners cooperating with the Administrator may also use Cookie files placed on the Website User’s end device.