Privacy policy

The following Privacy Policy sets out rules for storing and accessing data on User Devices using the Website for the purposes of the provision of services by electronic means by the Administrator and rules for collecting and processing Users' personal data, which were provided by them personally and voluntarily via the tools available on the Website.

§1 Definitions

  • Service – the „Hi Urban Sp. z o.o.” website operating at https://hiurban.pl

  • External service – websites of partners, service providers or clients cooperating with the Administrator

  • Service / Data Administrator – The Administrator of the Website and the Data Administrator (hereinafter the Administrator) is „Hi Urban Sp. z o.o.”, operating at the address: Gdynia, ul. Janowska 48, with the assigned tax identification number (NIP): 958 167 46 43, with the assigned KRS number: 0000628354, providing electronic services via the Website

  • User – a natural person to whom the Administrator provides services by electronic means via the Website.

  • Device – electronic device together with software, through which the User gains access to the Website

  • Cookies – text data collected in the form of files placed on the User's Device

  • GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)

  • Personal data – 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 that natural person

  • Processing – means any operation or set of operations performed upon personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

  • Restriction of processing – means the marking of stored personal data with the aim of limiting their future processing

  • Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements

  • Agreed – data subject's consent means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her

  • Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed

  • Pseudonymisation – means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person

  • Anonymisation – Data anonymisation is an irreversible data processing operation that destroys / overwrites „personal data”, making it impossible to identify or link a given record to a specific user or natural person.

§2 Data Protection Officer

Pursuant to Article 37 of the GDPR, the Controller has not appointed a Data Protection Officer.

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

§3 Types of Cookies

  • First-party cookies – files placed and read on the User's Device by the ICT system of the Website

  • Third-party cookies – files placed on and read from the User's Device by the ICT systems of external Services. The scripts of external Services that may place Cookies on the User's Device have been deliberately placed in the Service via scripts and services made available and installed in the Service

  • Session cookies – files placed and read from the User's Device by the Service during a single session of a given Device. Once the session has ended, 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. Files are not automatically deleted at the end of a Device session unless the User's Device configuration is set to delete cookies at the end of the Device session.

§4 Data storage security

  • Cookie storage and retrieval mechanisms – The mechanisms for storing, reading and exchanging data between Cookies saved on the User's Device and the Website are implemented through the built-in mechanisms of web browsers and do not allow for the downloading of other data from the User's Device or data of other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojan horses and other worms to the User's Device is also practically impossible.

  • Internal cookies – Cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content or information that could threaten the security of personal data or the security of the Device used by the User.

  • Third-party cookies – The Administrator takes all possible measures to verify and select website partners in the context of Users' security. The Administrator selects well-known, large partners with global public trust for cooperation. However, the Administrator does not have full control over the content of Cookie files originating from external partners. To the extent permitted by law, the Administrator shall not be liable for the security of Cookie files, their content, or their use in accordance with the licence by Scripts installed on the website originating from external Services. The list of partners is provided later in the Privacy Policy.

  • Cookie settings

  • User-side threats – The Administrator applies 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 activity. The Administrator shall not be held liable for the interception of such data, impersonation of the User's session, or their deletion as a result of conscious or unconscious activity of the User, viruses, Trojan horses, and other spyware with which the User's Device may be or has been infected. 

  • Storage of personal data The Administrator ensures that they make every effort to ensure that the personal data voluntarily entered by Users is secure, and that access to it is restricted and carried out in accordance with its intended use and the purposes of processing. The Administrator also ensures that they make every effort to secure the data in their possession against loss by applying appropriate physical and organisational safeguards.

§5 Purposes for which Cookie files are used

  • Streamlining and facilitating access to the Website
  • User Service Personalisation
  • Ad serving services
  • Maintaining statistics (users, number of visits, types of devices, connection, etc.)
  • Provision of social networking services

§6 Purposes of processing personal data

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

  • Provision of electronic services:
  • Communication between the Administrator and Users on matters related to the Service and data protection
  • Ensuring the legitimate interest of the Controller

User data collected anonymously and automatically is processed for one of the following purposes:

  • Keeping statistics
  • Serving advertisements tailored to Users' preferences
  • Ensuring the legitimate interest of the Controller

§7 Cookies of External Services

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

Services provided by third parties are beyond the Controller's control. These parties may at any time change their terms of service, privacy policies, purposes of data processing and methods of using cookies.

§8 Types of data collected

The Website collects data about Users. Some of the data is collected automatically and anonymously, and some are personal data voluntarily provided by Users during registration for individual services offered by the Website.

Automatically collected anonymous data:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Opened subpages of the website
  • Time spent on the relevant subpage of the website
  • Operating system type
  • URL of the previous subpage
  • Referrer URL
  • Browser language
  • Internet connection speed
  • Internet service provider

Some data (excluding identifying data) may be stored in cookies. Some data (excluding identifying data) may be transferred to the statistics service provider.

§9 Access to personal data by third parties

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

Access to the data (most commonly on the basis of a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the website, such as:

§10 Method of personal data processing

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless they have been published as a result of the User's individual action (e.g. entering a comment or post), which will make the data available to anyone visiting the website.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

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

§11 Legal basis for the processing of personal data

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

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation)
    • Article 6(1)(a)
      the data subject has given consent to the processing of their personal data for one or more specific purposes
    • Article 6(1)(b)
      processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
    • Article 6(1)(f)
      processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
  • Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws of 2018, item 1000)
  • Act of 16 July 2004 – Telecommunications Law (Journal of Laws of 2004, No. 171, item 1800)
  • Act of 4 February 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 indicated personal data are stored only for the duration of the provision of the Service within the Website by the Administrator. They are deleted or anonymised within up to 30 days from the moment the provision of services ends (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation which requires the protection of the legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User's request for their deletion, for no longer than a period of 3 years in the event of a breach or suspected breach of the terms of service by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, which do not constitute personal data, are stored by the Administrator for the purpose of maintaining website statistics for an indefinite period

§13 Users' rights regarding 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 a request submitted to the Administrator

  • Right to rectification of personal data
    Users have the right to request that the Controller immediately rectifies personal data that is incorrect and/or completes incomplete personal data, fulfilled upon a request submitted to the Controller.

  • Right to erasure of personal data
    Users have the right to request the Administrator to immediately delete personal data, executed upon a request submitted to the Administrator. In the case of user accounts, the deletion of data consists in the anonymisation of data enabling the identification of the User. The Administrator reserves the right to withhold the execution of a data deletion request in order to protect the Administrator's legitimate interests (e.g. when the User has breached the Terms and Conditions or the data were obtained as a result of ongoing correspondence).
    In the case of the Newsletter service, the User has the option to delete their personal data independently by using the link included in every sent e-mail message.

  • Right to restriction of processing of personal data
    Users have the right to restrict the processing of personal data in the cases specified in Article 18 of the GDPR, inter alia, contesting the accuracy of personal data, exercised upon a request submitted to the Controller

  • Right to data portability
    Users have the right to obtain from the Controller personal data concerning the User in a structured, commonly used and machine-readable format, to be exercised upon request made to the Controller.

  • 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 Article 21 of the GDPR, exercised upon a request submitted to the Controller

  • Right of appeal
    Users have the right to lodge a complaint with a supervisory authority dealing with the protection of personal data.

§14 Contacting the Administrator

You can contact the Administrator in one of the following ways

  • Postal address – Hi Urban Sp. z o.o., Gdynia, ul. Janowska 48.

  • Email address – office@hiurban.pl

  • Telephone call – +48 515 151 411

  • Contact form – available at: /kontakt

§15 Service Requirements

  • Restricting the storage of and access to cookies on the User's Device may cause some features of the Website to malfunction.

  • The Administrator bears no responsibility for any malfunctioning of the Website's features in the event that the User restricts in any way the ability to save and read Cookie files.

§16 External links

The Website – in Users' articles, posts, entries or comments – may contain links to external websites with which the Website Owner does not cooperate. These links, as well as the pages or files indicated by them, may be dangerous to your Device or pose a threat to the security of your data. The Administrator shall not be liable for content located outside the Website.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to amend this Privacy Policy at their discretion without the need to inform Users regarding the application and use of anonymous data or the use of Cookies.

  • The Administrator reserves the right to arbitrarily amend this Privacy Policy regarding the processing of Personal Data, of which Users who hold user accounts or are subscribed to the newsletter service will be notified via email within 7 days of the amendment of the provisions. Continued use of the services implies acknowledgement and acceptance of the introduced amendments to the Privacy Policy. In the event that the User does not agree with the introduced amendments, they are obliged to delete their account from the Website or unsubscribe from the Newsletter service.

  • Changes made to the Privacy Policy will be published on this subpage of the Website.

  • The introduced changes shall come into force upon their publication.