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Halo Rental System

Privacy policy

 

Privacy policy

Privacy policy

The Halo Rental System Website (hereinafter referred to as the ‘Website’) is operated by Halo Rental System Limited Liability Company with its registered office in Warsaw, located at Aleje Jerozolimskie 181B, 02-222 Warsaw (hereinafter referred to as ‘Halo’).

Trust is a fundamental value of our company. At Halo, we believe that safeguarding the privacy and protecting the personal data of our customers is an integral value that contributes to building mutual trust. Consequently, Halo adheres to legal regulations that provide the highest level of personal data protection and continually strives to improve its practices in this regard. Your personal data is processed in accordance with applicable legal provisions, notably 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 (hereinafter referred to as the ‘GDPR’).

This Privacy Policy defines the principles of processing personal data of Users in connection with their use of the halorentalsystem.com website.

1. Personal data’s administrator

The administrator of your personal data is Halo Rental System Ltd. located at Aleje Jerozolimskie 181B, 02-222 Warsaw. For matters concerning your privacy, you can contact us at the email address: rodo@halorentalsystem.com.

2. What are Personal Data?

Personal data – all information about an identified or identifiable individual through one or several specific factors determining their physical, physiological, genetic, mental, economic, cultural, or social identity, including device IP, location data, internet identifiers, and information collected through cookies and similar technologies.

3. What Personal Data is Processed?

3.1. Data Provided by Users

If you wish to ask us a question via the contact form, please provide your identifying information (name, surname) and contact details (email, phone). This data will be used to respond to the question you’ve asked and, with your consent, to send you information about our offers.

3.2. Automatically Collected Personal Data

In order to provide you with necessary information on our website, Halo also processes data in the following scope:

  • The address of the page (subpage) you visit on our website;
  • The address of the website from which you were directly redirected to our website (known as a ‘referrer’);
  • The date and time of your visit;
  • Properties of your device, specifically the operating system, internet browser, and browser window size;
  • IP address of your device;
  • Identification numbers stored on your device, which allow us to recognize it on our website. These identification numbers are stored in cookies or eTags;
  • Device identifiers, composed of unique characteristics of your mobile device. Device identifiers enable us to recognize your device on our website. Examples of device identifiers are the ‘Ad-ID’ for the iOS operating system or the ‘Advertising ID’ for the Android operating system.

4. When Do We Process Your Personal Data?

4.1. Contractual Arrangements and Pre-contractual Information at the User’s Explicit Request

All personal data provided by you are processed when responding to queries submitted through the contact form and when sending you marketing information – provided you have given consent for such purposes. Unless otherwise specified in the following provisions, the legal basis for data processing is Article 6(1)(b) of the GDPR (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). In the case of sending marketing information, the legal basis will be separately expressed and completely voluntary consent (Article 6(1)(a) of the GDPR).

4.2. Website Usage – Cookies

We also process your personal data to create the best possible product offerings tailored to your needs. We want your visit to the halorentalsystem.com website to be as transparent and enjoyable as possible. For this reason, we process your personal data in the form of cookies. The legal basis for data processing is Article 6(1)(a) of the GDPR, meaning your expressed consent.

You can withdraw your consent at any time by changing the settings in your browser. On the website, you can also choose whether you want to allow non-essential cookies to be used.

5. Purposes of Data Processing

5.1. Contact Form

To provide you with a convenient communication channel, we offer the option to use a contact form through which you can ask questions prior to entering into a contract.

The legal basis for data processing is Article 6(1)(b) of the GDPR (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).

Providing the above-mentioned personal data is voluntary but necessary to create a personal user account.

5.2. Sending Commercial Information

If you provide your consent, we will send you commercial information electronically. This way, you can stay up to date with our offerings and utilize various opportunities to support the development of your business. You can withdraw your consent at any time by sending a brief email with the content: ‘I withdraw my consent for marketing’ to the address: rodo@halorentalsystem.com. Your request will be promptly honored without any additional conditions. The legal basis for processing is Article 6(1)(a) of the GDPR and also Article 10 of the Act on Provision of Services by Electronic Means.

5.3. Proper Service Delivery, Claims Investigation, and Defense Against Claims

We anticipate a harmonious and smooth collaboration with you. However, in the event of a dispute, your data may be used to defend against potential claims or effectively pursue them. They may also be essential to demonstrate the proper execution of services.

The legal basis for processing is Halo’s legitimate interest, which involves the ability to assert claims, defend against claims, and demonstrate the correctness of services rendered (Article 6(1)(f) of the GDPR).

In this case, you have the right to object to further processing of personal data for the aforementioned purpose. However, such objection must be based on your specific situation.

6. Data Recipients

Recipients of your data may include entities that support us in managing our business processes – these can be entities providing IT and accounting services. Such entities collaborate with us based on separate agreements and, while processing your data, are obligated to follow our directives and instructions.

7. Web Tracking Systems for Website Analysis

7.1. General Conditions

We strive to design our websites in the best possible way. To continually improve quality, we employ ‘tracking’ tools that allow us to monitor the effectiveness of online offerings. We use network monitoring tools to collect the following data:

  • Through which links online users are redirected to the halorentalsystem.com website;
  • Which of our pages are visited, when, how often, and in what order?
  • What information are users searching for on our site?
  • Which links or offers are accessed by users of our website?

Based on this information, we compile statistics that help us understand the answers to the following questions:

  • Which tabs are particularly appealing to users of our website?
  • Which articles are most interesting to our users?
  • What services should we offer our users?

In particular, we utilize automatically collected data as mentioned in point 3.2 above. Based on these data, anonymous user profiles are created under pseudonyms, in which data is stored.

7.2. Google Analytics

This website uses Google Analytics, a web analytics service provided by Google Inc. (‘Google’), USA. Google Analytics employs cookies that enable the analysis of your use of the website. The information generated by the cookie about your use of this website is transmitted to and stored on Google’s servers. This website has enabled IP anonymization, causing Google to truncate the IP addresses of users within the member states of the European Union or other parties to the Agreement on the European Economic Area before transmission. Only in exceptional cases will the full IP address be transmitted to Google’s servers in the USA and truncated there. On behalf of this website, Google will use this information to analyze the website’s use by users, generate reports on website activity, and provide other services related to website and internet usage to the website owner.

The IP address transmitted via Google Analytics from your internet browser will not be associated with other Google data.

You can prevent the storage of cookies by adjusting the settings of your browser. However, please note that in doing so, you may not be able to fully utilize all functions of this website. Furthermore, users can prevent the collection of data generated by cookies, including data related to your use of the website (including your IP address), as well as the processing of this data by Google, by downloading and installing the browser plugin available at the following link:

https://tools.google.com/dlpage/gaoptout?hl=en

Third-party information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.

Terms of use: http://www.google.com/analytics/terms/us.html

Privacy Policy: https://policies.google.com/privacy?hl=en

Objection to Data Processing:

At any time, you have the option to object to the collection and processing of data related to the use of the Google site (including your IP address) by downloading and installing the browser plugin available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en

7.3. Google AdWords / Remarketing

We also utilize the remarketing feature in Google AdWords by Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (hereinafter referred to as ‘Google’).

Remarketing in Google AdWords is a feature that, once the appropriate code is implemented on a website, allows the creation of personalized messages for users who previously viewed specific pages on the Google website, in order to create tailored advertisements based on users’ needs. For this purpose, cookies are stored in your browser from individual pages you visit through the Google browser. User visits are collected using cookies, which identify the internet browser of the device and not personal data; personal data is not stored. Of course, you can also visit our website without storing cookies in your browser. At any time, you can limit or deactivate the storage of cookies by Google by following the link provided and installing the plugin located there: www.google.com/settings/ads/plugin

More information about Google AdWords and Google’s privacy policy can be found at: www.google.com/privacy/ads

7.4. Google AdWords / Conversion Tracking

Halo uses the Google AdWords advertising system, a service provided by Google Inc. based in the USA (‘Google’), and the capabilities it offers for conversion tracking. If a user arrives at our website through a Google ad, Google AdWords will place a cookie in the browser that allows us to gather statistics on the user’s activity on our site. These cookies expire after 30 days, do not contain any personal data, and therefore are not used for personal identification. If you visit the advertiser’s website while these cookies are active, Google and the advertiser will receive information that the ad was displayed. Each Google AdWords client receives a unique cookie. Therefore, cookies cannot be tracked through AdWords clients’ websites. Information collected through the conversion cookie is used to generate conversion statistics for AdWords advertisers who have opted for conversion tracking. Clients receive a combined number of users who clicked the ad and were redirected to the conversion tracking tag’s page. However, you will not receive any information that allows user identification. At any time, you can limit or deactivate the storage of cookies by Google by following the link provided and installing the plugin located there: www.google.com/settings/ads/plugin. More information about Google AdWords and Google’s privacy policy can be found at: www.google.com/privacy/ads.

7.5. DoubleClick provided by Google

We also plan to utilize the DoubleClick Google device. DoubleClick Google is a service by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (‘Google’). Google’s DoubleClick was developed to display ads suitable for you. These ads are displayed on our website as well as on external websites that collaborate with Google.

Our website stores so-called cookies, which are used to create anonymous user profiles in which data is stored. Google uses these cookies to recognize your browser during visits to our website (or other websites whose providers use DoubleClick provided by Google). In this manner, Google attempts to collect the following information:

  • Which pages have you visited?
  • Which ads have you opened?

Based on this information, Google selects ads to be presented to you. You can manage the display of such ads by Google here. More information about Google ads can be found here. For more information about Google’s privacy practices, please click here.

Google operates its servers in the USA, a third country outside the EU. The Google DoubleClick service transfers your data to these servers. The European Commission has not yet made a decision ensuring an adequate level of data protection by the USA. However, Google adheres to the highest security standards and employs legal mechanisms to legitimize such transfers, such as Binding Corporate Rules or Standard Contractual Clauses.

The legal basis for integrating DoubleClick by Google, as described in this section, is Article 6(1)(f) of the GDPR (legitimate interest of the administrator, based on our interest in promoting the website for advertising purposes). Google collects and processes data arising in this context at its own responsibility.

7.6. LinkedIn Plugin

On the halorentalsystem.com website, we provide the option to use a plugin for the LinkedIn portal. Plugins are marked with the portal’s logo and icon. If a user launches a website containing such a plugin, the browser establishes a direct connection to the LinkedIn server. The plugin’s content is directly transmitted from the selected portal to the browser and integrated into the website. Halo has no influence over the amount of data that LinkedIn collects through this plugin. By integrating the plugin, Halo only receives information that the user has launched the corresponding website in this session. For information regarding the purpose and scope of data acquisition by LinkedIn, as well as the extent of its processing and usage, along with rights and privacy settings, please refer to the appropriate documentation concerning LinkedIn’s privacy policy.

In terms of using plugins, both Halo and the LinkedIn portal are joint data controllers. If you wish to exercise your rights related to the processing of data connected to the use of the halorentalsystem.com service, please reach out to us. All of your legally justified requests will be promptly fulfilled.

8. Data Retention

In accordance with applicable legal regulations, we process your personal data for the period necessary to achieve the designated purpose. After this period, your personal data will be irreversibly deleted or destroyed.

We will provide you with detailed information about data retention periods in the informational obligations presented during data collection.

Data collected for website analysis will be stored until you withdraw your consent for the use of cookies collected for this purpose. Please remember that you can withdraw your consent at any time by adjusting your browser settings.

9. Rights Related to Data Processing

Regarding the personal data concerning you as a user of the website, you have the following rights towards us:

  • The right to be informed about the processing of personal data – based on this right, upon your request, the Data Controller provides information about the processing of personal data, including primarily the purposes and legal bases of processing, the scope of data held, the entities to whom personal data is disclosed, and the planned date of their deletion;
  • The right to rectification – based on this right, the Data Controller corrects any inconsistencies or errors concerning the processed personal data and supplements or updates them if they are incomplete or have changed;
  • The right to erasure – based on this right, you may request the deletion of data when the processing is no longer necessary for any of the purposes for which it was collected;
  • The right to restriction of processing – based on this right, the Data Controller stops performing operations on personal data, except for operations to which the data subject has given consent, and retains them in accordance with the adopted retention rules or until the reasons for restricting data processing cease (e.g. a decision from a supervisory authority permitting further data processing);
  • The right to data portability – based on this right, to the extent that data is processed in connection with a concluded agreement or given consent, the Data Controller issues data provided by you in a format allowing computerized reading. It is also possible to request the transfer of this data to another entity – provided that there are technical capabilities on both the Data Controller’s side and the other entity’s side;
  • The right to object to the processing of data for marketing purposes – the data subject may at any time object to the processing of personal data for marketing purposes without having to justify such objection;
  • The right to object to processing for other purposes also applies to you, but it depends on your specific situation and may not necessarily be taken into account by the Data Controller.

A request related to the exercise of the rights described above can be submitted by using traditional mail by writing to the address: ul. Prosta 70, 00-838 Warsaw or by email to the address: rodo@halorentalsystem.com.

To withdraw consent for further processing of data related to the use of cookies, you can easily do so by changing the settings of the browser you are using.

The request should, as much as possible, precisely indicate the nature of the request, specifically:

Who is submitting the request and which of the rights described above they wish to exercise.

The purpose(s) of processing to which the request pertains (e.g., marketing purposes, analytical purposes, etc.).

If the Administrator is unable to determine the content of your request or identify the requester based on the submitted information, they may ask for additional information.

A response to the request will be provided promptly, no later than one month from its receipt. In case an extension of this deadline is necessary, the Administrator will inform you of the reasons for such an extension.

The response will be sent to the email address from which the request was submitted. For requests sent by mail, the response will be sent by registered mail to the address indicated by the requester, unless the letter’s content implies a desire for feedback to be provided to an email address (in such case, the email address should be provided).

You also have the right to file a complaint with the supervisory authority – the President of the Personal Data Protection Office, if you suspect that personal data is being processed in violation of the GDPR regulations.

10. Transfer of Personal Data to Third Countries and International Organizations

As a result of using the marketing tools described above, there might be a transfer of your personal data to Third Countries, i.e., outside the European Economic Area (EEA).

Your personal data may be transferred to Third Countries, i.e., outside the European Economic Area (EEA), only due to the fact that the providers assisting in the provision of marketing services have servers located outside the EEA, over which we have no control.

11. Changes to the Privacy Policy

For matters not covered by this Privacy Policy, the provisions of the GDPR apply.

You will be notified by email of any changes made to this Privacy Policy.

This Privacy Policy is effective as of March 1, 2023.

12. Questions

If you have any questions or suggestions regarding data protection, please contact us via email at rodo@halorentalsystem.com or at info@halorentalsystem.com.

Current as of: March 2023