Privacy Notice

PRIVACY NOTICE

Last updated January 02, 2023

This privacy notice for Vatanmad (“Company,” “we,” “us,” or “our”) describes how and why we might collect, store, use, and/or share (“process”) your information when you use our services (“Services”), such as when you:

• Visit our website at https://vatanmed.pl/en/, or any website of ours that links to this privacy notice.
• Engage with us in other related ways, including any sales, marketing, or events.

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at poland@vatanmed.com.

SUMMARY OF KEY POINTS

This summary provides key points from our privacy notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for. You can also click here to go directly to our table of contents.

What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with Vatanmad and the Services, the choices you make, and the products and features you use. Click here to learn more.

Do we process any sensitive personal information? We do not process sensitive personal information.

Do we receive any information from third parties? We do not receive any information from third parties.

How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so. Click here to learn more.

In what situations and with which parties do we share personal information? We may share information in specific situations and with specific third parties. Click here to learn more.

What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information. Click here to learn more.

How do you exercise your rights? The easiest way to exercise your rights is by filling out our data subject request form available here, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

Want to learn more about what Vatanmad does with any information we collect? Click here to review the notice in full.

TABLE OF CONTENTS

• WHAT INFORMATION DO WE COLLECT?
• HOW DO WE PROCESS YOUR INFORMATION?
• WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?
• WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
• DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?
• HOW LONG DO WE KEEP YOUR INFORMATION?
• DO WE COLLECT INFORMATION FROM MINORS?
• WHAT ARE YOUR PRIVACY RIGHTS?
• CONTROLS FOR DO-NOT-TRACK FEATURES
• DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
• DO WE MAKE UPDATES TO THIS NOTICE?
• HOW CAN YOU CONTACT US ABOUT THIS NOTICE?
• HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

1. WHAT INFORMATION DO WE COLLECT?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names;
• phone numbers;
• email addresses.

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity, such as your name or contact information, but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information.

This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. You can find out more about this in our Cookie Notice: https://vatanmed.pl/en/cookie-policy/.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings, and information about your activity in the Services, such as date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use, as well as device event information such as system activity, error reports (sometimes called “crash dumps”), and hardware settings.
• Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address or proxy server, device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
• Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location based on your IP address. You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. However, if you choose to opt out, you may not be able to use certain aspects of the Services.

2. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To deliver and facilitate delivery of services to the user. We may process your information to provide you with the requested service.
• To respond to user inquiries and offer support to users. We may process your information to respond to your inquiries and solve any potential issues you might have with the requested service.
• To send administrative information to you. We may process your information to send you details about our products and services, changes to our terms and policies, and other similar information.
• To enable user-to-user communications. We may process your information if you choose to use any of our offerings that allow for communication with another user.
• To send you marketing and promotional communications. We may process the personal information you send to us for our marketing purposes, if this is in accordance with your marketing preferences. You can opt out of our marketing emails at any time. For more information, see “WHAT ARE YOUR PRIVACY RIGHTS?” below.
• To deliver targeted advertising to you. We may process your information to develop and display personalized content and advertising tailored to your interests, location, and more. For more information, see our Cookie Notice: https://vatanmed.pl/en/cookie-policy/.
• To determine the effectiveness of our marketing and promotional campaigns. We may process your information to better understand how to provide marketing and promotional campaigns that are most relevant to you.
• To save or protect an individual’s vital interest. We may process your information when necessary to save or protect an individual’s vital interest, such as to prevent harm.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR PERSONAL INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason, i.e. legal basis, to do so under applicable law, such as with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission, i.e. consent, to use your personal information for a specific purpose. You can withdraw your consent at any time. Click here to learn more.
• Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
• Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information in order to:
  • send users information about special offers and discounts on our products and services;
  • develop and display personalized and relevant advertising content for our users;
  • support our marketing activities.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission, i.e. express consent, to use your personal information for a specific purpose, or in situations where your permission can be inferred, i.e. implied consent. You can withdraw your consent at any time. Click here to learn more.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• if collection is clearly in the interests of an individual and consent cannot be obtained in a timely way;
• for investigations and fraud detection and prevention;
• for business transactions provided certain conditions are met;
• if it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim;
• for identifying injured, ill, or deceased persons and communicating with next of kin;
• if we have reasonable grounds to believe an individual has been, is, or may be a victim of financial abuse;
• if it is reasonable to expect collection and use with consent would compromise the availability or accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
• if disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records;
• if it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced;
• if the collection is solely for journalistic, artistic, or literary purposes;
• if the information is publicly available and is specified by the regulations.

4. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with specific third parties.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• When we use Google Maps Platform APIs. We may share your information with certain Google Maps Platform APIs, e.g. Google Maps API and Places API. To find out more about Google’s Privacy Policy, please refer to this link.
• Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

5. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies, such as web beacons and pixels, to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice: https://vatanmed.pl/en/cookie-policy/.

6. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law, such as tax, accounting, or other legal requirements.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible, for example because your personal information has been stored in backup archives)then we will securely store your personal information and isolate it from any further processing until deletion is possible.

7. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 years old or that you are the parent or legal guardian of such a minor and consent to the minor’s use of the Services.

If we learn that we have collected personal information from users under 18 years of age, we will deactivate the relevant account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under the age of 18, please contact us at poland@vatanmed.com.

8. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), the United Kingdom, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions, such as the EEA, the United Kingdom, and Canada, applicable data protection laws provide you with certain rights. These may include:

• the right to request access to and obtain a copy of your personal information;
• the right to request rectification or deletion of your personal information;
• the right to restrict the processing of your personal information;
• where applicable, the right to data portability.

In certain circumstances, you may also have the right to object to the processing of your personal information. You may make such a request by contacting us using the contact details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?” below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or the United Kingdom and believe that we are unlawfully processing your personal information, you also have the right to lodge a complaint with your local data protection supervisory authority. You can find their contact details here: https://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

If you are located in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.

Withdrawing Your Consent

If we rely on your consent to process your personal information, which may be express and/or implied consent depending on applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?”.

However, please note that withdrawing your consent will not affect the lawfulness of processing carried out before its withdrawal, nor, where permitted by applicable law, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting Out of Marketing and Promotional Communications

You can unsubscribe from our marketing and promotional communications at any time by clicking the unsubscribe link in the emails we send or by contacting us using the details provided in the section “HOW CAN YOU CONTACT US ABOUT THIS POLICY?”.

You will then be removed from our marketing lists. However, we may still communicate with you, for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and Similar Technologies

Most web browsers are set to accept cookies by default. However, you can usually change your browser settings to remove or reject cookies. Removing or rejecting cookies may affect certain features or Services.

To opt out of interest-based advertising by advertisers on our Services, visit http://www.aboutads.info/choices/. More information is available in our Cookie Policy: https://vatanmed.pl/polityka-plikow-cookie/.

If you have questions or comments about your privacy rights, you may contact us at poland@vatanmed.com.

9. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting that you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected.

At this stage, no uniform technology standard for recognizing and implementing DNT signals has been adopted. As such, we currently do not respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online.

If a standard for online tracking is adopted in the future that we are required to follow, we will inform you about that practice in an updated version of this Privacy Policy.

10. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes. If you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits users who are California residents to request and obtain from us, once a year and free of charge, information about the categories of personal information, if any, that we disclosed to third parties for direct marketing purposes, as well as the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year.

If you are a California resident and would like to make such a request, please submit your request to us in writing using the contact details provided below.

If you are under 18 years of age, reside in California, and have a registered account with our Services, you have the right to request the removal of unwanted data that you publicly posted on the Services.

To request the removal of such data, please contact us using the contact details provided below and include the email address associated with your account and a statement that you reside in California. We will ensure that the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all of our systems, for example, from backups.

CCPA Privacy Notice

The California Code of Regulations defines a “resident” as:

1. every individual who is in the State of California for other than a temporary or transitory purpose; and
2. every individual who is domiciled in the State of California but is outside the State of California for a temporary or transitory purpose.

All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, we must comply with certain rights and obligations regarding your personal information.

What Categories of Personal Information Do We Collect?

We have collected the following categories of personal information in the preceding twelve (12) months:

We will use and retain the collected personal information as needed to provide the Services or as follows:

• Category A — indefinitely.

We may also collect other personal information outside of the categories listed above in instances where you interact with us in person, online, by telephone, or by mail, including in connection with:

• receiving assistance through our customer support channels;
• participating in customer surveys or contests;
• facilitating the delivery of our Services and responding to your inquiries.

How Do We Use and Share Your Personal Information?

More information about our data collection and sharing practices can be found in this Privacy Policy and in our Cookie Policy: https://vatanmed.pl/polityka-plikow-cookie/.

You may contact us by email at poland@vatanmed.com or use the contact details provided at the end of this document.

If you use an authorized agent to exercise your right to opt out, we may deny the request if the authorized agent does not provide proof that they have been properly authorized to act on your behalf.

Will Your Information Be Shared With Anyone Else?

We may disclose your personal information to our service providers pursuant to a written contract between us and each such service provider. Each service provider is a for-profit entity that processes information on our behalf in accordance with the same strict privacy protection obligations required by the CCPA.

We may use your personal information for our own business purposes, such as conducting internal research for technological development and demonstration. This is not considered to be the “sale” of your personal information.

Vatanmad has not disclosed, sold, or shared any personal information with third parties for business or commercial purposes during the preceding twelve (12) months. Vatanmad will not sell or share personal information belonging to website visitors, users, or other consumers in the future.

Your Rights With Respect to Your Personal Information

Right to Request Deletion of the Data — Request to Delete

You may request the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as, but not limited to, another consumer’s exercise of their right to free speech, our need to comply with a legal obligation, or processing necessary to protect against unlawful activities.

Right to Be Informed — Request to Know

Depending on the circumstances, you have the right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information with third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information;
• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not required to provide or delete information that has been de-identified in response to a consumer request, nor are we required to re-identify individual data to verify a consumer request.

Right to Non-Discrimination for Exercising Your Privacy Rights

We will not discriminate against you for exercising your privacy rights.

Right to Limit the Use and Disclosure of Sensitive Personal Information

We do not process consumers’ sensitive personal information.

Verification Process

Upon receiving your request, we will need to verify your identity to determine whether you are the same person to whom the information in our system relates.

As part of the verification process, we may ask you to provide information that allows us to compare it with information you previously provided to us. For example, depending on the type of request you submit, we may ask you to provide certain information so that we can compare it with information already contained in our records, or we may contact you through a previously provided method of communication, such as telephone or email. Depending on the circumstances, we may also use other verification methods.

We will use personal information provided in connection with your request solely for the purpose of verifying your identity or your authority to make the request. To the extent possible, we will avoid requesting additional information for verification purposes.

However, if we are unable to verify your identity based on the information already in our possession, we may ask you to provide additional information to confirm your identity and for security or fraud-prevention purposes. We will delete such additionally provided information promptly after completing the verification process.

Other Privacy Rights

• You may object to the processing of your personal information.
• You may request correction of your personal information if it is incorrect or no longer relevant, or request restriction of its processing.
• You may designate an authorized agent to make a request under the CCPA on your behalf. We may deny a request from an agent who does not provide proof that they have been properly authorized to act on your behalf in accordance with the CCPA.
• You may request to opt out of the future sale or sharing of your personal information with third parties. Upon receiving such a request, we will act as soon as reasonably practicable, but no later than fifteen (15) days from the date the request is submitted.

To exercise these rights, you may contact us by email at poland@vatanmed.com or by using the contact details provided at the end of this document. If you have a complaint about how we process your data, we would like to hear from you.

11. DO WE MAKE UPDATES TO THIS POLICY?

In Short: Yes. We will update this Policy as necessary to stay compliant with relevant laws.

We may update this Privacy Policy from time to time. The updated version will be indicated by a new “Updated” date and will become effective as soon as it is made available.

If we make material changes to this Privacy Policy, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification.

We encourage you to review this Privacy Policy regularly to stay informed about how we protect your information.

12. HOW CAN YOU CONTACT US ABOUT THIS POLICY?

If you have questions or comments about this Policy, you may contact us by email at poland@vatanmed.com or by post at:

Vatanmad
Poland

13. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Depending on the laws applicable in your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it.

To request to review, update, or delete your personal information, please submit a request form by clicking here.