We present information on how Willet 24 Sp. z o.o. with its registered office in Warsaw, ul. Franciszka Klimczaka 1, 02-797 Warsaw, entered into the register of entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XIII Economic Division of the National Court Register under KRS: 0000583559, TAX ID [NIP]: 5223045539, REGON: 363013926 processes the Personal Data provided by Users on the occasion of visiting www.neonatolin.com („Site”).

§ 1 DEFINITIONS

1. Personal Data – shall be construed as personal data within the meaning of Article 4(1) of the of the GDPR which Users make available to the Controller in connection with the use of the Site.
2. Controller – shall be construed as Willet 24 Sp. z o.o. with its registered office in Warsaw, ul. Franciszka Klimczaka 1, 02-797 Warsaw, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register under KRS: 0000583559, TAX ID [NIP]: 5223045539, REGON no.: 363013926.
3. GDPR - shall be construed as 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).
4. Site – shall be construed as the Site www.neonatolin.com.
5. User – shall be construed as any person using the Site in any way.

§ 2 GENERAL INFORMATION

1. The Controller is the Controller of Users' Personal Data
2. in any matters related to the protection of Users' Personal Data, including for the purposes of exercising Users' rights as the persons to whom the Personal Data pertains (these rights are described below), the Controller may be contacted by e-mail at the following address: www.neonatolin.com www.neonatolin.comor by post at the address of the registered office at ul. Franciszka Klimczaka 1, 02-797 Warsaw.

§ 3 DATA CATEGORIES AND PURPOSES OF PROCESSING

1. The Controller shall process the following categories of Users' Personal Data:
   • Basic identification data entered voluntarily into the contact form on the Site, e.g. name, surname, e-mail address, telephone,
   • Cookies and other data of diagnostic nature collected by the Controller during use of the Service, e.g. Internet logs and IP addresses of Users.
2. Personal Data of Users shall be processed for the following purposes:
   • for the purpose of carrying out business performed at your request prior to the conclusion of an agreement, for the purpose of concluding and performing an agreement with the Controller, for the purpose of performing an agreement concluded with Willet 24 Sp. z o.o. on your behalf as a third party (Article 393 of the Civil Code), when another entity is a contracting party - pursuant to of Article 6(1)(b) of the GDPR and no longer than until the completion of the aforementioned business;
   • to distribute a newsletter which may contain commercial information on the business, services and products provided by the Controller (if the relevant consent has been obtained) – pursuant to of Article 6(1)(a) of the GDPR and no longer than until the withdrawal of the consent;
   • fulfilment of obligations imposed on the Controller by relevant legislation – pursuant to of Article 6(1)(c) of the GDPR and for no longer than the period of the statute of limitations for public law claims;
   • for the purposes of the Controller's legally legitimate interests, including the promotion and advertising of the Controller's business, services and products (for no longer than the period for which an objection is raised), responding to messages and enquiries submitted to the Controller, ongoing cooperation and contacts with our customers' representatives in order to provide services pursuant to effective agreements, monitoring traffic on the Site, ensuring its correct and optimal work, diagnosing errors related to the operation of the server, analysing possible security breaches and Site management, and for statistical purposes, i.e. collection and analysis of demographic data of Users (where the connection was made from), and adaptation of the Service to the needs and interests of Users, investigation and defence against claims, archiving for the purposes of protection of the Controller's legally legitimate interests (e.g. demonstrating compliance with the relevant provisions of law (no longer than until these purposes are attained) - pursuant to Article 6 (1) (f) of the GDPR),
3. With regard to the purposes related to the fulfilment of the legitimate interests related to the protection of the Controller's legal interest, we are entitled to process data by automated shall be construed as, including using profiling on the principles set forth in this Privacy Policy and the Cookies Policy.

§ 4 COOKIES AND SIMILAR TECHNOLOGY

1. The Controller shall use cookies mainly to provide the User with services provided electronically and to improve the quality of these services. Accordingly, the Controller and other entities providing analytical and statistical services to the Controller use cookies, storing information or accessing information already stored in the User's telecommunications terminal equipment (computer, phone, tablet, etc.). The use of cookies on the Site shall not be intended to identify Users. The Policy regulates the processing of data related to the use of its own cookies.
2. Necessary cookies
   • The Controller shall use necessary cookies primarily to provide Users with the services and functionalities of the Site that the User wishes to use. Necessary cookies may only be installed by the Controller through the Site.
   • The legal basis for the processing of data in connection with the use of essential cookies is the necessity of the processing for the performance of the contract (Article 6(1)(b) of the GDPR).
3. Functional and analytical cookies
   • Functional cookies shall be used in order to remember and adapt the Site to the User's choices, inter alia in terms of language preferences. Functional cookies may be installed by the Controller and its partners through the Site.
   • Analytical cookies make it possible to obtain information such as the number of visits and traffic sources on the Site. They are used to determine which pages are more and which are less popular, and to understand how Users navigate the Site by keeping statistics on traffic on the Site. The processing is done to improve the performance of the Site. The information collected by these cookies is aggregated and is therefore not intended to establish the identity of the User. Functional cookies may be installed by the Controller and its partners through the Site.
4. The legal basis for the processing of Personal Data in connection with the use of necessary and analytical cookies by the Controller, for this purpose, is its legitimate interest (Article 6(1)(f) of the GDPR) in ensuring the highest quality of services provided on the Site.
5. The processing of Personal Data on the occasion of the use of functional and analytical cookies shall be subject to the User's consent to the use (separately) of functional and analytical cookies via the cookie consent management platform. This consent can be withdrawn at any time via this platform.
6. Advertising cookies
   • Advertising cookies allow the advertising content displayed to be tailored to the interests of Users within and outside the Site. Based on the information from these cookies and the User's activity on other sites, a profile of the User's interests is built. Advertising cookies may be installed by the Controller and its partners through our Site.
7. The legal basis for the processing of Personal Data in connection with the use of advertising cookies by the Controller, for this purpose, is the Controller's legitimate interest (Article 6(1)(f) of the GDPR) in ensuring the highest quality of services provided on the Site.
8. The Personal Data may be processed on the occasion of the use of advertising cookies after obtaining the User's consent to the use of consent through the consent management platform. This consent may be withdrawn at any time through this platform

§ 5 PROCESSING TIME

1. The Controller shall only collect and process Personal Data that is necessary and appropriate for the fulfilment of the purposes set out above. The Controller shall keep them for no longer than is necessary to fulfil these purposes.
2. Where Personal Data is processed pursuant to consent, such consent may be withdrawn at any time, but this will not affect the lawfulness of the processing carried out pursuant to of consent prior to its withdrawal.
3. The provision of personal data by Users is voluntary but necessary for the above purposes - this will not be the case if they refuse to provide it.

§ 6 RIGHTS OF DATA SUBJECTS

1. Users shall enjoy the following rights:
   • The right to access their Personal Data, to obtain a copy of it and to be informed, inter alia, of the purposes of its processing, the categories, recipients and the period of storage of such data;
   • The right to require the Controller to erase one’s Personal Data ("the right to be forgotten") in certain situations, including where the processing is unlawful, is no longer necessary for the purposes for which the data were collected, or where an objection has been raised and there are no other legal grounds for processing the data;
   • The right to request the Controller to restrict the processing of one's Personal Data in certain situations, including during the period of the Controller's verification of the accuracy of the Personal Data that has been contested or until the verification of the raised objection;
   • The right to portability of one's Personal Data, i.e. to receive it in a structured, commonly used format and to provide it to another controller, provided that the data are collected pursuant to the consent given or processed on the occasion of the performance of a contract concluded with the Controller;
   • The right to object to the processing of one's Personal Data where it is carried out for the purposes of the Controller's legitimate interests - on grounds relating to the User's particular situation;
   • The right to object to the processing of one’s Personal Data if it is carried out for direct marketing purposes;
   • The right to withdraw one's consent, where the User has given his/her consent to the processing of Data;
   • The right not to be subject to a decision which is based solely on automated processing, including profiling;
   • The right to lodge a complaint with a supervisory authority if it is considered that the processing by the Personal Data fails to comply with the applicable legislation.

§ 7 RECIPIENTS OF DATA

1. The Controller may make Personal Data available to third parties (recipients) who cooperate with the Controller in the operation of the Service and provide services to the Controller in this regard.
2. All entities to which the Controller will make Personal Data available shall be required to process such data in accordance with applicable regulations, including the GDPR.

§ 8 EXTERNAL SITES

The Site may contain links to external Sites and social networks that do not belong to the Controller. The Controller shall not be responsible for the manner in which personal data is processed or the use of cookies by entities owning external Sites and recommends reading the privacy policies published there.

§ 9 FINAL PROVISIONS

This Privacy Policy shall be updated on an ongoing basis by the Controller. Any amendments caused by changes in the provisions of law or related to changes in the offer of services available on the Site or the development of its functionalities shall be forthwith communicated on the Site.