Privacy Policy

Last modified: 02/08/2022


The following Privacy Policy defines rules for storing and accessing data on Users' Devices using the Website for the purpose of providing electronic services by the Administrator, and rules for collecting and processing Users' personal data that they have provided personally and voluntarily through the tools available on the Website.

The following Privacy Policy is an integral part of the Regulations of Service, which defines the rules, rights and obligations of Users using the Service.

§1 Definitions

  • Service - Internet service "Wenar e-mob" operating at https://wenar.eu

  • External service - websites of partners, service providers or recipients cooperating with the Administrator

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  • Service / Data Administrator - the Administrator of the Service and the Data Administrator (hereinafter referred to as the Administrator) is the company "WENAR sp. z o.o.", conducting business at: 322 Cieszynska Street, 43-300 Bielsko-Biała, with assigned tax identification number (NIP): 9372662222, with assigned KRS number: 0000412028, providing services electronically through the Service

  • User - a natural person for whom the Administrator provides electronic services through the Service.

  • Device - an electronic device with software through which the User accesses the Service

  • Cookies (cookies) - text data collected in the form of files placed on the User's Device

  • 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 one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person

  • Processing - means an operation or set of operations performed on personal data or sets of personal data by automated or non-automated means, such as collection, recording, organizing, structuring, storing, adapting or modifying, retrieving, viewing, using, disclosing by transmission, dissemination or otherwise making available, matching or linking, limiting, erasing or destroying;

  • Processing Limitation - means the marking of stored personal data to limit its future processing

  • Profiling - means any form of automated processing of personal data that involves the use of personal data to evaluate certain personal factors of an individual, in particular to analyze or forecast aspects relating to that individual's work performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movement

  • Consent - consent of the data subject means a voluntary, specific, informed and unequivocal demonstration of will by which the data subject, in the form of a statement or explicit affirmative action, consents to the processing of personal data concerning him/her

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

  • Pseudonymization - means the processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and is covered by technical and organizational measures preventing its attribution to an identified or identifiable natural person

  • Anonymization - Data anonymization is an irreversible process of data operations that destroys / overwrites "personal data" making it impossible to identify, or link, a particular record to a specific user or individual.

§2 Data Protection Officer

On the basis of Article 37 of RODO, the Administrator has not appointed a Data Protection Officer.

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

§3 Types of Cookies

  • Internal cookies - files posted and read from the User's Device by the Service's data communications system

  • External cookies - files posted and read from the User's Device by the Service's ICT systems of external Services. The scripts of External Services that may place Cookies on User Devices have been knowingly placed on the Service through scripts and services made available and installed on the Service

  • Session Cookies - files placed and read from the User Device by the Service during a single session of a given Device. When the session ends, the files are deleted from the User Device.

  • Permanent Cookies - files posted and read from the User Device by the until they are manually deleted. The files are not deleted automatically after the end of the Device session unless the configuration of the User Device is set to delete cookies after the end of the Device session.

§4 Data Storage Security

  • Cookie Storage and Reading Mechanisms - The mechanisms for storing, reading, and exchanging data between Cookies stored on a User Device and the Service are implemented through the built-in mechanisms of web browsers and do not allow other data to be retrieved from the User Device or data of other websites visited by the User, including personal data or confidential information. It is also virtually impossible to transfer viruses, Trojan horses and other worms to the User Device.

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

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  • External Cookie - The Administrator makes all possible efforts to verify and select service partners in the context of Users' security. The Administrator selects well-known, large partners with global public trust for cooperation. However, it does not have full control over the content of cookies from external partners. The Administrator is not responsible for the security of Cookie files, their content and their use in accordance with the license by the Scripts installed in the service, coming from external Services, as far as the law allows. The list of partners is provided later in the Privacy Policy.

  • Control of Cookies

  • Threats on the side of the User - The Administrator uses all possible technical measures to ensure the security of the data placed in cookies. However, it should be noted that ensuring the security of this data depends on both parties including the activities of the User. The Administrator is not responsible for the interception of this data, impersonation of the User's session or its deletion, as a result of the User's conscious or unconscious activity, viruses, Trojan horses and other spyware with which the User's Device may be or has been infected. Users, in order to protect themselves from these threats, should follow the rules for safe use of the Internet.

  • Personal Data Storage - The Administrator ensures that it makes every effort to ensure that the processed personal data voluntarily entered by Users is secure, access to it is limited, and it is carried out in accordance with its purpose and the purposes of processing. The Administrator also ensures that it makes every effort to secure the data it holds against loss, through the use of appropriate physical as well as organizational safeguards.

  • Password storage - The Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. It is virtually impossible to decrypt account passwords provided on the Service.

§5 Purposes for which cookies are used

  • To improve and facilitate access to the Service
  • Personalizing the Service for Users
  • Enabling Login to the Service
  • Marketing, Remarketing in external services
  • Advertising serving services
  • Affiliate services
  • Maintaining statistics (users, number of visits, types of devices, links, etc.)
  • Serving multimedia services
  • Providing community services

§6 Purposes of personal data processing

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

  • Realization of electronic services:
    • Services of registration and maintenance of the User's account on the Website and functionalities related to it
    • Newsletter services (including sending advertising content with consent)
    • Services for commenting / liking posts on the Service without registering
    • Services for sharing information about content posted on the Service on social networks or other sites.
  • The Administrator's communication with Users on matters related to the Service and data protection
  • Provide for the legitimate interest of the Administrator

Data about Users collected anonymously and automatically is processed for one of the following purposes:

  • Maintaining statistics
  • Remarketing
  • Serving ads tailored to Users' preferences
  • Servicing affiliate programs
  • Providing the Administrator's legitimate interest

§7 Cookies of External Services

The Administrator on the Website uses javascript and web components of partners that may place their own cookies on your Device. Remember that in your browser settings you can decide for yourself about the allowed cookies that can be used by particular websites. Below is a list of partners or their services implemented on the Website that may place cookies:

Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, privacy policies, purpose of data processing, and use of cookies at any time.

§8 Types of data collected

The Service collects data about Users. Part of the data is collected automatically and anonymously, and part of the data is personal data voluntarily provided by Users when signing up for particular services offered by the Website.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Open subpages of the website
  • Time spent on relevant sub-page of the website
  • Type of operating system
  • Previous sub-page address
  • Address of referring page
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected during registration:

  • Name/surname/alias
  • Login
  • E-mail address
  • IP address (collected automatically)
  • TIN number

Data collected when signing up for the Newsletter service

  • Name / surname / nickname
  • E-mail address
  • IP address (collected automatically)

Data collected when adding a comment

  • Name and surname/pseudonym
  • E-mail address
  • Web address
  • IP address (collected automatically)

Some data (without identifying information) may be stored in cookies. Part of the data (without identifying data) may be transferred to a statistical service provider.

§9 Access to personal data by third parties

In principle, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or resold to third parties.

Access to the data (most often on the basis of the Contract of Entrustment of Data Processing) may have entities responsible for maintaining the infrastructure and services necessary for the operation of the service, i.e.:

  • Firms through which the Newsletter service is provided
  • Firms mediating online payments for goods or services offered within the Service (in case of making purchase transactions on the Service)
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  • Firms responsible for the delivery of physical products to the User (postal/courier services in case of making purchase transactions on the Site)
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Transfer of personal data processing - Newsletter

Administrator, in order to provide the Newsletter service, uses the services of a third party - MailChimp, The data entered in the newsletter subscription form is transmitted, stored and processed in the third-party service of this service provider.

Please be advised that the indicated partner may modify the indicated privacy policy without the consent of the Administrator.


Processing of data in case of online payments

In case of online payment processing, all payment data are transferred directly by the User to the payment processor - rel="nofollow external" href="" The selected data necessary to complete the transaction are then transferred by this entity to the Administrator. The transfer of data is governed by an agreement between the Administrator and the Service Provider.


Transfer of personal data - Courier Services

When a transaction is concluded that requires the transfer of the subject matter of the transaction through the mail or by courier, part of the personal data of individuals or data of individuals conducting business is transferred to the entity providing postal/courier services on behalf of the Administrator, selected by the User. The transfer of this data is governed by an agreement between the Administrator and the Service Provider.


§10 Method of processing personal data

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless published as a result of an individual action of the User (e.g., entering a comment or entry), which will make the data available to any person visiting the site.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be resold to third parties.

Anonymized data (without personal information) collected automatically:

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

§11 Legal grounds for processing 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 April 27, 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 consented to the processing of his/her personal data for one or more specified purposes
    • Article 6(1)(b)
      processing is necessary for the performance of a contract to which the data subject is a party, or 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 legitimate interests pursued by the controller or by a third party
  • The Act of May 10, 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
  • Act of July 16, 2004. Telecommunications Law (Journal of Laws 2004 No. 171 item 1800)
  • The Act of February 4, 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24 item 83)

§12 Personal data processing period

Personal data provided voluntarily by Users:

As a rule, the indicated personal data are kept only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized within a period of up to 30 days from the termination of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation that requires securing the legitimate purposes of further processing of such data by the Administrator. In such a situation, the Administrator will keep the indicated data, from the time of the User's request for deletion, no longer than for a period of 3 years in case of violation or suspected violation of the provisions 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 statistics of the service for an indefinite period of time

§13 Users' rights related to the processing of personal data

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

  • Right to access personal data
    Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator

  • Right to rectification of personal data
    Users have the right to request the Administrator to promptly rectify their personal data that is inaccurate or/and to complete incomplete personal data, exercised upon request submitted to the Administrator

  • Right to delete personal data
    Users have the right to demand from the Administrator the immediate deletion of their personal data, realized upon a request submitted to the AdministratorIn the case of user accounts, deletion of data consists of anonymization of data that allows identification of the User. The Administrator reserves the right to withhold the execution of a request for deletion of data in order to protect the legitimate interest of the Administrator (e.g. when the User has committed a violation of the Rules and Regulations or the data was obtained as a result of conducted correspondence).
    In the case of the Newsletter service, the User has the possibility to delete his/her personal data on his/her own using a link placed in each e-mail message sent.

  • Right to limit processing of personal data
    Users have the right to restrict the processing of their personal data in the cases indicated in Article 18 of the RODO, including but not limited to questioning the accuracy of their personal data, exercised upon request made to the Administrator

  • Right to portability of personal data
    Users have the right to obtain from the Administrator, personal data concerning the User in a structured, commonly used machine-readable format, exercised upon request submitted to the Administrator

  • 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 RODO, exercised upon request made to the Administrator

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

§14 Contact to the Administrator

The Administrator can be contacted in one of the following ways

  • Postal address - WENAR sp. z o.o., 322 Cieszynska St., 43-300 Bielsko-Biala

  • E-mail address - info@wenar.pl

  • Phone connection - +48 33 445 13 31

  • Contact form - available at: /contact

§15 Service Requirements

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

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  • Administrator shall not be held responsible for malfunctioning features of the Service if the User restricts the saving and reading of Cookies in any way.

§16 External Links

In the Service - articles, posts, entries or comments of Users may contain links to external sites with which the Owner of the Service does not cooperate. These links and the sites or files indicated under them may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for the content located outside the Service.

§17 Changes to Privacy Policy

  • Administrator reserves the right to amend this Privacy Policy at will without notice to Users with respect to the use and application of anonymized data or the use of cookies.

  • The Administrator reserves the right to amend this Privacy Policy at will with regard to the processing of Personal Data, of which it will inform Users with user accounts or enrolled in the newsletter service, via email within 7 days of the change in records. Continued use of the services implies familiarization with and acceptance of the introduced changes to the Privacy Policy. In the event that the User does not agree with the introduced changes, he/she is obliged to delete his/her account from the Service or unsubscribe from the Newsletter service.

  • Made changes to the Privacy Policy will be published on this subpage of the Service.

  • Any changes made shall become effective upon publication.