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Privacy Policy

The following Privacy Policy defines the rules for storing and accessing data on User Devices using the Service for the purpose of providing electronic services by the Administrator and the rules for collecting and processing personal data of Users provided by them personally and voluntarily through tools available in the Service.


§1 Definitions

  • Service - the internet service "AtirSoft" operating at https://atirsoft.io
  • External Service - internet services of partners, service providers, or service recipients cooperating with the Administrator
  • Service Administrator / Data Controller - The Service Administrator and Data Controller (hereinafter referred to as the Administrator) is the company "ATIR INWEST SP. Z O.O.", conducting business at: 379A, 32-442, Krzywaczka, with the assigned tax identification number (NIP): 6812070927, providing electronic services 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 - 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 relating to 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 which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction
  • Limitation of Processing - means the marking of stored personal data with the aim of limiting their processing in the future
  • 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 analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements
  • Consent - consent of the data subject 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, unauthorized disclosure of, or access to, personal data transmitted, stored, or otherwise processed
  • Pseudonymization - 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 organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
  • Anonymization - Anonymization of data is the irreversible process of operations on data that destroys/overwrites "personal data" making it impossible to identify, or link, a particular record with an individual user or person.

§2 Data Protection Officer

In accordance with Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer. For matters concerning the processing of data, including personal data, please contact the Administrator directly.


§3 Types of Cookies Files

  • Internal Cookies - files placed and read from the User's Device by the teleinformation system of the Service
  • External Cookies - files placed and read from the User's Device by teleinformation systems of external Services. Scripts of external Services that may place Cookies files on User's Devices have been deliberately placed in the Service through scripts and services provided and installed in the Service.
  • Session Cookies - files placed and read from the User's Device by the Service
  • Persistent Cookies - files placed and read from the User's Device by the Service

§4 Data Storage Security

  • Cookie Storage and Retrieval Mechanisms - Storage, retrieval, and data exchange mechanisms between Cookies Files stored on the User's Device and the Service are implemented through built-in mechanisms of web browsers and do not allow for the retrieval of other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, trojans, and other malware to the User's Device is also practically impossible.
  • Internal Cookies - Cookies files used by the Administrator are safe for User Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the User's Device.
  • External Cookies - The Administrator takes all possible actions to verify and select service partners in terms of User security. The Administrator selects well-known, large partners with global social trust for cooperation. However, the Administrator does not have full control over the content of Cookies files from external partners. The Administrator is not responsible for the security of Cookies files, their content, or their licensed use by installed Scripts originating from external Services to the extent permitted by law. The list of partners is included in the further part of the Privacy Policy.
  • Cookie Control
  • User-side Threats - The Administrator employs all possible technical means to ensure the security of data placed in Cookies files. However, it should be noted that ensuring the security of this data depends on both sides, including User activity. The Administrator is not responsible for intercepting this data, impersonating the User's session, or deleting it due to deliberate or inadvertent User activity, viruses, trojans, and other spyware that may or may have been infected on the User's Device. Users should adhere to internet usage guidelines to protect themselves from these threats.
  • Storage of Personal Data - The Administrator ensures that every effort is made to ensure that voluntarily provided personal data by Users is secure, access to it is restricted, and it is processed in accordance with its purpose and processing objectives. The Administrator also ensures that all efforts are made to secure the data held against loss, through the use of appropriate physical and organizational security measures.

§5 Purposes for which Cookies Files are Used

  • Improving and facilitating access to the Service
  • Personalizing the Service for Users
  • Conducting statistics (users, number of visits, types of devices, bandwidth, etc.)
  • Providing social services

§6 Purposes of Personal Data Processing

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

  • Electronic service provision:
    • Services providing information about content posted on the Website on social media platforms or other websites.
  • Communication of the Administrator with Users regarding matters related to the Service and data protection
  • To ensure the legally justified interest of the Administrator

Anonymous data collected automatically are processed for one of the following purposes:

  • Conducting statistics
  • To ensure the legally justified interest of the Administrator

§7 Cookies of External Services

In the Service, the Administrator uses javascript scripts and web components from partners who may place their own cookies on the User's Device. Remember that in your browser settings, you can decide on the allowed cookies that can 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 control of the Administrator. These entities may change their terms of service, privacy policies, data processing purposes, and ways of using cookies at any time.


§8 Types of Collected Data

The Service collects data about Users. Some data is collected automatically and anonymously, and some data are personal data voluntarily provided by Users when registering for individual services offered by the Service.


Automatically collected anonymous data:

  • IP address
  • Approximate location
  • Pages visited on the website
  • Time spent on a specific page of the website

Data collected during registration:

  • Name / surname / pseudonym
  • Email address
  • Phone number
  • IP address (collected automatically)

Data collected during Newsletter subscription

  • Email address

Some data (without identifying data) may be stored in cookies files. Some 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. The data collected as part of the services provided are not transferred or resold to third parties.


Access to data (usually based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary for the operation of the service, such as:

  • Hosting companies providing hosting services or related services for the Administrator

Data Processing Agreement - Hosting, VPS, or Dedicated Servers Services:

In order to operate the service, the Administrator uses the services of an external hosting provider, VPS, or Dedicated Servers - . All data collected and processed on the website is stored and processed in the infrastructure of the service provider located in Poland. There is a possibility of accessing the data as a result of service work carried out by the service provider's staff. Access to this data is regulated by an agreement between the Administrator and the Service Provider.


§10 Method of Processing Personal Data

Personal data voluntarily provided by Users:

  • Personal data will not be transferred outside the European Union unless it has been published as a result of individual user action (e.g., posting a comment or entry), making 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.

Anonymized data (without personal data) collected automatically:

  • Anonymized data (without personal data) 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 Basis for Processing Personal Data

The Service collects and processes User 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 May 10, 2018 on the protection of personal data (Journal of Laws of 2018, item 1000)
  • Act of July 16, 2004 Telecommunications Law (Journal of Laws of 2004 No. 171 item 1800)
  • Act of February 4, 1994 on copyright and related rights (Journal of Laws of 1994 No. 24 item 83)

§12 Period of Personal Data Processing

Personal data voluntarily provided by Users:

As a rule, the specified personal data are stored only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized within 30 days from the end of service provision (e.g., deleting a registered user account, unsubscribing from the Newsletter, etc.). An exception is a situation that requires securing the legally justified interests of further processing of this data by the Administrator. In such a situation, the Administrator will store the specified data, from the time of the User's request for their deletion, for no longer than 3 years in the event of a violation or suspicion of a violation of the provisions of the service regulations by the User.


Anonymized data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, are stored by the Administrator for the purpose of conducting website statistics for an indefinite period.


§13 User Rights Related to Personal Data Processing

The Service collects and processes User data on the basis of:

  • Right of access to personal data
    Users have the right to access their personal data, exercised upon request to the Administrator
  • Right to rectification of personal data
    Users have the right to request the Administrator to promptly rectify personal data that is incorrect and/or to complete incomplete personal data, exercised upon request to the Administrator
  • Right to erasure of personal data
    Users have the right to request the Administrator to promptly erase personal data, exercised upon request to the Administrator. In the case of user accounts, data deletion involves anonymization of data enabling the identification of the User. The Administrator reserves the right to suspend the execution of the data deletion request in order to protect the legally justified interests of the Administrator (e.g., when the User violates the Service Regulations or the data was obtained as a result of correspondence). In the case of the Newsletter service, the User has the possibility to independently delete their personal data using the link provided in each email sent.
  • Right to restriction of processing of personal data
    Users have the right to restrict the processing of personal data in cases specified in Article 18 of the GDPR, including questioning the accuracy of personal data, exercised upon request to the Administrator
  • Right to data portability
    Users have the right to receive from the Administrator personal data concerning them in a structured, commonly used, machine-readable format, exercised upon request 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 cases specified in Article 21 of the GDPR, exercised upon request to the Administrator
  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data.

§14 Administrator Contact Information

The Administrator can be contacted in one of the following ways:

  • Mailing address - ATIR INWEST SP Z O.O., 379A, 32-442, Krzywaczka
  • Email address - info@atirsoft.io
  • Phone call - +48 662 408 198

§15 Service Requirements

  • Limiting the storage and access to Cookie files on the User's Device may cause some functions of the Service to malfunction.
  • The Administrator is not responsible for any malfunctioning functions of the Service if the User limits in any way the possibility of storing and reading Cookie files.

§16 External Links

In the Service - articles, posts, entries, or comments by Users may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated beneath them may be dangerous for 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 the Privacy Policy

  • The Administrator reserves the right to make any changes to this Privacy Policy without the need to inform Users to the extent of the application and use of anonymous data or the use of Cookie files.
  • The Administrator reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, which will be communicated to Users with user accounts or subscribed to the newsletter service by email within 7 days of the change. Further use of the services implies familiarity with and acceptance of the introduced changes to the Privacy Policy. If the User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
  • The introduced changes to the Privacy Policy will be published on this subpage of the Service.
  • The introduced changes come into effect upon their publication.