Cookies Policy

Processing of personal data using cookies and other internet technologies

Introduction

Welcome to the .mdd website ("Website") belonging to .mdd Sp. z o.o. (Ltd.) with its registered office in Sępólno Krajeńskie, Poland, at (89-400), ul. Koronowska 22, KRS (National Court Register): 0000097731, NIP (Taxpayer Identification Number): 5611437378, REGON (National Official Business Register): 092911632 ("we", "our", "us" or ".mdd", accordingly).

You will find legal information and our contact details at the end of this Policy.

We use cookies and other similar technologies to access or store information on the device you use to visit this Website. We refer to all of these technologies as "Cookies" for ease of reference in this policy.

This Policy provides information about how Cookies work and when, how and why we and third parties who work with us use cookies. Almost all Cookies work by collecting and storing some form of your personal data, so this Policy also describes the personal data we process or share with others when we use Cookies, as well as the associated data protection rights.

Our General Privacy Policy contains equivalent information regarding our processing of personal data more broadly in connection with this Website.

This Policy may be subject to change from time to time. Any changes made to this Policy will be published on this page and, in the event of any material changes, we will notify you using an appropriate method of communication.

Personal Data Controller

.mdd Sp. z o.o. (Ltd.) with its registered office in Sępólno Krajeńskie, Poland, at (89-400), ul. Koronowska 22, KRS: 0000097731 NIP: 5611437378, REGON: 092911632 in cooperation with DIRECT DIGITAL Sp. z o.o. (Ltd.) with its registered office in Bydgoszcz, Poland, at (85-023), ul. Toruńska 33, KRS: 0000915881, NIP: 9532784828, REGON: 38966249000000, place and read Cookies on your devices in cooperation. Cookies are collected and read by .mdd Sp. z o.o. (Ltd.) and by DIRECT DIGITAL Sp. z o.o. (Ltd.) for individual purposes.

For the purposes of the Data Protection Laws, .mdd and DIRECT DIGITAL are "Joint Controllers" of your personal data processing in respect of all such Cookies, as described in paragraphs 5 and 6, unless this Cookie Policy expressly provides that .mdd is the sole "Controller" of your personal data processing in respect of certain cookies.

Concerning Cookies placed by third parties through this Website, these parties may also be the Controllers of your personal data, which means that they will also be legally responsible to you for the personal data received. Please see Cooperation with Third Parties and Legal Basis for Data Processing for further information.

Cookies

Cookies are small files or other information that are stored on your device or that you access from your device that help us collect data about your activities. The name "Cookies" can refer to browser cookies as well as a range of similar technologies such as tracking pixels / beacons, local shared objects / flash cookies and access to device information (including sensors). Please see the next section for details of the types of cookies used on this Website.

Cookies enable us to provide essential functions of this Website. We also use them for purposes that are not essential but are very useful to us or to you, including storing your settings and preferences, remembering access information, delivering targeted content and marketing information, better understanding which part of this Website is most popular and analysing how it works.

Types of cookies that we use

Cookies are associated with all information stored on or accessed by a user's device and therefore take a variety of forms. We use the following types of Cookies.

Browser cookies

Cookies may originate from us (our own cookies, "first-party cookies") or from third parties whose services we use or with whom we collaborate (“third-party cookies”) and whom we allow to place their cookies, by configuring this Website accordingly. In some cases, we will receive information collected through a third-party cookie, while in other cases, the third party will provide services to us without sharing the information as it was collected with us.

Cookies may be used only for the duration of the browsing session ("session cookies") or longer ("persistent cookies"). Please see the section below for details of the different types of Cookies used by us.

Analytical scripts

Analytics scripts are small pieces of computer code that enable us to track users and their behaviour when they visit the Website. This can be either basic tracking, e.g. tracking to see if and when a user has visited this Website, or advanced tracking, e.g. tracking to see if and when a user has added a product to a request or shopping cart, saved configurations or compared products in the mechanisms provided on the Website.

These scripts also help us to personalise the content and advertisements that are published on the Site, and to provide relevant offers on other websites.

Device data

In some cases, information is accessed and read from the device without writing or accessing a file on the device. As this information is usually personal data, details are provided in the section below.

Tracking Pixel

It is programming code that allows tracking of users and their behaviour on the websites where it is embedded. This can range from basic tracking, i.e. checking whether a user has visited a website, to a detailed record of actions taken by a user, such as adding a product to a basket, selecting a product, submitting a form, etc. The tracking pixel may transmit the collected information to third parties, such as computer code providers.

Types of personal data obtained through Cookies

Through the Cookies that we use, we receive the following types of personal data, including information that we access directly from your computer, phone, tablet or other device without saving or accessing the file:

Browser cookie data: identyfikatory plików cookie, godzina/data, wybrane cookie identifiers, time/date, selected services/products, whether the user has consented to cookies and, if so, to which cookies;

Device data: device model, unique device identifiers, MAC address, IP address, operating system version and device settings, language set, screen resolution, browser version and type;

Log data: time and date of use of this Website, search data and any information stored in Cookies that uniquely identify the browser or user account, e.g. last visit to the Website, length of visit to the Website, type of pages and sub-pages visited, address of the page visited (URL), which step the customer is on in the configurator, browser version and type, language set in the browser, forms filled in / configurations completed, models and offers recently viewed, list of campaigns on the Website in which the customer has participated;

Location data: IP address, and country access data provided on the device; User location data obtained through various positioning technologies such as GPS, Wi-Fi access points and other sensors that transmit data of devices in the vicinity;

Behavioural data: data on the use of this Website that we may process if you visit or use third-party websites or applications to cooperate with us, as well as data on your interaction with the content of this Website (pages visited if you were redirected from a marketing campaign, button clicks, vehicle configuration data, etc.).

We may combine personal information about you or your activities with other information we receive from third parties or publicly available sources, where permitted by law. Please see our General Privacy Policy for more information about the sources of information we may use.

Purposes for the use of Cookies

Cookies are a very common technology used to remember certain information about how users interact with sites and use their devices. The vast majority of sites now use Cookies and they are widely used for a number of reasons.

We use Cookies for the following purposes:

Detailed information on Cookies [file name, file provider, file type and file retention period] is contained in the Website's cookie bar, the settings of which can be accessed here.

User’s consent to the use of Cookies and related personal data

Cookies and related personal data used for essential purposes
Following Data Protection Law, we do not require your consent for the use of these Cookies as they are necessary for the proper functioning of this Website.

Cookies and related personal data used for purposes that are not essential
We will store or read Cookies on your device for non-essential Cookies and process related personal data (or allow our third-party service providers and partners to do so) provided that you have given your consent and not withdrawn it. We ask you to do this via the cookie tool that appears when you visit any page of this Website.

How to give your consent to the use of Cookies that are not essential and related personal data
When you first visit this Website, you will be asked to give your consent to the use of Cookies that are not essential and the personal data that we receive as a result of their use.
You may consent to all Cookies that are not essential by selecting the "Accept All" option, or decline to consent to all Cookies that are not essential by selecting the "Decline" option. You can also choose to consent to Cookies according to the different categories of purposes of use.
If you do not consent to these Cookies, we will not use them or process any personal data in connection with them. Accordingly, your provision of any personal data in connection with Cookies is voluntary, and you may withdraw your consent at any time.
The use of the Cookies or related personal data prior to the withdrawal of consent will be legitimate and lawful. Please see the User Rights and How to Exercise Your Rights sections below for further information on your data protection rights.

Duration of consent
The user's consent will remain valid until it is withdrawn by the user.

How to withdraw consent to the use of Cookies that are not essential and the processing of related personal data
Depending on the type of Cookies, you may withdraw the consent you have previously given concerning Cookies, in one of two ways:

1. By using the cookies tool provided by us on this Website. You may access the cookies tool from any page of this Website at any time by clicking on the "Cookies" variable element (located in the bottom left-hand corner of the Website) and withdrawing your consent by setting the option of the relevant cookie category to "off". Please be advised that email tracking cookies cannot be disabled using this tool.
2. By changing your browser settings. Most web browsers are set by default to accept all cookies. However, you have the option to configure your browser settings so that information about cookies is displayed before they are stored or cookies are categorically rejected. You can find detailed information on the various cookies settings available and the associated changes in the most popular web browsers by clicking on the relevant link below:

1. Google Chrome: https://support.google.com/accounts/answer/61416?hl=en
2. Internet Explorer: https://support.microsoft.com/en-gb/help/17442/windows-internet-explorer- delete-manage-cookies
3. Microsoft Edge: https://privacy.microsoft.com/en-us/windows-10-microsoft-edge-and-privacy
4. Mozilla Firefox: https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
5. Opera: http://www.opera.com/help/tutorials/security/privacy/
6. Safari: https://support.apple.com/kb/PH19214?locale=cs_CZ&viewlocale=en_US

Please note that any changes to your browser settings will only apply to the specific web browser for which you have changed them. If you use more than one web browser on your device, you will need to change the settings separately for each browser and each device. Additional information regarding cookies may be available within the 'help' function of your browser or operating system, or in your device manual.

Cookies and related personal data stored on your device after withdrawal of consent
When you withdraw your consent to Cookies that are not essential, this Website will no longer be able to access or read these Cookies. Depending on the Cookies, this means that files, scripts, code and other cookie-related information may remain stored on your device. You can delete these Cookies by deleting cookies and the browser cache using your browser settings. Please see the links to each of the above popular browsers for more information.

Consequences of refusing/withdrawing consent to Cookies and processing of related personal data
Suppose you refuse or withdraw your consent to the use of Cookies that are not essential or related personal data. In that case, the relevant functions or features of this Website may not function properly or may cease to function. This will not affect your use of the core features and functionality of this Website.

If you disable essential Cookies (or all Cookies) using your browser settings, one or more of the core features and functionalities of this Website, including those designed to ensure safety and security during your visit, will not function properly or will cease to function.

Method of cooperation with third parties and legal basis for data processing

We or third parties may place Cookies on your device, which provide third-party processors with access to your personal data. However, as the processing of your personal data by such processors follows strict instructions for us or the relevant third party, we or the relevant third party are the Data Controller for the processing, as the third parties do not make any decisions about your data. Where applicable (and this is the case in most cases), we or the relevant third party are primarily responsible to you for the processing of your personal data.

Duration of processing and storing of personal data

We do not process or store personal data in an identifiable format for longer than necessary.

We process and retain personal data for the following periods:

1. concerning essential Cookies, the processing of personal data ends at the end of the browsing session, after which the personal data is deleted (with the exception of Cookies used to remember consent preferences, which we retain and process for 13 months from the date of consent);
2. all other personal data related to Cookies is processed until the expiry of the cookie or the withdrawal of the consent that allows such processing and is then deleted.

1. law, a court or supervisory authority requires us to keep your personal data for a longer period or to delete it sooner;
2. the user has made a claim, complaint or concern regarding the processing activities described in this policy; in which case .mdd will retain the user's data for 6 years from the date the claim, complaint or concern was made, similarly DIRECT DIGITAL will retain the user's data for 6 years from the date the claim, complaint or concern was made;
3. you exercise your right to delete the information (where applicable) and we are not obliged to retain it for any reason permitted or required by law.

We disclose your personal data to third parties or allow them access to this data in connection with the above-mentioned purposes.

Our third-party service providers, agents and subcontractors ("Suppliers"), business partners, group companies and other third parties may receive personal data related to Cookies directly from you, from us or one of our suppliers.

Our suppliers can be divided into the following categories:

1. advertising technology (Adtech) and data exchange technology providers,
2. advertising agencies, PR agencies, interactive and creative agencies,
3. providers of cloud-based software systems, including database, email and document management,
4. equipment and technology service providers, including providers of scanning and data destruction services,
5. legal, security and other advisors and consultants,
6. providers of market and customer research services,
7. social networking platforms,
8. providers of data modelling and analytics platforms and websites,
9. website and application developers,
10. hosting providers.

Most of the suppliers we use are administrators with whom we have a contractual agreement that requires them to keep your information secure and only use it under our specific instructions. We only disclose or allow them access to the personal data they need to provide their services.

Concerning the Cookies used on this Website, we specifically use the following key providers.

Google

This Website uses the Google Analytics service provided by Google, Inc. ("Google"), which uses cookies to analyse your use of this Website. The following modules are used on the Website:

1. Google Analytics – account status and performance monitoring, summary of audience information, active users, user browsing, audience analysis, quality of visits, probability of conversion, benchmark reports, demographics and interests, user flow report, AdWords service reports;
2. DoubleClick Digital Marketing – integration of Campaign Manager solution, activation of remarketing and ad reporting functions in Analytics, content marketing optimisation, search engine marketing optimisation, site speed;
3. AdSense – AdSense in Analytics, content grouping, search within the site, events, behaviour change report, target creation and management, attribution, acquisition reports, user behaviour.

The information generated by cookies about your use of this Website (including your IP address) may be transferred to and stored on Google servers in the United States. For more information on the implications of such a transfer, please see Cross-border transfer of personal data.

Google will use this information for the purpose of evaluating your use of this Website, compiling usage reports and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may disable Cookies on this Website in accordance with the instructions above or by changing the relevant settings in your browser. However, if you disable all types of cookies, you will not be able to take full advantage of all elements of this Website.

To opt out of Google Analytics tracking across all sites, please go to: https://tools.google.com/dlpage/gaoptout

Detailed information about the modules mentioned above and Google's processing of personal data can be found on the following pages: www.google.com/policies/privacy/partners and https://policies.google.com/privacy?hl=en.

Facebook

The Website uses analytical cookies, tracking pixels and other technologies from Facebook, Inc. ("Facebook"), which enable them to collect or retrieve data from this Website and any other websites on the internet. Facebook may then use this data to provide services related to targeting and measuring the effectiveness of advertisements. Information collected by Facebook may be transferred to and stored on servers in the United States. For more information on the implications of such transfer, please see Cross-border transfer of personal data.

If you withdraw your consent to personalisation cookies (as described above in this policy) using the consent tool on this Website or disable the collection of cookies in your browser settings, this will terminate Facebook's collection and use of such information, but if you do this for all types of cookies you will not be able to take full advantage of all elements of this Website.

LinkedIn

This Website uses the LinkedIn Insight Tag, a short JavaScript tag from LinkedIn Corporation, a subsidiary of Microsoft Corporation ("LinkedIn"), which allows you to perform in-depth campaign reporting and unlock information about Website visitors that may arise from campaigns on LinkedIn (e.g., learning about demographics by combining LinkedIn data with Site visitor data). Insight Tag enables the collection of data such as IP address, timestamp, and events such as the number of page views. The information collected by Microsoft Corporation may be transferred to and stored on servers in the United States. For more information on the implications of such a transfer, please see Cross-border transfer of personal data.

You can opt out of cookies from LinkedIn on the LinkedIn settings page. You can find more information about Insight Tag here: https://www.linkedin.com/help/lms/answer/a427660/the-linkedin-insight-tag-overview?lang=en .

Synerise

We use Synerise S.A.'s services to collect user session information for analytics purposes, to improve website functionality and for profiling and retargeting.

Other websites

We may disclose your personal data to other third parties:

1. third parties who restructure, sell or acquire some or all of our business or assets or otherwise in the event of a merger, reorganisation or similar event; and
2. if we are required to disclose or share your information in order to comply with any legal or regulatory obligation or request, including from the police, court, regulators, government or other institutions.

Personal data received by other Data Controllers

Where we disclose or allow access to your personal data to third parties who are also Data Controllers (e.g. certain suppliers, group companies or our business partners), such parties may disclose or transfer such data to other organisations in accordance with their data protection policies. For example, this applies to some of the activities described above concerning Facebook. This does not affect the rights of data subjects as detailed below. If you ask us to rectify, erase or restrict the processing of your data, we will take reasonable steps to pass on that request to third parties with whom we have shared your personal data.

Sources of personal data

All personal information obtained through Cookies on this Website is obtained directly from you. We may receive this information from a third party if we are not the party placing the Cookies on your device.

Cross-border transfer of personal data

Personal data related to cookies may be transferred outside of the VGP and the European Economic Area ("EEA") if you have given us your express consent to do so or if we provide appropriate safeguards to protect the data transferred.

In connection with Google Analytics or the use of the analytics, marketing and social media cookies described above and other online technologies such as those provided by Facebook, once you have consented to the transfer of your personal data, your data will be transferred to companies based in the USA and stored on servers located in the United States of America ("USA"). Please note that such transfers may jeopardise the processing of your data due to the absence of a decision establishing an adequate level of protection and the lack of appropriate safeguards. In particular, the transfer and processing of data by our partners in the USA may be subject to surveillance programmes by US authorities, and US intelligence agencies or federal investigators may subsequently access your data. In addition, non-US citizens do not have the same opportunities to object to surveillance by the National Security Agency or the Director of National Intelligence. Furthermore, there is no single authority responsible for surveillance activities in the US. Various points of contact for data protection-related supervisory powers are available in individual US states, including a special Foreign Intelligence Surveillance Court.

If we transfer your information to other countries outside the EU and EEA, we will take steps to ensure that appropriate security measures are in place that serve to guarantee your privacy rights as described in this policy. These steps include:

1. ensuring that countries outside the EU and EEA to which data is transferred have been recognised by the relevant authorities as providing an adequate level of protection of personal data for the purposes of data protection legislation;
2. the imposition of contractual obligations on the recipient of personal data using legislation formally issued by the relevant authorities for this purpose. We use these provisions to ensure that your personal data is protected when we transfer your personal data to our suppliers outside the EU and EEA.

For further information on the safeguards we put in place and to obtain copies of relevant documents, please contact us using the details provided at the end of this policy.

If you use this Website while you are outside the EU and EEA, your data will be transferred outside these areas to enable you to use this Website.

Automated decision-making

We do not envisage that any processing of data to make decisions that have a legal or significant impact on you will be carried out using purely automated means, but we will update this policy and inform you if this position changes.

Exercise of rights

Concerning our processing of your personal data, you have the right to:

1. withdraw consent to cookies and processing (if we are acting based on such consent),
2. request access to your personal data,
3. request the rectification of your personal data,
4. request the erasure or restriction of the processing of your personal data,
5. object to the processing based on legitimate interests (unless there is an overriding legal basis) or for direct marketing purposes,
6. not be subject to automated decision-making that has a significant impact on you,
7. have your data transferred in a machine-readable format to you or another Data Controller,
8. complain with the supervisory authority, which in Poland is the President of the Office for Personal Data Protection.

If you have any questions about this policy, our general processing of your personal data or your data protection rights, you can contact .mdd and DIRECT DIGITAL using the information below:

• .mdd Sp. z o.o.
• ul. Koronowska 22,
• 89 – 400 Sępólno Krajeńskie

• DIRECT DIGITAL Spółka z o.o.
• ul. Toruńska 33,
• 85-023 Bydgoszcz

• iod@mdd.pl

Other information

In order to protect your personal information from unauthorised access, disclosure, alteration or destruction, we have taken appropriate organisational and technical measures, including physical, electronic and management procedures, to ensure the protection and security of the information collected through this Website.