The following Privacy Policy sets out the rules for saving and accessing data on User Devices who use 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 via tools available on the Service.

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

§1 Definitions

  • Service – the website “TINES RAIL” operating at https://tinesrail.com/en/
  • External Service – websites of partners, service providers, or service recipients cooperating with the Administrator
  • Service / Data Administrator – The Service Administrator and the Data Administrator (hereafter Administrator) is the company “TINES RAIL SA”, operating at: 00-105 Warsaw, Twarda 18 Street, WARSAW, with the assigned tax identification number (NIP): 5252776636, and the National Court Register (KRS) number: 0000764008, providing services electronically via the Service
  • User – a natural person for whom the Administrator provides services electronically through the Service.
  • Device – an electronic device along 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 about an identified or identifiable natural person (“data subject”); an identifiable natural person is someone 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 several specific factors defining the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person
  • Processing – means an operation or a set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction;
  • Processing restriction – means the marking of stored personal data with the aim of limiting their future processing
  • 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 analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements
  • Consent – the 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, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
  • Pseudonymisation – 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 organisational 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 identification or associating a given record with a specific user or natural person impossible.

§2 Data Protection Officer

Based on Art. 37 of the GDPR, the Administrator did not appoint a Data Protection Officer.

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

§3 Types of Cookies

  • 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 can place Cookies on the User’s Device have been deliberately placed on 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 during a single session of a given Device. After the session ends, the files are deleted from the User’s Device.
  • Persistent Cookies – files placed and read from the User’s Device by the Service until they are manually deleted. Files are not automatically deleted after the end of the Device session unless the User’s Device configuration is set to delete Cookie files after the end of the Device session.

§4 Data Storage Security

  • Cookie storage and reading mechanisms – Mechanisms for storing, reading, and exchanging data between Cookies saved on the User’s Device and the Service are carried out through built-in internet browser mechanisms and do not allow the downloading of other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. It is also practically impossible to transfer viruses, Trojans, and other worms to the User’s Device.
  • Internal Cookies – Cookies used by the Administrator are safe for the User’s Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the Device used by the User.
  • External Cookies – The Administrator takes all possible actions to verify and select service partners in the context of User security. The Administrator chooses well-known, large partners with global social trust. However, it does not have full control over the content of Cookies coming from external partners. The Administrator is not responsible for the security of Cookies, their content, and their use in compliance with the license by scripts installed in the service, coming from external services, to the extent permitted by law. The list of partners is provided in the further part of the Privacy Policy.
  • Cookie control
    • The User can at any time independently change the settings related to saving, deleting, and accessing data saved from Cookies by any website
    • The User can at any time delete all files saved so far using the tools of the User’s Device through which the User uses the Service’s services.
  • Threats on the User’s side – The Administrator uses all possible technical means to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Administrator does not take responsibility for intercepting this data, impersonating the User’s session, or their deletion, due to the deliberate or unintentional activity of the User, viruses, Trojans, and other spyware that the User’s Device may or has been infected with. To protect against these threats, users should follow recommendations for safe use of the internet.
  • Personal data storage – The Administrator ensures that it makes every effort to ensure that the personal data voluntarily provided by Users are secure, that access to them is limited and is carried out in accordance with their intended purpose and processing purposes. The Administrator also ensures that it makes every effort to secure the data it holds from loss, by applying appropriate physical and organizational safeguards.

§5 Purposes for which Cookies are used

  • Improving and facilitating access to the Service
  • Personalization of the Service for Users
  • Marketing, Remarketing in external services
  • Ad serving services
  • Affiliate services
  • Conducting statistics (users, number of visits, types of devices, links, etc.)
  • Providing multimedia services

§6 Purposes of Processing Personal Data

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

  • Provision of electronic services:
  • Communication between the Administrator and Users regarding the Service and data protection
  • Ensuring the legally justified interest of the Administrator

Data about Users collected anonymously and automatically are processed for the following purposes:

  • Conducting statistics
  • Remarketing
  • Serving ads tailored to the preferences of Users
  • Affiliate program support
  • Ensuring the legally justified interest of the Administrator

§7 External Service Cookies

The Administrator in the Service uses JavaScript scripts and web components of partners who may place their own cookies on the User’s Device. Remember that in your browser settings you can decide for yourself about 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:

  • Media services:
    • YouTube
  • Statistics:
    • Google Analytics
  • Other services:
    • Google Maps

Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, privacy policies, processing purposes, and cookie usage 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 subscribing to specific services offered by the Service.

Anonymous data collected automatically:

  • IP Address
  • Browser type
  • Screen resolution
  • Approximate location
  • Opened service subpages
  • Time spent on a particular service subpage
  • Type of operating system
  • Address of the previous subpage
  • Referring page address
  • Browser language
  • Internet connection speed
  • Internet service provider

Data collected during registration:

  • Email address

Data collected when subscribing to the Newsletter service:

  • Email address

Some data (without identifying information) may be stored in cookies. Some data (without identifying information) may be passed to a statistical service provider.

§9 Access to personal data by third parties

As a rule, 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 data (most often based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary for running the website, such as:

§10 Processing of personal data

Personal data voluntarily provided by Users:

  • Personal data will not be transferred outside the European Union unless published due to individual user action (e.g., posting a comment or entry), making the data available to every person visiting the website.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

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

§11 Legal basis for processing personal data

The website collects and processes user data based on:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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)
    • Art. 6(1)(a)
      The data subject has consented to the processing of their personal data for one or more specific purposes
    • Art. 6(1)(b)
      Processing is necessary for the performance of a contract to which the data subject is a party, or for taking steps at the request of the data subject before entering into a contract
    • Art. 6(1)(f)
      Processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
  • Act of 10 May 2018 on personal data protection (Journal of Laws 2018, item 1000)
  • Act of 16 July 2004 – Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)
  • Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24, item 83)