Privacy policy
Contents
1.Controller and contact
- The controller of the personal data of users of the skionline.eu website is SKIONLINE Sp. z o.o., ul. Prosta 109, Kawęczynek, 05-520 Konstancin-Jeziorna, Poland, KRS 0000815915, NIP 123-145-56-23 (hereinafter: “we”). skionline.eu is the English edition of skionline.pl; skionline.pl and its ski market have their own documents.
- For personal data matters, write to [email protected] or by post to our registered office address. We do not handle personal data matters by telephone.
- We have not appointed a data protection officer; we are not required to do so.
- In some matters another entity is the controller: Google for advertising (section 4.2). We indicate this for each purpose.
2.Where we get data from
- from you: the contact form and e‑mails you send us,
- automatically: technical connection data (section 6) and, after your consent, data from cookies (cookie policy),
- from public sources: sources of editorial content.
3.Why we process data and on what legal basis
Abbreviations of the legal bases under Article 6(1) GDPR: (a) consent, (b) contract or steps taken before entering into it, (c) legal obligation, (f) our legitimate interest (named next to the letter). Storing and accessing information on your device for purposes other than strictly necessary ones (statistics, advertising) additionally requires consent under Article 399 of the Polish Electronic Communications Law (Prawo komunikacji elektronicznej).
| Purpose | Data | Legal basis | How long | Recipients |
|---|---|---|---|---|
| Operation of the website, security, protection against abuse | IP address, address of the page visited, browser, time, referring page; on protected forms, the result of Cloudflare Turnstile verification | (f) security and stability of the website | server logs 14 days; an IP address used solely to protect forms is not stored permanently | hosting (section 4.1); Cloudflare as a content delivery network and for Turnstile verification (sections 4.1 and 4.2) |
| Replying to a message sent through the contact form (section 3.1) | subject, first name, e‑mail, message, IP address (protection against abuse) | (f) conducting correspondence | on the website 90 days from sending; a copy in the mailbox up to 12 months from the last message | Google Workspace |
| E‑mail correspondence (editorial, advertising) | sender’s data, content | (f) handling matters; (b) advertising orders | 12 months from the last message | Google Workspace |
| Consent banner (record of your decision) | consent to statistics and to advertising (yes or no), banner version and time of the decision, stored solely in your browser’s storage (cookie policy, section 2) | (f) remembering your choice so that the banner does not ask on every page; storage in the browser is strictly necessary for this (Article 399 of the Electronic Communications Law) | 12 months, after which the banner asks again; you can change your choice earlier in “Cookie settings” | no one; Google receives only information about the consent status |
| Visit statistics (Google Analytics 4) | after consent to statistics: identifiers from Google cookies (cookie policy, section 4), IP address (Google Analytics 4 does not store it in reports), browser, pages visited, events on the website (e.g. a search with the phrase entered); without consent: the same events and page views without cookies and without a browser identifier. Never first names, e‑mail addresses or telephone numbers | cookies: (a) consent (Article 399 of the Electronic Communications Law); measurement without cookies: (f) measuring traffic | cookies up to 2 years (cookie policy); data in Google Analytics according to the service’s standard retention period | Google Ireland Limited and Google LLC (sections 4.1 and 5) |
| Google ads (Ad Manager and AdSense) | after consent to advertising: identifiers from Google advertising cookies (cookie policy, section 5), IP address, browser, page address; without advertising consent Google shows limited ads without cookies | (a) consent to advertising in the banner (Article 399 of the Electronic Communications Law); limited ads without consent: (f) financing the website with advertising | cookies up to 13 months; data on Google’s side according to its own rules | Google Ireland Limited (separate controller, section 4.2) |
| Website search | query entered, IP address (protection against abuse) | (f) searching the content of the website | we do not store queries in the database; the address of the page with the query in the server log for 14 days (section 6) | OVH (hosting, section 4.1); search event in Google Analytics (section 9) |
| Editorial content (people in news stories, authors, photo credits) | first name and surname, nickname, image | (f) journalistic activity and archive; the exemption in Article 2(1) of the Personal Data Protection Act applies to press material | archive, indefinitely | OVH (hosting, section 4.1) |
| Website backups | copy of the website database | (f) business continuity | data deleted from the website disappear from backups within 3 weeks at the latest | OVH (section 4.1) |
3.1. Contact form
- We are the controller of data from the contact form (section 1). You provide a subject (editorial, advertising and partnerships, something else), your first name, e‑mail address and the content of the message. All fields are required; without them we cannot reply to the message.
- We process the data to reply to the message and to continue the correspondence: this is our legitimate interest (Article 6(1)(f) GDPR).
- We forward the message by e‑mail to our mailbox [email protected] (Google Workspace) and reply to the e‑mail address provided. On the website we keep the message for 90 days from sending, and its copy in the mailbox for up to 12 months from the last message in the matter.
- We use the sender’s IP address solely to protect the form against abuse and do not store it permanently. The form is also protected by the Cloudflare Turnstile service (section 4).
- You have the rights described in section 8, including the right to object to processing based on legitimate interest.
On skionline.eu we do not process national identification numbers, identity document numbers, health data or payment card data.
4.Recipients of data
4.1. Entities processing data on our behalf
| Category | Entity | Country |
|---|---|---|
| Hosting of the website, databases and website search | OVH sp. z o.o., ul. Swobodna 1, 50-088 Wrocław (KRS 0000220286); servers in Poland | Poland |
| E‑mail (sending and mailboxes) | Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Google Workspace); data may be processed by Google LLC in the USA (section 5) | Ireland, USA |
| Website backups | OVH sp. z o.o., storage space in Poland | Poland |
| Content delivery network and protection against attacks (all website traffic passes through its servers) | Cloudflare, Inc. | USA |
| Protection of forms against bots (on protected forms only) | Cloudflare, Inc. (Turnstile) | USA |
| Visit statistics (Google Analytics 4) | Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Google Ads and Google Analytics data processing terms); data may be processed by Google LLC in the USA (section 5) | Ireland, USA |
4.2. Separate controllers
- Google Ireland Limited for Google ads on the website; how Google uses data from partner websites,
- Cloudflare, Inc., to the extent that it uses data from Turnstile verification to improve bot detection,
- providers of maps and embedded content: the list, when they load and the data passed to them are set out in the cookie policy, section 6,
- public authorities, where the law requires it.
5.Transfers of data outside the European Economic Area
- We host the website on servers in Poland (OVH), and e‑mail in Google Workspace; as a rule, we process data in the EEA. The following may be transferred outside the EEA:
- technical data (IP address, cookie identifiers, pages visited and events) to Google LLC for visit statistics and advertising, and to Cloudflare, Inc. for content delivery and Turnstile verification: on the basis of European Commission adequacy decision (EU) 2023/1795 (EU-US Data Privacy Framework), to which these companies have signed up,
- e‑mail correspondence in Google Workspace to Google LLC: on the basis of the European Commission adequacy decision (EU-US Data Privacy Framework) and standard contractual clauses.
- Video players loaded after you click connect your browser directly to the provider (cookie policy, section 6).
- You can obtain a copy of the safeguards by writing to [email protected].
6.Technical data and logs
- The server records in its logs the IP address, the address of the requested page, the browser, the time and the referring page. Logs are used to ensure security and fix errors; we keep them for 14 days.
- The map fetches tiles from the OpenFreeMap server: the provider receives the IP address and the coordinates of the area being viewed (cookie policy, section 6).
- We do not permanently store the IP address used to protect forms and search against abuse.
7.Security
We apply technical and organisational measures appropriate to the risk (Article 32 GDPR), including encryption of connections to the website. Only authorised persons have access to the data.
8.Your rights
- You have the right to access your data and obtain a copy of it, the right to rectification, erasure, restriction of processing and data portability (where the basis is a contract or consent), and the right to withdraw consent at any time without affecting earlier processing. You can withdraw consent to cookies using the “Cookie settings” link in the page footer or in the cookie policy.
- You have the right to object at any time to processing based on our legitimate interest. After an objection we stop processing the data unless we demonstrate compelling, overriding grounds.
- Send your request to [email protected]. We reply within one month; for complex matters we may extend this period by a further two months, and we will inform you of this. We may ask you to confirm your identity.
- You have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warszawa, Poland, uodo.gov.pl, or with the supervisory authority of the EU country where you live or work.
- Providing data is voluntary, but without the data marked as required we will not reply to a message.
9.Profiling, automated decisions, statistics and advertising
- We do not profile users ourselves and do not make decisions about them based solely on automated processing which produce legal effects concerning them or similarly significantly affect them (Article 22 GDPR). We do not send a newsletter or carry out direct marketing from skionline.eu.
- For visit statistics we use Google Analytics 4. Google Analytics cookies are stored only after you consent to statistics in the consent banner. Without consent, Google receives only measurements without cookies and without a browser identifier (Google consent mode), on the basis of which it estimates traffic. We do not pass personal data from forms to Google. Details: cookie policy, section 4.
- We display ads on the website via Google Ad Manager and Google AdSense. Without your consent to advertising, Google shows limited ads without cookies, and after consent in the banner it stores advertising cookies and shows ads tailored to your interests (Google’s rules on advertising). You can withdraw consent in “Cookie settings” (cookie policy, section 7); you can also switch off ads selected on the basis of your activity in your Google account settings (adssettings.google.com).
10.Changes to the policy
We change the policy when the law, the scope of our services or our providers change. The new version has its date in the header; we make previous versions available on request.