Privacy Policy

The following Privacy Policy sets out the rules for storing and accessing data on the Devices of Users using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users’ personal data, which were provided by them personally and voluntarily through the tools available in the Service.

§1 Definitions

Service – the website “mily-gabinet.pl” operating at https://mily-gabinet.pl
External Service – websites of partners, service providers, or service recipients cooperating with the Administrator
Service / Data Administrator (Controller) – The Service Administrator and Data Controller (hereinafter the Administrator) is the company “Agata Tabiszewska Indywidualna Praktyka Lekarska Miły Gabinet Pediatryczny”, operating at: Aleja Krakowska 205, Warsaw, with Tax Identification Number (NIP): 9512178295, providing services electronically via the Service
User – a natural person for whom the Administrator provides services electronically via 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 (RODO) – 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, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction
Restriction 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 analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, 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, 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
Anonymisation – Anonymisation of data is an irreversible process of data operations that destroys/overwrites “personal data” making it impossible to identify or link a given record with a specific user or natural person

§2 Data Protection Officer

Based on Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer. In 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 Service’s IT system
External Cookies – files placed and read from the User’s Device by the IT systems of External Services. Scripts of External Services that may place Cookies on User Devices have been intentionally placed in the Service through scripts and services made available 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 deleted automatically after the session ends unless the User’s Device configuration is set to delete Cookies after the session ends.

§4 Data Storage Security

Mechanisms for storing and reading Cookies – Mechanisms for storing, reading, and exchanging data between Cookies saved on the User’s Device and the Service are implemented through built-in browser mechanisms and do not allow for downloading other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. Transfer of viruses, Trojan horses, or other worms to the User’s Device is also practically impossible.
Internal Cookies – Cookies used by the Administrator are safe for Users’ 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 makes all possible efforts to verify and select service partners in the context 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 originating from external partners. The Administrator is not responsible for the security of Cookies, their content, or their use by scripts from External Services installed in the Service, to the extent permitted by law. A list of partners is included further in the Privacy Policy.
Cookie Control
- The User may at any time independently change the settings regarding the saving, deleting, and accessing data of saved Cookies by any website
- Information on how to disable Cookies in the most popular computer browsers is available at: how to disable cookies or from one of the following providers:
- The User may at any time delete any Cookies saved so far using the tools of the User’s Device through which the User uses the Service.
User-side threats – 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 is not responsible for the interception of this data, session hijacking, or its deletion resulting from the conscious or unconscious activity of the User, viruses, Trojan horses, or other spyware with which the User’s Device may be or was infected. To protect themselves against these threats, Users should follow principles that increase their cybersecurity.
Personal Data Storage – The Administrator ensures that every effort is made to keep processed personal data entered voluntarily by Users secure, that access to it is limited and carried out in accordance with its purpose and processing goals. The Administrator also ensures that every effort is made to protect the data held against loss through the use of 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
Maintaining statistics (users, number of visits, types of devices, connection, etc.)
Providing multimedia services

§6 Purposes of Personal Data Processing

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

Provision of electronic services:
Communication of the Administrator with Users on matters related to the Service and data protection
Ensuring the legitimate interest of the Administrator

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

Maintaining statistics
Remarketing
Ensuring the legitimate interest of the Administrator

§7 Cookies of External Services

The Administrator uses javascript scripts and web components of partners in the Service, 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:

Maintaining statistics:
- Google Analytics
Other services:
- Internet Archive
- Google Maps
- Online appointment booking system (mydr.pl): An online registration module (iframe) is displayed within the Service. The provider of this module may place its own cookies on the User’s Device, necessary for the correct functioning of the booking and authorization process.

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

§8 Types of Data Collected

The Service collects data about Users. Some data is collected automatically and anonymously, and some data is personal data provided voluntarily by Users while signing up for individual services offered by the Service. Anonymous data collected automatically:

IP address
Browser type
Screen resolution
Approximate location
Subpages of the service opened
Time spent on the relevant subpage of the service
Type of operating system
Address of the previous subpage
Address of the referring page
Browser language
Internet connection speed
Internet service provider

Data collected during registration:

Name / surname / nickname
Email address
IP address (collected automatically)

Data collected during Newsletter subscription:

Name / surname / nickname
Email address
IP address (collected automatically)

Data collected during comment submission:

Name and surname / nickname
Email address
Website address
IP address (collected automatically)

Part of the data (without identifying information) may be stored in cookies. Part of the data (without identifying information) may be transferred 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 (usually based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the service, i.e.:

Hosting companies providing hosting or related services to the Administrator
Service and IT support companies performing maintenance or responsible for maintaining IT infrastructure

Entrustment of personal data processing – Hosting, VPS or Dedicated Server Services To run the service, the Administrator uses the services of an external hosting, VPS or Dedicated Server provider – SEOHOST Sp. z o.o.. All data collected and processed in the service are stored and processed in the provider’s infrastructure located in Poland. There is a possibility of access to data as a result of maintenance work carried out by the provider’s personnel. Access to this data is regulated by an agreement concluded between the Administrator and the Provider. Entrustment of personal data processing – Website support services To support the service, the Administrator uses the services of an external service provider – Vreego Sp. z o.o.. The personnel of the indicated entity has access to data entered by users during registration and editing of the user account and/or data regarding the Newsletter service. Access to this data is regulated by an agreement concluded between the Administrator and the Provider. Entrustment of personal data processing – Online appointment booking system

The Administrator uses the services of an external provider of a system for managing a medical facility – mydr.pl. A booking module operating in the form of a frame (iframe) is made available within the Service.

Data entered by the User directly in the booking window are processed by the myDR system provider in accordance with its own regulations and privacy policy.
Use of the booking module is voluntary and requires acceptance of the terms of service by the system provider.
The myDR terms of service are available at: https://mydr.pl/static/Regulamin.pdf
The myDR system privacy policy is available at: https://mydr.pl/polityka-prywatnosci

§10 Method of Personal Data Processing

Personal data provided voluntarily by Users:

Personal data will not be transferred outside the European Union unless they have been published as a result of an individual action by the User (e.g., entering a comment or post), which will make the data available to anyone visiting the service.
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) may be used for automated decision-making (profiling). Profiling of anonymous data (without personal data) does not produce legal effects or similarly significantly affect the person whose data is subject to automated decision-making.
Anonymous data (without personal data) will not be resold to third parties.

§11 Legal Grounds for Personal Data Processing

The Service collects and processes Users’ 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)
- Art. 6(1)(a) the data subject has given consent to the processing of his or her 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 party or in order to take steps at the request of the data subject prior to entering into a contract
- Art. 6(1)(d) processing is necessary in order to protect the vital interests of the data subject or of another natural person
- 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 the Protection of Personal Data (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)

§12 Personal Data Processing Period

Personal data provided voluntarily by Users: As a rule, the indicated personal data are stored exclusively for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized within 30 days from the moment of termination 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 this data by the Administrator. In such a situation, the Administrator will store the indicated data from the time the User requests their removal, for no longer than a period of 3 years in the event of a breach or suspected breach of the service regulations by the User. Anonymous data (without personal data) collected automatically: Anonymous statistical data, not constituting personal data, are stored by the Administrator for the purpose of maintaining service statistics for an indefinite period.

§13 User Rights Related to Personal Data Processing

The Service collects and processes User data based on:

Right of access to personal data Users have the right to access their personal data, exercised upon request submitted to the Administrator
Right to rectification of personal data Users have the right to request from the Administrator the immediate rectification of personal data that is incorrect and/or completion of incomplete personal data, exercised upon request submitted to the Administrator
Right to erasure of personal data Users have the right to request from the Administrator the immediate erasure of personal data, exercised upon request submitted to the Administrator. In the case of user accounts, erasure of data consists of anonymization of data enabling the identification of the User. The Administrator reserves the right to suspend the execution of the request for erasure of data in order to protect the legitimate interest of the Administrator (e.g., when the User has breached the Regulations or the data was obtained as a result of ongoing correspondence). In the case of the Newsletter service, the User has the possibility of independently removing their personal data using the link included in each email sent.
Right to restriction of personal data processing Users have the right to restrict the processing of personal data in the cases indicated in Art. 18 GDPR, including contesting the accuracy of personal data, exercised upon request submitted to the Administrator
Right to data portability Users have the right to receive from the Administrator personal data concerning the User in a structured, commonly used and 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 Art. 21 GDPR, exercised upon request submitted to the Administrator
Right to lodge a complaint Users have the right to lodge a complaint with the supervisory authority dealing with personal data protection.

§14 Contacting the Administrator

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

Postal address – Agata Tabiszewska Indywidualna Praktyka Lekarska Miły Gabinet Pediatryczny, Aleja Krakowska 205, Warsaw
Email address – kontakt@mily-gabinet.pl
Telephone – +48 570 322 442
Contact form – available at: /kontakt

§15 Service Requirements

Restricting the saving and access to Cookies on the User’s Device may cause incorrect operation of some functions of the Service.
The Administrator bears no responsibility for incorrectly functioning Service functions if the User restricts in any way the possibility of saving and reading Cookies.

§16 External Links

In the Service – articles, posts, entries, or User comments – there may be links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated under 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 regarding the use of anonymous data or the use of Cookies.
The Administrator reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, of which it will inform Users who have user accounts or are subscribed to the newsletter service, via email within 7 days of the change. Continued use of the services means you have read and accepted the 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.
Changes made to the Privacy Policy will be published on this subpage of the Service.
The introduced changes come into force upon their publication.