Privacy and Cookie Policy

In the interest of safeguarding the personal data of Users and ensuring their security while using the websites Defence24.pl, InfoSecurity24.pl, Energetyka24.com, Space24.pl, CyberDefence24.pl, Defence24.com, Academy24.pl (hereinafter collectively referred to as the “Websites”) and the services provided through them, as well as while using mobile applications intended to operate the Websites, Defence24 spółka z ograniczoną odpowiedzialnością, with its registered office in Warsaw, hereby publishes this Privacy Policy. This document sets forth the principles for the processing and protection of personal data provided by Users in connection with their use of the Websites and the services offered through them.

For the purposes of this Privacy Policy, 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, repealing Directive 95/46/EC (General Data Protection Regulation), shall hereinafter be referred to as “GDPR”.

Personal Data Controller
The controller of your personal data is Defence24 spółka z ograniczoną odpowiedzialnością, with its registered office in Warsaw, address: ul. Foksal 18, 00-372 Warszawa, entered into the Register of Entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number 0000427851, holding Tax Identification Number (NIP): 1132857583, and National Official Business Register Number (REGON): 146224999 (hereinafter also referred to as “D24” or the “Controller”).

Data Protection Officer
The Controller has appointed a Data Protection Officer (“DPO”), Attorney-at-law Joanna Bogdańska. You may contact the DPO in all matters relating to the processing of personal data, including with regard to your rights connected with such processing. You may contact the DPO by traditional mail, addressed to:
Defence24 sp. z o.o. – DPO, ul. Foksal 18, 00-372 Warsaw, or by e-mail: [email protected].

Purpose and Legal Basis of Personal Data Processing
The Controller may process the personal data of Users of the Websites for the following purposes:
• Processing inquiries and providing responses to inquiries submitted via the contact form (legal basis: Article 6(1)(f) GDPR – legitimate interest of the Controller).
• Provision of electronic services in the scope of making content collected on the Websites available (legal basis: Article 6(1)(b) GDPR – processing necessary for the performance of a contract).
• Enabling Users to subscribe to the Websites and to create individual accounts within the Websites (legal basis: Article 6(1)(b) GDPR) – processing necessary for the performance of a contract).
• Ensuring the functionality of the individual User account referred to above (legal basis: Article 6(1)(b) GDPR) – processing necessary for the performance of a contract).
• Marketing purposes, including sending information about events, promotional campaigns, competitions, services, and products, including the provision of newsletter services, provided that the User has given consent (legal basis: Article 6(1)(a) GDPR – The user has given their consent to process their personal data).
• Sharing personal data with Partners for the purpose of enabling them to pursue their marketing objectives (legal basis: Article 6(1)(a) GDPR – The user has given their consent to process their personal data).
• Analytical and statistical purposes, including conducting analyses of Users’ activity within the Websites to ensure improved functionality of the Websites (legal basis: Article 6(1)(a) GDPR – The user has given their consent to process their personal data).
• Handling potential complaints (legal basis: Article 6(1)(b) GDPR – processing necessary for the performance of a contract).
• Establishing, pursuing, and defending claims (legal basis: Article 6(1)(f) GDPR – legitimate interest of the Controller in protecting their rights).

What Data We Process
We process the data that you provide, leave, or to which we may gain access in the course of your use of the Websites or the D24 applications, as well as in other locations on the Internet, including data you have made available in your browsing history of websites and applications. We process data that are necessary to provide you with accounts or profiles on the Websites, as well as the data you provide to us, for example, through forms or windows available on our Websites, in surveys, questionnaires, or research studies. In particular, we process the following categories of personal data:
• E-mail address
• First name
• Surname
• Nickname
• IP address
• User identifier
• User name in social media and services such as Facebook, Google+, LinkedIn, X (formerly Twitter), Instagram
• Age
• Gender
• City
• Date of birth

We also process the data you leave in the course of navigating our Websites (including those stored in so-called cookies), data about the websites, applications, and content you visit or are interested in (including advertising content), your search queries, your clicks, the manner in which you use our Websites, as well as data from the websites of our Partners. We process information about your activity within the services, portals, websites, D24 applications, and other locations on the Internet, as well as information stored on end-user devices you use, including browser information and your precise geographic location data.

Automated Data Processing and Profiling
Displayed advertisements and editorial materials shall be targeted and profiled using your data. Targeting is the process of selecting a target audience most likely to be interested in particular editorial and advertising materials. Profiling is the process of automated processing of your data that consists in using your data to evaluate certain characteristics relating to you, in particular to analyse or predict your interests or other behaviours, such as online credibility, location, movements, consumer preferences, worldview, or professional profile. The advertisements and editorial materials displayed will be targeted and profiled using your following data and according to the following criteria:
Your activity within the Websites and D24 applications and those of our Partners, in particular the editorial materials you use;
• Your activity and interactions with advertising materials;
• Your location and the size of the locality from which you come;
• Information stored on your end devices, in particular the type of end device, browser type, operating system you use, and the language set in the operating system you use;
The processing of your data, which you provide, leave, or to which we may gain access in connection with your use of D24 services, websites, or applications, is necessary for the provision of our electronic services. This necessity arises from the requirement to tailor all types of content to your interests and to ensure the secure and optimal use of our services. The scope of data processed may vary across individual D24 services.

Your Rights in Connection with the Processing of Personal Data

You have the following rights in connection with our processing of your personal data:
• Right of access to your data, including the right to obtain a copy of your data.
• Right to request rectification of data.
• Right to erasure of data (“right to be forgotten”) where one of the following circumstances applies:
- the data are no longer necessary for the purposes for which they were collected or otherwise processed;
- the User has withdrawn their consent to the processing and there is no other legal basis for processing;
- the User has objected to the processing and there are no overriding legitimate grounds for processing;
- the personal data were processed unlawfully;
- the data must be erased to comply with a legal obligation. Provided, however, that the Controller, in justified circumstances, is not obliged to immediately erase the User’s personal data, in particular insofar as processing is necessary to comply with a legal obligation requiring processing, or where processing is necessary for the establishment, exercise, or defence of legal claims.
• Right to file a complaint with the supervisory authority responsible for personal data protection (the President of the Personal Data Protection Office).
• Right to restriction of processing.
• Right to data portability.
• Right to object to the processing of data.

If your data are processed on the basis of consent, you may additionally exercise the right to withdraw consent to the extent that the data are processed on that basis. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal. Consent is voluntary and may be given using the consent management platform functionality. You may also withdraw it at any time by using the advanced settings available on the platform.

Recipients of Personal Data
The Controller shall make every effort to protect Users’ personal data against unauthorised access by third parties. The transfer of personal data to recipients is possible only when it arises from a legally justified purpose and is necessary for the proper performance of the service in connection with which the personal data are processed.
Accordingly, Users’ personal data may be transferred to the following categories of recipients:
• Entities providing IT services in the scope of ongoing maintenance of the Websites and D24 applications;
• Legal advisors or attorneys, for the purpose of pursuing potential claims.
In addition, recipients of the data may include only institutions authorised to receive them under mandatory provisions of law.

Data Retention Period

The Controller stores personal data for a period necessary to achieve the purposes for which such data are processed.
If the basis for processing personal data is the User’s consent, the personal data shall be stored until the withdrawal of consent, and after its withdrawal, if necessary, for a period corresponding to the limitation period for claims that may be available to the User or the Controller.
Where the basis for processing personal data is the performance of a contract, the personal data will be stored for the duration of the contract, and thereafter for the period of the limitation of claims.

Cookies and Similar Technologies

The Controller places information in the form of cookies (so-called “cookies”) and in other forms on end-user devices (e.g., computer, laptop, smartphone) and gains access to information collected using cookies and other technologies identifying end-user devices.
Cookies are IT data, in particular text files, that are stored on the end-user’s device. Cookies contain the name of the domain of the website from which they originate, the time they are stored on the end-user’s device, and a unique name.
Cookies store information that is often necessary for the proper operation of a website. A cookie may store a unique number that identifies the User’s device but does not allow for the identification of the User’s identity. The D24 Websites may place a cookie in your browser if the browser allows it. Importantly, the browser permits the website to access only the cookies placed by that website, not cookies placed by other websites.
The User may withdraw consent to the use of cookies by clicking the settings change link placed at the end of this Privacy Policy or by navigating to the cookie settings section labelled “COOKIES” at the bottom of each D24 website.

Purpose of Using Cookies and Similar Technologies
We use cookies and similar technologies for the following purposes:
• Ensuring the functionality of the Websites and the proper provision of services.
• Adapting the content of the Websites and applications to the User’s preferences and optimising the use of the websites. For example, cookies make it possible, in particular, to recognize the User’s device and to properly display the website in a manner tailored to their individual needs.
• Creating statistics to help understand how Users use the Websites and applications, enabling improvement of their structure and content.
• Measuring and analysing the viewership of our Websites and editorial content, including advertisements, for the purpose of analyzing, assessing, improving, enhancing, and developing our Services and applications. To this end, we also create user segments — that is, groups of recipients of specific services and content, or categories thereof.
• Maintaining the User’s session after logging in which allows the User to avoid having to re-enter their login and password on each subpage of the given Service or application.
• Presentation of advertisements, including personalised advertising based on the User’s interests or place of residence, while ensuring that the same advertisement is not displayed to the User repeatedly.
• Remarketing, which consists in displaying advertisements from Partners whose websites you have visited or whose products or services you have shown interest in — for example, by previously clicking on a Partner’s advertisement.
• Conducting surveys, in particular, to avoid displaying the same survey multiple times to the same recipient and to present surveys in a manner that takes into account the recipients’ interests; as well as to link multiple devices belonging to the same end User for the purpose of achieving one or more of the objectives described above.

Types of Cookies We Use

With regard to the lifespan of cookies and similar technologies, we use two main types of these files:
• Session cookies – temporary files stored until the User logs out, leaves the website or application, or closes the software (web browser);
Persistent — stored on the user's end device for the duration specified in the cookie parameters or until deleted by the User.
Based on the purpose served by cookies and similar technologies, we employ the following types:
• Essential for the operation of the Services and applications — enabling the use of our services, e.g., authentication cookies used for services that require user authentication;
• Security cookies — used to ensure security, for example, to detect authentication abuses;
• Performance cookies — allowing the collection of information on how the website and applications are used;
• Functional cookies — enabling the “remembering” of user-selected settings and personalizing the user interface, e.g., regarding the selected language or region of the user, font size, website and application appearance, etc.;
• Advertising cookies — allowing the delivery of advertising content more closely aligned with users’ interests;
• Statistical cookies — used for counting statistics related to the website and applications.

Changes to the Privacy Policy
The Privacy Policy is subject to ongoing review and updated as necessary. Changes may result from the development of the Websites and applications, changes to legal provisions, or technological advancements. Changes will be marked with the date of last modification. The current version has been in effect since 1 January 2024.

The user has the option to change the cookie settings by clicking the 'Cookies' icon located in the bottom left corner of the page.