Privacy policy

PRIVACY POLICY

Dear User,

when you visit our website (www.runflair.com), we process certain information about you such as

information on a device you use, country you are from, web browser you use and your IP address,

including personal data you wish to share with us by subscribing for a newsletter or otherwise interacting

with the website.

Additionally, we process your personal data when you enter and interact with our fanpage on Facebook®

(https://www.facebook.com/runflair) and Instagram® (https://www.instagram.com/runflair/). In such

case we may process your personal data for example your name, surname, profile picture and

information you send us via Facebook Messenger® or your comments.

Any personal data we collect will be used in accordance with applicable laws, including 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 (“GDPR”).

This privacy policy governs how we process you personal data we collect through our website and

fanpage on Facebook, mentioned above, which in this policy are referred to as “Website” or “Websites”.

1. WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

Any personal data collected via the Websites are controlled by RUNFLAIR SPÓŁKA Z OGRANICZONĄ

ODPOWIEDZIALNOŚCIĄ with its registered office in Wrocław, ul. Życzliwa 33, 53-030 Wrocław,

entered into the business register of KRS (national court register) under no 0000924896, having NIP

(tax identification number) 8992907812 (hereafter referred to as “Runflair” or “we”).

You may contact us at any time in relation to personal data of yours processed by us.

Our contact details: gdpr@runflair.com

2. DATA THIS POLICY APPLIES TO.

This privacy policy applies to information, including personal data, we collect:

• through the Websites.
• through mobile and desktop applications which provide dedicated non-browser-based

interaction between you and this Websites.

• when you interact with our advertising and applications on third-party websites and services, if

those applications or advertising include links to this policy.

It does not apply to information collected by:

• Runflair offline; or
• any third party (including Runflair’s affiliates and subsidiaries), including through any application

or content (including advertising) that may link to or be accessible from or on the Website.

The term ‘personal data’ as used herein comprises any information relating to an identified or identifiable

natural person; 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.

3. CHILDREN UNDER THE AGE OF 16

The Website is not intended for children under 16 years of age. No one under age 16 may provide any

personal data to or on the Website. We do not knowingly collect personal data from children under 16.

If you are under 16, please do not use or provide any information on this Website or on or through any

of its features, use any of the interactive or public comment features of this Website or provide any

personal data to Runflair. If we learn that we collected or received personal data from a child under 16

without verification of parental consent, Runflair will delete that information. If you believe we might have

any personal data about a child under 16, please contact us.

4. INFORMATION RUNFLAIR COLLECTS THROUGH THE WEBSITE

Runflair collects information, including personal data:

• directly from you when you provide it to us or automatically as you enter and navigate through

the Website always with your consent; or

• automatically as you enter and navigate through the Website, collected through essential and

functional cookies, without your express consent. Such information may include usage details,

information on a device you use, country you are from, web browser you use and your IP

address. We do not collect any other personal data in such way, for example name, surname

or e-mail address.

If we collect personal data with your expressed consent such personal data will be collected and

processed only within the scope of such consent. You are entitled to withdraw the consent at any time,

however the withdrawal of the consent will not affect the lawfulness of processing based on consent

before its withdrawal.

Personal data collected for purposes other than compliance with legal obligation may be subject of

profiling, which is an automated processing of personal data to analyse or predict aspects concerning

your personal preferences or behaviour (for example, to personalize the Website or marketing content

sent to you). This pertains particularly to Google and Meta Platforms advertising services.

We will not use automated individual decision-making producing any legal effects or significantly

affecting you.

The provision of all personal data is voluntary, however necessary for you to be presented with and

use the Website and its functionalities.

The information Runflair collects will also be used to help us review, develop and improve the products

and services we offer.

If it is applicable, we collect information you have published or displayed (hereinafter, “posted”) on public

areas of the Website by using the functionalities of the Website (collectively, “User Contributions”). Your

User Contributions are posted on and transmitted to others at your own risk. Although please be aware

that no security measures are perfect or impenetrable. Additionally, Runflair cannot control the actions

of other users of the Website with whom you may choose to share your User Contributions. Therefore,

we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized

persons.

Any publication of a photograph on the Website containing your image, constitutes a consent to use

such image by Runflair on the Website.

We may request additional personal data to provide certain services available on the Website. If such

personal data are not provided by you, Runflair will not be able to provide you requested services.

5. COOKIES

Cookies are text files containing small amounts of information which are downloaded to your device

when you visit a website. You can find more information about cookies

at: www.allaboutcookies.org and www.youronlinechoices.eu.

Cookies do lots of different jobs, like letting you navigate between pages efficiently, remembering your

preferences (for example language choice), and generally improving the user experience. They can also

help to ensure that adverts you see online are more relevant to you and your interests.

Cookies are referred to as session or persistent, depending on how long they are stored on your

computer or device:

• Session cookies only last for the length of your online session. They disappear from your

computer or device when you close your browser.

• Persistent cookies stay on your computer or device after the browser has been closed and last

for a set period of time specified in the cookie. These cookies are activated each time you visit

the site that generated the cookie.

Runflair does not use cookies with the aim of collecting commercial data for sale to third parties.

Currently we use following types of cookies on the Website (www.runflair.com):

Necessary (essential) cookies

This type of cookies are necessary for you to enter and display the Website and to use services available

on the Website, for example authentication cookies used for authentication services on the Website

during a session or user-centric security cookies which are used for increasing the security of the service

explicitly requested by the user.

These cookies are automatically saved on your device without your explicit consent as they are

exempted from such consent. You may disable such cookies only in cookies management section of

your web browser.

Performance cookies

Performance cookies collect information about how visitors use a website, for instance which pages

visitors go to most often, and if they get error messages from web pages. These cookies do not collect

information that identifies a visitor. All information these cookies collect is aggregated and therefore

anonymous. It is only used to improve how a website works.

The Website currently uses one performance cookie – Google Analytics.

Google Analytics is a web analytics service provided by Google, Inc. Google Analytics sets a cookie in

order to evaluate your use of the Website and compiles reports on user activity. Google stores the

information collected by the cookie on servers in the United States and other countries. 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. Google will not associate your IP address with any other

data held by Google. By using the Website, you consent to the processing of data about you by Google

in the manner and for the purposes set out above.

It is possible to opt-out of having your anonymized browsing activity within websites recorded by

analytics through cookie banner on the Website, or through options of your web browser, or on the

website Google Analytics: http://tools.google.com/dlpage/gaoptout

Functional cookies

These cookies allow the website to remember choices you make (such as your username, language or

the region you are in) and provide enhanced, more personal features. For instance, a website may be

able to provide you with local weather reports by storing in a cookie the region in which you are currently

located. These cookies can also be used to remember changes you have made to text size, fonts and

other parts of web pages that you can customize. They may also be used to provide services you have

asked for such as watching a video. The information these cookies collect may be anonymized and they

cannot track your browsing activity on other websites.

Use of these cookies requires your express consent which you may give us through cookie banner on

the Website or options of your web browser.

Advertising cookies

Cookies of third parties that are used for behavioral advertising and other purposes such as

advertisement affiliation, research and market analysis.

Currently on the Website we use:

Facebook Pixel – promotional and advertising actions based on re-engagement. These cookies serve

for Meta Platforms Inc. to reach people who previously visited our Website and match the right people

with the right message. These features’ goal is to attract past visitors back to our Website. You may find

privacy policy regarding advertisement on Facebook® or other social media platforms of Meta

Platforms® here: https://www.facebook.com/adpreferences/ad_settings

Google Ads – promotional and advertising actions based on re-engagement. These cookies serve for

Google LLC to reach people who previously visited our Website and match the right people with the

right message. These features’ goal is to attract past visitors back to our Website. You may find privacy

policy of Google LLC here: https://policies.google.com/technologies/partner-sites?hl=en-US

Use of these cookies requires your express consent which you may give us through cookie banner on

the Website or options of your web browser.

Managing cookies in your browser

Modern browsers allow you to perform a number of tasks in relation to cookies including the ability to

view the cookies currently stored on your computer or device and delete them on an individual basis,

block third party cookies, block cookies from particular sites, prevent all cookies from being set and

delete all cookies when you close your web browser.

You should note that any individual preferences will be lost if you delete cookies, including a preference

to opt out of cookies (since this requires an opt-out cookie to be set). If you choose to block cookies

completely, many websites will not work properly and some functionality may be lost.

Runflair does not control these third parties’ tracking technologies or how they may be used. If you have

any questions about an advertisement or other targeted content, you should contact the responsible

provider directly.

6. PROCESSING OF INFORMATION

Runflair will use your information to provide and personalize the Website. We may also use your contact

details to communicate with you. Your information will enable us to notify you about important

functionality changes to the Website and will be used for statistical analysis purposes to improve the

quality and the services offered to you.

We may use the information, except for personal data (processing of which is described below), it

collects for a range of business purposes, including but not limited to:

• present the Website and its contents to you and enable you to use functions of the Website and

its contents;

• evaluate and respond to your requests, inquiries, and applications;
• communicate with you through various channels;
• publish public product reviews as submitted by you;
• compliance with obligations as required by applicable laws, including protection against and

prevention from fraud and unauthorized transactions, investigate and manage claims, risk

exposure, and quality, generally improve and provide security;

• control the compliance of your actions with and enforcement of applicable legal requirements

and Runflair’s policies and terms; determine, protect and enforce any of Runflair’s rights,

including an assignment to any third party;

• carry out summaries, analysis, statistics in order to operate, evaluate, and improve business,

products, and services (including developing new products and services; managing our

communications; determining and managing the effectiveness of advertising and marketing;

analyzing products, services, websites and applications; administering the Website and

applications);

• direct marketing;
• conclude and perform contracts to provide services and deliver products;
• fulfill any other purpose for which you provide it;
• in any other way Runflair may describe when you provide the information; and
• for any other purpose with your consent.

Following personal data collected through the Website (www.runflair.com) are processed by Runflair

for following purposes and on following legal grounds:

Purpose Personal data Legal basis Duration

• present the Website and its contents to you and

enable you to use functions of the Website and

its contents, generally improve and provide

security.

• Data received automatically

from the computer, mobile

phone or other device you use

to access the Website: IP

address, location and time.

• Article 6 pt. 1.f

GDPR –

legitimate

interest

• For the time of using the

Website and afterwards

until you end the session

of web browser.

• carry out summaries, analysis, statistics in order

to operate, evaluate, and improve the Website,

business, products, and services (including

developing new products and services;

managing our communications; determining

and managing the effectiveness of advertising

and marketing; analyzing products, services,

websites and applications; administering the

Website and applications).

• Data received from the

computer, mobile phone or

other device you use to

access the Website: IP

address, location and time.

• Article 6 pt. 1.f

GDPR –

legitimate

interest

• For the time needed to

carry out such activities,

no longer than 14 months.

• evaluate and respond to your requests,

inquiries, and applications.

• Contact and identification

information provided by you:

name, surname, email

address.

• Article 6 pt.

1.a GDPR –

consent

• For the time needed to

complete the exchange of

communication and 3

years afterwards or until

withdrawal of the consent.

• communicate with you through various

channels, including for advertisement purposes.

• Contact and identification

information provided by you:

name, surname, email

address.

• Article 6 pt.

1.a GDPR –

consent

• For the time needed to

complete the exchange of

communication and 3

years afterwards or until

withdrawal of the consent.

• carry out obligations as required by applicable

laws, including protection against and

prevention from fraud and unauthorized

transactions, investigate and manage claims,

risk exposure, and quality, generally improve

and provide security.

• Data received automatically

from the computer, mobile

phone or other device you use

to access the Website: IP

address, location and time.

• Contact and identification

information provided by you:

name, surname, email

address.

• Article 6 pt.

1.c GDPR –

legal

obligation

• For the time needed to

carry out such obligation.

• control the compliance of your actions with and

enforcement of applicable legal requirements

and Runflair’s policies and terms; determine,

protect and enforce any of Runflair’s rights,

including an assignment to any third party;

• Data received automatically

from the computer, mobile

phone or other device you use

to access the Website: IP

address, location and time.

• Contact and identification

information provided by you:

name, surname, email

address.

• Article 6 pt. 1.f

GDPR –

legitimate

interest

• Until the expiry of

limitation period.

• Re-engagement advertisement § Data received automatically

from the computer, mobile

phone or other device you use

to access the Website: IP

address, location and time.

• Article 6 pt.

1.a GDPR –

consent

• No longer than 24 months

in case of Google Ads and

180 days in case of

Facebook Pixel or until

withdrawal of the consent.

• Other purpose § As agreed § Article 6 pt.1.a

GDPRconsent

Following personal data collected through the Website (https://www.facebook.com/runflair) and

(https://www.instagram.com/runflair/) are processed by Runflair for following purposes and on following

legal grounds:

Purpose Personal data Legal basis Duration

• carry out summaries, analysis, statistics in order

to operate, evaluate, and improve social media

fanpage business, products, and services

(including developing new products and

services; managing our communications;

determining and managing the effectiveness of

advertising and marketing; analyzing products,

services, websites and applications;

administering social media fanpage and

applications);

• Data received when you

interact with the Website:

name, surname, posted

content, photographs.

• Article 6 pt. 1.f

GDPR –

legitimate

interest

• For the time needed to

carry out such activities

no longer than 24 months.

• Publish on the Website public product reviews

as submitted by you or comments.

• Data received when you

interact with the Website:

name, surname, posted

content, photographs.

• Article 6 pt. 1.f

GDPR –

legitimate

interest

• For the time you have an

account on social media

portal or until you delete

such comment.

• carry out obligations as required by applicable

laws, including protection against and

prevention from fraud and unauthorized

transactions, investigate and manage claims,

risk exposure, and quality, generally improve

and provide security.

• Data received when you

interact with the Website:

name, surname, posted

content, photographs.

• Article 6 pt.

1.c GDPR –

legal

obligation

• For the time needed to

carry out such obligation.

• control the compliance of your actions with and

enforcement of applicable legal requirements

and Runflair’s policies and terms; determine,

protect and enforce any of Runflair’s rights,

including an assignment to any third party;

• Data received when you

interact with the Website:

name, surname, posted

content, photographs.

• Article 6 pt. 1.f

GDPR –

legitimate

interest

• Until the expiry of

limitation period.

• communicate with you through various

channels, including for advertisement purposes,

however we do not initiate contact.

• Contact and identification

information provided by you:

name, surname, email

address, posted content,

photographs

• Article 6 pt.

1.a GDPR –

consent

• For the time needed to

complete the exchange of

communication and 3

years afterwards or until

withdrawal of the consent.

7. SHARING OF THE INFORMATION WE RECEIVE

Runflair uses third parties service providers to carry out certain activities on its behalf. Examples include

operating IT systems, including e-mail, hosting services, providing IT resources, analyzing data,

providing marketing assistance and providing customer service, legal services, accounting services etc.

These third parties are processors of your personal data needed to perform their functions, but may not

use it for other purposes. We will ensure that any processing of personal data by processors complies

with provisions of GDPR, especially that any such processor is aware of and abides by obligations set

for the therein. We will also ensure that any processor treats your personal data no less protective as

required by applicable data protection laws and that they adopt adequate technical and organizational

security measures.

We may share your personal data with other controllers, when we believe it necessary to comply with

the law, to protect the rights or safety of the Website, other users, or third parties (e.g., for fraud

protection purposes, settlements purposes). Without limitation, this may include cases in which we share

your personal data with government authorities, local authorities or court authorities, persons running

offices of business information and assignees. Runflair will carefully determine the permissibility of

providing personal data in each such context, paying particular attention to the type of request, types of

data affected and any impact that a disclosure of personal data would have on the user affected. Should

we decide to disclose personal data in such context we will also consider ways of reducing the scope of

the disclosure, for instance by redacting the information provided.

We may disclose personal data as described in this Privacy Policy to a buyer or other successor in the

event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some

or all of Runflair’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar

proceeding, in which personal data held by us about the Website users is among the assets transferred

We may share your personal data with carefully selected third parties so they may contact you with

offers and information about their goods and services or for other purposes, unless you expressed your

consent.

Recipients of your personal data may be located in any country. This may include countries where

applicable data protection laws provide a lesser degree of protection than EU laws, especially countries

outside the territory of European Union (“third countries”). In such case, we may transfer your personal

data to a third country only where:

• the Commission has decided that the third country, a territory or one or more specified sectors

within that third country, ensures an adequate level of protection. Such a transfer shall not

require any specific authorization, or

• adequate level of protection is applied for your personal data, for instance by ensuring that the

recipient abides by so-called EC Model Clauses, which are sets of contractual clauses adopted

by the European Commission for the purpose of adducing adequate safeguards to personal

data in connection with cross-border transfers, or

• the transfer meets other requirements set forth in GDPR.

Currently we transfer your personal data collected through the Website (www.runflair.com) to following

entities who provide us with certain services:

• Google LLC with its registered office in California, USA and Google Ireland Ltd – entities that

have provided and are responsible for a tool and cookies for website traffic analysis (Google

Analytics) and for a Google Ads cookies. In section 6 of this privacy policy you may find details

regarding cookies on the Website. Export of personal data to the USA is based on Standard

Contractual Clauses accepted by European Commission.

• Meta Platforms, Inc with its registered office in California, USA and Meta Platforms Ireland Ltd.

– entities that have provided and are responsible for Facebook Pixel cookie and access to our

Facebook® and Instagram® fanpage. As a result you may like our fanpage, read our posts,

watch materials posted by us and post you own content like comments or give likes and more.

Export of personal data to the USA is based on Standard Contractual Clauses accepted by

European Commission.

• Wills Integrated sp. z o.o. z siedzibą we Wrocławiu – entity that provides us with hosting

services. Personal data transfer is governed by Data Processing Agreement.

• FreshMail spółka z ograniczoną odpowiedzialnością z siedzibą w Krakowie – entity that

provides us with mass correspondence services in relations to subscribers of our newsletter.

Personal data transfer is governed by Data Processing Agreement.

8. LINKS TO THIRD PARTY WEBSITES

Runflair may from time to time establish relationships with other third party companies and the Website

may contain links to and from such third party websites. We will try to provide you with links to high

quality, reputable sites which it believes will be of interest and relevant to you, but please note that such

third party sites are not under its control and Runflair does not contribute to the content of such sites.

If you follow a link to any third party website, please note that they will have their own policies. When

you click through to these sites you leave the area controlled by us. We cannot accept responsibility for

any issues arising in connection with either the third party’s use of your data, the site content or the

services offered to you by these sites. Runflair therefore encourages you to check any third party

website’s policies before you submit any personal data to these sites.

9. SECURITY

Runflair maintains administrative, technical, and physical safeguards designed and intended to protect

personal data against accidental, unlawful, or unauthorized destruction, loss, alteration, access,

disclosure or use. Despite these safeguards, due to inherent uncertainty in the use of the Internet and

information systems and the potential for unlawful attacks by third parties, Runflair cannot guarantee

that the use of systems, websites (including the Website) or applications will be completely safe or

secure.

The safety and security of your personal data also depends on you. Where Runflair has given you (or

where you have chosen) a password for access to certain parts of the Website, you are responsible for

keeping this password confidential. We kindly ask you not to share your password with anyone. Runflair

also urges you to be careful about giving out information in public areas of the Website like message

boards. The information and personal data you share in public areas may be viewed by any user of the

Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although Runflair

does its very best to protect your personal data, we cannot guarantee the security of your personal data

transmitted to the Website. Any transmission of personal data is at your own risk. We are not responsible

for circumvention of any privacy settings or security measures contained on the Website.

10. YOUR RIGHTS

You have following rights under GDPR in relation to your personal data:

1) accessing your personal data (including receiving copies thereof) – under article 15 GDPR;

2) correcting your personal data – under article 16 GDPR;

3) deleting your personal data – under article 17 GDPR;

4) to demand restriction of processing – under article 18 GDPR;

5) to demand transmission of personal data – under article 20 GDPR.

You may enforce the above rights by contacting our representative for data protection or sending a

respective email to our address: gdpr@runflair.com

We may require additional information enabling us to verify your identity and your right to enforce the

above rights.

You can review and change your personal data by logging into the Website and visiting your account

profile page.

Right to object

Apart from rights referred to in preceding paragraphs, you have the right to object, at any time, to

processing of your personal data by us (including profiling) for direct marketing purpose. After filing the

objection, we will restrain from processing your data for this purpose.

You have also right to object, on grounds relating to your particular situation, at any time to processing

of your personal data which is based on legitimate interest or public interest (including profiling). The

controller shall no longer process the personal data unless the controller demonstrates compelling

legitimate grounds for the processing which override the interests, rights and freedoms of the data

subject or for the establishment, exercise or defence of legal claims.

Complaint

You have the right to lodge a complaint to Prezes Urzadu Ochrony Danych Osobowych. You may find

details on the website: https://uodo.gov.pl/

– if you are of the opinion that we process your personal data illegaly.

11. CHANGES TO OUR PRIVACY POLICY

We may revise, update and change this privacy policy at any time and without notice to you.

____________________

Wroclaw, 04.12. 2023 r.