Tronik Sp. z o.o. Sp. k.

Privacy Policy

Tronik Spółka z ograniczoną odpowiedzialnością Sp. k. (dalej Tronik) places significant importance on protecting your privacy. We want to assure you that we handle your data with careful consideration, adhering to the obligations stipulated by the relevant regulations concerning personal data protection. Through this Policy, you will learn how we utilize information about you, which qualifies as personal data according to the provisions of the General Data Protection Regulation. You will also find information about the rights afforded to you regarding the processing of your personal data by Tronik.

 

The policy applies to all Tronik subscribers and its subsidiary companies, as well as to all visitors to our websites and users of our software and services, who may or may not be subscribers of Tronik Sp. z o.o. Sp. k.

 

The provisions of the terms of service for individual services may describe in a separate manner the rules for processing your data. In such cases, these detailed terms may have a superior or complementary character in relation to this Policy.

 

Our products and services may contain links to websites of other companies and services offered by them. These companies may have their own privacy policies, which should be reviewed and understood.

 

We are not responsible for the privacy practices or for the products and services of the aforementioned third-party websites.

 

All capitalized terms have meanings assigned to them in the Dictionary found in Section IV of this Policy. Please familiarize yourself with the contents of this Policy, our general terms of agreement, as well as the principles that may apply when using our products and services. This Policy may undergo changes, so we encourage you to regularly visit our website.

 

 

I. Your Personal Data and How We Use It.

In this section of the Policy, you will find information about the purposes and legal bases for processing, the scope of usage, and the period of storage of your data by Tronik.

 

1. Delivering products and providing services.

The provision of services and delivery of products by Tronik encompass the following activities:

  • Administrative tasks related to the conclusion and execution of a subscription agreement, including subscriber support, also via telephone, email, and traditional correspondence,
  • Handling complaints, invoicing, fee collection, possible debt collection, including assessing your creditworthiness,
  • Managing, servicing, and developing software created and owned by Tronik,
  • Installation and servicing work on equipment that is part of the services,
  • Providing technical support through telephone, email, remote assistance, and on-site visits.
  • Processing data that is part of the agreement, such as the location of vehicles and devices in Tronik software, as well as driver identification data (name, surname), and their working hours.

 

What data do we process in connection with providing our services or delivering products?

– Contact information;
– Data about your subscriber account;
– Phone data;
– Data entered and processed in our software;
– Data regarding the location of monitored vehicles equipped with Tronik devices or devices from other manufacturers operating within Tronik software;
– Data about the location of mobile devices if they are equipped with applications from Tronik.

 

What information do we have access to?

To ensure proper service provision, we have access to your contact information and details of your subscriber account, which are necessary for the conclusion and execution of a subscription agreement. Contact information, including correspondence and content viewed by you, is subject to telecommunications secrecy. Without your consent, we do not access the content of SMS messages, email messages, or messages originating from our software. We may process transmission data, which signifies data processed for the purpose of transmitting communications, including call setup, delivering content over telecommunication networks, or billing for services. We also process data entered and processed in our software, such as information on the operation and location of vehicles and mobile devices covered by the subscription, as well as driver identification data (name, surname), for the purpose of fulfilling the subscription agreement.

 

How long do we keep your data?

We retain your data no longer than necessary to fulfill the purposes for which they were collected unless applicable laws require us to retain them for a longer period.

The maximum retention period for your data for accounting purposes is 5 years, calculated from the end of the calendar year in which the deadline for tax payment related to the provided service expires. This is associated with the expiration period for tax liabilities in the territory of the Republic of Poland. After the retention periods expire, your personal data will be deleted or anonymized.

 

Do we share your data?

Based on the applicable data protection regulations, we may disclose your data to the following entities:

– To the extent permitted by applicable law, we may share your data with trusted entities for purposes related to the provision of our services, e.g., employees and collaborators of Tronik company, IT service providers, marketing agencies, postal or courier companies, payment institutions, telecommunications companies, with which Tronik has entered into cooperation agreements.
– To the extent permitted by applicable law, we may also share your data with business information offices and institutions involved in debt collection, including enterprises engaged in debt recovery and trading of receivables, as well as their representatives.

In such cases, we require third parties to maintain confidentiality and security of the information and to use it solely for the purpose of providing us with a given service or product.

 

Legal basis for the processing of your personal data:

Conclusion and execution of the subscription agreement: e.g., Your contact details, which you provide voluntarily, but are necessary for the conclusion and execution of the subscription agreement. Data about your subscription account and telephone data processed for the purpose of providing services and charging fees; Data entered and processed in our software for the proper execution of the subscription agreement.

Given consent: Your contact details processed for the purpose of sending marketing communications to an email address or telephone contacts for marketing purposes, as well as for the proper execution of the subscription agreement; Data entered and processed in our software for efficient diagnosis of potential causes of faults and failures.

Fulfilling a legal obligation incumbent upon Tronik: e.g., Contact details and data about your subscription account processed for the purpose of providing subscribers with a list of services provided, considering complaints.

Legitimate interests of Tronik: e.g., Information about your subscription account and contact details processed for the purposes of direct marketing of Tronik Sp. z o.o. Sp. k., charging fees, and telephone data processed for the purpose of detecting and preventing abuse in the telecommunications network.

 

2. To create your customer profile.

We create your customer profile in order to improve the quality of service, to best tailor customer service and marketing offers to your individual needs. This allows us to efficiently diagnose potential causes of malfunctions and failures, as well as offer you products and services tailored to your needs, which is profiling.

 

How do we create your customer profile?

We analyze the information about your subscription account in terms of the services you use. This gives us the opportunity to learn how we can improve your satisfaction with our services. When you visit our websites, we use cookies and similar data collection technologies to gather information about user activities. You can find more information in our cookie policy.

 

We create your customer profile based on the following categories of data:

– Contact details;
– Data about your subscription account;
– Telephone data;
– Data entered and processed in our software;

If you do not wish us to create your customer profile for the purposes of direct marketing, you can express your objection to us. Then, we will not be able to inform you about new offers better tailored to the way you use our services. At any time, you can also decide whether you want to receive marketing communications from us by expressing or withdrawing your consent. Detailed information on how to object and manage consents can be found in Section II You have control over your data.

At the same time, we inform you that in connection with the conclusion and execution of the subscription agreement, Tronik does not use mechanisms, including profiling, based on automated decision-making (e.g., based on scoring models, statistical analyses, risk assessment methods).

 

How long do we store your data?

If we do not receive different instructions from you, we will delete your customer profile upon the expiration of the subscription agreement.

 

Do we share your data?

We may share your customer profile exclusively with employees and collaborators of Tronik. We do not sell your data to any third parties.

 

Legal basis for processing the aforementioned personal data:

Legally justified interests of Tronik Sp. z o.o. Sp. k.

 

3. For analytical purposes and solving technical problems.

We verify data from our systems for the purpose of conducting analyses that enable us to solve technical issues, improve and optimize our services. Such information allows us, for example, to better tailor our services to the needs of subscribers, make decisions regarding the development of our offerings, and continuously improve our operational processes.

 

Which data do we use for preparing reports and analyses?

The data we use for preparing reports and analyses includes information from your subscriber account, phone data, data entered and processed within our software, as well as location data from monitored vehicles equipped with Tronik devices or devices from other manufacturers operating within Tronik software. We also utilize location data from phones/tablets if they have Tronik company applications installed.

 

How long do we retain your data?

For statistical purposes, we process your data for the duration of the subscriber agreement.

 

What data do we have access to?

We process your data that we have obtained as part of providing services.

 

Do we share your data?

We only share your data with Tronik employees and collaborators.

We do not sell your data to any third parties.

 

The legal basis for processing the above-mentioned personal data is:

The legitimate interests of Tronik Sp. z o.o. Sp. k.

 

4. In order to fulfill our legal obligations.

We may be legally obligated to provide your personal data, including data covered by telecommunications secrecy, upon request from authorized services and authorities, as well as to courts and the prosecutor’s office. This data may be disclosed without your knowledge or consent, based on applicable legal regulations. In such cases, Tronik always verifies the legality of the request made by services and authorities regarding the disclosure of your data.

 

What data are we required to retain?

In accordance with the Telecommunications Act regulations, we are required to retain and store your phone data, necessary for:
– determining the termination of the network or telecommunications end device,
– the initiating user of the connection, and the end user to whom the connection is directed.

The specification includes:
– date and time of the connection and its duration,
– type of connection,
– location of the telecommunications end device.

 

II. YOU HAVE CONTROL OVER YOUR DATA

In accordance with the General Data Protection Regulation and the Telecommunications Act, you have the following rights:

a) You have the right to give and withdraw consent for:
– processing your contact data, such as email address and phone number, for receiving electronic marketing communications via email, SMS, phone calls, or through automated calling systems;
– processing your contact data, such as email address, for receiving electronic invoices from Tronik;
– processing your contact data, such as email address or phone number, for receiving electronic notifications or confirmations related to changes in the terms of the Subscriber Agreement.

You can give or withdraw consent via email or postal correspondence.

b) You have the right to access your data, including obtaining copies of data undergoing processing, including in electronic form.

c) You have the right to rectify (correct) your personal data if the data we hold about you is inaccurate or incomplete.

d) You have the right to have your data erased if your data is no longer necessary for the purposes for which it was collected, and Tronik has no legal basis for their processing, such as your consent or legal obligations.

e) You have the right to data portability, which means that you can request your data that you have provided to us in a machine-readable format if you wish to transfer it to another service provider.

f) You have the right to restrict the processing of your data in the following cases (when submitting a request, please indicate one of the following situations):
– if you have concerns about the accuracy of your data;
– if you believe that we should not process your data, but at the same time, you do not want us to delete it;
– if such personal data is no longer needed by us, but you require it for the purpose of asserting claims;
– if you have objected to the processing of your data, and it is our duty to verify whether we should continue processing it.
You can exercise your rights by submitting the appropriate request via traditional mail or email. Tronik Sp. z o.o. Sp. k. will provide you with information about the actions taken in response to your request within one month of receiving the request. If necessary, the deadline for fulfilling your request may be extended by an additional two months due to the complexity of the request or the number of requests received.

In order to fulfill your request, we are authorized to verify your identity to ensure that your data does not fall into the wrong hands.

If your request is evidently unfounded or excessive, especially due to its repetitive nature, Tronik Sp. z o.o. Sp. k. may request a reasonable fee for processing the request or refuse to take action in response to the request.

 

III. USEFUL CONTACT INFORMATION

The administrator of your personal data is Tronik Spółka z ograniczoną odpowiedzialnością Sp. k., with its registered office in Pułtusk at ul. R. Traugutta 2 B, registered in the entrepreneurs’ register kept by the District Court for the capital city of Warsaw, XIV Economic Division of the National Court Register under the KRS number 0000683043, and Tax Identification Number (NIP): 5681567494.

You can direct any questions, comments, or requests regarding your personal data to our Data Protection Officer at the following email address: iod@tronik.pl.

To exercise your rights, give or withdraw consent, and raise objections, please use the following contact options:
Email address: iod@tronik.pl
Traditional mail: Tronik Sp. z o.o. Sp. k. Office, 06-100 Pułtusk, ul. R. Traugutta 2B
Phone number: 23 69 26 888 (call charges in accordance with the operator’s tariff).

 

IV. GLOSSARY

 

Abonent Tronik Sp. z o.o. Sp. k.:

A natural person or civil partnership who is a party to a service agreement with Tronik or its subsidiaries.

 

Contact data

Information provided by you when entering into a subscriber agreement, such as your name, company name, PESEL number or ID card series and number, tax identification number (NIP), National Court Register (KRS) number, REGON number, mailing address, service location address, phone number, and email address.

 

Information about your subscriber account:

Data collected and processed during the term of the subscriber agreement, including the subscriber’s identification number, payment method, bank account number, information about provided services, customer segment, products and services purchased through any of our sales channels, as well as transaction details and information about your creditworthiness (obtained from a credit information bureau). This category also includes Customer Support data: requests for technical support and data required to resolve the issues related to them, call time and duration for phone inquiries, and the applied solutions.

 

Phone data:

Data processed for the provision of mobile telephony services, including data about calling and called numbers, names if provided, call type, call duration, date and time of the call or unsuccessful call, location data of the initiating device and the receiving device, technical data about devices (MSISDN numbers, IMSI numbers, IMEI numbers or ESN numbers), dates and times of the initial logins of mobile end devices to the public mobile telephone network, the number of calls made, and data about the amount of sent and received data.

 

Data entered and processed in our software:

Data processed for the purpose of providing vehicle and machinery monitoring services, including data about:
– Objects covered by the service (e.g., type, license plate number, model, brand, year of production, and color),
– Software users (names, usernames, their work phone numbers and emails if provided),
– Driver names obtained from the digital tachograph or entered by the user in connection with an electronic identifier,
– Location data of the initiating device,
– Technical data about devices (MSISDN numbers, IMSI numbers, IMEI numbers or ESN numbers, device serial numbers),
– Call type, date, and time of connection or login to the software,
– The number of calls made and data about the amount of sent and received data.

 

Policy:

This privacy policy.

 

Tronik Sp. z o.o. Sp. k:

Tronik Spółka z ograniczoną odpowiedzialnością Sp. k. with its registered office in Pułtusk at ul. R. Traugutta 2 B, registered in the entrepreneurs’ register kept by the District Court for the capital city of Warsaw, XIV Economic Division of the National Court Register under the KRS number 0000683043, and Tax Identification Number (NIP): 5681567494.

 

Data collected during visits to Tronik Sp. z o.o. Sp. k. websites:

Visited places and user activity on websites and software managed by Tronik Sp. z o.o. Sp. k., including session start and end time, marketing campaign attributes, URL of the page that contained the link that redirected the user to the Tronik Sp. z o.o. Sp. k. website; transaction details and technical information about the device (IP/MAC address, operating system, and browser type); information about the location of the user’s mobile device or internet browser.”

 

Data collected during the use of Tronik Sp. z o.o. Sp. k. software:

User activity in software managed by Tronik Sp. z o.o. Sp. k., including session start and end time, URL of the page containing the link, technical information about the device (IP/MAC address, operating system, and browser type); information about the location of the user’s mobile device and all data entered by the user into the software for proper service delivery.

 

General Data Protection Regulation:

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 (Official Journal of the European Union L 119, p. 1).

 

V. UPDATES TO OUR POLICY

This Policy comes into effect on May 25, 2018, and is published on our website.