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Privacy Policy


The following Privacy Policy sets out the rules for saving and accessing data on the Users' Devices using the Service for the purposes of providing services electronically by the Owner, as well as the rules for collecting and processing Users' personal data that were provided by them personally and voluntarily via the tools available through the Service. The following Privacy Policy is an integral part of the Terms of Service, which defines the rules, rights and obligations of Users using the Service.

§1 Definitions

  • Service - the "R2Rmarine" website operating at https://www.r2rmarine.com/ antd the "R2Rmarine" multiplatform application

  • External Service - services of partners, service providers or service recipients cooperating with the Owner

  • Owner of the Service - The Owner of the Website (hereinafter referred to as the Owner) is the company "SYLLIC GROUP EUROPE", operating at the following address: Soukenicka Street 877/9, Ostrava, with the assigned tax identification number: 14254468, providing services electronically via the Service

  • Data Administrator - The Data Administrator (hereinafter referred to as the Administrator) is Piotr Lange, operating at the following address: ul. Sikorskiego 106, Wejherowo, with the assigned tax identification number: 5882514375, responsible for collecting, storing, processing and deleting Users' data

  • User - a natural person for whom the Owner provides services electronically via the Service.

  • Device - an electronic device with software through which the User gains access to the Service

  • Cookies - text data collected in the form of files placed on the User's Device

  • GDPR - Regulation 2016/679 of the European Parliament and of the Council of the European Union 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 (Data Protection Directive)

  • Personal data - means information about 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 the individual

  • Processing - means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or modifying, downloading, viewing, using, disclosing by sending, disseminating or otherwise such sharing, alignment or combination, restriction, erasure or destruction

  • Restriction of processing - means marking stored personal data in order to limit their future processing

  • Profiling - means any form of automated processing of personal data, which consists in using personal data to evaluate certain personal factors of a natural person, in particular to analyze or predict aspects regarding the performance of that natural person, his or her economic situation, health, personal preferences, interests, reliability , behavior, location or movement

  • Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which the data subject, by means of a statement or a clear affirmative action, signifies agreement to the processing of personal data concerning him or her

  • Breach of personal data protection - means a breach of security leading to accidental or unlawful destruction, loss, modification, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise processed

  • Pseudonymization - means the processing of personal data in such a way that they 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 organizational measures to prevent their attribution to an identified or an identifiable natural person

  • Anonymization - means 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 Inspector

Pursuant to Article 37 of the GDPR, the Administrator did not appoint a Data Protection Inspector.

In matters relating to 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's Devices have been consciously included in the Service through scripts and services made available and installed as a part of the Service

  • Session Cookies - files placed and read from the User's Device by the Service and/or External Services during one 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 and/or External Services until they are manually deleted. Files are not deleted automatically after the end of the Device session, unless the configuration of the User's Device is set to delete cookies after the end of the Device session.

§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 Website are implemented through built-in mechanisms of web browsers and do not allow downloading other data from the User’s Device or data of other websites that you have visited, including personal or confidential information. Transferring viruses, Trojan horses and 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 may threaten the security of personal data or the security of the Device used by the User.

  • External cookies - The Administrator makes all possible actions to verify and select website partners in the context of Users’ security. The administrator selects well-known, large partners with global social trust for cooperation. However, it does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the security of Cookie files, their content and license-compliant use by Scripts installed on the website, coming from external websites, the Administrator is not responsible as far as the law allows. The list of partners is included in the further part of the Privacy Policy.

  • Cookie Control

  • User-side threats - The Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. 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 such data, impersonation of the User’s session or their removal as a result of the User’s conscious or unconscious activity, viruses, Trojan horses and other spyware that may have infected the User’s Device. In order to protect themselves against these threats, users should comply with the rules of safe use of the Internet.

  • Storage of personal data - The Administrator ensures that he makes every effort to ensure that the processed personal data entered voluntarily by Users is safe, access to them is limited and implemented in accordance with their intended purpose and purposes of processing. The administrator also ensures that he makes every effort to protect his data against loss by using appropriate physical and organizational security measures.

§5 Purposes for which cookies are used

  • Improving and facilitating access to the Service
  • Personalization of the Service for Users
  • Umożliwienie Logowania do serwisu
  • Keeping statistics (users, number of visits, types of devices, link, etc.)
  • Serving multimedia services

§6 Purposes of personal data processing

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

  • Implementation of electronic services:
    • Registration and maintenance services for the User's account in the Service and related functionalities
  • Communication of the Administrator with Users in matters related to the Service and data protection
  • Ensuring the Administrator’s legitimate interest

User data collected anonymously and automatically is processed for one of the following purposes:

  • Statistics
  • Ensuring the Administrator’s legitimate interest

§7 Cookie files of external websites

The Administrator on the Website uses javascript scripts and web components of partners who can 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:

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

§8 Types of collected data

The Service collects data about Users. Part of the data is collected automatically and anonymously, and part of the data is personal data provided voluntarily by Users when subscribing to individual services offered by the Service.

Anonymous data collected automatically:

  • IP Address
  • Browser type
  • Screen resolution
  • Approximate location
  • Service subpages opened
  • Time spent on the relevant subpage of the Service
  • Type of operating system
  • The address of the previous subpage
  • Referrer address
  • Browser language

Data collected during registration:

  • First name / last name / pseudonym
  • Login
  • E-mail address
  • IP address (collected automatically)

Some data (without identifying data) may be stored in cookies. Part of the data (without identifying data) may be transferred to the 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. The data collected as part of the services provided are not transferred or resold to third parties.

Access to data (usually on the basis of a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the website, i.e.:

  • Hosting companies providing hosting or related services to the Administrator

Entrusting the processing of personal data - Hosting Services, VPS or Dedicated Servers

To run the Service, the Administrator uses the services of an external hosting provider, VPS or Dedicated Servers - OVH SAS.. All data collected and processed on the website is stored and processed in the service provider's infrastructure located outside and/or inside the European Union. It is possible to access data as a result of service work carried out by the service provider's staff. Access to this data is regulated by the contract concluded between the Administrator and the Service Provider.


§10 Personal data processing method

Personal data provided voluntarily by Users:

  • Personal data is transferred outside the European Union.
    The transfer of data outside the EU is caused by the use of the services of entities located outside the EU, or as a result of publication as a result of an individual action of the User (e.g. entering a comment or entry), which will make the data available to every person visiting the website. In the event of transferring or entrusting the processing of personal data outside the EU, these data are processed on the basis of an agreement concluded between the Administrator and the Service Provider.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be sold to third parties.

Anonymous data (no personal data) collected automatically:

  • Anonymous data (without personal data) will be transferred outside the European Union.
  • Anonymous data (without personal data) will not be used for automated decision making (profiling).
  • Anonymous data (without personal data) will not be sold to third parties.

§11 Legal basis 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 Regulation on data protection)
    • art. 6 sec. 1 lit. a
      the data subject has consented to the processing of his or her personal data for one or more specific purposes
    • art. 6 sec. 1 lit. b
      processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract
    • art. 6 sec. 1 lit. f
      processing is necessary for the purposes of legitimate interests pursued by the administrator or by a third party
  • Act of 10 May 2018 on the protection of personal data (Journal of Laws of 2018, item 1000)
  • Act of 16 July 2004 Telecommunications Law (Journal of Laws of 2004, No. 171, item 1800)
  • Act of February 4, 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 only for the period of providing the Service as part of the Website by the Owner. They are deleted or anonymized within 30 days from the end of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation that requires securing legally justified 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, no longer than for a period of 3 years in the event of a violation or suspected violation of the provisions of the website regulations by the User.

Anonymous data (no personal data) collected automatically:

Anonymous statistical data, which are not personal data, are stored by the Administrator in order to keep website statistics for an indefinite period.

§13 Users’ rights related to the processing of personal data

The Service collects and processes Users’ data on the basis of:

  • The right of access to personal data
    Users have the right to access their personal data, implemented at the request submitted to the Administrator

  • Right to rectification of personal data
    Users have the right to request the Administrator to immediately rectify incorrect personal data and/or supplement incomplete personal data, carried out at the request submitted to the Administrator

  • Right to delete personal data
    Users have the right to request the Administrator to immediately delete personal data, performed at the request of the Administrator. In the case of user accounts, deletion of data consists in anonymizing data enabling identificationUser ication. The Administrator reserves the right to suspend the execution of the request to delete data in order to protect the Administrator’s legitimate interest (e.g. when the User has violated the Regulations or the data was obtained as a result of correspondence).

  • The right to limit the processing of personal data
    Users have the right to limit the processing of personal data in the cases indicated in art. 18 GDPR, e.g. questioning the correctness of personal data, carried out at the request submitted to the Administrator

  • The right to transfer personal data
    Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used machine-readable format, carried out on request submitted to the Administrator

  • The 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 of the GDPR, carried out at the request submitted to the Administrator

  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory body dealing with the protection of personal data.

§14 Contact to Administrator

The Administrator can be contacted in one of the following ways

  • E-mail addres - support@r2rmarine.com

§15 Service Requirements

  • Restricting the storage and access to cookies on the User’s Device may result in incorrect operation of some of the Service’s functions.

  • The Administrator bears no responsibility for incorrectly functioning Service functions if the User restricts in any way the ability to save and read Cookie files.

§16 External links

In the Service – articles, posts, entries or Users’ comments, there may be links to External Services 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 outside the Service.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to change this Privacy Policy at any time without the need to inform Users about the use and use of anonymous data or the use of Cookies.

  • Changes to the Privacy Policy will be published on this subpage of the Service.

  • The introduced changes come into force upon their publication.