Privacy policy

Preamble

Dimark S.A., with its registered office in Golęczewo, attaches particular importance to the protection of the privacy of users visiting the website dimark.eu. This Privacy Policy aims to provide transparent information on the principles of processing personal data of users of the Website, in accordance with applicable laws, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council (GDPR).

This Privacy Policy constitutes the fulfillment of obligations arising from national and EU regulations on personal data protection, in particular those resulting from:

1. 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 (hereinafter: GDPR),
2. The Act of 10 May 2018 on the Protection of Personal Data,
3. The Act of 18 July 2002 on the Provision of Electronic Services,
4. The Act of 16 July 2004 – Telecommunications Law,
5. The Labour Code of 26 June 1974,
6. The Accounting Act of 29 September 1994.

The purpose of adopting this Privacy Policy is to:

1. ensure compliance of personal data processing of Website users with applicable data protection laws, in particular GDPR,
2. guarantee transparency of personal data processing rules towards persons using the Website, including users of the contact form, access form to the Resource Center and other functionalities available on the Website,
3. inform Website users of their rights related to the processing of personal data and the manner of exercising them,
4. define the principles and scope of personal data processing in connection with the use of the Website, including security principles and applied technical and organizational measures,
5. build users’ trust and maintain the Company’s image as a reliable and transparent personal data controller.

The Company declares that all personal data is processed in accordance with the principles of lawfulness, fairness, transparency, purpose limitation, data minimization, accuracy, storage limitation, integrity and confidentiality, and accountability.

ARTICLE 1. Definitions

For the purposes of this Privacy Policy, the following definitions shall apply:

1. Administrator – Dimark S.A., a joint-stock company with its registered office in Golęczewo (address: ul. Gottlieba Daimlera 17, 62-001 Golęczewo), entered into the Register of Entrepreneurs of the National Court Register under KRS number 0000852879, NIP: 9721309844, REGON: 386660800, share capital: PLN 100,000.00, acting as the personal data administrator within the meaning of GDPR.
2. Dimark – a term used interchangeably with “Administrator” in this document, referring to Dimark S.A.
3. Dimark Group – a group of entities linked by capital and operational ties, including Dimark S.A., Dimark Manufacture S.A. and Dimark IT S.A.
4. Website – the Administrator’s website available at: https://dimark.eu/.
5. GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
6. Personal Data – any information relating to an identified or identifiable natural person, in particular based on identifiers such as name and surname, identification number, contact details or online identifier.
7. Processing of Personal Data – any operation performed on personal data, whether automated or not, such as collection, recording, storage, viewing, use, transmission or deletion.
8. User – any natural person visiting the Website whose personal data may be processed in connection with the use of the Website.
9. Client – a natural person, legal person or organizational unit that is a party to a contract concluded with the Administrator or uses its services.
10. Potential Client – an entity that has expressed interest in the Administrator’s offer but has not concluded a contract.
11. Contractor – an entity cooperating with the Administrator in the provision of services, deliveries or other business relations.
12. Potential Contractor – an entity that has expressed interest in cooperation but has not yet commenced cooperation.
13. Cookies – IT data, in particular text files, stored on the User’s end device, used to enable use of the Website, analyze traffic or adjust content to User preferences.
14. Policy – this document, i.e. the Privacy Policy governing the processing of personal data of Website Users.

ARTICLE 2. General Provisions

1. This Privacy Policy sets out the principles for processing and protecting personal data of Users of the dimark.eu Website by Dimark S.A.
2. The provisions of this Privacy Policy apply exclusively to personal data processed in connection with the use of the Website and its functionalities, in particular the contact form, Resource Center and cookies.

ARTICLE 3. Administrator and Contact Details

1. Administrator’s details
   1. The administrator of personal data is Dimark S.A., a joint-stock company with its registered office in Golęczewo, ul. Gottlieba Daimlera 17, 62-001 Golęczewo, entered into the Register of Entrepreneurs of the National Court Register under KRS number: 0000852879, Tax Identification Number (NIP): 9721309844, Statistical Number (REGON): 386660800, share capital: PLN 100,000.00.
   2. In matters related to the protection of personal data, you may contact us:
      • in writing: Dimark S.A., ul. Gottlieba Daimlera 17, 62-001 Golęczewo, Poland,
      • by e-mail: office@dimark.eu,
      • by phone: +48 882 799 998.
2. Contact via the website
   1. The Administrator operates a website available at https://dimark.eu, which includes a “Contact” section (https://dimark.eu/contact/) enabling users to submit messages via a contact form.
   2. The following personal data are processed as part of the contact form:
      • first and last name,
      • e-mail address,
      • message content.
3. Cooperation within the Dimark Group
   1. For the purposes of handling enquiries, commercial cooperation or administrative matters, personal data may be transferred to companies belonging to the Dimark Group, including:
      • Dimark Manufacture S.A. with its registered office in Golęczewo,
      • Dimark IT S.A. with its registered office in Golęczewo.
   2. Personal data are transferred solely to the extent necessary to achieve the purpose of contact and with the application of appropriate safeguards required under Regulation (EU) 2016/679 (GDPR).

ARTICLE 4. Categories of Data Subjects

Within the scope of its activities, the Administrator processes personal data of the following categories of persons:

1. Business partners and their representatives

Business partners include, in particular, entrepreneurs, companies, individual clients and other entities with which the Dimark Group establishes business relationships, such as clients, suppliers, subcontractors or commercial partners.

In particular, these may include:

1. natural persons conducting business activity (sole traders),
2. legal persons and organisational units, including commercial law companies,
3. natural persons acting on behalf of the above-mentioned entities, in particular employees, authorised representatives, proxies and associates.

These relationships may concern cooperation with any of the companies forming part of the Dimark Group.

The companies jointly carry out projects and activities within the Dimark Group; therefore, in certain cases, they may share contact and operational data of their business partners and their representatives.

2. Website users

Natural persons visiting the website available at www.dimark.eu, including:

1. persons browsing the content of the website,
2. persons whose data may be processed in connection with cookies used on the website.

ARTICLE 5. Scope of Data Processing, Purposes and Legal Bases

Depending on the relationship established with Dimark, personal data are processed for different purposes, within different scopes and on different legal bases resulting from the GDPR.
Below is a description of the categories of data, purposes of processing and the applicable legal bases.

1. Handling enquiries and correspondence

Scope of data:
First and last name, e-mail address, telephone number and other data voluntarily included in the content of the message.

Purpose:
Responding to enquiries and conducting communication with persons interested in the offer or cooperation.

Legal basis:
Article 6(1)(f) GDPR – the legitimate interest of the Administrator consisting in ensuring contact with third parties.

2. Marketing of own services

Scope of data:

Contact data (e-mail address), data regarding activity on the website (IP address, cookies, clicks, viewed content).

Purpose:
Sending marketing information, conducting promotional activities, adjusting marketing content to user interests (including profiling).

Legal basis:

Article 6(1)(a) GDPR – consent (in the case of sending marketing communications),

Article 6(1)(f) GDPR – the legitimate interest of the Administrator in promoting its own services.

3. Profiling 

Scope of data:

Data relating to website activity and user behaviour, including IP address, cookies, information about viewed content, clicks, time spent on the website, and declared or inferred preferences.

Purpose:
Creating a profile of user interests in order to tailor content, improve the quality of services and marketing activities, and better match information to user needs and expectations.

Legal basis:

Article 6(1)(a) GDPR – consent, where required under applicable regulations (in particular with regard to marketing profiling),

Article 6(1)(f) GDPR – the legitimate interest of the Administrator consisting in optimising content and improving the effectiveness of communication and services.

Additional information:

The Administrator does not make decisions based solely on automated processing that would produce legal effects or similarly significantly affect the data subject.

Consent may be withdrawn at any time by sending an e-mail to: info@dimark.eu.

4. Statistics and analysis of website use

Scope of data:

Data regarding website activity, including IP address, cookies, duration of visits, visited subpages, location, browser type and operating system.

Purpose:
Improving the quality of the website, analysing user preferences and optimising content.

Legal basis:

Article 6(1)(f) GDPR – the legitimate interest of the Administrator.

5. Establishment, exercise and defence of claims

Scope of data:

Identification data, contractual data, correspondence and documentation related to potential disputes.

Purpose:
Protection of legal interests and securing evidence.

Legal basis:

Article 6(1)(f) GDPR – the legitimate interest of the Administrator.

6. Contact via the website contact form

Scope of data:

First and last name, e-mail address, region (Europe / Asia Pacific), message content.

Purpose:
Responding to enquiries submitted via the contact form and maintaining communication related to handling the enquiry.

Legal basis:

Article 6(1)(f) GDPR – the legitimate interest of the Administrator consisting in ensuring contact with persons interested in the offer, cooperation or technical support.

Additional information:

Providing data is voluntary, however necessary to achieve the purpose of contact.
Data submitted via the contact form are not used for marketing purposes without the prior consent of the data subject.

7. Reports submitted via the Dimark Ethics Line

Scope of data:

Identification data (if not submitted anonymously), contact details, content of the report, data of persons concerned by the report.

Purpose:
Receiving, analysing and handling reports regarding potential violations of law, ethical principles or values applicable within the Dimark Group.

Legal basis:

Article 6(1)(c) GDPR – compliance with a legal obligation incumbent on the Administrator (in particular in connection with whistleblower protection regulations, upon their entry into force),
and Article 6(1)(f) GDPR – the legitimate interest of the Administrator consisting in ensuring compliance and ethical conduct of business activities.

Additional information:

The data are processed confidentially and access is limited exclusively to authorised persons responsible for handling the reports.

With regard to reports submitted via the Ethics Line, certain rights of data subjects may be restricted to the extent permitted by the GDPR and applicable whistleblower protection regulations, in particular in order to ensure the confidentiality of the investigation, protect the identity of the whistleblower and persons indicated in the report, and safeguard the proper conduct of the proceedings.

8. Access to materials in the Resource Center section

Scope of data:

First and last name, e-mail address, company name, job title, area of interest (e.g. Brownfield or Greenfield), as well as technical data related to the use of the website.

Purpose:
Enabling access to informational, technical or presentation materials made available in the Resource Center section, conducting communication related to downloaded materials and undertaking activities aimed at developing business relationships.

Legal basis:

Article 6(1)(f) GDPR – the legitimate interest of the Administrator consisting in providing industry-related and informational materials and establishing business relations, and, where separate consent has been given – Article 6(1)(a) GDPR.

Additional information:

Providing data is voluntary, however necessary to obtain access to the materials made available in the Resource Center.

ARTICLE 6. Data Recipients

In connection with its activities, your personal data may be disclosed to the following categories of recipients:

1. Service providers supporting our operations

We may disclose your personal data to service providers that support our business operations. These may include entities processing data on our behalf or acting as independent data administrators. In particular, these include:

1. IT companies – providing maintenance and support for IT systems and managing hosting and communication infrastructure (including email, cloud tools, and CRM systems),
2. accounting service providers,
3. law firms and tax advisors – providing legal and advisory services,
4. auditing and consultancy firms – performing audits and controls,
5. postal and courier service providers – for the purpose of sending documents, parcels, or informational materials.

2. Business partners and contractors

In certain cases, personal data may be disclosed to contractors cooperating with Dimark, solely to the extent necessary to perform contracts or act at your request (e.g., order fulfillment, joint projects, organization of industry events).

3. Public authorities and state institutions

Your personal data may be disclosed to authorized public authorities if we are required to do so by law, in particular:

1. Police, public prosecutors, and courts,
2. tax authorities and the Social Insurance Institution (ZUS),
3. President of the Personal Data Protection Office,
4. other authorized supervisory or control institutions.

4. Other data recipients

In justified cases, personal data may be disclosed to:

1. insurance companies (e.g., for property or liability insurance),
2. document archiving service providers,
3. companies handling document destruction or equipment disposal.

5. Data sharing within the Dimark Group

Personal data may be shared with other entities belonging to the Dimark Group, i.e., Dimark S.A., Dimark Manufacture S.A., and Dimark IT S.A., for administrative, accounting, or joint project purposes.
Data sharing is conducted only to the extent necessary for the specified purposes and based on:

• the legitimate interest of the data administrator (Article 6(1)(f) GDPR), or
• appropriate data processing agreements if the entity processes data on behalf of the Administrator.

6. Data transfer outside the European Economic Area (EEA)

In certain cases, personal data may be transferred outside the European Economic Area, in particular to cloud service providers, technology providers, or communication tools providers.
In such cases, the Administrator ensures appropriate safeguards in accordance with GDPR. Data transfer is based on:

1. a European Commission adequacy decision, or
2. standard contractual clauses approved by the European Commission, or
3. other mechanisms provided for in Articles 46–49 GDPR.

Data subjects may request a copy of the applied safeguards by contacting the Administrator at: office@dimark.eu.

ARTICLE 7. Data Retention Period

The period for which personal data are stored depends on the purpose of their processing and the legal basis for such processing. We store data for the time necessary to achieve the purposes for which they were collected, as well as in accordance with applicable laws and adopted accounting, archiving, and claims protection rules.

Below we present detailed information:

1. Data processed on the basis of consent

Data processed on the basis of your consent (e.g. for marketing purposes) are stored until such consent is withdrawn. After withdrawal, the data are deleted or anonymized, unless further processing is necessary for evidentiary purposes for the duration of the limitation period for claims.

2. Data from cookies and other tracking technologies

Data collected via cookies are stored for a period corresponding to the lifespan of a given cookie, in accordance with your browser settings, or until they are deleted by the user.

3. Data processed to comply with legal obligations

Where legal provisions require us to retain data (e.g. accounting documentation), we store such data for the period specified by those provisions—typically 5 years, calculated from the end of the calendar year in which the tax obligation arose.

4. Data processed on the basis of the controller’s legitimate interest

Data processed for the purposes of establishing, pursuing, or defending claims, ensuring security, preventing abuse, or conducting statistical analyses are stored until the expiration of the limitation period for claims or until the legitimate legal interest ceases to exist.

5. Data processed via the website

Personal data of website users (e.g. data provided via contact forms or chat) are stored for the period necessary to handle the inquiry or provide the service. Where consent for marketing or contact has been given, the data are processed until such consent is withdrawn. Technical data (e.g. IP address, server logs) are stored for up to 12 months for security and administrative purposes.

6. Data reported via the Ethics Line (whistleblowing)

Personal data contained in reports submitted via the Ethics Line are stored for the period necessary to examine the report and in accordance with applicable whistleblower protection regulations – no longer than 12 months from the completion of the explanatory proceedings, unless further processing is necessary to pursue or defend claims.

ARTICLE 8. Rights of Data Subjects

Every person whose personal data are processed by the Controller is entitled to certain rights arising from the GDPR. In order to exercise any of the rights listed below, please contact us at the e-mail address indicated in ARTICLE 3(1) of this Privacy Policy.

1. Right of access to data (Article 15 GDPR)

You have the right to obtain confirmation as to whether we process your personal data and, if so, the right to access such data and information including, in particular, the purposes of processing, categories of data, recipients, data retention period, and your rights. You also have the right to obtain a copy of the personal data being processed.

2. Right to rectification (Article 16 GDPR)

You have the right to request the rectification of inaccurate personal data or the completion of incomplete personal data.

3. Right to erasure (“right to be forgotten”, Article 17 GDPR)

You have the right to request the erasure of your personal data in cases provided for by law, in particular where:

1. you withdraw your consent to data processing (where consent was the legal basis),
2. the data are no longer necessary for the purposes for which they were collected,
3. you lodge an effective objection to the processing,
4. the data are processed unlawfully.

We reserve the right to retain certain personal data to the extent necessary, e.g. for the purposes of establishing, pursuing, or defending claims.

4. Right to restriction of processing (Article 18 GDPR)

You have the right to request restriction of the processing of your personal data where:

1. you contest the accuracy of the data – for the period needed to verify them,
2. the processing is unlawful and you object to the erasure of the data,
3. the data are no longer needed for processing purposes, but are required by you for the establishment, pursuit, or defense of claims,
4. you have objected to the processing – pending verification of the objection.

5. Right to data portability (Article 20 GDPR)

You have the right to receive the personal data you have provided to us in a structured, commonly used, and machine-readable format. You may also request that such data be transmitted directly to another controller, where technically feasible.

6. Right to object (Article 21 GDPR)

You may object at any time to the processing of your personal data:

1. based on our legitimate interests (e.g. for marketing or analytical purposes),
2. for profiling purposes.

After an objection is lodged, we will no longer process your data unless we demonstrate compelling legitimate grounds overriding your interests, rights, and freedoms, or grounds for the establishment, pursuit, or defense of claims.

7. Right to withdraw consent (Article 7(3) GDPR)

Where the processing of your personal data is based on consent, you may withdraw it at any time.
Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal.

8. Right to lodge a complaint with a supervisory authority (Article 77 GDPR)

If you believe that the processing of your personal data infringes the GDPR, you have the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw; www.uodo.gov.pl).

9. Time limit for handling requests

Your request will be handled without undue delay and no later than within one month of its receipt. In the case of complex matters or a large number of requests, this period may be extended by a further two months, of which you will be informed.

ARTICLE 9. Data Security Principles

1. The Controller makes every effort to ensure the security of processed personal data and to protect them against access by unauthorized persons, loss, destruction, alteration, or disclosure.
2. We apply appropriate technical and organizational measures in accordance with the requirements of the GDPR, in particular:
   1. encryption of data transmissions (e.g. SSL protocol),
   2. access control systems and authorization management,
   3. antivirus protection and network firewalls,
   4. physical safeguards restricting access to data,
   5. procedures for creating and storing backup copies.
3. We have implemented information security policies and incident management procedures in order to minimize the risk of personal data breaches.
4. Personal data are processed exclusively by authorized persons who have been trained in data security and are obliged to maintain confidentiality.

ARTICLE 10. Cookies and the Website

1. The website dimark.eu does not require user registration, and access to its content is possible without creating an account.
2. Contact with the website administrator is possible via e-mail at office@dimark.eu or by phone at +48 882 799 998.
3. The website dimark.eu uses cookies for technical, statistical, and marketing purposes. These files enable, among other things, the proper functioning of the website, adjustment of content to user preferences, and the collection of anonymous data regarding user activity in order to improve the quality of services.
4. Users may manage cookies through their web browser settings. They may block the saving of cookies or delete them from their device. However, please note that disabling cookies may affect the functionality of the website, and some of its features may become less available or more difficult to use.

ARTICLE 11. Final Provisions

1. The Controller reserves the right to amend and update this Privacy Policy as necessary. Any changes will be introduced in accordance with applicable laws.
2. Users will be informed of any changes to the Privacy Policy by means of an appropriate notice published on the website https://dimark.eu/. In the event of material changes, users may receive individual notification at the e-mail address provided.
3. This Privacy Policy shall enter into force on 8 March 2026, i.e. as of the date of its publication on the Website.