Privacy policy


SWIMER Łukasz Otremba, with its registered office at ul. Płaska 64, 87-100 Toruń, is the Data Controller and processes personal data in accordance with the 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, the so called General Data Protection Regulation (in short GDPR).

1. Personal data, as defined in the GDPR, means any information relating to an identified or identifiable natural person in any form (by means of writing, sound, or image), such as, for example, name, surname, address, telephone number, e-mail address, PESEL (Personal ID no.), NIP (Tax ID no.).

Customer personal information databases at SWIMER Łukasz Otremba are stored and secured in accordance with the SWIMER Łukasz Otremba security policy, which is an integral part of the ISO 9001 compliant quality management system and the ISO 27001 compliant information security management system.

2. Filing system, as defined in the GDPR, means any structured set of personal data which is accessible according to specific criteria. SWIMER Łukasz Otremba has databases of employees, customers, suppliers, and collaborators, which only authorised employees have access to.

3. The processing of personal data, as defined in the GDPR, means any operation or set of operations which is performed on personal data or on sets of personal data, such as: collection, storage, erasure, sharing, development.

4. SWIMER Łukasz Otremba processes personal data for the following purposes:

  1. execution of civil law contracts concluded with customers

  2. execution of commercial transactions

  3. execution of orders placed by customers

  4. performance of maintenance services under guarantee and post-guarantee agreements

  5. provision of technical support services to customers

  6. performing marketing activities, in particular: bonus sales, contests, promotions, and information campaigns

  7. sending marketing and commercial emails and newsletters related to products offered by SWIMER Łukasz Otremba

  8. making telephone calls of marketing and commercial nature in relation to products and services offered by SWIMER Łukasz Otremba

  9. postal mailing of commercial information related to products and services offered by SWIMER Łukasz Otremba

5. The legal grounds for collection, processing and use of personal data by SWIMER Łukasz Otremba are as follows:

  1. The consent given by customers in accordance with the applicable law, including the provisions of the Act of 18 July 2002 on Providing Services by Electronic Means and the Telecommunications Act of 16 July 2004 in the case of contact via e-mail and automated calling systems and telecommunications terminal equipment (including voice calls and text messages).

  2. The legitimate interest of SWIMER Łukasz Otremba as the Data Controller referred to in Article 6 paragraph 1 point f) of the 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 (the General Data Protection Regulation, GDPR), in the case of sending marketing and commercial information by post.

Failure to consent to the processing of personal data for the purposes indicated above by natural persons and natural persons engaged in an economic activity:

  1. will prevent the implementation of commercial transactions

  2. will prevent the performance of maintenance services

  3. will prevent the sending of commercial communication to customers as indicated in this notice - in the case of contact via e-mail and telephone (including voice calls and text messages)

  4. may prevent the sending of commercial and marketing communication to customers on the terms indicated in this notice

Who we may disclose your personal information to and for what purpose  

We may pass on your personal data to: 

  1. our employees and associates who require access to your data in order to perform our obligations or activities on your behalf. 

2. Like most businesses, we also use the assistance of other entities in our activities, which sometimes involves the transfer of personal data. Accordingly, we may transfer your personal data to the following entities, if necessary:

  1. entities operating our IT and data ICT system

  2. entities carrying out payment activities (banks, payment institutions)

  3. entities offering lending services (banks)

  4. entities carrying out postal, courier or transport activities - transport of goods or forwarding services

  5. entities engaged in debt collection

3. In addition, it may happen, for example, that in line with a relevant legal provision or a decision of a competent authority, we will also have to provide your personal data to other entities, whether public or private. It is therefore extremely difficult for us to predict who may come forward with a request for personal data. Nevertheless, for our part, we assure you that we analyse each request for personal data very carefully and very thoroughly, so that we do not inadvertently pass on information to an unauthorised person.

7. As the Data Controller, SWIMER Łukasz Otremba commits to implementing appropriate technical and organisational security measures to protect the personal data processed. SWIMER Łukasz Otremba or data processors keep personal data only for the time necessary to achieve the purposes for which they were collected, i.e. for the entire period of validity of the consent and for the period required by law (in particular tax law and the period of limitation of claims) after its withdrawal.

1. With regard to the specific processing periods for personal data, we kindly inform you that we process personal data for the period of:

a) the duration of the contract - for personal data processed for the purpose of concluding and performing the contract;

b) up to 10 years - with regard to personal data processed for the purpose of establishing, asserting or defending claims, but for no longer than the applicable legal provisions;

c) 1 year - with regard to personal data which were collected in connection with the referral of an offer, while no immediate conclusion of a contract has taken place;

d) 5 years - with regard to personal data related to the fulfilment of obligations under tax law, e.g. storage of invoices, receipts;

e) until the consent is withdrawn or the purpose of the processing is achieved, but for no longer than 2 years - with regard to personal data processed on the basis of consent;

f) until an effective objection is lodged or the purpose of the processing is achieved, but for no longer than 2 years - with regard to personal data processed on the basis of the Controller's legitimate interest or for marketing purposes;

g) until it becomes obsolete or is no longer relevant, but for no longer than 2 years - in respect of personal data processed primarily for the purposes of using cookies and website administration;

h) for the duration of the product warranty, but for no longer than the applicable legal provisions;

2. We count the periods in years from the end of the year in which we started processing personal data in order to streamline the process of deletion or destruction of personal data. Counting the period separately for each event would involve significant organisational and technical difficulties as well as a significant financial outlay, so establishing a single date for the erasure or destruction of personal data allows us to manage the process more efficiently.

3. The right to be forgotten: Of course, in the event that you exercise your right to be forgotten, such situations are dealt with on a case-by-case basis.

8. All data subjects are entitled to data protection rights. According to the applicable data protection law, data subjects are entitled to lodge a complaint with the competent supervisory authority (i.e., the President of the Personal Data Protection Office or its successor authority).

In addition, data subjects have the right to:

a) request access to personal data; the data subject has the right to obtain confirmation from SWIMER Łukasz Otremba that personal data relating to him or her is being processed and, if so, access to it. SWIMER Łukasz Otremba will provide, upon request, a copy of the personal data subject to processing. For any further copies, SWIMER Łukasz Otremba may charge a reasonable fee to cover administration costs;

b) the rectification of personal data concerning them that is inaccurate. Taking into account the purposes of the processing, data subjects have the right to request the completion of incomplete personal data, including by providing an additional statement;

c) erasure of data ("right to be forgotten"); data subjects have the right to request, provided that there are circumstances provided for by law, the immediate erasure of personal data concerning them, and SWIMER Łukasz Otremba is obliged to erase such personal data without undue delay;

 d) restriction of the processing of personal data; in this case, SWIMER Łukasz Otremba will indicate such data upon request, and the processing may be restricted only for specific purposes;

e) portability of personal data; under certain conditions, data subjects have the right to receive in a structured, commonly used, machine-readable format the personal data processed by SWIMER Łukasz Otremba;

f) to object; under certain circumstances, the persons whose personal data is processed have the right to object at any time to the supervisory authority - on grounds relating to their particular situation - to the processing of personal data, and SWIMER Łukasz Otremba may be under an obligation to cease processing such personal data;

9. Please be informed that we do not carry out automated decision-making, including profiling.

10. We kindly inform you that your personal data is not transferred outside the European Economic Area.

11. SWIMER Łukasz Otremba does not have a Personal Data Protection Officer.

12. Contact with the Data Controller.


If you have any questions regarding data protection or the exercise of your privacy rights, please contact the Data Controller:

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We will advise, prepare an offer, recommend a distributor, deliver and launch an investment
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ul. Płaska 64
87-100 Toruń, POLAND
+48 690 056 664


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