Политика конфиденц.

PRIVACY AND COOKIES POLICY

of the B2B Platform and Website of
Alnor Systemy Wentylacji Sp. z o.o.
Last revision: 30/01/2026

I. General Provisions

This Privacy Policy is a complete information document setting out the rules for the processing of personal data and the use of cookies and tracking technologies within:

  1. the B2B Sales Platform (hereafter: the "B2B Platform");
  2. Website operating under the domain alnor.com.pl (hereinafter: "Website").

Personal data collected by the Controller is processed in accordance with the highest security standards and legal provisions, in particular:

  1. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ EU L 2016.119.1 of 04/05/2016) (hereinafter: "GDPR");
  2. the Act of 12 July 2024 – Electronic Communications Law, Journal of Laws of 2024, item 1221 of 09/08/2024 (hereinafter: "ECL");
  3. Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on the Digital Single Market for digital services and amending Directive 2000/31/EC (Digital Services Act) OJ EU L 2022.277.1 of 27/10/2022 (hereinafter: "DSA");
  4. Regulation of 10 May 2023 of the European Parliament and of the Council on general product safety, amending Regulation (EU) No 1025/2012 of the European Parliament and of the Council and Directive (EU) 2020/1828 of the European Parliament and of the Council and repealing Directive 2001/95/EC of the European Parliament and of the Council and Council Directive 87/357/EEC OJ UE L 2023.135.1 of 23/05/2023 (hereinafter: "GPSR").

1. Data Controller

The data controller of the personal data is Alnor Systemy Wentylacji Sp. z o.o. with its registered office in Warsaw (00-719), ul. Zwierzyniecka 8b, entered into the register of entrepreneurs of the National Court Register under KRS number: 0000038889, Tax Identification Number (NIP): 521-10-68-747, Business Registry Number (REGON): 010685817, with the share capital of PLN 334,500.00 (hereinafter: the "Controller" or "Alnor").

2. Addressees of the Policy

The Policy is addressed to all users of the Website and the B2B Platform (hereinafter: the Users), in particular to:

  1. Professional Entrepreneurs (companies, large entities);
  2. Entrepreneurs on Consumer Rights (natural persons conducting business activity – sole proprietorship, making non-professional purchases);
  3. Representatives and employees of contractors (Authorised Users).

Sole Proprietorship status: The User's status as a Professional Entrepreneur or an Entrepreneur on Consumer Rights may be verified on the basis of the User's declaration, registration data and the nature of the specific transaction. To the extent that the Entrepreneur on Consumer Rights benefits from the protection provided for consumers, the Controller shall apply to them the information and protection standards of legal regulations in force.

II. Contact Details and DSA Contact Point

In the interests of transparency and ease of communication, the Controller has designated dedicated channels of contact.

1. Protection of Personal Data (GDPR)

The User may contact the Controller on matters related to data processing:

E-mail: rodo@alnor.com.pl

Office address: Alnor Systemy Wentylacji Sp. z o.o., Aleja Krakowska 10, 05-552 Wola Mrokowska

2. DSA (Digital Services Act) Contact Point

In accordance with the requirements of DSA Regulation, the Controller has designated an electronic contact point for the reporting of illegal content and for communication with supervisory authorities and the European Commission:

E-mail: b2b.support@alnor.com.pl

Languages of communication: Polish, English

III. Purposes, Legal Basis and Scope of Processing

The Controller processes personal data for specific purposes, based on the legal grounds indicated below and for a limited period of time (retention).

Purpose of Processing Legal Basis Scope of Data Retention Period
1. Registration and Operation of a B2B Business Account
Conclusion and execution of the agreement for the provision of electronic services, verification of entrepreneurial status.
Article 6(1)(b) of GDPR (Necessity for performance of the agreement). Name, e-mail address, telephone number, VAT number, company name, business address, password (encrypted), order history. For the duration of the Service Agreement (having the Account). Upon deletion of the account – for the period of the statute of limitations for claims (3 years for B2B claims, 6 years in other cases).
2. Execution of Orders and Sale Agreements
Delivery of goods, payment processing, invoicing.
Article 6(1)(b) of GDPR (Execution of the sale agreement) and Article 6(1)(c) of GDPR (Legal obligation – tax/accounting). Delivery address details, contact person details (full name, telephone number), invoice details. 5 years counting from the end of the calendar year in which the deadline for payment of the tax expired (a requirement of the Tax Ordinance).
3. Product Safety (GPSR) and Traceability
Safety notifications, recalls, service actions, batch tracking.
Article 6(1)(c) of GDPR read with GPSR (Legal obligation). Customer contact details, order history (goods indices, batch numbers). 10 years after the product is placed on the market (in line with product safety and traceability requirements).
Important: The withdrawal of marketing consents or the lodging of objections to marketing does not affect the Controller's ability to contact the User on matters relating to product safety, recalls and mandatory technical and warning messages.
4. Direct Marketing (Newsletter, SMS, Telephone)
Sending of offers, price lists, news.
Article 6(1)(f) of GDPR (Legitimate interest – own marketing) OR Article 6(1)(a) of GDPR (Consent). Read with Article 398 of ECL (Consent to the communication channel). E-mail address, telephone number, first name, purchase history. Until the withdrawal of consent to the communication or making an effective objection.
Cold Calling Prohibition: The Controller does not carry out telephone or e-mail marketing without the prior consent required by the provisions of the Electronic Communications Law (Article 398 of the ECL), regardless of whether the recipient is a consumer or a professional entity (B2B).
5. Individual Pricing (Omnibus)
Presentation of personalised commercial terms and discounts.
Article 6(1)(b) of GDPR (Performance of the agreement) and Article 6(1)(f) of GDPR (Legitimate interest). History of cooperation, volume of purchases, timeliness of payments, commercial parameters. For the duration of an active B2B Account and trade cooperation.
6. Analytics, Statistics and Development
Traffic analysis, process automation, recommendations (including AI).
Article 6(1)(f) of GDPR (Legitimate interest) or Consent (for marketing cookies). Anonymised statistical data, cookies, device parameters. In accordance with the validity period of the cookies (details in the cookie banner), a maximum of 2 years.
7. Handling of DSA Requests and Moderation Decisions
Dealing with reports of illegal content.
Article 6(1)(c) of GDPR (Legal obligation under the DSA). Reporting party's data, content of the report, correspondence, decision. For the duration of the investigation and report archiving for 5 years (in accordance with the DSA reporting requirements).

7. Sources of Data (Article 14 of GDPR)

As a rule, personal data is collected directly from Users. In some cases, data may be obtained from other sources:

  1. from the data subject's employer or principal (in the case of employees of the contractor setting up sub-accounts or designated contact persons);
  2. from public registers (Central Registration and Information on Business (CEIDG), National Court Register (KRS));
  3. from business partners or contractors (in connection with the performance of agreements). In the case of indirect data acquisition, the Controller shall comply with the information obligations pursuant to Article 14 of GDPR.

8. Voluntary Data Provision

  1. Strictly necessary: The provision of data marked as mandatory is necessary for the conclusion of the agreement, establishing the B2B Account and the processing of the order. Their absence makes the provision of service impossible.
  2. Voluntary: The provision of marketing and additional data is voluntary.

IV. Data Recipients

Personal data may be transferred to entities cooperating with the Controller in order to provide services. We ensure legal compliance with each data processor (e.g. through outsourcing agreements). The recipients of the data may be:

  1. IT service providers: Providers and maintainers of the B2B Platform, hosting, CRM/ERP systems.
  2. Logistics and Transport: Courier companies, carriers (for delivery of goods).
  3. Payment operators: Banks and online payment systems.

Roles of third parties: With regard to the use of analytical and marketing tools (e.g. Google, Meta), these providers may act as:

  1. processors (on behalf of the Controller);
  2. independent controllers;
  3. data joint controllers (in accordance with Article 26 of GDPR). The specific processing rules for third party providers (e.g. Google) are set out in their terms and conditions and privacy policies.

V. Data Transfer Outside the EEA

The Controller generally processes data in the European Economic Area (EEA). However, in connection with the use of global technology providers, the Controller may transfer anonymised statistical data (cookies) or technical data to third countries. The transfer is always carried out in compliance with the requirements of GDPR based on:

  1. European Commission decision (e.g. EU-US Data Protection Framework / Data Privacy Framework);
  2. EU-approved Standard Contractual Clauses (SCCs). A copy of the safeguards in place may be obtained by contacting the Controller.

VI. Profiling, Automation and Individual Pricing

1. Pricing and Transparency (Omnibus)

We would like to inform you that the prices, discounts, bonuses and commercial terms presented to Users on the B2B Platform are of an individual nature. They are determined based on the history of cooperation, volume of purchases, timeliness of payments and other commercial parameters. This means that an offer presented to one user may differ from an offer to another counterparty and does not constitute a uniform public offer.

The Controller informs that data on purchase history and activity on the Platform may be used to personalise the commercial offer (e.g. presentation of recommended products, commercial conditions or discounts), but is not used to mislead as to prices, promotions or to manipulate product rankings within the meaning of the regulations on consumer protection and unfair competition practices (the so-called Omnibus / Office of Competition and Consumer Protection (UOKiK)).

2. Automation and AI

The Controller reserves the right to use tools to support data analysis, process automation, profiling or commercial recommendations (including artificial intelligence algorithms). These activities are aimed at improving the B2B service (e.g. recommendations of complementary products).

The Controller informs that decisions regarding the granting, modification or revocation of a trade credit limit are not taken solely by automated means and are always subject to review by an employee. The User has the right to request human intervention and to make their point of view known.

VII. Cookies and Content Presentation

1. Cookies

The B2B Platform uses cookies in two main categories:

  1. Strictly necessary: These are cookies that are necessary for the proper functioning of the Website (in particular for maintaining the session, logging in, handling the shopping basket). Their use is permitted without obtaining the User's consent, as they are strictly necessary for the provision of electronic services.
  2. Analytical/Marketing: They are only used with the prior, voluntary consent of the User, in accordance with the provisions of the Electronic Communications Law and GDPR.

The Controller may, depending on the analytical or marketing tools currently in use, use consent management mechanisms and privacy signals (e.g. as part of consent management platforms – CMPs or solutions offered by third party tool providers) that allow information about the User's consent status to be transmitted to these tools. Irrespective of the technical solution used, cookies and non-essential tools are only activated with the appropriate consent of the User, in accordance with the provisions of the Electronic Communications Law and GDPR.

In the absence of the User's consent, the Controller does not store analytical or marketing category cookies on the User's device and the data, if processed, is only aggregated or anonymised.

2. Rankings and Sorting (Omnibus)

If the Website uses sorting or presentation mechanisms for products (e.g. "most popular", "recommended"), the order may be determined on the basis of objective business criteria, such as: availability of goods, popularity (sales volume), current sale campaigns or margins.

3. Opinions

If the function for publishing opinions is made available, the Controller shall indicate each time an opinion is published whether and how it verifies that it comes from an actual customer who purchased the product.

VIII. Rights of Data Subjects

Each User has rights under GDPR:

  1. Right to access data: Obtaining information about processing and copies of data.
  2. Right to rectify: Correction of erroneous data or completion of incomplete data.
  3. Right to erase data ("right to be forgotten"): In cases defined by law.
  4. Right to limit processing.
  5. Right to data portability.
  6. Right to object: Against processing based on legitimate interests (including profiling).
  7. Right to withdraw consent: At any time (without affecting the lawfulness of the processing before its withdrawal).
  8. Right of complaint: The data subject has the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw).

To exercise your rights, please contact: rodo@alnor.com.pl

IX. Security and Infringements

Protections: The connection to the B2B Platform is encrypted (SSL/TLS protocol) and user passwords are stored in hashed form.

Infringement procedure: The Controller has procedures in place to detect and report data breaches. In the event of a violation that threatens the rights or freedoms of persons, the Controller:

  1. Performs a risk assessment;
  2. Reports the breach to the President of the Personal Data Protection Office (within 72h, if required);
  3. Notifies data subjects (if the risk is high).

X. Digital Services Act (DSA) and Fairness

In relation to the implementation of the Digital Services Act (DSA) and the fairness (interface fairness) principles:

  1. Reporting procedure (Notice & Action): Any User may report the presence of illegal content on the Website via a dedicated point of contact: b2b.support@alnor.com.pl.
  2. Lack of "Dark Patterns": The Controller declares that it does not use the so-called deceptive interfaces (dark patterns), i.e. mechanisms aimed at forcing consent, making it difficult to resign from services or misleading the Users as to the consequences of their decisions.
  3. Voluntariness of marketing consents: Consent to marketing communications is not a prerequisite for setting up a B2B Account or using the Platform.

XI. Policy Changes

The Privacy Policy is continuously reviewed and updated in the event of changes in law or technology. Registered Customers shall be informed of significant changes by e-mail in advance.

REKUPERACJA
PROJEKTOWANIE
x
Alnor Ventilation Systems
Aleja Krakowska 10
05-552 Wola Mrokowska
Польша

tel. +48 22 737 40 00