Privacy Policy

Privacy Policy

(updated on 10.03.2025)

This document contains information about the processing of your personal data by:

Buglo Play Sp. Z o. o.
BoWiD 4
75-209 Koszalin

(hereinafter: the “Company”) in connection with the use of services available on the buglo.pl website (hereinafter: the “Site”), as well as in connection with establishing or maintaining contact with the Company through other channels of communication, including e-mail, telephone calls or traditional postal correspondence.

1. conditions for processing personal data

In accordance with Article 13 and Article 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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: “RODO” or “General Data Protection Regulation”) we inform you that:

BUGLO Play Sp. z o.o., located at 4 Bojowników o wolność i demokracji Street, Koszalin (75-209), is the administrator of the personal data obtained when Users use the website. Users’ personal data are processed in accordance with the principles of the General Data Protection Regulation of April 27, 2016. (hereinafter “RODO”) and other applicable regulations.
Compliance with data protection rules is supervised by the Administrator’s designated Data Protection Officer, who can be contacted via email: iod@buglo.pl
Personal data will be processed for the following purposes and based on the following legal grounds:

Purpose of data processing

Legal basis of data processing

Taking action

aimed at concluding a contract

Art. Article 6(1)(a) 1(b) RODO (taking action at the request of the data subject prior to entering into a contract and performance of the contract) – with respect to the ordering party

	Art. Article 6(1)(a) 1(f) RODO (legitimate interest – contacting representatives of customers and suppliers
Conclusion and implementation of contracts for cooperation	Art. Article 6(1)(a) 1(b) RODO (conclusion and performance of a contract) – with respect to parties to the contract, e.g. customer, supplier
Conclusion and implementation of contracts for cooperation	Art. Article 6(1)(a) 1(f) RODO (legitimate interest of the Administrator – providing contact with persons executing the contract or order) – with regard to representatives, persons responsible for the execution of the contract (contact persons on the side of the customer, suppliers)
Conduct of proceedings recruitment for the position of indicated in the advertisement, contact with selected candidates	Art. Article 6(1)(a) 1(a) of the General Data Protection Regulation (consent – expressed through a clear affirmative action, i.e., sending application documents) in the event that the candidate submits a broader range of data than indicated by the law and agrees to retain the submitted data for future recruitment.
	Art. Article 6(1)(a) 1(b) of the General Data Protection Regulation (taking action at the request of the data subject before entering into a contract).
Conducting promotional and marketing activities, including through electronic communication tools (e.g. email). Selected forms of communication such as sending newsletters may require obtaining additional	Art. Article 6(1)(a) 1(f) RODO (legitimate interest – direct marketing of own services),

Consent under separate provisions of law.
Handling the claims process	Art. Article 6(1)(a) 1(b) of the DPA (taking action at the request of the data subject to take action on a complaint in accordance with the contract).
Handling the claims process	Art. Article 6(1)(a) 1(c) of the DPA (legal obligation incumbent on the administrator) – handling of complaints in accordance with the provisions of the Civil Code on warranty for defects of goods and quality guarantee.
Receiving inquiries and responding (via the form available on the Site or by contacting us by email, telephone, postal mail)	Art. Article 6(1)(a) 1(f) RODO (legitimate interest – providing contact with the Administrator, receiving inquiries regarding the goods and/or services offered by the Administrator, and providing a response
Conducting analytical and statistical activities regarding user activity on the Site via cookies or other similar technologies. Installing cookies for this purpose may require obtaining your additional consent under separate laws.	Art. Article 6(1)(a) 1(f) RODO (legitimate interest – conducting analytical and statistical activities on the Site for the purpose of developing and improving services).
Investigating claims and taking action in connection with the debt collection process, as well as defending against claims	Art. Article 6(1)(a) 1(f) RODO (legitimate interest – establishing, asserting claims, taking action of a debt collection nature, defending against claims).
Organizing events with of a promotional nature, including webinars, conferences, fairs	Art. Article 6(1)(a) 1(f) RODO (legitimate interest – promotion of the company and its employees, publication of event materials).

Image processing

employees and other categories of persons

Art. Article 6(1)(a) 1(f) RODO (legitimate interest – publication of image based on consent).

Recipients of personal data will be entities providing services to the Administrator, in particular IT support, hosting services, providers of mailing services, providers of tools used by the Site[MR2] and other entities providing services on the basis of a contract of entrustment. Recipients of your data may also be entities authorized to receive data under the law.
In case you are a representative of Our client, supplier, the Administrator will process your contact data (e.g. name, surname, place of employment, e-mail address, telephone number, official position) in connection with the ongoing cooperation or for the purpose of its establishment. In case we did not obtain this data directly from you, we received it from Our client or supplier of which you are a representative.
Personal data will be stored:

for the period of the executed contract/order, ongoing cooperation or use of services,
For the period of correspondence or maintaining contact,
until you object to the processing of your data – in case the processing of personal data is based on the so-called legitimate interest (cases are described in point 3 above),
Until the withdrawal of consent – in case the processing of personal data is based on consent.

After the aforementioned period, personal data will be kept for the time in which the relevant law prescribes the storage of data or for the period of the statute of limitations for possible claims, and then they will be deleted.

In connection with the processing of personal data, you have the following rights:

The right to withdraw consent, the right to access the content of data, the right to rectify data, the right to erase data, the right to restrict data processing, the right to data portability,
The right to object to the processing of data – where the processing of your personal data is carried out on the basis of the so-called legitimate interest and under the conditions set forth in the provisions of the General Data Protection Regulation,
The right to lodge a complaint with a supervisory authority (the President of the Office for Personal Data Protection) in case the processing of personal data is deemed to violate the provisions of the General Data Protection Regulation.

All of the rights indicated above apply to the extent that they arise under the provisions of the General Data Protection Regulation. The above rights can be exercised by

sending the request to the Administrator’s registered address or, if contacted by email, to: iod@buglo.pl[MR3]

Provision of personal data is mandatory in the event that such an obligation arises from generally applicable laws. Provision of data for other purposes (described in Section 3) is voluntary, but may be necessary for their implementation, i.e. responding to an inquiry, ordering a service, concluding and performing a contract or using the Site.

2 Cookies Policy

When you visit the Site (hereinafter also referred to as the “Service”), we may collect information from you such as cookie IDs, information collected through cookies or other similar technologies.
Cookies (so-called “cookies”) are IT data, in particular text files, which are stored on a user’s terminal device and are intended for use on the Website. Cookies usually contain the name of the website from which they come, the time they are stored on the end device and a unique number.
Cookie identifiers, as well as information collected through cookies or other similar technologies in some situations may constitute personal information.
The entity placing cookies on the Website user’s end device and accessing them is the Website operator, i.e. ………………
Cookies are used for:

enable the user to use the Site and ensure the proper functioning of its functionality (essential cookies);
creation of statistics that help to understand how users of the Site use its websites, which allows to improve their structure and content (analytical cookies)

The Site uses two main types of cookies: “session” (session cookies) and “permanent” (persistent cookies). “Session” cookies are temporary files that are stored on the user’s terminal device until the user leaves the website or shuts down the software (web browser). “Permanent” cookies are stored on the user’s end device for the time specified in the parameters of the cookies or until they are deleted by the user.
The Site uses the following types of cookies:

Name

Validity period

Purpose of enrollment

_fbp

3 months

The Facebook Pixel cookie tracks users’ activities,

Optimizes ads and enables remarketing.[MR4]

When entering the Site’s website for the first time, the user will see a banner that will inform him/her of the use of cookies and allow them to be managed. The user can manage the cookies that are installed on his/her device, i.e. consent to all categories of cookies or only some of them. He can also revoke the given consents at any time by clicking on the “I reject” button. If the user accepts the installation of all categories of cookies he should click the “I accept all” button. To manage the cookie settings for a particular cookie category, click on the “Customize” button, move the corresponding button on the cookie banner, and then click on the “Save and close” button. The “Cookie Settings” button is located in the lower left corner of the Site. The ability to manage cookies does not apply to essential cookies, which cannot be disabled or rejected. [MR5]
The user can also, at any time, change the setting of cookies in the settings of the software used for browsing the Internet (web browser). By default, the web browser allows the storage of cookies on the user’s terminal device. These settings can be changed, in particular, in such a way as to block the automatic handling of cookies in the settings of the web browser or inform on their placement in the device of the Site user every time. Detailed information about the possibility and methods of handling cookies is available in the settings of your web browser.
Analytical and marketing tools used by the Site[MR6]

Please note that third parties (including Facebook, Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, hereinafter Facebook, and Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland, hereafter referred to as. Google) may use cookies and similar technologies to collect or receive information from the Site or other places on the Internet and use it to provide measurement and ad targeting services. By managing your cookie settings, you can choose whether you consent to the collection and use of information for ad targeting.

Google Analytics

The Site uses Google Analytics, which is an online web statistics and web analytics tool that gives insight into the Site’s data traffic, provided by Google. We use this tool to create statistics for the purpose of adapting the content of our websites to Users’ preferences and continuously optimizing them.

You can prevent the installation of cookies by using the appropriate setting on your web browser. You can also prevent Google from collecting data collected by cookies and about your use of the Site by installing an add-on in your browser that blocks the embedding of Google Analytics scripts available here. For more information on Google Analytics, see here.

Due to the use of the Google Analytics tool, personal data obtained in connection with the use of the website may be transferred outside the European Economic Area. The transfer of personal data in such case is based on the standard contractual clauses concluded by the Administrator with the tool’s provider. We encourage you to read the following agreement on the processing of personal data, including the content of standard contractual clauses being its element.

Information on how Google uses the data collected when you use its partners’ sites and applications is available here.

Google AdWords

It is a tool that allows you to measure the effectiveness of your advertising campaigns, including allowing you to analyze the data you collect. Google AdWords allows us to display our ads to people who have visited the Site in the past. Information about Google’s processing of Google AdWords is available at here.

Facebook’s business tools

In connection with the use of Facebook’s business tools, we and Facebook serve as joint controllers within the meaning of Article 26(1) of the DPA, based on the following agreements between co-administrators concluded in order to determine the relevant responsibilities for ensuring compliance with the obligations under RODO. In accordance with these agreements, we are responsible for providing you with the following information:

o The use of business tools is in furtherance of the legitimate interests of the Administrator and our trusted partners (Article 6(1)(f) of the RODO) to conduct marketing activities (behavioral advertising) and to measure the effectiveness of advertisements.

o For more information on data processing, see Facebook’s Data Policy (including information that Facebook is a joint controller, information required by Article 13(1)(a) and (b) of the DPA, information on how Facebook processes data, the legal basis, and how to enforce data subjects’ rights against Facebook) at the link https://www.facebook.com/about/privacy.

o Facebook is responsible for ensuring that the rights of data subjects are enforced in accordance with Articles 15-20 of the RODO with respect to personal data stored by Facebook after joint processing.

Facebook also acts as our processor, whereby it may transfer personal data outside the European Economic Area. The transfer of personal data in this case is based on the following. standard contractual clauses.

You can manage your privacy settings from your Facebook account. – Facebook pixel

This is an analytics tool available within Facebook that helps measure the effectiveness of ads based on analysis of Users’ actions on the Store, provided by Facebook, Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland), as well as enabling the targeting of personalized ads to you on the site

Facebook. Please note that Facebook may combine it with other information it has acquired in connection with your use of Facebook and then use it for its own purposes (including marketing).

HubSpot

HubSpot offers features for content management, SEO, social media marketing, web analytics, landing pages, blogging, email marketing and more. These tools are designed to help companies like ours implement and manage marketing strategies to attract customers through content and interactions on our Site.

We use the tool to collect and process personal data of our customers and employees. The tool has a module for, among other things, sending marketing content to people whose personal data we have obtained through, among other things, a form on our website. In addition, thanks to HubSpot we can effectively manage the process of collecting consents from Website Users.

Information on HubSpot’s data processing is available at the link: HubSpot Privacy Policy

Hotjar

The website uses the Hotjar plugin (Hotjar Ltd, Level 2, St Julians Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta, “Hotjar”) is the provider of the Hotjar plugin service. The Hotjar plugin is an analytics tool designed to collect information about user activity on the website. Only designated users of a Hotjar account can use the data collected by the plugin. Additional information and Hotjar’s privacy policy are available at the following addresses:

https://www.hotjar.com/legal/policies/privacy;
https://www.hotjar.com/legal/policies/terms-of-service;
https://www.hotjar.com/cookies;

To deactivate the Hotjar plugin (opt-out), disable it using the following page: https://www.hotjar.com/legal/compliance/opt-out

LinkedIn Insight Tab

The LinkedIn Insight Tag (also known as the LinkedIn Pixel) is a piece of JavaScript code that, when added to a site, collects data that can help with conversion tracking, remarketing and gaining insights into statistics about the people who visit and interact with the Site. This tool makes it easier for us to implement LinkedIn conversion tracking on the Site, as well as create targeted audiences.

Information on LinkedIn’s data processing is available at the link: LinkedIn Privacy Policy

Social networks

BUGLO Play sp. z o.o. processes the data of Users visiting company profiles maintained on social media. In the course of running profiles on social media, we are, together with the operator of the social networks, co-controllers of your personal data.

The data is processed solely in connection with the operation of the profile, including for the purpose of informing Users about the activities and actions undertaken by the companies and promoting their products, services and organized events, as well as for the purpose of contacting and interacting with Users. The legal basis for the processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO) consisting of marketing and providing interaction with Users.

The Administrator processes only the personal data designated by the User as publicly available. The processing of other personal data is carried out by social networks and under the terms of their regulations.

You can find our profiles on:

Facebook

In this situation, the co-controllers of the data are Meta Platforms Ireland Limited – you will find the rules of data processing at: https://www.facebook.com/privacy

Instagram

In this situation, the co-controllers of the data are Meta Platforms Ireland Limited – you will find the rules of data processing at: https://privacycenter.instagram.com/policy/?entry_point=ig_help_center_data_policy_redirect

Linkedin

In this situation, the co-controllers of the data are LinkedIn Ireland Unlimited Company – the rules of data processing can be found at: https://pl.linkedin.com/legal/privacy-policy

YouTube

In such a situation, the co-controllers of the data are Google Ireland Limited – you can find the principles of data processing at : https://policies.google.com/privacy

The Operator of the Site – Buglo Play sp. z o.o. reserves the right to make changes to the Privacy Policy and the Cookies Policy. Any changes will be published on the Site .