Privacy and cookies policy

The policy applies to the collection and use of information about users of the websites, and social media operated by companies from the Freundschaft group.


General information

The controller of users' personal data is Grupa Freundschaft sp z o. o. ul. Mangalia 2A, 02-758 Warsaw.


Data collection rules

When browsing the website's pages, data regarding visits are collected, e.g. data of the search engine and the query that directed the user to the website, information about the time spent on the website, the number of pages viewed, time spent on individual pages. This is information that allows us to adapt the website to the needs of users and display desired content.
The controller also collects data provided directly by the user, e.g. via e-mail or telephone conversation.


Rights of the data subject

In connection with the processing of personal data, each natural person has the right to request: access to personal data, rectification, deletion, limitation of the processing of personal data, transfer, and objection to the processing of personal data in accordance with the principles set out in Articles 15-22 of the GDPR. Each person has the right to lodge a complaint with the President of the Personal Data Protection Office regarding the manner of data processing by the controller.


Purposes and basis of data processing

  • Website users: The basis for the processing of personal data of users who contact the controller is voluntarily expressed consent, through conscious action, such as contact via telephone or e-mail (Article 6(1)(a) of the GDPR), as well as legally the justified interest of the controller, which is conducting business contacts (Article 6(1)(f) of the GDPR). Processing is carried out for the purpose of contact, including presenting an offer for services, at the user's request. Based on your consent, the controller also processes data collected via cookies and similar technologies in connection with the marketing of products and services. 
  • Customers and contractors: processing is necessary to perform the contract or to take action at the customer's request before concluding the contract, as well as to fulfill the legal obligation imposed on the controller, in particular in connection with the provisions of the law on income tax and tax on goods and services. Some data may also be processed on the basis of voluntarily expressed consent, e.g. to enable faster contact. If it is necessary to pursue claims, including debt collection, the basis for processing is the legally justified interest of the controller (Article 6(1)(a), b, c, f of the GDPR). 
  • Job candidates - data will be processed for recruitment purposes, pursuant to the provisions of the Labor Code, and also on the basis of voluntarily expressed consent to the extent exceeding the required provisions, which the candidate will voluntarily submit together with the submitted application (Article 6(1)(a) a, c GDPR). 
  • Users of the Fanpage and other social media websites - data will be processed for the purpose of contact, answering questions, submitting an offer based on voluntarily expressed consent, which is a conscious action in the form of sending a message, as well as the legitimate interest of the controller related to ensuring the continuity of business activities ( which is a premise legalizing processing under Article 6(1)(a), (f) of the GDPR).  
  • Persons subject to video monitoring - data will be processed for the purpose of protecting persons and property, on the basis of labor law provisions and the legally justified interest of the controller (Article 6(1)(cif) of the GDPR). 


The right to withdraw consent

Each person whose data is processed by the controller has the right to withdraw consent at any time without affecting the processing that took place until the consent was withdrawn. To do this, please contact the controller.


Obligation or voluntariness to provide data and consequences of failure to provide data

Providing data by:

  • The use of the website is voluntary. Failure to provide data or providing incomplete data may make contact and answering questions difficult or impossible. 
  • the customer/contractor in terms of data necessary to conclude a contract is a requirement of the provisions of the Civil Code, failure to provide them will result in the inability to effectively conclude the contract, data necessary to issue an invoice is an obligation resulting from the provisions of tax law, failure to provide them will result in the inability to settle; contact details are voluntary, and failure to provide them may hinder or slow down mutual business relations. 
  •  A job candidate is an obligation arising from the provisions of labor law to the extent that it is necessary to perform work in a given position, failure to provide data will prevent participation in the recruitment process; regarding additional data provided on the basis of consent, providing them is not necessary and failure to provide them will not affect the recruitment process. 
  • The User's contact details are voluntary and failure to provide them will result in limited correspondence on Facebook. 
  • A person subject to video monitoring - it is voluntary, but necessary to stay in the controller's office and warehouse rooms. 


Information about entities to which data may be disclosed

The controller may share data:

  • Users – entities ensuring proper operation of the website, and AdForm, Facebook, Google (detailed information below). 
  • Customers and contractors - banks, insurance companies, service subcontractors, postal operators and couriers, companies from the MEDIACAP group - based on concluded entrustment agreements.
  • Job candidates – MEDIACAP Sp. z o. o. on the basis of the concluded entrustment agreement 
  • Fanpage users - to Meta Platforms Ireland Limited and its partners on the terms set out below. 
  • Persons subject to video monitoring - the building manager from whom office and warehouse spaces are rented. 


Information on the principles of data sharing


Google Ireland Limited is the controller of your personal data for users located in the European Economic Area or Switzerland, unless otherwise indicated in the Service-Specific Privacy Notice. This means that Google Ireland Limited is a Google affiliate responsible for the processing of personal data and compliance with applicable privacy laws. Google Analytics privacy policy:
Google Analytics is used to analyze traffic on the Website, which involves collecting and analyzing the behavior of Website users.
Data collected by the tool: location, source of visits, time spent on the website, website traffic, keywords that referred the user to the website, pages viewed by the user, anonymized IP address, demographic data.

The analysis of statistical data is used to display content and make changes to the Website and Fanpage in order to increase User activity. Google allows you to exercise your rights under the GDPR. The rules for exercising these rights are set out here: To disable tracking by Google tools, download and install the browser add-on available at:



Adform privacy policy:
Adform collects and stores data for its clients related to users' interactions with advertising and digital properties such as websites or mobile applications:

  • The type of browser used by the user and its settings. 
  • Information about the device's operating system. 
  • Information about cookie IDs and other identifiers assigned to your device. 
  • IP addresses from which the device interacts with the customer's website or mobile application; IP addresses may be truncated or hashed based on local regulations or other requirements. 
  • Information about user interactions and activity on websites and mobile applications, including interaction or activity time, web addresses engaged, and search terms entered into a search engine. 
  • Information about the approximate geographic location (city, state, zip code) of your device when accessing a website or mobile application based on truncated IP address information or truncated GPS data. 

Adform may also receive information from third parties to enable targeted and tailored advertising on websites and mobile applications. While Adform may make such data available for use by its customers through the Service, it will always do so strictly in accordance with the permissions and restrictions imposed by the third party providing such data.
AdForm may share the collected data with its partners indicated in the adform privacy policy. The website controller is not responsible for the actions of these third parties. The data processed by AdForm is used to adapt the display of advertising materials to user preferences.
You can disable AdForm at any time using the OPT-OUT tool:


Data storage time

  • Users: personal data of users who contact us regarding the possibility of providing services until the contact ends and any claims expire, but no longer than 3 years.  
  • Customers/contractors: until the completion of the contract, and then for the period specified in applicable law in connection with the controller's obligations regarding archiving documents and tax settlements. 
  • Job candidates: up to 6 months from the end of recruitment or 2 years in the event of consent to further processing for other recruitment processes. 
  • Fanpage users: until consent is withdrawn or Facebook account is deleted. 
  • Persons covered by video monitoring - up to a maximum of 3 months, unless the recording serves as evidence in the case, then until the proceedings are completed. 



The user can disable cookies in the browser settings. They will not affect the viewing of the content available on the website.
The website uses the following cookies:
Session cookies : are stored on the User's Device and remain there until the end of the browser session. The saved information is then permanently deleted from the Device's memory. The session cookie mechanism does not allow downloading any personal data or any confidential information from the User's Device. The website uses Facebook, Google and AdForm cookies on the terms and for the purposes described above. 
Persistent cookies : are stored on the User's Device and remain there until they are deleted. Ending a given browser session or turning off the Device does not delete them from the User's Device. The persistent cookies mechanism does not allow downloading any personal data or any confidential information from the User's Device. Links to other sites
The controller is not responsible for the operating principles and privacy policies of other websites to which the user can go via links available on the website.


Information for Fanpage users

General information

  • When browsing the Fanpage (regardless of whether the User is logged in or not), his data is collected by the Facebook application in order to be able to provide him with advertisements from Facebook Inc and its partners.  
  • The rules for using Facebook Users' data are available in the Facebook privacy policy: 
  • When the User uses the Fanpage, its owner also processes his or her data. 
  • Providing data, including through cookies, is voluntary, but necessary for the proper use of the Fanpage. 

What data is collected?

  • The fanpage is used to present opinions, present the scope of services provided, and to enable contact with the controller.  
  • When browsing the Fanpage, Facebook automatically collects information about each visit. 
  • Through the provided controller panel, the Fanpage owner sees statistical information about visits to the Fanpage, e.g. the age of visitors, their reactions, activity. This is used to select content to suit the preferences of Fanpage users, as well as to check the effectiveness of displayed advertisements.  
  • Facebook decides whether the User will see a given advertisement. The owner of the Fanpage only sees statistical information about reactions to the advertisement, as well as reactions and comments under the advertisements. 
  • The owner of the Fanpage sees comments and reactions of Users. As a Facebook user (Fanpage controller), you can also view the User's public profile and contact him via the Facebook messenger available on Facebook. 

How is the data used?
Statistical data is used to create new advertisements and to select the content displayed. All decisions are made in a non-automated manner.

Use of cookies (“cookies”)
1.    Facebook uses cookies and options to track the User, also when he or she uses other websites. More information here: and here:
User Rights
1.    The User has the right to request editing, access, information about the source of acquisition, objection to further processing, transfer of data to another controller, as well as the right to be forgotten, unless the law clearly states otherwise or the request conflicts with the legitimate interest of the controller. . 
2.    To exercise your rights, please contact us via e-mail available on the website or via private message on Facebook. 
3.    At any time, the User may submit a complaint about the way his or her data is processed by the controller to the personal data protection supervisory authority - the President of the Office of Data Protection ( 

Data storage time
1.    The Fanpage User's data is stored until you stop using Facebook, and then for the period specified in the Facebook Regulations. 
Information about co-controlling data with Meta Platforms Ireland Limited
1.    In connection with running a fan page on Facebook, the controller and Meta Platforms Ireland Limited (4 Grand Canal Square, Grand Canal Harbor, Dublin 2 Ireland) are joint controllers of the User's data in the field of data processing for statistical and advertising purposes. 
2.    Co-administration includes collective data analysis in order to display statistics on the activity of Fanpage users. 
3.    Meta Platforms Ireland, as part of joint control, is responsible for: 

  • having a legal basis for data processing for the purposes of website statistics 
  • ensuring the implementation of the rights of data subjects 
  • reporting violations to the supervisory authority and notifying persons affected by the violation about the event 
  • ensuring appropriate technical and organizational measures to ensure data security. 

4.    controller's liability resulting from co-administration: 

  • having a legal basis for processing data for statistical purposes 
  • fulfillment of information obligations 

5.    Facebook Ireland may provide the User with the main content of the attachment regarding page statistics in accordance with Art. 26 section 2 GDPR, through the data contained in Information about website statistics, which can be accessed from the websites' Fanpage. 
6.    The main supervisory authority for joint control is the Irish Data Protection Commission (notwithstanding Article 55(2) of the GDPR, where applicable). 
7.    Detailed information regarding mutual arrangements between controllers is available at: 
8.    The rules for processing user's personal data by Facebook Ireland are available at:



In the event of a change in the applicable privacy policy, appropriate modifications will be made to the above provision.



To the Data Protection Officer:
Grupa Freundschaft sp. z o. o., ul. Mangalia 2A, 02-758 Warszawa, T +48 22 879 69 00, F +48 22 463 99 08,