Total Commander Ultima Prime - One For All

Privacy Policy

The following Privacy Policy defines the principles of saving and accessing data on Users' Devices using the Website for provision of electronic services by the Administrator and principles of collecting and processing Users' personal data, which were provided by them personally and voluntarily through the tools available on the Website.

§1 Definitions

  • Website - "tcup.pl" website operating at https://tcup.pl
  • External website - websites of partners, service providers or recipients cooperating with the Administrator
  • Website/ Data Administrator - The Administrator of the Website and the Data Administrator (hereinafter referred to as the Administrator) is a natural person Robert Łajka, providing electronic services via the Website
  • User - a person natural person for whom the Administrator provides services electronically via the Website.
  • Device - an electronic device with software through which the User the User gains access to the Website
  • Cookies - text data collected in the form of files placed on the User's Device
  • RODO - 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 the repeal of Directive 95/46/EC (General Data Protection Regulation)
  • Personal data - means information about an identified or identifiable natural person ( "data subject"); an identifiable natural person is a person who can be identified, directly or indirectly, in particular on the basis of an identifier such as name and surname, identification number, location data, online identifier or one or more specific physical, physiological, genetic, mental factors, the economic, cultural or social identity of a natural person
  • Processing - means an operation or a set of operations performed on personal data or sets of personal data in an automated or non-automated manner, such as collecting, recording, organizing, organizing, storing, adapting or modifying, downloading, viewing, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • Restriction of processing - means marking stored personal data in order to limit their future processing
  • Profiling - means any form of automated processing of personal data, which consists in the use of personal data to evaluate certain personal factors of a natural person, in particular to analyze or forecast aspects concerning the effects of that natural person's work economic situation, health, personal preferences, interests, credibility, behavior, location or movement
  • Consent - the consent of the data subject means voluntary, specific, informed and unambiguous indication of the will by which the data subject, in the form of a statement or a clear affirmative action, consents to the processing of personal data concerning him/her
  • Breach personal data protection - means a breach of security leading to accidental or unlawful destruction, loss, modification, unauthorized disclosure or unauthorized access to personal data sent, stored or otherwise processed
  • Pseudonymisation - means the processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is stored separately and are subject to technical and organizational measures that prevent them from being assigned to an identified or identifiable natural person
  • Anonymization - Data anonymization is an irreversible process of operations on data, which destroys/ overwrites "personal data" making it impossible to identify or link a given record to a specific user or natural person.

§2 Security Inspector

Pursuant to Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

In matters relating to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookie Files

  • Internal Cookies - files placed and read from the User's Device by the Website's ICT system
  • External cookies - files placed and read from the User's Device by ICT systems of External Services. Scripts of external websites that may place cookies on the User's Devices have been consciously placed on the Website through scripts and services made available and installed on the Website
  • Session cookies - files posted and read from the User's Device by the Website or External Websites during one session of a given Device. After the end of the session, the files are deleted from the User's Device.
  • Permanent cookies - files placed and read from the User's Device by the Website or External Sites until manually removed. Files are not automatically deleted after the end of the Device session, unless the configuration of the User's Device is set to delete cookies after the end of the Device session.

§4 Security of data storage

  • Mechanisms for storing and reading Cookie files - Mechanisms for storing, reading and exchanging data between Cookies saved on the User's Device and the Website are implemented through built-in mechanisms of web browsers and do not allow downloading other data from the User's Device or data from other websites that the User has visited, including personal data or confidential information. Transferring viruses, Trojan horses and other worms to the User's Device is also practically impossible.
  • Internal cookies - cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content or information that may threaten the security of personal data or the security of the Device used by the User.
  • External cookies - The Administrator takes all possible actions to verify and select website partners in the context of Users' security. The administrator selects well-known, large partners with global social trust for cooperation. However, it does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the security of Cookie files, their content and license-compliant use by Scripts installed on the website, coming from external websites, the Administrator is not responsible as far as the law allows. The list of partners is included in the further part of the Privacy Policy.
  • Cookie file control
  • User-side threats - The Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User's activity. The Administrator is not responsible for the interception of such data, impersonation of the User's session or their removal as a result of the User's conscious or unconscious activity, viruses, Trojan horses and other spyware that may have infected the User's Device.
  • Storage of personal data - The Administrator ensures that he makes every effort to ensure that the processed personal data entered voluntarily by Users is safe, access to it is limited and implemented in accordance with their intended use and purposes of processing. The administrator also ensures that he makes every effort to protect the data held against loss by applying appropriate physical and organizational security measures.
  • Password storage - The Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. Decryption of account access passwords provided on the Website is practically impossible.

§5 Purposes for which Cookies are used

  • Improving and facilitating access to the Website
  • Personalizing the Website for Users
  • Enable logging in to the website
  • Marketing, Remarketing on websites
  • Advertising services
  • Affiliate services
  • Keeping statistics (users, number of visits, types of devices, etc.)
  • Serving multimedia services

§6 Purposes of personal data processing

Personal data provided voluntarily by Users is processed in one of the for the following purposes:

  • Implementation of electronic services:
    • Registration services and maintenance of the User's account on the Website and related functionalities
  • Communication of the Administrator with Users in matters related to the Website and data protection
  • Ensuring the Administrator's legitimate interest

Data about Users collected anonymously and automatically is processed for one of the following purposes :

  • Keeping statistics
  • Remarketing
  • Serving advertisements tailored to Users' preferences
  • Handling affiliate programs
  • Ensuring the legitimate interest of the Administrator

§7 Cookie files of external websites

The administrator on the Website uses javascript scripts and web components of partners who may place their own cookies on the User's Device. Remember that in your browser settings you can decide for yourself about the allowed cookies that can be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

Services provided by third parties are beyond the Administrator's control. These entities may change their terms of service, privacy policy, the purpose of data processing and the ways of using cookies at any time.

§8 Types of collected data

The website collects data about Users. Part of the data is collected automatically and anonymously, and part of the data is personal data provided voluntarily by Users when subscribing to individual services offered by the Website.

Anonymous data collected automatically:

  • IP address
  • Browser type
  • Screen resolution
  • Approximate location
  • Site subpages opened
  • Time spent on the relevant subpage of the website
  • Type of operating system
  • Previous page address
  • Referrer address
  • Browser language
  • Internet speed
  • Internet service provider

Data collected during registration on the Forum Board:

  • Nickname
  • Login
  • E-mail address
  • IP address (collected automatically)

Data collected when subscribing to the RSS service

  • E-mail address

Some data (without identifying data) may be stored in cookies. Part of the data (without identifying data) may be transferred to the statistical service provider.

§9 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or resold to third parties.

Access to data (usually on the basis of a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the website, i.e.:

§10 Method of personal data processing

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless they have been published as a result of the User's individual action (e.g. entering a comment or entry), which will make the data available to every person visiting the website.
  • Personal data will not be used for automated decision-making (profiling).
  • Personal data will not be sold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) will not be transferred outside the European Union.
  • Anonymous data (without personal data) will not be used for automated decision-making (profiling).
  • Anonymous data (without personal data) will not be sold to third parties.

§11 Legal basis for personal data processing

The website collects and processes Users' data on the basis of:

  • 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)
    • art. 6 sec. 1 lit. a
      the data subject has consented to the processing of his/her personal data for one or more specific purposes
    • art. 6 sec. 1 lit. b
      processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract
    • article 6 sec. 1 lit. f
      processing is necessary for the purposes of legitimate interests pursued by the administrator or by a third party
  • Act of 10 May 2018 on the protection of personal data (Journal of Laws of 2018, item 1000)
  • Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)
  • Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No. 24, item 83)

§12 Period of personal data processing

Personal data provided voluntarily by Users:

In principle, the indicated data personal data are stored only for the period of providing the Service as part of the Website by the Administrator. They are deleted or anonymized within 30 days from the end of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation that requires securing legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data from the time the User requests their removal, no longer than for a period of 3 years in the event of a violation or suspected violation of the provisions of the website regulations by the User

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, which are not personal data, are stored by the Administrator in order to keep website statistics for an indefinite period

§13 Users' rights related to the processing of personal data

The website collects and processes Users' data on the basis of:

  • Right to access personal data
    Users have the right to access their personal data upon request submitted to the Administrator
  • Right to rectify personal data
    Users have the right to request the Administrator to immediately ocular rectification of personal data that is incorrect or/ and supplementing incomplete personal data, carried out at the request submitted to the Administrator
  • Right to delete personal data
    Users have the right to request the Administrator to immediately delete personal data, performed at the request of the Administrator. In the case of user accounts, deletion of data consists in anonymizing data enabling User identification. The Administrator reserves the right to suspend the execution of the request to delete data in order to protect the Administrator's legitimate interest (e.g. when the User has violated the Regulations or the data was obtained as a result of correspondence).
    In the case of the Newsletter service, the User has the option of removing his personal data using the link placed in each sent e-mail.
  • Right to limit the processing of personal data
    Users have the right to limit the processing of personal data in the cases indicated in art. 18 GDPR, e.g. questioning the correctness of personal data, carried out at the request submitted to the Administrator
  • Right to transfer personal data
    Users have the right to obtain personal data from the Administrator concerning the User in a structured, commonly used machine-readable format, performed at the request submitted to the Administrator
  • Right to object to the processing of personal data
    Users have the right to object to the processing of their personal data in the cases specified in art. 21 of the GDPR, implemented at the request submitted to the Administrator
  • Right to lodge a complaint
    Users have the right to lodge a complaint to the supervisory body dealing with the protection of personal data .

§14 Contacting the Administrator

You can contact the Administrator by email

§15 Website Requirements

  • Restricting the storage and access to cookies on the User's Device may result in incorrect operation of some Website functions.
  • The administrator bears no responsibility for incorrectly functioning functions of the Website in the event that the User limits how The number of ways to save and read Cookie files.

§16 External links

On the Website - articles, posts, entries or comments of Users, there may be links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated under them may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content outside the Website.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to any change of this Privacy Policy without the need to inform the Users about the use and use of anonymous data or the use of Cookies.
  • Administrator reserves the right to change this Privacy Policy at any time regarding the processing of Personal Data, about which it will inform Users with user accounts or subscribed to the newsletter service via e-mail within 7 days of changing the records. Further use of the services means that you have read and accepted the changes to the Privacy Policy. In the event that the User does not agree with the changes made, he is obliged to delete his account from the Website or unsubscribe from the Newsletter service.
  • The changes made to the Privacy Policy will be published on this page. subpage of the Website.
  • Introduced changes come into force upon their publication.
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