FREECAP spółka z ograniczoną odpowiedzialnością
1.2. This Policy is adopted in accordance with:
(a) Article 5(3) of Directive 2002/58/EC (ePrivacy Directive);
(b) Regulation (EU) 2016/679 (General Data Protection Regulation – “GDPR”);
(c) the Polish Electronic Communications Law (Prawo komunikacji elektronicznej);
(d) applicable guidance issued by the European Data Protection Board (EDPB) and the President of the Polish Personal Data Protection Office (UODO).
2. DEFINITIONS
2.1. “Cookies” shall mean small text files stored on a user’s terminal device (computer, smartphone, tablet or other device) when accessing the Website, which enable storage of information or access to information already stored on such device.
2.2. To the extent Cookies involve the processing of personal data, such processing shall be carried out in accordance with the GDPR and the Company’s Privacy Policy.
3. CATEGORIES OF COOKIES
3.1. Strictly Necessary Cookies
3.1.1. These Cookies are essential for the proper functioning, security and stability of the Website.
3.1.2. The use of strictly necessary Cookies does not require prior consent pursuant to Article 5(3) of the ePrivacy Directive, as they are indispensable for the provision of a service explicitly requested by the user.
3.1.3. Such Cookies are stored for the duration of the session or for a limited period not exceeding 12 months, depending on technical necessity.
3.2. Analytics Cookies
3.2.1. The Website may use analytics tools, including Google Analytics 4 provided by Google Ireland Limited.
3.2.2. Analytics Cookies are used for statistical measurement, traffic analysis and improvement of Website performance.
3.2.3. Analytics Cookies are activated solely on the basis of prior, explicit consent, in accordance with Article 5(3) of the ePrivacy Directive and Article 6(1)(a) GDPR.
3.2.4. Data processed may include online identifiers (including truncated IP address), browser type, device data and interaction data.
3.2.5. The retention period for analytics data does not exceed 14 months, subject to configuration settings.
3.3. Marketing Cookies
3.3.1. Marketing Cookies may be set by advertising or targeting partners in order to display relevant advertising content and measure campaign effectiveness.
3.3.2. Such Cookies are activated exclusively upon prior consent.
3.3.3. The retention period is determined by the respective third-party provider and typically does not exceed 24 months.
3.4. Google Maps Cookies
3.4.1. The Website may use embedded Google Maps services for the purpose of displaying office locations.
3.4.2. Google Maps functionality is loaded only after the user has provided explicit consent to the use of non-essential Cookies.
3.4.3. The use of Google Maps may involve the processing of IP address and other technical identifiers and may result in international data transfers as described in Section 5 below.
4. CONSENT MECHANISM
4.1. Non-essential Cookies (including Analytics, Marketing and Google Maps Cookies) are not installed or activated prior to obtaining the user’s explicit consent.
4.2. Consent is obtained via a cookie management banner and is:
(a) freely given;
(b) specific;
(c) informed;
(d) unambiguous;
(e) capable of being withdrawn at any time.
4.3. The Company maintains records of granted consents, including consent ID and timestamp, for compliance and audit purposes.
4.4. Users may withdraw or modify their consent at any time through the “Cookie Settings” link available on the Website.
5. INTERNATIONAL DATA TRANSFERS
5.1. Where Cookies are provided by third-party service providers established outside the European Economic Area (EEA), personal data may be transferred outside the EEA.
5.2. Such transfers are carried out in compliance with Chapter V GDPR, including, where applicable:
(a) the EU–US Data Privacy Framework; and/or
(b) Standard Contractual Clauses adopted by the European Commission, together with supplementary safeguards.
6. MANAGEMENT OF COOKIES
6.1. Users may manage or delete Cookies via their browser settings.
6.2. Restricting strictly necessary Cookies may result in limited functionality of the Website.
7. FINAL PROVISIONS
7.1. This Policy may be amended to reflect changes in applicable law, regulatory guidance or technological developments.
7.2. The current version of the Policy is available on the Website at all times.
Version 17.02.2026