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Privacy Policy

This Privacy Policy outlines the rules for storing and accessing data on the Users’ Devices using the Website for the purposes of providing electronic services by the Administrator, as well as the rules for collecting and processing personal data of Users, which have been provided by them personally and voluntarily via tools available on the Website.

This Privacy Policy is an integral part of the Website’s Terms of Service, which defines the rules, rights, and obligations of Users using the Website.

§1 Definitions

  • Website – the “Prometheusmedtech AI” website operating at https://www.prometheusmedtech.ai/
  • External Website – websites of partners, service providers, or recipients cooperating with the Administrator
  • Website/Data Administrator – The Website Administrator and Data Administrator (hereinafter Administrator) is the company “LPTW sp. z o.o.”, operating at the address: ul. Nowogrodzka 64/43 02-014 Warsaw, with the assigned tax identification number (NIP): 7010995896, providing services electronically via the Website
  • User – a natural person for whom the Administrator provides electronic services via the Website.
  • Device – an electronic device along with software, through which the User gains access to the Website
  • Cookies – text data collected in the form of files placed on the User’s Device
  • GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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 (General Data Protection Regulation)
  • Personal Data – means information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, an online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person
  • Processing – means an operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
  • Restriction of processing – means the marking of stored personal data with the aim of limiting their processing in the future
  • Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements
  • Consent – consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
  • Personal data breach – means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed
  • Pseudonymization – means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
  • Anonymization – Data anonymization is an irreversible process of data operations that destroys/overwrites “personal data” to prevent identification or association of a given record with a specific user or individual.

§2 Data Protection Officer

Based on Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

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

§3 Types of Cookies

  • 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 Websites. Scripts from External Websites that may place Cookies on the User’s Devices have been deliberately placed on the Website through scripts and services provided and installed on the Website
  • Session Cookies – files placed and read from the User’s Device by the Website during a single session of that Device. After the session ends, the files are deleted from the User’s Device.
  • Persistent Cookies – files placed and read from the User’s Device by the Website until they are manually deleted. The files are not automatically deleted after the Device session ends unless the User’s Device settings are set to delete Cookies after the Device session ends.

§4 Data Storage Security

  • Mechanisms for storing and reading Cookies – Mechanisms for storing, reading, and exchanging data between Cookies stored on the User’s Device and the Website are implemented through built-in web browser mechanisms and do not allow for the retrieval of other data from the User’s Device or other websites visited by the User, including personal or confidential information. Transferring viruses, trojans, 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 could 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 the Website partners regarding User safety. The Administrator collaborates with known, large partners with global social trust. However, the Administrator does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the safety, content, and lawful use of these Cookies by scripts installed on the Website from External Websites to the extent permitted by law. The list of partners is included in a later section of the Privacy Policy. Control of Cookies
  • The User can independently change the settings for saving, deleting, and accessing data saved in Cookies by any website at any time.
  • Information on how to disable Cookies in the most popular computer browsers is available on the website: how to disable cookies or from one of the indicated providers:
    • Managing cookies in Chrome
    • Managing cookies in Opera
    • Managing cookies in Firefox
    • Managing cookies in Edge
    • Managing cookies in Safari
    • Managing cookies in Internet Explorer 11
  • The User can delete all stored Cookies using the tools of the User’s Device through which the User uses the Website’s services at any time. User Threats – The Administrator uses all possible technical measures to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of these data depends on both parties, including the User’s activity. The Administrator is not responsible for data interception, session impersonation, or deletion due to the User’s conscious or unconscious activity, viruses, trojans, and other spyware that may infect the User’s Device. Users should follow safe internet usage principles to protect themselves against these threats. Personal data storage – The Administrator ensures that it makes every effort to ensure that personal data voluntarily provided by Users are secure, access to them is limited, and carried out following their purpose and processing objectives. The Administrator also ensures that it makes every effort to secure the possessed data against loss by using appropriate physical and organizational security measures.

§5 Purposes for Using Cookies

  • Improving and facilitating access to the Website
  • Personalizing the Website for Users
  • Marketing, remarketing in external websites
  • Affiliate services
  • Statistics (users, number of visits, types of devices, connections, etc.)
  • Serving multimedia services
  • Providing social services

§6 Purposes for Processing Personal Data

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

  • Provision of electronic services:
    • Communication between the Administrator and Users regarding the Website and data protection
    • Ensuring the Administrator’s legitimate interests

Anonymous and automatically collected User data are processed for one of the following purposes:

  • Conducting statistics
  • Remarketing
  • Supporting affiliate programs
  • Ensuring the Administrator’s legitimate interests

§7 External Website Cookies

The Administrator uses JavaScript scripts and web components from partners in the Website, who may place their own Cookies on the User’s Device. Remember that you can decide which cookies are allowed for use by individual websites in your browser settings. Below is a list of partners or their services implemented in the Website that may place Cookies:

  • Multimedia services:
    • YouTube
  • Social/combined services:
    • (Registration, login, content sharing, communication, etc.)
    • Facebook
    • LinkedIn
  • Statistics:
    • Google Analytics

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

§8 Types of Data Collected

The Website collects data about Users. Some of the data is collected automatically and anonymously, while some are personal data voluntarily provided by Users when registering for services offered by the Website.

  • Anonymous data collected automatically:
    • IP address
    • Browser type
    • Screen resolution
    • Approximate location
    • Opened subpages of the website
    • Time spent on each subpage
    • Type of operating system
    • Address of the previous subpage
    • Referrer URL
    • Browser language
    • Internet connection speed
    • Internet service provider
  • Data collected during registration:
    • Email address
    • IP address (collected automatically)
  • Data collected when subscribing to the Newsletter:
    • Email address

Some data (excluding identifying data) may be stored in Cookies. Some data (excluding identifying data) may be transferred to the provider of statistical services.

§9 Access to Personal Data by Third Parties

As a general 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.

Entities responsible for maintaining the infrastructure and services necessary to run the website, such as:

  • Hosting companies providing hosting services or related services for the Administrator
  • may have access to the data (usually based on a Data Processing Agreement).

Entrustment of personal data processing – Hosting, VPS, or Dedicated Server services

The Administrator, for running the website, uses the services of an external hosting provider, VPS, or Dedicated Servers – OVH sp. z o.o. All data collected and processed on the website are stored and processed in the service provider’s infrastructure located in Poland. Access to data due to service works carried out by the service provider’s personnel is possible. Access to these data is regulated by an agreement between the Administrator and the Service Provider.

§10 Method of Processing Personal Data

  • Personal data voluntarily provided by Users:
    • Personal data will not be transferred outside the European Union unless published as a result of the User’s individual action (e.g., entering a comment or post), making the data available to any person visiting the website.
    • Personal data will not be used for automated decision-making (profiling).
    • Personal data will not be resold to third parties.
  • Anonymous data (without personal data) collected automatically:
    • Anonymous data (without personal data) will be transferred outside the European Union.
    • Anonymous data (without personal data) may be used for automated decision-making (profiling).
    • Profiling of anonymous data (without personal data) does not have legal effects or similarly significantly affect the person whose data are subject to automated decision-making.
    • Anonymous data (without personal data) will not be resold to third parties.

§11 Legal Basis for Processing Personal Data

The Website collects and processes User data based on:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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 (General Data Protection Regulation)
    • Art. 6(1)(a) – the data subject has given consent to the processing of their personal data for one or more specific purposes
    • Art. 6(1)(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
    • Art. 6(1)(f) – processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
  • The Act of May 10, 2018, on the protection of personal data (Dz.U. 2018 poz. 1000)
  • The Act of July 16, 2004, Telecommunications Law (Dz.U. 2004 nr 171 poz. 1800)
  • The Act of February 4, 1994, on Copyright and Related Rights (Dz. U. 1994 Nr 24 poz. 83)

§12 Duration of Processing Personal Data

  • Personal data voluntarily provided by Users:
    • As a general rule, the indicated personal data are stored only for the period of providing the Service within the Website by the Administrator. They are deleted or anonymized within up to 30 days from the termination of service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.).
    • An exception is a situation that requires the protection of legally justified purposes for further processing of these data by the Administrator. In such a case, the Administrator will store the indicated data from the time of the User’s request for deletion, no longer than for 3 years in case of violation or suspicion of violation of the website’s terms of service by the User.
  • Anonymous data (without personal data) collected automatically:
    • Anonymous statistical data that do not constitute personal data are stored by the Administrator for an indefinite period to conduct website statistics.

§13 Users’ Rights Related to Processing Personal Data

The Website collects and processes User data based on:

  • Right to access personal data – Users have the right to access their personal data, fulfilled on a request submitted to the Administrator
  • Right to rectify personal data – Users have the right to request the Administrator to promptly rectify their personal data that is incorrect or/and to complete incomplete personal data, fulfilled on a request submitted to the Administrator
  • Right to delete personal data – Users have the right to request the Administrator to promptly delete their personal data, fulfilled on a request submitted to the Administrator. In the case of user accounts, deleting data involves anonymizing data that enables the User’s identification. The Administrator reserves the right to delay fulfilling the request to delete data to protect the legally justified interest of the Administrator (e.g., when the User violated the Terms of Service or the data was obtained as a result of correspondence).
    • In the case of the Newsletter service, the User can delete their personal data using the link included in each sent email.
  • Right to restrict the processing of personal data – Users have the right to restrict the processing of personal data in cases indicated in Art. 18 GDPR, including questioning the correctness of personal data, fulfilled on a request submitted to the Administrator
  • Right to data portability – Users have the right to obtain from the Administrator, personal data concerning the User in a structured, commonly used, and machine-readable format, fulfilled on a 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 cases specified in Art. 21 GDPR, fulfilled on a request submitted to the Administrator
  • Right to lodge a complaint – Users have the right to lodge a complaint with a supervisory authority responsible for the protection of personal data.

§14 Contact with the Administrator

The Administrator can be contacted in one of the following ways:

  • Postal address – LPTW sp. z o.o., ul. Nowogrodzka 64/43 02-014 Warsaw
  • Email address – w.strzelczyk@lptw.pl
  • Phone call – +48 601 360 035
  • Contact form – available at: /contact

§15 Website Requirements

  • Limiting the storage and access to Cookies on the User’s Device may cause some Website functions to malfunction.
  • The Administrator is not responsible for improperly functioning Website features if the User restricts the ability to save and read Cookies in any way.

§16 External Links

The Website may contain links to external websites, with which the Website Owner does not cooperate, in articles, posts, entries, or comments by Users. These links and the pages or files they point to may be unsafe for your Device or pose a threat to your data security. The Administrator is not responsible for the content found outside the Website.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to change this Privacy Policy at any time without informing the Users in the scope of using and processing anonymous data or using Cookies.
  • The Administrator reserves the right to change this Privacy Policy regarding the processing of Personal Data, of which Users with user accounts or subscribed to the newsletter will be informed via email within 7 days of the changes being made. Continued use of the services implies familiarization and acceptance of the introduced changes to the Privacy Policy. If the User disagrees with the introduced changes, they are obliged to delete their account from the Website or unsubscribe from the Newsletter.
  • The changes made to the Privacy Policy will be published on this subpage of the Website.
  • The changes made take effect upon publication.
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