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Privacy Policy

The following Privacy Policy defines the rules for saving and accessing data on Users' Devices using the Service for the purpose 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 through tools available in the Service.

The following Privacy Policy is an integral part of the Terms of Service, which defines the rules, rights, and obligations of Users using the Service.


§1 Definitions

  • Service – the website "filamentpoint.com" operating at https://filamentpoint.com

  • External Service – websites of partners, service providers, or service recipients cooperating with the Administrator

  • Service / Data Administrator – the Administrator of the Service and Data (hereinafter: Administrator) is the company "GOTOMA SP. Z O.O", operating at: ul. Nawojowska 38a, 33-300 Nowy Sącz, with tax identification number (NIP): 7343589668, providing electronic services through the Service

  • User – a natural person for whom the Administrator provides electronic services through the Service

  • Device – an electronic device with software through which the User accesses the Service

  • 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, an 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 a set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collection, recording, organisation, 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 future processing

  • 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 analyse or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location, or movements

  • Consent – 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, unauthorised disclosure of, or access to, personal data transmitted, stored, or otherwise processed

  • Pseudonymisation – 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 organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person

  • Anonymisation – the irreversible process of operations on data that destroys/overwrites "personal data," preventing identification or linking a given record to a specific user or natural person


§2 Data Protection Officer

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

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


§3 Types of Cookies

  • Internal Cookies – files placed on and read from the User's Device by the Service's IT system

  • External Cookies – files placed on and read from the User's Device by IT systems of External Services. Scripts of External Services that may place Cookie files on the User's Devices have been deliberately included in the Service through scripts and services made available and installed in the Service

  • Session Cookies – files placed on and read from the User's Device by the Service during a single session of a given Device. Upon the end of the session, the files are deleted from the User's Device

  • Persistent Cookies – files placed on and read from the User's Device by the Service until they are manually deleted. Files are not automatically deleted upon the end of the Device session unless the User's Device configuration is set to delete Cookie files after the Device session ends


§4 Data Storage Security

  • Cookie Storage and Reading Mechanisms – The mechanisms for storing, reading, and exchanging data between Cookie files saved on the User's Device and the Service are carried out through built-in web browser mechanisms and do not allow the retrieval of other data from the User's Device or from other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojan horses, and other worms to the User's Device is also practically impossible.

  • Internal Cookies – Cookie files 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 steps to verify and select the Service's partners in the context of User security. The Administrator selects well-known, large partners with global social trust. However, the Administrator does not have full control over the content of Cookie files originating from external partners. The Administrator is not responsible, to the extent permitted by law, for the security of Cookie files, their content, and the lawful use by Scripts installed in the Service that originate from External Services. A list of partners is included further in the Privacy Policy.

  • Cookie Control

  • Risks on the User's Side – The Administrator applies all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that the security of this data depends on both parties, including the User's actions. The Administrator is not responsible for the interception of such data, impersonation of the User's session, or their deletion as a result of the User's conscious or unconscious activity, viruses, Trojan horses, and other spyware that may infect or have infected the User's Device. Users should follow the principles of internet use to protect themselves against these threats.

  • Personal Data Storage – The Administrator ensures that all efforts are made to keep personal data voluntarily entered by Users secure, with access restricted and carried out in accordance with their intended purpose and processing goals. The Administrator also ensures that all efforts are made to protect the held data against loss through the application of appropriate physical and organisational safeguards.

  • Password Storage – The Administrator states that passwords are stored in encrypted form, using the latest standards and guidelines in this regard. Decryption of passwords provided in the Service to access an account is practically impossible.


§5 Purposes for Which Cookies Are Used

  • Improving and facilitating access to the Service

  • Personalisation of the Service for Users

  • Enabling login to the Service

  • Marketing and remarketing in external services

  • Ad serving services

  • Affiliate services

  • Conducting statistics (users, number of visits, types of devices, connection speed, etc.)

  • Serving multimedia services

  • Providing social media services


§6 Purposes of Personal Data Processing

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

  • Provision of electronic services:

    • User account registration and maintenance services and related functionalities

    • Newsletter service (including sending promotional content with consent)

    • Comment/like posting services on the Service without the need to register

    • Services for sharing information about content published on the Service via social media or other websites

  • Communication between the Administrator and Users regarding Service-related matters and data protection

  • Ensuring the legitimate interest of the Administrator

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

  • Conducting statistics

  • Remarketing

  • Serving advertisements tailored to Users' preferences

  • Operating affiliate programmes

  • Ensuring the legitimate interest of the Administrator


§7 Cookies of External Services

The Administrator uses JavaScript scripts and web components from partners in the Service, who may place their own cookie files on the User's Device. Remember that in your browser settings, you can decide which cookies may be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:

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


§8 Types of Data Collected

The Service collects data about Users. Some data is collected automatically and anonymously, and some data consists of personal data voluntarily provided by Users when signing up for particular services offered by the Service.

Anonymous data collected automatically:

  • IP address

  • Browser type

  • Screen resolution

  • Approximate location

  • Subpages of the Service visited

  • Time spent on individual subpages

  • Type of operating system

  • Address of the previously visited subpage

  • Referring page address

  • Browser language

  • Internet connection speed

  • Internet service provider

Data collected during registration:

  • First name / surname / nickname

  • Login

  • Email address

  • Home address

  • Gender

  • Date of birth / age

  • Phone number

  • IP address (collected automatically)

  • Tax identification number (NIP)

Data collected when subscribing to the Newsletter service:

  • First name / surname / nickname

  • Email address

  • IP address (collected automatically)

Data collected when adding a comment:

  • First name and surname / nickname

  • Email address

  • Website address

  • IP address (collected automatically)

Some data (excluding identifying data) may be stored in cookie files. Some data (excluding identifying data) may be passed to a statistics service provider.


§9 Access to Personal Data by Third Parties

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

Access to data (most often on the basis of a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to operate the Service, i.e.:

  • Hosting companies providing hosting or related services for the Administrator

  • Companies through which the Newsletter service is provided

  • IT service and support companies performing maintenance or responsible for maintaining IT infrastructure

  • Companies acting as intermediaries in online payments for goods or services offered within the Service (in the case of purchase transactions made in the Service)

Entrustment of Personal Data Processing – Newsletter

To provide the Newsletter service, the Administrator uses the services of a third party – Mailerlite, GetResponse, GetAll. Data entered in the newsletter sign-up form is transferred to, stored, and processed in the external service of this provider.

Please note that the indicated partner may modify the stated privacy policy without the Administrator's consent.

Entrustment of Personal Data Processing – Hosting, VPS, or Dedicated Server Services

To operate the Service, the Administrator uses the services of an external hosting, VPS, or dedicated server provider – IQ PL Sp. z o.o. All data collected and processed in the Service is stored and processed in the service provider's infrastructure located within the borders of the European Union. There is a possibility of access to data as a result of maintenance work carried out by the service provider's personnel. Access to this data is governed by an agreement concluded between the Administrator and the Service Provider.

Entrustment of Personal Data Processing – Website Management Services

To manage the Service, the Administrator uses the services of an external service provider – GOTOMA SH SP. Z O.O. The personnel of the indicated entity have access to data entered by users during account registration and editing and/or data relating to the Newsletter service. Access to this data is governed by an agreement concluded between the Administrator and the Service Provider.

Processing of Data in the Case of Online Payments

In the case of online payments, all payment data is provided directly by the User to the entity processing the payment. Selected data necessary to complete the transaction is then transferred by this entity to the Administrator. The transfer of data is governed by an agreement concluded between the Administrator and the Service Provider.


§10 Method of Personal Data Processing

Personal data voluntarily provided by Users:

  • Personal data will not be transferred outside the European Union, unless it has been published as a result of an individual User's action (e.g., posting a comment or entry), which will make the data available to any person visiting the Service.

  • 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) will not be used for automated decision-making (profiling).

  • Anonymous data (without personal data) will not be resold to third parties.


The Service 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 natural persons with regard to the processing of personal data and on the free movement of such data (GDPR):

    • 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 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 Administrator or by a third party

  • Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 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 Personal Data Retention Period

Personal data voluntarily provided by Users:

As a rule, the indicated personal data is stored only for the duration of the provision of the Service by the Administrator. It is deleted or anonymised within 30 days from the end of service provision (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.).

An exception is a situation that requires securing the legally justified purposes of further processing of such data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User's request for its deletion, for no longer than 3 years in the case of a breach or suspected breach of the Service's Terms of Service by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, is stored by the Administrator for the purpose of conducting Service statistics for an indefinite period of time.


§13 Users' Rights Regarding Personal Data Processing

  • Right of access to personal data – Users have the right to obtain access to their personal data, exercised upon a request submitted to the Administrator.

  • Right to rectification of personal data – Users have the right to request the Administrator to immediately rectify personal data that is inaccurate and/or to complete incomplete personal data, exercised upon a request submitted to the Administrator.

  • Right to erasure of personal data – Users have the right to request the Administrator to immediately erase personal data, exercised upon a request submitted to the Administrator. In the case of user accounts, the erasure of data involves the anonymisation of data enabling the identification of the User. The Administrator reserves the right to suspend the fulfilment of a data erasure request in order to protect the Administrator's legitimate interest (e.g., where the User has violated the Terms of Service or where data was obtained as a result of correspondence). In the case of the Newsletter service, the User can independently delete their personal data using the link included in every email message sent.

  • Right to restriction of personal data processing – Users have the right to restriction of processing of personal data in cases indicated in Art. 18 of the GDPR, including questioning the accuracy of personal data, exercised upon a request submitted to the Administrator.

  • Right to data portability – Users have the right to receive from the Administrator the personal data concerning the User in a structured, commonly used, machine-readable format, exercised upon a request submitted to the Administrator.

  • Right to object to personal data processing – Users have the right to object to the processing of their personal data in cases specified in Art. 21 of the GDPR, exercised upon a request submitted to the Administrator.

  • Right to lodge a complaint – Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.


§14 Contact with the Administrator

You can contact the Administrator in one of the following ways:

  • Postal address – GOTOMA SP. Z O.O, ul. Nawojowska 38a, 33-300 Nowy Sącz

  • Email addresssklep@filamentpoint.com

  • Contact form – available at: /contact


§15 Service Requirements

  • Restricting the saving of and access to Cookie files on the User's Device may cause some functions of the Service to malfunction.

  • The Administrator bears no responsibility for improperly functioning Service features if the User restricts in any way the ability to save and read Cookie files.


The Service – in articles, posts, entries, or User comments – may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files they point to may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for content located outside the Service.


§17 Changes to the Privacy Policy

  • The Administrator reserves the right to make any changes to this Privacy Policy without notifying Users regarding the application and use of anonymous data or the use of Cookie files.

  • The Administrator reserves the right to make any changes to this Privacy Policy with regard to the processing of Personal Data, of which Users who have user accounts or are subscribed to the Newsletter service will be informed via email within 7 days of the change. Continued use of the services constitutes acknowledgement and acceptance of the introduced changes to the Privacy Policy. If a User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.

  • Introduced changes to the Privacy Policy will be published on this subpage of the Service.

  • Introduced changes take effect upon their publication.