1. Statement
2. Terms used in the Policy
3. Personal details
4. Use of the data
4.1 Execution of a service of the User
4.2 Marketing and PR purposes
4.3 Recruitment
4.4 Partners 
4.5 Clients
4.6 Website Press Office
4.7 Electronic advertisements 
5. System logs
6. Cookies and other similar technologies
7. Modification of personal details
8. Disclosure required by law
9. Data protection
10. Links to other websites of other companies / organisations
11. Notice of changes
12. Questions related to privacy protection

1. Statement

The rule in Comarch S.A. and in other companies in the Comarch Capital Group (in the meaning of Article 3 Para 1 Clause 44 of the Accounting Act of 29 September 1994, hereinafter referred to as the “Comarch Capital Group” is to observe the applicable legal regulations concerning the privacy and protection of personal details. The Comarch Capital Group operates in respect of the right of each person to protect his / her privacy. The Comarch Capital Group declares that it shall make all efforts to ensure the appropriate security of the details for each User of Comarch Capital Group websites, and undertakes to execute activities preventing interference of third persons in the privacy of the Users. This Privacy Policy explains and regulates the issues related to storing, processing and using the details of the Users who make use of the Comarch Capital Group websites. The following Policy applies to all the websites managed by or on behalf of Comarch Capital Group and its units all over the world. If the User does not express consent for storing, using and disclosing his/her personal details in the way indicated in this Policy (and in all the relevant documents concerning privacy which apply at the domestic level or at the level of a specific website), he/she is requested to refrain from using Comarch Capital Group websites.

The Comarch Capital Group as the owner of this Privacy Policy reserves the right to change it in entirety or in part. The new wording of the Policy applies from the time of its publication in the Comarch Capital Group corporate website. The consent granted by the User in accordance with the contents of this document shall constitute consent granted to Comarch S.A. and other companies included in the Comarch Capital Group. The administrator for the stored data is the company of Comarch S.A. with an office in Krakow, Al. Jana Pawła II 39A, registered in the National Court Register managed by the District Court for Krakow Śródmieście in Krakow, the XI Department for Commercial Issues of the National Court Register, under KRS 0000057567, with the initial capital of the Company in the amount of PLN 7,960,596.00 (the initial capital paid in entirety), NIP 677-00-65-406, hereinafter referred to for the needs of this Privacy Policy the Data Administrator.

2. Terms used in the Policy

User – any person visiting Comarch Capital Group websites, who becomes acquainted with the information included in them and/or using the forms and questionnaires available in these websites. Policy – the  Comarch Capital Group Privacy Policy. Comarch Capital Group websites – any websites managed by or on behalf of the Comarch Capital Group and its units all over the world. Trade information – any information intended directly or indirectly for promoting goods, services or the image of the Comarch Capital Group. Data integrity – the name for the situation in which data maintains its proper form during operations such as reading, saving, transmission or storage.

3. Personal details

Please be advised that the User may enter Comarch Capital Group websites in order to become acquainted with information about the organisation, its programs and services and to listen to or view specific messages without the necessity of providing his/her personal details. Irrespective of the above, there may be circumstances when personal details of a User are necessary for execution of the required service or process. In such cases, the User shall be informed about the necessity of making the data available and about the method of using this data, thus being able to make a decision on providing his/her data or refusing them. Making personal details available may be required in a situation in which the User is interested in ordering the execution of a specific service with an entity owned by  the Comarch Capital Group (e.g. preparation of an offer, sending information about a product, downloading a product demo) or in the situation in which he is interested in participation in a process or event (e.g. recruitment, participation in a conference). The User may then be asked to fill in and send the form/questionnaire in which he/she shall be clearly informed about what type of personal details will be stored.

In a situation in which the User discloses in the form/questionnaire personal details of a third person (e.g. a colleague),  Comarch Capital Group shall deem the User to have the appropriate permission from the person whose data he/she has disclosed.

The data made available by the user in the above method are used only by the Comarch Capital Group and solely for the execution of the service ordered by the User, conducting the process or organisation of participation in the event.

4. Use of the data

4.1 Execution of a service of the User

When informing the Comarch Capital Group via its websites about a willingness to become acquainted with trade information, in particular with an offer of products, reception of marketing and PR materials, publications, newsletters, as well as collection of electrical and electronic equipment used, the User thus consents to direct contact with him/her or with a third person indicated by him/her.

The Comarch Capital Group is entitled to make personal details available to entities whose involvement in the execution of the service is absolutely necessary (e.g. partners, an organisation involved in the recovery of electrical and electronic equipment, financial, mail, government institutions, transport companies). Such entities are obliged to use the personal details made available to them only for the provision of services on behalf of  the Comarch Capital Group and to regard the personal details of the User as strictly confidential. The data provided by the User may also be used for maintaining or developing business relationships, as well as for ensuring the optimum provision of services. The Comarch Capital Group may contact the User in order to conduct satisfaction or market research.

4.2 Marketing and PR purposes

Personal details and information are made available by the User through Comarch Capital Group websites, as well as during participation in a conference, presentation or any other form of a so-called event, and may be used by the Comarch Capital Group for marketing and PR purposes. This data may also be made available to selected third persons with which the Comarch Capital Group cooperates in the delivery of products and services to its clients, and with which it cooperates in the scope of marketing. Personal details shall be used in the above way only when the User expresses consent for such action. The consent of the user shall be understood as consent for receiving trade information.

4.3 Recruitment

The Comarch Capital Group manages recruitment of new employees and trainees through its corporate websites.  The Comarch Capital Group shall use the personal details obtained in this way only for the needs of its own recruitment.  The Comarch Capital Group reserves the right to use this data also after completion of the recruitment process in the scope indicated above.

By filling out the recruitment form, the user expresses consent for the processing of his/her personal details by the Comarch Capital Group in order to undertake actions necessary for execution of the recruitment processes as well as after completion of the recruitment process in the scope indicated above. This consent also includes additional documents enclosed by the User (resume, letter of application, references, etc.).

4.4 Partners

The Comarch Capital Group will make available to its Partners the websites dedicated for them along with the information necessary for cooperation with the Comarch Capital Group. Access to these websites requires registration and successful User login with each visit.

The personal details and information provided through such services may be used by  the Comarch Capital Group for managing business relationships within the entire Comarch Capital Group with the User, with a Partner represented by the User, as well as with all Partners, and for developing such relationships. Such activities may be expressed, in particular, in transmitting trade information, product information, marketing information or information on partnership programs. The Comarch Capital Group reserves the right to make personal details and information available to its Partners or suppliers in order to perform any service or process, if no additional obligations have been reserved in the scope of confidentiality of the data made available.

4.5 Clients

The Comarch Capital Group will make available to its Clients the websites dedicated for them which constitute the database of knowledge regarding systems the Clients use. Access to these websites requires registration and successful User login with each visit.

The information provided with such websites may be used by the Comarch Capital Group for managing business relationships within the entire Comarch Capital Group with the User, with a Client represented by the User and with all the Clients and to develop such relationships. Such activities may be expressed, in particular, in transmitting trade information, product information, marketing information and offers.

The Comarch Capital Group reserves the right to make personal details and information available to its Partners or suppliers in order to perform any service or process, if no additional obligations have been reserved in the scope of confidentiality of the data made available.

4.6 Website Press Office

The Website Press Office (PL abbr.: IBP) is a communication platform between the Comarch Capital Group and the media. IBP provides information on the company’s functioning, multimedia materials, and provides the possibility of subscribing to a weekly information newsletter and magazines published by Comarch S.A. This platform is also used for submitting questions.

When using IBP, Users may be asked to state their personal details in order to enable provision of the service related to ordering/receiving newsletters, magazines and press information, and the inquiry sent to the company through a contact form. The Users provide the Comarch Capital Group with their personal details by way of filling in the form. This data in most cases includes: first name, surname, email address. In case of order forms, Users will be asked to state their complete personal details. The mandatory fields are marked.

The Comarch Capital Group requires provision of only the data which is necessary for operation of the IBP website. If the User does not provide the required data, he/she will thus block the activity to which this data were related.

4.7 Electronic advertisements 

The Comarch Capital Group makes use of services of external entities which participate in providing interactive electronic advertising services (for example advertising banners). These entities are authorised to collect and use information about Clients only in order to support the Comarch Capital Group in its optimum provision of services as well as in determining what offers, promotions and types of advertising are best received by the Clients of the Comarch Capital Group. Information collected in this way is aggregated, and thus it cannot be used to identify a single User.

5. System logs

Each visit of a User visiting Comarch Capital Group websites is automatically registered in the server in the so-called system logs. Data saved in this way includes, among other things, date, time of the visit and the IP address. Data from the system logs are used only for purposes of server administration and for managing statistics of website visits.

6. Cookies and other similar technologies

Comarch Capital Group websites utilizes so-called cookies, or information saved by the servers on User devices. This information can be collected every time the device is connected to the server. Comarch Capital Group may use other similar technologies. Under our Privacy Policy, information about cookies can also refer to other similar technologies used within Comarch Capital Group websites. Cookies usually contains the name of the server it was sent from, the time of storing them on Users devices and a unique number. Cookies may be saved on the Users device, and then be used by external suppliers of tools for monitoring traffic and activity on the website, who cooperate with Comarch Capital Group.

Cookies are used by the majority of highly developed websites to help Users navigate their websites efficiently and perform certain functions, including:

  • creating individual content viewing statistics,
  • personalization of services provided within a website,
  • maintaining user session,
  • authentication of people using the service,
  • providing users with personalized advertising content.

Comarch Capital Group sites use the following types of cookies:

  • Essential Cookies, which use is essential for the running of our website services, for example to allow the use of sessions,
  • Functional Cookies, used to remember Users preferences on our websites. This can be anything from remembering Users mobile/classic view, last phrases typed by the User or Users preference on our website,
  • Analytical Performance Cookies, used to monitor the performance of our websites and how Users use it.

Cookies are not used for processing or storing personal details, they cannot be used for direct identification of a User, they do not change Users browser options or device configuration.

The User can independently determine and modify browser settings so that they will not accept cookies. If this option is selected many websites may not function properly or at all. It may be possible to set your browser to not accept cookies and ask for Users consent before each cookie used. This gives the User control over what is set on their device, however this has the drawback of slowing down the user’s browsing experience.

In order to manage your cookies, please select your browser from the list below and follow the instructions:

  • Internet Explorer,
  • Firefox,
  • Chrome,
  • Opera,
  • Safari.


    Mobile devices:.
  • Android,
  • Windows Phone,
  • Blackberry,
  • Safari.

No change in cookies configuration means they will be set by the User’s devices, therefore Comarch Capital Group will keep information regarding User devices and gain access to this information.

7. Modification of personal details

A User is entitled to become acquainted with his/her details stored by the Comarch Capital Group and, if there is such a necessity, to correct and supplement all incorrect or incomplete personal details. Moreover, the User is entitled at any time to demand the removal of his/her personal details from the Comarch Capital Group database. For this purpose, an electronic message can be sent to the addresses: unsubscribe@comarch.pl or unsubsribe@comarch.com with a request for modification or removal of personal details.

8. Disclosure required by law

Under specific, limited circumstances, the Comarch Capital Group may make available or provide personal details to third parties not related to the Comarch Capital Group. In particular, the Comarch Capital Group may provide personal details to a third party:

  • upon request of a User
  • for adjustment to legal requirements or court orders
  • for verification of the possibility of perpetration of an offence constituting identity theft
  • in reference to a sale, purchase, merger, reorganisation, liquidation or dissolution of Comarch S.A. or any unit of the Comarch Capital Group
  • under other similar circumstances.

9. Data protection

The Comarch Capital Group implements the appropriate measures for protection of the confidentiality of personal details and maintaining their integrity. In order to protect the data during their transmission, Comarch Capital Group uses encoded connections.

10. Links to other websites of other companies/organisations

Comarch Capital Group websites may include links to websites of other companies or organisations. The Comarch Capital Group shall not be responsible for procedures and mechanisms used in these companies/organisations as regards the protection of privacy and for the contents of other websites.

11. Notice of changes

Any significant change to this Policy will be published in on the Comarch Capital Group website for 30 consecutive days in the form of a notice.

12. Questions related to privacy protection

Questions should be sent to: privacy@comarch.pl, privacy@comarch.com

2013.03.28