Privacy Policy


This Privacy Policy (hereinafter referred to as the “Privacy Policy”) sets out the terms and conditions of processing and protecting the personal data of users of the Closer website which is available at (hereinafter referred to as the “Website”) and provides information about the terms and conditions of the use of cookies.

Capitalized terms that are not defined otherwise in the Privacy Policy shall have the meaning ascribed to them in the Regulations, which sets out the terms of Website use.

If you do not accept this Privacy Policy, you are not allowed to use the Website.

The data controller with respect to the personal data of the Website users is Ratel sp. z o.o. with its seat at ul. 3 maja 9, 30-062 Kraków, Poland, European Union entered in the register of business entities kept by the District Court for the Capital City of Kraków, XI Division of the National Court Registry under number 0000579921, with the share capital amounting to PLN 12.000, NIP [tax identification number] 6762494630, owner of the Website, that provides services through the Website without the simultaneous presence of the parties, by means of a telecommunications network, hereinafter referred to as the “Data Controller”.

Scope of data collection

  1. The Data Controller collects the data of individuals who use the services of the Website, in particular registered Website Users with individual Accounts.
  2. In order to create an Account, you should provide data which enables the performance of the Agreement in accordance with the Regulations, including your contact data, in particular your e-mail address, name and surname, position, and your business phone number, or company data, if any.
  3. If you post the personal data of other persons on the Website, you can do so only on the condition that it does not infringe on the law or the moral rights of such persons.

Purpose of data collection

  1. The Data Controller shall use any and all data provided by you in the Registration Form available from the Website page only to conclude and draft the content of the Agreement for the Provision of Services by Electronic Means which concerns the provision to you of the Services referred to in the Regulations, including the creation of Accounts and provision of Services. This does not preclude the possibility of processing personal data that has been provided, in particular the e-mail address and phone number to ensure contact between you and the Data Controller.
  2. In the event that the relevant consent was given at the time of completion of the Registration Form or in the event the relevant option was selected in the Account settings, the e-mail address provided by you will be processed by the Administrator for the purposes of sending you a free newsletter which will contain commercial information as understood by the Act on the Provision of Services by Electronic Means. You are entitled to withdraw the consent referred to herein if you do not wish to receive such a newsletter.
  3. All transaction data (including personal data) entered by the user during the process of payment is processed by Adyen NV – operator of credit card payments.

Right of access

  1. You are entitled to have access to your personal data and to correct it .
  2. In the event personal data is  processed on the basis of Article 23.1.4 or Article 23.1.5 of the Act on Personal Data Protection, the individual whom such data concerns is entitled to submit in writing a reasonable demand that the processing of such individual’s personal data be stopped due to his or her special situation.
  3. In the event that the personal data is  processed on the basis of Article 23.1.4 or Article 23.1.5 of the Act on Personal Data Protection, the individual whom such data concerns is entitled to object to his or her data being processed, if the Data Controller intends to process it for marketing purposes or for the provision of his/her personal data to another data controller.
  4. You can introduce any changes to your personal data by sending a relevant declaration of will to the e-mail address of the Data Controller, that is, and in the event that such declaration requires a written form, to the postal address of the Data Controller, that is Ratel sp. z o.o., ul. 3 maja 9, 30-062 Kraków.
  5. The Data Controller reserves the right to refuse to remove your data if it is entitled to keep such data based on the applicable regulations.

Data is provided voluntarily

The provision of data is voluntary but necessary for the purposes of conclusion and performance of the Agreement and in order to use the Services.


  1. The Website uses Cookies.
  2. Cookies are small information files (data), especially text files, saved and stored on the devices through which you use the Website pages that allow, in particular, to
    1. maintain sessions (after logging in), so that you do not have to re-enter your Login and Password on every page of the Website
    2. adjust and optimize the Website to meet the needs of Website users
    3. create statistics of Website viewing figures
    4. personalize marketing messages
    5. ensure the safety and reliability of Website operations.
  3. Cookies are stored by the server on your computer.
  4. The Website uses session cookies that are deleted after the browser window is closed and persistent cookies that are saved for a specified time on the devices through which you use the Website.
  5. Your limitation of cookie use may impede or prevent the use of certain functionalities of the Website.
  6. You can change the settings for cookies by determining the terms on which cookies are stored and access the device through which you use the Website. Changes in such settings may be introduced in the browser settings. Such settings can be changed, among others, in such a way as to block the automatic handling of cookies or notify you each time a cookie is placed on the device through which you use the Website. Detailed information about options and ways of handling cookies are available in the browser tools.
  7. Cookies are not used to collect personal data. Cookies can be removed by means of the tools in the browser.
  8. Cookies do not use the configuration of your computer, are not used to install or uninstall any software, and do not disturb the integrity of the system or your data.
  9. Cookies of the Service Provider are not processed by other websites.

Third-party cookies

  1. The Data Controller reserves the right to use the services of the third parties in the scope of development of the statistics concerning Website use. We ensure that in such a case no data that  identifies our Users will be provided to such entities.
  2. The advertisements posted on the Website pages may use third-party cookies so that the advertiser is able to analyze the effectiveness of the advertising campaign. This Privacy Policy does not stipulate the rules of cookie mechanism use by third parties.

IP address

The Data Controller reserves the right to collect Users’ IP addresses that may prove helpful when it comes to diagnosing technical problems with the server or developing statistical analyses (e.g. specifying which regions visit us most often). Furthermore, they can also be useful for the purposes of administering and improving the Website.

Access to third-party data

  1. Authorized employees or associates of the Data Controller and entitled individuals that maintain the Website who have been granted special authorization are the only persons who have direct access to the personal data collected by the Data Controller.
  2. Your personal data may be made available to the entities authorized to receive it based on the applicable legal regulations and in particular to the competent law enforcement authorities.

Means of security and personal data protection

The Data Controller represents that it processes personal data in accordance with the Act on Personal Data Protection and applies technical and organizational measures to ensure the protection of the processed data corresponding to the risks and categories of data being protected, and in particular that it protects personal data against unauthorized access, loss, or damage.


Any additional questions concerning the Privacy Policy should be sent to the e-mail address of the Data Controller, that is

Amendments to the Privacy Policy

The Data Controller reserves the right to amend the Privacy Policy. The date provided below is the date of the latest version of the Privacy Policy.