Cookies Policy – Sellhorn Polska Sp. z o.o.

Cookies Policy – Sellhorn Polska Sp. z o.o.

§ 1. Introduction

  1. This Cookies Policy sets out the rules for the use of cookies and similar technologies on the website operated by Sellhorn Polska Sp. z o.o., based in Szczecin. The document explains what cookies are, the purposes for which they are used, the types of cookies that may be employed on the Website, and how Users can manage their cookie settings.
  2. The purpose of this Policy is to ensure transparency regarding the use of cookies and to inform Users about how these technologies operate, as well as their impact on privacy.
  3. Cookies and similar technologies may be used by the Controller to ensure the proper functioning of the Website, tailor its features to the needs of Users, conduct statistical analyses, and support external services used on the Website.
  4. The Controller of the Website and the entity managing the cookies is:

Sellhorn Polska Sp. z o.o.
 ul. Szeroka 56B, 71-211 Szczecin
 NIP: 852 270 93 74
 REGON: 529139530
Privacy Contact Information: info@sellhorn.pl

  1. The detailed rules for processing personal data, including information about the Controller, User rights, and security measures, are set out in a separate Privacy Policy available on the Website.

§ 2. Entity using cookies (Controller)

  1. The entity responsible for the use of cookies on the Website and for processing the data related to their use is:


Sellhorn Polska Spółka z ograniczoną odpowiedzialnością
 ul. Szeroka 56B, 71-211 Szczecin
 NIP: 852 270 93 74
 REGON: 529139530
Contact address for privacy matters: info@sellhorn.pl

  1. The Controller uses on the Website only those cookies and technologies that are necessary for its proper functioning or whose use is based on the User’s voluntary consent given via the cookies banner or the consent management panel (CMP).
  2. The Website may also use cookies and technologies provided by external service providers, in particular:
    • Google Ireland Ltd. (e.g. Google Analytics, Google Tag Manager, Google Ads),
    • Microsoft (e.g. Microsoft Clarity),
    • Meta Platforms Ireland Ltd. (e.g. Meta Pixel),
    • LinkedIn Ireland Unlimited Company (Insight Tag),
    • dostawcy multimediów i osadzonych treści (e.g. YouTube, Vimeo),
    • providers of maps and interactive components (e.g. Google Maps).

The use of cookies from external providers depends on the functionalities implemented on the Website and on the consents given by the User.

  1. Information about specific tools, their functions, and how they operate can be found in Section 5 of this Cookies Policy.

§ 3. What are cookies?

  1. Cookies (also known as “small text files”) are small text files stored on the User’s device while using the Website. Cookies typically contain basic information about the device and the User’s settings, which enable the proper functioning of the Website, customization of displayed content, statistical analysis, and support for certain functionalities.
  2. Cookies can be read both by the Website and by third parties whose services the Controller uses (e.g., providers of analytical or multimedia tools).
  3. In addition to standard cookies, the Website may also use similar technologies that allow storing or reading information from the User’s device, in particular:
    1. Local storage – a mechanism for storing data in the web browser that retains information even after the browser window is closed;
    2. Session storage – a mechanism for storing data only for the duration of the browser session; the data is deleted when the session ends;
    3. Web Beacons / Pixel Tags – invisible graphic elements (tracking pixels) used to monitor User behavior, such as page visits or campaign effectiveness;
    4. SDK (Software Development Kits) – sets of programming tools used, for example, in mobile applications or advanced Website components (if implemented).
  4. Both cookies and similar technologies can process information about the User’s device, but they do not lead to identification of the User unless the User voluntarily provides additional information that allows identification (e.g., via email contact).

§ 4. What types of cookies does the Website use?


The Website may use different types of cookies and similar technologies, depending on the functionalities provided by the Controller and the consents given by the User via the cookies banner or the consent management panel.


4.1. Necessary (technical) cookies

  1. Necessary cookies enable the proper functioning of the Website and provide basic security and session management mechanisms.
  2. Their functions include, among others:
    • maintaining the correct operation of interface elements,
    • handling security settings,
    • remembering cookie preferences (e.g., storing information about granted consent),
    • ensuring proper display of the Website’s content and structure.
  3. These cookies do NOT require the User’s consent, as they are essential for using the Website.

4.2. Analytical / Statistical Cookies

  1. Analytical cookies are used to collect anonymous information about how Users interact with the Website, for the purposes of:
    • analyzing User traffic and activity,
    • improving the Website’s functionality,
    • optimizing its content and structure.
  2. If analytical tools are implemented, they may include, among others:
    • Google Analytics / GA4,
    • Matomo,
    • Microsoft Clarity (once implemented).
  3. Analytical cookies require the User’s consent.

4.3. Functional Cookies

  1. Functional cookies allow the Website to remember the User’s settings and preferences so that it can operate in a way more tailored to their individual needs.
  2. They may be used, for example, to:
    • remember the preferred language,
    • store settings related to the Website’s appearance,
    • support tools that enhance the User’s experience on the Website.
  3. Functional cookies require the User’s consent unless they are strictly necessary.

4.4. Marketing / Advertising Cookies

  1. Marketing cookies are used to deliver personalized advertisements to the User and measure their effectiveness, as well as to conduct remarketing activities.
  2. They may be used by:
    • Meta Pixel,
    • Google Ads,
    • LinkedIn Insight Tag,
    • other advertising tools, if implemented.
  3. Marketing cookies always require the User’s consent.

4.5. Cookies from External Services

  1. The Website may use services from external providers that may deploy their own cookies or tracking technologies, particularly when using:
    • maps (e.g., Google Maps),
    • video players (e.g., YouTube, Vimeo),
    • social media widgets (e.g., Facebook, LinkedIn, Instagram).
  2. Such technologies may collect information about the User’s activity, even if the User is not logged into the given service.
  3. Cookies from external services require the User’s consent, unless the component is purely technical and does not involve the processing of personal data.

§ 5. Which tools do we use?

  1. As of the date of this Policy, no analytical, marketing, tracking, or multimedia tools that would install additional cookies or similar technologies beyond the necessary cookies are active on the Website.
  2. In the future, if new Website functionalities are implemented or integrations with external services occur, the Controller may use tools provided by third parties. The use of such tools will always depend on:
    • their actual implementation on the Website,
    • the purpose for which they are used,
    • the User’s consent given via the cookies banner or CMP panel.
  3. Possible tools that may be implemented in the future include, in particular:
a. Google Analytics / Google Analytics 4 (GA4) – an analytical tool that enables the analysis of User traffic and behavior; it may process data such as IP address (anonymized), device identifiers, and activity on the Website.
 b. Google Tag Manager (GTM) – a tag management system that does not collect personal data by itself but allows the deployment of tags from other tools.
 c. Google Ads – an advertising tool that enables conversion measurement and campaign management (requires marketing consent).
 d. Meta Pixel – a Meta Platforms tool that allows analysis of User behavior and remarketing activities (requires marketing consent).
 e. LinkedIn Insight Tag – an analytical and marketing tool by LinkedIn used for conversion analysis and audience creation (requires marketing consent).
 f. Microsoft Clarity – an analytical tool that enables analysis of User behavior, such as mouse movements and interactions with Website elements.
 g. Hotjar – an analytical tool used to analyze User behavior, create heatmaps, and record sessions.
 h. Google Maps – a tool that allows the display of interactive location maps and may install cookies from an external provider.
 i. YouTube or Vimeo – video players that may install tracking cookies to measure viewership and associate activity with the User’s account.
 j. Other marketing, analytical, or multimedia tools, if implemented on the Website in the future.
  4. Each of the tools mentioned in section 3 may process technical data, such as:
    • IP address (often anonymized),
    • device and browser identifiers,
    • data about interactions and activity on the Website,
    • browser or device settings,
    • data regarding content views or conversions.
  5. The current list of tools actually used on the Website will be published:
    • in this Cookies Policy, or
    • in a separate section of the Website containing the list of active tools,
depending on the Controller’s needs.
  6. The introduction of new tools does not affect the obligation to obtain the User’s consent in accordance with the cookies banner mechanism and Google Consent Mode v2.

§ 6. Legal Basis for Using Cookies

  1. The use of cookies and similar technologies on the Website is carried out in accordance with applicable regulations, in particular:
    • Regulation (EU) 2016/679 of the European Parliament and of the Council (“GDPR”),
    • the Act of 18 July 2002 on the Provision of Electronic Services,
    • the Act of 16 July 2004 – Telecommunications Law, in particular Articles 173 and 174.
  2. The legal basis for the use of necessary cookies is the Controller’s legitimate interest (Art. 6(1)(f) GDPR), which consists of:
a. ensuring the proper functioning of the Website,
 b. enabling the use of technical functions and security features,
 c. managing the User’s cookie preferences,
 d. ensuring IT security.

Necessary cookies are installed without the need to obtain the User’s consent.

  1. The legal basis for the use of analytical, functional, and marketing cookies is the User’s consent (Art. 6(1)(a) GDPR), given via the cookies banner or the consent management panel (CMP). Consent is voluntary, and its absence or withdrawal does not affect the ability to use the Website, except for functions that depend on consent.
  2. According to Art. 173(1) of the Telecommunications Law, storing information or accessing information stored on the User’s device requires the User’s prior consent, except for:
    • necessary cookies,
    • cookies used solely for the transmission of electronic communications.
  3. The User’s consent can be withdrawn at any time using:
    • web browser settings,
    • the consent management panel available on the Website (CMP),
    • options available in the cookies banner.
  4. The Controller ensures that the cookies used comply with Google Consent Mode v2, meaning that analytical and marketing tools are activated only after the appropriate consent is given.

§ 7. Consent Management – Cookies Banner / CMP

  1. The Website uses a simple consent management mechanism for cookies, allowing the User to make informed decisions regarding the use of cookies other than necessary ones. On the User’s first visit to the Website, a cookies banner is displayed containing basic information about the technologies used and the option to accept or reject specific categories of cookies.
  2. Consent is voluntary and can be withdrawn at any time, without affecting the legality of processing carried out before its withdrawal. Refusal of analytical or marketing cookies does not limit the ability to use the Website, except for functionalities that require these cookies to function properly.
  3. The User can manage their cookie settings by:
    1. changing choices via the preferences panel (CMP), if available on the Website,
    2. redisplaying the cookies banner (e.g., via a relevant link in the Website footer),
    3. changing web browser settings, including blocking or deleting cookies.
  4. The Website may use Google Consent Mode v2, which adjusts the operation of Google analytical and marketing tools according to the User’s choices. This mechanism ensures that these tools do not collect data requiring consent without it being granted.
  5. If additional analytical, marketing, or multimedia tools are implemented on the Website, their operation will always depend on the User’s consents and the settings available in the cookies banner or preferences panel.
  6. The Controller strives to ensure that consent management mechanisms are simple, transparent, and intuitive, in line with the principle of minimal intrusion into the User’s privacy.

§ 8. How to Disable Cookies in Your Browser?

  1. Users can manage cookies themselves through their web browser settings. In most browsers, it is possible to:
    • block the storage of cookies,
    • delete cookies that have already been saved,
    • set blocking of cookies from specific websites,
    • enable private browsing mode, which limits cookie usage.
  2. Below are links to instructions for managing cookies in the most popular browsers:

Google Chrome:
 https://support.google.com/chrome/answer/95647
Mozilla Firefox:
https://support.mozilla.org/pl/kb/ciasteczka
Safari (macOS):
 https://support.apple.com/pl-pl/guide/safari/sfri11471/mac
Microsoft Edge:
 https://support.microsoft.com/pl-pl/microsoft-edge/usuwanie-plik%C3%B3w-cookie-w-przegl%C4%85darce-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09

  1. Users should be aware that restricting the use of cookies may affect how the Website is displayed or the functioning of certain features (if implemented in the future).

§ 9.Cookie Retention Period

  1. The retention period of cookies depends on their type and the purpose for which they are used. The Website may use both session cookies and persistent cookies.
  2. Session cookies are stored on the User’s device only for the duration of the browser session. They are automatically deleted when the session is closed.
  3. Persistent cookies remain on the User’s device for a specified period or until they are manually deleted. Their retention period may be:
    • from 1 month to 24 months – depending on browser settings and the configuration of the tools used,
    • for some analytical tools (e.g., Google Analytics) – typically up to 26 months,
    • for marketing tools – according to the settings of the external provider.
  4. Cookies from external providers (e.g., YouTube, Google Maps, Meta, LinkedIn) are subject to the privacy policies and settings of those providers. Information about the data retention periods of external entities is available on the websites of these service providers.
  5. Users can delete stored cookies or limit their use at any time through their browser settings or via the consent management panel (CMP), if such a panel is available on the Website.

§ 10. Are data transferred outside the EU/EEA?

  1. As of the date of this Policy, the Website does not use tools or services that would result in the transfer of Users’ personal data outside the European Economic Area (EEA).
  2. In the future, if analytical, marketing, or multimedia tools provided by entities based outside the EEA (e.g., Google LLC, Meta Platforms, LinkedIn Corporation, Microsoft Corporation, YouTube LLC) are implemented on the Website, data may be transferred to third countries, in particular to the United States.
  3. The transfer of data outside the EEA, as mentioned above, will occur only:
    • after the User has given consent to the use of the relevant categories of cookies,
    • to the extent necessary for the use of the given tool,
    • using the appropriate legal mechanisms provided under the GDPR.
  4. For tools provided by Google, Meta, Microsoft, LinkedIn, YouTube, and other entities, the transfer of data outside the EEA may be based on:
a. Data Privacy Framework (DPF) – if the provider holds a current certification under this program approved by the European Commission,
 b. Standard Contractual Clauses (SCCs) – together with additional technical and organizational safeguards applied by the providers.
  5. Entities outside the EEA process data in accordance with their privacy policies, which specify, among other things, rules for data storage, protection, and international transfers.
  6. The User retains the right to withdraw consent at any time, which will halt the transfer of data for tools requiring consent and trigger adjustment of these tools’ operation in accordance with Google Consent Mode v2 (if implemented).

§ 11. Data Recipients

  1. In connection with the use of cookies and similar technologies, User data may be shared with third parties only to the extent necessary for the proper functioning of the Website, the management of its infrastructure, and the provision of services that require the use of cookies.
  2. Data recipients may include, in particular:
    1. Entities processing data on behalf of the Controller, including:
      • hosting and server infrastructure providers,
      • companies providing Website maintenance and technical support services,
      • IT firms responsible for the development and operation of the Website;
    2. External providers of analytical, marketing, or multimedia tools – only if such services are implemented and after the User has given consent, e.g.:
      • Google (Google Analytics, Google Tag Manager, Google Ads, YouTube),
      • Meta Platforms (Meta Pixel),
      • LinkedIn (Insight Tag),
      • Microsoft (Microsoft Clarity),
      • providers of solutions such as Hotjar or Vimeo;
    3. Providers of technical components used on the Website (e.g., maps, video players, social media widgets), if their implementation involves the use of cookies or similar technologies;
    4. Entities providing legal, advisory, or audit services, if access to data is necessary to protect the Controller’s rights or to fulfill legal obligations;
    5. Public authorities – only in cases provided by law and to the extent required by the obligations imposed on the Controller.
  3. Data is not transferred to entities within the Sellhorn Group (including Sellhorn Ingenieurgesellschaft mbH in Hamburg), unless in the future there is a genuine need to transfer data in connection with a specific User inquiry or matter requiring the involvement of a Group company. As of the date of this Policy, no such situation exists.
  4. All entities processing data on behalf of the Controller operate based on appropriate data processing agreements in accordance with Art. 28 GDPR or equivalent legal instruments.

§ 12. Changes to the Cookies Policy

  1. The Controller reserves the right to make changes to this Cookies Policy, in particular in the event of:
    • implementation of new Website functionalities or changes in its operation,
    • deployment of new analytical, marketing, or multimedia tools,
    • changes in applicable legal regulations,
    • recommendations or decisions of supervisory authorities,
    • updates to the technologies used on the Website.
  2. The current version of the Cookies Policy will be published on the Website with an indication of its effective date.
  3. Using the Website after changes to the Cookies Policy take effect constitutes acceptance of the updated version.
  4. The Controller may additionally inform Users of significant changes to the Policy through an appropriate notice on the Website or another form provided within its structure.

§ 13. Contact Information

  1. For matters related to the use of cookies, tracking technologies, and the processing of personal data in connection with the operation of the Website, the User can contact the Controller using the following details:

Sellhorn Polska Spółka z ograniczoną odpowiedzialnością
 ul. Szeroka 56B
 71-211 Szczecin
 NIP: 852 270 93 74
 REGON: 529139530
Email address for privacy-related contact: info@sellhorn.pl

  1. The Controller ensures that any inquiries regarding privacy, cookies, or consent settings will be handled as promptly as possible, and no later than the timeframes required by the GDPR.
  2. Information about the rules for processing personal data can be found in a separate Privacy Policy, available on the Website.

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