Cookie Policy

Cookies and similar technologies on the ttms.com website

This Cookie Policy sets out the rules for the use of cookies and similar technologies on the website operated by Transition Technologies MS S.A. at ttms.com (hereinafter: the “Website”). This Policy fulfils the information obligations referred to in Article 173 of the Act of 12 July 2024 – Electronic Communications Law (Journal of Laws of 2024, item 1221, as amended) and – with respect to the processing of personal data through cookies – in Article 13 of Regulation (EU) 2016/679 (GDPR). It supplements the Privacy Policy of the Website.

1. Definitions

Controller – Transition Technologies MS S.A., with its registered office in Warsaw (00-801), at ul. Chmielna 69, entered in the Register of Entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS No. 0000913657, REGON 360679205, NIP (Tax ID) 5272728327. Cookies – small text files saved on the User’s terminal equipment (computer, phone, tablet) while using the Website, as well as other similar technologies used to collect, store or gain access to information on the User’s terminal equipment (in particular web beacons, tracking pixels, device identifiers, local storage and session storage technology, and fingerprinting). Website – – the website operated by the Controller at ttms.com, together with all its subpages and language sections (in particular ttms.com/pl/). User – any natural person visiting the Website. CMP (Consent Management Platform) – the consent management platform used on the Website to obtain and manage Users’ consents to optional cookies and to enable their withdrawal. PKE – the Act of 12 July 2024 – Electronic Communications Law (Journal of Laws of 2024, item 1221, as amended). 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. Privacy Policy – the document available at ttms.com/pl/polityka-prywatnosci/ describing the rules for the processing of personal data by the Controller.

2. Contact Details

The Controller may be contacted on matters relating to the Cookie Policy and the processing of personal data through cookies:

in writing – to the address: Transition Technologies MS S.A., ul. Chmielna 69, 00-801 Warsaw, marked “GDPR”; by e-mail – to the address: rodo@ttms.pl; by telephone – on +48 22 378 45 58. The Controller has appointed a Data Protection Officer, who may be contacted on all matters relating to the processing of personal data, including cookie-related matters, at: rodo@ttms.pl

3. What Are Cookies and Similar Technologies?

Cookies are small text files saved by a website in the memory of the User’s device (web browser). A cookie contains, among other things, the domain name, the storage period and a unique value. Cookies enable, in particular:

ensuring the proper operation of the Website and the security of the User’s session; remembering the User’s settings and preferences (e.g. language, regional version); analysing how the Website is used; conducting marketing and advertising activities tailored to the User. The Controller also uses technologies similar to cookies, in particular local storage and session storage (browser mechanisms used to store information on the User’s device). In this Policy, all these technologies are collectively referred to as “cookies”.

4. Categories of Cookies Used on the Website

Cookies on the Website fall into four categories:

4.1. Essential Cookies

Cookies necessary for the proper functioning of the Website. They enable the use of basic functionalities (e.g. navigation, access to secure areas, form handling, load balancing). Without these cookies, the Website cannot operate properly. Consent required: NO – essential cookies are used pursuant to Article 173(3) PKE (an exception to the consent requirement where they are necessary solely to transmit a communication over a telecommunications network or to provide a telecommunications service requested by the User).

4.2. Functional Cookies

Cookies that enable the User’s preferences and settings to be remembered (e.g. language version, display preferences) in order to improve the User’s experience of the Website. Consent required: YES.

4.3. Analytical and Statistical Cookies

Cookies that enable the collection of information about how the Website is used, including the number of visits, traffic sources, time spent on the site and errors. They allow the Controller to measure and improve the operation of the Website. Consent required: YES.

4.4. Marketing and Advertising Cookies

Cookies used to conduct marketing and advertising activities, including displaying content tailored to the User on the Website or on third-party websites, measuring the effectiveness of advertising campaigns, marketing profiling and integration with social media services. Cookies of this category may lead to profiling within the meaning of Article 4(4) GDPR. Such profiling does not produce legal effects concerning the User or similarly significantly affect the User – it does not constitute automated decision-making within the meaning of Article 22 GDPR. Consent required: YES.

5. Legal Bases

Legal bases for the use of cookies and the processing of personal data collected through them:

6. List of Cookies Used on the Website

Below is a list of the cookies used on the Website. The current and complete list is also available in the CMP (consent management panel).

6.1. Essential Cookies

6.2. Functional Cookies

6.3. Analytical Cookies

6.4. Marketing Cookies

The current, complete list of cookies, together with the exact retention periods, is available in the CMP panel – the User may open it at any time by clicking the “Cookie settings” icon in the footer of the Website.

7. Third-Party Cookies

The Website uses cookies originating from third parties cooperating with the Controller. Data collected through these cookies may be processed by those entities on their own terms – the User should review the privacy policies of those providers.

8. Transfers of Data Outside the EEA

Some third-party cookie providers have their registered office outside the European Economic Area or use infrastructure in third countries (in particular in the United States). Consequently, Users’ data collected through the cookies of those providers may be transferred outside the EEA. The Controller ensures that any transfer of data outside the EEA takes place on the basis of appropriate safeguards as referred to in Chapter V of the GDPR, in particular:

with respect to U.S. providers certified under the EU-U.S. Data Privacy Framework (DPF) – European Commission Implementing Decision of 10 July 2023 No. C(2023) 4745 finding an adequate level of data protection (among others, Google LLC, LinkedIn Corporation and Meta Platforms, Inc. are currently certified under the DPF – their status should be verified on an ongoing basis in the DPF register); in other cases – standard contractual clauses (SCCs) adopted by the European Commission (Implementing Decision 2021/914 of 4 June 2021) together with additional safeguards resulting from a transfer impact assessment (TIA). Upon a request addressed to rodo@ttms.pl, the Controller will provide information on the specific transfer mechanism applied to the User’s data.

9. How to Manage Cookies?

9.1. CMP Panel

The Website uses a consent management platform (CMP). Through it, the User may at any time:

\review detailed information about the cookies used on the Website and the Controller’s trusted partners; grant or refuse consent to optional cookies, separately for each category (functional, analytical, marketing); withdraw previously granted consent at any time. The CMP is available:

on the first entry to the Website – in the form of a consent banner; at any subsequent time – by clicking the “Cookie settings” link in the footer of the Website. Rejecting optional cookies in the banner is just as easy as accepting them – both options are available at the first level of the banner. The absence of consent to optional cookies does not limit the ability to use the Website in its basic scope.

9.2. Web Browser Settings

Independently of the CMP, the User may manage cookies through the settings of their web browser. Most browsers allow the User to:

block all cookies or cookies of specific entities; delete stored cookies; receive notifications when cookies are being set. Detailed instructions on managing cookies in popular browsers are available on the websites of their manufacturers:

Google Chrome – support.google.com/chrome Mozilla Firefox – support.mozilla.org Microsoft Edge – support.microsoft.com Apple Safari – support.apple.com Note: changing browser settings also affects essential cookies and may therefore limit or prevent the use of certain functionalities of the Website. Essential cookies cannot be disabled in the CMP, as they are necessary for the operation of the Website.

10. User Rights

WTo the extent that the use of cookies involves the processing of the User’s personal data, the User has the following rights under the GDPR:

the right of access to data and to obtain a copy thereof (Article 15 GDPR); the right to rectification of data (Article 16 GDPR); pc. the right to erasure of data (Article 17 GDPR); the right to restriction of processing (Article 18 GDPR); the right to data portability (Article 20 GDPR); the right to object to processing based on the Controller’s legitimate interest (Article 21 GDPR) – including an objection to direct marketing (including profiling for that purpose) without the need to state a reason; the right to withdraw consent at any time (Article 7(3) GDPR) – with respect to optional cookies for which the legal basis is consent; withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal; the right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office (UODO) – if the User considers that the processing of data infringes the provisions of the GDPR. Rights are exercised at the request addressed to rodo@ttms.pl or by another means indicated in section 2 of this Policy.

11. Relationship with the Privacy Policy

This Cookie Policy supplements the Privacy Policy of the Website, available at https://ttms.com/cookies/. The Privacy Policy sets out in detail the rules for the Controller’s processing of Users’ personal data, including the full scope of information required by Article 13 GDPR.

In the event of any conflict between the provisions of the Cookie Policy and the Privacy Policy, the provisions of the Privacy Policy prevail – except for the provisions specifically governing the use of cookies, which are set out in this document.

12. Changes to the Cookie Policy

The Cookie Policy is reviewed and updated on an ongoing basis, in particular in the event of:

changes in the law; b. the introduction of new cookie tools or providers on the Website; the discontinuation of existing tools; changes in the position of supervisory authorities (the President of the UODO, the European Data Protection Board). The Controller will inform Users of material changes in a manner appropriate to the nature of the change, in particular by posting information on the Website and – where applicable – by displaying the consent banner again.

The current version of the Policy is effective as of 12 June 2026.