Administrator – [company_name oneline], based in [oneline address].
Personal data – all information about a natural person identified or identifiable by one or more specific factors determining physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, internet identifier and information collected for via cookies and other similar technology.
RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC.
Website – the website run by the Administrator at [website_address]
User – any natural person visiting the Website or using one or several services or functionalities described in the Policy.
DATA PROCESSING IN CONNECTION WITH THE USE OF THE WEBSITE
In connection with the User’s use of the Website, the Administrator collects data to the extent necessary for commercial contact as well as information about the User’s activity on the Website using cookies. Detailed rules and purposes for processing personal data collected while using the Website by the User are described below.
2. OBJECTIVES AND LEGAL BASIS FOR PROCESSING DATA ON THE WEBSITE
USE OF THE WEBSITE [page_address]
Personal data of all persons using the Website (including the IP address or other identifiers and information collected via cookies or other similar technologies), and who are not registered Users (i.e. persons without a profile on the Website) are processed by the Administrator:
in order to provide services electronically in the scope of making content collected on the Website available to Users, providing contact forms – then the legal basis for processing is the necessity of processing to perform the contract (Article 6 paragraph 1 point b of the GDPR);
for marketing purposes of the Administrator and other entities, in particular related to the presentation of behavioral advertising – the rules for processing personal data for marketing purposes are described in the “MARKETING” section.
The User’s activity on the Website, including his personal data, is recorded in system logs (a special computer program used to store a chronological record containing information about events and activities related to the IT system used to provide services by the Administrator). Information collected in logs processed in connection with the provision of services. The administrator also processes them for technical purposes, in particular, data may be temporarily stored and processed in order to ensure the security and proper functioning of IT systems, e.g. in connection with making backup copies, testing changes in IT systems, detecting irregularities or protecting against abuse and attacks.
3. CONTACT FORMS
The administrator provides the opportunity to contact him using electronic contact forms. Using the form requires providing personal data necessary to contact the User and answer the query. The User may also provide other data in order to facilitate contact or handle the query. Providing data marked as mandatory is required in order to receive and service the query, and failure to do so results in the inability to service. Providing other data is voluntary.
Personal data is processed:
in order to identify the sender and service his query sent via the provided form – the legal basis for processing is the necessity of processing to perform the contract for the provision of the service (Article 6 paragraph 1 point b of the GDPR);
The administrator processes Users’ personal data in order to carry out marketing activities that may consist of:
sending e-mail notifications about interesting offers or content, which in some cases contain commercial information;
conducting other types of activities related to direct marketing of goods and services (sending commercial information by electronic means and telemarketing activities).
In order to implement marketing activities, the Administrator uses profiling in some cases. This means that thanks to automatic data processing, the Administrator assesses selected factors regarding natural persons in order to analyze their behavior or create a forecast for the future.
If the User has agreed to receive marketing information via e-mail, SMS and other electronic means of communication, the User’s personal data will be processed for the purpose of sending such information. The basis for data processing is the legitimate interest of [company_name] consisting in sending marketing information within the limits of the consent given by the User (direct marketing). The User has the right to object to data processing for the purposes of direct marketing, including profiling. The data will be stored for this purpose for the duration of the legitimate interest of [company_name] unless the User objects to receiving marketing information.
The Administrator processes personal data of Users visiting the Administrator’s profiles kept in social media (Facebook, YouTube, Instagram). These data are processed only in connection with maintaining the profile, including to inform Users about the Administrator’s activity and to promote various types of events, services and products, as well as to communicate with users through the functionalities available in social media. The legal basis for the processing of personal data by the Administrator for this purpose is his legitimate interest (art.6 par.1 lit.f RODO) consisting in promoting his own brand and building and maintaining the brand-related community.
5. COOKIES AND SIMILAR TECHNOLOGY
Cookies are small text files installed on the device of the User browsing the Website. Cookies collect information that facilitates the use of the website – e.g. by remembering User’s visits to the Website and activities performed by him.
6. “SERVICE” COOKIES
cookies with data entered by the User (session ID) for the duration of the session (user input cookies);
authentication cookies used for services that require authentication for the duration of the session (authentication cookies);
cookies used to ensure security, e.g. used to detect fraud in the field of authentication (user centric security cookies);
session cookies of multimedia players (e.g. flash player cookies), for the duration of the session (multimedia player session cookies);
permanent cookies used to personalize the User interface for the duration of the session or a little longer (user interface customization cookies),
cookies used to remember the contents of the basket for the duration of the session (shopping cart cookies);
cookies used to monitor website traffic, i.e. data analytics, including Google Analytics cookies (these are files used by Google to analyze the way the User uses the Website, to create statistics and reports on the Website’s functioning). Google does not use the collected data to identify the User or combine this information to enable identification. Detailed information about the scope and rules of collecting data in connection with this service can be found at the following link: https://www.google.com/intl/pl/policies/privacy/partners.
7. “MARKETING” COOKIES
8. PERIOD OF PROCESSING OF PERSONAL DATA
The period of data processing by the Administrator depends on the type of service provided and the purpose of processing. As a rule, data is processed for the duration of the service or order, until the consent is withdrawn or effective objection to data processing is raised in cases where the legal basis for data processing is the Administrator’s legitimate interest.
The data processing period may be extended if the processing is necessary to establish and assert any claims or defend against them, and after that time only if and to the extent required by law. After the end of the processing period, the data is irreversibly deleted or anonymized.
9. USER PERMISSIONS
Data subjects have the following rights:
The right to information on the processing of personal data – on this basis, the person submitting such a request, the Administrator provides information about the processing of personal data, including primarily the purposes and legal grounds for processing, the scope of data held, entities to whom personal data is disclosed and the planned date of their removal ;
The right to obtain a copy of the data – on this basis, the Administrator provides a copy of the processed data regarding the person making the request;
Right to rectification – on this basis, the Administrator removes any incompatibilities or errors regarding the personal data being processed, and supplements or updates them if they are incomplete or have changed;
The right to delete data – on this basis, you can request the removal of data whose processing is no longer necessary to achieve any of the purposes for which it was collected;
The right to limit processing – on this basis, the Administrator ceases to carry out operations on personal data, with the exception of operations that the data subject has consented to and their storage, in accordance with the adopted retention rules, or until the reasons for the restriction of data processing cease (e.g. a decision of the supervisory authority will be issued, authorizing further data processing);
The right to transfer data – on this basis, to the extent that data is processed in connection with the concluded contract or consent, the Administrator issues data provided by the person to whom they relate, in a format that allows it to be read by a computer. It is also possible to request that the data be sent to another entity – however, provided that there are technical possibilities in this regard both on the part of the Administrator and that other entity;
The right to object to the processing of data for marketing purposes – the data subject may at any time object to the processing of personal data for marketing purposes, without the need to justify such an objection;
Right to object to other purposes of data processing – the data subject may at any time object to the processing of personal data on the basis of the justified interest of the Administrator (e.g. for analytical or statistical purposes or for reasons related to the protection of property). An objection in this respect should contain a justification and is subject to the Administrator’s assessment;
The right to withdraw consent – if the data is processed on the basis of consent, the data subject has the right to withdraw it at any time, which, however, does not affect the lawfulness of the processing carried out before the withdrawal of this consent;
Right to complain – if it is considered that the processing of personal data violates the provisions of the GDPR or other provisions regarding the protection of personal data, the data subject may submit a complaint to the President of the Office for Personal Data Protection
An application regarding the exercise of data subjects’ rights may be submitted:
in writing to the following address: [oneline address]
– by e-mail to the address: firstname.lastname@example.org
Taking into account:
what right the person submitting the application wants to use (e.g. the right to receive a copy of the data, the right to delete the data, etc.);
what processing process the request relates to (e.g. use of a particular service, activity on a specific website, receiving a newsletter containing commercial information to a specific email address, etc.);
what processing purposes the request relates to (e.g. marketing purposes, analytical purposes, etc.).
If the Administrator is unable to determine the content of the request or identify the person submitting the application based on the application, he will ask the applicant for additional information.
A response to applications will be given within one month of receipt. If it is necessary to extend this period, the Administrator will inform the applicant about the reasons for such an extension.
The answer will be given to the e-mail address from which the application was sent, and in the case of applications sent by letter, by ordinary letter to the address indicated by the applicant, unless the content of the letter indicates the desire to receive feedback to the e-mail address (in this case enter email address).
In connection with the provision of services, personal data will be disclosed to external entities, including in particular suppliers responsible for operating IT systems, entities such as legal entities and entities related to the Administrator.
The Administrator reserves the right to disclose selected information about the User to competent authorities or third parties who submit a request for such information, based on an appropriate legal basis and in accordance with applicable law.
- TRANSPORT OF DATA OUTSIDE THE EEA
The administrator does not transfer collected data outside the EEA.
SECURITY OF PERSONAL DATA
The administrator conducts risk analysis on an ongoing basis to ensure that personal data are processed by him in a secure manner – ensuring, above all, that only authorized persons have access to the data and only to the extent that it is necessary due to the tasks they perform . The administrator ensures that all operations on personal data are recorded and carried out only by authorized employees and associates.
The Administrator takes all necessary actions so that its subcontractors and other cooperating entities guarantee the use of appropriate security measures whenever they process personal data at the request of the Administrator.
Contact with the Administrator is possible via the e-mail address: email@example.com
The policy is reviewed on an ongoing basis and updated as necessary.