1. Scope of Privacy and Cookies Policy
- defines the types of personal information we collect;
- explains how and why we collect and use your personal information;
- explains when and why we will share your personal information with other organizations;
- explains the rights and choices you have regarding your personal information
In connection with the range of services we offer, we want you to be clear about what this Policy covers. This Policy applies to you if you use our Services (referred to in this Policy as “our Services”). Using our Services means:
- Creating an account on our Service and using our Services offered as part of its functionality;
- This Policy also applies if you contact us or we contact you about our Services;
Our Services or mobile applications may contain links to other websites operated by other entities that have their own terms and privacy policies that explain how they use your personal information. In such situations, please read the said terms and conditions and privacy policies carefully before providing any personal information on such websites, as we have no responsibility for third-party websites.
2. Personal information we collect
|By registering for our Services, you can give us:||– Your personal information, including your mailing address, email address, phone number and date of birth;|
– Your account login information, such as the username and password you have chosen
|When you browse our Services or use our mobile applications, we may collect:||– Information about how you browse our Services and mobile applications, and information about when you click on one of our advertisements (including on third-party websites);|
– Information about any devices used to access our Services (including make, model and operating system, IP address, browser type and mobile device IDs);
|When you contact us, or when we contact you, or when you participate in promotions, contests, surveys or polls about our Services, we may collect:||– Personal information you provide about yourself whenever you contact us about our Services (for example, your name, username, contact information, login), including by phone, e-mail or mail, or when you talk to us via social media;|
– Details of emails and other digital messages we send to you, including any links you click;
– Your feedback and input in customer satisfaction surveys;
3. Other sources of personal data
We may also use personal data from other sources like: specialized companies that provide information, our business partners and public records. This type of personal data helps us, among other things:
- review and improve the accuracy of the data we hold;
- improve and measure the effectiveness of our marketing communications, including online advertising.
4. How and why used personal data
In the table below, we explain in detail how and why we use personal data:
|We use your personal data to:||This means that processing your personal data allows us to:||Why do we process your data in this way?||Legal basis|
|Ensure the availability of our services||Manage the account you have created on our Service.||We need to process your personal data so that we can: manage your user account and provide you with the services you want to use.||Necessity for the performance of the contract|
When we process:
user profile information.
Without this information, we will not be able to provide you with our services.
and streamlining our daily business operations
Some cookies are essential, so you should not disable them to use all the features of our Services and mobile applications. You can disable other cookies, but this may affect your experience
of using our Sites. For more information about cookies and how to disable them, please see Cookies and similar technologies.
|Legally legitimate purpose|
|To develop and improve our service offerings, know-how and the way we communicate with you.||We rely on the use of personal information to conduct market research, and to improve our information systems (including security) and our services. This allows us to serve you better as a customer.|
|Detecting and preventing fraud and other crimes.||It is important that we monitor our Services in the context of detecting and preventing fraud, other crimes|
and misuse of the Services. This will help us make sure that you can use our Services safely.
|To personalize the Services to your expectations||To analyze your browsing habits on our Services so that we can better understand you as our user and provide you with personalized services.||Reviewing your behavior allows us to personalize our Services. This will help us meet your needs as a user.||Legally justifiable purpose|
|Sending relevant marketing communications|
(including by email, postal mail or online advertising) regarding our services and those of our partners. Accordingly, online advertising may be displayed on our websites and on third-party websites and other online media channels. We may also measure the effectiveness of our marketing communications and those of our business partners.
|We want to be sure that we deliver marketing communications, including online advertising, that are relevant to your interests. To achieve this, we measure your responses to marketing communications related to the services we offer, which means we can offer you services that better meet your needs as a customer.|
You can change your marketing choices, both when you register with us and and at any time thereafter.
You also have choices when it comes to online advertising. In the following section of the Policy, we outline the options you can choose regarding cookies and how you can control your online behavioral preferences.
|For most marketing communications, we rely on your consent, but there are situations where this is within our legitimate purpose.|
|Contact and interact with you||Contacting you about our Services, such as by phone, e-mail or mail, or by responding to social media posts you have directed to us.|
Manage promotions and contests in which you participate, including those we run with our business partners. Inviting you to participate in user satisfaction surveys and other market research conducted by us and other organizations acting on our behalf.
|We want to serve you best as a customer, so we use personal information to provide clarification or assistance in response to your communications. We need to process your personal information so that we can manage promotions and contests in which you choose to participate. We conduct market research to improve our Services. However, if we contact you about this, you do not have to participate in the survey. If you tell us that you do not want us to contact you for market research, we will respect that choice. This will not affect your ability to use our Services.||Legally justifiable purpose|
5. Our legitimate purposes in using your personal data
Where we have mentioned above that the use of your personal data is based on our “legitimate purpose,” these are:
- servicing the needs of our customers, including the delivery of our services;
- promoting and marketing our services;
- servicing your account (for example, your online user account), managing complaints and resolving any disputes;
- understanding our users, including their patterns, behavior, and their likes and preferences;
- Protecting and supporting our business, associates, users and co-owners;
- testing and developing new services, as well as improving existing ones;
- legal/regulatory requirements.
6. How and why we share personal information with service providers
In this section, we explain how and why we share personal data with service providers. When we share personal data with these companies, we require them to maintain security and they are not allowed to use personal data for their own marketing purposes.
|Service providers||We work with carefully selected service providers who perform certain functions|
on our behalf. These include, for example, companies that help us provide: customer services, technology services, data storage and linkage, payment processing
and delivering orders. We only share personal information that enables our providers to provide these services.
Some of the service providers we work with operate online media channels
within which they place relevant advertisements for our services, as well as for our suppliers. For example, you may see an ad for our services when you use a certain social media site or watch Internet TV.
7. How and why we share personal information with others
We may share personal information with other organizations in the following circumstances:
- when the law or a public authority says we must share personal data;
- when we need to share personal data to establish, exercise or defend our rights (including transferring personal data to others for fraud prevention and credit risk reduction);
- to an organization to which we sell or transfer (or enter into negotiations to sell or transfer) any of our rights or obligations under any contract we may have with you. If the transfer or sale is successful, the entity receiving your personal information may use your personal information in the same manner as we do;
- to any legal successors related to our business.
8. How we protect your personal information
We know how important it is to properly secure and manage personal data. This section outlines a selection
of the measures we have put in place. To ensure the security of your data, we use computer safeguards such as:
- restricting access only to employees who need it to perform their job duties;
- we enforce physical, electronic and procedural safeguards related to the collection, storage and disclosure of personal information;
- physical controls on access to our buildings and files;
- firewalls and encryption of data during transmission using the Secure Sockets Layer (SSL) protocol.
However, although we have taken appropriate technical and organizational measures to protect your personal information, we cannot guarantee the security of any personal information transmitted to us over the Internet.
The personal information we collect from you may be transferred to and stored at a destination outside the European Economic Area (“EEA”). They may also be processed by companies outside the EEA that work for us or for one of our service providers. If we do so, we ensure that your privacy rights are respected in accordance with this Policy. The most common way we do this is by putting in place a specific type of contract (see here for more information: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu_en) or through an approved program such as Privacy Shield: https://www.privacyshield.gov/welcome.
9. How long do we process personal data
We will not keep your personal data longer than we need to, which depends on several factors:
a) (Primarily) the reason we collected it;
b) How long ago they were collected;
c) Whether there is a legal/regulatory basis for us to retain them;
d) Whether we need them to protect your or our interest.
10. Choice, in terms of receiving marketing communications and participating in market surveys
We will send you relevant offers and information about our services in a number of ways, including by email, but only if you have previously agreed to receive these marketing communications.
When you register with our Service, we will ask you whether you want to receive marketing communications. You will be able to change your choice of marketing preferences at any time through the settings panel
within your user account, over the phone (phone_number) or in writing (mailing_address).
We would also like your feedback to help us improve our Services, so we may contact you to conduct market research. You will always have the choice to participate
in our market research or opt out.
Cookies (so-called “cookies”) are IT data – in particular text files – that are placed by our Website during each visit to a User’s final device, which allows our websites to remember the User’s computer or device and serves several purposes. The entity placing cookies on the Service User’s end device and accessing them is the Foundation. The Website server automatically logs information sent by the User’s browser when the Website is viewed. Server logs may include information such as network request, IP address, browser type and language, date and time the request was sent. This information allows us to improve the quality of our Services by identifying and storing User preferences and tracking trends, such as the ways in which our Services are searched.
The following types of cookies are used on our Services:
|Ensuring efficiency||– Compatibility (e.g., identifying browser type);|
– Optimization (e.g., measuring the loading time of the Service’s content);
|Session -> when you close your browser the cookies are deleted|
|Enhance security||– Verify that the user’s device is securely logged in throughout the user’s visit to the Website;||Session -> when you close your browser the cookies are deleted|
|Remembering preferences||– Improving the operation of the Service, e.g. through personalized content, greeting or remembering the selected language;||Session -> when you close your browser the cookies are deleted|
|Analyzing how you use|
of the Service
|– collecting statistics on, among other things, the total number of page views and references to the Website;||Permanent -> deleted after not visiting the Website for a long time|
|Feedback from users of the Service||– not displaying notifications of a one-time nature after the User navigates to the next subpage of the Website;|
– not displaying recurring notifications for a defined period;
|Session -> when you close your browser the cookies are deleted|
|Plugins / widgets||– Sharing the Service’s content on social media platforms;|
– noting users’ interactions on the Service (e.g., using a counter of the number of shares);
|Permanent -> deleted after not visiting the Website for a long time|
|Provision of relevant marketing content (in particular, online advertising)||– providing online advertisements that we believe are most relevant to you on our Services and third-party websites;||Permanent -> deleted after not visiting the Website for a long time|
|Measuring the effectiveness of our marketing communications|
(including online advertising)
|– measuring the effectiveness of our online advertising campaigns and those sent via e-mail;|
– controlling the number of ad impressions.
|Permanent -> deleted after not visiting the Website for a long time|
12. Your choice regarding cookies
Although most web browsers automatically allow cookies to be placed on your computer, you may choose not to receive cookies, thereby remaining anonymous. If this is the case, please note that by not consenting to the placement of cookies, you will not be able to take full advantage of all features of the Website. In order to configure the options of your device in terms of consenting to the storing of cookies and determining the scope of cookies stored, the User can make changes to the settings of the Internet browser used (in most cases, such option can be found in the Tools or Preferences menu of the browser).
Please be informed that failure to change the User’s settings regarding cookies means that they will be placed
on the User’s terminal device. In this case, our Services may store information on the User’s terminal device and access this information.
Information on how to manage cookies in individual browsers can be found on the pages dedicated to each browser:
- Firefox: https://support.mozilla.org/pl/kb/ciasteczka
- IE: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies
- Chrome: https://support.google.com/chrome/answer/95647?hl=pl
- Opera: http://help.opera.com/Linux/12.10/pl/cookies.html
- Safari: https://support.apple.com/pl-pl/HT201265
Additional information about cookie management can be found on sites such as http://allaboutcookies.org
13. Right to access your data
You have the right to inspect your personal data that we maintain.
14. Other rights of data subjects
With respect to your personal data, you also have:
14.1 The right to correct your data
If you believe that we have inaccurate or missing information about you, let us know and we will correct it.
14.2 Right to object
General objection – we will consider objections to our use of your personal information. If your rights outweigh our interests in using your personal information, then, at your request, we will either limit its processing (see section 14.3 below) or delete it (see section 14.4 below).
Objection to direct marketing – if you make such an objection, we will stop using your personal data for direct marketing purposes. As a result of your objection to direct marketing, and in the event that we have no other legal grounds for using it, the processing of your personal data will be stopped within 30 days.
14.3 Right to restrict data processing
There are several situations in which you can restrict the use of your personal data, including (but not limited to):
- you have made a general objection (listed in Section 14.2 above);
- you question the accuracy of the personal data we hold;
- we have used your personal data unlawfully, but you do not want us to delete it.
14.4 Right to erasure
There are several situations in which you can have us delete your personal data, including (but not limited to):
- we no longer need to store your personal data;
- you have successfully filed a general objection (listed in section 14.2 above);
- you have withdrawn your consent for us to use your personal data (and we have no other reason to use it);
- we have unlawfully processed your personal data.
14.5 Right to data portability
If you would like to receive a copy of the personal data we hold about you, please contact us via:
14.6 Right to lodge a complaint with a supervisory authority
We would like to be able to resolve any of your requests and comments, however, you also have the right to file a complaint directly with your local supervisory authority if you believe we are processing personal data unlawfully.
14.7 More information on your data protection rights
The President’s Office for the Protection of Personal Data (PUODO) data protection website provides more detailed information on your data protection rights mentioned above. If you would like to talk to us in more detail about these rights, please use the section below where we tell you “how to contact us.”
15. How to contact us
If you have questions about how we collect, store and use your personal information, please contact
You can also contact the Foundation’s Personal Data Supervisor via e-mail: email@example.com.
The policy was last updated: 1.09.2022