1. Introduction
If you have arrived at this document, it means that the security of your data is important to you. Be assured that, operating as Exodia sp. z o.o. at Krowica Zawodnia 5, 62-865 Szczytniki, Poland we ensure the proper handling of your personal data.
Our goal is to duly inform you about matters related to the processing of personal data, especially in light of the provisions on personal data protection, including 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 (hereinafter: “GDPR”).
In this Privacy Policy, we inform you about the legal bases for processing personal data, the methods of their collection and use, as well as your rights related thereto.
The controller of personal data is Exodia spółka z ograniczoną odpowiedzialnością with its registered office in Krowica Zawodnia 5, 62-865 Szczytniki, entered into the Register of Entrepreneurs of the National Court Register under the number 0000595748, NIP 9680977660, REGON 363439246, with a share capital of PLN 5,000.
This Privacy Policy also meets the requirements set forth in the Telecommunications Law of 15 September 2017, in connection with the use of cookies. As the owner of the website szkolajezykaniemieckiego.pl, we are obliged to inform about the aforementioned files that the service uses.
2. Personal Data
2.1. When does this Privacy Policy apply?
This Privacy Policy applies to all cases in which we process your personal data. This applies both to cases where we process personal data obtained directly from you and to cases where your personal data was obtained from other sources.
2.2 In what way, on what legal basis, and what type of personal data do we process?
We maintain transparency regarding the methods and legal bases for processing personal data, as well as the purposes for which we process personal data. We ensure that the necessary information is provided each time. To make these issues as clear as possible, we present the following summary of personal data processing operations in connection with our website.
At the same time, we indicate that whenever we process personal data based on a legitimate interest (Article 6(1)(f) of the GDPR), we try to analyse and balance our interest and the potential impact on your data (both positive and negative) and your rights under data protection regulations.
Processing of personal data of website visitors
In connection with your use of the website, we process the following data sent by your browser to the server: IP address, date and time of the session start, time zone information, source page information, access status/http access code, address of the page from which you entered, browser type, operating system and its interface, language and version of the browser software. The processing of this data is necessary for the proper functioning of the website and to ensure its stability and security. Their processing is carried out on the basis of Article 6(1)(f) of the GDPR. Explanations regarding cookies can be found in section 3 of this Privacy Policy.
Processing of personal data within the contact form
In the “contact” tab on the website, you can find a contact form that allows you to submit an enquiry. The contact form collects the following data: name, surname, e-mail address, message content. Optionally, within the content of the question, you can provide other personal data, the provision of which is voluntary and in accordance with your will. The aforementioned data are necessary to provide, as their submission will make it possible to answer your question. Personal data is processed on the basis of your consent expressed by entering the data in the form and sending it to us, i.e., on the basis of Article 6(1)(a) of the GDPR. The full scope of your rights and obligations in connection with the processing of personal data (in accordance with Article 13 of the GDPR) is included in the information clause in section 2.5 of the Privacy Policy.
Processing of personal data within the newsletter
By subscribing to the newsletter, you provide us with your data in the form of your name, surname, and e-mail address via the newsletter subscription form. Providing the data is voluntary, but necessary to subscribe to the newsletter. The legal basis for the processing of personal data is Article 6(1)(a) of the GDPR. You can withdraw your consent at any time. The full scope of your rights and obligations in connection with the processing of personal data (in accordance with Article 13 of the GDPR) is included in the information clause in section 2.5 of the Privacy Policy.
Processing of personal data within Google Analytics
This website uses Google Analytics, a web analytics service provided by Google Inc. (1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Google Analytics uses cookies stored on your computer, which enable an analysis of your use of the website. The information generated by the cookies about your use of the website is usually transmitted to a Google server in the USA and stored there. On behalf of the operator of this website, Google will use this information to evaluate your use of the website, to compile reports on website activity, and to provide other services related to website and internet usage to the website operator. The IP address sent by Google Analytics will not be merged with other Google data. We use this tool to analyse and regularly improve the use of our website. You can prevent the storage of cookies by setting your browser software accordingly or by using an appropriate browser plug-in. The legal basis for the processing of personal data is Article 6(1)(f) of the GDPR. The full scope of your rights and obligations in connection with the processing of personal data (in accordance with Article 13 of the GDPR) is included in the information clause in section 2.5 of the Privacy Policy.
Social Media
On the website, you can find links to social media portals where information about us and our activities is posted. The data controller within the social media portal is both us as the owner of the social media account and the owner of the respective portal itself.
2.3 How long is your personal data processed?
The period for which we will process personal data depends on the legal basis for its processing. We inform you that:
- where we process personal data based on consent, the processing period lasts until the intended purpose is achieved or the consent is withdrawn;
- where we process personal data for the performance of a contract or to take steps before entering into a contract (order fulfilment), for the period of order fulfilment and, after its completion, for the period of limitation of claims and archiving of accounting records (5 years), in accordance with applicable legal provisions;
- where we process personal data based on a legitimate interest, the processing period lasts until the aforementioned interest ceases (e.g., the limitation period for civil law claims) or until you object to further such processing – in situations where such an objection is available under the law;
- where we process personal data because it is necessary due to applicable legal provisions, the periods of data processing for this purpose are determined by those provisions.
2.4 When and how is personal data shared with third parties? Do we transfer data to third countries?
We only share personal data with others when permitted by law. In such a case, in a relevant agreement concluded with the third party, we provide for provisions and security mechanisms to protect the data and maintain our standards for data protection, confidentiality, and security. When we transfer personal data, for which we are the controller, to other entities for the performance of specific activities on our behalf, we conclude a specific agreement with such an entity. Agreements of this kind are called data processing agreements (Article 28 of the GDPR), which gives us control over how and to what extent the entity to whom we have entrusted the processing of certain categories of personal data processes that data.
List of processors:
- dhosting.pl sp. z o.o. with its registered office in Warsaw, address: al. Jerozolimskie 98, 00-807 Warsaw, NIP: 7010198361 – for the purpose of storing personal data on the server.
- SendPulse Inc., 220 E 23rd St #401, New York, NY 10010 – for the purpose of using the mailing system where your data is processed if you have subscribed to our mailing list or newsletter.
Data may also be transferred to our Partners with whom we cooperate in providing services, such as access to courses, and to entities responsible for payment processing and other services necessary for the proper functioning of our services. In other situations, personal data may only be disclosed to entities with appropriate authorisations under applicable law.
The Controller transfers personal data outside the EEA by using the services of entities such as SendPulse Inc. We make every effort to ensure an adequate level of personal data protection by carefully analysing the security measures used by these providers. The data transfer is carried out in accordance with standard contractual clauses approved by the European Commission.
2.5 What are your rights and how can you exercise them? [information clause]
You have specific rights regarding your personal data, and we, as their controller, are responsible for exercising these rights in accordance with applicable law. For any questions and requests regarding the scope and exercise of your rights, you can contact us at the following details:
We will respond to the message received from you after verifying your identity.
Access to personal data You have the right to access your data that we store as a controller. You can exercise this right by sending us an e-mail.
Change, rectification, or erasure of personal data You can make changes, including updating, rectifying, or erasing your personal data that we process by sending us an e-mail. You can exercise the right to erasure, for example, when your data is no longer necessary for the purposes for which it was collected by us or when you withdraw your consent for data processing.
Withdrawal of consent In the case of processing personal data based on consent, you can withdraw this consent at any time. We inform you of this right at every moment of collecting consents and allow you to withdraw consent as easily as it was given. To withdraw your consent, please send us an e-mail.
Right to restrict processing or to object to the processing of personal data You have the right to restrict the processing or to object to the processing of your personal data at any time, based on your particular situation, unless processing is required by law.
You may object to the processing of your personal data when:
– the processing of personal data is carried out on the basis of a legitimate interest or for statistical purposes, and the objection is justified by your particular situation;
– personal data is processed for direct marketing purposes, including being profiled for this purpose.
In turn, with regard to the request to restrict data processing, we inform you that it applies when:
– you contest the accuracy of the personal data – for a period enabling us to verify the accuracy of this data;
– the processing is unlawful, and you oppose the erasure of the personal data and request the restriction of their use instead;
– we no longer need the personal data for the purposes of processing, but they are required by you for the establishment, exercise or defence of legal claims;
– you have objected to processing by us pursuant to Article 21(1) of the GDPR, pending the verification of whether our legitimate grounds override your grounds for objection.
Right to data portability You have the right to the portability of data concerning you and you have the right to have this data transmitted through us to another controller, if:
– the processing is based on consent, pursuant to Article 6(1)(a) of the GDPR or Article 9(2)(a) of the GDPR; or
– the processing is based on a contract, pursuant to Article 6(1)(b) of the GDPR; and
– the processing is carried out by automated means.
When exercising the right to data portability, you can request that the personal data be transmitted by us directly to another controller, where technically feasible. The right to data portability must not adversely affect the rights and freedoms of others. If you wish to exercise these rights, please send us an e-mail.
Any other questions, concerns, and complaints Should you have any questions, reservations, or doubts regarding the content of this Privacy Policy or the manner in which personal data is processed, as well as complaints regarding these matters, please send an e-mail with detailed information regarding the complaint. All received complaints will be reviewed and responded to. You also have the right to lodge a complaint with the supervisory authority, which is the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw.
3. Cookies
As indicated in section 2.2. A, this website uses cookies. Therefore, we are informing you about the most important elements of cookies, so that your use of our website is transparent and understandable to you.
3.1 What are cookies?
Cookies are small files saved on your electronic device by the websites you visit. Cookies contain various information that is often essential for a website to function correctly. Cookies are encrypted in such a way that unauthorised persons do not have access to them. Information collected from cookies can only be read by us and – for technical reasons – by trusted partners whose services we use. Most importantly, cookies cannot run programs or transfer viruses to electronic devices.
3.2 For what purpose do we use cookies?
Essential cookies – installed if you have given consent via the settings of the software installed on your electronic device. Within essential cookies, we distinguish between technical and analytical ones.
Technical cookies – are necessary for the website to function correctly.
Cookies are used to:
– ensure the proper display of the website – depending on the device you are using,
– adapt the content to your choices that have technical significance for the website’s operation, e.g., the chosen language,
– remember whether you have given consent to display certain content.
Analytical cookies – are necessary to settle accounts with business partners or to measure the effectiveness of marketing activities without identifying personal data and to improve the functioning of the website.
They can be used to:
– examine statistics regarding website traffic and check traffic sources (referral directions),
– detect various types of abuse, e.g., artificial internet traffic (bots).
3.3. How long are cookies used?
Session cookies – remain on your device until you leave the website or close the software (web browser). These are primarily technical cookies.
Persistent cookies – remain on your device for the period specified in the file’s parameters or until you manually delete them.
3.4 Can I refuse to accept cookies?
You can always change your browser settings and reject requests to install cookies. However, before you decide to change the settings, note that cookies are for your convenience when using the website. Disabling cookies may cause the website to display incorrectly in your browser.
3.5 How do I disable cookies?
You can delete cookies from your browser at any time and block the possibility of their re-installation. Depending on the browser you use, the option to delete or withdraw consent for the installation of cookies may differ. In such a situation, you should consult the user manual available within the given browser on your electronic device.
4. Final Provisions
Are changes to this Privacy Policy possible and when?
We reserve the right to change this Privacy Policy in the event of changes in the technology we use to process personal data, as well as in the event of changes in the methods, purposes, or legal bases for processing personal data, and due to: new legal provisions, new guidelines from authorities responsible for supervising personal data protection processes.
To ensure the best possible contact on the subject of personal data protection, we allow for contact by post or e-mail using the following contact details:
Exodia sp. z o.o.
Krowica Zawodnia 5
62-865 Szczytniki
Poland