Privacy policy
Information Obligations HELLO POLAND sp. z o.o. (LLC), headquartered in Lublin, at Hugo Kołłątaja 6/3 Street, 20-006, Lublin, as the personal data administrator, pursuant to 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, hereby informs that: I. Personal Data Administrator The personal data administrator is HELLO POLAND sp. z o.o. (LLC), headquartered in Lublin, at Hugo Kołłątaja 6/3 Street, 20-006, Lublin, registered with the District Court, Lublin-East in Lublin with headquarters in Świdnik, VI Commercial Division of the National Court Register under number KRS: 0000676429, with share capital of: 10,000 PLN, NIP: 7123338711, REGON: 367183795. For any questions regarding "Personal Data Protection", you can contact us by email: hello.poland.office@gmail.com or by mail at: HELLO POLAND sp. z o.o. (LLC), headquartered in Lublin, at Hugo Kołłątaja 6/3 Street, 20-006, Lublin Contact: hello.poland.office@gmail.com II. PURPOSES OF DATA PROCESSING, LEGAL BASIS AND LEGITIMATE INTERESTS The Administrator processes and will process your personal data:
- For the conclusion and performance of a contract, i.e., on the basis of Art. 6(1)(b) GDPR, including, in particular, legal service agreements or Agreements for the provision of services to the Administrator by service providers;
- For the performance of legal obligations imposed on the personal data administrator in accordance with Art. 6(1)(c) GDPR, arising from European Union law or Polish law;
- For purposes arising from legitimate interests pursued by the Administrator or a third party in accordance with Art. 6(1)(f) GDPR, which the Administrator recognizes as, in particular: assertion of claims, establishment and defense against claims, fraud prevention, ensuring the security of the IT environment, etc., application of internal control systems, Administrator supervision and recording of entry and exit from the Administrator's Platform, determination of conflicts of interest and ethical violations to the extent necessary to combat abuse for archival and statistical purposes, as well as providing services for the benefit of the customer, in situations where the customer's interests are a priority, rights and freedoms of data subjects;
- Recruitment, establishment of cooperation (Art. 6(1)(a) and (b) GDPR), i.e., to the extent specified in the provisions of labor law, the legal basis is the necessity to take measures prior to entering into an agreement (Art. 6(1)(b) GDPR), and in the area beyond labor law, the basis for data processing;
- Taking measures to respond to a sent message (Art. 6(1)(f) GDPR, i.e., the Administrator's legitimate interest in processing correspondence);
- Considering a request based on GDPR (Art. 6(1)(c) GDPR, i.e., the obligation arising from GDPR to provide the data subject with information about actions taken in connection with the request);
- Processing business card data when they have been returned (for correspondence, establishing business contact, and any other purposes for which they were provided to us);
- Reception desk service (Art. 6(1)(f) GDPR for scheduling a meeting with the Administrator's representative and investigating or defending against claims);
- Document archiving (Art. 6(1)(c) or (f) GDPR);
- Conducting own marketing and advertising activities (Art. 6(1)(f) GDPR);
- Carrying out marketing and advertising activities based on separately provided consent (Art. 6(1)(a) GDPR);
- Transmission of commercial information in electronic form accordingly, including newsletter distribution (Art. 10(2) of the Act on Provision of Electronic Services of 18 July 2002 (Art. 10(2) of 2017, item 1219) – Art. 6(1)(a) GDPR);
- Use of telecommunications terminal equipment and automatic calling systems for direct marketing purposes in accordance with Art. 172 of the Act of 16 July 2004 Telecommunications Law (Journal of Laws of 2017, item 1907 as amended) (Art. 172 of the Act of 16 July 2004 Telecommunications Law (Journal of Laws of 2017, item 1907 as amended);
- Adapting the content of the portal segin-roman.com to the interests of Users, including profiling Users of the Administrator's web portal, as well as detecting bots and abuse, as well as statistical measurements and improving customer service;
- Maintaining statistics on the portal segin-roman.com;
- Presenting an offer (if you agree to receive it);
- Sending newsletters (if you agree to receive them).
III. CATEGORIES OF DATA RECIPIENTS The Administrator processes personal data, and in addition, for the purposes of implementing the agreement, the Administrator has the right to exchange collected or processed personal data of subjects, including:
- employees;
- collaborators working with the Administrator;
- other persons providing services on behalf of the Administrator and independently determining the purposes and methods of data processing, customer receivables;
- persons authorized in accordance with applicable law (in particular, courts and state authorities);
- economic information agencies;
- courier companies;
- payment service providers;
- internet service providers, domain and hosting providers, payment system operators, including online, accounting and financial auditors;
- IT service providers, network operators; service providers, including advertising, Google, social networks;
- document retrieval and destruction companies, legal entities cooperating with the Administrator;
- banks, financial institutions, compensation, insurance companies, state authorities, KAS, social security fund;
- as well as other persons authorized by the client.
Data will be transferred to the minimum necessary extent. Processed personal data are not transferred externally to recipients not specified above in a form that would allow any identification of Users. IV. CATEGORIES OF PROCESSED PERSONAL DATA The Administrator processes the following categories of personal data (if they are provided to it):
- first name, last name;
- residential/mailing address;
- e-mail address;
- phone number;
- bank account number;
- TIN (if required for service provision);
- additionally company name, business address, TIN number;
- data of your counterparties according to submitted documents.
In addition, the Administrator may process other categories of personal data if such data cannot be attributed to any of the specified groups, and processing is performed for the purposes specified by this information. V. Where does the Administrator obtain personal data from The Administrator collects personal data or may collect personal data through direct contact, telephone, email, or through a contact form available on the website. Information is obtained primarily by entering into an agreement with the Administrator, sending an offer, sending correspondence, subscribing to a newsletter, submitting an application. Personal data transmission can also be carried out by email or telephone. The Administrator may receive personal data obtained with User consent from cookies and other technical means of recording User preferences on the website. Data may also be obtained from publicly available sources, including web portals and social media sites, if this complies with applicable law. VI. Purpose of data processing Personal data is processed primarily for the performance of a contract or provision of a service by the Administrator, as well as for the purposes described in section II above. With the voluntary consent of the client, data may be processed for marketing and commercial purposes regarding the Administrator's or third parties' services, at least by receiving commercial offers. Personal data may also be processed in accordance with purposes arising from applicable law, including for the protection of employee rights. VII. Rights of data subjects Provision of data is necessary for the conclusion and performance of contracts and provision of services, as well as other purposes described in section II specified by this regulation; in case of non-compliance with data, it is impossible to conclude the above-mentioned agreements and their performance, as well as provision of services and performance of actions described above, unless otherwise provided by applicable law. Each person whose data is processed is granted a number of powers in accordance with GDPR rules:
- Right of access to data, including obtaining a copy of data.
- Right to request data correction.
- Right to data deletion, "right to be forgotten".
- Right to restrict data processing.
- Right to transfer personal data.
- Right to object.
- Right to withdraw consent.
To the extent that personal data is processed on this basis, withdrawal of consent does not affect the lawfulness of processing that was done on the basis of consent before its withdrawal. In case of withdrawal of consent, the Administrator has the right to further process personal data of a specific person if it is necessary:
- to exercise the right to freedom of expression and information;
- to comply with a legal obligation requiring processing, in accordance with European Union law or the law of the member state to which the Administrator is subject, or to perform a task carried out in the public interest or in the exercise of official authority entrusted to the Administrator;
- for reasons of public interest in the field of public health;
- for archiving purposes in the public interest, for scientific research or historical or statistical purposes, insofar as it is likely that the right to delete data will be impossible or seriously hinder the achievement of the purposes of such processing;
- to establish, investigate or defend claims.
Right to confirmation of processing You have the right to obtain from HELLO POLAND Sp. z o. o., based in Lublin, confirmation of whether your personal data is being processed, and if so, you have the right to obtain access to this data and information regarding the processing of your data. Right to withdraw consent You can withdraw your consent to the processing of your personal data at any time. Its withdrawal does not affect the lawfulness of processing of your data done by HELLO POLAND Sp. z o. o., based in Lublin, on the basis of consent before its withdrawal. Cancellation of consent to data processing for the purposes of contract performance may result in termination of service provision by HELLO POLAND Sp. z o. o., based in Lublin. Withdrawal of consent can be made by sending to the email address: hello.poland.office@gmail.com an appropriate statement. Right of access to personal data, restriction of processing, deletion, transfer and their correction HELLO POLAND Sp. z o. o., based in Lublin, informs that you also have the right of access to the content of your data and their correction, deletion ("right to be forgotten"), restriction of their processing, right to data transfer, right to object. Right to file a complaint with the supervisory authority dealing with personal data protection The Administrator informs about correction or deletion of data or restriction of processing that it carried out in accordance with Art. 16 GDPR, Art. 17 GDPR, Art. 18 GDPR, each recipient to whom personal data is disclosed, if it turned out to be impossible or will require disproportionately large efforts. The Administrator informs the data subject about these recipients if the data subject requests this. The Administrator processes submitted requests immediately, but no later than within a month from the moment of their receipt. However, if due to the complex nature of the request or the number of requests, the Administrator cannot process the User's request within the specified period, it will notify the User of the expected extension of the period and indicate the period for processing the request, no more than 2 months. VIII. Technical means The Administrator applies adequate technical and organizational measures to ensure the maximum level of protection for Users of the Administrator's website and transmits their personal data using a contact form, if this will be applied. The Administrator makes every effort to protect personal data and protect them from actions of third parties, and also exercises supervision over data security throughout the entire period of their processing in such a way as to ensure protection from unauthorized access by third parties, damage, distortion, destruction or loss. HELLO POLAND Sp. z o. o., based in Lublin, processes your personal data using computer systems and software that ensures the security of processing this personal data at the highest level. HELLO POLAND Sp. z o. o., based in Lublin, processes your personal data outside the information system using technical and organizational means that ensure a high level of personal data processing security. Data processed by HELLO POLAND Sp. z o. o., based in Lublin, comes directly from you or from your authorized employees, as well as from publicly available websites and registers (from the National Court Register search system and Central Register and Information on Business Activity). IX. Transfer of personal data outside the European Economic Area Personal data is generally not transferred to a third country or international organization outside the European Economic Area (EEA). However, such transfer may occur within the limits described below. Transfer of personal data outside the EEA may occur in connection with the Administrator's use of analytical or advertising services provided by Google LLC, including Google Adwords and Google Analytics. In this case, the transfer is made to the United States of America on the basis of the European Commission's decision (the so-called Privacy Shield), which provides for ensuring an adequate degree of protection of personal data regarding Program participants, including the Provider of the above-mentioned services – Google LLC, Mountain View, California. Data received by Google Analytics is processed in the supplier's country, i.e., in the USA, in compliance with all European Union requirements within the framework of processing by third countries. Detailed information about the services can be obtained at the following address: https://support.google.com/analytics/answer/6004245. In addition, HELLO POLAND Sp. z o. o., based in Lublin, using the Google Analytics system, tracks your traffic to its website. At any time, you can disable tracking of your movements on our site. To do this, use the device at the link: https://tools.google.com/dlpage/gaoptout. X. Cookies What are Cookies and why do we use them? For your convenience, the site uses cookies and similar technologies among other things to adapt the site to the needs of Users and for statistical purposes. Cookies are also used by pages we refer to, showing, for example, multimedia. Cookies are small text files sent by the website visited by an internet User to the User's device. They represent IT data, in particular text files that are stored on the User's end device and are intended for use by websites. They allow, among other things, to determine the type of User's device and view web pages taking into account individual preferences. "Cookies" files most often contain the address of the website, Storage time on the User's device, and its own unique identifier. Use of the website segin-roman.com is considered equivalent to the User's acceptance of cookies that allow management of the Administrator's website. The cookies used are part of the Google Analytics software. Data received by Google Analytics is processed in the supplier's country, i.e., in the USA, in compliance with all European Union requirements within the framework of processing by third countries. Detailed information about the services can be obtained at the following address: https://support.google.com/analytics/answer/6004245. The Service does not collect any information automatically, except for information contained in cookies. Cookie files (so-called "cookies") represent information data, in particular text files that are stored on the User's end device of the service and are intended for use by the service's websites. Cookies usually contain the name of the website from which they came, their storage time on the end device, and a unique number. The entity that places cookie files on the User's end device of the service and obtains access to them is the service operator, i.e., the Administrator. Cookie files are used to improve the functionality of the site (creating statistics that help understand how Users of the site use the site, which allows improving its structure) and maintain the User's session on the site (after logging in), thanks to which the User does not need to re-enter login and password on each page of the site. Within the service, two main types of cookie files are used: "session" (Session cookies) and "persistent" (persistent cookies).
- "Session" files are temporary files that are stored on the User's end device until you log out, leave the website, or turn off the software (web browser).
- "Persistent" cookie files are stored on the User's end device for the time specified in the cookie file parameters, or until the User deletes them.
In many cases, software for viewing web pages (web browser) by default allows storing cookie files on the User's end device. Users of the site can change settings related to cookie files at any time. These settings can be changed, in particular, in such a way as to block automatic processing of cookie files in web browser settings or notify about their each placement on the User's device of the site. Detailed information about the possibilities and ways of using cookie files is available in the software (web browser) settings. Restriction of the use of cookie files in the web browser may affect some functionality available on the service's websites. The Administrator may use cookie files for the purposes of:
- website customization;
- recognition of the User's device of the site and its location and accordingly viewing the web page adapted to its individual needs;
- remembering the history of visited pages in the service for content recommendations;
- User authentication on the site and ensuring support of the User's session on the site;
- settings of selected functions of the site, which allows, in particular, to verify the authenticity of the browser session-ensuring security and reliability;
- optimization and increase of efficiency of provided services;
- analysis and audience research;
- maintaining statistics of Users visiting your site;
- site analysis and research;
- correct operation and site support;
- marketing and advertising;
- security, for example, used to detect fraud with authentication;
- necessary for the operation of the site, for example, authenticating cookie files used for services requiring authentication.
"Cookies" used by website operator partners are governed by their own privacy policy. Deletion / enabling / blocking cookie files in the web browser The level of protection from cookies can be set in your web browser up to complete blocking of cookie files. This increases the level of security and data protection but may result in some site functions not working. In the most popular browsers, among other things, there is the possibility of:
- accepting the use of cookies, which allows full use of the possibilities offered by websites;
- managing cookies-files of selected individual sites;
- specifying parameters for different types of cookie files, including for accepting persistent files as session files;
- deleting or blocking cookies.
XI. DATA RETENTION PERIOD Personal data will be processed for the period in accordance with applicable law or in certain cases until the moment of withdrawal of consent. Personal data in accordance with applicable law will be processed as long as required by relevant laws, in particular tax and accounting, and as long as it is necessary to establish, investigate or defend claims and, in particular: a) purpose of contract/contracts performance – until the moment of their termination or expiration of their validity period; b) establishment, investigation or defense against claims – until the expiration of the statute of limitations for claims or objections; c) purpose of performance of legal obligations imposed on the Administrator – until the expiration of the period of obligations arising from the provisions of the Law. In case of consent to the processing of personal data, as a rule, until the moment of objection or withdrawal of consent to the processing of personal data, if we processed your data on such a basis. Your personal data is subject to profiling from the point of view of personal preferences and interests based on analytical data collected on the site segin-roman.com and for statistical and marketing purposes, for newsletter distribution purposes (in case of consent). XII. Whether and when the privacy policy can be changed The Administrator will take measures aimed at regular review of this policy and its changes in cases when this turns out to be necessary or desirable taking into account: new laws, new principles of authorities responsible for supervision over personal data protection processes, best practices used in the field of personal data protection. The Administrator reserves the possibility of changing the privacy policy at any time, and in particular in case of changes in the technology by means of which we process personal data (provided that its change affects the content of this document), as well as in case of changes in methods, purposes and legal basis for processing personal data. XIII. Final provisions Use of the website segin-roman.com and provision of your personal data for form purposes is completely voluntary. In some cases, provision of data may be needed to achieve a certain purpose described in the privacy policy or applicable law. At any time, you also have the right to contact us for additional information. The privacy policy in the field of processing is also available online at segin-roman.com.