The policy sets out the rules for the processing of personal data of users of the website located at http://www.salvena.pl/ (Website) operated by Salvena Justyna Galas Agnieszka Ożóg spółka cywilna with its registered office in Kraków (Salvena). The Website User is anyone who uses it in any way.
The policy also covers the issues of processing Users' personal data related to Salvena's account management on Facebook (Facebook, FB).
The policy also includes information on the use of cookies and analytical tools.
1. Identity and contact details of the personal data administrator
The administrators (co-controllers) of your personal data are: Justyna Galas, holding NIP 9441646291 and Agnieszka Ożóg, holding NIP 9441043003, running a civil law partnership Salvena Justyna Galas Agnieszka Ożóg spółka cywilna, ul. Żaków Krakowskich 6, 30-441 Kraków, with NIP 6793024115 and REGON 121083883.
The contact with the administrators can be in particular at the phone number: 12 256 10 52 or e-mail address: office@salvena.pl
Your rights in the field of personal data protection, including any reports or correspondence in this regard, can be made and directed to each of the controllers.
2. Where do we get your data from?
We can receive your data from you by filling out the contact form on the Website.
You can also simply write to us or call - using the e-mail, post and telephone addresses provided on the Website. Such correspondence can also be a source of data for us.
In addition, we may have received personal data from you via Facebook.
The analytical tools used on the Website, however, provide us with information on how you use the Website and what actions you take on it.
3. How we protect your personal data
We ensure that the protection and security of your personal data are an important element in our business operations and are taken into account when designing the procedures and solutions we use.
In implementing these assumptions, we have used technical and organizational measures to ensure the protection of processed data in accordance with the requirements set out in the provisions on the protection of personal data, including GDPR, which are adequate to the risk of violation of your rights and freedoms.
In particular, we have secured the data against disclosure to unauthorized persons, unauthorized removal or use, against processing in violation of applicable law and the change, loss, damage or destruction of data.
Further, we disclose your data to third parties only when it is necessary from the point of view of our business, and employees have access to your data and associates who have received the appropriate authorizations and signed the relevant commitments to protect personal data and keep it confidential.
We respect your rights in the field of personal data protection, and our technical solutions are consistent with the current state of technology.
4. Legal basis and purposes of personal data processing
Personal data is processed in accordance with 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 ( General Data Protection Regulation) [hereinafter: the GDPR] and the Personal Data Protection Act of 10 May 2018.
The legal basis for data processing is:
A. Article 6 para. 1 point b) GDPR: Processing is necessary [...] to take action at the request of the data subject before the conclusion of the contract.
Processing purposes based on the above basis:
B. Article 6 1 point f) GDPR: Processing is necessary for purposes resulting from legitimate interests pursued by the administrator.
Processing purposes based on the above basis.
5. Information on the categories of recipients of personal data
Personal data may be shared or entrusted by us in connection with negotiations and arrangements regarding the conclusion of a contract for the provision of services by us and for purposes arising from our legitimate interests.
The recipients of your personal data may be entities cooperating with Salvena, including providers of software supporting internal business processes, hosting service providers, email service providers, IT companies, mail and courier companies, accounting company, law firm, Facebook Ireland Ltd./Facebook Inc., Google Inc.
We do not transfer your data outside the European Economic Area (EEA).
6. Criteria for determining the period for which personal data will be stored
7. Information on the rights of the data subject
You have the right to:
in accordance with the Regulation.
In order to exercise your rights, please contact us at our address given in point 1 above.
8. Right to object
To the extent that personal data is processed on the basis of art. 6 clause 1 lit. f) GDPR, you have the right to object to their processing at any time - for reasons related to your particular situation. You may no longer process your data, unless we can prove that there are valid legitimate grounds for such processing, overriding your interests, rights and freedoms, or that there are grounds for establishing, pursuing or defending claims.
To the extent that personal data is processed for the purposes of direct marketing, you have the right to object to such processing at any time. Then we are no longer allowed to process your data for such purposes.
9. Information on the right to lodge a complaint with a supervisory authority
You have the right to lodge a complaint with a supervisory authority, in particular in a Member State of the European Union of your habitual residence, place of work or place of alleged infringement, if you believe that the processing of your data violates the GDPR.
In Poland, the powers of the supervisory body are held by the President of the Office for Personal Data Protection (Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw).
10. Profiling
We do not use automated decision making based on collected personal data, in particular profiling that would have legal effects on you or in a similar way significantly affect you.
However, we use analytical tools described below in point 15, under which, based on anonymized data, we investigate how Users use the Website.
11. Information whether providing personal data is a statutory or contractual requirement or a condition for concluding a contract and whether the data subject is required to provide it and what are the possible consequences of not providing data
Providing personal data is in principle voluntary.
Providing personal data required by us to conclude a contract on the provision of services by us is necessary to use these services.
12. Contact form on the Website
You can contact us quickly and efficiently via the contact form available on the Website.
By sending us the completed form, you agree to be contacted using the data provided in the form (including within the meaning of the Act on the provision of electronic services and the Telecommunications Law). This consent is voluntary - we respect your privacy and you decide to contact us.
You can revoke your consent at any time by contacting us via the SZC addresses available on the Website or in this Policy. Withdrawal of consent does not affect the actions taken by us on the basis of consent before its withdrawal.
The basis for data processing: depending on the content of the contact - its subject and detail, and effect: Article 6 para. 1 point b) [answering contact from potential clients regarding inquiries about specific services] or f) GDPR [direct marketing: answering contact regarding general inquiries regarding our activities, storing inquiries and contacts regarding specific services, on the basis of which the contract was concluded].
13. Contact using the addresses available on the Website
You can write to us or call us using the addresses given on the Website in the Contact tab.
By sending us this information, you agree to be contacted using the same or specified communication channel (including within the meaning of the Act on the provision of electronic services and the Telecommunications Law). This consent is voluntary - we respect your privacy and you decide to contact us.
You can revoke your consent at any time by contacting us via the SZC addresses available on the Website or in this Policy. Withdrawal of consent does not affect the actions taken by us on the basis of consent before its withdrawal.
The basis for data processing: depending on the content of the contact - its subject and detail, and effect: Article 6 para. 1 point b) [answering contact from potential clients regarding inquiries about specific services] or f) GDPR [direct marketing: answering contact regarding general inquiries regarding our activities, storing inquiries and contacts regarding specific services, on the basis of which the contract was concluded].
14. Cookies files
Please be advised that when using the Website, short IT data (so-called cookies) is installed on your device. Cookies should be understood as IT data,
in particular text files stored on Users' end devices
and intended for the use of websites. Cookies usually contain the name of the website from which they originate, their storage time on the end device and a unique number.
The cookies used have the following functions:
ensuring the safe use of the Website,
providing some Website functionalities,
collecting information on how Users use the Website (anonymized statistical data); Google Analytics, Google Tag Manager.
The main types of cookies that can be distinguished by their storage time:
session - temporary files that are stored on the User's end device until logging out, leaving the website or changing settings in the browser.
permanent - they are stored on the User's end device for the time specified in the cookie file parameters or until they are deleted by the User.
The maximum storage time for cookies is 2 years.
The use of cookies allows us to improve the structure of the Website and its content and is carried out without us processing data that identifies individual Users.
By using the Website, while using the settings of your web browser allowing cookies, you agree (including within the meaning of the Telecommunications Act) to install cookies, store them on the terminal device and access them. Consent is voluntary and you can withdraw it by changing your cookie settings and / or stop using the Website. Withdrawal of consent does not affect the lawfulness of actions taken on the basis of consent before its withdrawal.
You can change cookies settings at any time by specifying the storage conditions or accessing cookies using the web browser software settings, including disable the option of accepting cookies in such a way as to block the automatic handling of cookies or to inform you whenever they are sent to the end device and change their storage time. You can also delete cookies placed on your device after visiting the Website.
Restricting the use of cookies may affect some of the functionalities available on the Website.
Detailed information on managing various cookies is available in the software settings of individual web browsers.
Changes in settings and deleting cookies:
Chrome > http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647;
Internet Explorer https://support.microsoft.com/pl-pl/help/278835/how-to-delete-cookie-files-in-internet-explorer
Safari > http://support.apple.com/kb/PH5042
15. Analytical tools: Google Analytics, Google Tag Manager
Using the Website runs the Google Analytics analytical tool (and its cookies), aimed at analyzing the way you use the Website. As part of Google Analytics, data is obtained as a result of connecting a given IP address to a Google server and downloading this address by Google, which uses this information to create reports and provide other services related to the use of the Internet. We have activated the option of animating IP addresses provided by this tool; Anonymization policies: https://support.google.com/analytics/answer/2763052
We use Google Analytics to obtain statistical analysis on how Users use the Website. We use Google Analytics without any processing of data that allows us to identify individual Users.
Google Analytics cookies are stored for up to 2 years.
The Google Analytics tool is provided by Google (Google Inc. 1600 Amphitheater Parkway, Mountain View, CA 94043, USA).
A detailed description of Google cookies can be found here:
https://policies.google.com/technologies/types?hl=pl, https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage?hl=pl
Further information on managing Google cookies can be found here:
https://policies.google.com/technologies/managing?hl=pl
We also signal that Google is an independent administrator of many personal data that it obtains from other sources or which it has in connection with other activities undertaken as part of its operations and using its cookies. By combining his data and using his technologies, he can obtain additional information about people using the Internet and process and transfer this data outside the EEA, which, however, we have no influence over and what remains outside the scope of our activity. However, we inform you about this, because this processing takes place in connection with our activities and use of the Google service on the Website.
Google Inc. based in the US joined the EU-US Privacy Shield Framework. The agreement between the EU Commission and the USA states the appropriate level of protection of personal data by participants in this program.
You can read more about data processing by Google here:
https://policies.google.com/privacy?hl=pl#infochoices.
By using the Website, while applying the settings of your web browser allowing cookies, you agree to the use of Google Analytics. Consent is voluntary and you can withdraw it by changing the settings of cookies (point 14 above) and / or stopping the use of the Website, possibly by launching tools to block tracking systems. Withdrawal of consent does not affect the lawfulness of actions taken on the basis of consent before its withdrawal.
Legal basis for data processing: art. 6 clause 1 point f) GDPR [direct marketing: obtaining anonymous statistical data on the use of the Website by Users].
We also use Google Tag Manager - a tool that simplifies the configuration of Google Analytics and other similar tools. Thanks to its operation, there is no need to involve a programmer for these purposes. GTM works on data collected by other tools.
16. Facebook
We run a Facebook fanpage, where registered Facebook users can, for example, leave their entries, follow us, recommend or "like" us, as well as contact us via messenger. Such activity may result in users providing personal data to us. We also have access to statistics offered by Facebook for the business account through which the fan page is run (statistics are presented to us in anonymous form).
When you use our fan page on FB, regardless of whether you are a registered FB user or not, your personal data is / can also be processed by this Portal (Facebook Ireland Ltd. at EU level and Facebook Inc. in the remaining scope ), which is an independent administrator of your personal data in the scope of its activities and using its cookies. Due to the nature of this activity, Facebook also has access to many other data, including personal data, and by combining the data it possesses, it can obtain additional information about people using the Internet and transfer it outside the EEA. However, this is beyond our control and it remains outside the scope of our activities. However, we inform you about this, because this processing takes place in connection with our activity on FB.
Facebook Inc. based in the US joined the EU-US Privacy Shield Framework. The agreement between the EU Commission and the USA states the appropriate level of protection of personal data on the part of participants in this program.
More about data processing by FB: https://www.facebook.com/about/privacy
The basis for data processing: art. 6 clause 1 point f) GDPR [direct marketing - conducting SZC marketing activity on Facebook].
17. Third parties
We carefully select the entities with whom we cooperate, including verifying the links to other websites posted on the Website. However, we are not responsible for the standards and data protection policy that these entities apply. We recommend that you verify each of our partners on your own and, as a consequence, make an independent decision whether you want to entrust your personal data to him.
18. Change of privacy policy
We want to continually develop ourselves in the interests of the security of data entrusted to us.
We may change the Privacy Policy, if required by applicable law, will change: our data or data of other entities listed in the policy, the type of services rendered, or the technological conditions of the Website. The change may also take place in order to improve the standard of information or protection.
We will inform you about the change on the Website during the first entry after the change of the Privacy Policy.