Privacy policy

§1
Introduction

This privacy policy (hereinafter referred to as the „Policy”) contains information related to your personal data processing by the data controller defined hereinbelow, as well as cookie policy.

§2
Personal data processing

Due to the application as of 25th May 2018 of the 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 referred to as „GDPR”) (Official Journal of the EU, L of 4th May 2016), pursuant to Art. 13 of GDPR and in connection with the application of the personal data protection act of 10th May 2018 (Journal of Laws of 2018, item 1000, as amended), we present hereinbelow the information on your personal data processing.

I – Controller:

Sanmargar Team sp. z o.o., with its registered seat in Warsaw at ul. Brzeska 2, 03-973 Warszawa, entered into the register of entrepreneurs kept by District Court for the capital city of Warsaw, 12th Commercial Department of the National Court Register under No. 0000244506, with its share capital amounting to PLN 66,500.0, VAT No: PL526-288-17-54 and e-mail address: listy@sanmargar.com (hereinafter referred to as „ADO”) shall be your personal data controller.

II – Aim, data categories and the basis of data processing:

Your personal data shall be processed for the following reasons:

  • Website management, based on the legitimate interest of the controller (Art. (6)(1)(f) of GDPR), which constitutes in the provision of proper Website functioning – IP address, session data, information about the browser – the data is collected automatically
  • ensurance of Website and other users’ security – based on the legitimate interest of the controller (Art. 6(1)(f)),which constitutes in ensuring the Website and other users’ security – automatic collection of IP address, browser name and type, type of operating system
  • the use of the contact form by the user. Personal data is processed pursuant to Art. 6(1)(f) of GDPR being the legitimate interest of the Controller.
  • if you are a subscriber of our newsletter – sending to your e-mail address information about interesting events pursuant to the legitimate interest of the controller (Art. 6(1)(f) of GDPR in connection with your consent to receive such information pursuant to Art. 10 of the act on rendering electronic services – your e-mail address.

III – Data recipients:

  • your personal data may be transmitted to a hosting company, as well as public and private entities if such obligation results from generally applicable law provisions.

The transmission of data to the entities indicated hereinabove shall be executed only upon an entrustment agreement concluded between ADO and the entities indicated hereinabove. Entities entitled to access to your personal data pursuant to generally applicable law shall be an exception.

IV – Data storage period

  • Website management – until the data becomes useless for us
  • provision of Website and users’ security – until the data becomes useless for us
  • data processed in order to send you information about the events – until you object or unsubscribe from the newsletter
  • If the consent is the basis for data processing, the period shall continue until the consent is withdrawn and upon such a withdrawal, it shall last for a period of time equal to the limitation period which may be borne by the Controller and which may be claimed from the Controller. Unless a special provision provides otherwise, the limitation period is 6 years, and for claims for periodic benefits and claims related to business activity – 3 years.

V – Transmission of personal data to third countries

Your personal data shall not be transmitted to third countries (outside EEA).

VI – Your rights:

Please be informed that you are entitled to:

  • Access your data and copies of data,
  • Correct your data,
  • Remove your data – if you deem we are not entitled to process your data you may request its removal,
  • Restrict data processing – you may request the restriction of personal data to the storage of agreed activities if your data is incorrect or its processing is illegal, if you don’t want your data to be removed, since it’s necessary to exercise, establish or defend a claim or is needed for the time of examining the reasons of an appeal,
  • Appeal – you may raise an appeal against processing of your data for marketing purposes, if such processing results from a legitimate interest of the controller and we shall refrain from such data processing. You may also raise an appeal against processing your data for other purposes, including profiling of your data, if the legal basis for processing is the legitimate interest of the controller. A request shall contain the justification of an appeal by defining the exceptional situation being the cause of an appeal. The appeal shall not be taken into consideration if we prove that our legitimate interest is superior to your claim or that your data is needed to exercise, establish or defend a claim against you.
  • Data transfer – the right to data transfer relates to the data processed automatically, which were made available to us based on a consent or a contract. You may receive the data in a structured format, e.g. .xml or we may send it directly to the indicated data controller.
  • File a claim – as of 25th May 2018 you may file a claim to the President of the Personal Data Protection Office or any other supervisory body, should you deem your data is processed illegally,
  • If your data is processed by us based on your consent, you may withdraw the consent at any time, which shall result in the cessation of data processing, if there is no other legal basis for doing it. The withdrawal of the consent does not affect the legitimacy of  data processing exercised before the with drawal.

If you would like to exercise your rights, please send a request to the following e-mail address: listy@sanmargar.com .

VII – Data provision voluntariness/requirement clause

  • Provision of your personal data (e-mail address) for the purposes of sending you information about events is the requirement for obtaining our newsletter containing such information. It won’t be possible without this data. You may object against such data processing at any time and we are ready to consider such an objection. You may unsubscribe from the newsletter at any time by clicking the deactivation link present in every e-mail message.
  • Providing your data (name, surname, company, e-mail address and phone number) in the contact form – it will not be possible to use the form without this data. You are entitled to withdraw the consent.
  • In all other cases the provision of data is voluntary.

VIII – Automated personal data processing

Your personal data is processed in an automated manner via profiling, but this shall not result in producing legal effects towards you, nor affect you in any other way.

§3
Cookies

  • By starting to use the website, you accept by activating the “Accept” button the placement of cookies on your device (e.g. computer, phone) by the website.
  • We use cookies in order to guarantee the highest possible website convenience level. Cookies are small text files sent by the www server and stored by the browser computer software. If the browser connects to the website again, the website recognises the type of device used for the connection. The parameters allow for reading the data contained in the files only by the server which created them. Cookies improve browsing websites visited before.
  • The collected data is used for monitoring and verifying the way the users browse our websites in order to improve their functioning, ensuring more effective and trouble-free navigation.
  • Monitoring of user information is performed with the use of Google Analytics tool, which registers the users’ behaviour on the website. We implemented IP addresses anonymization in Google Analytics, therefore we collect only aggregated, anonymous data, i.e. the data which doesn’t allow the identification of particular users.
  • To sum up, the following cookies are used on our website:
    – „necessary” cookie files enabling the usage of the services available as a part of the website, e.g. authentication cookies used for services that require authentication as a part of the website;
    – cookies to ensure security, e.g. used to detect fraud in the field of website authentication;
    -„performance” cookies enabling the collection of data on the manner of website usage (we use Google Analytics for statistics purposes);
    – „functional” cookies, enabling „saving” user-selected settings and personalising the user interface, e.g. language or region the user comes from, font size, website layout, etc.;
  • The user may turn off or restore the cookies at any time by changing the browser settings. Cookie management tips are available on the website: http://www.allaboutcookies.org/manage-cookies