Privacy policy
GENERAL PROVISIONS
This privacy policy of the Website is for information purposes only, which means that it is not a source of obligations for persons using the Website. The privacy policy primarily contains the principles regarding the processing of personal data collected by the Administrator on the Website, including the basis, purposes and period of processing personal data and the rights of data subjects, as well as information on the use of Cookies and similar technologies and analytical tools on the Website.
The administrator of personal data collected via the Website is InEativena Sp. zoo with its registered office at ul. Dybowskiego 13/2, 62-800 Kalisz – hereinafter referred to as the ” Administrator ” and being at the same time the Owner of the Website.
Contact details of the Data Protection Officer: Mariola Wegner, e-mail address: personal.data@ineativena.com
Personal data on the Website are processed by the Administrator in accordance with applicable legal provisions, in particular in accordance with 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 (General Data Protection Regulation) – hereinafter referred to as ” GDPR ” or ” GDPR Regulation “. Official text of the GDPR Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679 .
The use of the Website is voluntary. Similarly, the provision of personal data by the user using the Website is voluntary, with the proviso that failure to provide specific data required to use a specific functionality of the Website may result in the inability to use that functionality (e.g. contact form). In such a case, providing personal data is a contractual requirement and if the data subject wants to use a specific functionality provided on the Website by the Administrator, they are obliged to provide the required data. Each time, the scope of data required to use the functionality of the Website is indicated by the Administrator on the Website (e.g. before filling out the contact form).
The Administrator takes special care to protect the interests of persons whose personal data he processes, and in particular is responsible and ensures that the data he collects are: (1) processed in accordance with the law; (2) collected for specified, lawful purposes and not subject to further processing incompatible with these purposes; (3) substantively correct and adequate in relation to the purposes for which they are processed; (4) stored in a form which allows identification of persons to whom they relate, no longer than is necessary to achieve the purpose of processing and (5) processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organizational measures.
Taking into account the nature, scope, context and purposes of processing and the risk of violating the rights or freedoms of natural persons with varying probability and severity of threat, the Controller implements appropriate technical and organizational measures to ensure that processing is carried out in accordance with the GDPR Regulation and to be able to demonstrate this. These measures are reviewed and updated as necessary. The Controller applies technical measures to prevent unauthorized persons from obtaining and modifying personal data sent electronically.
All words, phrases and acronyms appearing in this privacy policy and beginning with a capital letter should be understood in accordance with their meanings arising from this document.
BASICS OF DATA PROCESSING
The Controller is entitled to process personal data in cases where – and to the extent that – at least one of the following conditions is met: (1) the data subject has consented to the processing of his or her personal data for one or more specific purposes; (2) processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary to fulfil a legal obligation to which the Controller is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject requiring protection of personal data, in particular where that person is a child.
The processing of personal data by the Administrator requires each time the existence of at least one of the bases indicated above. The specific bases for the processing of personal data of users of the Website by the Administrator are indicated in the next point of the privacy policy – in relation to the given purpose of processing personal data by the Administrator.
PURPOSE, BASIS AND PERIOD OF DATA PROCESSING ON THE WEBSITE
Each time, the purpose, basis and period, as well as the recipients of personal data processed by the Administrator result from the actions taken by a given user on the Website. The Administrator may process personal data on the Website for the following purposes, on the following bases and for the period in accordance with the table below:
The purpose of data processing | Legal basis for data processing | Data storage period |
Using electronic services provided by the Administrator on the Website | Article 6(1)(b) of the GDPR Regulation (performance of a contract) – processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject before entering into a contract, such as responding to an inquiry sent by the user via the contact form | The data is stored for the period necessary to execute, terminate or otherwise expire the contract concluded with the Administrator, e.g. for the time needed to provide the user with a response to an inquiry sent via the contact form. |
direct marketing | Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes resulting from the legitimate interests of the Administrator – consisting in taking care of the interests and good image of the Administrator and striving to provide services | Data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims against the data subject resulting from the business activity conducted by the Administrator. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to conducting business activity is three years). The administrator may not process data for direct marketing purposes in the event of an effective objection in this respect by the data subject. |
Marketing | Article 6(1)(a) of the GDPR Regulation (consent) – the data subject has consented to the processing of his or her personal data for marketing purposes by the Controller | The data is stored until the data subject withdraws consent to further processing of his or her data for this purpose. |
Determining, pursuing or defending claims that may be raised by the Administrator or that may be raised against the Administrator | Article 6 paragraph 1 letter f) of the GDPR Regulation – processing is necessary for the purposes of the legitimate interests of the Administrator – consisting in determining, pursuing or defending claims that may be raised by the Administrator or that may be raised against the Administrator | Data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for claims against the data subject resulting from the business activity conducted by the Administrator. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims that may be brought against the Administrator is six years). |
Using the Website and ensuring its proper functioning | Article 6 paragraph 1 letter f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes resulting from the legitimate interests of the Administrator – consisting in running and maintaining the Website | Data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for the Administrator’s claims against the data subject, resulting from the Administrator’s business activity. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years). |
Maintaining statistics and analyzing traffic on the Website | Article 6 paragraph 1 letter f) of the GDPR Regulation (legitimate interest of the administrator) – processing is necessary for the purposes resulting from the legitimate interests of the Administrator – consisting in keeping statistics and analyzing traffic on the Website in order to improve the functioning of the Website | Data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than the limitation period for the Administrator’s claims against the data subject, resulting from the Administrator’s business activity. The limitation period is specified by law, in particular the Civil Code (the basic limitation period for claims related to business activity is three years). |
RECIPIENTS OF DATA ON THE WEBSITE
For the proper functioning of the Website, it is necessary for the Administrator to use the services of external entities (such as a software provider). The Administrator only uses the services of such processors who provide sufficient guarantees for the implementation of appropriate technical and organizational measures so that the processing meets the requirements of the GDPR Regulation and protects the rights of data subjects.
Personal data may be transferred by the Administrator to a third country, whereby the Administrator ensures that in such a case it will take place in relation to a country ensuring an adequate level of protection – in accordance with the GDPR Regulation, and in the case of other countries, that the transfer will take place on the basis of standard data protection clauses. The Administrator ensures that the data subject has the possibility to obtain a copy of their data. The Administrator transfers the collected personal data only in the case and to the extent necessary to achieve a given purpose of data processing in accordance with this privacy policy.
The Controller does not transfer data in every case and not to all recipients or categories of recipients indicated in the privacy policy – the Controller transfers data only when it is necessary to achieve a given purpose of personal data processing and only to the extent necessary to achieve it.
Personal data of users of the Website may be transferred to the following recipients or categories of recipients:
- service providers supplying the Administrator with technical, IT and organizational solutions enabling the Administrator to conduct business activities, including its Website and electronic services (in particular, suppliers of computer software for running the Website, e-mail and hosting providers, and suppliers of software for managing the company and providing technical support to the Administrator) – the Administrator makes the collected personal data of the user available to a selected supplier acting on its behalf only in the case and to the extent necessary to achieve a given purpose of data processing in accordance with this privacy policy.
- legal and advisory service providers providing the Administrator with legal or advisory support (in particular a law firm) – the Administrator makes the collected personal data of the user available to a selected provider acting on its behalf only
in the case and to the extent necessary to achieve a given purpose of data processing in accordance with this privacy policy. - providers of social plugins, scripts and other similar tools placed on the Website that enable the browser of the person visiting the Website to download content from the providers of said plugins :
- Meta Platforms Ireland Ltd. – The Administrator uses social plugins from Facebook on the Website (e.g. the Like button, Share button) and therefore collects and shares personal data of the user using the Website to Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy policies available here: https://www.facebook.com/about/privacy/ (this data includes information on activities on the Website – including information about the device, websites visited, advertisements displayed and the manner of using the services – regardless of whether the user has a Facebook account or is logged in to Facebook).
PROFILING
The GDPR Regulation imposes on the Controller the obligation to inform about automated decision-making, including profiling, referred to in Article 22 paragraphs 1 and 4 of the GDPR Regulation, and – at least in these cases – relevant information on the principles of their making, as well as on the significance and foreseeable consequences of such processing for the data subject. With this in mind, the Controller provides information on possible profiling in this section of the privacy policy.
The Administrator may use profiling on the Website for direct marketing purposes, but decisions made on its basis by the Administrator do not concern the conclusion or refusal to conclude an agreement or the possibility of using electronic services on the Website. The effect of using profiling on the Website may be, for example, granting a given person a discount, sending them a discount code, reminding them about unfinished activities on the Website, sending a proposal for a service that may meet the interests or preferences of a given person or proposing better conditions compared to the Administrator’s standard offer. Despite profiling, the given person freely decides whether they will want to use the discount received in this way or the Administrator’s offer.
Profiling on the Website consists of automatic analysis or forecasting of a given person’s behavior on the Website, e.g. by analyzing the previous history of activity on the Website. The condition for such profiling is that the Administrator has the personal data of a given person in order to be able to send them, e.g. a discount code or an offer.
The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her or significantly affects him or her in a similar manner.
DATA SUBJECT RIGHTS
The right to access, rectify, limit, delete or transfer – the data subject has the right to request from the Controller access to their personal data, their rectification, deletion (“the right to be forgotten”) or restriction of processing and has the right to object to the processing, as well as the right to transfer their data. Detailed conditions for the exercise of the above-mentioned rights are indicated in Articles 15-21 of the GDPR Regulation.
The right to withdraw consent at any time – a person whose data is processed by the Controller on the basis of expressed consent (based on art. 6 sec. 1 letter a) or art. 9 sec. 2 letter a) of the GDPR Regulation) has the right to withdraw consent at any time without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal.
The right to lodge a complaint with a supervisory authority – a person whose data is processed by the Administrator has the right to lodge a complaint with a supervisory authority in the manner and procedure specified in the provisions of the GDPR Regulation and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Personal Data Protection Office.
Right to object – the data subject has the right to object at any time – for reasons relating to his or her particular situation – to the processing of his or her personal data based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interest of the controller), including profiling based on these provisions. In such a case, the controller is no longer allowed to process the personal data, unless he or she demonstrates compelling legitimate grounds for processing that override the interests, rights and freedoms of the data subject, or grounds for establishing, pursuing or defending claims.
Right to object to direct marketing – if personal data are processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of his or her personal data for the purposes of such marketing, including profiling, to the extent that the processing is related to such direct marketing.
In order to exercise the rights referred to in this point of the privacy policy, you can contact the Administrator by sending an appropriate message in writing or by e-mail to the Administrator’s address indicated at the beginning of the privacy policy.
WEBSITE COOKIES AND ANALYTICS
Cookies are small text information in the form of text files, sent by the server and saved on the side of the person visiting the Website (e.g. on the hard drive of a computer, laptop, or on the memory card of a smartphone – depending on what device the visitor to our Website uses). Detailed information on Cookies, as well as the history of their creation can be found here: https://pl.wikipedia.org/wiki/HTTP_cookie .
Cookies that may be sent by the Website can be divided into different types, according to the following criteria:
According to their supplier : 1) own (created by the Administrator’s Website) and 2) belonging to third parties/entities (other than the Administrator) | Due to their storage period on the device of the person visiting the Website: 1) session (stored until you leave the Website or close your web browser) and 2) persistent (stored for a specified period of time, defined by the parameters of each file or until manually deleted) | Due to the purpose of their use : 1) necessary (enabling the proper functioning of the Website), 2) functional/preferential (enabling customization of the Website to the preferences of the person visiting the site), 3) analytical and performance (collecting information on how the Website is used), |
The Administrator may process data contained in Cookies when visitors use the Website for the following specific purposes:
The purposes of using Cookies on the Administrator’s Website | remembering data from completed forms and surveys (necessary and/or functional/preference cookies) |
adapting the content of the Website to the individual preferences of the user (e.g. regarding colours, font size, page layout) and optimising the use of the Website (functional/preference Cookies) | |
keeping anonymous statistics showing how the Website is used (analytical and performance Cookies) | |
displaying and rendering advertisements, limiting the number of times an advertisement is displayed and ignoring advertisements that the user does not want to see, measuring the effectiveness of advertisements, and personalising advertisements, i.e. examining the behavioural characteristics of visitors to the Website by anonymously analysing their activities (e.g. repeated visits to certain pages, keywords, etc.) in order to create their profile and provide them with advertisements tailored to their expected interests, also when they visit other websites in the advertising network of Google Ireland Ltd., Meta Platforms Ireland Ltd. and LinkedIn Ireland Unlimited Company (marketing, advertising and social cookies) |
You can check in the most popular web browsers which Cookies (including the period of operation of Cookies and their provider) are currently being sent by the Website in the following way:
In Chrome : (1) in the address bar, click the lock icon on the left, (2) go to the “Cookies” tab. | In Firefox : (1) in the address bar, click the shield icon on the left, (2) go to the “Allowed” or “Blocked” tab, (3) click the “Cross-site tracking cookies”, “Social media trackers” or “Content with trackers” box | In Internet Explorer : (1) click the “Tools” menu, (2) go to the “Internet Options” tab, (3) go to the “General” tab, (4) go to the “Settings” tab, (5) click the “View files” box |
In the Opera browser : (1) click the lock icon on the left in the address bar, (2) go to the “Cookies” tab. | in Safari : (1) click the “Preferences” menu, (2) go to the “Privacy” tab, (3) click the “Manage website data” box | Regardless of the browser, using the tools available, for example, on the website : https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/ |
By default, most web browsers available on the market accept the saving of Cookies by default. Everyone has the ability to define the terms of using Cookies using the settings of their own web browser. This means that you can, for example, partially limit (e.g. temporarily) or completely disable the ability to save Cookies – in the latter case, however, this may affect some functionalities of the Website.
The settings of the Internet browser in terms of Cookies are important in terms of consent to the use
of Cookies by our Website – in accordance with the regulations, such consent may also be expressed through the settings of the Internet browser. Detailed information on changing the settings for Cookies and their independent removal in the most popular Internet browsers is available in the help section of the Internet browser and on the following pages (just click on the appropriate link):
The Administrator may use Google Analytics, Universal Analytics services provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) on the Website. These services help the Administrator to conduct statistics and analyze traffic on the Website. The collected data is processed as part of the above services to generate statistics that help in administering the Website and analyzing traffic on the Website. This data is of aggregate nature. By using the above services on the Website, the Administrator collects such data as the sources and medium of acquiring visitors to the Website and the manner of their behavior on the Website, information on the devices
and browsers from which they visit the website, IP and domain, geographic data and demographic data (age, gender) and interests.
It is possible for a given person to easily block the provision of information about their activity on the Website to Google Analytics – for this purpose, you can, for example, install a browser add-on provided by Google Ireland Ltd., available here: https://tools.google.com/dlpage/gaoptout?hl=pl.
In connection with the possibility of the Administrator using advertising and analytical services provided by Google Ireland Ltd. on the Website, the Administrator indicates that full information on the principles of processing data of persons visiting the Website (including information saved in Cookies) by Google Ireland Ltd. can be found in the privacy policy of Google services available at the following Internet address: https://policies.google.com/technologies/partner-sites.
The Administrator may use the Facebook Pixel service provided by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) on the Website. This service helps the Administrator measure the effectiveness of advertisements and find out what actions visitors to the Website take, as well as display tailored advertisements to these people. Detailed information about the operation of Facebook Pixel can be found at the following Internet address: https://www.facebook.com/business/help/742478679120153?helpref=page_content.
You can manage the performance of the Facebook Pixel through the advertising settings in your Facebook.com account: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
The Administrator may use the Lead Forensics service on the Website, provided by Lead Forensics Limited (3000 Lakeside, North Harbour, Portsmouth PO6 3EN). This service helps to keep statistics and analyze traffic on the Website. The collected data is processed as part of the above services to generate statistics that help in administering the Website and analyzing traffic on the Website. This data is of aggregate nature. By using the above services on the Website, the Administrator collects such data as IP address, time of visits to the Website, information about links clicked by users. Detailed information on the operation of Lead Forensics is available at: https://www.leadforensics.com/.
The Administrator may use the LinkedIn Insight Tag service provided by LinkedIn Ireland Unlimited Company (Gardner House, 2 Wilton Pl, Saint Peter’s, Dublin 2, Ireland) on the Website. This service helps the Administrator measure the effectiveness of advertisements and find out what actions visitors to the Website take, as well as display tailored advertisements to these people. The LinkedIn Insight Tag allows for the collection of data regarding visits to the Website, including the URL, referring page, IP address, device and browser information and the time stamp. Detailed information on the operation of the LinkedIn Insight Tag is available at: https://www.linkedin.com/help/lms/answer/a425677/linkedin-insight-tag-najczesciej-zapisane-pytania?lang=pl.
The Administrator may use the Hotjar service on the Website provided by Hotjar Limited (Level 2, St Julian’s Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta). This service helps the Administrator learn what actions visitors to the Website take. Detailed information about the operation of Hotjar can be found at the following Internet address: https://www.hotjar.com/tour.
The Website may contain links to other websites. The Administrator encourages you to read the privacy policy established there after going to other websites. This privacy policy applies only to this Website of the Administrator and personal data processed in connection with its use.