1.1. Collector – STRATEGA CEE Sp. z o.o. Limited liability company with registered seat at ul. Wólczańska 125 St, 90-521 Łódź, entered into the register of entrepreneurs kept by the District Court for the Łódź, Downtown in Łódź, XX Commercial Division registered under numbers: KRS: 0000541582, NIP: 7692223109, REGON: 360412382, hereinafter referred to as the Data Collector, share capital: 5,000 PLN.
1.2. Personal data – any information relating to identified or identifiable natural person who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
1.4. RODO – 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/WE.
1.5. Website – the website conducted by the Collector at the address: grupyfokusowe.pl; panelkonsumencki.pl; strategaresearch.pl; strategaresearch.com,stratega.pl; i-viewwarsaw.com; i-viewwarsaw.pl; i-viewmeetings.pl; i-viewmeetings.com.
1.6. User – any natural person visiting the Website or using one or many services or functions described in the Policy.
THE PROCESSING OF PERSONAL DATA IN THE CONTEXT OF THE USE OF THE WEBSITE
2.1. In the context of the use of the Website by the User, the Collector collects data to the extent that is strictly necessary to provide offered services as well as information about the activity of User on the Website. Detailed rules and purposes of processing personal data collected when visiting the Website are presented below.
THE PURPOSES AND LEGAL GROUND OF PROCESSING DATA ON THE WEBSITE
VISITING THE WEBSITE
3.1. Personal data every users (including IP address or others identificators and information collected through cookies internet protocol addresses, cookies identifiers or other identifiers) but not registered as the website users (that is individuals who does not own a profile on the Website) are processed by the Collector:
3.1.1. In order to render electronic services in transmitting content collected on the Website – the legal ground of processing personal data is the necessary for the performance of a contract (art.6 para.1 lett. b RODO).
3.1.2. For analytical and statistical purposes – the legal ground of processing personal data is legitimate interest of the Collector (art. 6 para. 1 lett. f RODO) based on conducting analyses of Users activity as well as their preferences in order to improve functions and rendering services.
3.1.3. In order to possibly determine and assert claims or defend against them – the legal ground of processing personal data is reasoned interest of the Collector (art. 6 para.1 lett. f RODO) based on protection of his rights.
3.1.4. For marketing purposes of the Collector and other subjects, especially related to a presentation of behavioural advertising – the rules of processing personal data for marketing purposes are presented in “MARKETING” section.
3.2. The activity of user on the Website, including user’s personal data, are logged in the system (specialised programme storing the chronological record containing the information about events and action that concern IT system used for providing services by the Collector). Information logged in the system are transmitted mostly for purposes related to rendering services. The Collector processes them for administrative, technical purposes due to system safety and managing this system and also for statistical and analytical purposes – in this terms the legal ground of processing personal data is a legally justified interest of Collector (art. 6 para. 1 lett. f RODO).
REJESTRACJA W SERWISIE
3.3. Persons, who complete the registration on the Website are asked to provide the data necessary to create and operate the account. In order to facilitate service,an User can provide additional data, thereby giving the consent to their processing. Such data can be deleted at any time. Providing data marked as mandatory is required to complete the registration and operate the account as lack of these results in no capability of creating an account. Providing other data is voluntary.
3.4. Personal data are processed:
3.4.1. In order to provide services related to account operations and service on the Website – the legal ground of personal data processing is the necessity of processing to perform an agreement (art. 6 para. 1 lett. b RODO), in extent to data provided facultatively – the legal ground of personal data processing is the agreement (art. 6 para. 1 lett. a RODO).
3.4.2. For statistical and analytical purposes – the legal ground of personal data processing is reasoned interest of the Collector (art. 6 para. 1 lett. f RODO) based on conducting Users activity analysis on the Website/Application and manner of using the account and also their preferences to improve functions applied.
3.4.3. In order to determine and assert claims or defense against them – the legal ground of processing is reasoned interest of the Collector (art. 6 para. 1 lett. f RODO) based on protection of his rights.
3.4.4. For marketing purposes of the Collector and other subjects – the rules of personal data processing for marketing purposes are presented in “MARKETING” section.
3.5. If the User uploads any personal data of other persons (including full name, address, telephone number or e-mail address) onto the website, he can do so only under condition of non-infringement of generally applicable law and personal interests of these persons.
3.6. The Controller ensures the ability to contact him via electronic contact forms. Using the form requires providing personal data necessary to contact with the User and answer to his query. The User can also insert other personal data to facilitate contact and support of a query. Providing the data marked as mandatory is required to accept and support a query and not providing them results in failure to provide service. Providing other data is voluntary.
3.7. Personal data is processed:
3.7.1. In order to identify the sender and support his query that has been sent through contact form – the legal ground of the processing is the necessity for the performance of a contract (art.6 para.1 lett. b RODO).
3.7.2. For statistical and analytical purposes – the legal ground of processing is reasoned interest of the Collector (art. 6 para. 1 lett. f RODO) based on keeping statistics on queries sent by Users via the Website to improve its function.
4.1. The Collector processes personal data of Users in order to carry out marketing that covers:
4.1.1. Displaying marketing content for the User not meeting his preferences (contextual advertising).
4.1.2. Displaying marketing content for the User meeting his interests (behavioural advertising).
4.1.3. Sending e-mail notifications presenting interesting offers and contents which in some cases contain commercial information (newsletter service).
4.1.4. Conducting other type of action related to direct marketing of goods and services (commercial information by electronic means and telemarketing activities).
4.2. In order to carry out marketing, the Collector uses profiling. This means that due to automated processing of personal data, the Collector evaluates certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance.
4.3. The Collector processes personal data of Users for marketing purposes with regards to targeting contextual advertising (an advertisement that does not meet Users’ preferences) at Users. Then, the processing of personal data is carried out in relation to the realisation of Collector’s reasoned interest (art. 6 para. 1 lett. f RODO).
4.4. The Collector and his trusted associates process personal data of Users, including personal data collected through cookie identifiers and other similar technologies for marketing purposes in relation to targeting behavioural marketing (an advertisement that meets Users’ preferences) at Users. Then, processing of personal data also includes profiling Users. The use of personal data collected through this technology for marketing purposes, especially in terms of promoting services and third parties’ goods requires the consent given by the User. The User have the right to withdraw his or her consent at any time.
4.5. The Collector provides newsletter service, accordingly to the rules specified in the regulation, to persons who provided their e-mail adress. Providing data is required in order to render newsletter services as the failure to make the data available results in lack of possibility to send the newsletter.
4.6. Personal data is processed:
4.6.1. In order to provide newsletter service – the legal ground of processing is necessity of processing to execute the agreement (art. 6 para.1 lett. b RODO);
4.6.2. In case of sending marketing content to the User as a form of newsletter – the legal ground of processing, including profiling, is reasoned interest of the Collector (art. 6 para. 1 lett. f RODO) in relation to consent to newsletter service;
4.6.3. For statistical and analytical purposes – the legal ground of processing is reasoned interest of the Collector (art. 6 para. 1 lett. f RODO) based on conducting analysis of Users activity on the Website/Application in order to improve functions;
4.6.4. In order to possibly determine and assert claims or defend against them – the legal ground of processing is reasoned interest of the Collector (art. 6 para.1 lett. f RODO).
4.7. User’s personal data can be used by the Collector to send him marketing content through different channels, that is via e-mail. Such activities are undertaken by the Collector only in case when User gave the consent that can be withdrawn at any time.
COOKIES AND SIMILAR TECHNOLOGIES
5.1. Cookies are small text files placed on the data terminal equipment of an User visiting the Website. Cookies collect information facilitating using the Website – i.e. by remembering the User’s visits and actions taken on the Website.
5.2. The Collector uses so called service cookies mostly in order to deliver electronically supplied services to User and to improve the quality of these services. In relation to this, Collector and other subjects rendering analytical and statistical services on his behalf uses cookie files, storing information or getting access to information that have been already stored within User’s data terminal equipment (Personal computer, phone, tablet etc.). Cookies files used for this purpose cover:
5.2.1. Cookie files with data inserted by the User (session ID) during the session (user input cookies);
5.2.2. Certifying cookies files used to services requiring certifying during the session (authentication cookies);
5.2.3. Cookies files used to ensure safety i.e. used to detect misuses in terms of certifying (user centric security cookies);
5.2.4. Session cookies of media players (i.e. Cookie files of flash player) during the session (multimedia player session cookies);
5.2.5. Permanent cookie files used for customization of User’s interface during session or slightly longer (user interface customization cookies);
5.2.6. Cookie files used to monitor the traffic on the website, that is data analytics, including cookies Google Analytics (these are the files used by Google in order to analyse the way of using the Website by User to create statistics and reports for User identification) Google does not use collected data to User identification and connect this data to enable the identification. Detailed information about the scope and rules of collecting data in relation to this service can be find under the following link: https://www.google.com/intl/pl/policies/privacy/partners
5.3. The Collector and his trusted associates also uses cookie files for marketing purposes, including targeting behavioural advertising at Users. For this purpose the Collector and his trusted associates store information or get access to information that is already stored in User’s telecommunication terminal equipment (Personal computer, phone, tablet etc.). Using cookie files and personal data collected through them for marketing purposes, especially in terms of services and third parties’ goods promotion, requires the consent given by the User. The User have the right to withdraw his or her consent at any time.
THE TIME OF PERSONAL DATA PROCESSING
6.1. The time of data processing by the Collector depends on a type of provided service and a purpose of processing. As a rule, data is processed by the whole time of providing service or order realisation until the withdrawal of given consent or raise an effective objection in cases when the legal ground of data processing is reasoned interest of the Collector.
6.2. The time of processing can be prolonged in case when processing is necessary to determine and assert claims or defend against them and after this time only to the extent that is required by the law. After the expiry of the processing period, data is irreversibly deleted or anonymised.
7.1. User has a right to: access the data, correction, erasure, restrict the processing, data portability, object to the data processing, and also the right to lodge a complaint with a supervisory data protection authority.
7.2. To the extent that User’s data is processed based on his or her consent, the consent can be withdrawn at any time by contacting the Collector or using functions provided by the Website.
7.3. The User has the right to object data processing for marketing purposes if the processing is performed in relation to reasoned interest of the Collector and also due to reasons relating to User’s specific situation – in other cases, when the legal ground of data processing is reasoned interest of the Collector (i.e. In terms of analytical and statistical purposes realisation).
8.1. In relation to service realisation, personal data will be disclosed to external entities, especially third party service providers responsible for operating information systems, subjects such as banks, payment operators, accounting service providers, couriers (in terms of order realisation), marketing agency (in terms of marketing services) and to subjects related to the Collector.
8.2. In case of obtaining the User’s consent, his or her data can be disclosed to other subjects for their own purposes, including marketing.
8.3. The Collector reserves the right to disclose selected information concerning the User to any third party or to authorities,which submit a request for such information, based on an appropriate legal basis.
THE RIGHTS RELATED TO PERSONAL DATA PROCESSING
THE RIGHTS OF DATA SUBJECTS
9.1. Data subjects have following rights:
9.1.1. The right to be informed of the processing of their personal data – base on that, the Collector informs a person who submits a request about data processing, mostly about the purposes and the legal ground of the processing, the extent of collected data, subjects to which personal data is disclosed to and the planned term of data deletion;
9.1.2. The right of the data subject to obtain a copy – based on that, the Collector transmits a copy of processed data concerning a person submitting a request;
9.1.3. The right of rectification – the Collector is obliged to remove possible discrepancies or errors in processed personal data or complete data if its incomplete;
9.1.4. The right to deletion of data – data subjects shall be entitled to request the removal of their personal data that is not necessary to realisation of any objectives for which they have been collected;
9.1.5. The right to have processing restricted – the Collector ceases to operate on personal data if the User so requests – with the exception of operation that was authorised by a data subject – also data storage, accordingly to accepted retention rules or as long as the causes of processing restriction will not cease;
9.1.6. The right to data portability – based on that – in terms which data is processed in relation to an agreement or given consent – the Collector provides data delivered by a data subject, in a form that can be displayed on a computer. It is possible to demand sending this data to other subject – however, under the condition that it is technically possible to provide this service by both sides, the Administrator as well as other subject;
9.1.7. The right to object to the data processing for marketing purposes – a data subject, can object to the processing of personal data for marketing purposes at any time without the need for further justification;
9.1.8. The right to object to the data processing for other purposes – a data subject can object to the processing of personal data that is carried out in relation to the realisation of Collector’s reasoned interes (i.e. For analytical or statistical purposes or because of security of property). In this respect, a data subject shall state the reason for objecting to the data processing;
9.1.9. The right of withdrawal – personal data is processed based on given consent, a data subject has the right to withdraw the consent at any time, which does not influence the lawfulness of the processing of personal data executed before the withdrawal;
9.1.10. The right to complaint – where it considers that the processing of personal data infringes the provisions of RODO or other provisions concerning the protection of personal data, a data subject may submit a complaint to the The Inspector General for the Protection of Personal Data.
BRINGING DEMANDS RELATED TO THE EXECUTION OF RIGHTS
9.2. The proposal concerning the data subject’s rights can be submitted:
9.2.1. In writing to the following address: Stratega CEE LCC ul. Wólczańska 125, 90-521 Łódź
9.2.2. via e-mail to the address: email@example.com
9.3. If the Collector will not be able to identify a person submitting the proposal basing on the submission he will seek supplementary information from the applicant.
9.4. The proposal can be submitted in person or through authorised representative (i.e. family member) Because of safety reasons the Collector encourages using authorised representative certified by a notary public or authorised legal counsel or attorney since that will significantly accelerate the verification of authenticity of proposal.
9.5. A reply to an application shall be send within a month from the date of the receipt. When an extension of term is necessary, the Collector informs an applicant about the causes of a delay.
9.6. A proposal is replied through post mail unless a proposal has been sent by e-mail or the reply in electronic form has been demanded.
SECURITY OF PERSONAL DATA
10.1. The Collector is analysing the risk in order to ensure the safety of processing of personal data – primarily ensuring that only authorised individuals have the access to data and only to the extent it is necessary due to their performed tasks. The Collector ensures that every operation carried out on personal data is registered and carried out only by authorised associates and coworkers.
10.2. The Collector take all measures necessary so as to his subcontractors and other cooperating subjects guarantee taking every appropriate security measures in each case, when processing personal data on behalf the Collector.
11.1. Contact with the Collector will be provided through following e-mail address: firstname.lastname@example.org, or by telephone on +48 690 020 489
or in writing addressed to the seat of the Collector.
11.2. The Collector has appointed a Data Protection Officer that may be contacted by e-mail email@example.com in any case concerning processing of personal data.
12.1. The policy will be reviewed annually and revised as needed. The current version of Policy was accepted and applies with effect from 11 April 2018.