PRIVACY AND COOKIES POLICY
publication date: 15.11.2019
last update: 17.06.2024
This is an auxiliary English translation of our official Privacy and Cookies Policy.
It is supposed to help you understand its content and meaning, but it does not replace the official and legally binding Polish version.
Good to see you here!
We take your data and its protection responsibly and seriously. We strongly urge you to read the document prepared for you. It contains rules for the processing of personal data and the use of cookies and other tracking technologies in connection with the use of this website.
My business will grow. This website and the document you are reading will evolve with it. In view of the above, we encourage you to take a look at this page regularly.
For your convenience, we provide information at the beginning of the document about updates to the privacy and cookies policy.
BASIC INFORMATION
The administrator of the data is Aga & Justyna Spółka Z Ograniczoną Odpowiedzialnością, with permanent place of business in Katowice, ul 3 Maja 22 / 2C, NIP: 6343024842, REGON 525606650.
You can contact the administrator by writing to the e-mail address: rodo@easypolish.org
Remember that by contacting me by e-mail or subscribing to the newsletter, you provide me with your personal data, for example name and e-mail address.
We assure you that we take every care to ensure that the data provided is secure.
Wherever data processing requires the involvement of external providers, we ensure that we consciously select the entities we work with to ensure an adequate standard of security for the data provided to me.
APPLICABLE PRINCIPLES
The use of this website is voluntary. You are not compelled/forced in any way to provide personal data. However, failure to provide certain information may entail the impossibility of providing a certain service and achieving a certain purpose, e.g. contacting me by e-mail or subscribing to a newsletter.
This website, like many other websites, uses cookies in order to function properly. In the following we indicate exactly how cookies work and what this means for you.
We use analytical tools that collect anonymous information about your visit to this website, e.g. time spent on the website or tabs viewed. You can find details in this document.
PROTECTION OF PERSONAL DATA
We know that personal data is a valuable asset. We am also aware of the risks involved in processing personal data through the use of the Internet.
However, we make every effort to ensure that your data is properly protected.
We would like to inform you already at this stage that not all rights will be granted to you absolutely and in relation to all personal data processing activities. This is not due to any ill will on my part, but due to the nature of the law.
PURPOSES:
Contact with You
Email address (name and surname), data contained in the message content
Phone number
Other data provided by you in the correspondence
The legal basis for such processing is Art. 6(1)(a) GDPR, which allows us to process data based on consent to respond to your message, and Art. 6(1)(f) GDPR, which allows us to pursue our legitimate interest, namely ensuring efficient and effective communication between the website administrator and the user.
Placing an Order and Execution of the Sales Agreement/Provision of Content/Digital Service
Name and surname
Address
Email address
Residence address
Phone number
Additionally:
Tax Identification Number (NIP)
Data on the conducted business activity
Providing data is voluntary but necessary to fulfill the order.
The legal basis for such processing is Art. 6(1)(b) GDPR, which allows data processing to take actions aimed at concluding a contract and to perform the contract made by placing an order.
Issuing an Invoice and Fulfilling Legal Tax Obligations
Name and surname
Address
Optionally:
Data concerning business activity
Tax Identification Number (NIP)
The legal basis for such data processing is primarily Art. 6(1)(c) GDPR, which allows processing personal data if such processing is necessary for the administrator to fulfill obligations arising from the law.
Considering Complaints and Handling Withdrawal from a Contract
Email address
Name and surname
Data contained in the complaint content
Bank account number
Residence address
Phone number
The legal basis for such data processing is, firstly, Art. 6(1)(b) GDPR, which allows processing personal data if it is necessary for the performance of a contract or to take steps to conclude a contract, and secondly, Art. 6(1)(c) GDPR, which allows processing personal data if such processing is necessary for the administrator to fulfill obligations arising from the law. Data will be processed for the time necessary to carry out the complaint procedure or the withdrawal procedure. Complaints and statements of withdrawal from the contract may also be archived to demonstrate the course of the complaint or withdrawal process in the future. Some rights may not always and under all conditions apply to data provided during the complaint or withdrawal process.
Marketing Purpose (Newsletter)
Email address
Name
The legal basis for such data processing is primarily Art. 6(1)(a) GDPR, i.e., your consent to receive commercial information and marketing content from us, and Art. 6(1)(f) GDPR, which allows processing personal data if the administrator pursues a legitimate interest (in this case, the marketing purpose of its own services and products).
Contact with You via ManyChat Tool
Identification data (name and surname, email address)
Publicly available information in social media profiles
Linked pages and accounts
Telecommunications data (IP addresses, geographical location, usage data, cookie data, browser data)
Chat history and content data
Chatbot usage information
Other electronic and personal data whose scope is determined and controlled by the Administrator according to the available functions within the ManyChat service.
To provide you with informational or educational content without transmitting commercial information, the Administrator processes your data to carry out direct marketing directed to you based on Art. 6(1)(f) GDPR, i.e., the legitimate interest of the administrator.
To present you with commercial information about products or services, the Administrator processes your data based on Art. 6(1)(a) GDPR, i.e., your consent given before sending this information via ManyChat.
To subscribe to the Administrator, i.e., to receive informational and educational content, as well as commercial information about the Administrator's services and products, the Administrator processes your data based on Art. 6(1)(a) GDPR, i.e., your consent to subscribe given before sending this information via ManyChat.
To fulfill obligations for some content, the Administrator processes your data based on Art. 6(1)(b) GDPR concerning the transmitted informational content depending on the message content sent using the ManyChat tool.
Archival and Evidentiary Purpose, for the Purpose of Securing Information that May Serve to Prove Facts
All data mentioned above by us
The legal basis for such data processing is Art. 6(1)(f) GDPR, which allows processing personal data if the administrator pursues a legitimate interest (in this case, the administrator's interest is to have personal data that will allow proving facts related to the use of the website, the performance of the contract, processing data on a legitimate legal basis).
Establishing, Pursuing, or Defending Against Claims
All the above-mentioned data
The legal basis for such data processing is Art. 6(1)(f) GDPR, which allows processing personal data if the administrator pursues a legitimate interest (in this case, the administrator's interest is to have personal data that will allow establishing claims, pursuing claims, or defending against claims of website users or third parties or customers).
Website Management, Using Tools to Improve the Website, and Analyzing Data Related to Website Usage
IP
Behavior on the website
The legal basis for such data processing is Art. 6(1)(f) GDPR, which allows processing personal data if the administrator pursues a legitimate interest (in this case, the administrator's interest is to take actions aimed at optimizing the website, including content presented on the website, to users' needs, improving the administrator's offer).
Use of Cookies on the Website
IP
User behavior on the website
The legal basis for such data processing is Art. 6(1)(a) GDPR, which allows processing personal data with your consent. You give consent during the first visit to the website.
Managing Administrator Profiles in Social Media
Data related to the use of a specific social media platform
The legal basis for processing is the administrator's authorization based on Art. 6(1)(f) GDPR, i.e., the legitimate interest of the administrator to manage the profile on a specific platform and your consent (Art. 6(1)(a) GDPR), which you express, for example, by joining a group created by the administrator on a specific platform.
Fulfilling Data Protection Obligations (e.g., the obligation to create registers and records)
The scope of data is specified by legal regulations and varies depending on the content of the specific legal obligation imposed on the administrator.
The legal basis for processing is Art. 6(1)(c) GDPR, i.e., it is carried out based on legal provisions that mandate the processing of personal data.
Posting Comments/Opinions on the Website
Name
Email address
The legal basis for processing is Art. 6(1)(a) GDPR, i.e., your consent, which you express to add a comment on our website.
YOUR RIGHTS
The GDPR grants the following rights in relation to the processing of personal data:
(a) The right of access to information and the duty to inform - this means that every person whose data is processed has the right to know what happens to their personal data. Among other things, the privacy policy you are currently reading has been created for this purpose.
b) The right of access to personal data - means that if I, as the controller of your data, receive a request from you for access to your data, we’re obliged to provide you with such information. We, as the data controller, are to fulfil my obligations in this respect immediately, no later than within one month. If it is not possible to do so within this period, we’re obliged to inform you at least whether we’re processing your data and may then extend the deadline for a complete response to your request by two months.
c) The right to rectification of personal data - means that you can request that the controller of your data rectifies inaccurate data or completes incomplete data.
d) The right to erasure of personal data, the right to be forgotten - means that you can request that I, as the controller of your personal data, erase your data, informing the person to whom your data has been transferred of the erasure. You also have the right to demand that your data that has been made public by me is also subject to deletion by other controllers. As the controller of your data, we’re also obliged, upon your request, to inform you of the recipients to whom your data to be deleted has been communicated.
e) The right to restrict the processing of your personal data - means that you can request the restriction of the processing of your personal data. This is the case, for example, when you disagree with the accuracy of the data being processed or when you consider that you no longer need the data for the purposes of the processing.
f) Right to object to the processing of your personal data - means that you can object to your data being processed by the controller.
g) The right to data portability - means that you can, under certain conditions, request that your data be transferred directly to a designated, other controller.
h) Right to lodge a complaint - means that as soon as you consider that our processing of your data violates the law, you can lodge a complaint with the President of the Data Protection Authority.Please note, please, that not every one of these rights will be available to you always and in every case. This is not a sign of ill will, but the nature of the law.
RECIPIENTS OF YOUR PERSONAL DATA
Your personal data may be transferred to third parties whose services we use in connection with the operation of the website and the sale and delivery of the services offered.
However, we assure you that we carefully select the entities with which we cooperate or whose services we use and am always guided by the assurance of adequate data protection.
Due to the use of Google or Facebook, your data may be transferred to the United States of America (USA) and Canada. However, we inform you that these entities guarantee an adequate level of data protection as required by European legislation.
In order to organise the entities whose services we use, they have been divided into two groups. The first is the entities that process data within the European Union. The second group are entities processing data outside the European Economic Area.
(a) Data processors in the European Economic Area:
1. STRATO AG - a service that provides IT system maintenance, email and hosting services to store personal data on a server;
2. Easy Languages GmbH - the entity co-administering the website and social media profiles and providing technical support;
3. AJL-System sp. z o.o. - a company that performs accounting services in order to issue an accounting document for the service and product provided, to process payments and to carry out accounting settlements;
4. PayPal (Europe) S.à r.l. et Cie, S.C.A. - platform through which you can make payments for our services;5. MailerLite Limited - newsletter service provider
(b) Data Processors outside the European Economic Area:
1. Google LLC - for the use of email;
2. YouTube by Google LLC - to embed audiovisual material on my pages;
3. Squarespace Inc. - provider of the system on which the website and marketing tool is built.4. ManyChat Inc. - a tool for efficient communication with the community and for achieving marketing goals, enabling the sending of automated messages on the META platform within the Instagram social networking service.
Social media plug-ins have also been embedded on the website as part of the administrator's activities. The purpose and scope of data collection and their further processing and use by the service providers are described in the privacy policies of the following:
(a) Facebook - https://www.facebook.com/privacy/explanation,
b) Instagram - https://help.instagram.com/519522125107875?helpref=page_content,
c) YouTube - https://support.google.com/youtube/answer/7671399,
COOKIES AND TRACKING TECHNOLOGIES
This website, like many others, uses cookies.
When you first visit the website, you will be prompted about the use of cookies. If you do not change your browser settings, you consent to their use.
Cookies are short text files which are stored on the device you use to browse websites.
They can be read by me ("own cookies", which we use to make this website work properly) and also by systems belonging to other parties whose services we use ("external cookies").
Please note that you have the right to change your cookie settings from your browser or to delete them.
This website uses the following tracking technologies:
(a) social plugins such as: Facebook, Instagram, YouTube;
(b) analytical and marketing tools provided by Squerespace Inc.
MANYCHAT
We use ManyChat, a tool that improves our communication with you on social media (e.g., Instagram) in our marketing activities. ManyChat allows us to send you messages with content specified by us. Some data related to the use of this tool may be obtained from the META platform and from your public profiles within the META platform.
We may use the ManyChat tool in several ways:
Sending You Content Without Commercial Information or Direct Marketing
To send you educational or informational messages, you just need to use a "keyword" in a comment on our content published on our social media channel, including Instagram.
We can then send you messages of this nature for 24 hours. After this period, the conversation window will no longer be active, and we will not send you automated messages.
If you do not want to receive messages from us, simply do not use the "keyword." After receiving a message from us, you can object, withdraw your consent, depending on the basis for data processing, at any time.
Sending You Commercial Information and Direct Marketing
To send you messages containing commercial information or direct marketing via ManyChat, we need your consent.
You can provide this consent in the first message sent to you after you use the "keyword," which is sent by us to you using the ManyChat tool.
Using the keyword activates the ManyChat tool. If you do not want to receive such messages, do not give us consent and do not enter the "keyword" indicated under each of our content where we use automation.
We can send you a message containing commercial information only within 24 hours from the moment you enter the "keyword" and give consent. You can withdraw your consent at any time. To send you commercial information, direct marketing messages about our products or services, we need your consent. The same applies to using the subscription option within the ManyChat tool.
Sending You Content Containing Commercial Information, Direct Marketing, and Enabling Subscription within the ManyChat Tool
With a subscription, we can send you messages for more than 24 hours.
If you do not want to receive messages from us, simply do not use the "keyword" and do not consent to receiving messages.
In each of the above situations, you can withdraw your consent at any time.
We conduct marketing activities and contact you through the ManyChat tool because it is an official Business Partner of Meta Inc., which means it is a trusted and verified entity by Meta Inc. According to ManyChat's declarations, it complies with Meta's security guidelines, including data security requirements and Meta's Privacy Policy. As part of the Meta Business Partner requirements, ManyChat undergoes periodic compliance audits with Meta's guidelines.
ManyChat, as a marketing tool or for communication with our community, serves two roles in data processing:
It can act as a data controller, usually in relation to our data, and
It is a data processor, usually concerning your data.
Data that ManyChat may process as a processor includes your identification data (name and surname, email address), publicly available information on your social media profiles, your related pages and accounts, IT data (IP addresses, geographic location, usage data, cookie data, browser data), and more.
Additionally, if we communicate with you via ManyChat or enter data into this service, your identification data, publicly available profile information on social media (photo, name, date of birth, gender, geographic location), chat history and content, chatbot usage information, and other electronic data sent, stored, sent, or received by you, as well as other personal data, whose scope is determined and controlled by us and according to the available features within the ManyChat service, will also be processed. We will inform you before processing this data if it takes place.
The source of obtaining the aforementioned data is the registration process in the ManyChat service and the use of this service by both us and you, especially communication with you and application integration (e.g., Facebook, Instagram, Telegram, Zapier) and other applications specified on the website http://www.apps.manychat.com/.
An integral part of our agreement with ManyChat (Terms of Use: https://manychat.com/legal/tos) is the data processing addendum, which outlines the rules for data processing by ManyChat. You can read more here: https://manychat.com/legal/dpa.
ManyChat processes data as a processor until the termination of our agreement, and as a data controller until the resignation from receiving marketing messages and the expiration of the legally required data retention period, including the statute of limitations.
In connection with the use of ManyChat, personal data may be transferred outside the European Economic Area based on Standard Contractual Clauses.
According to ManyChat's declaration, it also applies appropriate security measures to data processing. Detailed information about the security measures applied by ManyChat can be found at https://manychat.com/legal/dpa.
ManyChat also uses subprocessors, meaning your data may be transferred to these entities as part of using the ManyChat service. ManyChat cooperates with the following entities:
a) Processing subcontractors to provide the ManyChat Service located in the following countries:
Amazon Web Services, Inc. - Cloud service provider for hosting and data storage - USA
Freshworks, Inc. - Cloud-based software supporting customer interactions, e.g., via chat or email - USA
Hotjar Limited - Cloud-based recording software - Malta, EU
Rollbar, Inc. - Cloud-based error logging software - USA
Sentry LLC - Cloud-based error logging software - USA
Snowflake, Inc. - Cloud solutions provider - USA
Twilio, Inc. - Cloud-based SMS, MMS, and email services provider - USA
OpenAI, LLC - Cloud services provider exclusively supporting AI functions - USA
b) Service providers on behalf of ManyChat (service providers acting either as processors on behalf of ManyChat or as separate controllers) located in the following countries:
Google LLC - Email services and file storage software - USA
Impact Tech, Inc. - Affiliate marketing partners - USA
InMoment, Inc. (Wootric) - Marketing (NPS) - USA
Intercom, Inc. - Cloud-based CRM platform - USA
PartnerStack, Inc. - Affiliate marketing partners - USA
Stripe, Inc. - Payment gateway and processing - USA
The Rocket Science Group LLC d/b/a Mailchimp - Ad-hoc email communication with the Customer - USA
Zoom Video Communications, Inc. - Video conferencing system - USA
Usercentrics GmbH - Consent management service - Germany
c) ManyChat partners:
Manychat, Inc. - Services and support - USA
OctoHub LLC - Services and support - Armenia
ManyChat, SL - Services and support - Spain
These entities may change, so you can regularly check here and at https://manychat.com/legal/service-providers.
I have also signed up for ManyChat notifications, available at www.manychat.com/legal/subscribe-subprocessor-updates, so ManyChat will notify me of a new Subprocessor engagement at least ten calendar days before the new entity gains access to the data.
You can learn more about data processing by ManyChat and the security measures applied by clicking the following links:
I can use the help of third parties who provide technical support for ManyChat. I use entities for whom the protection of your data is important and enter into appropriate data processing agreements with them.
SERVER LOGINS
Use of the website involves sending requests to the server on which my website is hosted.
Each request made to the server is recorded in the server logs, which include, for example: your IP address, the date and time of the server, information about your web browser and the operating system you are using.
The data stored in the server logs are not associated with specific users of the website and are used as support material for administrative purposes.
Their contents are not disclosed to anyone other than those authorised to administer the server.
NEWSLETTER
We consciously select the service providers we use to provide you with the highest level of protection for your data.
The newsletter service provider is MailerLite Limited, 38 Mount Street Upper, Dublin 2, D02 PR89 Ireland.
Your data will not be transferred to a Third Country outside the European Union for the purpose of sending the newsletter.
Your data, i.e. your name and your email, provided in the newsletter sign-up form, will be processed for the purpose of sending the newsletter.
The data you provide in the newsletter sign-up form is voluntary, but necessary to send you the newsletter on the basis of the consent you have given, as well as to send you information about the marketing of our own products or services on the basis of our, as the administrator, legitimate interest (i.e. Article 6(f) GDPR) and for the purpose of asserting possible claims in connection with the sending of the newsletter.
You are guaranteed that your data will be processed until you withdraw the consent you have given, unsubscribe from the newsletter or express your objection.
The mechanism for unsubscribing from the newsletter service is not complicated and consists of clicking on the active link stating I unsubscribe from the newsletter.
Once you have exercised this right and unsubscribed from the newsletter, your data relating to your subscription to this service will be stored for the period necessary to defend against potential claims. This is our, as data controller, legitimate interest.
SQUARESPACE ANALYTICS SERVICE
This website uses analytical tools provided by Squerespace, Inc. These tools allow for the analysis of web services and activities.
Details of this service are available by clicking the link: https://www.squarespace.com/websites/analytics
Squerespace, Inc. uses so-called "cookies", text files which are stored on your computer and enable analysis of the use of the website.
You have the option of disabling the storage of cookies by means of appropriate settings in your browser software. However, there is a risk that this will lead to a situation in which you will not be able to make full use of all the functions of this website.
We use Squerespace, Inc. to analyse the use of this website and to improve it according to your preferences. With the statistics obtained, we can, for example, tailor my offer.
The information obtained by the cookie regarding the use of this website is usually transmitted to a server of Squerespace, Inc in the USA and stored there.
Details on data protection by Squerespace, Inc are available at the following link: https://www.squarespace.com/privacy
SOCIAL MEDIA
The website you are using contains plugins for the following social media services: Facebook, Instagram, YouTube.
Through the plugin, you can directly connect with the profile on the indicated services. The services can then obtain information that you are visiting the site from your IP address.
We inform you that if you visit our site while simultaneously logged into your social media profiles, information about your visit will be recorded on these social media services. Even if you are not logged in, social media services can still obtain information about your IP address.
We would like to emphasize that we do not have information from social media platforms about the collected data and how it is used. For more information regarding privacy on social media services, we suggest contacting the services directly and reviewing their privacy policies, which are linked in this document.
If you do not want social media services to obtain information about your visits to our site, we recommend logging out of social media platforms beforehand.
INFORMATION CLAUSE FOR VISITORS OF OUR FACEBOOK FANPAGE
The personal data of visitors to my fanpage will be processed in accordance with the requirements of the Data Protection Act of 10 May 2018 and in accordance with the requirements set out in the Regulation of the European Parliament and of the Council of 27 April 2016 ("GDPR").
We have obtained this data from Facebook Inc. and from your public profile on the Facebook online platform.
We process the personal data of persons who:
Have subscribed to the fanpage by clicking on the "Like" or "Follow" icon
Have used the chat option to contact the Administrator
Have published a comment under any of the posts posted on the fanpage;
Personal data will be processed for the following purposes:
in order to manage this fanpage on the Facebook social network and to inform through it about our activity, to promote various events, campaigns, actions that we organise and our brand, products and services, to build and maintain the community associated with us and to communicate through the available Facebook functionalities (comments, chat, messages) which is our legitimate interest (the basis of Article 6(1)(f) GDPR),
for statistical purposes concerning the analysis of the functioning, popularity, use of the fanpage, which is our legitimate interest (the basis of Article 6(1)(f) GDPR),
for the possible establishment, investigation or defence against claims, which is our legitimate interest (basis of Article 6(1)(f) GDPR)
in order to take steps to conclude a contract due to an interest in our services (basis of Article 6(1)(b) GDPR).
We will process the following categories of Users' personal data:
basic identification data (first and last name) to the extent published by Users on their own/private profile on the social network Facebook,
other data published by Users on their Facebook profile, including their image (profile photo - if embedded),
other data published by Users during a conversation conducted via the Messenger application, anonymous statistical data regarding Users visiting the fanpage collected through cookies, each of which contains a unique User code that can be linked to the connection data of Users registered on Facebook, which is downloaded and processed when the fanpage is opened.
The duration of data processing is linked to the purposes and grounds for processing. Accordingly:
data processed on the basis of the legitimate interest of the Administrator will be processed until an objection is effectively lodged or this interest ceases,
data processed for the purpose of asserting or defending against claims will be processed for a period equal to the period of limitation of such claims,
personal data collected by Facebook, i.e. history of posts, history of activity in the Messenger application, history of activity via the Instagram application shall be subject to retention under the terms of Facebook's regulations;
statistical data on fanpage visitors available via the "Facebook Insights" function will be processed for the duration of the availability of this data on Facebook;
Personal data may be transferred to third parties processing data on behalf of the Administrator.
The entities referred to above will process the data on the basis of a contract with the Administrator and only in accordance with the Administrator's instructions and the processing of personal data will take into account the necessary security measures.
You have the right of access to your data, the right to request their rectification, erasure or restriction of their processing as well as the right to object.
You also have the right to lodge a complaint with the supervisory authority in charge of personal data protection (President of the Office for Personal Data Protection).
We inform you that you will not be subjected to a decision which is based solely on automated processing and which would produce legal effects on you or in a similar manner significantly affect you.
Given the international nature of data flows within the Facebook platform, Facebook may transfer data outside the European Economic Area in accordance with the rules set out by Facebook in its privacy policy. However, do not worry that your data will be processed in contravention of applicable law. Facebook has stated that it has implemented standard contractual clauses between processors, which, according to Facebook's statement, means that your data is safe. You can read more about this here.
VIDEO SHARING
We place audiovisual material from YouTube on my website. Google LLC cookies are used for this purpose.
Cookies are automatically generated when you play audiovisual material from the above-mentioned websites.
If you do not agree to this, do not play the video material.
FINAL PROVISIONS
The content posted on this site and in the supported social media services is a manifestation of our own intellectual creativity. Therefore, it is subject to our copyright.
We do not consent to copying the content in whole or in part without our explicit prior consent.
Using the provided content beyond permissible personal use may result in the risk of criminal and civil liability.
You are obligated to use our site in a manner that is lawful and in accordance with good customs, considering the respect for personal rights and intellectual property rights of third parties.
If you have any doubts regarding the legal nature of the provided content (or how you can legally use it), send us a message (email address indicated at the beginning of this document), and we will provide you with a comprehensive answer.
Also, remember that the provided content is educational in nature and does not constitute or replace individual expert advice.
Finally, we remind you that the content of this Privacy Policy may change, for example, when we change the service provider or the scope of functionality on the site. For your convenience, the date of the Privacy Policy update is provided at the beginning of the document.
Thank you for your time!
Aga & Justyna