Website ibris.pl
TABLE OF CONTENTS:
- GENERAL PROVISIONS
BASES FOR DATA PROCESSING
PURPOSE, BASIS, PERIOD AND SCOPE OF DATA PROCESSING IN THE WEBSITE
RECIPIENTS OF DATA IN THE WEBSITE
PROFILING IN THE WEBSITE
RIGHTS OF THE PERSON WHOSE DATA CONCERN
COOKIES IN THE WEBSITE, OPERATIONAL DATA AND ANALYTICS
FINAL PROVISIONS.
1) GENERAL PROVISIONS
This Website privacy policy is for information purposes only, which means that it does not create any obligations for Website Users. The Privacy Policy primarily contains rules regarding the Administrator’s processing of personal data on the Website, including the grounds, purposes and scope of personal data processing and the rights of data subjects, as well as information on the use of cookies and analytical tools on the Website.
The administrator of the personal data collected via the Website is the ‘Institute for Market and Social Research’ Foundation with its registered office in Warsaw (address: 00-807 Warsaw, Al. Jerozolimskie No. 96), NIP: 7010413440, REGON: 14711540400000, entered in the register of associations, other social and professional organisations, foundations and independent public health care centres under KRS No. 0000495043, whose registration files are stored in the District Court for the Capital City of Warsaw, XII Economic Division of the National Court Register, represented by: Marcin Duma – President of the Management Board, authorised to represent the Foundation independently and e-mail address: biuro@ibris.pl – hereinafter referred to as the ‘Administrator’ and being at the same time the Internet Service Provider.
Personal data on the Website are processed by the Administrator in accordance with the 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 in relation 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 “RODO” or “RODO Regulation”. Official text of the RODO Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679
The use of the Website, including the conclusion of contracts, is voluntary. Likewise, the related provision of personal data by the Customer using the Website is voluntary, subject to two exceptions: (1) conclusion of agreements with the Administrator – failure to provide, in the cases and to the extent indicated on the Website and in the Website Terms and Conditions and this Privacy Policy, the personal data necessary for the conclusion and performance of an agreement for the provision of Electronic Services with the Administrator results in the impossibility of concluding such an agreement. The provision of personal data in such a case is a contractual requirement and if the data subject wishes to conclude a given agreement with the Administrator, he/she is obliged to provide the required data. Each time the scope of data required to conclude a contract is indicated beforehand on the Website and in the Terms and Conditions of the Website; (2) the Administrator’s statutory obligations – providing the personal data is a statutory requirement resulting from generally applicable laws imposing an obligation on the Administrator to process personal data (e.g. processing of data for the purposes of keeping tax or accounting books), and failing to provide such data will prevent the Administrator from fulfilling those obligations.
The controller shall take particular care to protect the interests of the persons whose personal data it processes and in particular shall be responsible and ensure that the data it collects are: (1) processed lawfully; (2) collected for specified, legitimate purposes and not subjected to further processing incompatible with those purposes; (3) substantively correct and adequate in relation to the purposes for which they are processed; (4) kept in a form which permits identification of data subjects for no longer than is necessary to achieve the purpose of the processing; and (5) processed in a manner which ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by means of appropriate technical or organisational measures.
Having regard to the nature, scope, context and purposes of the processing and the risk of violation of the rights or freedoms of natural persons of varying probability and seriousness, the Controller shall implement appropriate technical and organisational measures to ensure that the processing is carried out in accordance with this Regulation and to be able to demonstrate this. These measures shall be reviewed and updated as necessary. The Administrator shall apply technical measures to prevent the acquisition and modification by unauthorised persons, of personal data transmitted electronically.
2) GROUNDS FOR PROCESSING
The controller shall be entitled to process personal data where, and to the extent that, one or more of the following conditions are met: (1) the data subject has given his or her consent to the processing of his or her personal data for one or more specified purposes; (2) the processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract; (3) the processing is necessary for compliance with a legal obligation incumbent on the Controller; 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 which require protection of personal data, in particular where the data subject is a child.
The processing of personal data by the Controller requires in each case the existence of at least one of the grounds indicated in point. 2.1 of the Privacy Policy. The specific grounds for the Administrator’s processing of the personal data of Website users are indicated in the next section of the privacy policy – with reference to the particular purpose of the Administrator’s processing of personal data.
3) PURPOSE, BASIS, DURATION AND SCOPE OF DATA PROCESSING ON THE WEBSITE
- In each case, the purpose, basis, duration, scope and recipients of the personal data processed by the Administrator result from the activities undertaken by the respective User on the Website.
- The Administrator may process personal data on the Website for the following purposes, on the following grounds, for the following periods and to the following extent:
Purpose of data processing | Legal basis for processing and data retention period | Scope of data processing |
Performing a contract for the provision of an Electronic Service or taking action at the request of the data subject prior to entering into the aforementioned contracts | Article 6(1)(b) of the RODO Regulation (performance of a contract) The data are stored for the period necessary for the performance, termination or otherwise expiry of the contract concluded. | Maximum scope: first and last name; e-mail address; contact telephone number; street, house number, apartment number, postal code, city, country, residential/business/site address. In the case of Service Recipients who are not consumers, the Administrator may additionally process the company name and tax identification number (NIP) of the Service Recipient. |
Direct marketing | Article 6(1)(f) of the RODO Regulation (legitimate interest of the Controller). The data shall be stored for the period of existence of the legitimate interest pursued by the Controller, but no longer than for the period of limitation of claims against the data subject in respect of the business activities conducted by the Controller. The period of limitation is determined by the provisions of law, in particular the Civil Code (the basic limitation period for claims related to the conduct of business activities is three years, and for a sales contract it is two years).The Administrator may not process data for the purpose of direct marketing in the event of an effective objection to this effect by the data subject. | E-mail address |
Marketing | Article 6(1)(a) of the RODO Regulation (consent). Data is stored until the data subject withdraws his or her consent to further processing for this purpose. | Name, e-mail address |
Maintenance of tax or accounting books | Article 6(1)(c) of the RODO Regulation in conjunction with Article 86(1) of the Tax Ordinance i.e. of 17 January 2017. (Journal of Laws of 2017, item 201) or Article 74(2) of the Accounting Act, i.e. of 30 January 2018. (Journal of Laws of 2018, item 395). The data shall be kept for the period required by the provisions of law requiring the Administrator to keep tax books (until the expiry of the statute of limitations for tax liabilities, unless otherwise provided by tax acts) or accounting books (5 years, counting from the beginning of the year following the financial year to which the data refer). | The first and last name; the residence / business / site address (if different from the delivery address), company name and tax identification number (TIN) of the Customer. |
Establishing, asserting or defending claims which the Administrator may assert or which may be asserted against the Administrator | Article 6(1)(f) of the RODO Regulation Data shall be stored for the period of existence of the legitimate interest pursued by the Controller, but no longer than the period of limitation of claims against the data subject in respect of the business activities conducted by the Controller. The period of limitation is determined by the provisions of law, in particular the Civil Code (the basic limitation period for claims related to the conduct of business activities is three years, and for a sales contract it is two years). | First and last name; contact telephone number; e-mail address; delivery address (street, house number, apartment number, postal code, city, country), residential/business/site address (if different from delivery address). For Service Recipients who are not consumers, the Administrator may additionally process the company name and tax identification number (NIP) of the Service Recipient. |
4) RECIPIENTS OF DATA ON THE WEBSITE
For the proper functioning of the Website, including the execution of concluded agreements for the provision of services by electronic means, it is necessary for the Administrator to use the services of external entities (such as a software provider). The Administrator shall only use the services of such processors who provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing meets the requirements of the RODO Regulation and protects the rights of the data subjects.
- The transfer of data by the Controller does not take place 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 for the fulfilment of the given purpose of personal data processing and only to the extent necessary for its fulfilment.
- The personal data of Website users may be communicated to the following recipients or categories of recipients
Service providers supplying the Administrator with technical, IT and organisational solutions enabling the Administrator to conduct his/her business activity, including the Website and the Electronic Services provided through it (in particular, providers of computer software for running the Website, e-mail and hosting providers and providers of business management and technical support software for the Administrator) – the Administrator shall make the collected personal data of the Customer available to the chosen provider acting on his/her behalf only in the case and to the extent necessary to achieve the given purpose of data processing in compliance with this Privacy Policy.
Accounting, legal and advisory service providers providing accounting, legal or advisory support to the Administrator (in particular, an accounting office, a law firm or a debt collection company) – The Administrator shall make the collected personal data of the Customer available to the selected provider acting on its behalf only in the case and to the extent necessary to fulfil the given purpose of data processing in accordance with this Privacy Policy.
5) PROFILING ON THE WEBSITE
The RODO Regulation imposes an obligation on the Controller to provide information on automated decision-making, including profiling as referred to in Article 22(1) and (4) of the RODO Regulation, and, at least in these cases, relevant information on the modalities of such decision-making, as well as on the significance and the envisaged 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 the decisions made on its basis by the Administrator do not relate to the conclusion or refusal of an agreement for the provision of electronic services or the possibility of using Electronic Services on the Website. The effect of the use of profiling on the Website may be, for example, to send a proposal that may match the person’s interests or preferences or to offer better terms and conditions compared to the standard offer of the Website. Despite the profiling, it is up to the individual to decide freely whether he or she wishes to take advantage of the discount or better conditions received in this way and make a purchase on the Website.
- Profiling on the Website involves the automatic analysis or prediction of a person’s behaviour on the Website, or by analysing the previous history of activities undertaken on the Website. The prerequisite for such profiling is that the Administrator has the personal data of the person in question in order to be able to subsequently send the person, for example, a discount code.
- The data subject has the right not to be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects on the data subject or similarly significantly affects the data subject.
6) RIGHTS OF THE DATA SUBJECT
Right of access, rectification, restriction, erasure or portability – The data subject has the right to request from the Controller access to his/her personal data, rectification, erasure (“right to be forgotten”) or restriction of processing, and has the right to object to processing, and has the right to portability of his/her data. The detailed conditions for exercising the rights indicated above are indicated in Articles 15-21 of the RODO Regulation.
- Right to withdraw consent at any time – a person whose data is processed by the Controller on the basis of expressed consent (on the basis of Article 6(1)(a) or Article 9(2)(a) of the RODO Regulation), then he/she 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.
Right to lodge a complaint to the supervisory authority – the person whose data is processed by the Controller has the right to lodge a complaint to the supervisory authority in the manner and mode specified in the provisions of the RODO Regulation and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Office for Personal Data Protection.
Right to object – The data subject has the right to object at any time – on grounds relating to his or her particular situation – to the processing of personal data concerning him or her based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interest of the controller), including profiling on the basis of these provisions. In such a case, the controller shall no longer be allowed to process these personal data unless the controller demonstrates the existence of compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defence of claims.
- Right to object to direct marketing – where personal data is processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of personal data concerning them for 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 section of the privacy policy, the Administrator may be contacted by sending an appropriate message in writing or by e-mail to the Administrator’s address indicated at the beginning of the privacy policy or by using the contact form available on the Website.
7) COOKIES ON THE WEBSITE, USAGE DATA AND ANALYTICS
- Cookies are small text files sent by a web server and stored on the website visitor’s computer (e.g. on the hard drive of a computer, laptop or smartphone memory card – depending on the device used by the visitor to our Website). Detailed information on cookies, as well as the history of their creation, can be found, inter alia, here: http://pl.wikipedia.org/wiki/Ciasteczko.
- The Administrator may process the data contained in Cookies when visitors use the Website for the following purposes:
- Identify Service Recipients as logged in to the Website and show that they are logged in;
- remembering data from Forms you have filled in or login data for the Website;
- to adapt the content of the Website to the individual preferences of the Customer (e.g. concerning colours, font size, page layout) and to optimise the use of the Website’s pages;
- to keep anonymous statistics showing how the Website is used;
remarketing, i.e. the study of the behavioural characteristics of visitors to the Website through an anonymous analysis of their actions (e.g. repeated visits to specific pages, keywords, etc.) in order to create their profile and provide them with advertising tailored to their anticipated interests, also when they visit other websites on the advertising network of Google Inc. and Facebook Ireland Ltd
- By default, most web browsers on the market accept the storing of cookies. You can determine the conditions for the use of cookies via the settings of your own browser. This means that you can, for example, partially restrict (e.g. temporarily) or completely disable the storage of cookies – in the latter case, however, this may affect some of the functionality of the Website.
- The cookie settings of your internet browser are relevant for your consent to the use of cookies by our Website – in accordance with the regulations, such consent can also be expressed through your browser settings. In the absence of such consent, the cookie settings of your internet browser must be changed accordingly.
- Detailed information on how to change your cookie settings and how to delete them yourself in the most popular web browsers is available in the help section of your browser and on the following pages (just click on the respective link):
The Administrator may use Google Analytics, Universal Analytics, Google Tag Manager provided by Google Inc. (1600 AmphitheatreParkway, MountainView, CA 94043, USA), tools provided by Gemius SA (ul. Domaniewska 48, 02-672 Warsaw), tools provided by Alexa Internet, Inc. (PresidioBuilding 37, San Francisco, CA 94129-0141, USA). These services help the Administrator to analyse traffic on the Online Shop. The data collected is processed as part of the aforementioned services in an anonymised manner (this is so-called exploitation data, which prevents the identification of the person) to generate statistics to help administer the Online Shop. This data is aggregated and anonymous, i.e. it does not contain identifying characteristics (personal data) of persons visiting the website of the Internet Shop. When using the above services in the Internet Shop, the Administrator collects such data as the source and medium of obtaining visitors to the Internet Shop and the manner of their behaviour on the website of the Internet Shop, information on the devices and browsers from which they visit the website, IP and domain, geographical data and demographic data (age, gender) and interests.
It is possible for a person to easily block Google Analytics from sharing information about his or her activity on the Website – for this purpose, you can install a browser add-on provided by Google Inc. available here: https://tools.google.com/dlpage/gaoptout?hl=pl
The Administrator may use on the Website the Facebook Pixel service provided by Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland). This service helps the Administrator measure the effectiveness of advertisements and find out what actions visitors take on the Website, and display tailored advertisements to those visitors. You can find detailed information on how the Facebook Pixel works at the following web address: https://www.facebook.com/business/help/742478679120153?helpref=page_content.
You can manage the operation of the Facebook Pixel via the ad settings in your Facebook.com account: https://www.facebook.com/ads/preferences/?entry_product=ad_settings_screen.
8) FINAL PROVISIONS
The Website may contain links to other websites. The Administrator urges that when you go to other sites, you should familiarise yourself with the privacy policy established there. This privacy policy applies only to the Administrator’s Website.