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PRIVACY POLICY

The following Privacy Policy sets out the rules for saving and accessing data on the Devices of Users using the Website for the purposes of providing services electronically by the Administrator and the rules for collecting and processing Users' personal data that were provided by them personally and voluntarily via the tools available on the Website.

The following Privacy Policy is an integral part of Website Regulations, which specifies the rules, rights and obligations of Users using the Website.

§1 Definitions

  • Website - the "letsdoads.pl" website operating at https://letsdoads.pl

  • External website - websites of partners, service providers or service recipients cooperating with the Administrator

  • Website/Data Administrator - the Website Administrator and Data Administrator (hereinafter referred to as the Administrator) is the company "LET'S DO ADS Sp. z o. o., operating at the following address: ul. Piękna 24/26A, 00-549 Warsaw, with an assigned tax identification number (NIP) : 7011169953, providing services electronically via the Website

  • User - a natural person for whom the Administrator provides services electronically via the Website.

  • Device - an electronic device with software through which the User gains access to the Website

  • Cookies - text data collected in the form of files placed on the User's Device

  • GDPR - 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 data) 

  • Personal data - means information about an identified or identifiable natural person ("data subject"); an identifiable natural person is one 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, the economic, cultural or social identity of the natural person 

  • Processing - means an operation or set of operations performed on personal data or sets of personal data, whether or not by automated means, such as collecting, recording, organizing, structuring, storing, adapting or modifying, downloading, viewing, using, disclosing by sending, disseminating or otherwise kind of sharing, aligning or combining, restricting, deleting or destroying; 

  • Restriction of processing - means marking stored personal data in order to limit their future processing.

  • Profiling - means any form of automated processing of personal data, which consists in using personal data to evaluate certain personal factors of a natural person, in particular to analyze or predict aspects regarding the performance of that natural person, his or her economic situation, health, personal preferences, interests, reliability , behavior, location or movement 

  • Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which the data subject, by means of a statement or a clear affirmative action, signifies agreement to the processing of personal data concerning him or her.

  • Breach of personal data protection - means a breach of security leading to accidental or unlawful destruction, loss, modification, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise processed.

  • Pseudonymization - means the processing of personal data in such a way that they can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to prevent their attribution to an identified or an identifiable natural person 

  • Anonymization - Data anonymization is an irreversible process of data operations that destroys / overwrites "personal data", making it impossible to identify or link a given record with a specific user or natural person.

§2 Data Protection Inspector

Pursuant to Article 37 of the GDPR, the Administrator did not appoint a Data Protection Inspector.

In matters relating to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

  • Internal cookies - files placed and read from the User's Device by the Website's IT system

  • External cookies - files placed and read from the User's Device by the IT systems of external websites. Scripts of external websites that may place Cookies on User's Devices have been consciously placed on the Website through scripts and services made available and installed on the Website.

  • Session cookies - files placed and read from the User's Device by the Website during one session of a given Device. After the session ends, the files are deleted from the User's Device.

  • Persistent cookies - files placed and read from the User's Device by the Website until they are manually deleted. Files are not deleted automatically after the end of the Device session, unless the configuration of the User's Device is set to delete cookies after the end of the Device session.

§4 Security of data storage

  • Mechanisms for storing and reading Cookie files - Mechanisms for storing, reading and exchanging data between Cookies saved on the User's Device and the Website are implemented through built-in mechanisms of web browsers and do not allow downloading other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. It is also practically impossible to transfer viruses, Trojan horses and other worms to the User's Device.

  • Internal cookies - cookies used by the Administrator are safe for Users' Devices and do not contain scripts, content or information that may threaten the security of personal data or the security of the Device used by the User.

  • External cookies - the Administrator takes all possible actions to verify and select website partners in the context of Users' security. The administrator selects well-known, large partners with global social trust for cooperation. However, it does not have full control over the content of cookies from external partners. The Administrator is not responsible for the security of Cookie files, their content and the license-compliant use by Scripts installed on the website from external websites, to the extent permitted by law. The list of partners is provided further in the Privacy Policy.

  • Cookie control

     

  • Threats on the User's side - The Administrator uses all possible technical measures to ensure the security of data stored in cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User's activity. The Administrator is not responsible for intercepting this data, impersonating the User's session or deleting it as a result of the User's conscious or unconscious activity, viruses, Trojan horses and other spyware that may have infected the User's Device. To protect themselves against these threats, users should follow the following instructions:rules for using the network.

  • Storage of personal data - the Administrator ensures that he makes every effort to ensure that the processed personal data entered voluntarily by Users are safe, access to them is limited and carried out in accordance with their purpose and processing purposes. The Administrator also ensures that it makes every effort to protect its data against loss by using appropriate physical and organizational security measures.

§5 Purposes for which cookies are used

  • Improving and facilitating access to the Website

  • Personalization of the Website for Users

  • Marketing, Remarketing on external websites

  • Advertising serving services

  • Maintaining statistics (users, number of visits, types of devices, connection, etc.)

  • Providing community services

§6 Purposes of personal data processing

Personal data voluntarily provided by Users is processed for one of the following purposes:

  • Implementation of electronic services:

    • Services for sharing information about content posted on the Website on social networking sites or other websites.

  • The Administrator's communication with Users on matters related to the Website and data protection

  • Ensuring the legally justified interest of the Administrator

User data collected anonymously and automatically is processed for one of the following purposes:

  • Keeping statistics

  • Remarketing

  • Serving advertisements tailored to Users' preferences

  • Ensuring the legally justified interest of the Administrator

§7 Cookies of external websites

The Administrator of the Website uses JavaScript scripts and web components of partners who may place their own cookies on the User's Device. Remember that in your browser settings you can decide about allowed cookies that can be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

Services provided by third parties are beyond the Controller's control. These entities may change their terms of service, privacy policy, purpose of data processing and methods of using cookies at any time.

§8 Types of data collected

The website collects data about Users. Some of the data is collected automatically and anonymously, and some of the data is personal data provided voluntarily by Users when signing up for individual services offered by the Website.

Anonymous data collected automatically:

  • IP address

  • Browser type

  • Screen resolution

  • Approximate location

  • Opened website subpages

  • Time spent on the appropriate subpage of the website

  • Type of operating system

  • Address of the previous subpage

  • Referrer address

  • Browser language

  • Internet connection speed

  • Internet service provider

  • Demographics (age, gender)

Data collected during registration:

  • Name/surname/nickname

  • E-mail adress

  • Phone number

  • IP address (collected automatically)

Data collected when subscribing to the Newsletter service

  • Name/surname/nickname

  • E-mail adress

  • IP address (collected automatically)

Some data (without identifying data) may be stored in cookies. Some of the data (without identifying data) may be transferred to a statistical service provider.

§9 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or resold to third parties.

Access to data (usually on the basis of a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the website, i.e.:

  • Hosting companies providing hosting or related services to the Administrator

Entrusting the processing of personal data - Hosting Services, VPS or Dedicated Servers

To run the website, the Administrator uses the services of an external hosting provider, VPS or Dedicated Servers - WIX. All data collected and processed on the website are stored and processed in the service provider's infrastructure located within the European Union. It is possible to access data as a result of service work carried out by the service provider's staff. Access to this data is regulated by the contract concluded between the Administrator and the Service Provider.

 

§10 Method of processing personal data

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless they have been published as a result of an individual action by the User (e.g. entering a comment or entry), which will make the data available to every person visiting the website.

  • Personal data will not be used for automated decision-making (profiling).

  • Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) will be transferred outside the European Union.

  • Anonymous data (without personal data) will not be used for automated decision-making (profiling).

  • Anonymous data (without personal data) will not be sold to third parties.

§11 Legal basis for the processing of personal data

The website collects and processes Users' data on the basis of:

  • 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)

    • art. 6 section 1 letter and
      the data subject has consented to the processing of his or her personal data for one or more specific purposes

    • art. 6 section 1 letter b
      processing is necessary for the performance of a contract to which the data subject is party or to take action at the request of the data subject before concluding the contract

    • art. 6 section 1 letter f
      processing is necessary for the purposes of the legitimate interests pursued by the administrator or a third party

  • Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)

  • Act of July 16, 2004, Telecommunications Law (Journal of Laws 2004, No. 171, item 1800)

  • Act of February 4, 1994 on copyright and related rights (Journal of Laws 1994, No. 24, item 83)

§12 Personal data processing period

Personal data provided voluntarily by Users:

As a rule, the indicated personal data are stored only for the period of provision of the Service on the Website by the Administrator. They are deleted or anonymized within a period of up to 30 days from the end of the provision of services (e.g. deletion of a registered user account, unsubscription from the Newsletter list, etc.)

An exception is a situation that requires securing legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data from the time the User requests their removal, no longer than for a period of 3 years in the event of a violation or suspected violation of the provisions of the website regulations by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, which do not constitute personal data, are stored by the Administrator in order to maintain website statistics for an indefinite period of time.

§13 Users' rights related to the processing of personal data

The website collects and processes Users' data on the basis of:

  • The right to access personal data
    Users have the right to access their personal data upon request submitted to the Administrator

  • The right to rectify personal data
    Users have the right to request from the Administrator to immediately correct personal data that is incorrect and/or complete incomplete personal data, upon request submitted to the Administrator.

  • The right to delete personal data
    Users have the right to request the Administrator to immediately delete personal data, which is carried out upon request submitted to the Administrator. In the case of user accounts, deletion of data involves anonymization of data enabling the User's identification. The Administrator reserves the right to suspend the execution of a request to delete data in order to protect the Administrator's legitimate interest (e.g. when the User has violated the Regulations or the data was obtained as a result of correspondence).
    In the case of the Newsletter service, the User has the option of deleting his/her personal data on his/her own using the link included in each e-mail message sent.

  • The right to restrict the processing of personal data
    Users have the right to limit the processing of personal data in the cases indicated in Art. 18 GDPR, among others questioning the accuracy of personal data, carried out upon request submitted to the Administrator

  • The right to transfer personal data
    Users have the right to obtain from the Administrator personal data regarding the User in a structured, commonly used, machine-readable format, carried out upon request submitted to the Administrator.

  • The right to object to the processing of personal data
    Users have the right to object to the processing of their personal data in the cases specified in Art. 21 GDPR, carried out upon request submitted to the Administrator

  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data.

§14 Contact to the Administrator

You can contact the Administrator in one of the following ways

  • Postal address - LET'S DO ADS Sp. z o. o. street Piękna 24/26A, 00-549 Warsaw

  • E-mail address - hello@letsdoads.pl

  • Telephone call - +48 572118762

  • Contact form - available at: /kontakt

§15 Website Requirements

  • Restricting the storage and access to cookies on the User's Device may result in incorrect operation of some functions of the Website.

  • The Administrator is not liable for incorrectly functioning functions of the Website if the User limits in any way the ability to save and read Cookie files.

§16 External links

The Website - articles, posts, entries or comments by Users - may contain links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated under them may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for the content located outside the Website.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to make any changes to this Privacy Policy without the need to inform Users regarding the use and use of anonymous data or the use of cookies.

  • The Administrator reserves the right to make any changes to this Privacy Policy regarding the processing of Personal Data, about which it will inform Users who have user accounts or are subscribed to the newsletter service via e-mail within 7 days of changing the records. Further use of the services constitutes reading and acceptance of the changes introduced to the Privacy Policy. If the User does not agree with the changes introduced, he or she is obliged to delete his or her account from the Website or unsubscribe from the Newsletter service.

  • Changes introduced in the Privacy Policy will be published on this subpage of the Website.

  • The changes introduced come into force upon publication.

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