Privacy and cookies policy
PRIVACY AND COOKIES POLICY WEBSITE www.anitagosiewska.com
(last updated: November 11, 2024)
§ 1. ADMINISTRATOR OF THE PERSONAL DATA, DEFINITIONS, INTRODUCTORY INFORMATION
Notwithstanding any other definitions as established in the content of this Privacy Policy, whenever the following terms are capitalized in the text of the Privacy Policy, they shall have the meaning ascribed to them below:
- The Operator of the Website and the Administrator of the Personal Data of Website Users, hereinafter also referred to as the Administrator, is:
ANITA GOSIEWSKA, conducting business in Warsaw, at Jana Olbrachta 29 / 113, 01-102 Warsaw, TIN: 7182115527, REGON: 366552859.
Administrator’s contact information:
Mailing address: Jana Olbrachta Street 29 / 113, 01-102 Warsaw
E-mail address: pause@anitagosiewska.com
Phone number: +48 518 739 067 - Privacy Policy – means this Privacy and Cookies Policy of the www.anitagosiewska.com Website, setting out detailed rules for the processing and protection of Users’ personal data and the use of cookies on the Website, available at www.anitagosiewska.com, in the footer of the Website under the button: “PRIVACY AND COOKIES POLICY“.
- RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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).
- Website – the Website run by the Administrator, available at the following address: www.anitagosiewska.com, through which the User may obtain information about the Administrator, the Administrator’s business activities and the possibility of entering into a specific agreement the subject of which are the services offered by the Administrator, establish contact with the Administrator or the Administrator’s representatives, as well as perform other activities covered by the functionalities of the Website and provided for in the Terms and Conditions and in this Privacy Policy.
- Personal Data Protection Act – the Act of May 10, 2018 on the protection of personal data (i.e., Journal of Laws of 2019, item 1781).
- User – an individual who visits the Website page(s) and/or uses the services and functionalities of the Website as described in this Privacy Policy and in the Terms and Conditions of the Website (hereinafter referred to as “Terms and Conditions“).
- Provision of personal data for the purposes of processing by the Administrator is voluntary, and consent to processing may be withdrawn at any time.
- Users’ personal data are stored in a database, on the Administrator’s servers or on servers belonging to the Administrator’s service providers, using technical and organizational measures required by generally applicable laws.
- The Administrator uses security measures to protect personal data from loss, misuse and modification.
- This Privacy Policy does not cover in its scope any information, advertising and content regarding goods and services provided by entities other than the Administrator, which are posted on the Website regardless of the basis and purpose of their posting. The User is advised to read the privacy policy of the relevant third party before using or taking any action in relation to the posted information and content.
- This Privacy Policy does not cover in its scope the manner and extent of processing, storage and protection of personal data of Users who have moved to other separate platforms through the relevant functionalities of the Website, and this Privacy Policy and the Terms and Conditions, do not apply to them, unless otherwise directly stated in the Terms and Conditions and / or Privacy Policy.
- The Administrator shall make this Privacy Policy available through a link provided in the footer of the Website. The User may review the Privacy Policy at any time he/she chooses.
§ 2. PURPOSES, LEGAL BASIS AND DURATION OF PERSONAL DATA PROCESSING
- The Administrator may process the following categories of personal data and information concerning Users:
1) Information about the User’s device in order to ensure the correctness of the provision of services: the IP address of the computer, domain name, information contained in cookies or other similar technologies, session data, data and type of Internet browser, type of operating system, data about the device, data about activity on the Website, including on individual subpages;
2) geolocation information, if the User has consented to the Administrator’s access to the User’s geolocation; geolocation information is used to provide more customized information and offers to the User;
3) Users’ personal data: name, surname, e-mail address, telephone number, mailing address, required for the purpose of contacting the Administrator or its representatives, including through the electronic contact form available in the “Contact” tab and the electronic form for Newsletter subscription available in the “Contact” tab and on the homepage of the Website and the procedures established therein, or for the purpose of initiating and carrying out the complaint process as described in the Terms and Conditions. - Although not all of the information listed in § 2 section 1 of the Privacy Policy may be considered personal data of Users, as it may obtain such qualification in combination with other information, the Administrator covers it with the full protection afforded to personal data under the RODO.
- Personal data may be processed for the following purposes and on the following legal grounds:
1) in order to conclude and perform a contract for the provision of services by electronic means (legal basis – art. 6. 1. b. RODO) – the purpose of processing personal data is to provide services; by using the Website and agreeing to the provisions contained in the Terms and Conditions and Privacy Policy, the User enters into an agreement with the Administrator for the provision of services electronically, consisting of making it possible to use the functionalities of the Website, in particular to receive and handle inquiries directed by Website Users, to take certain actions at the request of the person to whom the personal data pertains; failure to provide the required personal data may result in limiting the User’s ability to use all the functionalities of the Website;
2) in order to fulfill the Administrator’s legal obligations in connection with the concluded contract for the provision of services by electronic means (legal basis art. 6.1.c RODO in connection with art. 6.1.b RODO) – the purpose of processing personal data is to fulfill the Administrator’s legal obligations in connection with the concluded contract for the provision of services by electronic means, including the realization of rights and obligations of complaints;
3) for the purpose of defending, asserting or establishing claims related to the contract for the provision of electronic services, which is the legitimate interest of the Administrator (legal basis Article 6.1.f. RODO) – the purpose of processing personal data is to secure information in case of a legal need to prove certain events, which is the legitimate interest of the Administrator;
4) for purposes related to cookie technology, based on the consent of the data subject (legal basis of Article 6.1.a. and Article 6.1.f. of the RODO) – processing of personal data in the subject area takes place only on the basis of a separate consent expressed by the User for the processing of personal data, the use of cookies or other similar technologies, expressed by a statement made at the time of the first visit to the Website from the User’s device, through the appropriate functionalities of the Website, and thus before the conclusion of the agreement on the provision of services electronically;
5) for direct marketing purposes (legal basis art. 6.1.f RODO) – in order to offer the Administrator’s services, most often in the form of online advertising, selected according to the User’s interests, and through the Newsletter, which is the Administrator’s legitimate interest; the Administrator may use electronic communication tools for this purpose, such as, in particular, the e-mail address provided by the User;
6) for analytical purposes (legal basis Art. 6.1.f RODO) – including – researching opinions of Website Users, contacting Website Users for analytical purposes; on the basis of analysis of User activity on the Website, the Administrator is able to better select content and services and adjust them to the needs of Users, develop statistics related to the use of the Website, research satisfaction with offered services and determine their quality, as well as take care of data security on the Website, which constitutes the Administrator’s legitimate interest. - Personal data collected by the Administrator will be processed for no longer than necessary for the purposes for which the personal data was collected:
1) Personal data collected for the purpose of entering into and performing a contract for the provision of electronic services will be stored and processed for the period of entering into and performing the contract in question, and thereafter for the required data archiving period provided by law.
2) Personal data collected for the purpose of fulfilling the Administrator’s legal obligations under the concluded contracts will be processed for the period necessary for the purpose of fulfilling the Administrator’s legal obligations.
3) Personal data collected for the purpose of defending, asserting or establishing claims related to concluded contracts will be processed for the period of assertion, defense or establishment of claims, but no longer than until the statute of limitations for claims.
4) Personal data collected for the purpose of handling inquiries made by Users of the Website will be processed for the period necessary to contact the User and settle the matter.
5) Personal data collected for marketing and analytical purposes will be processed for the duration of the marketing action or until the receipt of the object to such processing.
6) Personal data collected for the purpose of surveying Users’ opinions will be processed for the duration of the survey and for the period of analysis of its results.
7) Personal data collected for the purposes of cookie technology – personal data will be processed until withdrawal of the consent granted.
8) Personal data will also be processed until the expiration of statutory limitation periods for claims or the expiration of archiving obligations under applicable laws. - The Administrator shall cease processing personal data which were collected on the basis of the Administrator’s legitimate interest, whenever the person whose personal data are being processed objects to the processing of personal data and, moreover, when the consent on the basis of which the personal data were collected and are being processed is withdrawn, or the Administrator determines that the data are no longer relevant.
- Information and personal data about Users are obtained by voluntarily entering personal data and information into the Website’s systems through electronic forms available on its pages, voluntarily providing personal data in the process of contacting the Administrator through other methods, as well as by automated means, through cookies stored in terminal devices and through the collection of web server logs by the Website’s hosting operator (necessary for the proper operation of the Website).
- The User may enter the Website without providing any personal data and browse the pages of the Website in such a mode, subject to the data which are collected automatically, which include mainly – IP address, domain name, type and type of browser, type of operating system, interests, age and gender of the Website user. The data in question are collected automatically mainly through cookies.
- Although the provision of personal data is voluntary and the consent to their processing may be withdrawn at any time, in a situation where the provision of personal data is necessary due to an existing legal obligation or for the purpose of entering into and performing a service contract and taking necessary actions prior to its conclusion, the User’s failure to provide the required personal data may result in the impossibility of entering into and performing a service contract.
- Personal data may be subject to automated decision-making, including profiling for the purpose of providing services under the concluded contract and for direct marketing. Profiling consists, in particular, in adjusting the display of content to Users’ preferences based on their previous choices.
- The user consents to the processing of personal data:
1) at the time of the first access to the Website by selecting the “I agree” option in the Privacy and Cookies Policy message;
2) Before selecting the “Send” button and thus – sending a message via the contact form available in the “Contact” tab of the Website, by checking the checkbox regarding consent to the processing of personal data;
3) Before selecting the “Sign Up” button and thus – subscribing to the Newsletter via an electronic form available in the “Contact” tab of the Website and on the homepage of the Website, by checking the checkbox regarding consent to the processing of personal data;
4) by initiating the complaint process, described in the Terms and Conditions, which requires the User’s personal information in order to process and respond to the User’s complaint.
§ 3. RECIPIENTS OF USER DATA
- The Administrator may provide the User’s personal data to entities that process personal data on behalf of the Administrator, i.e. external entities that provide services to the Administrator, on the basis of agreements concluded for the entrustment of personal data processing in order to perform services for the Administrator and in accordance with the Administrator’s instructions.
- Users’ personal data may be transferred to the following categories of entities that provide sufficient guarantees for the implementation of appropriate technical and organizational measures so that the processing meets the requirements of the RODO and the Personal Data Protection Act and protects the rights of data subjects:
1) Subcontractors – external companies providing services for the Administrator, in particular, such as: hosting, maintenance of servers, including email servers, maintenance of databases, maintenance, diagnostic and repair work, marketing, analytics, accounting, provision of widgets to be placed on the website, provision of a helpdesk type system, creation and provision of backups, services related to testing the quality of services provided, hosting, technical / IT support, marketing and PR services, legal and consulting services, advertisers and similar entities, and, moreover, to the extent arising from legal obligations – public authorities. These entities are recipients of the data, processors acting on behalf of and at the direction of the Administrator.
2) Advertisers – i.e. entities that, on the basis of information contained in cookies or other similar identifiers (if they contain personal data), participate in the process of selecting the content of advertisements that are displayed to Users on the Website. For more information on what cookies are and how they work, and how you can adjust your browser settings in this regard, see § 7 of this Privacy Policy. - Personal data will not be processed in third countries.
§ 4. RIGHTS OF PERSONAL DATA SUBJECTS
- Any person whose personal data are processed has the right to:
1) access (Article 15.1. of the RODO) – to obtain confirmation from the Administrator as to whether personal data concerning him or her is being processed. If personal data concerning a person is processed by the Administrator, he or she is entitled to access it and obtain the following information: about the purposes of processing, the categories of personal data, the recipients or categories of recipients to whom the data have been or will be disclosed, the period for which the data are stored or the criteria for determining the period in question, the right to request from the Administrator rectification, erasure or restriction of the processing of personal data to which the data subject is entitled, and to object to such processing, information about the right to lodge a complaint with a supervisory authority, and in addition, if the personal data have not been collected from the data subject – any available information about their source, information about automated decision-making, including profiling;
2) obtain a copy of the data (Article 15.3. RODO) – to obtain a copy of the data being processed, with the first copy being free of charge, and for subsequent copies the Administrator may impose a reasonable fee based on administrative costs;
3) rectify data (Article 16 of the RODO) – to request the rectification of personal data concerning a person that is inaccurate, or to complete incomplete data by providing an additional statement;
4) erasure (art. 17 RODO) – to request the erasure of personal data concerning a person if the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, the data subject has withdrawn the consent on which the processing is based and there is no other legal basis for the processing, the data subject objects to the processing and there are no overriding legitimate grounds for the processing, the personal data have been processed unlawfully, the personal data must be erased in order to comply with a legal obligation under European Union law or the law of a Member State to which the Administrator is subject, unless the processing of the personal data is necessary for the establishment, investigation or defense of claims, or there are other circumstances listed in Art. 17.3. RODO;
5) restrict processing(Article 18 of the RODO) – to request the restriction of processing of personal data concerning a person when:
I. the data subject disputes the accuracy of the personal data – for a period that allows the Administrator to verify the accuracy of the data,
II. processing is unlawful, and the data subject objects to the erasure of the data by requesting restriction of its use,
III. the Administrator no longer needs the data, but it is needed by the data subject to establish, assert or defend a claim,
IV. the data subject has objected to the processing – until it is determined whether the legitimate grounds on the part of the Administrator override the grounds of the data subject’s objection;
6) data portability (Article 20 RODO) – to receive in a structured, commonly used, machine-readable format personal data concerning a given person that he or she has provided to the Administrator, and to request that the data be sent to another administrator if the data are processed on the basis of the data subject’s consent or a contract with him or her, and if the data are processed by automated means;
7) object (Article 21 RODO) – to object to the processing of his/her personal data for the legitimate purposes of the Administrator, on grounds relating to his/her particular situation, including profiling. In such a case, the Administrator shall not be entitled to process such personal data unless the Administrator demonstrates the existence of compelling legitimate grounds for processing overriding the interests, rights and freedoms of the data subject, or grounds for establishing, asserting or defending claims. If personal data are processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of personal data concerning him or her for such marketing, including profiling, to the extent that the processing is related to such direct marketing;
8) withdraw consent at any time and without stating a reason, with the proviso that withdrawal of consent does not affect the lawfulness of the processing that was carried out on the basis of consent before its withdrawal. Withdrawal of consent will result in the Administrator ceasing to process personal data for the purpose for which the consent was given;
9) to file a complaint with the President of the Office for Personal Data Protection in any case in which the User believes that the Administrator has violated the regulations on personal data protection by his/her actions. - In order to exercise the above-mentioned rights, the data subject should contact the Administrator, using the Administrator’s contact information indicated in § 1.1 of this Privacy Policy, and inform the Administrator which right and to what extent he or she wishes to exercise. Please note and bear in mind that the execution of the User’s request will require confirmation of the User’s identity, which may require additional activity on the part of the User.
§5. PRESIDENT OF THE OFFICE OF PERSONAL DATA PROTECTION
- The subject of the processed personal data has the right to lodge a complaint to the supervisory authority, which in Poland is the President of the Office for Personal Data Protection, based in Warsaw, who can be contacted as follows:
1) By mail: 2 Stawki Street, 00-193 Warsaw;
2) via electronic mailbox available at: https://www.uodo.gov.pl/pl/p/kontakt;
3) By phone through the hotline, at 606-950-000. - You can read more about how to complain to the regulator at: https://uodo.gov.pl/pl/83/155.
- The subject of the processed personal data has the right to lodge a complaint to the supervisory authority, which in Poland is the President of the Office for Personal Data Protection, based in Warsaw, who can be contacted as follows:
§6. PRIVACY POLICY CHANGES
- The contents of the Privacy Policy set forth herein shall be effective as of the date indicated on the first page of the Privacy Policy, under the title, in the place “last updated (…)”.
- The Privacy Policy may be supplemented or updated according to the current needs of the Administrator in order to provide current and reliable information to the Users of the Website and to take into account any factual and legal changes that have occurred. The current Privacy Policy is available to Users at the appropriate link on the Website.
§7 COOKIES
- The Website performs the functions of obtaining information about Users and their behavior as follows:
1) through information voluntarily entered by the User into electronic forms made available on the Website and for purposes resulting from the function of a specific form, or provided to the Administrator in another form, including for the purposes of starting and carrying out the complaint process described in the Terms and Conditions;
2) by means of cookies stored in the User’s terminal equipment (so-called “cookies”) – after the User agrees to install cookies on his/her terminal equipment, which will enable the Administrator to provide services;
3) through the collection of web server logs by the Website hosting operator (necessary for the proper operation of the Website). - Cookies are IT data, in particular text files, which are sent while browsing the Website and stored on the User’s terminal device and are intended for the use of the Website. Cookies usually contain the name of the website they come from, the time they are stored on the User’s terminal device and a unique number.
- The entity placing cookies on the User’s terminal equipment of the Website and accessing them is the Administrator. The legal basis for the processing of personal data derived from cookies is the Administrator’s legitimate interests in ensuring high quality and security of services provided, and the consent of the User whose personal data is involved.
- The Website uses cookies after the User of the Website has given his/her prior consent in this regard. Consent to the Website’s use of all cookies is given by selecting the “I agree” option in the message regarding the Website’s use of cookies, which is displayed when you first access the Website.
- If a User of the Website does not consent to the Website’s use of cookies, he/she may make changes in the settings of the Internet browser he/she is currently using or via the “Settings” button in the message regarding the Website’s use of cookies, which is displayed when he/she first accesses the Website (however, this may cause the Website to function incorrectly).
- The process of giving and refusing consent may vary depending on the web browser. Please refer to the browser’s help or documentation for details. To manage cookie settings, select your browser/system from the list and follow the instructions: Internet Explorer, Chrome, Safari, Firefox, Opera, Android, Safari (iOS), Windows Phone.
- The Website uses two main types of cookies: “session” (session cookies) and “permanent” (persistent cookies). “Session” cookies are temporary files that are stored on the User’s terminal equipment until the User leaves the Website or shuts down the software (web browser). “Permanent” cookies are stored on the User’s end device for the time specified in the parameters of the cookies or until they are deleted by the User. In addition, we distinguish between own files (coming directly from the Website) and external files (coming from a third party through the Website). In the latter case, it is recommended to read the privacy and cookies policy of the third party.
- Cookies are used for the following purposes:
1) cookies remember the user’s preferences, which allows to increase the quality of services provided and improve the relevance of search results;
2) creation of statistics, which help to understand how the Users use the Websites, which allows to improve their structure and content;
3) To determine the User’s profile for the purpose of displaying product recommendations and tailored advertising materials to the User, in particular the Google network. - Web browsing software (Internet browser) usually allows cookies to be stored on the User’s terminal device by default. Users can change their settings in this regard. The web browser allows the removal of cookies. It is also possible to automatically block cookies through the appropriate settings of the web browser.
- Cookies do not cause configuration changes in devices and software installed in User’s devices.
- Restrictions on the use of cookies may affect some of the functionality available on the Website, and in some cases completely prevent the use of some of its functions and options.
- Cookies placed in the User’s end device may also be used by advertisers cooperating with the Website and Website partners.
- Cookies may be used by the Google network, to display advertisements tailored to the way the User uses the Website. For this purpose, they may retain information about the User’s navigation path or the time they stayed on a particular page: https://policies.google.com/technologies/partner-sites.
- The Website uses statistical analysis of website traffic through Google Analytics (Google Inc., based in the USA). Google Analytics, which automatically collects data about the User, is a web analytics system through which the Administrator obtains insight into the Website’s data traffic and User demographics, used for marketing purposes. It is recommended that the User read the Google Analytics privacy policy to learn about the use of cookies used in statistics: Google Analytics Privacy Policy can be found at the following link: https://policies.google.com/privacy?hl=pl. In order to block the operation of Google Analytics, you must disable the use of cookies.
- With regard to the information about User preferences collected by the Google advertising network, the User can view and edit the information resulting from cookies using the tool: https://www.google.com/ads/preferences/.
- There are plug-ins on the Website that may transmit Users’ data to administrators of portals such as: Facebook, Google, Instagram, LinkedIn, YouTube, Salesmanago, Gemius and others. The tool in question allows the indicated portals to identify visitors to the Website as a target group, to whom advertisements with appropriate content can then be displayed. In order to avoid the transfer of the data in question to the indicated portals, you should avoid clicking on links that take you to the said portals or log out of your account on the said portal before clicking on the link. The processing of personal data by the above portals shall be based on the rules and policies applied by the above portals. The Administrator recommends that you familiarize yourself with the documents in question before making the moves described in the preceding sentences.
§ 8. SECURITY OF PERSONAL DATA PROCESSING
- The Administrator uses security measures to protect personal data from loss, misuse and unauthorized modification.
- Taking into account the state of the technology, the nature, scope and purposes of the processing and the risk of violation of the rights or freedoms of natural persons with different probability of occurrence and severity, the Administrator has implemented appropriate technical and organizational measures to ensure a degree of security corresponding to the existing risk, in particular, it applies the measures listed below:
1) Minimize the required, collected and processed personal data;
2) Ability to continuously ensure the confidentiality, integrity, availability and resilience of processing systems and services;
3) Ability to quickly restore personal data availability and access in the event of a physical or technical incident;
4) Regularly test, measure and evaluate the effectiveness of technical and organizational measures to ensure processing security;
5) By default, only those personal data that are necessary to achieve each specific processing purpose are processed;
6) Collecting personal data for designated legitimate purposes and not subjecting it to further processing incompatible with those purposes;
7) Processing of personal data in a substantively correct and adequate manner in relation to the purposes for which they are processed;
8) Keeping records of persons authorized to process personal data. Persons who have been authorized to process data are obliged to maintain strict secrecy of personal data and ways of securing them;
9) Regular updating of all software used by the Administrator to process personal data, which in particular means regular updates of software components.