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Privacy Policy

Privacy Policy
 

PRIVACY POLICY
of
ADAPTIVE GROUP SP. Z O.O. (ADAPTIVE GROUP LTD)

Since 25 May 2018 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, the GDPR) provides for new legal framework relating to personal data protection.

Privacy, confidentiality and security of your personal data are very important for us.

We protect that data by implementing appropriate security measures, collect and process them lawfully, fairly and in a transparent manner, only for specified, explicit and legitimate purposes and they are not subject to further processing in a manner that is incompatible with those purposes,

In this Privacy Policy, we inform you about the way, in which we process your personal data fullfilling our obligations under Article 13 and Article 14 of the GDPR. 

What is personal data?

According to the GDPR personal data means any information relating to an identified or identifiable natural person (‘data subject’): an identifiable natural person, so the 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, economic, cultural or social identity of that natural person.

Who is personal data Controller ?

Adaptive Group Sp. z o.o. (Adaptive Group Ltd) seated in Lodz, 34 Narutowicza Street, 90-135 Lodz, registered in Register of Entrepreneurs of the National Court Register under No. KRS 0000546851, registry court, where the documentation of the Company is stored : Lodz-Śródmieście District Court, XX Commercial Department of the National Court Register, share capital : 120.000 zł (PLN), NIP (tax identification number) : 7252083756, REGON: 360954025.

How to contact us in matters connected with personal data?

As for data protection issues please contact us via e-mail : contact@adaptivesag.com

What categories of personal data we collect, in what purposes and on what legal basis ?

We collect only the personal data that is necessary in relation to the purposes such as:

  1. our contact before conclusion of the contract between us, then for it proper performance and documentation of that fact and for ongoing contact in connection with our contractual relations - so the processing is based on Article 6 paragraph b) of the GDPR. Usually we process not more than your: name, surname, address, telephone number, a bank account number, and in relation with entrepreneurs also tax identification number, name of the company; other data only if it’s necessary to conclude our contract and to provide on its basis services to you. Provision of personal data is voluntary however it constitutes a necessary condition to enter into the contract.
  2. fulfilment of our legitimate interests as a data Controller:
    • processing personal data of contact persons indicated in concluded contracts,
    • establishment of claims, redress, or defence against claims,
    • having the database of our Contractors and suppliers for repeated orders and supplies within the framework of trade/commercial relations,
    so the processing data is based on Article 6 paragraph 1 f) GDPR,
  3. storage of the contracts and accounting documents connected with our economic activity which is based on acts of fiscal legislation, so under Article 6 paragraph 1 c) of the GDPR - processing is necessary to comply with our legal obligation,
  4. having our company’s profile in social and professional media (such as Facebook, LinkedIn) - we can process your personal data as users of such media, in case of using their functionalities. While conducting and managing our profiles/accounts in social/professional media, depending on your acitivity there (for example by liking/sharing/recommending our posts or publications, making comments, liking websites or observing it) and according to social/professional media’s conditions and polices, we can process your personal data which you share or disclose, for example: your login/username or profile photo. Processing takes place under Article 6 paragraph 1 f) of the GDPR, so it is carried out for our legitimate interests as a data Controller, which consists in creating and mantaining a social/bussines network connected with our company by having such profile/account, informing about our activity, promoting our events and services as well as to communicate with users of social/profesional media.

    We would like to inform you regardless of having or not your profile/account on social/professional media we can use all functionalities/tools available on those media such as: parameters setting, filters, criterias for statistics to prepare relevant information about our company and to present the best offer which includes also creating events connected with our activity. That is why our activity on social/professional media (having profiles/accounts there) enables those media storing the cookies on the computer or any other device of a person who even only visits our profile/account or is observing/ following our content posted on social/professional media.

    The details regarding data processing rules (including cookies) applied by given social/professional media is available in its privacy and cookies policy which you can currently find e.g.:

    on Facebook:

    https://pl-pl.facebook.com/privacy/explanation: https://www.facebook.com/policies/cookies/,

    on LinkedIn: https://www.linkedin.com/legal/privacy-policy?_l=pl_PL, https://www.linkedin.com/legal/cookie-policy,

    so if visiting our social/professional account/profile we encourage you to visit first those media privacy and cookies policy.

Whose personal data we process and from who it is obtained?

Personal data are collected directly from you, however it can be also obtained from other person/entity in situations as follows :

  • providing your personal data by our Client or Contractor in connection with a contract performance or with our bussines cooperation/partnership,
  • in other cases: from public resources such as National Court Register, Bussines Activity Central Register, Central Statistical Office, websites and portals, e.g: when we look for the cooperation with suppliers/service providers and other Contractors.

Do we disclose your personal data to other entities?

  1. Your personal data can be disclosed to other entities - data recipients:

    • service providers who support our business such as: external accounting office, server and e-mail providers,
    • other Contractors and subcontractors (including processors who process your personal data on the basis of our authorisation and on our instructions), also the insurers, in connection with our economic cooperation and in order to perform the contract properly,
    • banks or payment operators, when it is necessary for money transfer between us,
    • other recipients entitled to receive the data in accordance with domestic law,
  2. We do not transfer your personal data to a third countries which means outside European Economic Area.

How long do we store your personal data ?

  1. Data contained in contracts concluded between us and/or in our communication by e-mail regarding our contractual relations are stored by us for the legal claims limitation period, as for accounting documents – for the taxpayer’s liability limitation period. For longer period we store personal data only for compliance with a legal obligation to which we as Controller are subject, e.g. data of those who we employ.
  2. For the longest period until the right to object has been exercised, we can store the data of our Contractors and suppliers, to have the database for repeated orders and supplies.

What rights do you have in connection with processing of your personal data ?

  1. Under the GDPR, you have the right to access to your personal data, their rectification, erasure, right of restriction of processing, the right to data portability and to object to personal data processing. If the processing is based on your consent (e.g. in case of direct marketing by e-mail) you have also the right to withdraw the consent at any time, which shall not however affect the lawfulness of processing based on consent before its withdrawal.
  2. Within the framework of the right to access to the data we provide a copy of the personal data that are subject to undergoing processing. For any further copies requested, we can charge a reasonable fee based on administrative costs. Where your request is made by electronic means, and unless otherwise requested, the information shall be provided in a commonly used electronic form.
  3. In order to exercise your rights connected with personal data processing please contact us – all contact details are availabe above in this Privacy Policy.
  4. You have also the right to lodge a complaint with a supervisory authority (in Poland: Prezes Urządu Ochrony Danych Osobowych), if the processing of personal data infringes the GDPR.

Are the personal data subject to automated processing and profiling ?

Processing of your personal data is not based on automated processing (including profiling), however to a certain extent we do analyse your eventual preferences regarding our services taking into account the previous contractual relations, to prepare our current offer better.

Our website and cookies

  1. Our website (the Service) uses files/small pieces of text called cookies.

    The Service shall mean website/application of which we are Operator, excluding our professional accounts and profiles in social media and networking platforms, which operates on the basis of their own, published privacy and cookies policies.

    The Service does not collect by automated means any information except for information contained in cookies. Cookies help to analyse users’ activity in our Service.

  2. Cookies are small pieces of data (text files) sent from a website and stored on the user's computer by the user's web browser/a computer hard drive, used in order to improve the functionnalities of the Service’s websites. Cookies contain mainly a name of the website, which they are obtained from, their storage time and their unique number.
  3. We use and store cookies as the Service Operator in a way explained below.
  4. Cookies are used by the Service:
    • 4.1.  to optimise websites content and structure to best suit individual preferences of users, and to recognise users’ devices to display websites in a proper way and well adapted to these preferences.
    • 4.2. for anonymous statistics which help to analyse users’ activity on websites and their preferences to prepare better structure and content.
  5. There are two basic types of cookies: session cookies and persistent (tracking cookies). Session cookies are disapearing as soon as a user leaves a Website (logs out/turns of the software or web browser), whereas persistent cookies are stored on the user’s computer until they expire or until the user deletes them.
  6. Our Service, as it is using statistics/analytics tools (Google Analytics, Facebook Piksel), uses the following such cookies as:
    • „essential cookies” which enable the use of the services availabe (e.g. of those that require user’s authentication, verification);
    • „performance cookies” used to generate anonymous information about how users use the Service and its features;
    • „advertising cookies” used in order to provide users with more relevant advertisements;
  7. Most browsers are initially set to accept cookies. User may change the browser settings at any time to block the cookies, he or she can also, on a current basis, obtain information on cookies located in user’s device. For more information we recommend visiting your browser and consulting its settings.
  8. The Service Operator informs that the change of the browser settings and disabling cookies may affect websites’ functioning.
  9. Cookies used by the Service and stored on the users’ terminal equipment can be also used by partners and advertisers cooperating with us.
  10. The Service may contain, when relevant and for users’ information, links and references to other sites but has no responsability for their content and their privacy policies.
  11. For more information about cookies please consult “Help” option on the toolbar of your browser.
Privacy Policy