Clipatize Sp. z o.o. sp. k.
This Website represents Clipatize Sp. z o.o. sp. k., with its registered office in Warsaw, address: ul. Siewierska 16A/14, 02-360 Warsaw, entered into the register of entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register (KRS), under KRS number 559610, REGON 361597656.
- General provisions
I.1. The controller of personal data processed through the Website or other communication channels with the User is Clipatize Sp. z o.o. sp. k., with its registered office in Warsaw, address: ul. Siewierska 16A/14, 02-360 Warsaw, entered into the register of entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register (KRS), under KRS number KRS 0000559610, REGON 361597656; e-mail: firstname.lastname@example.org, tel. +48537190320, (charge per call according to the pricelist of the relevant operator), hereinafter referred to as “Clipatize”).
I.2. Clipatize processes the User’s personal data pursuant to the Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws of 2018, item 1000) and 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 (OJ L 119, p. 1) (hereinafter also referred to as: GDPR) and taking into account the provisions of the Act of 18 July 2002 on Providing Services by Electronic Means (Journal of Laws of 2017, item 1219, consolidated text of 2017.06.24, as amended).
I.3. Clipatize uses technical and organisational measures ensuring the protection of processed data, suitable for threats and categories of protected data, in particular it secures data against unauthorised access, takeover by an unauthorised person, processing in violation of applicable laws and any alteration, loss, damage or destruction.
- Scope of personal data protection and processing
II.1. Clipatize protects the personal data of the Users who visit the Website and the persons who share personal data through other communication channels. In particular, we protect the personal data of the users ofwww.facebook.com and any other Facebook branded or co-branded websites, whose principles of operation are based on the following: https://www.facebook.com/legal/terms, as provided by Facebook, Inc. or Facebook Ireland Limited, also via Facebook Lead Ads for direct marketing of Clipatize’s own products or services. The rules of personal data processing by Facebook are made available at: https://www.facebook.com/policy.php. Clipatize has no influence on the rules of personal data processing by Facebook.
II.2. Clipatize may process the following personal data of Users: name, e-mail address, contact phone number. In addition, the following personal data may be collected: information included in the user profile, confirmation of a private user status, IP address, operating system, browser type, browser version, browser configuration, ISP name and other information on the type of computer and Internet access used to identify the type of device, establish a connection to the Website, enable data exchange, URL address and IP address of the website from which the User visited or was redirected to the Website, including date and time, full history of clicks as URL addresses with date and time, subpages visited on the Website, activated links with date and time
II.3. Clipatize asks for consent prior to the beginning of collection, processing and use of the Users’ personal data.
II.4. The purpose and scope of personal data processing result from the User’s consent or generally applicable laws.
II.5. Clipatize ensures that the User’s personal data collected by the company are:
- a) processed lawfully, fairly and in a transparent manner in relation to the data subject;
- b) collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes;
- c) adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- d) accurate and, where necessary, kept up to date;
- e) kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
- f) processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
I.6. Clipatize has technical capacity to communicate with the User at a distance using electronic mail. The User can contact Clipatize at any time via e-mail using Clipatize’s address, a written letter sent by post and by phone using Clipatize’s phone number or via Facebook.
I.7. Clipatize keeps the correspondence with the User to answer the Users’ questions, carry out the complaint procedure and for statistical purposes. Personal data processed in this way will not be used to communicate with the User for any purpose other than handling the request. If the User contacts Clipatize via the form, Clipatize may request the User to provide personal data to confirm the User’s identity and to enable contact regarding the case. Such personal data may be transferred on a voluntary basis, however, it may be necessary to perform activities or obtain information of interest to the User.
I.8. Any commercial information related to Clipatize’s activity can be sent only with the prior consent of the User for the purpose of performing a Newsletter service agreement.
III. The purpose of using the Users’ personal data by Clipatize
III.1. In the light of the applicable regulations and, first of all, the security of the Users’ personal data, in each case of personal data processing by Clipatize, the purpose and scope of data processing result from the User’s consent or laws and are specified as a result of the User’s actions on the Website or through other communication channels with the User.
III.2. Clipatize processes personal data only for the following purposes:
- handling of complaints and any other claims;
- managing, operating, maintaining and improving the operation of the Website;
- analysing and testing the Users’ behaviour;
- answering the Users’ questions and processing briefs sent to Clipatize;
- enable Users to receive information on services via e-mail, telephone, fax, through a newsletter, SMS or MMS (direct marketing);
- sending messages dedicated to Users (e.g. reminders, technical information, updates, safety warnings, administrative messages and service bulletins);
- enabling the submission of prizes, sending questionnaires, information on lotteries, competitions or other promotional activities;
- for the purpose of performing the Newsletter service agreement, personal data may also be processed for marketing purposes of the products or services of the entities cooperating with Clipatize.
IV.1. Transfer of the Users’ personal data to third parties
IV.1. Clipatize shall not sell, exchange, lend, disclose, transfer or otherwise provide access to any personal data of the Users, except when the User has given his or her consent and except for the circumstances described below.
IV.2. Clipatize may transfer the Users’ personal data to the following entities:
- providers of hosting and ICT services, software servicing companies, supporting Clipatize in marketing campaigns, as well as providers of legal and consulting services;
- entities using Cookies on the Website;
- legal service providers (in particular law firms and debt collection companies) as well as audit and consulting services;
- other entities entrusted by Clipatize with personal data processing while maintaining a full guarantee of securing personal data of the Users.
IV.3. The catalogue of recipients of personal data processed by Clipatize each time results mainly from the scope of services utilised by the User and from the User’s consent or laws, and it is specified as a result of the User's actions on the Website.
II.4. Personal data may be made available by Clipatize when it is necessary to protect the rights or security of Clipatize, other Users or third parties - under the applicable law.
- Transfer of the Users’ personal data to third countries (outside the European Economic Area)
V.1. Collected personal data is stored and processed within the European Economic Area, subject to section X.
- Voluntary submission of personal data
VI.1. The User provides his or her personal data on the Website voluntarily, however, it is necessary to use specific Website features, including, in particular, to establish contact and to send a brief or sign up for a meeting.
VI.2. The scope of data required for the above purposes is each time pre-indicated on the Website as part of other communication channels with the User, or in the Terms. The consequence of not submitting the Personal Data can be the lack of ability to effectively do the above activities.
VII. Basis for personal data processing by Clipatize
VII.1. The legal grounds for the processing of the User’s personal data is the User’s voluntary consent to contact Clipatize, in particular communication via the contact form (Art. 6(1)(a) of GDPR).
VIII.2. To handle complaints and any other claims, the basis for processing is the legitimate interest of Clipatize (Art. 6(1)(f) of GDPR).
VII.3. In the case of data processing operations for marketing purposes, except for those carried out as part of a newsletter, the basis for such processing is to meet the objectives arising from legitimate interests pursued by Clipatize or its partners (Art. 6(1)(f) of GDPR); in this case the partners do not participate in the processing of the User's data.
VII.4. To the extent that Clipatize’s partners may have direct access to such information, the legal grounds for such processing is the User’s voluntary consent (Art. 6(1)(a) of GDPR).
VII.5. For other purposes, the User's Personal Data may be processed on the basis of:
- voluntary consents (Art. 6(1)(a) of GDPR);
- applicable laws (Art. 6(1)(c) of GDPR);
- necessary purposes other than those listed above, resulting from legitimate interests pursued by Clipatize or a third party, in particular to establish, investigate or defend claims, maintain correspondence with the User, also via contact forms (including responding to Users’ messages), market and statistic analyses (Art. 6(1)(f) of GDPR).
VIII. Users’ rights in respect of personal data processing
VIII.1. Each User has the right to access their personal data and to change their personal data.
VIII.3. Each person has the right to control the processing of data concerning him or her, including the right to access his or her personal data, to request their update, rectification and erasure and the right to object in cases specified in the provisions of the Act on the Protection of Personal Data.
VIII.4. If the User demonstrates that the personal data are incomplete, out of date, incorrect or have been collected in violation of the law or are unnecessary for the purpose for which they have been collected, Clipatize is obliged, without undue delay, to complete, update or rectify the data, temporarily or permanently suspend the processing of the questioned data or erase them, unless this applies to the personal data for which the procedure for their completion, updating or rectifying is determined by law.
VIII.5. Each User has the right to file a complaint to the President of the Office for Personal Data Protection.
VIII.6. Each User has the right to transfer Personal Data which he or she provided to Clipatize and which are processed in an automated manner, and the processing takes place under a consent or contract.
VIII.7. Each User has the right to withdraw any consent given to the Controller at any time, whereas the withdrawal of consent will not affect the processing by the Processor in accordance with the law before its withdrawal.
VIII.8. Each User has the right to object to the processing of the Personal Data concerning him or her to pursue legitimate interests of the Processor or a third party, including in particular to the processing for marketing purposes, including profiling (if there is no other legitimate grounds for processing, overriding the User's interests).
- Personal data storage period
IX.1. Personal Data may be kept by Clipatize for the period of:
- a) resulting from accounting and tax regulations that oblige Clipatize to store accounting documents, and
- b) for legal security reasons, until the limitation of claims, which occurs after two years from the date of the agreement
- depending on which of these two periods (a or b) is longer.
IX.2. To the extent to which the personal data is processed under the User’s consent, the personal data will be processed until it is withdrawn.
IX.3. In the case of marketing activities, personal data may be stored until the User objects, and if they apply to Cookies and similar technologies, depending on technical issues, until such files are erased with the use of the browser / device settings (the erasure of files does not always means the erasure of Personal Data obtained through these files, hence the option to object).
X.2. The Cookies technology used by Google Analytics collects information about each person visiting the Website; the following provisions of the Policy apply to persons who use the Website, regardless of whether they are its Users.
X.4. Clipatize may process the data contained in the Cookies while the visitors use the Website for the following purposes:
- storage of data from the filled Contact Form and Brief Form;
- keeping anonymous statistics on how the Website is used.
X.5. The information obtained via Cookies is stored on servers used by Google Inc, including in the United States territory. If the IP address anonymisation is activated when using the Website, the IP address will be shortened in the member states of the European Union or other parties to the Agreement on the European Economic Area. In exceptional cases, the full IP address will be transferred to the United States and shortened there.
X.5. Web browsers and devices available on the market by default accept the saving of Cookies. The terms of using Cookies can be determined in the web browser or device settings. This means that it is possible to partially limit or completely turn off the option to save Cookies. It should be borne in mind that the limitations on saving Cookies may make it difficult or impossible to use the Website.
X.6. If the User gives his or her consent, including to the presentation, creation, granting and execution of dedicated advertising, offers or promotions (discounts) adjusted to his or her preferences, it may be withdrawn at any time - this will not affect the compliance with the processing right granted under the consent prior to its withdrawal.
X.7. It is possible to prevent the transmission of data from the User’s device to Google Analytics via Cookies (including the transfer of IP address) by downloading and installing the browser plug-in provided by Google Inc at the following address: https://tools.google.com/dlpage/gaoptout?hl=pl .
X.8. Detailed information on the terms of the above services, including the terms of data collection and processing, are available here: www.google.com/intl/pl/policies/privacy/partners/.
X.9. Depending on the purposes and legal grounds for the processing of Personal Data collected by Cookies, they can be stored for the period specified in section IX of the Policy. The collected Personal Data concerning a person who is not a User shall be stored until objection is made. Clipatize may remove Personal Data if they are not used for marketing purposes for 3 years, unless the applicable laws oblige Clipatize to longer processing of Personal Data. A part of the Personal Data may be stored longer in the event that the person visiting the Website has any claims against Clipatize or for Clipatize to assert claims or defend against claims (including by third parties), for the period of their limitation, as specified by the laws, in particular the Civil Code. In any case, the longer period for the storage of Personal Data shall prevail.
- Personal Data Security
Clipatize uses technical and organisational measures ensuring the protection of processed data, suitable for threats and categories of protected data, in particular it secures data against unauthorised access, takeover by an unauthorised person, processing in violation of applicable laws and any change, loss, damage or destruction. Clipatize provides, for example, the following technical measures to prevent the acquisition and modification by unauthorised persons of Personal Data sent by electronic means.
XII. Final provisions
XII.2. Any actions related to personal data processing are based on the prior voluntary consent given by the User or the applicable laws.