1. Data Controller
In matters regarding your personal data, you can contact us:
- by mail or personally – 43B Jana Pawła II Avenue, 31-864 Kraków, Poland,
- by e-mail: firstname.lastname@example.org
2. Purpose and legal basis of processing of personal data
- to respond to your requests for contact sent to us via contact form or to consultant’s contact details – based on our legitimate interest as a personal data controller,
- to analyze the use of the Website, as well as to improve its functioning and security – based on our legitimate interest as a personal data controller,
- to pursue and defend against claims, before courts and administrative authorities and outside them – based on our legitimate interest as a personal data controller,
- for direct marketing of products or services – based on our legitimate interest if we have an existing business relationship with you, and if we are just going to establish such a relationship – based on your consent,
- to send newsletters – based on our legitimate interest if we have an existing business relationship with you or if we are just going to establish such a relationship – based on your consent,
- for data archiving and backing up – in connection with the obligation imposed on us as a data controller to properly secure data and based on our legitimate interest as a personal data controller.
3. Data processed for contact and marketing purposes – scope of processing
In the event that you decide to contact us using the contact form available on our Website, or using our email addresses, phone numbers, we will process personal data that you provide to us or are necessary to respond to your inquiry (including identification and contact details, as well as the IP address when using the form contact on our Website), or which you decide to provide us with. We process these data due to the fact that they are necessary to pursue the legitimate interests of Ailleron and in cases when your consent is needed – based on your consent, i.e.:
- in order to reply to a message sent to us and further contact with you,
- for direct marketing of products and services,
- for archiving and backing up data in connection with the obligation imposed on us as a data controller to properly protect data).
In the event that you sign up to our newsletter we will process: e-mail address, name, date and time of signing up to our newsletter.
4. Data processed in connection with the use of our Website – scope of processing
If you use the Website, we save data such as: IP address, type and version of the device and browser you use, region, Website settings, choices made in the area of cookies, and how you use the Website. In most cases, we will not be able to identify you as a user and this data will be anonymous to us. However, in a situation where we are able to connect them with you, which may occur when we have additional data from another source (e.g. we will save such data when you contact us using the contact form), they become your personal data for us. We process this data
- due to the fact that they are necessary for purposes resulting from legitimate interests pursued by us, that is in particular:
- adjusting the way the Website is displayed and personalizing it,
- analyzing the Website’s behavior to improve its functioning and protect against abuse,
- based on your consent – if this data is used for marketing purposes and we do not have an existing business relationship, or when it is collected to provide it to third parties.
Our external service provider (Hubspot) will be able to attribute data gathered using cookies (views of the Website) to your contact data (e-mail address) if you click a link in a tracked marketing email which directs you to our Website. In marketing emails, HubSpot will only associate the cookie with an existing contact once. Any subsequent clicks on email links such as in a forwarded email will assign a temporary identity to the cookie. You must then submit a form, or enter your information via another method for HubSpot to identify you and associate the cookie with your record. More information about how cookies or other mechanisms from Hubspot work, can be found here: https://knowledge.hubspot.com/account/how-does-hubspot-track-visitors.
5. How long we process personal data
Your personal data will be processed:
- to contact you – from the day they were collected and as long as we are holding the conversation in the matter in which you made contact,
- for marketing purposes – for the duration of our legitimate interest, i.e. the duration of the relationship that connects us or until consent is withdrawn, if it was given to us, but not longer than for 3 years from the end of the year during which the consent has been given,
- for sending newsletter – from the day you give your consent and up to the day you withdraw your consent,
- for the purposes of pursuing and defending against claims – for a period not exceeding the limitation period for claims,
- for the purposes of performing obligations imposed by law – for a period not longer than necessary to demonstrate that these obligations were carried out by Ailleron,
- for the purpose of improving the functioning and security of the Website – for the time for which these data are necessary to achieve this purpose, but no longer than until you express an effective objection to their processing,
- for archiving and backup purposes – for the period determined in accordance with the backup and archiving policy at Ailleron.
6. Data recipients
We will use due diligence in the selection of entities to which we will transfer your data and in the case of such selected entities we will require that they protect your data by appropriate technical and organizational measures. Your personal data may only be disclosed:
- to third parties providing services to us that are needed to achieve the purposes in relation to which we process your data (e.g. IT services, recruitment, electronic communication, hosting),
- to entities from the Ailleron capital group (entities associated with Ailleron), in particular when they provide each other services, or as part of the internal administrative purposes of the Ailleron group (e.g. when this results from the organization of tasks within the group),
- to recipients to whom the disclosure is required by applicable law or order of a court or other authority,
- to other recipients, if you give us your consent to disclose data to them or if the transfer of data to them is necessary to protect your vital interests or vital interests of other individuals or for the common good.
7. Transfer of data to third countries
Your personal data may be transferred to entities outside the European Economic Area (EEA), including the USA, with whom we cooperate. Whenever your personal data is transferred outside the European Economic Area (EEA) or to countries that do not provide the same or an adequate level of protection for personal data, we will ensure that this is done on the basis of a valid legal basis and using the safeguards required by law.
8. Links to other websites
The Website also includes links to other websites owned by Ailleron. When you visit these pages valid are the rules in the field of personal data processing that are provided on those websites. We recommend that you read those rules .
9. Data subject rights
- The right to obtain information, access to data and to receive a copy of the data. You have the right at any time to request information about your personal data that we store or to which we have access. At your request, a copy of your personal data that is subject to processing will be presented to you free of charge. For sending each subsequent copy of data we have the right to request a fee that will cover the reasonable costs of handling such a request.
- Right to withdraw consent. Each time your data is processed based on your consent given, you have the right to withdraw this consent at any time, whereas withdrawal of consent will not affect the lawfulness of data processing that happened before you withdraw your consent.
- The right to rectify personal data. We take reasonable steps to ensure that your personal data is correct, complete and up to date. If it is necessary to change these data, please let us know.
- Right to data portability. You have the right to request the transfer of your personal data in a structured, commonly used machine-readable format, as well as to request the transfer of data to another data controller, when your consent is the legal basis for the processing of your personal data.
- The right to delete data and to limit processing. In the cases indicated in the provisions of law on the protection of personal data, you have the right to request the deletion of your personal data. However, this right is not absolute – there may be occasions when we are still entitled to process your personal data. You can also request a restriction on the further processing of your data.
- Right to object to processing. In the cases indicated in the provisions of law, you have the right to object to the further processing of your data when the legal basis for the processing of personal data is our legitimate interest.
- The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with the supervisory body dealing with the protection of personal data – in principle, it will be the President of the Office for Personal Data Protection (Prezes Urzędu Ochrony Danych Osobowych).
10. Cookies Policy
The Website uses the tools indicated above for various purposes, including:
- to adapt the way the page is displayed to the devices, software and users’ preferences as well as the settings selected by them,
- to monitor how users use the Website and to improve its functioning,
- to personalize the marketing content offered,
- to target better tailored marketing content displayed to users via other websites.
We use the following types of cookies:
- analytical cookies that investigate user behavior on the Website;
- functional cookies enabling to remember the settings selected by the user and personalization, i.a. in terms of the selected language or the cookies options you select.;
Ways to disable cookies
- Google Chrome – https://support.google.com/chrome/answer/95647?Every=GENIE.Platform%3DDesktop&hl=en
- Opera – https://help.opera.com/en/latest/web-preferences/#cookies
- Firefox – https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Apple Safari – https://support.apple.com/en-us/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Windows Internet Explorer – https://support.microsoft.com/fil-ph/help/17442/windows-internet-explorer-delete-manage-cookies
Users can also set their browsers in a way so that they have to accept cookies each time. Then, the browser will ask the user for permission to grant access each time before granting access to the cookie. This gives the user control over what is stored on his device, however, it has the disadvantage that it slows down the ability to navigate the Website and other websites.
In addition, any user can opt out of receiving ads targeted to him in the following ways:
- by using the NAI tool (www.networkadvertising.org/chioces), which will allow you to opt out of watching targeted advertising from us and from other approved NAI member companies,
- via the Digital Advertising Alliance – DDA website (www.aboutads.info/chioces). We follow the Self-Regulatory Principles for Online Behavioral Advertising developed by this organization,
- via the website of the European Interactive Advertising Digital Alliance (www.youronlinechioces.com). We follow the guidelines for online advertising developed by this organization.
When using the opt-out option using the tools described above, please remember that:
- we may still collect certain data about your online activity for purposes other than marketing,
- opt-out options of other advertising companies may function differently than our opt-out options,
- each time you can opt out of tracking your activity for advertising purposes by using the “Do Not Track” option. In such cases we respond to “DNT” signals sent from the user’s browser. If the ‘DNT’ signal is received on the page of one of our advertisers during a user’s visit, we will not combine the collected data with the user’s browser ID during this visit, so new data collected about the user cannot be used by us for the purpose of targeted advertising, but previously collected user data can still be used,
- at any time it is possible to modify the browser settings in terms of cookies. Restricting the use of cookie files may lead to restrictions on some of the functions available on our Website.
You have the option of disabling the transfer of your data for analytical and statistical purposes using Google Analytics. To do this, you can install the browser extension in accordance with the instructions at this address: https://support.google.com/analytics/answer/181881?hl=en.