IDENTIFICATION AND CONTACT DATA OF THE PERSONAL DATA ADMINISTRATOR
The administrator of your personal data – within the meaning of the GDPR * – processed in connection with the use of our website is Onwelo SA. with headquarters in Poland, in Warsaw (01-207 Warsaw), ul. Karolkowa 30 (hereinafter referred to as “Onwelo”).
If you have any questions or concerns regarding our policy regarding your personal data and your rights, please contact us:
- via our contact form, or
- with our Data Protection Officer by e-mail to the following address: firstname.lastname@example.org.
WHAT DATA, FOR WHICH PURPOSES, ON WHICH LEGAL BASIS AND HOW DO WE PROCESS THEM?
The data we collect depends on the context of your interaction with us and our website, the choices you make and the functions you use. We have grouped the information adequately to the services and functionalities that you can use through our website:
Data collected automatically
When visiting our website, the browser you are using automatically sends to our server data that is technically necessary to display the website and ensure its security and stability. This information includes, among others: the name of the website from which you accessed our website, browser type, language and version, device IP address, operating system and its interface, date and time of visit, URL of the pages viewed and files downloaded in our website. service.
We use the data from the system logs for the purposes of website administration, ensuring the comfort of using the website and analyzing the security and stability of the website.
We process the data from system logs on the basis of Onwelo’s legitimate interests (Article 6 (1) (f) of the GDPR), which are the same as the above-mentioned purposes of processing and the possibility of establishing, investigating and defending against any claims.
System logs are saved until they are automatically deleted, no longer than 3 years.
Cookies and similar technologies
We process cookies in order to:
§ adjusting the content of the website to the user’s preferences and optimizing the process of using our website (e.g. by recognizing the user’s device and displaying the website appropriate for the mobile device),
§ creating statistics that help to understand how website users use it, which allows improving its functionality and content,
§ providing users with advertising content tailored to their interests.
The basis for processing cookies depends on their type, and this is the case of:
§ necessary and session cookies – the basis for processing is Onwelo’s legitimate interest (Article 6 (1) (f) of the GDPR), consisting in ensuring the proper functioning of the website,
§ analytical, functional and advertising cookies – the basis is your consent, which you express when you visit our website when our cookie accepting tool is displayed, which gives you the option of accepting or rejecting them; You can always withdraw your consent by changing your browser settings – see our Cookies policy.
The processing time of cookies depends on their type. Session cookies are deleted immediately after closing the browser, other cookies have a specified expiry date. Additionally, you can disable or delete cookies in your web browser. Details can be found in the Cookies policy.
Information you provide to us
On our website, you can ask questions about our products and services via the contact form. Using the form requires providing personal data necessary to contact you and answer the inquiry – i.e. name, surname and e-mail address. You can also provide other data in the content of the inquiry to facilitate contact or handling the inquiry.
We process the data provided by you for the purpose of:
§ identification of the sender and handling of the inquiry sent via the provided form,
§ marketing of our products and services – if you have additionally consented to communication in order to receive such information from us (you can read more about marketing in a separate section below).
We process the data from the form on the basis of:
§ Onwelo’s legitimate interests (Article 6 (1) (f) of the GDPR), consisting in the need to resolve a reported case related to our business activity and the possibility of establishing, investigating and defending against any claims,
§ your consent to our marketing of products and services, including companies from the Onwelo SA group (Article 6 (1) (b) of the GDPR), which you can withdraw at any time.
We process the data for a period enabling the implementation of our legitimate interests or for the submission of an effective objection to data processing, no longer than until the period of possible claims expires. If the processing is based on consent for purposes related to sending marketing and commercial information, we will process it until its withdrawal.
Marketing of our products and services
If you have consented to communication in order to receive commercial information from us, in order to provide this service, we will use the personal data you provided using the contact form.
We process the data in order to send commercial information, including for direct marketing of the services of companies from the Onwelo SA group, understood as directing marketing messages (including information, commercial and promotional content) via e-mail.
We process the data on the basis of your consent (Article 6 (1) (b) of the GDPR) for electronic communication in order to receive such information from us. You can unsubscribe from our messages at any time by clicking on the deactivation link included in each marketing message we send you.
We process the data until you opt out of receiving commercial information (i.e. until you withdraw your consent or object).
In order to conduct direct marketing of our products and services, to provide you with personalized marketing messages, we may create a profile of your preferences and interests based on data collected automatically via cookies.
The result of profiling is the display of personalized marketing messages regarding our products and services, also on websites of non-related entities using the Google or Facebook, LinkedIn and Twitter advertising networks – for this purpose unique identifiers (using cookies), visit time and history are processed browsing the pages on the website. We use external analytical tools (Google Analytics, Google Tag Manager) and advertising tools (Google Ads, Facebook Pixel, Linkedin Insight Tag) to analyze, profile and personalize messages.
Profiling is aimed at adapting the sent and presented marketing content or information to your interests. The data is not processed for the purpose of automated decision making. The profiling we do does not result in making decisions that have legal effects on you or affect you in a similarly significant way.
We process data on the basis of:
§ Onwelo’s legitimate interest (Article 6 (1) (f) of the GDPR), consisting in conducting activities as part of direct marketing, including profiling,
We process the data until the expiry dates of individual cookies or until you opt out of personalized messages, i.e. until you withdraw your consent or object to profiling by rejecting cookies, clearing them or blocking them in your browser settings.
Contact by phone or e-mail to the e-mail addresses and phone numbers provided on the website
If you contact us by phone or e-mail, to the numbers and e-mail addresses provided on our website, we will collect your personal data necessary to handle the case to which the contact relates, e.g. name, surname, telephone number, e-mail address.
We process data provided by phone or contained in correspondence for the purpose of communication and resolution of the matter to which the contact or correspondence relates.
In this case, the basis for processing is the legitimate interest of Onwelo (Article 6 (1) (f) of the GDPR) consisting in the need to resolve the reported case and / or correspondence related to our business activity and the possibility of establishing, investigating and defending against any claims.
We process the data for a period that enables the implementation of our legitimate interests or to submit an effective objection to the processing of data, no longer than until the period of possible claims expires.
Onwelo profiles in social media
Onwelo has public profiles on social networks such as Facebook, LinkedIn, Xing, Instagram, Twitter. Therefore, we may process data that you leave when visiting our profiles (including comments, likes, online identifiers).
We process this data in order to:
§ enabling activity on our profiles
§ answering inquiries addressed to us via social networks
§ promoting various types of Onwelo events and services
§ for statistical and analytical purposes
We process data on the basis of Onwelo’s legitimate interests (Article 6 (1) (f) of the GDPR), consisting in promoting our own brand and the services provided.
We process the data for a period that allows the implementation of our legitimate interests or to submit an effective objection to data processing.
Determining, investigating and defending against claims
In the event of unlawful use of our website or damages incurred by you in connection with the use of our website, it is possible to establish, pursue or defend against claims.
For this purpose, we may process data entered in electronic forms, system logs, data on the use of the website and other necessary to prove the existence of the claim.
We then process the data on the basis of Onwelo’s legitimate interest (Article 6 (1) (f) of the GDPR), consisting in establishing, investigating and defending against any claims related to the website.
In this case, the data will be processed until the claims are time-barred according to the regulations.
WHO DO WE SHARE YOUR DATA WITH?
Your personal data processed in connection with the use of the website may be made available:
- Authorized state authorities, e.g. the police, prosecutor’s office, courts and supervisory authorities in the field of personal data protection in order to meet our legal obligation
- Companies from the Onwelo SA group in the event of consent to disclose personal data
Our suppliers and service providers with whom we cooperate in the field of:
- statistical and analytical services (e.g. Google Analytics, Google Tag Manager),
- online marketing systems (e.g. Google Ads, Facebook Pixel, Linkedin Insight Tag),
- IT services and IT infrastructure (e.g. Microsoft Corporation, hosting companies providing space on servers),
- marketing activities,
- legal advice.
Some of our suppliers may be based outside the European Economic Area (EEA) and therefore your data may be processed outside of this area. In the case of transfer of data to a third country for which no decision of the European Commission has been issued stating an adequate level of protection, Onwelo applies appropriate safeguards through standard data protection clauses adopted by the European Commission or a supervisory authority (in accordance with Article 46 (2) (c)) d) GDPR). The conditions for the transfer of personal data to third countries can be found at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/standard-contractual-clauses-scc_en.
SOCIAL MEDIA AND LINKS TO THIRD PARTIES
Our website contains links to websites of other companies, if you want to use them, you should read their privacy policies.
We have also integrated the so-called plugins of the following social media that allow direct redirection to our profiles on these portals:
- Facebook Inc.
- LinkedIn Corporation
- Twitter Inc.
- Instagram LLC
When you click on the plugin, your browser connects directly to the server of a given portal. If you are logged in to any of the social networking sites at that time, information about your visit to our website will be sent to their servers, which can be assigned to your account on a given portal. If you do not want to transfer this data, log out of the social network before clicking on the plug-in. The purpose and scope of data collection and further processing and use of data by social media, as well as your related rights and setting options to protect your private sphere, can be found in the privacy policies of social networks.
WHAT ARE YOUR RIGHTS IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA?
Under the terms of the GDPR, you have the following rights:
- The right to access your personal data and receive a copy of it (Article 15 of the GDPR)
- The right to rectify (correct) your personal data (Article 16 of the GDPR)
- The right to limit the processing of personal data in the cases specified in art. 18 GDPR
- The right to delete personal data in the cases specified in art. 17 sec. 1 GDPR, taking into account the exceptions set out in the provision of art. 17 sec. 3 GDPR
- The right to transfer data in the cases specified in art. 20 GDPR
- The right to object to the processing of personal data in the cases specified in art. 21 GDPR – you have the right to object at any time to the processing of your personal data, including profiling, if we process your data based on our legitimate interest (e.g. in the case of marketing our products and services).
- The right to withdraw consent – you have the right to withdraw your consent if we process your personal data on the basis of consent, its withdrawal only works for the future and does not affect the processing performed by us in accordance with the law before its withdrawal
You can submit requests to exercise your rights via e-mail at email@example.com.
You have the right to lodge a complaint with the supervisory authority if you believe that the controller is processing your personal data contrary to the legal requirements. The supervisory body for the processing of personal data by Onwelo SA is the Polish Office for Personal Data Protection https://uodo.gov.pl/en.
* Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC (general regulation on data protection)