PRIVACY POLICY AND COOKIE POLICY

By using the aleksandrawelman.com website, you accept the following terms of the Privacy Policy and Cookies Policy.

As a User, please familiarize yourself with its provisions. The following table of contents will help you with this. We inform you in it how we take care of User Data, how we process it, who we entrust it to, and many other important issues related to Personal Data. 


  1. This Privacy Policy and Cookie Policy define the principles of Processing and protection of Personal Data provided by Users and Cookie files, as well as other technologies appearing on the Website under the name and link: aleksandrawelman.com.

  2. The Administrator of the Website and Personal Data provided within it is Aleksandra Welman, conducting business activity under the name of Aleksandra Welman, at ul. Poznańska 3/3, 60-848 Poznań, NIP: 281 001 09 65 in accordance with the document generated from the Central Registration and Information on Business system.
  1. The Administrator processes Personal Data in accordance with the currently applicable provisions of law, in particular in accordance with the GDPR and the Personal Data Protection Act. 
  2. The Administrator takes special care to ensure respect for the privacy of Users and the protection of their interests, in particular by ensuring that Personal Data collected by the Administrator via the Website are processed only for specified purposes and not subject to further processing incompatible with these purposes. 
  3. Users’ personal data are collected and processed only on the basis of appropriate legal bases, and the scope of data depends on the type of service provided and is as limited as possible. 
  4. In case of any doubts regarding the provisions of this Privacy Policy and Cookie Policy, please contact the Administrator via e-mail: aleksandrawelman@gmail.com.
  5. The Administrator reserves the right to make changes to the Privacy Policy and the Cookie Policy, and each User of the Site is required to be familiar with the current Privacy Policy and the Cookie Policy. The reasons for the changes may be: the development of Internet technology, changes in generally applicable law or the development of the Site through, for example, the use of new tools by the Administrator. At the bottom of the Site is the date of publication of the current Privacy Policy and the Cookie Policy. 
  6. This Policy also specifies the terms of use of the services provided by the Administrator, including the Indirect Service, regulating the relations between the Administrator, as the provider of the Indirect Service, and the Recipient of the services referred to in § 10 of this Policy.
  7. Other definitions, procedures, obligations and powers under the Digital Services Act (DSA) are described in Section 10 of this Policy and are an integral part thereof. 
  8. Capitalized terms used in this Privacy Policy and the Cookie Policy have the meaning given to them in § 2 of the Privacy Policy. 
  • 2 DEFINITIONS
  1. Administrator – Aleksandra Welman, ul. Poznańska 3/3, 60 – 848 Poznań, NIP 281 001 09 65.
  2. User – any entity staying on the website and using it.
  3. Website – the website located at aleksandrawelman.com.
  4. Personal data – any information about an identified or identifiable natural person, i.e. name, surname, identification number, location data, internet identifier or one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person. 
  5. Consent – ​​voluntary, specific, conscious and unambiguous expression of will by which the User, in the form of a declaration or clear confirmatory action, consents to the processing of Personal Data concerning him/her. 
  1. Form – a place on the Website that enables the User to enter Personal Data for the purposes indicated therein, e.g. to place an order. 
  2. Service – a set of cooperating IT devices and software, ensuring processing and storage, as well as sending and receiving data via telecommunications networks using a terminal device appropriate for a given type of network (Internet), including the Website or a part thereof, the Store or a part thereof, and applications, including mobile applications and other services of the Administrator, social media and Administrator channels operating within these Media.
  3. GDPR – means 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).
  4. DSA – means Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on the single market for digital services and amending Directive 2000/31/EC (Digital Services Act).
  5. Personal Data Protection Act – Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2019, item 1781, as amended).
  6. Act on the provision of services by electronic means  – Act of 18 July 2002 on the provision of services by electronic means (Journal of Laws of 2020, item 344, as amended).
  7. Telecommunications Law Act – the Act of 16 July 2004, Telecommunications Law (Journal of Laws of 2024, item 34 , as amended). 
  • 3 PERSONAL DATA AND PRINCIPLES OF THEIR PROCESSING

WHO IS THE CONTROLLER OF THE USER’S PERSONAL DATA?

The Administrator of the User’s Personal Data is Aleksandra Welman, ul. Poznańska 3/3, 60 – 848 Poznań, NIP 281 001 09 65.

The Administrator co-administers data with providers of social media platforms, e.g. Facebook, TikTok, etc. indicated in this document in the scope of the Data of persons using social media and following the Administrator’s profile on a given social media platform and interacting with the Administrator. The principles of co-administering are indicated below in the scope of each social media platform on which the Administrator has a profile.

IS PROVIDING DATA VOLUNTARY? WHAT ARE THE CONSEQUENCES OF NOT PROVIDING IT?

Providing Data is voluntary, however, failure to provide certain information, generally marked on the Administrator’s websites as mandatory, will result in the inability to perform a given service and achieve a specific goal or take specific actions.

The provision by the User of Data that is not mandatory or excess data that the Administrator does not need to process is based on the User’s decision and then the processing is carried out on the basis of the premise contained in art. 6 sec. 1 letter a of the GDPR (consent). The User grants Consent to the processing of this data and to the anonymization of data that the Administrator does not require and does not want to process, and yet the User has provided it to the Administrator.

FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DOES THE ADMINISTRATOR PROCESS THE USER’S PERSONAL DATA PROVIDED WHILE USING THE WEBSITE?

The User’s personal data on the Administrator’s Website may be processed for the following purposes and on the following legal bases:

No.The purpose of data processingLegal basis for processingProcessing time
  1.  
performance of a service or execution of a concluded contract, sending an offer (e.g. advertising) at the User’s requestArticle 6(1)(b) of the GDPR (necessity to conclude and/or perform a contract or to take action at your request)

Data is processed for the duration of the contract/the time necessary to send the offer and the User’s response, and then until the expiry of the limitation period for claims 

2 years or 6 years from the execution of the contract, depending on whether the User is an entrepreneur

  1.  
issuing an invoice, bill and fulfilling other obligations resulting from tax law provisions in the case of placing orders in the Online Store or other products and servicesArticle 6, paragraph 1, letter c of the GDPR (obligation resulting from legal provisions)The data is processed for 5 years from the end of the tax year in which the tax event occurred. 
  1.  
providing discounts or information about promotions and interesting offers from the Administrator or entities recommended by himart. 6 section 1 letter a GDPR (consent)Data is processed until the consent is withdrawn, then for a period of 2 years in the case of persons who have withdrawn the consent or after a period of 6 months of no activity on the part of the recipient
  1.  
storing unpaid ordersArticle 6(1)(f) of the GDPR (legitimate interest of the administrator)

Data is processed until it becomes ineffective.

14 days from placing the order

  1.  
consideration of complaints or claims related to the contract Article 6, paragraph 1, letter b of the GDPR (necessity to conclude and/or perform a contract) and on the basis of Article 6, paragraph 1, letter c of the GDPR (obligation resulting from legal provisions)

Data is processed for the duration of the procedure or claim.

1 year from the expiry of the claim settlement deadline or 5 years from the end of the tax year in the scope of Data stored under tax regulations

  1.  
establishing, pursuing or defending against claims Article 6(1)(f) of the GDPR (legitimate interest of the administrator)

Data is processed until the basis for processing ceases.

2 years or 6 years from the execution of the contract, depending on whether the User is an entrepreneur

  1.  
telephone contact in matters related to the implementation of the service, contract Article 6, paragraph 1, letter b of the GDPR (necessity to conclude and/or perform a contract)

Data is processed for the duration of the contract/the time necessary to send the offer and the User’s response, and then until the expiry of the limitation period for claims 

2 years or 6 years from the execution of the contract, depending on whether the User is an entrepreneur

  1.  
telephone contact to present the offer and direct marketingart. 6 section 1 letter a GDPR (consent)Data is processed until the consent is withdrawn.
  1.  
creating registers related to GDPR and other regulations Article 6 paragraph 1 letter c of the GDPR (obligation resulting from legal provisions) and Article 6 paragraph 1 letter f of the GDPR (legitimate interest of the administrator)Data is processed until the basis for processing ceases or it becomes ineffective for the Administrator.
  1.  
archiving for the purpose of securing information that can be used to demonstrate facts Article 6(1)(f) of the GDPR (legitimate interest of the administrator)

The data is processed until an objection is raised or until it becomes ineffective for the Administrator.

2 years or 6 years from the execution of the contract, depending on whether the User is an entrepreneur

  1.  
analytical purpose, including the analysis of Data collected automatically when using the website, including cookies, e.g. Google Analytics cookies or Meta PixelArticle 6(1)(f) of the GDPR (legitimate interest of the administrator)The data is processed until the User deletes the cookies from the browser.
  1.  
use of cookies on the Website and its subpages art. 6 section 1 letter a GDPR (consent)The data is processed until the User deletes the cookies from the browser.
  1.  
management of the Website and Administrator’s pages on other platforms Article 6(1)(f) of the GDPR (legitimate interest of the administrator)The data is processed until an objection is filed or the data ceases to be useful to the Administrator.
  1.  
satisfaction survey with the services offered Article 6(1)(f) of the GDPR (legitimate interest of the administrator)The data is processed until an objection is filed or the data ceases to be useful to the Administrator.
  1.  
posting an opinion by the User about the services provided by the Administrator art. 6 section 1 letter a GDPR (consent)The data is processed until the consent is withdrawn or until it ceases to be useful to the Administrator, unless the consent is withdrawn earlier
  1.  
internal administrative purposes of the Administrator related to managing contact with the User Article 6 section 1 letter f GDPR (legitimate interest of the administrator)

Data is processed until the basis for processing ceases.

2 years or 6 years from the execution of the contract, depending on whether the User is an entrepreneur

  1.  
matching the content displayed on the Administrator’s websites to individual needs and continuous improvement of the quality of the services offered Article 6(1)(f) of the GDPR (legitimate interest of the administrator)The data is processed until an objection is filed or the Data loses its usefulness to the Administrator.
  1.  
direct marketing directed to the User of products or Services or recommended third partiesArticle 6(1)(f) of the GDPR (legitimate interest of the administrator)The data is processed until an objection is filed or the Data loses its usefulness to the Administrator.
  1.  
managing the Facebook fanpage and interacting with Users Article 6(1)(f) GDPR (legitimate interest of the controller) and Article 6(1)(a) GDPR (consent)The data is processed until the consent is withdrawn or an objection is filed or the data loses its usefulness for the Administrator.
  1.  
managing a profile on the Instagram platform and interacting with UsersArticle 6(1)(f) GDPR (legitimate interest of the controller) and Article 6(1)(a) GDPR (consent)The data is processed until the consent is withdrawn or an objection is filed or the data loses its usefulness for the Administrator.
  1.  
managing a profile on the LinkedIn platform and interacting with UsersArticle 6(1)(f) GDPR (legitimate interest of the controller) and Article 6(1)(a) GDPR (consent)The data is processed until the consent is withdrawn or an objection is filed or the data loses its usefulness for the Administrator.
  1.  
   
  1.  
   
  1.  
   
  1.  
targeting advertising on social media and websites, the type of ads created using Facebook Ads Manager, and remarketing targeting Article 6 paragraph 1 letter a of the GDPR (consent) and on the basis of Article 6 paragraph 1 letter f of the GDPR (legitimate interest of the administrator) consisting in the promotion and advertising of the Administrator’s services through remarketing directed to persons subscribed to mailing or visiting a given website)The data is processed until the consent is withdrawn or an objection is filed or the data loses its usefulness for the Administrator.
  1.  
contact with the Administrator via chatbotArticle 6 paragraph 1 letter a of the GDPR (consent) or Article 6 paragraph 1 letter b of the GDPR (consent) the data are processed for the purpose of answering the website user’s questionThe data is processed until the consent is withdrawn or an objection is filed or the data loses its usefulness for the Administrator.
  1.  
User posting commentsart. 6 section 1 letter a GDPR (consent)The data is processed until the consent is withdrawn or until it ceases to be useful to the Administrator.
  1.  
User posting an opinionart. 6 section 1 letter a GDPR (consent)The data is processed until the consent is withdrawn or until it ceases to be useful to the Administrator.
  1.  
   
  1.  
creating your own User Databases Article 6(1)(f) of the GDPR (legitimate interest of the administrator)The data is processed until an objection is filed or the Data loses its usefulness to the Administrator.

The provision by the User of Data that is not mandatory or excess data that the Administrator does not need to process is based on the User’s decision and then the processing is carried out on the basis of the premise contained in art. 6 sec. 1 letter a of the GDPR (consent). The User grants Consent to the processing of this Data and to the anonymization of Data that the Administrator does not require and does not want to process, and yet the User has provided it to the Administrator.

HOW IS DATA COLLECTED?

Only the Data that the User provides himself is collected and processed (except – in certain situations – Data collected automatically using cookies and login data, as referred to below). 

During a visit to the website, Data relating to the visit itself is automatically collected, e.g. the User’s IP address, domain name, browser type, operating system type, etc. (login data). Data collected automatically may be used to analyze User behavior on the Website, collect demographic data about Users or to personalize the content of the website in order to improve it. However, this data is processed solely for the purposes of administering the Website, ensuring efficient hosting service, or directing marketing content and is not associated with the Data of individual Users. More about cookies can be read later in this Policy. 

Data may also be collected for the purposes of completing forms on the Website, as discussed later in the Privacy Policy. 

Information society services 

The Administrator does not collect Data of children. The User must be at least 16 years old to independently express Consent to the processing of Personal Data for the purpose of providing information society services, including for marketing purposes, or obtain the Consent of a legal guardian (e.g. parent) for this purpose. 

If the User is under 18 years of age, he or she should not use the Website and the aleksandrawelman.com service.

The Administrator is entitled to make reasonable efforts to verify whether the User meets the age requirement referred to above or whether the person exercising parental authority or care over a User under 16 years of age has given Consent or approved it. 

WHAT ARE USER RIGHTS?

The User has at any time the rights contained in Articles 15-21 of the GDPR, i.e.: 

  • the right to access the content of his Data, 
  • the right to transfer Data, 
  • the right to correct Data, 
  • the right to rectify Data, 
  • the right to delete Data if there is no basis for their processing,
  • the right to restrict processing if it was carried out incorrectly or without legal basis, 
  • the right to object to the processing of Data based on the legitimate interest of the administrator, 
  • the right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office (under the principles set out in the Personal Data Protection Act), if he/she considers that the processing of his/her data is inconsistent with the currently applicable legal provisions on data protection. 
  • the right to be forgotten if further processing is not provided for by current law.

The Administrator points out that these rights are not absolute and do not apply to all activities of processing the User’s Personal Data. This applies, for example, to the right to obtain a copy of the data. This right cannot adversely affect the rights and freedoms of other people, such as copyright, professional secrecy. In order to learn about the limitations of the User’s rights, we refer to the content of the GDPR.  

However, the User always has the right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw, tel. 22 531-03-00, e-mail: kancelaria@uodo.gov.pl , if he/she considers that the processing of personal data violates the provisions of the GDPR or other applicable regulations regarding the processing of Personal Data. 

In order to exercise their rights, the User may contact the Administrator via e-mail: aleksandrawelman@gmail.com or by mail to the address of the Administrator’s place of business, if provided in this Privacy Policy, indicating the scope of their requests. The response will be provided no later than 30 days from the date of receipt of the request and its justification, unless an extension of this period is justified in accordance with the GDPR. 

CAN A USER WITHDRAW CONSENT?

 If the User has expressed Consent to a specific action, such Consent may be withdrawn at any time, which will result in the removal of the e-mail address from the Administrator’s mailing list and cessation of the indicated actions (in the case of registration based on Consent). The User may also withdraw Consent by sending a statement to the Administrator’s e-mail address or to the address of the Administrator’s place of business, if provided in this Privacy Policy. Withdrawal of consent does not affect the processing of data that was carried out on the basis of consent before its withdrawal. 

In some cases, the Data may not be completely deleted and will be retained for the purpose of defending against potential claims for a period of time in accordance with the provisions of the Civil Code or, for example, in order to fulfil legal obligations imposed on the Administrator.

Each time, the Administrator will respond to the User’s request, appropriately justifying further actions resulting from legal obligations. 

DOES THE CONTROLLER TRANSFER USER DATA TO THIRD COUNTRIES?

User data may be transferred outside the European Union – to third countries. 

Due to the fact that the Administrator uses external providers of various services, e.g. Meta Platforms Ireland Limited (Facebook and subsidiaries) hereinafter referred to as Meta or Facebook, Google, Microsoft, etc. User Data may be transferred to the United States of America (USA) in connection with their storage on American servers (in whole or in part). Google and Facebook, based on the implementing decision of the European Commission of 10 July 2023, issued on the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council, stating the adequate level of protection of personal data within the framework of EU-US data protection, have passed the certification system and obtained a certificate confirming the protection of Personal Data at the European Union level. Users’ personal data will be transferred only to recipients who guarantee the highest protection and security of Data, including through:   

  1. cooperation with entities processing Personal Data in countries for which an appropriate decision of the European Commission has been issued, 
  2. use of standard contractual clauses issued by the European Commission,  
  3. application of binding corporate rules approved by the relevant supervisory authority,  

or those to whom the User has given consent to the transfer of Personal Data.

Detailed information is available in the privacy policy of each of the providers of these services, available on their websites. For example:

Google Ireland Limited: https://policies.google.com/privacy?hl=pl

Meta Platforms Ireland Limited: https://www.facebook.com/privacy/explanation

Linkedin Corp. : https://pl.linkedin.com/legal/privacy-policy

Currently, the services offered by Google Ireland Limited and Meta Platforms Ireland Limited are mainly provided by entities located in the European Union. However, you should always review the privacy policies of these providers to obtain the latest information regarding the protection of Personal Data. MailerLite may store some Data in the United States or use service providers from that country, but the Data is mainly processed in the European Union. 

HOW LONG DOES THE ADMINISTRATOR STORE USER DATA?

User data will be stored by the Administrator for the duration of the implementation of individual services/achievement of the goals indicated in the table above, and:

  1. for the period of service provision and cooperation, as well as for the limitation period for claims in accordance with legal provisions – in relation to Data provided by contractors and customers or Users,
  2. for the period of talks and negotiations preceding the conclusion of the contract or the provision of the service – in relation to the Data provided in the request for quotation,
  3. for the period required by law, including tax law – in relation to Personal Data related to the fulfilment of obligations arising from applicable provisions,
  4. until an effective objection is lodged pursuant to Article 21 of the GDPR – in relation to Personal Data processed on the basis of the legitimate interest of the controller, including for direct marketing purposes,
  5. until the Consent is withdrawn or the purpose of processing, business purpose is achieved – in relation to Personal Data processed on the basis of Consent. After the Consent is withdrawn, the Data may still be processed for the purpose of defending against potential claims in accordance with the limitation period for such claims or the (shorter) period indicated to the User,
  6. until they become outdated or no longer useful – in relation to Personal Data processed mainly for analytical and statistical purposes, use of cookies and administration of the Administrator’s Websites,
  7. for a maximum period of 2 years in the case of persons who have unsubscribed from the Newsletter in order to defend against potential claims (e.g. information on the date of subscription and date of unsubscription from the Newsletter, the number of Newsletters received, actions taken and activity related to the messages received), or after a period of 6 months of no activity by a given subscriber, e.g. not opening any message from the Administrator.

Data storage periods indicated in years are counted at the end of each year in which Data processing began. This is intended to streamline the Data processing and management.

Detailed periods of processing of Personal Data relating to individual processing activities can be found in the register of the Controller’s processing activities. 

LINKS TO OTHER SITES

The Site may contain links to other websites. They will open in a new browser window or in the same window. The Administrator is not responsible for the content provided by these websites. The User is required to familiarize themselves with the privacy policy or regulations of these websites.

SOCIAL MEDIA ACTIVITIES – FACEBOOK

The Administrator administers User Data on the fanpage called System Settings Aleksandra Welman on Facebook. 

The User’s personal data provided on the Fanpage will be processed for the purposes of administering and managing the Fanpage, communicating with the User, interacting, sending marketing content to the User and creating the Fanpage community.

The basis for their processing is the User’s Consent and the legitimate interest of the Administrator consisting in interacting with Users and Followers of the Fanpage. The User voluntarily decides to like/follow the Fanpage.

The rules governing the Fanpage are established by the Administrator, however the rules for staying on the Facebook social networking site result from Facebook’s regulations. 

At any time, the User may stop following the Fanpage. However, the Administrator will not then display to the User any content from the Administrator related to the Fanpage. 

The Administrator sees the User’s Personal Data, such as name, surname or general information that the User places on their profiles as public. The processing of other Personal Data is carried out by the social networking site Facebook and under the terms and conditions contained in its regulations. 

The User’s personal data will be processed for the period of running/existing the Fanpage based on the Consent expressed by liking/clicking “Follow” the Fanpage or entering into interactions, e.g. leaving a comment, sending a message, and in order to pursue the legally justified interests of the Administrator, i.e. marketing of own products or services or defense against claims. 

The User’s personal data may be made available to other Data recipients, such as Facebook, cooperating advertising agencies or other subcontractors servicing the Administrator’s Fanpage, IT services, or virtual assistants, if contact occurs outside of Facebook. 

Other User rights are described in this Privacy Policy.

User data may be transferred to third countries in accordance with Facebook’s terms and conditions.

These data can also be profiled, which helps to better personalize the advertising offer directed to the User. However, they will not be processed in an automated manner within the meaning of the GDPR (having a negative impact on the rights and freedoms of the User).

Facebook Privacy Policy:

https://www.facebook.com/privacy/explanation .

 

SOCIAL MEDIA ACTIVITIES – INSTAGRAM

The Administrator administers User Data on the profile page called System Settings available at the URL: https://www.instagram.com/ustawienia_systemowe_hellinger/ on Instagram (hereinafter referred to as Profile). 

The User’s personal data provided on the Profile will be processed for the purposes of administering and managing the Profile, communicating with the User, interacting, sending marketing content to the User and creating a Profile community.

The basis for their processing is the User’s Consent and the legitimate interest of the Administrator consisting in interacting with Users and Followers of the Profile. The User voluntarily decides to like/follow the Profile.

The rules governing the Profile are established by the Administrator, however, the rules for staying on the Instagram social networking site result from the Instagram regulations. 

At any time, the User may stop following the Profile. However, the Administrator will not then display to the User any content from the Administrator related to the Profile. 

The Administrator sees the User’s Personal Data, such as name, surname or general information that the User places on their profiles as public. The processing of other Personal Data is carried out by the social network Instagram and under the conditions contained in its regulations. 

The User’s personal data will be processed for the period of maintaining/existing the Profile based on the Consent expressed by liking/clicking “Follow” the Profile or entering into interactions, e.g. leaving a comment, sending a message, and for the purpose of pursuing the legitimate interests of the Administrator, i.e. marketing of own products or services or defense against claims. 

The User’s personal data may be made available to other data recipients, such as cooperating advertising agencies or other subcontractors servicing the Administrator’s Profile, IT services, or virtual assistants, if contact occurs outside of Instagram. 

Other User rights are described in this Privacy Policy.

User data may be transferred to third countries in accordance with Instagram’s terms and conditions.

These data can also be profiled, which helps to better personalize the advertising offer directed to the User. However, they will not be processed in an automated manner within the meaning of the GDPR (having a negative impact on the rights and freedoms of the User).

Instagram Privacy Policy:

https://help.instagram.com/519522125107875

SOCIAL MEDIA ACTIVITIES – LINKEDIN

The Administrator administers the User Data on the profile page under the name Aleksandra Welman available at the URL: https://www.linkedin.com/in/aleksandra-welman-100389254/?originalSubdomain=pl on the LinkedIn website (hereinafter referred to as the Profile). 

The User’s personal data provided on the Profile will be processed for the purposes of administering and managing the Profile, communicating with the User, interacting, sending marketing content to the User and creating a Profile community.

The basis for their processing is the User’s Consent and the legitimate interest of the Administrator consisting in interacting with Users and Followers of the Profile. The User voluntarily decides to like/follow the Profile.

The rules governing the Profile are established by the Administrator, however the rules for staying on the LinkedIn social networking site result from the LinkedIn regulations. 

At any time, the User may stop following the Profile. However, the Administrator will not then display to the User any content from the Administrator related to the Profile. 

The Administrator sees the User’s Personal Data, such as name, surname or general information that the User places on their profiles as public. The processing of other Personal Data is carried out by the LinkedIn social networking site and under the terms and conditions contained in its regulations. 

The User’s personal data will be processed for the period of maintaining/existing the Profile based on the Consent expressed by liking/clicking “Follow” the Profile or entering into interactions, e.g. leaving a comment, sending a message, and for the purpose of pursuing the legitimate interests of the Administrator, i.e. marketing of own products or services or defense against claims. 

The User’s personal data may be made available to other Data recipients, such as LinkedIn, cooperating advertising agencies or other subcontractors servicing the Administrator’s Profile, IT services, or virtual assistants, if contact is made outside the LinkedIn portal. 

Other User rights are described in this Privacy Policy.

User data may be transferred to third countries in accordance with LinkedIn’s terms and conditions.

These data can also be profiled, which helps to better personalize the advertising offer directed to the User. However, they will not be processed in an automated manner within the meaning of the GDPR (having a negative impact on the rights and freedoms of the User).

LinkedIn Privacy Policy:

https://pl.linkedin.com/legal/privacy-policy

DATA SECURITY 

The User’s personal data is stored and protected with due diligence, in accordance with the implemented internal procedures of the Administrator. The Administrator processes information about the User using appropriate technical and organizational measures that meet the requirements of generally applicable legal provisions, in particular the provisions of the Personal Data Protection Act and the GDPR. These measures are primarily intended to protect the Users’ Personal Data from access by unauthorized persons. 

In particular, only authorized persons who are obliged to keep this Data confidential or entities entrusted with the processing of Personal Data on the basis of a separate Data entrustment agreement have access to Users’ Personal Data.

At the same time, the User should exercise due diligence in securing his/her Personal Data transmitted via the Internet, in particular not to disclose his/her login details to third parties, use anti-virus protection and update the software. 

WHO CAN BE THE RECIPIENTS OF PERSONAL DATA?

The Administrator informs that it uses the services of external entities. Entities entrusted with the processing of Personal Data (such as courier companies, companies intermediating in electronic payments, companies offering accounting services, companies enabling the sending of newsletters) guarantee the use of appropriate measures for the protection and security of Personal Data required by law, in particular by the GDPR.

The Administrator informs the User that he entrusts the processing of Personal Data to, among others, the following entities:

  1. OVHcloud, www.ovhcloud.com.pl – for the purpose of storing Personal Data on the server,
  2. Wordpress, www.wordpress.com/pl/ and Stripe www.stripe.com – to create landing pages and collect leads,
  3. Subiekt123 www.app.subiekt123.pl – for the purpose of issuing accounting documents,
  4. Stripe www.stripe.com – to support the payment system and electronic transactions,
  5. Podbielscy Tax Advisory Office, https://kancelaria.podbielscy.pl/   – for the purpose of managing the company,
  6. Chrome browser – to use Google services, including email,
  7. Gmail,– for the purpose of managing the domain and mail server,
  8. Troskliwa Graficzka https://troskliwa-graficzka.pl/ – for IT support or management of the Website from the IT side,
  9.  other contractors or subcontractors engaged in technical, administrative or legal support for the Administrator and its clients, e.g. accounting, HR, IT, graphic, copywriting assistance, debt collection companies, lawyers, etc.

Personal data may also be made available to other recipients, including offices such as the tax office – in order to fulfil legal and tax obligations related to settlements and accounting.

Entities that process Personal Data, such as the Administrator, ensure compliance with European standards in the field of Personal Data protection, including standards set by legal acts and decisions of the European Commission and apply compliance mechanisms also when transferring Data outside the EEA, among others in the form of standard contractual clauses adopted by the European Commission Decision 2021/915 of 4 June 2021 on standard contractual clauses between controllers and processors pursuant to Article 28 paragraph 7 of Regulation (EU) 2016/679 of the European Parliament and of the Council and Article 29 paragraph 7 of Regulation (EU) 2018/1725 of the European Parliament and of the Council https://eur-lex.europa.eu/legal-content/PL/TXT/PDF/?uri=CELEX:32021D0915&from=PL

HAS THE CONTROLLER APPOINTED A DATA PROTECTION INSPECTOR?

The Personal Data Administrator hereby informs that he has not appointed a Personal Data Protection Officer (DPO) and performs the duties related to the processing of Personal Data independently.

The User acknowledges that his/her Personal Data may be transferred to authorized state authorities in connection with proceedings conducted by them, at their request and after meeting the conditions confirming the necessity of obtaining such Data from the Administrator.

 

DOES THE ADMINISTRATOR PROFILE USER DATA?

The User’s personal data will not be used for automated decision-making affecting the User’s rights, obligations or freedoms within the meaning of the GDPR. 

As part of the Website and tracking technologies, User Data may be profiled, which helps to better personalize the company’s offer that the Administrator directs to the User (mainly through so-called behavioral advertising). However, this should not have any impact on the User’s legal situation, in particular on the terms of the agreements concluded by him or her or the agreements that he or she intends to conclude. It can only help to better match the content and targeted advertisements to the User’s interests. The information used is anonymous and is not associated with Personal Data provided by the User, e.g. in the purchase process. They result from statistical data, e.g. gender, age, interests, approximate location, behavior on the Website. 

Every User has the right to object to profiling if it would have a negative impact on the User’s rights and obligations.

More about behavioral advertising here: https://www.youronlinechoices.com/pl/o-reklamie-behawioralnej

  • 4 FORMS
  1. Order form in the Store – When placing an order in the Administrator’s online store, the User must provide certain Data in accordance with the principles contained in the sales regulations in order to complete the order, fulfill the legal obligations imposed on the Administrator, settle accounts, consider claims, for statistical and archival purposes, as well as for direct marketing towards customers, which is the legitimate interest of the Administrator. 

These are mainly: first name, last name, company name, Tax Identification Number, residential address or company headquarters, e-mail address. 

The Administrator stores the Data for the duration of the order or service, and after its completion for the period necessary to protect against claims. In addition, for the period specified by law, e.g. tax law (including the period of storing invoices). 

  1. Complaint and withdrawal form in the online store – In the case of using the Administrator’s services or products, the User may file a complaint or withdraw from the concluded contract. For this purpose, the Administrator allows the User to fill out the complaint form and the withdrawal form attached to the sales regulations. The User may also perform these activities without filling out the form, but providing the necessary Data. 

The Data required in this case are: first name, last name or possibly the User’s name, residential address or company registered office address (if the order was made on behalf of the company), e-mail address, telephone number (if necessary), bank account number (if a refund is necessary). 

Providing Data is voluntary, but necessary to consider the complaint in accordance with the law and the sales regulations. The data will be stored for the purpose of implementing the complaint procedure / withdrawal from the contract and for archival purposes and defense against claims. 

The Administrator may entrust the processing of Personal Data to third parties without separate User Consent (based on an entrustment agreement). Data obtained from forms may not be transferred to third parties.

 If the User uses the services of external providers, such as Google, they should become familiar with their privacy policies, available from the providers of these services on their websites.

  • 5 DISCLAIMER AND COPYRIGHT
  1. The content presented on the Site does not constitute advice or specialist (e.g. educational) tips and does not refer to a specific factual situation. If the User wants to obtain help in a specific matter, they should contact a person authorized to provide such advice or the Administrator using the provided Contact Details. The Administrator is not responsible for the use of the content contained on the Site or actions or omissions taken on their basis. 
  2. All content placed on the Site is subject to copyright of specific persons and/or the Administrator (e.g. photos, texts, other materials, etc.). The Administrator does not consent to copying this content in whole or in part without his express prior consent. 
  3. The Administrator hereby informs the User that any dissemination of content made available by the Administrator constitutes a violation of the law and may result in civil or criminal liability. The Administrator may also demand appropriate compensation for material or non-material losses in accordance with applicable regulations.
  4. The Administrator is not responsible for the use of materials available on the website in an unlawful manner.
  5. The content on the Site is current as of the date of posting unless otherwise indicated.  
  • 6 TECHNOLOGIES

In order to use the Administrator’s website it is necessary to have:

  1. Internet access from a device that allows it, such as a desktop computer, laptop, or other portable device, including equipment that enables communication and filling in the necessary forms within the service, e.g. a working keyboard, 
  2. an appropriately configured, up-to-date version of a web browser that supports cookies, e.g. Microsoft Edge, Opera, Mozilla Firefox, Safari, Google Chrome, and allows you to browse websites, 
  3. an active and properly configured e-mail account (the Administrator recommends that the User checks whether e-mails with the Service domain do not end up in the “spam”, “offers” or other than “main/received” mailboxes). The Administrator has no influence on this and it depends on the settings of the User’s e-mail box and/or the provider of the e-mail box used, 
  4. software enabling reading of content in the presented formats, e.g. pdf., video, mp3, mp4. 
  • 7 COOKIE POLICY
  1. Like most websites, the Administrator’s Website uses so-called tracking technologies, i.e. cookies, which enable the Website to be improved to meet the needs of the Users who visit it.
  2. The website does not automatically collect any information, except information contained in cookies.
  3. Cookies (so-called “cookies”) are IT data, small text files that are stored on the end device, e.g. computer, tablet, smartphone, when the User uses the Website.
  4. These may be first-party cookies (originating directly from the Website) and third-party cookies (originating from websites other than the Website).
  5. Cookies allow the content of the Website to be customized to the individual needs of the User and the needs of other Users visiting it. They also enable the creation of statistics that show how Users of the Website use it and how they navigate it. Thanks to this, the Administrator can improve the Website, its content, structure and appearance.
  6. The Administrator uses the following third-party cookies on the Website:
  1. Facebook conversion pixel and ads created through Facebook Facebook Ads (Facebook Custom Audiences) – to manage Facebook ads and conduct remarketing activities, which is the legitimate interest of the Administrator. The Administrator may also direct advertising content to the User through Facebook as part of contact ads.   

The Facebook Pixel tool is provided by Meta Platforms Ireland Limited. and its affiliates. This is an analytical tool that helps measure the effectiveness of advertisements, shows what actions the Users of the Site take and helps to reach a specific group of people (Facebook Ads, Facebook Insights). The Administrator can also direct advertising content to the User via the Facebook portal as part of contact advertisements.   

The Administrator may also conduct remarketing on the basis of art. 6 sec. 1 letter f of the GDPR (legitimate interest of the Administrator, consisting in the promotion and advertising of services directed to persons who have expressed their Consent to the sending of offers (or persons similar to them or to Users who have liked the Fanpage) in such a way that the provided e-mail addresses are uploaded to the marketing tool offered by Meta Platforms Ireland Limited, the so-called ad manager, and then an advertisement created by the Administrator or authorized persons is directed to them, through the Administrator’s advertising account, provided that these persons are also users of the Facebook platform (they have an account there). Each time, these Data are deleted after the end of the advertising campaign. In the case of implementing another advertising campaign, an updated contact database is uploaded to the tool). Detailed information about the so-called groups of custom recipients, the principles of hashing Data and processing this Data can be found in the privacy policy of Facebook at the following link https://www.facebook.com/legal/terms/customaudience# and https://www.facebook.com/legal/terms/dataprocessing, and the Administrator recommends that each User read these principles.  

The information collected through the use of Facebook Pixel is anonymous and does not allow the User to be identified. It shows general Data about Users: location, age, gender, interests. The Facebook provider may combine this information with the information that the User provides to it as part of their Facebook account and then use it in accordance with their own assumptions and purposes.  

The Administrator recommends that you familiarize yourself with the details related to the use of the Meta Pixel tool (Facebook) and, if necessary, ask the provider of this tool questions, as well as manage your privacy settings on Facebook. More information can be found at the following link: https://www.facebook.com/privacy/explanation and  https://www.facebook.com/business/help/742478679120153?id=1205376682832142&_ga=2.140230195.1899084027.1676390445-251481724.1675757116 . You can opt out of cookies responsible for displaying remarketing ads at any time, e.g. at https://www.facebook.com/help/1075880512458213/. 

By using the Website, the User consents to the installation of the indicated cookie on his/her end device.  

  1. Google Analytics embedded code – for the purpose of analyzing Site statistics. Google Analytics uses its own cookies to analyze the actions and behavior of Site Users. These files are used to store information, e.g. from which site the User came to the current web page. They help to improve the Site.

This tool is used under an agreement with Google Ireland Limited and is provided by Google LLC. Actions taken in the use of the Google Analytics code are based on the legitimate interest of the Administrator in creating and using statistics, which then enables the improvement of the Administrator’s services and the optimization of the Site.

When using the Google Analytics tool, the Administrator does not process any User Data that would enable his or her identification. 

The Administrator recommends that you familiarize yourself with the details related to the use of the Google Analytics tool, the possibility of disabling the tracking code and, if necessary, ask the provider of this tool questions at the link: https://support.google.com/analytics#topic=3544906 or read the privacy policy at the link: https://policies.google.com/privacy?hl=pl&_ga=2.64139695.1899084027.1676390445-251481724.1675757116 . 

  1. Web push notifications from the browser level – in order to better communicate with the User and to provide him/her with valuable content or offers faster, the Administrator enables the expression of Consent to receiving web push notifications from the User’s browser level. 

To consent to receiving web push notifications, the User should select the “display notifications” or other similar option in the message sent by his/her web browser (each browser may name this option differently). 

The consent to receive the above notifications may be withdrawn at any time by changing the settings of the User’s web browser. The Administrator does not process any Personal Data of Users using web push notifications. Users are identified solely on the basis of information that is stored by their web browsers, to which the Administrator does not have access.

  1. Plug-ins leading to social media , e.g. Facebook, Instagram, LinkedIn.

After clicking on the icon of a given plug-in, the User is redirected to the website of an external provider, in this case the owner of a given social networking site, e.g. Facebook. Then, they have the option of clicking “Like” or “Share” and liking the Administrator’s fanpage on Facebook or directly sharing its content (post, article, video, etc.). 

The Administrator recommends that you read the Facebook privacy policy before creating an account on this portal. The Administrator has no influence on the Data processed by Facebook. From the moment the User clicks on the plug-in button referring to social media, Personal Data is processed by the social portal, e.g. Facebook, which becomes their administrator and decides on the purposes and scope of their processing. Cookies left by the Facebook plug-in (or other third parties) may also be applied to the User’s device after entering the Site and then associated with the Data collected on Facebook. By using the Site, the User accepts this fact. The Administrator has no influence on the processing of Data by third parties in this way.  

The above instructions also apply to the handling of: 

Facebook – fanpage located at the URL address: https://www.facebook.com/profile.php?id=61556522949217

Profile on the social networking site Instagram, located at the URL address: https://www.instagram.com/ustawienia_systemowe_hellinger/   ,

Linkedin channel located at the URL: https://www.linkedin.com/in/aleksandra-welman-100389254/ .

  1. Tools for assessing the effectiveness of Google Ads advertising campaigns – in order to conduct advertising and remarketing campaigns, which is the legitimate interest of the Administrator.

The Administrator does not collect any Data that would allow for the identification of the User’s Personal Data. The Administrator recommends that you read the Google privacy policy to learn the details of how these functions work and how to disable them from the User’s browser.

  1. Cookies used to recover abandoned shopping carts and User activity on the online store website,

in order to send advertising communication to the User related to the unfinished order, which is a legitimate interest of the Administrator. 

  1. Content from portals and websites of external providers,

The Administrator may embed content from portals, services, blogs and other websites of external entities on the Site. In particular, these may be films from YouTube or Vimeo and sound recordings on the SoundCloud portal.

These third parties may record certain Data about content playbacks made by the User. 

If the User does not want this to happen, they should log out of the portal (if you have an account there and are logged in) before visiting the Administrator’s Website or should not play the content on the Website. The User can also change their browser settings and block the display of certain content from specific portals. 

By playing recordings available on the SoundCloud portal, the User uses the services provided by SoundCloud, which is an independent entity providing services to the User electronically. Details regarding the processing of Personal Data by SoundCloud are included in the privacy policy of this portal:  https://soundcloud.com/pages/privacy and the cookies policy: https://soundcloud.com/pages/cookies , as well as the regulations: https://soundcloud.com/terms-of-use .

YouTube

YouTube is operated by Google Ireland Limited and allows you to play recordings located on the Administrator’s websites. YouTube may save cookies on the User’s device about playbacks of recordings and assigns them to the User’s account on YouTube if they are logged in. 

By using recordings placed on the YouTube portal, the User uses services provided electronically by Google Ireland Limited. Details regarding the processing of Personal Data by YouTube are included in the privacy policy and regulations of this portal:  https://policies.google.com/privacy and  https://www.youtube.com/t/terms .

  1. Affiliate Links and Affiliate Programs

Affiliate links to specific products or services of third parties may appear on the Administrator’s Website. This is a method of monetizing the content on the Website, which is generally provided free of charge. Clicking on the link will not result in any fees being charged to the User. If the User goes to the website of an external entity by clicking on the affiliate link and purchases a product, the Administrator may be awarded a commission. By using the Website, the User agrees to the use of cookies in this regard. 

The Website may also display advertising windows with third-party products, as part of the so-called Google AdSense. The Administrator informs that it has no influence on the content of these advertisements or their appearance, which are determined by the provider’s algorithm, in this case Google Ireland Iimited. The User can modify the settings and personalization of advertisements directly from their browser by going to the address: https://adssettings.google.com/authenticated

  1. Yandex metrics analytical tool

This tool is used for analytical purposes and to improve and optimize the Administrator’s Website and Online Store. It collects Data related to the User’s activity on the Website, moving around the Website. Such activity is then recorded in video format and the Administrator can play it back to analyze the behavior of the Website Users (movements on the website, mouse clicks in individual places, time spent on the website, exits, entries to individual subpages). As part of such activity, the Administrator does not obtain information that would allow for the identification of the User. For this purpose, there is a special Yandex tracking code on the Website, which uses cookies from this company. The User can disable it at any time by changing the browser settings. 

Yandex Metrica is represented by an entity located in the European Union Yandex Oy, Moreenikatu 6, 04600 Mantsala, Finland. 

If the User wants to learn more about the privacy protection and processing of Personal Data by Yandex Metrica, the Administrator recommends reading the privacy policy here: https://yandex.com/legal/confidential/index.html .

  1. The Administrator once again recommends that you review the privacy policy of each of the providers of the above services in order to learn about the possibilities of making changes and settings that ensure the protection of the User’s rights.
  2. The Website uses two types of cookies: session cookies, which are deleted when you close your browser, log out or leave the website, and permanent cookies, which are stored on your end device, which enables your browser to be recognized the next time you visit the Website, for the time specified in the cookie parameters or until you delete them.
  3. In many cases, the software used to browse websites (internet browser) by default allows cookies to be stored on the User’s end device. Users of the Service may change the settings for cookies at any time. These settings may be changed in particular in such a way as to block the automatic handling of cookies in the settings of the internet browser or to inform each time they are placed on the User’s device. Detailed information on the possibilities and methods of handling cookies is available in the software settings (internet browser).
  4. The Administrator informs that restrictions on the use of cookies (disabling them, limiting them) may affect some functionalities available on the Website and hinder its functioning. 
  5. More information about cookies is available at      http://wszystkoociasteczkach.pl/  or in the “Help” section in the web browser menu.
  6. As part of the web browser settings, the User may delete cookies from the Site or Online Store, or from the Administrator’s suppliers, by making changes to their web browser settings at any time. The method of deleting cookies will vary depending on the web browser used by the User. Information on how to delete cookies is available in the “Help” tab in the selected web browser. 
  7. Deleting cookies does not mean that the Administrator deletes Personal Data obtained via cookies. 
  • 8. COOKIE CONSENT

When entering the Site for the first time, the User must express Consent to cookies or take other possible actions indicated in the message in order to continue using the Site’s content. Using the Site means expressing Consent. If the User does not want to express such Consent, they should leave the Site. They can also always change their browser settings, disable or delete cookies. The “help” tab in the User’s browser contains the necessary information. 

  • 9 SERVER LOGS
  1. Using the Website involves sending queries to the server on which the Website is stored.
  2. Each query directed to the server is saved in the server logs. The logs include, among others, the User’s IP address, server date and time, information about the web browser and operating system used by the User.
  3. Logs are saved and stored on the server.
  4. Server logs are used to administer the Site, and their content is not disclosed to anyone other than persons and entities authorized to administer the server.
  5. The Administrator does not use server logs in any way to identify the User. 
  • 10 DEFINITIONS, PROCEDURES, OBLIGATIONS AND POWERS RELATED TO DSA 
  1. This section of the Privacy Policy sets out information on any restrictions imposed by the Administrator in connection with the use of its services, in relation to information provided by Service Recipients, including, but not limited to: information on any policies, procedures, measures and tools used for content moderation, including algorithmic decision-making and human review, as well as on the internal regulations of the complaint handling system, any significant changes to the terms of use of the services and the mechanisms for reporting Illegal Content. The Administrator makes the above information and terms of use of the Service available in an understandable and legible manner, including for minor recipients. The Administrator designs, organizes and operates its Internet Services (and interfaces) in a way that does not mislead Users or manipulate them or in any other significant way interferes with or limits the ability of Users to make free and informed decisions.
  2. The Administrator is a provider of Indirect Services within the meaning of DSA, offering the following services:
  1. ordinary communication,
  2. Hosting
  3. “caching”. 
  1. The Administrator also provides indirect Services as part of its profiles available in social media, i.e. on Instagram (link: https://www.instagram.com/ustawienia_systemowe_hellinger/ ), Facebook (link: https://www.facebook.com/profile.php?id=61556522949217 ), LinkedIn (link:) https://www.linkedin.com/in/aleksandra-welman-100389254/ , enabling Users to leave comments under posted posts,
  1. adding ratings and opinions
  1. other forms of interaction enabling Content to be left available on the above-mentioned portals.  
  1. The definitions used in this section and the Regulations mean:
  1. Administrator – as defined in §2 section 1 of the Privacy Policy, as well as an entrepreneur, i.e. a natural or legal person, regardless of whether it is a public or private entity, who acts – including through a person acting in its name or on its behalf – for purposes related to its commercial, economic, craft or professional activity, providing the services referred to in this paragraph, including information society services within the Service. 
  2. Service recipient – ​​Customer or User or person using intermediate services or other information society services provided by the Administrator, including, for example, the Website or the Administrator’s social media, in particular for the purpose of searching for information or sharing it.
  3. Content – ​​any information provided by the User in any form within the Service, Social Media or other platforms and places owned or moderated by the Administrator, in particular within the Service or the functionalities of these places made available to the User.
  4. Illegal Content – ​​means information that, in itself or by reference to action, is incompatible with Union law or with the law of any Member State that is incompatible with Union law, regardless of the specific subject matter or nature of that law.
  5. Content Moderation – means actions, regardless of whether they are automated, undertaken by the Administrator or cooperating indirect service providers, the purpose of which is, in particular, to detect, identify and combat illegal content or information that is inconsistent with the terms of use of their services, provided by Service Recipients, including implemented measures that affect the availability, visibility and accessibility of such illegal content or information, such as deposition of such content or information, demonetization, preventing access to it or removing it, or that affect the ability of service recipients to transmit such information, such as closing or suspending the recipient’s account.
  6. Indirect service – means one of the following information society services provided by the Administrator: 
  1. a “standard transmission” service consisting in the transmission in a telecommunications network of information provided by the Service Recipient or in providing access to a telecommunications network;
  2. “caching” service consisting in the transmission in a telecommunications network of information provided by the Service Recipient, including automatic, intermediate and short-term storage of this information, performed solely for the purpose of improving the subsequent transmission of information at the request of other recipients;

iii. “hosting” service consisting in storing information provided by the Service Recipient and at his request.

  1. Internet Platform – means a hosting service that, at the request of the Service Recipient, stores and publicly disseminates information, unless such activity is an insignificant or solely secondary feature of another service or an insignificant function of the main service, and for objective and technical reasons it cannot be used without such other service, and the inclusion of such feature or function in such other service is not a way to circumvent the application of DSA.
  2. Public dissemination means making information available at the request of the Service Recipient who provided the information, to a potentially unlimited number of third parties.
  3. Social media – social media platforms within which the Administrator creates additional channels of communication with the User or the Recipient of the information or content provided by him, whether as part of publishing content publicly available to a wide audience, or as part of other forms of contact with the Recipient of the content, including contact related to commercial offers, which in particular applies to: private or public social media groups, channels on social media platforms, public accounts, referred to, among others, in the Privacy Policy, the so-called fanpage, communication channels, within these social media platforms, etc. 

Contact point

  1. The Controller designates the following single point of contact enabling it to communicate directly, by electronic means, with the authorities of the Member States, the Commission and the Digital Services Board, via the email address aleksandrawelman@gmail.com or by telephone at 793 572 334. Communication may take place in Polish.
  1. The Administrator designates the following single point of contact enabling Service Recipients to communicate directly – electronically – with the Administrator via the e-mail address: aleksandrawelman@gmail.com or by telephone: 793 572 334. Communication may take place in Polish.

Illegal Content and Content that is inconsistent with the Administrator’s terms of service

  1. The User may not post the following Content on the Website, Internet Platform or Social Media of the Administrator:
  1. Illegal Content or Content that is inconsistent with the Privacy Policy,
  2. Content containing profanity, hate towards third parties, spam,
  3. Content contrary to good customs, in particular containing offensive content, violating religious feelings, personal rights of third parties, or showing a lack of respect in accordance with generally understood social norms and principles of social coexistence, Content that is racist, vulgar, promotes violence, contains pornographic, fascist, discriminatory content, has sexual overtones, is inappropriate for underage users, etc. 
  4. Content that violates the rights of third parties, such as copyright or intellectual property rights, or is intended to disclose business secrets or other confidential information, 
  5. Content containing links to other websites (links), entities other than the Website, competitive websites or online stores, to which the Administrator has not previously given consent, in particular advertising, marketing, fundraising or other commercial links,
  6. Content that calls out or advertises other services, platforms, social media, etc.
  7. Content unrelated to a given service of the Administrator or any action of the Administrator or the Website, or Content unrelated to the subject matter of the Website or the Administrator’s Social Media,
  8. Content containing personal or contact information,
  9. Repetitive Content that has already appeared on the Website or the Administrator’s Social Media (the User is obliged to verify before publishing the Content whether it is not a copy of existing Content),
  10. Content of a technical nature, customer service inquiries regarding the Administrator’s products or services (for this purpose, the User should contact the details provided in the Privacy Policy).

Procedure for reporting illegal content, appeals procedure and Content Moderation

  1. The User who considers a given Content to be Illegal Content or Content violating this privacy policy is entitled to report this Content to the Administrator electronically to the e-mail address provided in the Privacy Policy, together with an indication of the place where the Administrator can familiarize themselves with the aforementioned Content and all details necessary to consider the report, including the contact details of the User and third parties involved (if possible). 

The User may use  the Illegal Content reporting form attached to this privacy policy. 

  1. If the contact details of the User reporting the Content are not provided, the Administrator will not be able to contact the User to notify him or her about the receipt of the report and the result of considering the report. 
  2. The Administrator will immediately notify the User upon receipt of a report of the given Content. 
  3. The Administrator shall make decisions within the scope of the notification within a period not longer than 14 days from the date of receipt of the notification, in a non-arbitrary, objective manner and with due diligence. For the purposes of consideration and decision-making, the Seller does not use/uses automated means.
  4. The Administrator shall notify the User without undue delay about the result of the decision taken regarding the notification, its content and justification. 
  5. In the event of Illegal Content or Content that is inconsistent with the Regulations, the Administrator may remove it, limit its visibility, prevent access to it, deposition it or leave it on the Service. It may also suspend, terminate or otherwise limit monetary payments, if such occur on the Service, suspend or terminate the provision of the service in whole or in part, or suspend or close the account of the User or a third party. At the same time, it informs the User and the third parties involved of its decision by providing them with a clear and specific justification for the decision (if it has their contact details).
  6. The User may appeal against the Administrator’s decision within 14 days from the date of receipt of the decision, providing justification. 
  7. The Administrator shall consider the User’s appeal within 14 days of its receipt, providing the User with its decision and justification. 

Administrator’s Responsibility for User Content

  1. The Administrator shall not be liable for User Content, especially Illegal Content left within the Service or Internet Platform, if the User’s actions are contrary to the Privacy Policy or generally applicable law. The Administrator shall make every effort to handle such Content in a manner consistent with generally applicable law and the Privacy Policy, including not modifying the Content in a way that affects the integrity of the information provided or made available, not facilitating the posting of Illegal Content, immediately taking action to remove it or prevent access to it in accordance with the Privacy Policy, respecting the fundamental rights of Users, including the right to freedom of expression and information, and taking all actions in good faith and with due diligence.

Algorithmic decision making

  1. There is no algorithmic decision-making within the Service , including decisions related to User appeals. OR 

Cooperation with public authorities regarding notifications of Illegal Content

  1. Where the Controller has any information giving rise to a suspicion that a criminal offence which threatens the life or safety of one or more persons has been, is being or may be committed, it shall immediately inform the law enforcement or judicial authorities of the Member State or Member States concerned of its suspicion and provide all available information on that subject.

Providing information to the Digital Services Coordinator

  1. The Controller shall provide the Digital Services Coordinator responsible for the place of establishment and the Commission, upon their request and without undue delay, with information on the average number of monthly active recipients of the service in the Union, calculated as an average over the previous six months, updated at the time of such request. The Digital Services Coordinator or the Commission may request the Controller to provide additional information on the calculation, including an explanation and justification for the data used. That information shall not contain personal data. 

Termination of use of the Administrator’s services

  1. The User is entitled to terminate the use of the Administrator’s services at any time. For this purpose, they may use available forms of termination of the use of services, such as automatic clicking on specific buttons enabling the deletion of the account (if such has been created) or unsubscribing from a given service, discontinuing observation of the Administrator’s Social Media, or by deleting the Content they have posted, as well as contacting the Seller using the details provided in this privacy policy. This provision does not prejudice the Administrator’s obligations and rights resulting from other generally applicable provisions of law and further storage of data, including personal data, in particular for the purposes indicated in the Privacy Policy and resulting from the GDPR or other acts. 

Changes to the rules for using the Administrator’s services

  1. The Administrator will promptly inform the User by appropriate means of any significant changes introduced in the terms of use of the Administrator’s services, including in the event of a change in the rules regarding permitted information about its services or other such changes that may have a direct impact on the Recipients’ ability to use the service.

Date of publication of the Privacy Policy: April 5, 2025.

Last update date: 04/05/2025

This Privacy Policy has been prepared by the Law Firm #Legalny Biznes Online legalnybiznesonline.pl. Do not copy it in whole or in part, as you will violate copyright and expose yourself to claims. Try to obtain your own legal license by contacting the Law Firm or using the legal store on legalnybiznesonline.pl or legalnastrefabiznesu.pl. 

I operate legally because I care about my clients, my image and the highest quality of what I provide for you! 🙂 

ANNEX No. 1 – SAMPLE FORM FOR REPORTING ILLEGAL CONTENT OR CONTENT NOT IN COMPLIANCE WITH THE TERMS OF SERVICE 

Date: ………………………….

Name and surname/company: …………………………… .

Address of residence: ……………………………….: 

E-mail (if available) : …………………………….

Telephone number (if available): …………………………….

Order number (if applicable): …………………………….

[except in the case of reporting information deemed to be related to one of the offences referred to in Articles 3 to 7 of Directive 2011/93/EU]

Link to Content: …………………………….

[Administrator data: name, address, e-mail]

__________________________________

__________________________________

REPORTING  ILLEGAL CONTENT OR CONTENT THAT IS INCONSISTENT WITH TERMS OF SERVICE

I hereby report that the following has been posted on the Website located at the link: ___________________________

  • illegal content
  • content inconsistent with the Privacy Policy
  • content that is inconsistent with the terms of use of the Administrator’s services [please select as appropriate]

Description of the content and evidence of its existence

The content posted on the Website violates the following provisions of the Privacy Policy/legal provisions: _________________________ [specify]and _________________________________ [specify other arguments why the indicated content is considered illegal or inconsistent with the Privacy Policy]. 

Additionally, as proof of my claims I am sending:

  • screenshots of the above content 
  • Other: ___________________________________ [specify and attach]

Infringer’s data

To my knowledge, the above content was published/posted by the following person:

Name: _____________________ [if you have one]

Link to your online profile: _____________________ [if you have one]

Email address: _____________________ [if you have one]

Tasks

Taking the above into account, I request:

  • remove the aforementioned content from the Service
  • limiting the visibility of the following information related to the above content: _________________________ [please specify] by:
    • preventing the infringer from accessing the content
    • content deposition
  • suspension of the violator’s account
  • Closing the infringer’s account
  • suspension of the provision of the service in whole/in part [select] by the Administrator in favour of the infringer
  • termination of the provision of the service in whole/in part [select] by the Administrator in favour of the infringer
  • suspension, termination or other restriction of monetary payments as follows: _________________________________ [specify]
  • other: ________________________________ [specify].

Statement

I declare that I am making this report in good faith and I am convinced that the information and allegations contained herein are correct and complete. 

 

 

Date: _____________________ Signature [if possible]: _____________ 

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