I. DEFINITIONS

1. 1. Administrator (also Company or We, Our, Us, etc.) – Softinet limited liability company with registered office in Warsaw (02-305), Jerozolimskie Avenue 142B, entered in the register of entrepreneurs by the District Court for the City of Warsaw in Warsaw, XIII Commercial Department of the National Court Register under KRS: 0000555732, NIP: 5342350817, REGON: 140899242.
   2. Personal data – any information about a natural person identified or identifiable by one or more specific factors that determine physical, physiological, genetic, mental, economic, cultural, or social identity, including device IP, location data, Internet ID, and information collected through cookies and other similar technology.
   3. Policy – this Privacy Policy.
   4. RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of individuals about the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC.
   5. Service – the website operated by Us at www.softinet.com.pl
   6. User – any natural person visiting the Site or using one or more of the services or functionalities described in the Policy.

II. DATA PROCESSING IN CONNECTION WITH THE USE OF THE SERVICE

1. In connection with the User’s use of the Website, we acquire data to the extent necessary to provide the particular services offered, as well as information about the User’s activity on the Website. Detailed rules and purposes of processing Personal Data collected during the User’s use of the Website are described below.
2. The Terms of Service are available at: https://softinet.com.pl/regulamin/

III. PURPOSES AND LEGAL BASIS OF DATA PROCESSING IN THE SERVICE

1. When processing Personal Data, we always take care to ensure that there is an appropriate legal basis for processing, in accordance with the provisions of the RODO. If you feel like reading a more detailed description of the legal basis for processing Personal Data – we have included the relevant information at the end of this document.

USE OF THE SERVICE

1. We process personal data of all persons using the Website (including IP address or other identifiers and information collected through cookies or other similar technologies):
   • To provide services electronically in the scope of providing Users with access to the content collected on the Website, the legal basis for processing is the necessity of processing to perform the contract.
   • for analytical and statistical purposes, in which case the legal basis for the processing is our legitimate interest in conducting analyses of Users’ activities, as well as their preferences to improve the functionalities used and services provided;
   • For the possible establishment and investigation of claims or defenses against claims, the legal basis for processing is our legitimate interest in protecting our rights.
   • For our marketing purposes, in particular related to the presentation of contextual advertising, the principles of processing Personal Data for marketing purposes are described in the MARKETING section.
   • Your activity on the Website, including your Personal Data, is recorded in system logs (a special computer program used to store a chronological record containing information about events and activities that relate to the computer system used to provide our services). The information collected in the logs is processed primarily for purposes related to the provision of services. We also process them for technical, administrative purposes, to ensure the security of the IT system and the management of this system, as well as for analytical and statistical purposes – in this regard, the legal basis for processing is our legitimate interest.

CONTACT FORMS

1. We provide the possibility to contact us using electronic contact forms. Use of the form requires the User to provide Personal Data necessary to contact the User and respond to the inquiry. The User may also provide other data to facilitate the contact or handling of the inquiry. Provision of data marked as mandatory is required to accept and handle the inquiry, and failure to provide such data will result in the impossibility of service. Provision of other data is voluntary.
2. Personal data is processed:
   • to identify the sender and handle his/her inquiry sent through the form provided – the legal basis for processing is the necessity of processing to perform the contract for the provision of services and the realization of Our legitimate interest in being able to process the inquiry and handle the correspondence sent through the contact form; in terms of data provided optionally, the legal basis for processing is the User’s consent;
   • for analytical and statistical purposes – the legal basis of the processing is Our legitimate interest, consisting in keeping statistics of queries submitted by Users via the Website, to improve its functionality.

REGISTRATION/SUBSCRIPTION FOR WORKSHOPS, CONFERENCES, WEBINARS

1. Registration for an event organized by Us involves the processing of the Personal Data of participants. Provision of data marked as mandatory is required to accept and process the registration, and failure to provide such data will result in the impossibility of processing the registration for the event. Provision of other data is optional.
2. Personal data is processed:
   • to carry out the registration of participation in the event – the legal basis for processing is the necessity of processing to take action at the request of the person making the registration to conclude a contract and perform the contract; in terms of Personal Data provided optionally – the legal basis for processing is the consent of the person making the registration;
   • to comply with statutory obligations incumbent on Us, arising in particular from tax and accounting regulations, the legal basis for processing is our legal obligation;
   • for analytical and statistical purposes – the legal basis of the processing is our legitimate interest, consisting in conducting analyses of Users’ activity on the Website, as well as Users’ preferences regarding our offer of trainings, conferences, and webinars.
   • For the possible establishment and investigation of claims or defenses against claims, the legal basis for processing is our legitimate interest in protecting our rights.

IV. MARKETING

1. We process Users’ Data to carry out marketing activities, which may consist of:
   • Displaying marketing content to the User that is not tailored to the User’s preferences (contextual advertising);
   • targeting e-mail notifications of interesting offers or content, which in some cases contain commercial information (newsletter service);
   • carrying out other activities related to direct marketing of goods and services (sending commercial information by electronic means and telemarketing activities).
2. To carry out marketing activities, we use profiling in some cases. This means that through automated data processing, we evaluate selected factors about Users to analyze their behavior or create a forecast for the future. This allows us to better tailor the content displayed to the individual preferences and interests of the User.

CONTEXTUAL ADVERTISING

1. We process Users’ Personal Data for marketing purposes in connection with targeting Users with contextual advertising (i.e., advertising that is not tailored to Users’ preferences). The processing of Personal Data is then carried out in connection with the fulfillment of our legitimate interests.

NEWSLETTER

1. We provide the newsletter service under the terms and conditions to people who have provided their e-mail address for this purpose. Providing data is required to provide the newsletter service, and failure to do so will result in the inability to send the newsletter. This form of communication with the User may include profiling.
2. Personal data is processed:
   • To provide the newsletter mailing service, the legal basis for processing is the necessity of processing for the performance of the contract.
   • In the case of directing marketing content to the User as part of the newsletter, the legal basis for processing, including with the use of profiling, is our legitimate interest in connection with the consent to receive the newsletter;
   • for analytical and statistical purposes – the legal basis for processing is our legitimate interest in conducting analyses of Users’ activity on the Website to improve the functionalities used;
   • for the possible establishment and investigation of claims or defense against claims, the legal basis of processing is our legitimate interest, consisting in protecting our rights.

DIRECT MARKETING

1. Your personal information may also be used by Us to target you with marketing content through various channels, i.e., email, MMS / SMS, or telephone. Such activities are undertaken by Us only if You have given Your consent, which You may withdraw at any time.
2. In some cases, we may also carry out direct marketing via snail mail. Concerning this type of marketing, the User has the right to object (objection to direct marketing does not require any justification and is effective from the moment we receive such objection from the User).

V. SOCIAL NETWORKS

1. We process the Personal Data of Users visiting our profiles maintained on social media (Facebook, LinkedIn). This data is processed solely in connection with the operation of the profile, including to inform Users about Our activities and to promote various events, services, and products. The legal basis for processing Personal Data for this purpose is our legitimate interest in promoting our brand.

VI. COOKIES AND SIMILAR TECHNOLOGY

1. Cookies are small text files installed on the device of the User browsing the Website. Cookies collect information that facilitates the use of the website – for example, by remembering the User’s visits to the Website and the actions performed by him.

“SERVICE” COOKIES

1. We use so-called service cookies primarily to provide the User with electronically provided services and to improve the quality of these services. In this regard, we use cookies to store information or access information already stored on the User’s telecommunications end device (computer, phone, tablet, etc.). Cookies used for this purpose include:
   • user input cookies for the duration of the session (session ID);
   • Authentication cookies are used for services that require authentication for the duration of the session (authentication cookies);
   • security cookies, such as those used to detect authentication abuse (user-centric security cookies);
   • multimedia player session cookies (e.g., flash player cookies), for the duration of the session (multimedia player session cookies);
   • Persistent user interface customization cookies, for the duration of the session or slightly longer (user interface customization cookies).

VII. ANALYTICAL TOOLS – GOOGLE ANALYTICS

1. We use various solutions and tools used for analytical and marketing purposes. Below is basic information about these tools. In contrast, you can find detailed information in the privacy policy of the respective partner.

GOOGLE ANALYTICS

1. Google Analytics cookies are cookies used by Google to analyze your use of the Website, to create statistics and reports on the operation of the Website. Google does not use the collected data to identify the User, nor does it combine this information to enable identification of an individual.
2. We use Google Analytics with a mechanism that anonymizes Users’ IP addresses. This means that IP addresses are processed further after truncation to exclude the possibility of referring them to specific individuals.
3. We use Google Analytics to analyze the use of our Website and to improve it regularly. With the statistics obtained, we can improve our offerings and make them more interesting for Users. Concerning exceptional cases in which Personal Data is transferred to the U.S., the Privacy Shield program referred to in Section 10 of the Policy applies. Google participates in the Privacy Shield program, which ensures the legality of data transfers to the US. The legal basis for the processing of data within the framework of Google Analytics is the necessity to fulfill our legitimate interest.
4. Detailed information about the scope and principles of data collection in connection with this service can be found at the following link: https://www.google.com/intl/pl/policies/privacy/partners

COOKIE SETTINGS MANAGEMENT

1. We only use cookies, the use of which is necessary for the proper functioning of the Website. In the case of the use of such cookies, the consent of the User is not required.
2. Changing the use of cookies is possible through the settings of your browser. Detailed information on this subject can be found at the following links:
   • Edge (Internet Explorer)1: https://support.microsoft.com/pl-pl/help/17442/windowsinternet-explorer-delete-manage-cookies
   • Mozilla Firefox: http://support.mozilla.org/pl/kb/ciasteczka
   • Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
   • Opera: http://help.opera.com/Windows/12.10/pl/cookies.html
   • Safari: https://support.apple.com/kb/PH5042?locale=en-GB
3. You can verify the status of your current privacy settings for the browser you are using at any time using the tools available at the links below:
   • http://www.youronlinechoices.com/
   • http://optout.aboutads.info/?c=2&lang=EN

VII. PERIOD OF PROCESSING OF PERSONAL DATA

1. The period for which we process Personal Data depends on the type of service provided and the purpose of the processing. As a general rule, Data is processed for the duration of providing the service or fulfilling the order, until the withdrawal of the consent given, or until an effective objection is made to the processing in cases where the legal basis for the processing is our legitimate interest.
2. The period of data processing may be extended if the processing is necessary for the establishment and assertion of possible claims or defense against claims, and thereafter only if and to the extent required by law. After the expiration of the processing period, the data shall be irreversibly deleted or anonymized.

IX. USER RIGHTS

1. You have the right to access the content of your data and to request rectification, deletion, restriction of processing, the right to data portability and the right to object to data processing, as well as the right to complain to the supervisory authority for the protection of Personal Data.
2. To the extent your data is processed based on consent, you may withdraw that consent at any time by contacting Us (Our contact information is provided below).
3. You have the right to object to the processing of your data for marketing purposes if the processing is carried out in connection with the fulfillment of Our legitimate interest, and – for reasons related to your particular situation – in other cases where the legal basis for the processing is Our legitimate interest (e.g. in connection with the fulfillment of analytical and statistical purposes).
4. For more information about your rights under the RODO, see our Transparency Policy for Personal Data Processing https://softinet.com.pl/personal-data/

X. DATA RECIPIENTS

1. In connection with the performance of services, Personal Data will be disclosed to external entities, including, in particular, suppliers responsible for the operation of IT systems, entities such as banks and payment operators, accounting service providers, couriers (in connection with the execution of the order), and marketing agencies.
2. If we obtain your consent, your data may also be shared with other entities for their purposes, including marketing purposes.
3. We reserve the right to disclose selected information concerning you to the competent authorities or third parties who make a request for such information, based on the relevant legal basis and by the provisions of the applicable law.

XI. TRANSFER OF DATA OUTSIDE THE EEA

1. The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, we transfer Personal Data outside the EEA only when necessary and with an appropriate level of protection, primarily by:
   • Cooperation with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the determination of ensuring an adequate level of protection of Personal Data;
   • application of standard contractual clauses issued by the European Commission;
   • application of binding corporate rules approved by the relevant supervisory authority; in the case of transfers to the US, cooperation with entities participating in the Privacy Shield program (Privacy Shield), approved by a decision of the European Commission.
2. In any case, we inform you of our intention to transfer Personal Data outside the EEA at the stage of collection.

XII. SECURITY OF PERSONAL DATA

1. We conduct ongoing risk analysis to ensure that Personal Data is processed by Us in a secure manner, ensuring, first and foremost, that only authorized persons have access to the data and only to the extent necessary for their tasks. We take care to ensure that all operations on Personal Data are recorded and performed only by authorized employees and associates.
2. We take all necessary measures to ensure that Our subcontractors and other cooperating entities also provide guarantees to apply appropriate security measures whenever they process Personal Data on Our behalf.

XIII. CONTACT INFORMATION

Contact with Us is possible via e-mail address: softinet@softinet.com.pl or mail address: Softinet sp. z o.o., 142B Jerozolimskie Avenue, 02-305 Warsaw (marked “Personal Data”).

XI. CHANGES TO THE PRIVACY POLICY

1. The policy is reviewed on an ongoing basis and updated as necessary.
2. The current version of the Policy has been adopted and is effective as of 1.09.2019.

Legal bases for the processing of Personal Data referenced in the Policy (in the order they appear in the RODO):