Every day we make sure that you use our services and the website comfortably and that it is safe for you. For this reason, we provide you with important information on how the data – collected during your visits to our website or while using our online and offline services – is used.
1. WHO IS YOUR PERSONAL DATA ADMINISTRATOR?
The Administrator of personal data processed by us is OSOM Studio Sp. z o.o. in Łódź (90-223), address: ul. Rewolucji 1905 r. 82, entered into the Entrepreneurs Register of the National Court Register kept by the District Court for Łódź-Downtown in Łódź, XX Economic Department of National Court Register, KRS number 0000457850, NIP identification number 725-20-66-858,
A full list of our Partners with information about the Privacy Policies they use, can be found here.
2. WHAT IS THE PURPOSE OF COLLECTING YOUR DATA?
1. General information
Cooperation with us or the use of our Website may involve the need for you to provide us with your personal data. We keep collected data in strict confidentiality and use it only for purposes we have informed you about. Thanks to the variety of choices, you decide what data you share and what information we can use.
2. Data collected automatically
3. Other data
When you provide us with your data to conclude a contract, we will process your data for the purpose of concluding the contract and then for its implementation, if the conclusion of the contract will take place.
When you contact us to perform various activities or obtaining information (e.g. offer inquiry) via the Website, by phone or e-mail, we will again require you to provide us with your personal data to confirm your identity and to reply to your message.
It applies to the same personal data you provided earlier. However, because of the specifics of your request, it may happen we will have to ask you to deliver more information. Your submission of the above-mentioned data is not mandatory, but it is necessary to perform actions or obtain information that you wish to acquire. We will process the above-mentioned data to provide you with the certain information or to perform certain actions – depending on the situation that is taking place.
3. BASIS FOR PROCESSING YOUR DATA
We process all collected data in accordance with the purpose for which they were collected for and regarding all relevant legal provisions. The basis authorizing us to process your personal data may be:
- Your consent;
- the contract between us (which is also an electronic provision of services indicated in respective Website regulations);
- legal obligation;
- a legitimate interest pursued by us or by a third party.
1. Data processing based on consent
2. Data processing on the basis of a contract
We will process your data when it is necessary to conclude a contract, which you are an entity of, or when it is necessary to take action on your request before concluding the contract. Your use of the services offered through the Website is equivalent to concluding a contract for the electronic provision of services. In a situation where we will collect your data, which is necessary for us to provide services, we will process these data on the basis of the contact.
3. Legal obligation
In some special situations, we have to process your data because of fulfilling our legal obligations. These will be situations where we must store your data, e.g. data resulting from issued invoices for tax and settlement reasons.
4. The legitimate interest pursued by us or by a third party
Your data will be processed by us when it is necessary for the purposes arising from legitimate interests pursued by us or by third parties. However, we will not process your personal data if it occurs that the nature of your interest, your fundamental rights and freedom overrides our interests or the above-mentioned third party’s interests.
For the above-mentioned reasons, we inform you that based on our legitimate interest, we will process your data for the purposes of profiled advertisements publications for our services, as well as for the purposes of investigating rights and defense against claims, for evidentiary and archival purposes.
On the same basis, we will also process your personal data collected automatically on the Website to ensure session security, ensure the quality of the session and to provide access to all functions of our Website.
4. IS DATA PROVISION MANDATORY?
When concluding and performing a contract, we only collect these data which is necessary to execute it. A failure to provide data necessary to conclude and perform the contract will make it impossible to conclude or execute it. It also applies to the data we need to collect due to our legal obligation (e.g. related to invoices).
In a situation where we obtain your consent to personal data processing, it is completely voluntary. If you do not agree to that, we will not take actions which this consent applies to. You have the right at any time to withdraw your consent. Withdrawal of consent does not affect, however, the lawfulness of processing your personal data made on the basis of consent before its withdrawal.
5. WHO WILL WE SHARE YOUR PERSONAL DATA TO?
In some situations, we transfer your personal data to third entities. The recipients of your data are:
- our authorized employees and associates to whom your personal information will be disclosed so that they can perform their duties;
- entities to whom we outsource personal data processing services (processors), they will be e.g. executing banner campaigns, e.g. on Onet and/or Wirtualna Polska;
- other data recipients – e.g. our subcontractors, banks, tax advisors, law firms, courier companies;
- public authorities including the Police, customs chamber, law enforcement authorities, in connection with their proceedings.
6. DURATION OF DATA STORAGE
The duration of storing the data is related to the purposes and the basis of processing. If in connection with the performance of the contract concluded with us or in connection with using our Website you will purchase goods from us – a product or service – for an additional fee, then we will process your data for a period of 6 years due to the tax law provisions.
7. YOUR RIGHTS
In connection with processing your data, you are entitled to a number rights. You can use them as well as get more explanations by contacting us:
- by e-mail: firstname.lastname@example.org,
- by correspondence: OSOM STUDIO Sp. z o.o., ul. Jaracza 47, 90-249 Łódź.
When contacting us, remember to give us your contact details and the preferred form and contact time. Thanks to that we will respond more efficiently to your questions and requests. You are entitled to:
- the right to request access to your personal data and the right to correct and delete them (“the right to be forgotten”);
- the right to object to the processing of personal data on the need for direct marketing that causes cessation of processing your data for direct marketing purposes;
- from 25th May 2018 the right to object on the following grounds related to your particular situation, if we process your personal data on the basis of a legitimate interest. However, we will further process your personal data to the necessary extent if we will have a legitimate reason for this;
- from 25th May 2018 the right to transfer data processed in connection with performing the contract or on the basis of your consent and the right to limit data processing;
- if the basis for processing personal data is your consent, you have the right to withdraw this consent at any time. Withdrawal of consent does not however affect the lawfulness of our processing of your of personal data that we have made on the basis of consent before its withdrawal.
To execute your right of revocation, you may use the contact e-mail you provided when you signed up for our Website. You can also use the contact details indicated in the introduction of this point.
8. PROFILING AND TARGETING
In advertising systems, i.e. Facebook Ads and Google AdWords we place targeted and profiled ads. Targeting is determining the appropriate parameters that will allow to reach the group of recipients that interest us the most, whereas these parameters are not very detailed. It is possible to target an ad basing on e.g. the medium, time of emission or the context of ad’s emission. Profiling in turn is a way of processing personal data for the use of – among others – analysis or forecasting personal preferences, interests, credibility, location, behavior or movement. The use of profiling enables us and our Partners a more detailed personalization of ads and content presented to the user. Ads and content displayed in advertising systems we use can be targeted or profiled, i.e. targeted on devices and browsers with specific features, according to various criteria.
These criteria are:
- geolocation: country, city, province;
- broadcast on our selected specific Services;
- broadcast of articles on specific topics (assuming they are marked with adequate tags) technical information about your end device: device type (PC, tablet, smartphone), browser type, operating system, language set in the system, type of internet connection – this type of profiling is used e.g. to reduce the emission of specific formats or advertising creations that work only under certain technical conditions (e.g. only on a PC).
For the purposes of profiling ads and content, we also divide users (essentially we divide cookie groups that users represent and devices’ ID) into segments. In such situations, the profiling we perform is more advanced, because then we match the content and advertising activities in accordance with user behavior on our Services. E.g. if a user viewed a website dedicated for women in a browser identified with cookies and then – in the same browser – read an article about fashion, we conclude that the user is a woman interested in fashion (behavioral reasoning). In such a situation profiling we perform will manifest itself in the emissions of ads realized by our agency.
Cookies neither damage your system, device or the files stored on it in any way nor intentionally affect its performance or functionality. Identification takes place impersonally, anonymously, and these are data only on the method and form of using the Website. Due to the storage period, there are two basic types of cookies used within the Website: session cookies and persistent cookies. Session cookies are temporary files stored on your end device until you leave the Website or close the browser. Persistent cookies are stored on your end device for the time specified in the cookie file parameters or until you delete them.
Due to the function, we use the following types of files within the Website cookies:
- necessary cookies, enabling the use of services available as part of the Website, e.g. authentication cookies used for services requiring authentication within the Website;
- cookies used to ensure security, e.g. used for detection of fraud within the authentication process on the Websites;
- performance cookies, enabling gathering the information on the method of Websites usage;
- functional cookies that remember your settings and personalization of the interface, e.g. selected language or region where you come from, font size, page view etc.;
- advertising cookies enabling delivery of content more suited to your interests.
In order not to receive cookies, use the browser you connect to the Website with and select the automatic rejection option. These settings usually allow managing cookies as well.
Below you will find links to official websites examples of most-used browser producers on which there is information about the activities you need to perform to change the settings of the browser in the above-mentioned range:
- Internet Explorer: https://support.microsoft.com/en-us/help/17442/windows-internet-explorer-delete-manage-cookies
- Mozilla Firefox: https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer?redirectlocale=en-US&redirectslug=Cookies
- Google Chrome: https://support.google.com/chrome/answer/95647?hl=en
- Opera: https://help.opera.com/en/latest/web-preferences/#cookies
- Safari: https://support.apple.com/en-gb/guide/safari/sfri11471/mac
To disable the localStorage technology, disable browser’s cooperation with this technology, which usually takes place in the same way as when you resign from receiving cookies.
To disable localStorage technology, we also recommend what follows, depending on the type of your browser:
- Internet Explorer: pressing the key combination [Ctrl + Shift + Delete] will open the window containing options to delete items. Element “Cookies and data websites ” refers to the removal of cookies and localStorage content.
Select Tools from the main menu -> Internet options -> tab Advanced -> in the Security section uncheck Enable DOM storage.
- Mozilla Firefox: pressing the key combination [Ctrl + Shift + Delete] will open the window containing options to delete items. “Cookies” element concerns the removal of cookies and localStorage content. In the space for entering the www address, enter the command about:config, and then in the line ‘dom.storage.enabled’ replace the default value ‘true’ with ‘false’.
- Chrome: pressing the key combination [Ctrl + Shift + Delete] will open the window containing options to delete items. The “Cookies and other website and plug-in data” refers to the deletion of cookies and localStorage content
- Opera: select Menu from the main menu -> Settings -> Delete private data. In the dialog box select the items to delete. “Delete all” cookies and “Clear browsing data” will delete the cookie files cookie and localStorage content.
Enter this command in the web address bar: opera:config. Set ‘0’ (zero) in the ‘LocalStorage’, in the ‘Domain Quota Exceeded Handling For localStorage” and “Domain Quota For localStorage” fields.
- Safari: choose the Safari menu option -> Preferences (press Cmd+) and then Privacy. Select one or more sites in the “Manage site data” box, and then click Delete or Delete all.
10. DESCRIPTIONS OF THE MOST IMPORTANT TOOLS OF COOPERATING ENTITIES, INCLUDING OUR PARTNERS
1. Google Analytics
On our site we use the Google Analytics tool provided by Google Inc. (“Google”) based in the US. This is a web analytic service provided by Google (Google is the processor here) for us using cookies. The information generated by cookies regarding your use of the Website / Mobile Application, the description of you will find here: https://policies.google.com/privacy?hl=en, are forwarded and saved on a Google server in the USA. Our websites enable the anonymization of IP addresses, which results in pre-shortening the IP addresses of Google users in the Member States of the European Union or in other countries party to the European Area Economic Agreement. Only in rare, exceptional situations will the full IP address be forwarded to the Google server in the USA and shortened there. Anonymisation takes place directly after receiving the data, even before saving it. On our behalf, Google will use the information obtained for verification of your use of our services, creation of reports on their functionality and providing additional services to us related to the use of digital services or the Internet, in particular Google Analytics reports on services rendered according to demographic criteria and interests. The IP address transmitted by your browser with Google Analytics will not be connected to other Google data. Please be advised that you can prevent the data related to the use of the website by Google as well as prevent Google from processing such data obtained by using cookies and data (including IP address) by downloading and installing the browser plug-in available at the following link: https://tools.google.com/dlpage/gaoptout?hl=en
To record paths of interaction with our Services and to conduct surveys, we use the HotJar tool provided by Hotjar Ltd, Level 2, St. Julians Business Center, 3, Elia Zammit Street, St Julians STJ 1000, Malta, Europe, +1 (855) 464-6788, email@example.com. It is a tool that anonymously records the activity of randomly selected users on our website. The data they collect is analyzed by our specialists, assisting in solving problems encountered by users in order to improve the quality of our services. You will find the data list collected by our partner here: https://www.hotjar.com/privacy. Please be advised that you can opt-out of the monitoring of your activity on https://www.hotjar.com/opt-out or by enabling the “do not track” option in your web browser settings. (https://support.mozilla.org/en-US/kb/enhanced-tracking-protection-firefox-desktop, https://support.google.com/chrome/answer/2790761?co=GENIE.Platform% 3DDesktop & hl = en)
We use HubSpot system provided by HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141 USA. The HubSpot tracking code is embedded in the code of our websites, which collects information about your use of our sites. We use this information to optimize our operations and increase their effectiveness. The information collected by the tracking code remains anonymous in the sense that we cannot identify you from it. These informations are similar to the information referred to in Section 8 above. The exception is when you submit a form available on our websites. In this case, your data provided on the form is also combined with information about your use of our sites.
Information on the data collected by our partner can be found here: https://legal.hubspot.com/privacy-policy
2. Analytics for advertising purposes and content adaptation
1. Facebook Pixel
We use Facebook Pixel to measure the effectiveness of our website advertising and optimization of our ads appearing on Facebook. It is a tool that helps us measure the effectiveness of ads based on an analysis of the users’ actions on our Site. We use the pixel data in the following range: emission of ads among the right audience, creating ad recipient groups, analyzing the results of clicking on the advertisements, use of other Facebook advertising tools. Information about the data collected by our partner can be found here: https://en-gb.facebook.com/business/gdpr, under “What data does Pixel collect? ”
2. Tracking conversions and the remarketing tag of Google Adwords
We utilize conversion tracking and remarketing in order to optimize our advertisements and measure the effectiveness of advertising of our site through Google AdWords. These tools allow us to find out what the results of the customer-advertisement interaction are and whether they finalized an action that we deem valuable. This, in turn, enables us to optimize our Google AdWords promotional activities. Thanks to these tools:
- we can tell what keywords, ad groups and campaigns provoke the most valuable actions
- we know our return on investment (ROI) in advertisements and we can make well-thought-out decisions related to our advertising budget
- we automatically optimize our campaigns according to the business goals
- we can tell how many customers interact with our advertisements on one device and achieve conversion on another
- we can display AdWords advertisements to users, who visited our websites.
You can find all the information regarding data processing by our partners here: https://policies.google.com/technologies/ads?hl=en https://support.google.com/google-ads/answer/93148?hl=en&ref_topic=3119146
3. Other information
1. Social media plugins
With some content on our Website – primarily our blog – we utilize so-called social media plugins for platforms such as Facebook, Google+ and Twitter. Thanks to these functions, you can share or recommend individual content with a friend directly to their social media.
When using these social plugins, such as the Facebook “like” button, Google+ or Twitter buttons, personal data might be collected by these social networks in the following way:
While browsing the content on our websites with integrated social plugins, the social network creates a direct connection with the search engine. By doing that, the social media platform receives information about your IP address or your device’s ID – this happens regardless of whether you are currently logged into a social media account or not. If you are, the social media platform will automatically assign the visit to your profile.
When utilizing social media plugins, if you recommend an article or any other content, the social media platform can assign this information to your profile. If you do not want the social network to assign visits to our pages to your user account, make sure you log off of these social media platforms for the time of using our websites.
We wish to point out that the data being collected due to the use of social media plugins can only be exchanged between your browser and the social network. We have no insight into the data that is being collected or processed. We recommend that you read the current information on the protection of personal data on social media platforms available below.
We pay great attention to the case of personal data processing security. We use appropriate technical and organizational measures to ensure the protection of your data against unauthorized disclosure and access, against accidental or unlawful destruction or loss. However, no way of transmitting data via the internet and no electronic means of physical storage is completely safe and secure.