PRIVACY POLICY – PRINCIPLES OF THE PROCESSING OF PERSONAL DATA WHEN USING THE WEBSITE
WHO WE ARE
Axcelo Sp. z o.o. with its seat in Warsaw, at 6a Lesznowolska Street, 01-808 Warsaw (hereinafter referred to as We or Axcelo) is the Controller of your personal data.
HOW TO CONTACT US
With regard to all issues related to your personal data, it is possible to contact us by sending an e-mail todane@axcelo.pl or by sending a letter to Axcelo Sp. z o.o., ul. Lesznowolska 6A, 01-808 Warszawa, annotated “My personal data.” To contact our Personal Data Protection Inspector, please send an e-mail to iod@axcelo.pl.
WHENCE HAVE WE ACQUIRED YOUR PERSONAL DATA?
We have acquired your personal data particularly from you. You provide us with your data through the contact form. You can find further information on the scope of processing your data in the section What Is the Scope of Processing Your Personal Data.
FOR WHAT PURPOSE DO WE PROCESS YOUR PERSONAL DATA?
Your personal data are processed in order to ensure the functionality of our website. This includes, in particular, enabling you to browse our website without difficulty and to regularly contact us using the contact form available on the website.
The data you provide in the contact form shall be processed in order to properly address your messages, including responding to your inquiries.
We also process your personal data for marketing purposes, which particularly includes promoting our range of products and services. As part of our marketing activities, we wish to be able to present offers and discounts tailored to your interests.
Additionally, if you consent to give us your e-mail address or phone number, we will use these data in order to present you our commercial offer.
WHAT IS THE SCOPE OF PROCESSING YOUR PERSONAL DATA?
The scope of processing your personal data includes:
- Name, surname and/or company’s name
- e-mail address
- phone number
- information on the way you use our website (if you consent to cookies*
- IP number of the device you use to connect with our website
- Information on the device you use to browse our website, including its settings (browser, screen resolution)/li>
- data from publicly available sources
- information on the sources of acquisition of your data
- content of your messages
- additional information about you, which you could have included in your e-mails or letters or which you could have given during a telephone conversation with our representative
- your permissions.
* What are cookies?
Cookies are small text files commonly used on the Internet and stored in your end device. You can control the way they are managed using your browser settings (possibility to accept or block cookies). Blocking cookies may result in the inability to register/log in to your account on the website and/or inability to complete a purchase.
Cookies are used for the following purposes:
- presenting content – protection against displaying the same content to the user once again,
- managing contact forms – protection against robots (computer programs used to automatically analyse the content of a website),
- statistics – developing anonymous statistics of our website visits
WHAT IS THE LEGAL BASIS FOR THE PROCESSING OF YOUR PERSONAL DATA?
The legal basis for processing your data depends on the purpose, for which we process them, and can be determined as follows:
- Personal data provided by a contact form are processed based on your consent;
- Your personal data shall be processed in order to send you marketing messages by e-mail or phone, if you have given us a separate consent to do so;
- Your data related to the use of our website, obtained through cookies, are processed based on your consent given in accordance with Art. 173 of the Telecommunications Law;
- We will process your data to the extent, which is necessary to request your opinion on a given product or service, invoking the so-called legitimate interest of the data controller, which is our goal to constantly improve our services and range of products;
- If you contact us to inquire upon the way we manage the website, the way to perform particular activities – we collect your questions and the related data and provide answers, referring to the legitimate interest of ours, which is to keep our customers and users well informed and provide them with a positive experience regarding our service;
- All your data that we possess as Data Controller shall be also processed for marketing purposes, invoking the so-called legitimate interest of the data controller. Marketing purposes particularly comprise presenting you with offers and discounts that we believe may be of interest to you.
JFOR HOW LONG ARE YOUR DATA PROCESSED?
The period of time used to process your personal data depends on the purpose of their processing and can be determined as follows:
- your consent to receive marketing messages by electronic means or by phone – until you withdraw such consent; after this time your personal data shall be processed for the purposes of accountability of our actions, to which we are obliged by data protection regulations, and for the limitation period of your claims, but not longer than for 10 years;
- responding to your inquiries – for the time required to respond to your message, depending on the information contained in it. Thus, it may be time to give you necessary explanations and answers;
- data on the manner you use our services (via cookies) and data processed in our marketing database – for the entire period of time, during which you are our customer as well as for the following 5 years from the moment you ceased to be our customer.
WHO IS THE RECIPIENT OF YOUR DATA?span class=”Apple-converted-space”>
We do not sell your data, we do not share them with any third parties commercially. Your personal data may be made available to our subcontractors, i.e.:
- the company managing our IT systems,
- the accounting company,
- the company that supports us in the maintenance and servicing of our website,
- the company providing us with the services of supply and maintenance of our database software, which enables us to run our service, send marketing messages by e-mail or by phone,
- our legal advisers.
We process your personal data in accordance with applicable law, in particular with the provisions of the Data Protection Act and the General Data Protection Regulation.
While processing your personal data, we take into consideration the following principles:
- The principle of appropriateness
Only do we process the data, which is necessary for the achievement of a given processing purpose. We have examined the compliance with this principle for each single process.
- The principle of transparency
You should be fully aware of what is happening to your data. This document, which aims to familiarise you with all the principles of processing of your personal data by Axcelo, is the application of this principle of transparency.
- The principle of correctness
We strive to keep your personal data in our systems up-to-date and accurate. Yet if you find that in certain fields your personal data is incorrect or has not been updated, please send us an e-mail to dane@axcelo.pl or write a letter to Axcelo Sp. z o.o., ul. Lesznowolska 6A, 01-808 Warszawa.
- The principle of integrity and confidentiality
We take necessary measures to safeguard the confidentiality and integrity of your personal data. We constantly improve them, as the environment change and technology progresses. These security measures include physical and technological ones aimed to limit the access to your data, as well as appropriate protection measures to prevent the loss of your data.
- The principle of accountability
We wish to be able to account for any of our activities on personal data so that in the event of your inquiry, we can provide you with full and reliable information on the activities we have performed on your data.
WHAT ARE YOUR RIGHTS?
The right of protection of personal data offers you a number of rights that you can exercise at any time. Unless you abuse these rights (e.g. through unjustified everyday requests for access to information), exercising them will be free of charge and should be easy to implement.
Your rights comprise:
- The right to access the content of your personal data
This right means that you can ask us to export the information we have about you from our databases and send it to you in one of the commonly used formats (e.g., XLSX, DOCX, etc.).
- The right to correct your data
If you learn that the data we process are incorrect, you have the right to request their rectification, which will oblige us to do so. In this case, we have the right to ask you to provide us with a document or other evidence of a change in your data.
- The right to restrict the processing of your data
If you consider, despite our compliance with the principle of appropriateness referred to in the section titled How Do We Process Your Personal Data?, that for a specific process the processing of your personal data is too far-reaching, you have the right to request that we restrict this processing. Unless your request opposes any requirements imposed on us by applicable law or prevents the performance of the contract, we shall accede to such request.
- The right to request the deletion of your data
his right, also called the right to be forgotten, means that you have the right to request that we delete any information containing your personal data from our database systems and documentation. Please note that we cannot do this, if we are obliged to process your data by law (e.g. transaction documents for tax purposes, warranty obligation, obligation to ensure the accountability of our actions). In all cases, however, we shall delete your personal data to the fullest extent possible and, where this cannot be done, we shall ensure their pseudonymisation (which means that a particular data subject cannot be identified without a relevant key). Thanks to this process, your personal data, which must be kept in accordance with applicable law, shall be available only to a very narrow group of employees in our organisation.
- The right to transfer your data to a different data controller
According to the GDPR, you can ask us to export all the data provided to us in the course of our cooperation to an individual file in order for it to be transferred to a different data controller.
If the processing of your personal data is based on your consent, you have the right to withdraw it at any moment. If you have given us a separate consent to carry out marketing communication by e-mail or phone, you are also entitled to withdraw such consent at any moment. Please note, however, that – after you withdraw your consent – it may take a certain amount of time before your application is accepted by the system and all databases are synchronised. We will endeavour to do so without undue delay, and under no circumstances may it take longer than one month. What is more, please do remember that the withdrawal of your consent shall not affect the lawfulness of the processing of your personal data carried out on the basis of your consent given prior to its withdrawal.
All of the aforementioned rights can be exercised by contacting us by e-mail to dane@axcelo.pl or by sending us a letter to Axcelo Sp. z o.o., ul. Lesznowolska 6A, 01-808 Warszawa, annotated “Personal data.”
You can also use the aforementioned contact addresses, when you encounter any action or situation that raises concerns about whether it is legal or whether it violates your rights or freedoms. In such case, we shall answer your questions, handle your doubts and address the issue in question forthwith.
If you conclude that we have violated the principles of processing your personal data in any way, you have the right to lodge a complaint directly to the supervisory authority (the President of the Personal Data Protection Office from 25 May 2018). When exercising this power, you should provide a full description of the situation and indicate the action you consider to be in breach of your rights or freedoms. The complaint shall be submitted directly to the supervisory authority: ul. Stawki 2, 00-193 Warszawa.
WHAT IS THE RIGHT TO OBJECT?
We would like to inform you that you also have the right to object to the processing of your personal data.
You can exercise the right to object when you do not want us to process your personal data for a given purpose (e.g., for our direct marketing purposes, which invokes the so-called legitimate interest of the personal data controller). In this case, we shall continue to process your data for other processes (for other purposes), but not for the purpose to which you objected.