Privacy and Cookie Policy
1. This document (hereinafter referred to as: Privacy Policy) defines the basic rules for processing of personal data obtained via the website http://warsaw-concierge.com/ (hereinafter referred to as: our website / website) and the use of cookies.
2. WARSAW CONCIERGE GROUP Sp. z o.o. with its registered office in Warsaw (02-305) at ul. Aleje Jerozolimskie 136, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw, 12th Commercial Division of the National Court Register under KRS number 0000382495, Tax Identification Number (NIP): 7010289945 and REGON number: 142887148 is the administrator of the website (hereinafter referred to as: We/Administrator).
3. We take care to ensure the highest standard of protection of the privacy of our website users. We collect and store data about users of our website and use them to provide services on request or with the consent of the user.
A. COOKIES
Remember - our website uses cookies. Below are some important details related to them.
1. WHAT ARE COOKIES?
It is nothing more than IT data, in particular text files, which are saved and stored on users' end devices intended for the use of websites (i.e. in computer memory).
The cookies we use are safe for the user's device, usually they contain: the name of the domain they come from, retention time on the device and a unique number. It is not possible for unwanted software or viruses to get through this way.
Cookies cannot download any personal data or confidential information from the user's devices.
2. TYPES OF USED COOKIES
A. session cookies - stored on the user's device until the end of the browser session. The information stored in them is removed from the device memory at the end of the session.
B. permanent cookies - they are stored on the user's device for the time specified in their parameters or until they are deleted. Ending the session does not delete them.
3. PURPOSE OF USING COOKIES
A. Our own cookies (placed by us) are used for the following purposes:
- authentication and maintenance of the Website user's session (thanks to this, you do not have to log in to our website after switching to the next page - this is how the so-called necessary cookies work);
- optimization and improvement of the efficiency of services provided - the so-called performance cookies enabling the collection of data on the use of website pages;
- increasing the functionality and reliability of the Website and access to its full functionality, as well as the correct configuration of selected functions - the so-called functional cookies that allow you to remember the settings selected by you and personalize the user interface, e.g. in terms of the selected language or font size;
- ensuring the security of the Website, e.g. detection of fraud in the authentication process.
B. External cookies placed by our partners for the purpose of:
- collecting general, anonymous statistical data via available analytical tools (e.g. files used by Google Analytics - privacy policy: www.google.com/intl/pl/policies);
- advertising, they are used to match the content of advertisements to the interests defined on the basis of the most searched content, as well as to control the number of displayed advertisements;
- presenting multimedia information published on external websites, such as YouTube - privacy policy: www.google.pl/intl/pl/policies/privacy/.
4. DELETING COOKIES
A. Default software settings for browsing websites allow cookies to be placed on the end device. Remember that you always have the option to limit or disable the access of cookies to your device from your own web browser.
B. Limiting the use of cookies may affect some of the functionalities available on our website.
C. Failure to change the browser settings means acceptance of the placement of cookies on your device.
5. PROFILING AND TRACKING ON THE NETWORK
We use cookies and track the traffic of our website users. We use the information obtained in this way, among others to create the so-called personalized advertising, as well as to optimize the Website and to increase its usability.
Your data is profiled using the following tools:
- Google AdWords,
- Google Analytics.
5.1. Profiling user data using Google AdWords
Profiling user data using Google AdWords takes place using the following tools: Remarketing and the Similar Audience function.
5.2. Description of the use of Remarketing and the Similar Audience function in the Administrator's online advertising.
The administrator uses Remarketing tools to track users' movements on the web and target personalized advertising to them, based on their preferences and previously disclosed demand for a specific service or product that users searched for on the Website. Thanks to this, the Administrator may also provide such users with information, e.g. about existing promotions or special offers for goods or services in which the user was previously interested.
Similar users are people who have not browsed the Website, but their general characteristics are similar to those of users who have viewed the Website. Based on the activities performed on the Internet by such users, Google categorizes them in terms of their similarity to the Administrator's users. Google may send the Administrator's advertisement to users similar to those who visited the Website.
5.3. Opting out of cookies
Website users may opt out of Google cookies by using the following link that allows you to change the settings of advertisements displayed by Google on users' devices: https://adssettings.google.pl/authenticated.
Website users may also opt out of third-party cookies on the Network Advertising Initiativewebsite, via the following link: http://optout.networkadvertising.org/?c=1#!/.
5.4. Profiling user data using Google Analytics
The Google Analytics system is used by the Administrator to track traffic on the Website, as well as to create analyses and improve the quality of information presented on the Website. In addition, using the Google Analytics system, the Administrator creates marketing lists based on specific actions taken by the user on the Website.
The Google Analytics tool used by the Administrator retains data for a period of 50 months from the date of their collection. The retention period applies to user-level and event-level data associated with cookies, user-identifiers (e.g., User-ID) and advertising identifiers (e.g., DoubleClick cookies).
The User may independently turn off the tracking of movements on the Website using the following device: https://tools.google.com/dlpage/gaoptout.
Each user may consent to the use of cookies (in terms of profiling) by clicking the "Continue" button or by clicking "X" on the pop-up that appears after starting the Website.
The consent to profiling may be withdrawn at any time - however, this will not affect the lawfulness of the processing of personal data carried out before its withdrawal.
The consent to profiling may be revoked by clicking the following button: https://tools.google.com/dlpage/gaoptout.
5.5. The effects of resignation from use of the Administrator of cookies for profiling
Opting out of cookies that allow the display of advertisements tailored to the interests of Website users means that users will not receive the Administrator's ads related to the activity of these users on the Website. In other words, users who disable cookies will not see the Administrator's ads based on cookies at all. However, they may see other Administrator's advertisements, but their targeting method will not use cookies.
5.6. How will the website work without consent to the use of cookies?
In the absence of users' consent to use of cookies aimed at the so-called profiling, cookies necessary to ensure the proper functioning of the Website (related to e.g. preferred language settings) will still be saved on users' devices. Each user can modify the settings from the level of the web browser used.
B. PERSONAL DATA
1. THE BASIS FOR PROCESSING OF PERSONAL DATA
A. The basis for processing of your personal data is in most cases your consent, i.e. the consent of the data subject (Article 6 (1) (a) of the 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 (hereinafter referred to as: GDPR - General Data Protection Regulation) and necessity to perform the contract/take action at your request prior to its conclusion (Article 6(1)(b) of GDPR).
B. In the case of data processing for direct marketing of the Administrator's own products or services, the basis for such processing is also your prior consent (Article 6(a) of GDPR)
C. In the case of data processing for direct marketing of products and services of entities cooperating with the Administrator, the basis for processing is also your prior consent (Article 6(a) of GDPR)
2. PURPOSES OF PROCESSING OF PERSONAL DATA
A. These data are processed in order to access our website and analyze traffic on it.
3. PROTECTION OF PERSONAL DATA
A. We process your personal data in accordance with the rules:
- lawfulness, fairness and transparency of data processing, according to which your data is processed by us lawfully, fairly and in a transparent manner for you.
- limitation of the purpose of data processing - this means that the data is collected by us for specific, explicit and legitimate purposes and is not further processed in a manner inconsistent with these purposes.
- minimizing the amount of data processing - we process the amount of data that is adequate, relevant and limited to what is necessary for the purposes for which they are processed.
- correctness of the processed data - we process only correct data and, if necessary, updated. We take all reasonable steps to ensure that personal data that is incorrect in view of the purposes of their processing are immediately deleted or rectified.
- limitation of the time and purposes for which the data may be stored - we store data in a form that allows the identification of the data subject, but only for a period not longer than it is necessary for the purposes for which the data are processed.
- integrity and confidentiality of data processing - we process data in a manner that ensures adequate security of personal data, including protection against unauthorized or unlawful processing as well as accidental loss, destruction or damage.
B. We have implemented and apply technical and organizational measures aimed at minimizing the risk of breach of personal data protection.
C. All our employees and associates who have access to your personal data, have been properly trained, operate on the basis of special authorizations and are bound by confidentiality agreements.
4. DATA OF MINORS
As a rule, all our activities are directed to adults who can make decisions or influence their making. If the legal guardians of a minor have information that they have completed the form available on our Website, please contact us in order to delete this data from the database.
5. TRANSFER OF PERSONAL DATA
A. The entities to which we can entrust your personal data are: our employees and associates, as well as accounting offices, law firms and our other trusted partners. All of these people have been trained by us in the proper processing of personal data and have committed to processing them in a manner that guarantees the highest level of security of this data.
B. As a consequence of the fact that in connection with the implementation of the above-mentioned purposes of personal data processing, we use the services of external entities that use the possibility to share data collected using cookies from our external suppliers, please be informed that some data may be transferred outside the European Area Economic. Such transfer of data may take place on the basis of a decision on the appropriate level of protection taken by the European Commission, i.e. for organizations participating in the Privacy Shield program, or on the basis of standard contractual clauses in accordance with the decision of the European Commission or on the basis of your explicit consent. At the same time, we would like to point out that Google LLC, Facebook and Sizmek are certified under the EU-US-Privacy Shield. Under the agreement between the US and the European Commission, the latter have established an adequate level of data protection in the case of companies certified by the Privacy Shield.
6. YOUR RIGHTS
A. RIGHT OF ACCESS
You have the right to obtain confirmation from us as to whether we process your personal data, and if so, to obtain access to it and information (Article 15 of GDPR).
B. RIGHT TO RECITIFICATION
You have the right to request us to rectify your personal data immediately (Article 16 of GDPR).
C. RIGHT TO ERASURE
You have the right to request us to erase your personal data immediately (Article 17 of GDPR).
D. RIGHT TO RESTRICTION OFPROCESSING
You have the right to request us to restrict the processing of your data (Article 18 of GDPR).
E. RIGHT TO DATA PORTABILITY
You have the right to receive your personal data from us stored on a carrier and to transfer it to another administrator (Article 20 of GDPR).
F. RIGHT TO OBJECT
You have the right to object to the processing of your personal data (Article 21 of GDPR).
G. RIGHT TO WITHDRAW THE CONSENT
You may withdraw your consent to the processing of personal data at any time. Withdrawal of consent to data processing does not affect the lawfulness of data processing carried out on the basis of consent before its withdrawal.
Withdrawal of consent to the processing of data necessary for the performance of the contract may result in the termination of trade negotiations, as well as the termination of our services. We will inform you about this fact immediately after the withdrawal of such consent.
The consent may be withdrawn by sending a statement to the following e-mail address: office@warsawcg.com
Sample content of the statement:
I (name and surname, address) withdraw my consent to the processing of my personal data by WARSAW CONCIERGE GROUP sp. z o. o. with its registered office in Warsaw.
7. TIME OF PROCESSING OF PERSONAL DATA
We process your personal data for the duration of trade negotiations aimed at signing the contract, and then for the duration of the contract or service, as well as for the time in which we are obliged to store sales documents (i.e. until the tax liability expires, while the tax liability expires within 5 years, counting from the end of the calendar year in which the tax payment deadline expired - Art. 86 § 1 in conjunction with Art. 70 § 1 of the Act of August 29, 1997, Tax Ordinance). After the indicated periods, the data will be anonymized and will be stored (processed) only for statistical purposes.
8. CHANGES TO THE PRIVACY POLICY
A. The Privacy Policy applies only to our website. The website may contain links or references to other websites that have their own, separate Privacy Policy.
B. The Privacy Policy may be subject to changes caused by the development of internet technology or changes in the law. Each user of our website should periodically read the provisions of this document.
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