Privacy Policy

RODO IN FUNDACJA ROZWOJU PRZEDSIĘBIORCZOŚCI „TWÓJ STARTUP”

From 25th May 2018 come into force the provisions 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 (General Data Protection Regulation) (referred to hereinafter as “the Regulation”). The Regulation introduces a number of amendments to obligations of entities processing personal
data. Its aim is to extend and harmonize the rights to the protection of personal data of citizens of the
European Union.

WHO IS THE ADMINISTRATOR OF DATA?

1. The Administrator of Your personal data is Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’ with its registered office in Warsaw, address: Żurawia 6/12/766, 00-503 Warszawa, entered into the register of entrepreneurs kept by the District Court for the capital city of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under the KRS number 0000442857, TAX Identification Number (NIP): 5213641211, National Business Registry Number: 146433467, contact details: phone number: + 48 731 867 373, +48 731 970 318, e-mail address: [email protected] (referred to hereinafter as “the Foundation”).

WHAT DATA IS COLLECTED?

1. WE PROCESS YOUR DATA FOR THE FOLLOWING PURPOSES:

a. related to the performance of the contract that binds us, or in connection with the activities undertaken by You in connection with the conclusion of the contract (Article 6 paragraph 1 point b of the Regulation), b. to fulfill all legal obligations imposed on us in connection with the cooperation undertaken (Article 6 paragraph 1 point c of the Regulation), this aim is related to legal obligations to store specific documents for the time specified in the legal provisions, e.g.:
 Article 74 paragraph 2 point 1-8 of the Accountancy Law dated 29 September 1994 (Official Journal from 2017, item 1858);
 Article 8b paragraph 3 in conjunction with Article 9k of the Act on Counteracting Money Laundering and Financing of Terrorism dated 16 November 200 (Official Journal from 2000, No. 116, item 1216); 
 Article 86 paragraph 1 and 2 of the Tax Ordinance Act dated 29 August 1997 (Official Journal from 1997, No. 137, item 926);

c. for archival purposes (evidence) to secure information in the event of a legal need to prove facts, which is our legitimate interest (Article 6 paragraph 1 point f of the Regulation);

d. in order to possible arrangement, investigation or defense against claims, which is our legitimate interest (Article 6 paragraph 1 point f of the Regulation);

e. for a specific purpose based on your consent to processing Your personal data in one or more purposes (Article 6 paragraph 1 point a of the Regulation) – if You consent to the use of your personal data, the content of this consent will specify in which specific purpose we will process this data.
Please be advised that in the above-mentioned purposes we will not perform profiling, ie automated analysis of Your data and prepare predictions about preferences or future behaviors (profiling means, for example in the case of marketing profiling, which offer may be the most interested based on your
choices earlier). In case of a change of decision regarding profiling You will be informed about this by completing this information and sending it to the e-mail address provided by You.

2. WHAT DATA SHOULD BE PROVIDED TO US?:

To conclude a contract, we require to provide the data on the contract form (if You do not provide them, we will not conclude the contract). In addition, we can request optional data that does not affect the conclusion of the contract (if we do not receive it, we will not be able to, for example, call the contact number). 
During the contract period, when we providing services, we enter into Your other data. The appearance of Your personal data with us is a consequence of our services that You use.
When concluding a contract, You can additionally for example, order services not previously covered by the contract. If it will require the use of Your data in a manner other than described in this document, we will complete the missing information and provide it, if possible, before obtaining the data. In the remaining scope, the information on data processing contained in this document will remain valid.

3. WHO CAN WE MAKE YOUR DATA AVAILABLE TO:

a. Public authorities, to the extent that they do not receive data as part of a specific legal proceeding (depending on the competence basic);
b. Entities that process your personal data on behalf of the Foundation based on the contract for entrusting the processing of personal data concluded with the Foundation
(the so-called data processor). These will include inter alia: IT specialists, archiving companies, service companies;
c. External data controllers (the so-called Parallel Administrator, to whom the data are made available, eg. attorneys-in-law and solicitors, entities conducting courier or
postal activities, entities purchasing receivables — if You do not pay our invoices on time);
d. Recipient in the third country or international organization, if we make a decision, about such transfer.

4. FOR WHAT DURATION WE WILL STORE YOUR PERSONAL DATA?

Your personal data will be processed for the period necessary to implement the purposes of processing indicated in point 1, i.e .:
a) within the scope of the contract concluded by You with the Foundation for a period until its completion, and after that:
 for a period required by law, e.g. for storing certain accounting records and specific data in accordance with tax regulations;
 for a period resulting from the legitimate interests of the Foundation (i.e. a limitation period to secure any claims);
b) in the scope of fulfilling the legal obligations incumbent on the Foundation in connection with conducting legal activities and the implementation of concluded contracts, for a
limited period of time until the Foundation fulfills these obligations;
c) in the internal administrative purposes, for a period of time before the legitimate interests of the Foundation forming the basis of this processing have been fulfilled or
until You object to such processing;
d) in the scope of marketing and promotion of services offered by the Administrator — for a period of objection to data processing;
e) within the scope of expressed consent — until its withdrawal.

ENTRUSTING THE PROCESSING OF PERSONAL DATA TO THIRD COUNTRIES

We are not entitled to entrust your personal data outside Poland, the European Union and the European Economic Area (including the European Union, Norway, Liechtenstein and Iceland). For the duration of this Agreement, it may turn out that we decide to entrust your personal data outside the area of EEA – only in the extent permitted by law and providing that the third country guarantees its appropriate protection. In that case, you will be informed about such an entrustment via e-mail or telephone contact.
In case of entrustment your personal data to a third country that won’t be recognized as a state that provides an adequate level of protection in virtue of the European Commission’s proper decision, we will ask you for your explicit acceptance of such an entrustment while sending a notification about the potential risk connected with such a transmittal, on the basis of the Article 40 paragraph 1 letter a) as mentioned in the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th 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), hereinafter referred to as ‘the Regulation’.

THE RIGHT TO ACCESS AND CORRECT PERSONAL DATA:

1. YOU ARE ENTITLED TO THE FOLLOWING RIGHTS:

a. the right to access to your personal data processed by us on the basis of Article 15 of the Regulation;
b. the right to refute the entrusted personal data, including its correction (Article 16 of the Regulation);
c. the right to remove your personal data from our systems, also known as ‘the right to be forgotten’ — if you think that there is no basis for us to process of your personal data, you are entitled to demand its removal on the basis of the Article 17 of the Regulation;
d. the right to limit the processing of the personal data – you can request us to limit the range of processing your personal data to storing or accomplishing agreed activities. If you think that we process your incorrect data or process them unjustifiably or you don’t want us to remove them because of the need to establish, investigate or defend your claims or in time of your objection to personal data processing (Article 18 of the Regulation);
e. the right to data transfer – you have the right to receive from us your personal data, based on a contract or your consent, applicable in a structured, commonly used readable format (eg. ‘.CSV’ format). The basis of this right is to have your personal data in electric form. Otherwise (e.g. in case we operate on your data consolidated in the paper form) , you won’t be entitled use the right mentioned above. You are entitled to demand sending your personal data directly to other entities (Article 20 of the Regulation);
f. the right to withdraw your consent to processing your personal data (at any time you are entitled to withdraw your consent to processing your personal data processed on the basis of your approval) – Article 7 paragraph 3 of the Regulation. The withdrawal of the consent will not affect the prior personal data processing accomplished on this basis before its withdrawal. In order to withdraw your consent, send an email to the email address: [email protected];

In order to use the above rights, please send an application with appropriate content to the Fundacja’s address or submit it in person at the Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’ headquarters (address: Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’, 6/12/766 Żurawia Street, postal code: 00-503 Warsaw).

2. THE RIGHT TO VOICE THE OBJECTION

Notwithstanding the above-mentioned rights, at any time you are entitled to voice the objection to the processing of your personal data (including the profiling if provided) for the direct marketing purposes – Article 21 of the Regulation. After receiving the proper application on this matter, we are obliged to stop processing of your personal data for such a purpose. 
In specific circumstances, at any time you are entitled to voice the objection to the processing of your personal data (including the profiling, if provided), if the basis for the processing of your personal data is our legitimate interest or public interest — Article 21 of the Regulation. In that case, after considering your application, we will not be entitled to process your personal data within the scope covered by the objection, unless we prove that they exist:
 Important legally justified basis for the processing of personal data that are legally superior to your interests and rights; 

or

 Legal basis for establishing, investigating or defending claims.

YOU CAN FIND MORE INFORMATION ABOUT THE ISSUES MENTIONED ABOVE IN THE ARTICLE 21 OF THE REGULATION.

INFORMATION ABOUT THE VOLUNTARY ENTRUSTMENT OF THE DATA

As far as data processing is needed to conclude and implement a contract with Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’, the entrustment of your personal data is obligatory for its conclusion. The entrustment of your personal data shall be treated as voluntary, but the failure of providing such data will cause a lack of possibility to conclude and implement the contract.

INFORMATION ABOUT CHANGING THE DATA PROCESSING PURPOSES BY THE ADMINISTRATOR

If Fundacja Rozwoju Przedsiębiorczości ‘Twój Startup’ decided to process your personal data for a different purpose than the previous ones in which your data has been collected before, we will inform you about the new purpose, as well as provide other relevant information about your data processing.

THE CONSENT

If the use of your data is not necessary for the execution of the contract, fulfillment of any legal obligation or does not constitute our legitimate interest, we can ask you for your permission to specific purposes of using your data. Such consent can enable, for example, providing data to other entities for the purpose of their promotional campaigns or automatic decision-making based on your data and on your request or telephone / e-mail contact to provide information about the execution of the contract.
You are entitled to withdraw your consent at any time (this will not affect the legality of using your personal data before your withdrawal of such a consent). The withdrawal of the consent takes place by relevant information, as mentioned in letter g point 1 of the chapter «Right to access and correct personal data.
If you voice your consent to our use of your data, its content will be determined by the purpose of such processing. Data processing consent will only be used for purposes where other processing conditions indicated in letter a)-e) mentioned above, would not be applicable.

THE RIGHT TO COMPLAINT

If the processing of personal data by Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’ with its registered office in Warsaw, violates — in your opinion — the provisions of the Regulation, you are entitled to lodge a complaint to the higher level agency, the President of the Office for Personal Data Protection.
If you have any questions, please contact us at: [email protected]

Effective date: October 19, 2018

99promo (“us”, “we”, or “our”) ownes and operates the domain and service located at https://99promo.me/ (the “Website”).
Protecting your private information is our priority.
This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Website and the choices you have associated with that data.

We use your data to provide and improve the Website.By using the Website, you agree to the collection and use of information in accordance with this policy. 

Definitions

Website
Website refers to the domain and service located at https://99promo.me/ which is owned and operated by 99promo.
Personal Data
Personal Data means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).
Usage Data
Usage Data is data collected automatically either generated by the use of the Website or from the Website infrastructure itself (for example, the duration of a page visit).
Cookies
Cookies are small pieces of data stored on your device (computer or mobile device).

Information Collection and Use

We collect several different types of information for the following purposes:
a) to respond to you, regarding the reason you contacted us, and
b) to provide, improve and maintain our Website.

Types of Data Collected

Personal Data
While using our Website and/or by filling out the forms on our Website, by contacting us by phone or email, you voluntarily may provide us with certain personal information (“Personal Data”) which is necessary to fulfill your request for the order.

Personally identifiable information may include, but is not limited to:

  • First name and/or last name;
  • Address, State, Province, ZIP/Postal code, city
  • Phone number;
  • Email address;
  • Cookies and Usage Data.

By providing us with ANY personal information you authorize that you are the owner of that information or you have the owner`s consent to share with us that information.

Your access to and Control Over Information

You may do the following at any time by contacting us at [email protected]:

  • See what data we have about you, if any;
  • Change/correct any data we have about you;
  • Have us delete any data we have about you;
  • Express any concern you may have about use of your data;
  • Unsubscribe from our mailing list.

Usage Data Your access to and Control Over Information

We may also collect information how the Website is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Website that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking Cookies Data

We use cookies and similar tracking technologies to track the activity on our Website and hold certain information.

What are cookies

Cookies are small pieces of text sent to your web browser by a website you visit. A cookie file is stored in your web browser and allows the Service or a third-party to recognize you and make your next visit easier and the Service more useful to you.
Cookies can be “persistent” or “session” cookies. Persistent cookies remain on your personal computer or mobile device when you go offline, while session cookies are deleted as soon as you close your web browser.

How 99promo uses cookies

When you use and access the Service, we may place a number of cookies files in your web browser.
Examples of cookies we use:

  • Session Cookies. We use Session Cookies to operate our Website
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

We use cookies for the following purposes:

  • To enable certain functions of the Service;
  • To provide analytics;
  • To store your preferences.

We use both session and persistent cookies on the Service and we use different types of cookies to run the Service:
Essential cookies. We may use cookies to remember information that changes the way the Service behaves or looks, such as a user’s language preference on the Service.
Accounts-related cookies. We may use accounts-related cookies to authenticate users and prevent fraudulent use of user accounts. We may use these cookies to remember information that changes the way the Service behaves or looks, such as the “remember me” functionality.
Analytics cookies. We may use analytics cookies to track information how the Service is used so that we can make improvements. We may also use analytics cookies to test new advertisements, pages, features or new functionality of the Service to see how our users react to them.

Third-party cookies

In addition to our own cookies, we may also use various third-parties cookies to report usage statistics of the Service, deliver advertisements on and through the Service, and so on.

What are your choices regarding cookies

If you’d like to delete cookies or instruct your web browser to delete or refuse cookies, please visit the help pages of your web browser.
Please note, however, that if you delete cookies or refuse to accept them, you might not be able to use all of the features we offer, you may not be able to store your preferences, and some of our pages might not display properly.
For the Chrome web browser, please visit this page from Google: https://support.google.com/accounts/answer/32050
For the Internet Explorer web browser, please visit this page from Microsoft: http://support.microsoft.com/kb/278835
For the Firefox web browser, please visit this page from Mozilla: https://support.mozilla.org/en-US/kb/delete-cookies-remove-info-websites-stored
For the Safari web browser, please visit this page from Apple: https://support.apple.com/kb/PH21411?locale=en_US
For any other web browser, please visit your web browser’s official web pages.

Where can you find more information about cookies

You can learn more about cookies and the following third-party websites:
AllAboutCookies: http://www.allaboutcookies.org/
Network Advertising Initiative: http://www.networkadvertising.org/
Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

Use of Data

99promo uses the collected data for following purposes:

  • To fulfill your request to the order, in other words, to provide you with our personalized books and services associated with creation/personalization of the book;
  • To provide and maintain our Website;
  • To notify you about changes to our Website;
  • To allow you to participate in interactive features of our Service when you choose to do so;
  • To provide customer support;
  • To gather analysis or valuable information so that we can improve our Website;
  • To monitor the usage of our Website;
  • To detect, prevent and address technical issues;
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information.

Security of Data

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security. Any transmission is at your own risk.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.
If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to United States and process it there.
Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.
99promo will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

Business Transaction
If 99promo is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.
Disclosure for Law Enforcement
Under certain circumstances, 99promo may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
Legal Requirements
99promo may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation;
  • To protect and defend the rights or property of 99promo;
  • To prevent or investigate possible wrongdoing in connection with the Service;
  • To protect the personal safety of users of the Website or the public;
  • To protect against legal liability.

Service Providers

We will never sell or rent the information we receive from you to anyone.

This does not include transfer of your personal data to third parties service providers, such as a shipping company to deliver;
We may employ third party companies and/or individuals to facilitate our Website, to provide the Website on our behalf, to perform Website-related services or to assist us in analyzing how our Website is used.
These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyse the use of our Service.

Google Analytics
Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualise and personalise the ads of its own advertising network.
You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Behavioral Remarketing
99promo uses remarketing services to advertise on third party websites to you after you visited our Service. We and our third-party vendors use cookies to inform, optimise and serve ads based on your past visits to our Service.

Google Ads (AdWords)
Google Ads (AdWords) remarketing service is provided by Google Inc.
You can opt-out of Google Analytics for Display Advertising and customise the Google Display Network ads by visiting the Google Ads Settings page: http://www.google.com/settings/ads
Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.
For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter
Twitter remarketing service is provided by Twitter Inc.
You can opt-out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405
You can learn more about the privacy practices and policies of Twitter by visiting their Privacy Policy page: https://twitter.com/privacy

Facebook
Facebook remarketing service is provided by Facebook Inc.
You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950
To opt-out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217
Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt-out from Facebook and other participating companies through the Digital Advertising Alliance in the USA http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt-out using your mobile device settings.
For more information on the privacy practices of Facebook, please visit Facebook’s Data Policy: https://www.facebook.com/privacy/explanation

Pinterest
Pinterest remarketing service is provided by Pinterest Inc.
You can opt-out from Pinterest’s interest-based ads by enabling the “Do Not Track” functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data
You can learn more about the privacy practices and policies of Pinterest by visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy

Links to Other Sites

Our Website may contain links to other sites that are not operated by us. If you click on a third party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit.
“Do Not Track” Signals Under California Online Privacy Protection Act (CalOPPA)
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked.
You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser.

Changes to This Privacy Policy

We reserve the right, at our sole discretion, to modify or replace these Privacy Policy at any time, without prior notice. What constitutes a material change will be determined at our sole discretion.Changes to this Privacy Policy are effective when they are posted on this page.
You are advised to review this Privacy Policy every time you visit our Website. By continuing to access or use our Website after any revisions become effective, you agree to be bound by the revised terms. If you do not agree to the new terms, you are no longer authorized to use the Website.

Contact Us

If you have any questions about this Privacy Policy, please contact us by email: [email protected]

tel:+1 267 603-83-15