This policy of DIGITAL GATEWAYS SP. Z O. O., hereinafter referred to as ‘DG’ or ‘us’, to comply with applicable legal regulations concerning privacy and data protection.
Issues related to data processing as part of subscription or other services purchased from DG are regulated by separate procedures and agreements.
DG declares that it will make every effort to ensure adequate security of processed data and agrees to carry out measures to prevent third-party interference in the personal data and privacy of the data subjects. Personal data provided will be used for the purposes specified further in the document.
The controller of the stored data is DIGITAL GATEWAYS SP. Z O.O., based in Warsaw, Pl. Europejski 1, 00-844 Warsaw, entered into the entrepreneurs’ register of the National Court Register kept by the District Court for the capital city of Warsaw in Warsaw, XII Commercial Division of the National Court Register, under entry number KRS: 0000790370, Taxpayer Identification Number (NIP): 5272896326.
This policy tells you:
- what information we might collect about you
- how we might use that information
- when we might use your details to contact you
- what information of yours we might share with others
- your choices about the personal information you give us
This policy covers the services that are offered by the DG. And sometimes it covers services offered by parts of our Partner that operate as separate companies. But only when those services link to this policy or tell you it applies.
User, you – a legal adult natural person, who provides his/her personal data in connection with the use of DG websites.
DPO – A Data Protection Officer is authorized to act in the name of DG to verify that our procedures are consistent with applicable regulations. The DPO is also available to answer any questions you may have regarding your personal data.
GDPR – General Data Protection Regulation of the European Parliament 2016/679 of April 27, 2016. This act protects physical persons and the use of their personal data and replaces Directive 95/46/WE regarding personal data.
DG websites – Internet websites operated by or on behalf of DG and its subsidiaries worldwide.
Commercial Information – any information intended directly or indirectly for promoting subscription, services or image of DG.
Data integrity – refers to a situation in which data consistency is maintained during such operations as reading, saving, transmission or storage.
Partner – an entity, in favour of whom DG provides services or an entity that provides its services in favour of DG.
3. Who is data controller and data protection officer?
We are the controller of your personal data. Who are ‘we’? We are – DIGITAL GATEWAYS SP. Z O.O. based in Warsaw, Pl. Europejski 1, 00-844 Warsaw, entered into the entrepreneurs’ register of the National Court Register kept by the District Court for the capital city of Warsaw in Warsaw, XII Commercial Division of the National Court Register, under entry number KRS: 0000790370, Taxpayer Identification Number (NIP): 5272896326.
You may contact us directly by accessing our websites in order to get acquainted with information about the company, our programmes and services, without the need to provide your personal information.
We have appointed Damian Klimas as our DPO, whom you can contact by e-mail: email@example.com.
4. Why DG process your data and what are the legal basis?
We try not to process your data at all, but circumstances may arise when your personal information is required to perform a requested service. In such cases you will be informed about the necessity to provide the data and the ways in which it will be used, thus enabling you to decide whether to provide or refuse to provide your data e.g. in our contact form or if you wish to receive our newsletter.
Making your personal data available may be required when you are interested in requesting performance of a particular service (for example preparation of an offer, receiving information about subscription) or in situations when you are interested in taking part in a process or event (for example participation in a conference). You may then be asked to fill out and send a form/ questionnaire in which you will be clearly advised about what kind of personal data will be collected. In situations when you disclose your personal data of a third party (e.g. of a colleague) in a form/questionnaire, we shall assume you are in possession of an appropriate permission from the person whose data was disclosed.
We have to have a valid reason to use your data. It’s called the “lawful basis for processing”. Sometimes DG might ask your permission to do things, like when you subscrible to an email newsletter. Other times, when you’d reasonably expect us to use your personal information, we don’t ask your permission, but only when:
- the law says it’s fine to use it, and
- it fits with the rights you have
We may process your data:
- to perform the agreement (art. 6.1.b GDPR) – when we provide you with premium content after registration and logging into respective service, or to organize the event (i.e. conference);
- basing on our legitimate interests (art. 6.1.f GDPR) – when we process your data to contact you (deal with your requests, complaints and enquiries) for marketing purposes, to send you newsletter if you will provide us with you e-mail, as well as to research, analyze and improve the quality our services (profiling, data analytics);
- basing on your consent (art.6.1.a GDPR) – i.e. in the case of the processing of your personal data for marketing purposes, send you marketing offers.
We use your personal data for these types of things:
- to deliver our services and to provide you with information about them,
- to deal with your requests, complaints and enquiries,
- to personalise services and give you things more tailored to your tastes
- If you don’t want to receive personalised emial you can always turn this option off. Email us: firstname.lastname@example.org
- to help us understand what kind of services you might use and sometimes how you might share things with other people
- to recommend things we think might interest you
- to research and innovate
- to contact you about various things
5. Do you have to provide your personal data to DG?
Providing us with your personal data is mostly not required at all, but it may be necessary to provide you with certain services – like newsletter subscription, receiving premium content prepared by DG and contacting us by our contact form. If you will not provide us with your data, we will not be able to provide you with mentioned services or we will not be able to contact you.
6. What types of personal information we collect about you?
We’ll give details about why we need your personal information and how we’ll use it before you provide them, unless it’s obvious – as per contact form.
6.1. Personal data that you might give us
If you wish to contact us through our contact form, we might ask for your name and contact details, depending on what you’re doing.
If you wish to receive newsletter or premium content prepared by DG, we will ask for your mail in order to provide newsletter or this content.
6.2. We might process information regarding your devices
Devices are lots of things like:
- your computer,
- your mobile,
- your tablet,
- your voice-enabled device,
- any other device used by you.
6.3. Data on your activities outside the DG.
If you will mention us in a Twitter post, we’ll collect your Twitter handle. If you will mention us in a Facebook post, we’ll collect your Facebook handle. Privacy policies regarding processing your data in social media are available
7. How long will DG keep your personal data?
When you give us any personal information we’ll always stick to these principles:
- we don’t hold your information any longer than we have to,
- we only hold your information for as long as we do the activities we told you about or have a valid reason to keep it
- we think about what type of information it is, the amount collected, how sensitive it might be and any legal requirements.
We will store your personal data no longer than three years. If you gave us your consent, we will be processing your data until you withdraw it.
8. When DG will use your personal data to contact you?
We might use your e-mail or telephone number to contact you about different things, like:
- to update you on any changes to the DG’s policies and practices
- to contact you about a request you sent us
- to answer you when you’ve contacted us, or to respond to a comment or complaint
- to invite you to take part in DG’s events
- for marketing purposes
- to send you notification on your device if you’ve selected them in your settings
We’ll only contact you when we need to or when you’ve given us permission.
9. What are your rights?
Remember, you’re in control of your personal data. You have the right to:
- request access to and a copy of your personal data,
- not let robots make decisions about you,
- to ask us to correct personal data that’s wrong (rectification), to delete it (erasure) or to request that we only use it for certain purposes (restriction of processing) and to object to processing
- right to data portability (for e.g. transfering your data to another controller),
- to change your mind and ask us to stop using your data. For e.g, unsubscribing from any marketing emails or turning off personalization,
- withdraw your consent at any time, without affecting the lawfulness of processing based on consent before the withdrawal,
In order to do the above, please send an email to the following address: email@example.com with your request.
You also have the right to lodge a complaint with a supervisory authority. Data protection supervisory authority in Poland is President of Personal Data Protection Office.
Bear in mind, that sometimes we might not be able to help. Like if the law tells us we have to process your personal data, or in cases when you object to processing and we will demonstrate compelling legitimate grounds for the processing which override your interests, rights or freedoms.
10. Use of personal data
10.1 Performance of services
By informing us about your willingness to get acquainted with commercial information, specifically including subscription offer, services, receipt of newsletters, you agree that you may be contacted directly. We may share your personal data with entities whose involvement in the execution of a service is absolutely necessary (e.g. technological partners, application developers, financial and government institutions, postal services, transport companies). Such entities are required to use personal data provided to them only for the purpose of rendering a service on behalf of us and shall treat your personal data as strictly confidential.
Data provided by you may be used to maintain or develop business relations, as well as in order to ensure adequate provision of services. We may contact you in order to conduct customer satisfaction survey or market research.
10.2 Marketing purposes
Your personal data shared through our websites or provided while attending our conference or an event, may be used by us for marketing purposes. This data may be also made available to selected third parties with whom we cooperate in providing products and services to our clients and with whom we cooperate in the field of marketing, provided that such entity has been entrusted with processing of personal data by DG as the personal data controller under separate agreement. Personal data shall be used in the abovementioned way only in the case when the you expressed your consent to such action. We’ll only send you marketing emails or contact you, if you’ve agreed to this.
Keep in mind, even if you unsubscribe, we may still contact you for some reasons.
We might use information that we hold about you to show you relevant and “targeted advertising” through other companies’ sites, like Facebook, Google, Snapchat or Twitter for example.
If you don’t want to see our targeted advertising, you can set ad preferences in your social media companies’ settings. Also, you can send us your request at firstname.lastname@example.org
We provide our Partners with dedicated websites containing information necessary for cooperation with us. Access to these websites requires registration and a proper logging of a registered User with each visit. Personal data and information provided through such services may be used by us to manage business relations with the User or a Partner represented by the User, as well as with all Partners and to develop such relations, which may occur in particular by transferring commercial information, product information, marketing information and information about partnership programmes. We reserve the right to share personal data and information with our Partners and suppliers in order to render a service or carry out a process, provided that such entity has been entrusted with processing of personal data by us as the personal data controller under separate agreement unless additional obligations to keep the data confidential have been reserved.
We provide our Tenants with dedicated websites which constitute a database of knowledge about services that the Tenants use. Access to these websites requires registration and a proper logging of a registered User with each visit Information provided through such services may be used by us to manage business relations with the User or Tenants represented by the User, as well as with all Clients and to develop such relations, which may occur in particular by transferring commercial information, product information, marketing information and offers. We reserve the right to share personal data and information with our Partners and suppliers in order to render a service or carry out a process, provided that such entity has been entrusted with processing of personal data by us as the personal data controller under separate agreement, unless additional obligations to keep the data confidential have been reserved.
10.5 Electronic advertisements
We use services of external entities providing interactive electronic advertising (for example banner advertisements). These entities are authorised to collect and use information about Clients solely for the purpose of ensuring optimal service provision to DG, as well as in order to determine which offers, promotions and types of advertisements are best received by our Clients. Information collected in such manner is aggregated and thus cannot be used to identify a single User.
10.6 When does the DG share my personal data with others?
We’ll never sell your personal information. We do share it with others in these ways:
- When you make something public, like post a comment which the public can see.
- When we use other companies to power our services
In order for us to give you quality experiences and to understand how you’re using our services we often use other companies to process your personal information on our behalf. For example, sending you emails about things we think might interest you, or to ask you what you think about our services.
We make sure that your personal information is looked after as if we were handling it directly. We carefully select these companies, only share with them what they need to do the work and we make sure they keep your information secure.
- When we do collaborative research
We do research activities and sometimes collaborate with research partners. Every now and then we share our content and data with them. This might include information we’ve collected about you. But we’re careful about what we share and what our research partners can do with it.
- Sometimes by law we have to pass on your information to other organisations
We might also share your information if we have to by law, or when we need to protect you or other people from harm.
11. System logs
Your visit to our websites is automatically registered on the server, in the so called system logs. The data saved this way includes, among other things: date, time of the visit and the IP address. The data from system logs is used solely for the purposes of administering the servers and gathering website traffic statistics. In most cases system logs does not allow us to identify you.
12. Cookies and similar technologies
Cookie technology is used by most highly developed Internet sites in order to enhance the quality of service and perform certain functions, including
- creating individual content viewing statistics,
- personalization of services performed using the service,
- maintaining user sessions,
- authentication of people using the service,
- providing you with personalised advertising content.
DG websites use the following types of cookies:
- ‘Essential’ cookies, which enable the use of our website services, for example to allow the use of sessions,
- ‘Functional’ cookies, used to remember the settings chosen by you and to personalize the User’s interface, e.g. in terms of selected mobile/classic version, last phrases typed by the User, the appearance of a website, the state mechanism bookmarks, etc.
- ‘Analytical’ cookies, used to profile and monitor your activity on the site.
Cookies are not used for processing or storing personal details, they cannot be used for direct identification and they do not change browser options or terminal device configuration. You can independently determine and modify browser settings so that they will not accept cookies. If this option is selected some of our services may not function properly or at all. It may be possible to set your browser to ask for the your consent before each cookie is used. This allows you to have full control over what is set on their device, however it may slow down the browser. In order to manage your cookies, please select your browser from the list below and follow the instructions:
- Internet Explorer
No change in cookies configuration means they will be stored in your terminal device, and therefore we will keep information regarding your terminal device and gain access to this data.
13. Modification of Personal Information
The User is entitled to become acquainted with his/her data stored by DG, and to correct and update any inaccurate or incomplete personal data, should it be necessary. Moreover, the User is entitled at any time to request the removal of his/her personal data from DG’s database. In order to do the above, please send an email to the following address: email@example.com with a request to modify or remove personal data.
14. Disclosure required by Law
Under certain, limited circumstances, we may make available or provide personal information to third parties not affiliated with us. In particular, we may transfer personal data to a third party: upon your request;
- in order to comply with legal requirements or a court order;
- in order to verify the possibility of committing an offense of identity theft;
- in connection with a sale, purchase, merger, reorganisation, liquidation or dissolution of DG;
- under other similar circumstances.
15. Data protection
We’re strongly committed to keep your data safe and to do this we design our services with maximum safety in mind. At the same time, no service can be completely secure – if you have any concerns that your DG personal information has been put at risk, please get in touch straight away: firstname.lastname@example.org.
Companies that provide services to us run their services in the European Economic Area. When you give us personal information it could not be being transferred, stored or processed in a location outside the EEA.
We implement appropriate measures to protect the confidentiality of personal data and to preserve the integrity thereof. We uses an encrypted connection (Secure Sockets Layer) for protecting the data being transmitted. We are not responsible for data sent by third parties, and for data transmitted over unsecured connections.
16. Links to websites of other companies/organisations
Our website may include links to websites of other companies or organisations. We shall not be liable for procedures and data protection mechanisms used by these companies/ organisations or the content of other websites.
17. Notices of Policy updates
If you don’t agree to the changes, then you can always stop using our services and stop giving us any more personal information. We’d be sorry to see you go.
18. Questions and complaints about Privacy
For potential questions or complaints on how DG uses personal data, please contact us at the following address:
by email: email@example.com
by post: DIGITAL GATEWAYS SP. Z O.O., Warsaw Spire, 38th floor, Plac Europejski 1, 00-844 Warszawa, Polska.
contact our DPO: firstname.lastname@example.org