This privacy policy sets out how we process information about you, including personal data and cookies.
1. General information
This policy applies to the website operating at: strategypartners.pl
The operator of the website and the controller of personal data is: Strategy Partners Prosta Spółka Akcyjna, with its registered office in Poznań at: Plac Andersa 7, 61-894 Poznań, Poland
The operator’s contact email address: biuro@strategypartners.pl
The Operator is the Controller of your personal data with regard to data provided voluntarily on the Website.
The Website uses personal data for the following purposes:
- Running a newsletter
- Handling enquiries submitted through forms
- Providing ordered services
- Presenting offers or information
The Website obtains information about users and their behaviour in the following ways:
Through data entered voluntarily in forms, which is entered into the Operator’s systems.
By storing cookie files on end devices.
2. Selected data protection methods used by the Operator
Places where you log in and enter personal data are protected in the transmission layer (SSL certificate). As a result, personal data and login details entered on the site are encrypted on the user’s computer and can only be read on the target server.
Personal data stored in the database is encrypted in such a way that only the Operator, who holds the key, can read it. This protects the data in the event of the database being stolen from the server.
User passwords are stored in hashed form. The hash function works one way – it cannot be reversed, which is the current standard for storing user passwords.
The Operator changes its administrative passwords periodically.
To protect data, the Operator regularly makes backup copies.
An important element of data protection is the regular updating of all software used by the Operator to process personal data, which in particular means regular updates of software components.
3. Hosting
The Website is hosted (technically maintained) on the servers of the operator: LH.pl
4. Your rights and additional information on how data is used
In some situations the Controller has the right to transfer your personal data to other recipients if this is necessary to perform a contract concluded with you or to fulfil the Controller’s obligations. This applies to the following groups of recipients:
- the hosting company, as a data processor
- authorised employees and associates who use the data to fulfil the purpose of the website
- companies providing marketing services to the Controller
Your personal data is processed by the Controller for no longer than is necessary to carry out the related activities specified in separate regulations (e.g. on accounting). Marketing data will not be processed for longer than 3 years.
You have the right to request from the Controller:
- access to your personal data,
- its rectification,
- its erasure,
- restriction of processing,
- and data portability.
You have the right to object to the processing indicated in point 3.3 c) of personal data for the purposes of the legitimate interests pursued by the Controller, including profiling; however, the right to object cannot be exercised where there are compelling legitimate grounds for the processing that override your interests, rights and freedoms, in particular the establishment, exercise or defence of legal claims.
You may lodge a complaint about the Controller’s actions with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stawki 2, 00-193 Warsaw, Poland.
Providing personal data is voluntary, but necessary to use the Website.
Automated decision-making, including profiling, may be carried out in relation to you in order to provide services under a concluded contract and for the Controller’s direct marketing.
Personal data is not transferred to third countries within the meaning of data protection law. This means that we do not send it outside the European Union.
5. Information in forms
The Website collects information provided voluntarily by the user, including personal data, if provided.
The Website may record information about connection parameters (time stamp, IP address).
In some cases, the Website may record information that makes it easier to link the data in a form with the email address of the user filling it in. In such a case, the user’s email address appears in the URL of the page containing the form.
Data provided in a form is processed for the purpose resulting from the function of the specific form, e.g. to handle a service request or a business enquiry, register for services, etc. In each case, the context and description of the form clearly state what it is for.
6. Administrator logs
Information about users’ behaviour on the website may be logged. This data is used to administer the website.
7. Key marketing techniques
The Operator uses statistical analysis of website traffic through Google Analytics (Google Inc., based in the USA). The Operator does not transfer personal data to the operator of this service, only anonymised information. The service is based on the use of cookies on the user’s end device. With regard to information on user preferences collected by the Google advertising network, the user can view and edit information derived from cookies using the tool: https://www.google.com/ads/preferences/
The Operator uses remarketing techniques that make it possible to tailor advertising messages to the user’s behaviour on the site. This may give the impression that the user’s personal data is being used to track them; however, in practice no personal data is transferred from the Operator to advertising operators. The technological precondition for these activities is that cookies are enabled.
The Operator uses the Facebook pixel. This technology means that Facebook (Facebook Inc., based in the USA) knows that a person registered with it is using the Website. In this case it relies on data for which it is itself the controller; the Operator does not pass on any additional personal data to Facebook. The service is based on the use of cookies on the user’s end device.
The Operator uses a solution that studies user behaviour by creating heat maps and recording behaviour on the site. This information is anonymised before being sent to the service operator, so that it does not know which natural person it relates to. In particular, passwords and other personal data entered are not recorded.
The Operator uses a solution that automates the operation of the Website in relation to users, e.g. one that can send an email to a user after they visit a specific page, provided that they have consented to receiving commercial communications from the Operator.
8. Information about cookies
The Website uses cookies.
Cookies are IT data, in particular text files, which are stored on the Website user’s end device and are intended for use with the Website’s pages. Cookies usually contain the name of the website they come from, how long they are stored on the end device and a unique number.
The entity that places cookies on the Website user’s end device and accesses them is the Website operator.
Cookies are used for the following purposes:
maintaining the Website user’s session (after logging in), so that the user does not have to re-enter their login and password on every page of the Website;
achieving the purposes set out above in the section “Key marketing techniques”;
The Website uses two main types of cookies: session cookies and persistent cookies. Session cookies are temporary files that are stored on the User’s end device until they log out, leave the website or close the software (web browser). Persistent cookies are stored on the User’s end device for the time specified in the cookie parameters or until they are deleted by the User.
Web browsing software (web browsers) usually allows cookies to be stored on the User’s end device by default. Website users can change these settings. The web browser allows cookies to be deleted. It is also possible to block cookies automatically. Detailed information on this can be found in the help section or documentation of your web browser.
Restrictions on the use of cookies may affect some of the functionality available on the Website’s pages.
Cookies placed on the Website user’s end device may also be used by entities cooperating with the Website operator, in particular: Google (Google Inc., based in the USA), Facebook (Facebook Inc., based in the USA), Twitter (Twitter Inc., based in the USA).
9. Managing cookies – how to give and withdraw consent in practice
If the user does not want to receive cookies, they can change their browser settings. Please note that disabling cookies necessary for authentication, security and maintaining user preferences may make it difficult, and in extreme cases impossible, to use the website.
To manage cookie settings, choose the web browser you use from the list below and follow the instructions:
Mobile devices:
This is an English translation provided for convenience. In the event of any discrepancy, the Polish version of this privacy policy prevails.