Privacy Policy of Hogart Business Intelligence sp. z o.o.
Dear Sir or Madam,
As of May 25, 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 (“GDPR”) is in force. In connection with this, we provide you with information on the legal bases and methods of processing your personal data by Hogart Business Intelligence sp. z o.o., as well as the rights of data subjects related thereto.
Personal Data Controller
Pursuant to Article 4(7) of the GDPR, the data controller, i.e., the entity deciding on the purposes and methods of data processing, is Hogart Business Intelligence sp. z o.o. with its registered office in Warsaw (01-042 Warsaw) at ul. Okopowa 58/72 (“HBI”).
Personal Data
Personal data means information about an identified or identifiable natural person (“data subject”).
Purpose, Legal Basis, and Period of Personal Data Processing by HBI
Your personal data may be processed by HBI for the purpose of providing information in response to your request, subscribing to newsletters and webinars, sending commercial information to the email address you provided, in the form of SMS to the indicated telephone number, and for direct marketing purposes, storing data for archival purposes, and demonstrating proper fulfillment of legal obligations incumbent upon HBI—based on your voluntary consent (Article 6(1)(a) GDPR) and in pursuit of HBI’s legitimate interests (Article 6(1)(f) GDPR).
At the same time, we inform you that before commencing the processing of personal data based on legitimate interests, HBI analyzes HBI’s interest, the potential impact of processing on the data subject, and the rights of that person arising from data protection regulations. HBI does not process personal data based on legitimate interest if the impact of processing on the data subject would outweigh HBI’s interests; in such a case, the processing of personal data is conditional upon HBI having appropriate consent from the data subject or when required or permitted by law.
Personal data are processed in IT systems used by HBI (including the CRM system).
HBI will process personal data in a form that allows your identification for no longer than is necessary for the purposes for which the data are processed. If there is another legal basis justifying the processing of data, the right to process personal data will cease upon expiration of the period provided for in those provisions.
Data Recipients
Your data may be transferred by HBI to entities that provide technical and organizational support for HBI, such as: entities providing hosting services, software providers for system management, entities providing technical support for software, providers supplying software for sending commercial correspondence electronically and SMS messages. HBI declares that the transfer of your data to these entities will take place on the basis of appropriate agreements compliant with GDPR and guaranteeing the security of your personal data.
Territory Where Personal Data Are Processed
Your personal data will be processed exclusively within the territory of the European Union and the European Economic Area.
Rights Related to Processed Personal Data
You have the right to: access your data, rectify and correct data, request erasure of data, restrict processing of data, and data portability—to the extent and on the terms specified in the GDPR.
You have the right to object to the processing of your personal data for direct marketing purposes at any time. In such a case, HBI will not process your data for these purposes.
In the case of processing your data based on consent given, you have the right to withdraw your consent to the processing of your data at any time without affecting the lawfulness of processing based on consent before its withdrawal.
You may exercise these rights by contacting the addresses indicated in the “Contact Regarding Personal Data Protection” section of this Privacy Policy.
If HBI violates data protection regulations when processing your personal data, you have the right to lodge a complaint with the supervisory authority, which is the President of the Personal Data Protection Office.
Processing of Personal Data of Persons Visiting HBI Websites or Using Services Provided Electronically
HBI limits the collection and use of information about persons visiting HBI websites or using services provided electronically to the minimum necessary to properly provide services to them, pursuant to Article 18 of the Act of July 18, 2002 on the provision of services by electronic means.
Cookie Mechanisms Cookies are small text files saved on a user’s computer or other mobile device while using online services. These files are used in particular to use various functions provided on the HBI website or to confirm that the user has viewed specific content from that site.
HBI may collect personal data automatically through cookies located on the HBI website, to a limited extent.
HBI uses the following types of cookies and for the purposes stated below:
1) necessary for the operation of the HBI website. These files are used to enable: maintaining the user session, saving the user session state, user authorization using login, saving information allowing anonymous user login, monitoring service availability.
2) facilitating the use of the HBI website. These files are used to enable: restoring the last visited view upon next login, remembering the user’s choice to stop displaying a selected message or display it a specified number of times, restoring the user session, remembering the last selected product or service category, checking the correct functioning of cookie storage, enabling automatic login to the product (“remember me” option), setting properties that facilitate working with the application.
HBI also uses cookies for the following purposes: monitoring traffic on the HBI website, collecting anonymous, aggregate statistics to understand how users use the HBI website, determining the number of anonymous users of the HBI website for analysis of site usage, researching newsletter and webinar subscriptions, using communication tools, integration with social media platforms.
Access Logs
HBI collects information regarding the use of the HBI website by users and their IP addresses. This information is collected based on access log analysis.
This information is used for the following purposes: diagnosing problems related to server operation, analyzing potential security breaches, and managing the website.
Information collected in this way may also be used to prepare aggregate, general statistical summaries for HBI’s own purposes; however, such summaries do not contain any data allowing identification of a given user.
Based on applicable law and at the request of authorized state authorities, within the limits of these provisions and requests, HBI may be obliged to disclose information regarding a given user’s IP number in connection with proceedings conducted by these authorities.
Methods of Blocking Cookies on the User’s Device
Users can manage cookies used by HBI by changing the settings of their web browsers.
Settings can be changed as follows:
HBI informs that after rejecting cookies, some functions on the HBI website may not work properly or may completely prevent use of the site.
Automated Processing of Personal Data
Information collected by HBI may be processed in an automated manner (including in the form of profiling); however, this will not produce any legal effects concerning you or similarly significantly affect you. Furthermore, for profiling purposes, HBI does not process any sensitive data (special categories of data); it processes pseudonymized data.
Contact Regarding Personal Data Protection
For matters concerning personal data protection and the exercise of related rights, you may contact HBI as follows:
1) contact at HBI’s registered office address: Hogart Business Intelligence sp. z o.o., 01-042 Warsaw, ul. Okopowa 58/72,
2) contact at HBI’s office address: Hogart Business Intelligence sp. z o.o., 01-042 Warsaw, ul. Okopowa 58/72,
3) contact at the email address: info@hogart-bi.pl
with the note “personal data protection”.
Changes to the Privacy Policy.
The Privacy Policy may be amended if necessary due to new legal provisions, guidelines on personal data protection, codes of good practice—if HBI is bound by such codes, changes in technology used by HBI when processing your personal data, and in the event of changes in the methods, purposes, or legal bases for processing personal data.
This Privacy Policy is effective as of November 17, 2019.