Ladies and Gentlemen,
From May 25, 2018, the Regulation of the European Parliament and of the Council (EU) 2016/679 of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”). Therefore, we provide you with information on the legal basis and method of processing your personal data by Hogart Business Intelligence sp. z o. o. and the rights of data subjects related to it.
Personal Data Administrator
Pursuant to art. 4 points 7 of the GDPR. The data administrator, 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) ul. Okopowa 58/72 (“HBI”).
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, for the purpose of sending commercial information to the e-mail address provided by you, in the form of an SMS to the indicated telephone number and direct marketing, data storage for archiving purposes, for the purpose of demonstrating the correctness of compliance with legal obligations incumbent on HBI – with your voluntary consent (Article 6(1)(a) of the GDPR) and in execution legally legitimate interests of HBI (Article 6(1)(f) of the GDPR).
At the same time, we would like to inform you that before starting the processing of personal data on the basis of legitimate interests, HBI analyzes the interest of HBI, the potential impact of processing on the data subject and the rights of that person under the provisions on the protection of personal data. HBI does not process personal data based on a legitimate interest, if the impact of processing on the data subject would outweigh the interests of HBI; in this case, the processing of personal data is subject to HBI having the appropriate consent of the data subject or when required or permitted by law.
Personal data is processed in IT systems used by HBI (including the CRM system).
HBI will process personal data in a form that allows you to be identified for a period not longer than it is necessary for the purposes for which the data is processed. If there is another legal basis justifying data processing, the right to process personal data will cease at the end of the period provided for in these provisions.
Recipients of data
Your data may be transferred by HBI to entities that provide technical and organizational support to HBI, such as: entities providing hosting services, suppliers of system management software, entities providing technical support for software, suppliers providing software for sending commercial correspondence via e-mail and SMS messages. HBI declares that the transfer of your data to these entities will take place on the basis of relevant contracts compliant with the GDPR and guaranteeing the security of your personal data.
Territory where personal data is processed
Your personal data will be processed only within the territory of the European Union and the European Economic Area.
Rights related to the processed personal data
You have the right to: access data, rectify and correct data, request data deletion, limit data processing and transfer data – within the scope and on the terms set out in the GDPR.
You have the right to object to the processing of your personal data for direct marketing purposes at any time. In this case, HBI will not process your data for these purposes.
If your data is processed on the basis of your consent, you have the right to withdraw your consent to the processing of your data at any time without affecting the lawfulness of the processing of this data that took place before the consent was withdrawn.
If HBI violates the provisions on the protection of personal data when processing your personal data, you have the right to lodge a complaint with the supervisory body, which is the President of the Office for Personal Data Protection.
Processing of personal data of persons visiting HBI websites or using electronic services
HBI limits the collection and use of information about persons visiting HBI websites or using electronic services to the minimum necessary for the proper provision of services to them, in accordance with art . 18 of the Act of July 18, 2002 on the provision of electronic services.
Cookies are small text files saved on the user’s computer or other mobile device while using websites. These files are used in particular to use the various functions provided on the HBI website or to confirm that the user has seen certain content from this website.
HBI may collect personal data automatically via cookies on the HBI website, to a limited extent.
HBI uses the following types of cookies and for the following purposes:
1) necessary for the operation of the HBI website. These files are used to enable: maintaining the user’s session, saving the user’s session state, authorizing the user using logging in, saving information allowing the user to log in anonymously, monitoring the availability of services.
2) facilitating the use of the HBI website. These files are used to enable: restoring the last visited view at the next login, remembering the user’s choice to stop displaying the selected message or displaying it a certain number of times, restoring the user’s session, remembering the last selected category of products or services, checking the correct functioning of saving to files cookies, enabling automatic login to the product (“remember me” option), setting properties that facilitate work with the application.
HBI collects information on the use of the HBI website by users and their IP addresses. This information is collected based on the analysis of access logs.
This information is used for the following purposes: diagnosing problems related to server operation, analyzing possible security breaches and managing the website.
The information collected in this way may also be used to prepare collective, general statistical summaries for HBI’s own purposes, however, such summaries do not contain any data enabling the identification of a given user.
On the basis of applicable law and at the request of authorized state authorities, within the limits of these regulations and requests, HBI may be required to disclose information regarding the IP number of a given user in connection with proceedings conducted by these authorities.
Ways of blocking cookies on the user’s device
Users can manage cookies used by HBI by changing the settings of their web browsers.
The 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 the use of the website.
Automatic processing of personal data
Information collected by HBI may be processed in an automated manner (including in the form of profiling), but it will not have any legal effects on you or similarly significantly affect you. In addition, for the purposes of profiling, HBI does not process any sensitive data (data of special categories), it processes pseudonymized data.
Contact regarding the protection of personal data
In matters relating to the protection of personal data and the exercise of related rights, you can contact HBI in the following way:
1) contact to the address of the HBI’s registered office: Hogart Business Intelligence sp. z oo, 01-042 Warsaw, ul.Okopowa 58/72,
2) contact to the address of the HBI office: Hogart Business Intelligence sp. z oo, 01-042 Warsaw, ul.Okopowa 58/72,
3) contact via e-mail: firstname.lastname@example.org
with the note “personal data protection”.