This privacy policy, hereinafter also referred to as “Policy” describes the modes of data collection, processing and using information about Users of the site www.syzygy.pl/ (hereinafter referred to as “the WWW”) and its components and the procedure of personal data protection of the Users of the WWW. The WWW is dedicated only to entrepreneurs and the site is designed to maintain B2B business relationships.

The Administrator of personal data

1.1. The administrator of the personal data of the WWW Users is: Ars Thanea S.A. with headquarters at Dziekońskiego 3, Warsaw registered in the Register of Entrepreneurs of the National Court Register maintained in the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register under the number KRS 000065391332, Tax Identification Number: 5252391391, REGON 140938516, with share capital of 270 000,00 PLN 00 paid in full (hereinafter also referred to as the „Administrator” or the „Company”).

1.2. In any matter regarding the processing of your personal data, please contact us at the following e-mail address: warsaw@syzygy.pl.

Processing of personal data – the basic information

2.1. Personal data is all information about an identified or identifiable natural person. All personal data is collected, stored and processed on the Website in accordance with the provisions of 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 (hereinafter referred to as “GDPR”).

2.2. The User of WWW provides an e-mail address on the WWW in order, to make contact with the Company and maintain business relations with the User of WWW.

2.3. Personal data is protected from access by third parties. The company uses data only for contact with Users of the WWW.

2.4. The Administrator does not process special categories of data.

2.5. The Company does not process personal data for purposes in which unambiguous consent is required, and such consent has not previously been granted.

The purposes of personal data processing

3.1. Personal data is collected, stored and used by the WWW with the consent of the persons to whom they relate, in accordance with the law and with due process and in a manner that ensures their safety.

3.2. The Administrator may use personal data only to provide proper service to the Users of the WWW and as part of communication with Users who have given their consent.

3.3. Personal data is used to conclude, execute and change, if any, the contract concluded with Users, including service delivery, complaint handling, abuse prevention and detection, and claim management.

3.4. The Administrator declares that he does not apply profiling for the purposes of direct marketing.

3.5. The Administrator provides the following legal grounds for data processing, including personal data:

• a) the data subject has given consent to the processing of his or her personal data for one or more specific purposes – the legal basis for the processing is art. 6 par. 1 point. a) of the GDPR;
• b) processing is necessary for the performance of the contract to which the data subject is a party – the legal basis for processing is art. 6 par. 1 point. b) of the GDPR;
• c) for analytical and statistical purposes, for the analysis of Users activity on the Website, in order to improve the functionalities used – the legal basis of the processing is the justified interest of the Administrator art. 6 par. 1 point. f) of the GDPR;
• d) for the purpose of potential determination, investigation or defense against claims – the legal basis of the processing is the legitimate interest of the Administrator art. 6 par. 1 point. f) of the GDPR.

 

Other purposes of processing personal data

4.1. The Company processes data for internal analyzes to manage the services provided and to plan their development. In addition, personal data are processed by us in order, to fulfill the obligations imposed on the Company by law.

4.2. The Administrator does not process personal data in automatic decision-making processes.

Protection of personal data being processed

5.1. The set of collected personal data is treated as a database with a high degree of security. The collection is stored on a secure server against both remote (IT) and physical access. In addition, all persons who process User’s personal data for the purposes of the WWW, appropriate authorizations issued by the Administrator. The basis for entrusting the processing of personal data is an appropriate agreement.

5.2. The Administrator does not transfer personal data of the WWW Users outside the European Economic Area.

Disclosure of personal data

6.1. The Company ensures special diligence in caring for the personal data protection. Personal data may be provided to entities that provide services to the Company. These entities are separate administrators of personal data that process data on their own behalf. These include courier and postal companies, banks, payment institutions or authorized public administration bodies, including the Chairman of Electronic Communications Office.

Duration of processing personal data

7.1. The data will be processed and stored by the Administrator for the time necessary due to the purpose of their processing. If personal data are processed in order, to conclude or perform the contract and fulfill the legal obligation of the Administrator, they will be kept for the duration of the contract, and after its expiry for the time necessary for after-sales customer service (e.g. complaint handling), security or investigation of possible claims related to the contract and fulfillment of the Administrator’s legal obligation.

7.2. In the case of processing personal data on the basis, of an expressed consent to the processing of personal data, the processing time will depend on the duration of the consent, i.e. until its revocation.

7.3. Personal data processed for the purpose of marketing and promotion of the Administrator’s own services, on the basis, of a justified legal interest, will be processed until the opponent complains.

Processing of other data of the WWW Users

8.1. Information contained in system logs (e.g. IP address) can also be collected on the WWW and its subpages. They are used for technical purposes related to server administration. IP Addresses are also used to collect general statistical information about Users visiting the WWW.

Transmission protection

9.1. Data of particular importance – in particular all kinds of passwords – are sent via SSL encrypted protocol.

Users’ rights in relation to personal data

10.1. The Company indicates the catalog of rights in relation to personal data:

• a) rectification (correction of data);
• b) deletion of data processed unreasonably in situations where this right is not excluded;
• c) limitation of data processing;
• d) access to information about the data and the data itself;
• e) transferring data to another administrator;
• f) the right to object to the data being processed to the competent authority: https://uodo.gov.pl/.

 

Request to delete personal data from the database and other applications

11.1. At any time, the User withdraws consent to the processing of personal data for the purposes of sending newsletter messages or processing data for marketing purposes, if such consent was previously expressed by the User. The appropriate message should be sent to the e-mail address: warsaw@syzygy.pl or traditional mail to the above-mentioned address of the Administrator’s office. Withdrawal of consent will result in the User not being receiving information about promotions, new products and other attractive offers dedicated to our clients from the time the User submits a statement of withdrawal.

11.2. Further processing of the User’s data may take place due to the following reasons:

• a) meeting the required period of data storage in relation to commercial and tax law;
• b) storage of evidence in the area of ​​legal restrictions.

 

11.3. Individual applications regarding User’s rights related to the processing of personal data, please direct:

• a) in writing to the address of the Administrator’s office;
• b) by e-mail to the following address: warsaw@syzygy.pl.

 

11.4. Any additional information about the rules for the processing of personal data, including their use and protection, as well as the User’s rights and conditions of use, will be available at the registered office of service providers by email at warsaw@syzygy.pl.

11.5. The administrator does not declare a formal obligation to appoint an Inspector of Personal Data Protection.

11.6. In the event that the User finds that the processing of his personal data is illegal, he has the right to lodge a complaint with the President of the Office for the Protection of Personal Data.

Cookies

12.1 The WWW uses “cookies”. Cookies are text files that are stored on your computer when you use websites. Cookies store information such as language settings, the amount of time a particular user spends on the website or information on the website. This prevents the Company from re-entering all the necessary data on the next visit to the website.

The Company uses so-called “session cookies” or “session cookies” which, depending on the User’s browser settings, will be deleted when the browser is closed.

The Company also uses files that are used immediately after the session ends (“trans-session cookies”). These cookies are used in particular to make the Company’s services more user-friendly and efficient. As such, it is possible that the Company may provide information tailored precisely to the User’s interests on the page the User is currently viewing.

The Company also uses third party cookies (“third party cookies”) – these are used by third parties, such as social media sites, to track your visits to various websites where they place advertisements.

The cookies used by the WWW can be divided into the following categories:

• a) Essential – Essential cookies include strictly necessary cookies that we use to make the WWW function, which help with the operation and design of the WWW. They improve the WWW’s functionality and allow it to be personalized. Necessary cookies are set only in response to actions taken by the User, i.e. requests for the provision of services, including setting the User’s privacy preferences or filling in forms (e.g. contact form). The User’s consent is not required for the operation of the necessary files.
• b) Functional – Functional cookies help us to remember the User’s chosen website settings or assist with other functions when browsing and using the WWW. These cookies remember your preferences and make it easier for you to use the website on subsequent visits. You may adjust your browser settings so that it blocks these cookies. Please note that if you choose to block these cookies, some parts of the website may not function properly.
• c) Analytical – Analytical cookies help to study statistics about web traffic and check the sources of that traffic. In addition, they provide information on which pages on the website are the most popular, as well as how users navigate the website. These cookies are designed to improve the user experience on the website. The User’s consent is required for analytical cookies to work.
• d) Performance – Performance cookies are used to understand and analyze key performance indicators of the WWW to help provide a better user experience for visitors. Consent is required for performance cookies to work.
• e) Advertising – Advertising cookies allow profiling of the advertisements displayed according to your preferences in terms of choice of services/materials on the basis of the data held by Administrator, including your behaviour while using the Website. Your consent is required for advertising cookies to work.
• f) Other Uncategorized cookies are those that are analyzed and not yet classified in any category. They only work with the User’s consent.

 

This is only intended to adapt the services to your needs and to make using the web as easy as possible. Most web browsers automatically accept cookies. The User can refuse to accept cookies by not allowing them to be processed in his/her browser. The User can find out how to do this in detail by reading the instructions of the browser manufacturer. The User may at any time delete the cookies that are stored on his/her terminal device. The Company emphasizes that without cookies, the web pages may only be partially accessible.

12.2 Tools using cookies for website optimization

12.2.1 Google – The Company uses products and functions provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA; “Google”):

• a) Google Tag Manager

The website uses the Google Tag Manager tool provided by the US company Google LLC, which is used to manage tags and script loading within the website. As a tool in itself, Google Tag Manager does not collect any information beyond that necessary for its proper operation but is responsible for loading the other scripts described below.

• b) Google Analytics

The “Universal Analytics” mode of operation is available on the website. This makes it possible to attribute data, sessions and interactions across multiple devices thanks to a pseudo-anonymous identifier and thus analyze User activity on different devices.

Google Analytics uses cookies, which are text files stored on your computer that help the website operator analyze how Users use its website. The information generated by the cookies in connection with your use of the Website is usually transferred to Google’s servers in the USA and stored there.

However, if IP anonymization is enabled on the website, Google will first reduce / shrink your IP address within all EU member states or other countries or countries covered by the agreement on the European Economic Area.

Only in exceptional cases will the entire IP address first be transferred to Google’s servers in the USA and only then will it be reduced. For more information on the terms of use and data protection, please visit: https://www.google.com/analytics/terms/gb.html or https://policies.google.com/?hl=en.

The User may opt out of cookies by selecting the appropriate settings on their web browser. If the User chooses such settings, it may not be possible to use the full functionality of the Website. The User may prevent Google from collecting the data generated by the cookies and related to the use of the Website (including the User’s IP address) and from processing this data by Google by downloading and installing a browser add-on. Opt-out cookies prevent future data collection when the User visits the Website. To prevent Universal Analytics from collecting data on several devices, the User must install the opt-out system on all devices. When you click on the opt-out cookie provided, the following will be installed: Disable Google Analytics.

12.2.2 HotJar – The website uses the Hotjar tool to better understand the needs of the User and to optimize the website for the user’s experience of the website. Hotjar registers each visitor to the website and allows a video recording of their movement on the website to be played, as well as generating heat maps. Within the Hotjar tool, the Administrator does not have access to information that identifies the User, as Hotjar does not record the process of filling in forms designed to provide personal data.

In order to use Hotjar, the Administrator has implemented a special Hotjar tracking code in the code of the website. The tracking code uses cookies from Hotjar Limited. The information collected through cookies is stored by Hotjar as part of a pseudonymous user profile. Neither Hotjar nor the Website uses this information to identify the User. The User may object to Hotjar’s creation of his/her user profile, to Hotjar’s storage of information about the use of the Website and to Hotjar’s use of cookies through information at: https://www.hotjar.com/legal/compliance/opt-out/. Details related to Hotjar’s data processing can be found here: https://www.hotjar.com/legal/policies/privacy/

12.2.3. Leedfeader.com – The website uses the Leedfeader tool, which collects behavioral data of website visitors, including pages viewed, source of visit and time spent on the website, in order to enrich the Administrator’s contact database. Detailed information on the data collected through Leedfeader is available at the following link: http://www.leadfeeder.com/leadfeeder-and-gdpr/.

12.2.4 Mailchimp – Administrator uses the MailChimp service to send out newsletters. The operator of the service is Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

This service allows, among other things, the organization of the dispatch of newsletters and its analysis. The data provided by the user in connection with the newsletter (e.g. email address), is stored on MailChimp servers in the USA.

MailChimp is certified as “EU-US-Privacy-Shield”. “Privacy-Shield” is an agreement between the European Union (EU) and the USA to ensure compliance with European data protection standards in the USA.

Using MailChimp, the Administrator can analyze newsletter campaigns. When a user opens an email sent using MailChimp, a file contained in the email (so-called web-beacon) connects to MailChimp’s servers in the USA. In this way, it can be determined whether a newsletter message has been opened and possibly which links have been clicked. In addition, technical information (e.g. time of visit, IP address, browser type and operating system) is stored. This information cannot be assigned to a specific newsletter recipient. It is used exclusively for statistical analyses of newsletter campaigns. The results of these analyses can be used in the future to better tailor the newsletter to the interests of the recipients.

If you do not consent to analysis by MailChimp, you should unsubscribe from the newsletter. This is done using a special link included in each newsletter. Furthermore, the newsletter subscription can also be deactivated directly on the website.

Data processing takes place on the basis of the consent given by the User (art 6 par. 1 point a) GDPR). You can revoke your consent at any time by deactivating your subscription to the newsletter. The revocation does not affect the legality of the data processing carried out so far.

The data provided by the User in connection with the newsletter service is stored by the Administrator until unsubscribing from the newsletter and is deleted from the MailChimp servers once the newsletter subscription is deactivated.
More information on MailChimp’s privacy policy is available at: https://mailchimp.com/legal/terms/.

12.2.5 HubSpot – The website uses HubSpot, a tool provided by HubSpot Inc, HubSpot Ireland Limited. We use the HubSpot tool for online marketing activities, contact management (e.g. user segmentation & CRM), landing pages and a contact form. HubSpot is a marketing automation tool used for hosting, email marketing and social media marketing. The tool tracks and reports on web activity. HubSpot uses the following data collected to track and monitor usage of the service:

• in anonymized form: browser information, demographic data, type of hardware/software, page views, areas served,
• in pseudonymized form: IP address, location data, clickstream data,
• in the contact form: name and personal contact details (i.e. e-mail address, telephone number), company name, content interests, web interactions, downloaded material.

 

Unless and until otherwise stated in this privacy policy, the legal basis for the use of Hubspot’s services is art. 6 par. 1 point f) of the DPA. Our legitimate interest in using this service is to optimize our marketing efforts and improve the quality of our website services.

For more information on HubSpot’s data protection activities, please visit the HubSpot website: https://legal.hubspot.com/privacy-policy

12.3 Interaction through our social media profiles

The Administrator has public profiles on social media platforms such as Facebook, LinkedIn, Instagram, Vimeo, YouTube. As such, we may process the data you leave when you visit our profiles (including comments, likes, web IDs). We receive data from you when you start following our profiles or otherwise interact with us. We process this data, in order to: enabling activity on our profiles, responding to requests made to us through social media, promoting various events and services of the Administrator through posts we make on social media, for statistical and analytical purposes.

Please note that social media collect personal data themselves (in connection with the user profiles created in them), so you should read the privacy policy of each site on which you create a user account. We process the data on the basis of the Company’s legitimate interests (Article 6 par. 1 point (f) of the GDPR), consisting of promoting its own brand and the services it provides.

13. Date of application

The Policy is accurate as at 23.11.2023.