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Privacy Policy

The following Privacy Policy sets out the rules for storing and accessing data on the Devices of Users using the Website for the purpose of providing electronic services by the Controller, as well as the rules for collecting and processing Users’ personal data that has been provided by them personally and voluntarily via the tools available on the Website.

The following Privacy Policy forms an integral part of the Website Terms and Conditions, which define the rules, rights and obligations of Users using the Website.

Definitions

  • Website - the “CodeAgency.pl” website operating at https://codeagency.pl

  • External Website - websites of partners, service providers or service recipients cooperating with the Controller

  • Website / Data Controller - the Controller of the Website and the Data Controller (hereinafter: the Controller) is “CodeAgency.pl Sp. z o.o.”, conducting business at: ul. Królowej Jadwigi 18, 85-231 Bydgoszcz, assigned tax identification number (NIP): 9671412160, assigned KRS number: 0000725181, providing electronic services via the Website

  • User - a natural person for whom the Controller provides electronic services via the Website.

  • Device - an electronic device together with software through which the User gains access to the Website

  • Cookies - text data collected in the form of files placed on the User’s Device

  • GDPR - 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 (General Data Protection Regulation)

  • Personal data - means information relating to an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name and surname, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

  • Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether by automated means or not, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

  • Restriction of processing - means the marking of stored personal data with the aim of limiting its processing in the future

  • Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements

  • Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her

  • Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or unauthorised access to personal data transmitted, stored or otherwise processed

  • Pseudonymisation - means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures preventing it from being attributed to an identified or identifiable natural person

  • Anonymisation - Data anonymisation is an irreversible process of operations performed on data that destroys / overwrites “personal data”, making it impossible to identify or link a given record to a specific user or natural person.

Data Protection Officer

Pursuant to Article 37 of the GDPR, the Controller has not appointed a Data Protection Officer.

In matters concerning the processing of data, including personal data, please contact the Controller directly.

Types of Cookies

  • Internal cookies - files placed on and read from the User’s Device by the Website’s ICT system

  • External cookies - files placed on and read from the User’s Device by the ICT systems of External Websites. Scripts of External Websites that may place Cookies on Users’ Devices have been deliberately embedded in the Website through scripts and services made available and installed on the Website

  • Session cookies - files placed on and read from the User’s Device by the Website during a single session of a given Device. After the session ends, the files are deleted from the User’s Device.

  • Persistent cookies - files placed on and read from the User’s Device by the Website until they are manually deleted. The files are not deleted automatically after the Device session ends unless the User’s Device configuration is set to delete Cookie files after the Device session ends.

Data storage security

  • Cookie storage and reading mechanisms - The mechanisms for storing, reading and exchanging data between Cookies saved on the User’s Device and the Website are implemented through the built-in mechanisms of web browsers and do not allow the collection of any other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojan horses and other worms to the User’s Device is also practically impossible.

  • Internal cookies - Cookies used by the Controller are safe for Users’ Devices and do not contain scripts, content or information that could threaten the security of personal data or the security of the Device used by the User.

  • External cookies - The Controller takes all possible actions to verify and select the Website’s partners in terms of User security. The Controller selects well-known, large partners with global public trust for cooperation. However, the Controller does not have full control over the content of Cookie files originating from external partners. To the extent permitted by law, the Controller is not responsible for the security of Cookie files, their content, or their licence-compliant use by Scripts installed on the Website and originating from External Websites. The list of partners is included later in this Privacy Policy.

  • Cookie control

  • Threats on the User’s side - The Controller uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of such data depends on both parties, including the User’s activity. The Controller is not responsible for the interception of such data, impersonation of the User’s session or deletion of such data as a result of the User’s intentional or unintentional actions, viruses, Trojan horses and other spyware with which the User’s Device may be or may have been infected. In order to protect themselves against these threats, Users should follow the rules that increase their cybersecurity.

  • Storage of personal data - The Controller ensures that it makes every effort to keep the processed personal data voluntarily entered by Users secure, to restrict access to such data and to process it in accordance with its intended purpose and processing purposes. The Controller also ensures that it makes every effort to protect the data it holds against loss by applying appropriate physical and organisational safeguards.

Purposes for which Cookies are used

  • Improving and facilitating access to the Website

  • Personalising the Website for Users

  • Marketing, remarketing on external websites

  • Keeping statistics (users, number of visits, types of devices, connection, etc.)

  • Serving multimedia services

Purposes of personal data processing

Personal data voluntarily provided by Users is processed for one of the following purposes:

  • Provision of electronic services:

    • Newsletter service (including the sending of advertising content with consent)

    • Service of sharing information about content posted on the Website on social networking sites or other websites.

  • Communication between the Controller and Users in matters related to the Website and data protection

  • Ensuring the Controller’s legitimate interest

Data concerning Users that is collected anonymously and automatically is processed for one of the following purposes:

  • Keeping statistics

  • Remarketing

  • Ensuring the Controller’s legitimate interest

The Controller uses javascript scripts and web components of partners on the Website, which may place their own cookies on the User’s Device. Please remember that in your browser settings you can decide independently which cookies may be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

Services provided by third parties are outside the Controller’s control. These entities may change their terms of service, privacy policies, purpose of data processing and methods of using cookie files at any time.

Types of data collected

The Website collects data about Users. Some data is collected automatically and anonymously, and some data constitutes personal data voluntarily provided by Users when signing up for individual services offered by the Website.

Anonymous data collected automatically:

  • IP address

  • Browser type

  • Screen resolution

  • Approximate location

  • Website subpages opened

  • Time spent on the relevant Website subpage

  • Type of operating system

  • Address of the previous subpage

  • Referring page address

  • Browser language

  • Internet connection speed

  • Internet service provider

  • Demographic data (age, gender)

Data collected during registration:

  • First name / surname / pseudonym

  • E-mail address

  • Website addresses

  • Telephone number

  • IP address (collected automatically)

  • NIP number

  • Other ordinary data

Data collected when subscribing to the Newsletter service

  • First name / surname / pseudonym

  • E-mail address

  • IP address (collected automatically)

Some data (without identifying data) may be stored in cookie files. Some data (without identifying data) may be transferred to the provider of statistical services.

Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Controller. Data collected as part of the services provided is not transferred or resold to third parties.

Access to data (most often on the basis of a data processing entrustment agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to operate the Website, i.e.:

  • Hosting companies providing hosting or related services to the Controller

  • Companies through which the Newsletter service is provided

Entrustment of personal data processing - Newsletter

For the purpose of providing the Newsletter service, the Controller uses the services of a third party - the MailChimp, service. Data entered in the newsletter subscription form is transferred to, stored and processed in the external website of this service provider.

Please be informed that the indicated partner may modify the indicated privacy policy without the Controller’s consent.

Entrustment of personal data processing - Hosting, VPS or Dedicated Server Services

For the purpose of operating the Website, the Controller uses the services of an external provider of hosting, VPS or Dedicated Server services - Home.pl S.A. All data collected and processed on the Website is stored and processed in the service provider’s infrastructure located within the borders of the European Union. Access to the data may be possible as a result of maintenance work performed by the service provider’s personnel. Access to such data is governed by the agreement concluded between the Controller and the Service Provider.

Method of personal data processing

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union unless it has been published as a result of an individual action by the User (e.g. posting a comment or entry), which will make the data available to every person visiting the Website.

  • Personal data will not be used for automated decision-making (profiling).

  • Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) will be transferred outside the European Union.

  • Anonymous data (without personal data) will not be used for automated decision-making (profiling).

  • Anonymous data (without personal data) will not be resold to third parties.

The Website collects and processes Users’ data on the basis 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 (General Data Protection Regulation)

    • Article 6(1)(a)
      the data subject has given consent to the processing of his or her personal data for one or more specific purposes

    • Article 6(1)(b)
      processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract

    • Article 6(1)(f)
      processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party

  • Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)

  • Act of 16 July 2004 - Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)

  • Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24, item 83)

Period of personal data processing

Personal data provided voluntarily by Users:

As a rule, the indicated personal data is stored only for the period during which the Service is provided within the Website by the Controller. It is deleted or anonymised within up to 30 days from the moment the provision of services ends (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation that requires safeguarding the Controller’s legally justified purposes for further processing of such data. In such a situation, the Controller will store the indicated data, from the time of the User’s request for its deletion, for no longer than 3 years in the event of a violation or suspected violation of the Website terms and conditions by the User

Anonymous data (without personal data) collected automatically:

Anonymous statistical data that does not constitute personal data is stored by the Controller for the purpose of keeping Website statistics for an indefinite period

The Website collects and processes Users’ data on the basis of:

  • Right of access to personal data
    Users have the right to obtain access to their personal data, exercised upon a request submitted to the Controller

  • Right to rectification of personal data
    Users have the right to request that the Controller promptly rectify personal data that is incorrect and / or complete incomplete personal data, exercised upon a request submitted to the Controller

  • Right to erasure of personal data
    Users have the right to request that the Controller promptly erase personal data, exercised upon a request submitted to the Controller. In the case of user accounts, data erasure consists of anonymising data that enables the User to be identified. The Controller reserves the right to suspend the execution of a data erasure request in order to protect the Controller’s legitimate interest (e.g. if the User has violated the Terms and Conditions or the data has been obtained as a result of conducted correspondence).
    In the case of the Newsletter service, the User may independently delete their personal data using the link included in each e-mail message sent.

  • Right to restriction of personal data processing
    Users have the right to restrict the processing of personal data in the cases indicated in Article 18 of the GDPR, including where the accuracy of personal data is contested, exercised upon a request submitted to the Controller

  • Right to data portability
    Users have the right to obtain from the Controller personal data concerning the User in a structured, commonly used and machine-readable format, exercised upon a request submitted to the Controller

  • Right to object to personal data processing
    Users have the right to object to the processing of their personal data in the cases specified in Article 21 of the GDPR, exercised upon a request submitted to the Controller

  • Right to lodge a complaint
    Users have the right to lodge a complaint with the supervisory authority responsible for personal data protection.

Contact details of the Controller

The Controller may be contacted in one of the following ways

Website requirements

  • Restricting the storage of and access to Cookie files on the User’s Device may cause some Website functions to operate incorrectly.

  • The Controller is not liable for any incorrectly operating Website functions if the User in any way restricts the possibility of storing and reading Cookie files.

The Website - in articles, posts, entries or Users’ comments - may contain links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated by them may be unsafe for your Device or may pose a threat to the security of your data. The Controller is not responsible for content located outside the Website.

Changes to the Privacy Policy

  • The Controller reserves the right to make any changes to this Privacy Policy without the need to inform Users thereof in the scope of applying and using anonymous data or using Cookie files.

  • The Controller reserves the right to make any changes to this Privacy Policy in the scope of processing Personal Data, of which it will inform Users who have user accounts or are subscribed to the newsletter service, by e-mail, within 7 days from the change of the provisions. Continued use of the services means that the User has read and accepted the changes introduced to the Privacy Policy. If the User does not agree with the introduced changes, the User is obliged to delete their account from the Website or unsubscribe from the Newsletter service.

  • Changes introduced to the Privacy Policy will be published on this Website subpage.

  • Changes introduced enter into force upon their publication.