Develtio Privacy Policy

I. Scope of Processed Data

  1. This concerns personal data collected during your use of the Develtio website, including:
    • First and last name,
    • Email address,
    • Shipping address,
    • Data required for issuing VAT invoices,
    • Date of birth,
    • Gender.
  2. Data collected in the profiling process is described in Section VIII below.

 

II. Administrator of Personal Data

  1. The owner of the Develtio website and the Administrator of the database is Develtio sp. z o.o. based in Warsaw, at ul. Franciszka Klimczaka 17/80 (02-797 Warsaw), registered in the entrepreneurs’ register kept by the District Court for the capital city of Warsaw in Warsaw, XII Economic Department of the National Court Register under the KRS number: 0000684368, REGON: 367647421, NIP: 9512440445, hereinafter referred to as “Develtio”.
  2. The Administrator of personal data ensures the security of the personal data provided by users. The Administrator complies with the provisions of the applicable law, including the General Data Protection Regulation of April 27, 2016, fulfilling the obligations arising therefrom and allowing users the right to access their own data, the right to request their update and deletion, and the right to object in cases specified in the above-mentioned law.
  3. The Administrator applies appropriate technical and organizational measures to ensure the protection of processed data, in particular by securing data against unauthorized access and processing in violation of applicable law.

 

III. Purpose of Processing Personal Data

  1. Personal data of users left through the Develtio website is processed solely for the purposes indicated in the applicable law and in the Privacy Policy, including in particular:
    • To the extent necessary for the provision of services and for statistical measurements and the Administrator’s own marketing (legitimate interest of the administrator according to art. 6 par. 1 lit. f, GDPR);
    • In the case of concluding an agreement with Develtio, in connection with such an agreement because processing is necessary for the performance of the contract (art. 6 par. 1 lit. b GDPR);
    • To establish, investigate, or defend against claims related to the contract concluded with the client or with the processing of their personal data, because processing is necessary to pursue the legitimate interests of Develtio;
    • To fulfill Develtio’s legal obligations, because processing in this case is necessary to fulfill the legal requirements to which Develtio is subject (legal basis: art. 6 par. 1 lit. c GDPR).
  2. Processing of users’ personal data for other purposes will be carried out only after obtaining the user’s consent and to the extent specified in the relevant consent.

 

IV. The duration of processing of personal data.

  1. Personal data obtained as a result of the conclusion of the contract are processed from the moment they are obtained from the User until:
    • The limitation period for claims arising from the contract for the provision of the Specialist selection service under processing based on art. 6 par. 1 lit. b GDPR,
    • Effective request to cease processing personal data/object/erase personal data or achievement of the purpose of processing in the case of processing based on art. 6 par. 1 lit. f GDPR;
    • Effective objection or achievement of the purpose of processing or expiration of claims arising from the newsletter delivery agreement (whichever event occurs earlier);
    • Until the end of the complaint procedure, and in the case of exercising the Customer’s rights, until their limitation period in the case of processing based on art. 6 par. 1 lit. c GDPR.
  2. Personal data obtained based on the owner’s consent are processed from the moment of giving the relevant consent until its withdrawal/request to cease processing personal data/request for deletion of personal data by its owner.
  3. Data collected in profiling are processed from the moment of starting to use the website (entering our website) until expressing objection to profiling.
  4. For the purpose of establishing, investigating, or defending against claims – personal data are processed until the limitation period for claims arising from the contract or claims related to the processing of personal data, or until objection is made.
  5. Personal data processed in connection with the Administrator’s legal obligation (taxation) will be kept for the period indicated in the relevant law and for the purpose indicated therein.

 

V. Transfer of Personal Data

  1. Personal data may̨ be transferred to international countries/organisations outside the European Economic Area, if these countries/organisations have been recognised by a decision of the European Commission as providing an adequate leveĺ of protection of personal data to that applicable in the European Economic Area or provided that appropriate safeguards have been applied́, which may̨ consist of the use of binding corporate rules, standard data protection clauses adopted by the European Commission, standard data protection clauses adopted by the President of the Data Protection Authority or contractual clauses authorised by the President of the Data Protection Authority, and a copy of which may be obtained́ upon request as indicated in point 1 above. 
  2. The Administrator uses the Google Analytics tool belonging to Google Inc. (“Google”) in order to analyse the use of our website and improve it. Thanks to the statistics obtained, we can improve the operation of the Website and the offer presented by it.
  3. Google Analytics uses so-called “cookies”, text files which are stored on your computer and enable analysis of your use of the website. The information generated by the cookie about your use of our website is usually transmitted to a Google server in the USA and stored there. On behalf of the owner of this website, Google uses this information to analyse your use of the website, to compile reports on website activity and to provide further services relating to website and internet usage to the website owner. The IP address transmitted by your browser within the scope of Google Analytics is not collated by Google with other data.
  4. If you do not wish your data to be collected by Google in the aforementioned manner and processed by Google, simply download and install the appropriate browser plug-in, available at the following link: tools.google.com/dlpage/gaoptout, however such a plug-in may impair the functionality of the Website. 
  5. The legal basis for the use of Google Analytics is Article 6(1) sentence 1(f) of the DPA.
  6. External supplier information: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, fax: +353 (1) 436 1001. Terms of use: www.google.com/analytics/terms/de.html, data protection information: www.google.com/intl/de/analytics/learn/privacy.html, and data protection statement: www.google.de/intl/de/policies/privacy.
  7. Personal data may̨ be communicated (entrusted) to the following categories of recipients: entities providing the controller with the services necessary for the above-mentioned purposes, including IT partners, entities providing technical or organisational support, other subcontractors for User support, marketing, entities authorised by law. 
  8. For any doubts regarding personal data, please contact: [email address………….] or in writing to the address: Develtio […………address].

 

VI. Data Owners’ Rights

  1. You have the right to access the content of your data and the right to correct, delete, limit processing, the right to data portability, the right to object, the right to withdraw consent at any time without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal.
  2. Consent can be withdrawn by sending an email to [email address] from the address to which the consent applies.
  3. To the extent that your data is processed on the basis of Develtio’s legitimate interest, you have the right to object to their processing due to your particular situation.
  4. You have the right to data portability, i.e., the right to receive your personal data from Develtio in a structured, commonly used, machine-readable format.
  5. You also have the right to lodge a complaint with the President of the Personal Data Protection Office if you believe that the processing of your personal data violates the provisions of the General Data Protection Regulation of April 27, 2016.

 

VII. Legal Basis for Data Processing

  1. Develtio processes your data based on legal grounds in accordance with applicable law.
  2. The legal basis for processing data for the purpose of providing services to Develtio’s Clients is an appropriate contract or consent.
  3. Develtio must use the data left by users in the contact form to establish contact and present a commercial offer.
  4. The legal basis for statistical measurements and Develtio’s own marketing is the legitimate interest of the administrator according to art. 6 par. 1 lit. F GDPR.
  5. The legal basis for processing personal data for purposes other than those mentioned above is a separate voluntary consent of its owner.

 

VIII. Profiling

  1. Profiling is the automated processing of your data for analytics and advertising purposes. Each data owner has the right to object to profiling.
  2. Profiled ads allow you to avoid most random ads (displayed on websites you visit), and are shown in those that are tailored to individual expectations. The profiling used by Develtio is largely limited to gender, age, and preferences related to Develtio’s activity. Thanks to it, the advertisement seen by you will resemble a proposal tailored to individual needs. Objecting to profiling will result in ads being displayed randomly, regardless of preferences.
  3. Information contained in system logs may contain various data, e.g., IP address. The user consents to their use only for technical purposes and for collecting general, statistical demographic information, as well as for determining the user’s location.
  4. The Develtio website uses cookies, i.e., text files stored on the user’s computer, identifying them in a way necessary to enable some operations. Cookies are used for:
    • Adjusting the content of pages to user preferences and optimizing the use of the website; in particular, these files allow recognizing the user’s device and displaying the page adapted to their individual needs;
    • Collecting statistics informing about how users use websites, which allows improving their structure and content;
    • Maintaining the user’s session after logging in, thanks to which the user does not have to re-enter their login and password on each subpage;
    • Tailoring ad content to user interests (including, e.g., recently viewed articles, articles similar to those purchased, news, etc.).
  5. The following types of cookies are used on the Develtio website:
    • “Essential” cookies, allowing the use of services available within the Develtio website, e.g., authentication cookies used for services requiring authentication within the Develtio website;
    • Cookies for ensuring security, e.g., used to detect abuse in the field of authentication within the Develtio website;
    • “Performance” cookies, allowing the collection of information about how websites are used within the Develtio website;
    • “Functional” cookies, allowing the user’s selected settings to be “remembered” and the user interface to be personalized, e.g., in terms of the selected language or the region from which the user comes, the font size, the appearance of the website, etc.;
    • “Advertising” cookies, allowing the delivery of advertising content more tailored to user interests.
  6. Limiting the use of cookies may affect some functionalities available on the Develtio website.