Information on personal data processing
Who is the controller of your data
The controller of the personal data processed on the above-mentioned websites is VELO sp. z o.o. with its registered office in Gliwice, ul. Pszczyńska 305 (hereinafter referred to as the Controller, the Company, VELO).
The Controller can be contacted:
- by post, at the above address of the Company
- by e-mail at firstname.lastname@example.org
For what purposes and on what grounds do we process your data?
Purposes of data processing on all of the Controller's websites are as follows:
- providing access to the website of the service - which constitutes the Controller's legitimate interest,
- ensuring safety and efficiency of the service - which constitutes the Controller's legitimate interest,
- marketing of products and services - which constitutes the Controller's legitimate interest,
- in the case of obtaining consent to data processing – data concerned with the consent will be processed in order to demonstrate lawful data processing, which constitutes the Controller's legitimate interest.
Additional information on the purposes and grounds for processing data processed using cookies and similar technologies can be found in the Cookies Policy further in this document.
What rights do you have?
Individuals whose data we process have the following rights:
- The right to access the content of their data and the right to its rectification, restriction of processing and, in certain cases, the right to erasure.
- Where the grounds for processing is consent or the data is processed for the conclusion or performance of a contract, they have the right to data portability.
- Information on how to exercise these rights in cases where the Company controls the data jointly with Facebook Ireland Ltd. are described in Facebook Pixel point.
In the case of users of websites processed for purposes that do not require user authentication, we are not able to identify the data subject on the basis of the data we have. In this case, in order to exercise the above-mentioned rights, you will be required to provide us with additional information allowing us to identify you (in particular, information confirming that you were using the computer with the IP address collected by us at a given time).
- In the case of processing data for marketing purposes, where the legal grounds for the processing is the legitimate interest of the Controller or a third party, you also have the right to object to the processing.
- Where the legal grounds for the processing is the legitimate interest of the Controller, you have the right to object to the processing on the grounds of your particular situation.
- You also have the right to lodge a complaint with the President of the Personal Data Protection Office, as available at https://uodo.gov.pl/.
How long do we will keep your data for?
Your personal data will be stored for a period of time depending on the purposes of the processing:
- when using the website, information such as the IP address, browser version, date and time of connection, website accessed will be stored for one year.
- data based on your consent will be processed until you withdraw your consent. Data on giving and withdrawing consent will be processed for the duration of the claims limitation period,
- data processed for the purpose of establishing, investigating or defending against claims will be processed for a period no longer than the limitation periods in civil and criminal matters established in accordance with the applicable provisions of Polish law,
- data processed using cookies and similar technologies will be processed until the cookie expires - see the Cookies Policy further in this document for details.
- the data storage period may be reduced as a result of your objection or withdrawal of consent.
Automated decision-making, including profiling
Your data will not be used to make decisions towards you that are based solely on automated processing, including profiling, and that produce legal effects towards you, or similarly significantly affect you.
Who will have access to your data?
The Company's websites contain links to websites owned by other parties. While the Company endeavours to link only to sites that represent an equally high standard and respect for privacy, the Company is not responsible for the content or privacy standards of sites that do not belong to the Company.
Data may also be disclosed to entities providing administrative, technical and IT services to the Controller. In particular, to entities administering IT systems, servicing IT equipment, providing transport of documents and electronic media, providing services connected with the destruction of documents and electronic media and entities providing legal services.
Elements of YouTube are embedded in the website of our services - this is an online video portal that allows you to publish videos that other users can view, rate and comment on. The provider of the YouTube service in the European Economic Area and Switzerland is Google Ireland Limited, a company registered and operating under the laws of Ireland (registration number: 368047), with its registered office at: Gordon House, Barrow Street, Dublin 4, Ireland, which is the controller of the data collected by the YouTube service.
Every time a website page with an embedded YouTube element is displayed, the web browser automatically connects to YouTube and is informed which specific subpage of our website the user is visiting. If the user is simultaneously logged in to YouTube or other Google services, YouTube recognises the specific subpage of our website with the YouTube video the user visited. This information is collected by YouTube and Google and associated with the relevant account of this particular user.
YouTube and Google receive information via the embedded YouTube element that the person has visited our website whenever such a person logs on to YouTube at the same time as accessing our website. This is the case regardless of whether the person clicks on the embedded YouTube video or not. If the person does not wish such information to be made available to YouTube and Google, he or she can prevent it by logging out of their YouTube account before opening our website.
In order to display adverts to the appropriate audience, increase sales and measure ad performance, we use the Facebook Pixel on some of our web pages.
By operating the Facebook Pixel mechanism, the platform’s operator Facebook Ireland Ltd. (hereafter referred to as Facebook in this section) has a joint responsibility with VELO in accordance with Article 26 of the GDPR. VELO together with Facebook, have adopted the provisions of the Annex concerning Controllers available at https://www.facebook.com/legal/controller_addendum to define the relevant responsibilities for ensuring compliance with the obligations under the GDPR in respect of Joint Data Processing. By accessing the aforementioned link, you can also view the content of the agreement between Facebook and VELO as the operator of the website. The above attachment is to be regarded as the agreement in accordance with Article 26 of the GDPR concluded between Facebook and VELO as the provider of the site using Facebook Pixel, with joint responsibility.
VELO and Facebook have agreed that VELO is responsible for providing you with this information and that it is Facebook's responsibility to ensure that the rights of data subjects are enforced in accordance with Articles 15-20 of the GDPR as regards the personal data stored by Facebook after joint processing. Our use of Facebook's Pixel data and the purposes for which personal data is collected and transferred in joint processing remain in accordance with the Terms and Conditions available at https://www.facebook.com/legal/terms/businesstools/. For more information about how Facebook processes Personal Data, its legal basis and how data subjects' rights against Facebook can be enforced, as well as the information required by Article 13(1)(a) and (b) of the GDPR regarding data processing by Facebook, please see Facebook's Data Policy at https://www.facebook.com/about/privacy.
Please contact Facebook directly if you have any questions about your rights to information, rectification, deletion, data transfer and the right to object. If we receive such requests, we will pass them on. In this context, we would like to point out that although we are jointly responsible under Article 26 of the GDPR as providers of services using Facebook Pixel, we have no influence on the collection and processing of statistical data. Facebook is solely responsible for such activities.
Google (services: Ads Customer Match, Google Analytics, Google Tag Manager, Google Optimize)
The websites use Ads Customer Match, Google Analytics, Google Tag Manager, Google Optimize developed and provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (hereinafter referred to as Google).
Google uses the information collected by these services to evaluate your use of our websites and to provide us with information about the traffic on our websites. More information can be found at https://policies.google.com/terms and https://policies.google.com/.
We use the above services to analyse data collected through Google's advertising functions for statistical purposes only. Users have the option to disable these settings via the Ads Preference Manager available at https://adssettings.google.pl/.
We also use the data to advertise the website in Google's search results and on third-party websites.
Additional information on the principles of cooperation between Google and VELO for the above services is available at https://privacy.google.com/businesses/processorterms/.
Cookies and similar technologies are used to store personal data, such as the time of access, the location from which it was accessed and the frequency of the Service user's visits to the website in question. Each time a user visits our website, this personal data, including the IP address of the Internet connection used by the person concerned, is sent to Google in the USA. Google may disclose this data to third parties.
The websites are hosted on behalf of VELO by Beyond.pl Sp. z o.o. with registered office at ul. A. Kręglewskiego 11, 61-248 Poznań, Poland. VAT ID: 782-23-24-152
Voluntary data provision
The provision of other data is voluntary, but refusal to provide it may prevent the fulfilment of the purpose of processing for which it is collected.
Transfer of data to a third country or international organisation
Your personal data may be transferred outside the European Economic Area (EEA).
In connection with the use of the Google service, access to the data may be given to Google LLC and its affiliates as stated at https://policies.google.com/privacy. Google LLC processes personal data in the United States. Transfer of data outside the EEA has been secured by standard contractual clauses approved by the European Commission. Additional information is available at https://policies.google.com/privacy/frameworks.
In connection with Facebook services, data may be transferred outside the EEA. Transfer of data outside the EEA has been secured by European Commission approved standard contractual clauses. Additional information is available at https://www.facebook.com/help/566994660333381.
The storage period of log data in relation to the Customer Panel is to be verified by Velo.
1. The Company is the controller of the data processed in connection with the operation of the Facebook and Instagram social media.
2. In operating the social media accounts, the Company uses data provided by Facebook Ireland Ltd, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereinafter referred to as Facebook) such as total page views, user actions on the page, post actions, video views, post reach, comments, shares, replies, geographical areas such as city and country, language, number of likes. Facebook collects and shares this data with the Company.
3. Facebook Ireland Ltd. is jointly liable with the Company in accordance with Article 26 of the GDPR*). Due to the collection of statistical data by Facebook, Facebook has undertaken to assume responsibility for the possibility to collect statistical data in accordance with data protection legislation. The same applies to ensuring the security of this data. For more information on this, as well as information on how data subjects' rights can be exercised, please visit Facebook's website and the relevant information on statistical data at the following link: https://www.facebook.com/legal/terms/page_controller_addendum.
At the link above, you can also read the agreement between Facebook and the Company. In accordance with this agreement, please contact Facebook directly if you have any questions regarding your rights to information, rectification, deletion, data transfer and the right to object. If we receive such requests, we will pass them on.
Despite joint liability under Article 26 of the GDPR*), the Company administering the fan page has no influence on the collection and processing of statistical data. The sole responsibility for such actions lies with Facebook Ireland Ltd.
4. Notwithstanding the joint processing of data for statistical purposes, Facebook is the controller of the data processed for its purposes. The Company, on the other hand, remains the controller of the data processed for marketing purposes, which is its legitimate interest. The legal basis for the use of statistical data and the processing of data for marketing purposes by the Company is Article 6(1)(f) of the GDPR*).
5. Your data will be transferred to:
- Facebook Ireland Ltd,
- Other users of Facebook social media profiles,
- Entities authorised to receive them by law,
- Entities that demonstrate a legitimate interest in receiving the data.
6. Your data will be processed for as long as you maintain your Facebook social media accounts.
7. Your personal data will not be used by the Company to make decisions towards you in an automated manner (i.e. without human involvement), including profiling.
8. You have the right to:
- access your personal data,
- rectification of your personal data - if it is incorrect or incomplete,
- deletion of your personal data or restriction of its processing (in certain cases),
- lodging a complaint with the President of the Personal Data Protection Office.
9. You also have the right to object to the Company to the processing of your personal data due to your particular situation.
10. In connection with Facebook services, data may be transferred outside the EEA. The transfer of data outside the EEA has been secured by European Commission approved standard contractual clauses. Additional information is available at https://www.facebook.com/help/566994660333381
11. Regarding matters concerning the processing of your personal data, you may contact the Company using the contact details provided above
12. Additional information about Facebook's data processing is available at https://www.facebook.com/privacy/explanation
*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