Privacy Policy

DEFINITIONS
1. Administrator – LABSEE Robert Borowski, registered at 19-400 Olecko, ul. Zielona 13A, Poland.
2. Personal data – any information relating to an identified or identifiable natural person; an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, 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.
3. Policy – this Privacy Policy.
4. 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.
5. Service – the online service provided by the Administrator at answeo.com.
6. User – any natural person visiting the Service or using one or more of the services or functionalities provided by the Service.
DATA PROCESSING IN CONNECTION WITH USING THE SERVICE
1. In connection with the User’s use of the Service, the Administrator collects data in the scope necessary to provide the services offered, as well as information on the User’s activity within the Service. Detailed rules and goals of processing the User’s personal data collected throughout the use of the Service have been described below.
PURPOSES AND LEGAL GROUNDS FOR DATA PROCESSING WITHIN THE SERVICE

USING THE SERVICE
1. Personal data of all individuals using the service (including the IP address and other identifiers as well as information gathered through cookie files or other similar technologies) who are not registered Users (that is who do not have an account within the Service) is processed by the Administrator:
  1. for the purpose of providing services by electronic means in the area of granting Users access to the Service content as well as to contact forms - whereby the legal grounds are provided by the necessity of processing 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)(b) GDPR);
  2. for the purpose of handling complaints w celu obsługi reklamacji - whereby the legal grounds are provided by the necessity of processing 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)(b) GDPR);
  3. for analytical and statistical purposes - whereby the legal grounds are provided by the legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR), consisting in carrying out User activity and preference analysis with the goal of improving the quality of provided services and functionalities used;
  4. for the purpose of determining and pursuing potential claims or defending oneself against them – whereby the legal grounds are provided by the legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR), consisting in protecting the Administrator’s rights;
  5. for marketing purposes of the Administrator and third parties, in particular those engaging in behavioral advertising - the rules for processing personal data for marketing purposes have been described in the section “MARKETING”;
The User’s activity within the Service, including the User’s personal data, is recorded in system logs (a special computer program dedicated to storing chronological records containing information on events and activities concerning the information system used for providing services by the Administrator). Information collected in the logs is processed in connection with the services provided. In addition, the Administrator processes data for technical purposes - in particular, data may be temporarily stored and processed in order to ensure the security and correct functioning of the information systems, e.g. in connection to creating backup copies, testing changes in the information systems, detecting irregularities or providing protection against misuse and attacks.
REGISTRATION IN THE SERVICE
1. Individuals who register in the System are asked to provide personal data necessary for account creation and maintenance. In order to facilitate account maintenance, the User may provide additional data, thereby consenting to its processing. This data may be deleted at any time. Providing data marked as mandatory is required for account creation and maintenance, refusal to provide it results in an inability to create an account. Providing any further data is voluntary.
2. Personal data is processed:
  1. for the purpose of providing services connected to account management and maintenance within the Service – whereby the legal grounds are provided by the necessity of processing 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)(b) GDPR). In the case of optional data, the User’s consent provides the legal grounds for data processing (Article 6(1)(a) GDPR);
  2. for analytical and statistical purposes - whereby the legal grounds are provided by the legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR), consisting in carrying out User activity and preference analysis with the goal of improving the quality of provided services and functionalities used;
  3. for the purpose of determining and pursuing potential claims or defending oneself against them - potential claim determining and w celu ewentualnego ustalenia i dochodzenia roszczeń lub obrony przed nimi – whereby the legal grounds are provided by the legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR), consisting in protecting the Administrator’s rights;
  4. for marketing purposes of the Administrator and third parties, in particular those engaging in behavioral advertising - the rules for processing personal data for marketing purposes have been described in the section “MARKETING”;
3. If the User places any personal data of other individuals (including their name and surname, address, phone number or email address) in the Service, they can do so only on the condition that it does not infringe on applicable laws or the personal rights of those individuals.
SERVICE EXECUTION
1. Service execution by the User involves personal data processing. Providing data marked as mandatory is required for service implementation, refusal to provide it results in inability to execute the service. Providing any further data is voluntary.
2. Personal data is processed:
  1. for the purpose of service execution - whereby the legal grounds are provided by the necessity of processing 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)(b) GDPR). In the case of optional data, the User’s consent provides the legal grounds for data processing (Article 6(1)(a) GDPR);
  2. for the purpose of compliance with the legal obligations placed on the Administrator, in particular those resulting from tax and accountancy regulations - whereby the legal grounds for processing are provided by the necessity for compliance with a legal obligation to which the controller is subject (Article 6(1)(c) GDPR);
  3. for analytical and statistical purposes - whereby the legal grounds are provided by the legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR), consisting in carrying out User activity and shopping preference analysis with the goal of improving the quality of functionalities used;
  4. for the purpose of determining and pursuing potential claims or defending oneself against them - potential claim determining and w celu ewentualnego ustalenia i dochodzenia roszczeń lub obrony przed nimi – whereby the legal grounds are provided by the legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR), consisting in protecting the Administrator’s rights;
CONTACT FORMS
1. The Administrator provides the possibility of contacting them through the use of electronic contact forms. Using the form necessitates providing personal data necessary for contacting the User and answering their question. The User may also provide additional information to facilitate contact or handling of the question. Providing data marked as mandatory is required in order for the question to be received and handled, refusal to provide this data results in an inability to handle the question. Providing any further data is voluntary.
2. Personal data is processed:
  1. for the purpose of identifying the sender and handling the question they submitted through the provided form - whereby the legal grounds are provided by the necessity of processing 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)(b) GDPR);
  2. for analytical and statistical purposes - whereby the legal grounds are provided by the legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR), consisting in keeping statistics of questions submitted by Users through the Service with the goal of improving the quality of its functionality;
MARKETING
1. The Administrator processes Users’ personal data for the purpose of, executing marketing activities, which may include:
  1. displaying marketing content to the User that is not tailored to the User’s preferences (contextual advertising);
  2. displaying marketing content to the User that matches the User’s interests (behavioral advertising);
  3. sending email notifications about interesting offers or content, which may in some cases include trade information;
  4. carrying out other types of activities connected to direct marketing of goods and services (sending trade information through electronic means and telemarketing activities).
2. In some cases, the Administrator may use profiling for the purpose of carrying out marketing activities. This means that, thanks to automatic data processing, the Administrator may evaluate select factors concerning natural persons in order to analyze their behavior or create a forecast for the future.
CONTEXTUAL ADVERTISING
1. The Administrator processes Users’ personal data for marketing purposes, in connection with directing contextual advertising (i.e. advertising not tailored to User preferences) at the Users. The legal grounds are then provided by the legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR);
BEHAVIORAL ADVERTISING
1. The Administrator processes Users’ personal data, including personal data collected through cookie files or other similar technologies, for marketing purposes, in connection with directing behavioral advertising (i.e. advertising tailored to User preferences) at the Users. In this case personal data processing additionally consists in profiling Users. Using personal data collected through the employment of this technology for marketing purposes, especially for promoting goods and services offered by third parties, is then legally grounded on the legitimate interests pursued by the Administrator and takes place only on the condition that the User consented to the use of cookie files. Consent to the use of cookie files can be expressed through configuring the browser accordingly, and can be revoked at any time, in particular by cleaning cookie history and disabling cookies in the browser settings.
2. This consent can be revoked at any time.
DIRECT MARKETING
1. If the User consented to receiving trade information via email, text, and other means of electronic communication, the User’s personal data will be processed in order to send them such information. Thus the legal grounds are provided by the legitimate interests pursued by the Administrator, consisting in mailing marketing information to the extent the User consented to (direct marketing). The User has a right to object to data processing for direct marketing purposes, including profiling. Data will be stored for this purpose for the duration of the existence of the legitimate interest pursued by the Administrator, unless the User objects to receiving marketing information.
SOCIAL MEDIA PROFILES
1. The Administrator processes the personal data of Users visiting the Administrator’s social media profiles. This data is processed solely in connection with managing the profile, including for the purpose of informing Users of the Administrator’s activity and promoting various types of events, services, and products, as well as for communicating with Users through the use of functionalities available on social media platforms. The legal grounds for processing personal data by the Administrator for these purposes are provided by the legitimate interests pursued by the Administrator (Article 6(1)(f) GDPR), consisting in promoting their brand and building and maintaining the community connected to it.
COOKIE FILES AND SIMILAR TECHNOLOGIES
1. Cookie files are small text files installed on the device of the User browsing the Service. Cookies collect information which facilitates the use of the website - e.g. by remembering the User’s previous visits and activity within the Service.
“SERVICE” COOKIES
1. The Administrator uses so-called service cookies mainly for the purpose of providing electronically supplied services to the User as well as improving the quality of those services. Consequently, the Administrator and other entities providing analytical and statistical services in the Administrator’s name, use cookie files, storing information or gaining access to information already stored on the end device of the User (a computer, smartphone, tablet, etc.). Cookie files used for this purpose include:
  1. cookies containing data entered by the User (session ID) for the duration of the session (user input cookies);
  2. cookies used for services which require authentication for the duration of the session (authentication cookies);
  3. cookies used to ensure security, e.g. cookies used to detect authentication abuses (user centric security cookies);
  4. cookies for multimedia players (i.e. flash player cookies), used for the duration of the session (multimedia player session cookies);
  5. permanent cookies used for customizing the User interface for the duration of the session (user interface customization cookies);
  6. cookies used for remembering shopping cart contents for the duration of the session (shopping cart cookies);
  7. cookies used for monitoring website traffic, i.e. for data analysis, including Google Analytics cookies (cookies used by the Google company to analyze how the User uses the Service and to create statistics and reports on the System’s functioning). Google does not use the collected data to identify the User nor does it connect this information for identification purposes. Detailed information on the scope and rules of data collection connected to this service can be found at https://www.google.com/intl/pl/policies/privacy/partners.
“MARKETING” COOKIES
1. In addition, the Administrator also uses cookies for marketing purposes, including in relation to directing behavioral advertising at Users. For this purpose, the Administrator stores information or gains access to information already stored on the end device of the User (a computer, smartphone, tablet, etc.). User consent is required in order to use cookies and the personal data gathered through them for marketing purposes, in particular in the scope of promoting goods and services of third parties. Consent to the use of cookie files can be expressed through configuring the browser accordingly, and can be revoked at any time, in particular by cleaning cookie history and disabling cookies in the browser settings.
PERSONAL DATA PROCESSING DURATION
1. The duration of data processing by the Administrator depends on the type of service provided and the purpose of its processing. As a rule, data is processed for the duration of the service, until consent is revoked or, in cases where the legitimate interests pursued by the Administrator provide the legal grounds for data processing, until an effective objection to data processing is submitted.
2. The data processing duration may be extended in the event that it is necessary for the purpose of determining and pursuing potential claims or defending oneself against them, and thereafter it may only be extended in the cases and scope required by the law. After this period, the processed data is irreversibly deleted or anonymized.
USER RIGHTS
1. Individuals whom the data concerns have the following rights:
  1. The right to information on personal data processing - on this basis the Administrator hands over information on personal data processing to the requesting individual, including above all information on the purposes and legal grounds for processing, the scope of the data kept, the entities to whom the data is revealed, and the planned date of its deletion;
  2. The right to obtain a copy of the data – on this basis the Administrator hands over a copy of the processed data concerning the individual who made the request;
  3. The right of rectification – on this basis the Administrator removes any possible inconsistencies or errors in the personal data processed, and completes or updates it if it is incomplete or was subject to change;
  4. The right to data deletion – on this basis one can request the deletion of data, provided that its processing is not necessary to achieve the goals for which it has been collected;
  5. The right to limit data processing – on this basis the Administrator ceases to perform operations on personal data, with the exception of operations to which the individual whom the data concerns consented, in accordance with the accepted rules of retention or until the reasons for limiting data processing cease to exist (e.g. a supervisory body issues a decision allowing for further data processing);
  6. The right to move data – on this basis, in the scope in which the data is processed in connection with the contract or expressed consent, the Administrator hands over data gathered from the individual whom it concerns, in a format allowing reading it on a computer. It is also possible to demand that the data be handed over to another entity - on the condition that this is within the scope of technical capabilities of both the Administrator and the aforementioned entity;
  7. The right to object to data processing for marketing services – the individual whom the data concerns may at any time object to having their personal data processed for marketing purposes, without the need to justify this objection;
  8. The right to object to data processing for other purposes – the individual whom the data concerns may at any time object to having their personal data processed in connection with the legitimate interests pursued by the Administrator (e.g. for analytical and statistical purposes or related to goods protection). Objections in this scope should include a justification and are subject to evaluation by the Administrator;
  9. The right to withdraw consent – if the data is processed on the basis of consent given by the individual whom it concerns, then the individual has the right to withdraw this consent at any time, which, however, does not affect the legality of data processing carried out prior to the withdrawal of consent;
  10. The right to submit complaints – if it is determined that the personal data processing is in violation of the GDPR or any other regulations concerning personal data protection, the individual whom the data concerns may submit a complaint to the President of the Personal Data Protection Office.
2. Requests regarding the implementation of data subjects’ rights may be submitted by sending an email to the address provided in the section “CONTACT DETAILS”.
3. Submitted requests should, to the extent possible, specify what the request concerns, i.e. in particular:
  1. which right does the person submitting the claim want to exercise (e.g. the right to obtain a copy of the data, the right to data deletion, etc.);
  2. which data processing process does the request concern (e.g. using a particular service, activity in a specified online service, receiving newsletter containing trade information to a given email address, etc.);
  3. which data processing purposes does the request concern (e.g. marketing purposes, analytical purposes, etc.).
4. If the Administrator is unable to determine the content of the request or identify its sender on the basis of the request received, they will contact the requester for additional information.
5. Requests will be answered up to a month from receiving the request. If the need for an extension arises, the Administrator will inform the requester of the reasons for this delay.
6. The response will be sent to the email address from which the request was submitted.
DATA RECIPIENTS
1. In connection with service provision, personal data will be revealed to third parties, including in particular suppliers responsible for information systems maintenance, entities such as banks and payment service providers, entities offering accounting, legal, auditing and consulting services, marketing agencies (in the scope of marketing services), as well as partners and entities connected to the Administrator, for the purpose and in the scope necessary for correct and adequate provision of the service.
2. Moreover, should the User grant their consent, their data may also be shared with other entities for marketing purposes.
3. The Administrator reserves the right to reveal select User information to the appropriate authorities or third parties, provided they request this information on the appropriate legal basis and in accordance with the provisions in force.
SECURITY OF PERSONAL DATA
1. The Administrator ensures that the data is processed by them in a secure manner - ensuring above all that access is granted only to authorized persons and only to the extent necessary for them to perform their tasks. The Administrator ensures that all operations carried out on personal data are performed by authorized employees and partners.
2. The Administrator takes any actions necessary to ensure that all subcontractors and partner entities can guarantee the application of appropriate security measures in all cases where they are processing personal data on behalf of the Administrator.
CONTACT DETAILS
1. The Administrator may be contacted via email at info@answeo.com.