Information Note on Data Management
for the Newsletter Service of Develor Polska Sp. z o.o.
This Information Note on Data Management applies to the personal data management related to the Newsletter of Develor Polska Sp. z o.o. (hereinafter referred to as: “Develor”) sent electronically.
The sender of the Newsletter is the free service of Develor (hereinafter referred to as: “Newsletter Service”), and the frequency of sending newsletters is ad-hoc.
The User is a natural person or legal entity who has become auhtorized to use the Newsletter Service by submitting their data. The User acknowledges that subscribing to the newsletter is not a guarantee that all relevant information will be sent to them in the form of a newsletter
After reading this Information Note on Data Management, by registering for the newsletter of Develor and using the service, the User agrees that their personal data will be managed by Develor in accordance with the provisions of this Information Note on Data Management.
PRINCIPLES OF DATA MANAGEMENT
In order to protect and respect the privacy of the User, Develor handles the data management related to the use of the Newsletter Service in accordance with the relevant regulations in force. This Information Note on Data Management has been defined based on the following regulations in force:
- Act CXII of 2011 on the Right of Informational Self-Determination and on Freedom of Information;
- Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities;
- Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services;
- Act VI of 1998 on the Protection of Individuals during the Machine Procession of Personal Data;
- Act CXIX of 1995 on the Use of Name and Address Information Serving the Purposes of Research and Direct Marketing.
Develor only manages the personal data of the User specified in this Information Note on Data Management, in accordance with the principle of purpose limitation, exclusively in the way, for the time and purpose defined in this Information Note on Data Management, and to which the User has given their consent when subscribing for the newsletter.
In order to ensure the security of the personal data provided throughout the data management process, Develor will take all the necessary technical and organisational measures. Develor has all the technical means – specified in Section 7 of Act CXII of 2011 – which protect the data against any unauthorized access, alteration, transmission, disclosure, deletion or destruction, furthermore, accidential destruction and damage.
The terms and expressions used in this Information Note on Data Management shall be interpreted according to the concepts defined in the interpretative provisions of Act CXII of 2011 on Informational Self-determination and Freedom of Information.
THE PURPOSE OF DATA MANAGEMENT
The purpose of data management by Develor related to the Newsletter Service is to send newsletters to the Users registered for this purpose, and to provide information about the company, service, special offers and events of Develor.
THE LEGAL BASIS OF DATA MANAGEMENT
The collection and management of personal data is based on the voluntary consent of the User using the Newsletter Service granted by the User when registering for the newsletter, by filling in the check box.
THE SCOPE OF DATA PROCESSED
The Newsletter Service of Develor is only available after registration, during which the necessary personal data are recorded and managed.
The scope of personal data managed by Develor during the provision of the Newsletter Service is determined by Section 6 of Act XLVIII of 2008 on the Basic Requirements and Certain Restrictions of Commercial Advertising Activities and Act CVIII of 2001 on Certain Issues of Electronic Commerce Services and Information Society Services.
In connection with the Newsletter Service, Develor only managed the name, consent statement and e-mail address of the User, furthermore, the date of their subscription. The User is solely responsible for the authenticity and accuracy of personal data.
Develor does not use the services of any data processor during the operation of the Newsletter Service.
The User shall be authorized to request information from Develor at any time about the User-related personal data managed in connection with the Newsletter Service, at the following mailing address: Al. KEN 98/12, 02-777 Warszawa or at the following electronic address: firstname.lastname@example.org. At the request of the User, Develor will provide information about the User-related personal data managed in connection with the Newsletter Service, the purpose, legal basis, duration of data management, furthermore, the legal basis and addressee of the data transmission. Develor shall provide the information requested by the User in the shortest possible time after the submission of the related request, but within a maximum of 30 days.
AMENDMENT OF THE DATA MANAGED
During the data management, the User shall be authorized at any time to check the content of their data or request their correction, amendment or alteration at any time, at the following mailing address: Al. KEN 98/12, 02-777 Warszawa or at the following electronic address: email@example.com. Develor shall execute the correction, modification or alteration requested by the User in the shortest possible time after the submission of the related request, but within a maximum of 30 days.
The Newsletter Service includes connection points leading to the website of Develor (www.develor.pl). The User acknowledges that during the browsing of the Develor website, technical information are recorded for statistical purposes. (IP-address, duration of the visit, etc.). These data are only transferred by Develor to the authorities in cases credibly justified and supported from legal aspects. The statistical tool used by Develor is Google Analytics. Learn about the data management guidelines of Google Analytics at the following website: http://www.google.com/analytics.
DURATION OF DATA MANAGEMENT
Develor manages the personal data of the User previously provided for senting the newsletter until the User’s consent is withdrawn.
In every newsletter sent out by it, Develor provides an immediate unsubscription possibility to the User in the form of the link indicated at the bottom of the Newsletter, clicking on which shall be regarded as the withdrawal of the consent to data management.
In addition to the above possibility, the User can also indicate their cancellation request related to their own data by an e-mail sent to firstname.lastname@example.org.
Develor will delete the personal data managed for the operation of the Newsletter Service from its system upon termination of the purpose of data management or on the basis of the provision of the User of relevant content, in 10 working days after the receipt of the deletion request and terminate the data management.
Develor will not automatically forward personal data related to the operation of the Newsletter Service to any third persons, and it transfers personal data to third persons exclusively after the prior and informed consenf of the user. This does not apply to the potential data transmissions which are mandatory based on the law.
OBJECTION AGAINST THE MANAGEMENT OF PERSONAL DATA
The rights and remedial opportunities relating to data management and described in this Information Note on Data Management may be exercised by the User after certifying their identity and their relationship with the data.
The User may object to the management of their personal data if:
- the management (forwarding) of personal data is necessary exclusively for the enforcement of the right or legitimate interest of the data controller or data importer, unless data management is prescribed by the law;
- the use or transmission of personal data is performed for the purposes of direct marketing, opinion poll or scientific research; and
- exercising the right of protest is otherwise permitted by the law.
Develor shall be obliged to examine the request in the shortest possible time after its submission but latest in 30 days, and inform the applicant about the result thereof, in writing. If the protest is justified, the data controller shall be obliged to terminate the data management – including also further data collection and data transmission – and block the data, furthermore, he shall inform about the protest and the steps he took based on it, all those to whom he has forwarded personal data concerned by the protest and who are obliged to take action in order to enforce the right to protest. If the request becomes rejected, Develor shall provide a statement of grounds in writing, in the same form in which the protest was submitted.
DATA MANAGEMENT RIGHTS AND REMEDIAL OPPORUTNITIES
If the protest is rejected; if person who submitted it does not agree with the decision brought on the basis of the request, or if Develor fails to keep the deadline available, the person concerned may bring the case to trial – in 30 days after the communication of the decision or the last day of the deadline, under Section 22 of Act CXII of 2011.
THE POSSIBILITY OF MODIFYING THE INFORMATION NOTE ON DATA MANAGEMENT
Develor reserves the right to unilaterally amend this Information Note on Data Management with prior notice to users. By using the service after the amendment enters into force, the User accepts the amended Information Note on Data Management.
DATA RELATED TO THE DATA CONTROLLER
Company name: Develor Polska Sp. z o.o.
Seat – postal address: Al. KEN 98/12, 02-777 Warszawa
VAT number: 525-233-16-09
Company registration number: 0000233469
Language of website: Polish
E-mail address: email@example.com
Telephone: +48 22 887 33 30