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- This Policy is informative, aimed at maintaining transparency regarding the basis and method of data processing and your rights, and its content is appropriately applicable when you use our Website at the URL address; avra.pl, hereinafter referred to as the ” Website “.
- We take the protection of personal data very seriously. In the case of collecting and using personal data, we make sure that we comply with the GDPR (General Data Protection Regulation), i.e. 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 (OJ UE No L119, 4.5.2016, p.1) and accordingly, other applicable provisions on the protection of personal data.
- We provide detailed information on the processing of personal data by means of additional information clauses, if we believe that it is justified in the given process of personal data processing. In the following section of the Policy you will find information related to the use of the Website, on the type of data, the purpose of their processing and the functionality of the use of which they are collected.
- In case of doubts or contradictions between the Policy and the content of the additional information clause provided by us in a specific case, the data subject should follow the information received under the information clause. Regardless of the Policy, the basis of our activities in the data processing are always the relevant provisions of law in force in the territory of the Republic of Poland.
How to contact the personal data administrator and the DPO??
5. The administrator of personal data, i.e. the entity deciding about the purposes and methods of processing your personal data, is Avra Sp. z o. o. based in Wrocław, ul. Marii Skłodowskiej-Cuire 12 floor IV, 50-381 Wrocław, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Wrocław-Fabryczna, 6th Commercial Division of the National Court Register under KRS number: 0000522815, NIP: 8982208679 (hereinafter also Avra).
6. The electronic address of our Data Protection Officer: IOD (at) avra.pl
postal address: ul. Marii Skłodowskiej-Curie 12 floor 4 with the annotation Data Protection Officer
Contact the above address if you have questions or doubts related to the processing of your personal data by the Administrator in connection with the use of the Website, as well as if you wish to submit a request to exercise your rights related to it.
7. Under GDPR, you have:
-the right to request access to the content of your personal data, including obtaining the data copy,
-the right to request correction of data
-the right to demand the deletion of data (so-called right to be forgotten),
-the right to demand limitation of data processing,
-the right to request data transfer (in case of processing the data under contract or consent,
-the right to object (against the processing of your personal data, against direct marketing, profiling, against processing carried out on the basis of the legitimate interest of the Administrator),
-the right to lodge a complaint to the supervisory authority for the protection of personal data (In Poland it is the President of the Personal Data Protection Office),
-If your data is processed under consent – you have the right to withdraw it (which does not affect the lawfulness of processing based on consent before its withdrawal).
General information on the processing of Personal Data
8. In connection with the possibility of using Website, we have defined the following Personal Data processing situations for the period necessary to achieve the purpose indicated below.
8.1. Contact with Avra . On our Website you will find Contact form , the use of which requires the voluntary provision of the subject and content of the message as well as an e-mail address, without which you will not start electronic correspondence with us. In this case, the primary purpose of processing your data is to read the correspondence received and provide answers where necessary. The legal basis for processing is Article 6(1)(f) of GDPR, i.e. the legitimate interest of the Administrator.
If the inquiry sent is related with the need of preparing an offer in accordance with your needs or with providing you with information about us and our scope of services, we act within the legitimate interest of the Administrator, which is self-marketing of our services, especially regarding building and developing relationships with our clients and striving to sell our services.
Depending on the content of the correspondence, we take action on your request before concluding a possible contract with us, and the legal basis for such processing is art. 6 sec. 1 letter b) of GDPR (e.g. sending a tailored offer of our services, performing other activities aimed at concluding a contract).
For the purposes of verification and protection against the use of the form by automatic tools (so-called Bots), the functionality of Contact Form uses an external ReCaptcha tool. For more information, see the subsequent parts of the Policy.
Depending on the case in which we communicate, we process your Personal Data for the period necessary to conduct correspondence with you and later for a maximum period of 24 months or for the period of establishing, defending, investigating or limiting any claims arising from such correspondence or for the duration of any possible claims in accordance with applicable regulations.
When using the Contact Form, you can additionally consent to the processing of the data provided therein for the purpose specified in the content of such consent. In this case, the basis for processing your Personal Data for a specific purpose is your consent (Article 6(1)(a) of the GDPR).
The above information remains relevant when you contact our e-mail address provided on the Website, skipping the Contact Form.
8.2. Recruitment. On our Website , we provide a form for submitting your application for a specific position and an e-mail address intended for handling applications. Using the form, you can voluntarily provide your name, surname, a few words about yourself, e-mail address. You can also attach a CV file. Providing your data is voluntary, although to the extent necessary it is required to take into account your application in the course of recruitment and to provide you with feedback (contact with you). Detailed information on the processing of Personal Data, including the processing period for the purposes related to the recruitment process, is provided in additional information clause for a job candidate. Your personal data will be processed in subsequent recruitment processes, provided you consent to it.
8.3. Other purposes resulting from your consent. If you give us your consent to process your personal data, the legal basis for their processing is Article 6(1)(a) of GDPR. Processing takes place for the period necessary to achieve the purpose covered by the consent, no longer than until you withdraw it or until its restriction or other actions on your part limiting this consent.
8.4. – Administration and management of the Website, including security and its systems, applications;
– monitoring and analyzing the Website traffic and making statistical measurements;
– using external internet tools on the Website.
The above cases include the legitimate interest of the administrator (Article 6 (1)(f) of the GDPR) and relate to the automatic collection and partly saving of information about you in cookies (or other similar technologies). In addition to cookies, we can also automatically collect data normally collected by internet system administrators as part of the so-called logs or log files. The information contained in the logs may include, among others the Website visitor’s IP address, location, type of platform / end device (e.g. mobile device) and web browser, internet provider and the address of the Website from which the visitor accessed our Website.
The Website uses the Google Analytics web analysis system which uses the cookie files system. More information on this subject in the subsequent part of the Policy.
Using external tools indicated in the further part of the Policy, we use the collected data in order to keep traffic statistics on our Website, including the number and duration of visits to our Website, transitions between subpages, counting repeat visits to the Website, etc. More about this in the subsequent part of the Policy.
The information collected in the way mentioned above is used to evaluate the use of the Website and improve the quality of its functioning. We do not combine it with personal data provided in a non-automated way by the Website user (e.g. via the contact form).
Other information on processing your Personal Data
9. Personal data will not be processed in an automated manner (including profiling) in such a way that as a result of such automated processing any decisions would be made, other legal effects would be caused or it would have a significant impact on the data subject using the Website.
10. If the basis for data processing is the legitimate interest of the administrator, the processing of personal data takes place no longer than it is necessary for its implementation or until you submit an effective objection.
11. Data Recipients. We may transfer (share) personal data to entities such as: entities providing and servicing IT systems or solutions (IT service providers, hosting, marketing and analytical tools), entities supporting us in the operation, development and maintenance of the Website, as well as our legal advisors . If we receive a request for rectification, deletion or limitation of the processing of personal data, we will inform the recipients of these data to whom the personal data has been disclosed, unless it turns out to be impossible or will require a disproportionate effort, and we will inform you about these recipients on your request regarding your personal data.
12. On the basis of applicable law, your data may be shared with entities authorized to obtain it (e.g. law enforcement authorities). Before we provide data to entities processing personal data on behalf of the Administrator (e.g. our subcontractors, IT service providers), we sign agreements with such entities entrusting the processing of personal data, requiring them to maintain confidentiality and security measures and personal data protection, and the processing of personal data takes place in accordance with our processing instructions.
13. We do not intend to transfer personal data to third countries – to entities based outside the European Economic Area (EEA).
General information about the Website and its operation
14. The Website, which is our corporate Website, was built using WordPress. The Website is operated by OVH servers. Additional information on the protection of data stored in the OVH infrastructure can be found directly on the Website https://www.ovh.pl/ochrona-danych-osobowych/bezpieczenstwo.xml .
15. Minimum measures used to protect data:
15.1. Technical measures:
– SSL – Each subpage of the Website is available using an encrypted connection between the user’s browser and the server on which the page is placed. The encrypted connection on the Website is induced.
– Access to data – Only designated persons have access to the collected information and the access requires using the login and password.
– Access to information in external tools – Only designated persons have access to information stored in external tools and the access requires using the login and password.
15.2. Organisational measures
– Each of the persons with access to the collected data was informed about the need to keep this data secret.
External Tools on the Website
17. We use the following tools:
17.1. Tracking and analytical tools: Google Analytics – We use the Google Analytics tool on the Website to keep statistics (including the number and duration of visits to our Website, transitions between individual subpages, re-visits to our Website, etc.). The Google Analytics tool can be used and is used on every subpage of the Website.
Security & Privacy Detailed information on the security and privacy of data used in connection with the use of Google Analytics can be found on on this page . https://support.google.com/analytics/answer/2838718
The right to block. If you do not want us to track your behavior on our Website using Google Analytics, you can block it at any time using a tool provided by Google. Read more about how to use it. https://support.google.com/analytics/answer/181881 https://support.google.com/analytics/answer/181881
Appendix No. 1 – Cookies and other similar technologies
- You can block cookies from our Website at any time directly in your browser settings. Failure to do so constitutes consent to their use. The additional external tools we use can use their own additional cookie files.
- The cookies we use are shown in the table below:
Cookie files / system
Supplier / Trusted partner
Automatic collection of information about your computer when you visit the Website. Purpose: Creating statistics and conducting analyzes to optimize the Website.
Google Ireland Limited