Privacy Policy

 

The following Privacy Policy sets out the rules for saving and accessing data on Users‘ Devices using the Website for the purpose of providing electronic services by the Administrator and the rules for collecting and processing Users’ personal data that have been provided by them personally and voluntarily through the tools available on the Website.

 

§1 Definitions

 

    • Website – the “mindgram.com” website operating at https://mindgram.com.
    • External website – websites of partners, service providers or recipients cooperating with the Administrator.
    • Website / Data Administrator – the Website Administrator and the Data Administrator (hereinafter referred to as the Administrator) is the company “Mindgram Sp. z o.o.”, operating at the address: Aleje Jerozolimskie 93, with the tax number (NIP): 5223196770, and the KRS number: 0000881002, providing services electronically via the Website.  
    • User – a natural person for whom the Administrator provides services electronically via the Website.
    • Device – an electronic device with software through which the User gains access to the Website.
    • Cookies – text data collected in the form of files placed on the User’s Device.
    • 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 (General Data Protection Regulation).
    • Personal data – means any information relating to an identified or identifiable natural person (‘data subject’); 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.
    • Processing – means an operation or set of operations performed on personal data or sets of personal data in an automated or non-automated manner, such as collecting, recording, organizing, storing, adapting or modifying, downloading, viewing, using, disclosing through transfer, distributing or any kind of sharing, matching or combining, limiting, deleting or destroying.
    • Restriction of processing – means the marking of stored personal data with the aim of limiting their processing in the future.
    • Profiling – means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements.
    • Consent – any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
    • Personal data breach – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
    • Pseudonymisation – means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
    • Anonymization – data anonymization is an irreversible process of data operations that destroys / overwrites “personal data”, making it impossible to identify or associate a given record with a specific user or natural person.

 

§2 Data Protection Inspector

 

Pursuant to Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

In matters relating to the processing of data, including personal data, please contact the Administrator directly.

 

§3 Types of Cookies

 

    • Internal Cookies – files uploaded and read from the User’s Device by the Website’s ICT system.
    • External Cookies – files placed and read from the User’s Device by the ICT systems of external websites. The scripts of external websites that may place cookies on the User’s Devices have been consciously placed on the Website through scripts and services made available and installed on the Website.
    • Session Cookies – files placed and read from the User’s Device by the Website during one session of a given Device. After the session ends, the files are removed from the User’s Device.
    • Persistent cookies – files uploaded and read from the User’s Device by the Website until they are manually deleted. Files are not deleted automatically after the end of the Device session, unless the User’s Device configuration is set to the Cookie deletion mode after the end of the Device session.

 

§4 Data storage security

 

    • Mechanisms for storing and reading Cookie files – mechanisms for storing, reading and exchanging data between Cookies saved on the User’s Device and the Website are implemented through the built-in mechanisms of web browsers and do not allow the collection of other data from the User’s Device or data of other websites visited by the User, including personal data or confidential information. It is also practically impossible to transfer viruses, Trojans and other worms to the User’s Device.
    • Internal cookies – cookie files used by the Administrator are safe for Users’ Devices and do not contain scripts, content or information that may threaten the security of personal data or the security of the Device used by the User.
    • External cookies – the Administrator takes all possible actions to verify and select website partners in the context of Users’ safety. The Administrator selects well-known, large partners with global social trust for cooperation. However, it does not have full control over the content of Cookie files from external partners. The Administrator is not responsible for the security of Cookie files, their content and the use in accordance with the license by the Scripts installed on the website, coming from external websites, to the extent permitted by law. The list of partners is provided further in the Privacy Policy.
    • Cookie control
    • Risks on the part of the User – the Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Administrator is not responsible for intercepting this data, impersonating the User’s session or removing them as a result of the User’s conscious or unconscious activity, viruses, Trojan horses and other spyware that may or may have been infected with the User’s Device. In order to protect against these threats, users should follow the recommendations of safe use of the network.
    • Storage of personal data – the Administrator ensures that he makes every effort to ensure that the processed personal data entered voluntarily by Users is safe, access to them is limited and carried out in accordance with their intended use and processing purposes. The Administrator also ensures that he makes every effort to protect his data against loss, by using appropriate physical and organizational safeguards.

 

§5 Purposes for which Cookie files are used

 

    • Improving and facilitating access to the Website.
    • Personalization of the Website for Users.
    • Marketing, Remarketing on external websites.
    • Keeping statistics (users, number of visits, types of devices, connection, etc.).
    • Provision of multimedia services.
    • Provision of social networking services.

 

§6 Purposes of personal data processing

 

Personal data voluntarily provided by Users are processed for one of the following purposes:

    • Implementation of electronic services:
      • Services of sharing information about the content posted on the Website on social networks or other websites.
    • Administrator’s communication with Users on matters related to the Website and data protection.
    • Ensuring the Controller’s legitimate interest.

Data about Users collected anonymously and automatically are processed for one of the following purposes:

    • Keeping statistics.
    • Remarketing.
    • Ensuring the legitimate interest of the Administrator.

 

§7 Cookies of external websites

 

The Administrator on the Website uses javascript scripts and web components of partners who may place their own cookies on the User’s Device. Remember that in your browser settings you can decide for yourself about the allowed cookies that can be used by individual websites. Below is a list of partners or their services implemented on the Website that may place cookies:

    • Multimedia services:
    • Social / Combined Services:
      (Registration, Login, content sharing, communication, etc.)

Services provided by third parties are beyond the Controller’s control. These entities may at any time change their terms of service, privacy policy, the purpose of data processing and the methods of using cookies.

 

§8 Types of collected data

 

The Website collects data about Users. Some data is collected automatically and anonymously, and some data is personal data provided voluntarily by Users when subscribing to individual services offered by the Website.

 

Anonymous data collected automatically:

  • IP address.
  • Browser type.
  • Screen resolution.
  • Approximate location.
  • Website subpages opened.
  • Time spent on the relevant subpage of the website.
  • Type of operating system.
  • Address of the previous subpage.
  • Referrer address.
  • Browser language.
  • Internet connection speed.
  • Internet Service Provider.

 

Data collected during registration:

  • Name / surname / nickname.
  • E-mail address.
  • Phone number.
  • IP address (collected automatically).

 

Data collected when subscribing to the Newsletter service:

  • Name / surname / nickname.
  • E-mail address.
  • IP address (collected automatically).

 

Data collected when adding a comment:

  • Name and surname / nickname.
  • E-mail address.
  • Web address.
  • IP address (collected automatically).

 

Part of the data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to the statistical service provider.

 

§9 Access to personal data by third parties

 

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or sold to third parties.

Access to data (most often on the basis of the Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary to run the website, i.e .:

  • Hosting companies that provide hosting or related services to the Administrator.
  • Companies through which the Newsletter service is provided.
  • IT service and support companies that maintain the IT infrastructure.

 

§10 Method of processing personal data

 

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless it has been published as a result of an individual action of the User (e.g. entering a comment or entry), which will make the data available to every visitor to the website.
  • Personal data will not be used for automated decision making (profiling).
  • Personal data will not be sold to third parties.

 

Anonymous data (without personal data) collected automatically:

  • Anonymous data (without personal data) will be transferred outside the European Union.
  • Anonymous data (without personal data) will not be used for automated decision making (profiling).
  • Anonymous data (without personal data) will not be sold to third parties.

 

§11 Legal basis for the processing of personal data

 

The Website collects and processes Users’ data on the basis of:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46 / EC (general regulation on data protection):
    • art. 6 sec. 1 lit. a
      and the data subject has consented to the processing of his personal data for one or more specific purposes.
    • art. 6 sec. 1 lit. b
      processing is necessary for the performance of a contract to which the data subject is party, or to take steps at the request of the data subject prior to entering into a contract.
    • art. 6 sec. 1 lit. f
      processing is necessary for the purposes of the legitimate interests pursued by the administrator or by a third party.
  • Act of 10 May 2018 on the protection of personal data (Journal of Laws of 2018, item 1000).
  • Act of July 16, 2004 Telecommunications Law (Journal of Laws of 2004, No. 171, item 1800).
  • Act of February 4, 1994 on copyright and related rights (Journal of Laws of 1994, No. 24, item 83).

 

§12 The period of personal data processing

 

Personal data provided voluntarily by Users:

As a rule, the indicated personal data is stored only for the period of providing the Service on the Website by the Administrator. They are deleted or anonymized within 30 days from the end of the provision of services (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.).

The exception is the situation that requires securing the legitimate purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time the User requests their removal, no longer than for a period of 3 years in the event of a breach or suspected breach of the provisions of the website regulations by the User.

 

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, are stored by the Administrator in order to keep website statistics for an indefinite period.

 

§13 Users’ rights related to the processing of personal data

 

The website collects and processes Users’ data on the basis of:

    • The right to access personal data.
      Users have the right to access their personal data, carried out at the request submitted to the Administrator.
    • The right to rectify personal data.
      Users have the right to request the Administrator to immediately correct personal data that is incorrect and / or supplement incomplete personal data, carried out at the request submitted to the Administrator.
    • The right to delete personal data.
      Users have the right to request the Administrator to immediately delete personal data, carried out at the request submitted to the Administrator. In the case of User accounts, the deletion of data consists of the anonymization of data enabling User’s identification. The Administrator reserves the right to suspend the execution of the request to delete data in order to protect the legitimate interest of the Administrator (e.g. when the User has violated the Regulations or the data has been obtained as a result of correspondence). In the case of the Newsletter service, the User has the option of removing his personal data by himself using the link in each email sent.
    • The right to limit the processing of personal data.
      Users have the right to limit the processing of personal data in the cases specified in art. 18 GDPR, incl. questioning the correctness of personal data, carried out at the request submitted to the Administrator.
    • The right to transfer personal data.
      Users have the right to obtain from the Administrator personal data regarding the User in a structured, commonly used machine-readable format, implemented at the request submitted to the Administrator.
    • The right to object to the processing of personal data.
      Users have the right to object to the processing of their personal data in the cases specified in art. 21 of the GDPR, implemented at the request of the Administrator.
    • Right to lodge a complaint
      Users have the right to lodge a complaint with the supervisory body dealing with the protection of personal data.

 

§14 Contact to the Administrator

 

The Administrator can be contacted in one of the following ways:

    • Postal address – Mingram Sp. z o. o., Aleje Jerozolimskie 93, Warsaw.
    • E-mail address[email protected]

 

§15 Website requirements

 

    • Restricting the saving and access to Cookie files on the User’s Device may cause some of the Website’s functions to malfunction. 
    • The Administrator does not bear any responsibility for incorrectly functioning functions of the Website if the User restricts in any way the possibility of saving and reading cookie files.

 

§16 External links

 

On the Website – articles, posts, entries or comments of Users, there may be links to external websites with which the Website Owner does not cooperate. These links and the pages or files indicated under them may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for the content outside the Website.

 

§17 Changes to the Privacy Policy

 

    • The Administrator reserves the right to change this Privacy Policy at any time without the need to inform Users about it regarding the use and use of anonymous data or the use of cookies.
    • The Administrator reserves the right to change this Privacy Policy in any way regarding the processing of Personal Data, about which he will inform Users who have user accounts or subscribed to the newsletter service, via e-mail within 7 days of changing the records. By continuing to use the services, you have read and accepted the changes to the Privacy Policy. In the event that the User does not agree with the introduced changes, he is obliged to delete his account from the Website or unsubscribe from the Newsletter service.
    • The changes made to the Privacy Policy will be published on this subpage of the Website.
    • The introduced changes come into force upon their publication.

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