Privacy Policy

 

The following Privacy Policy specifies the rules for saving and accessing data on Users‘ Devices using the Website for the purpose of providing electronic services by the Administrator as well as 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 Administrator / Data Controller – the Website Administrator and the Data Controller (hereinafter referred to as the Administrator) is “Mindgram Sp. z o.o.”, operating at the address: ul. Mazowiecka 9, tax identification number (NIP): 5223196770, and 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 – 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 based on one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
  • Processing – 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 – the marking of stored personal data with the aim of limiting their processing in the future.
  • Profiling – 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. The consent given to the personal data processing can be withdrawn at any time.
  • Personal data breach – a breach of security leading to accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed.
  • Pseudonymisation – 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 – 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 OFFICER

 

The Administrator has appointed a Data Protection Officer who can be contacted via email: [email protected]

In addition, it is possible to contact the Administrator directly:

  • address – Mingram Sp. z o. o., ul. Mazowiecka 9, Warsaw,
  • email address –  [email protected].

 

§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 deliberately placed on the Website by way of 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 Cookies – 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 steps to verify and select website partners in the context of Users’ safety. The Administrator selects for cooperation well-known, large partners with global social trust. However, it does not have full control over the content of Cookies from external partners. The Administrator shall not be liable for the security of Cookies, 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.
  • Cookies control
  • Risks on the part of the User – the Administrator uses all possible technical measures to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Administrator shall not be liable for intercepting this data, impersonating the User’s session or removing them as a result of the User’s actions, deliberate or otherwise, viruses, Trojan horses and other spyware that may infect the User’s Device. In order to protect against these threats, Users should follow the recommendations of safe use of the internet..
  • Storage of personal data – the Controller warrants that it makes every effort to ensure that the processed personal data entered voluntarily by Users are safe, and that access to them is limited and carried out in accordance with their intended use and processing purposes. The Controller also warrants that it makes every effort to protect its data against loss, by using appropriate physical and organizational safeguards.

Restricting saving and access to Cookies on the User’s Device may cause some functions of the Website to malfunction. The Administrator shall not bear liability for the incorrect functioning of the Website if the User, in any way, restricts the possibility to save and read Cookies.

 

 

§5 COOKIES OF EXTERNAL WEBSITES

 

On the Webstie, the Administrator 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.)
    • Instagram
    • LinkedIn
  • Statistics:

Services provided by third parties are beyond the Administrator’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.

 

 

§6 PURPOSE OF COOKIES

 

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

 

 

§7 TYPES OF COLLECTED DATA (EXCLUDING PERSONAL DATA)

 

The Website collects data about Users. Some data are collected automatically and anonymously, while some data are 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.

 

 

§8 TYPE, PURPOSE AND PERIOD OF PERSONAL DATA PROCESSING

 

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

  • Performance of a contract concluded with the User, through the Website, which is the basis for the User’s use of Mindgram’s Platform:
    • Legal basis: Article 6 section 1 letter b) of the GDPR (contract conclusion, performance and termination),
    • Processing period: the period needed for the performance, termination or expiry of the contract,
    • Scope of data processing: e-mail address, first name, last name, company name, other data voluntarily provided by the User in order to use Mindgram’s services;

while the data provision is voluntary, it is necessary in order to conclude and perform the contract concluded with Mindgram,

  • Performance of the contract concluded with the User which is the basis for the User’s use of the Mindgram’s Platform, through the Website:
    • Legal basis: Article 6 sec. 1 lit. a) GDPR (consent to personal data processing to the extent that it is not necessary to perform the concluded contract),
    • Processing period: until the data is deleted or consent is withdrawn, but no longer than the termination or expiry of the contract,
    • Scope of data processing: data voluntarily provided by the User with regard to the use of Mingram’s services,

data provision is voluntary, and the consent to data processing may be withdrawn by the User at any time.

  • Establishing contact, including answering inquiries addressed to the Controller via the contact form and e-mail:
    • Legal basis: Article 6 section 1 letter a) of the GDPR (consent to personal data processing),
    • Processing period: until consent is revoked,
    • Scope of data processing: first name and last name, e-mail address, phone number, company name, role in the company, number of employees, other data voluntarily provided in the message,

the provision of personal data is voluntary, but it is necessary to send an inquiry and obtain an answer from Mindgram, and the consent to personal data processing may be withdrawn at any time,

  • Pursuit of the Controller’s legitimate interests consisting in establishing, pursuing or defending claims that may be raised by the Controller, or which may be raised against the Controller with regard to the concluded contract:
    • Legal basis: Article 6 section 1 letter f) of the GDPR (pursuit of the Controller’s legitimate interests),
    • Processing period: the data are stored until the prescription of the claims resulting from the contract concluded with the Controller, the prescription period is determined by the provisions of the Civil Code Act of 23 April 1964,
    • Data scope: e-mail address, first name, last name, company name, other data voluntarily provided by the User in connection with the use of Mindgram’s services.
  • Pursuit of the Controller’s legitimate interests consisting in conducting marketing and commercial activities with regard to persons with whom the Controller has concluded contracts:
    • Legal basis: Article 6 section 1 letter f) of the GDPR (pursuit of the Controller’s legitimate interests),
    • Processing period: the term of the contract concluded with the Controller,
    • Data scope: e-mail address, first name, last name, company name, other data voluntarily provided by the User in connection with the use of Mindgram’s services
  • Conducting marketing and commercial activities with regard to persons who are not Mindgram’s customer:
    • Legal basis: Article 6 section 1 letter a) of the GDPR (consent to personal data processing),
    • Processing period: until consent is revoked,
    • Data scope: e-mail address, first name, last name, company name, other data provided voluntarily,

providing personal data and consenting to their processing is voluntary, but it is necessary in order to receive marketing and commercial content from Mindgram, and consent to personal data processing may be withdrawn at any time,

  • Pursuit of the Controller’s legitimate interests consisting in running social media profiles (including Facebook, Instagram, LinkedIn), including communication with social media users:
    • Legal basis: Article 6 section 1 letter f) of the GDPR (pursuit of the Controller’s legitimate interests),
    • Processing period: until the end of the activity of a given social media user in the Controller’s social media, or until an objection to data processing is submitted,
    • Data scope: e-mail address, first name, last name, nickname, image, company name, other voluntarily provided data,

 

 

§9 ACCESS TO PERSONAL DATA BY THIRD PARTIES

 

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

 

For the proper provision of services, it is necessary for the Controller to use external providers. The Controller uses only processors providing sufficient guarantees of implementing appropriate technical and organisational measures so that the processing meets the requirements of the GDPR, and ensures that the data protection rights of data subjects are protected.

 

Access to data may be granted to entities responsible for supporting our current activity, including entities providing services, in particular IT services, including software used in the provision of services, technical and organizational solutions, as well as other entities if their services are necessary for the proper provision of Mindgram’s services. Personal data collected by Mindgram could be disclosed to: appropriate state authorities upon their request based on relevant legal provisions, or other persons and entities – in cases specified by legal provisions.

 

Each entity entrusted by Mindgram with personal data processing guarantees an appropriate level of security and confidentiality with regard to personal data processing. The processing entity will process personal data based on a personal data processing outsourcing agreement. Mindgram may transfer personal data to non-EEA countries if any of the above-mentioned entities processes data in a non-EEA country, and only when the European Commission has determined an adequate level of protection, or using contractual clauses approved by the European Commission.

 

 

§10 METHOD OF PERSONAL DATA PROCESSING

 

  • Personal data and anonymous data may be transferred outside the European Union only if it is necessary for the proper provision of Mindgram’s services. 
  • Personal data will not be used for automated decision making (profiling).
  • Personal data will not be sold to third parties.

 

 

§11 USERS’ RIGHTS CONNECTED WITH 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, exercised at the request submitted to the Controller.
  • The right to rectify personal data.
    Users have the right to request the Controller to immediately correct personal data that are incorrect and / or supplement incomplete personal data, exercised at the request submitted to the Controller.
  • The right to delete personal data.
    Users have the right to request the Controller to immediately delete personal data, exercised at the request submitted to the Controller. In the case of User accounts, the deletion of data consists of the anonymisation of data enabling User’s identification. The Controller reserves the right to suspend the execution of the request to delete data in order to protect the legitimate interest of the Controller (e.g. when the User has violated the Regulations or the data have been obtained as a result of correspondence). In the case of the Newsletter service, the User has the option of removing their personal data themselves 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 Article 18 of the GDPR, incl. questioning the correctness of personal data, exercised at the request submitted to the Controller.
  • The right to personal data portability.
    Users have the right to obtain from the Controller personal data regarding the User in a structured, commonly used machine-readable format, exercised at the request submitted to the Controller.
  • 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 Article 21 of the GDPR, exercised at the request submitted to the Controller.
  • Right to lodge a complaint.
    Users have the right to lodge a complaint with the supervisory body dealing with the protection of personal data.

 

 

§12 EXTERNAL LINKS

 

On the Website – in articles, posts, entries or comments of Users – there may be links to external websites with which the Website Administrator 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 shall not be liable for the content found outside the Website.

 

 

§13 AMENDMENTS TO THE PRIVACY POLICY

 

  • The Administrator reserves the right to amend this Privacy Policy at any time without the need to inform Users, in regards to the application and use of anonymous data or the use of cookies.
  • The Administrator reserves the right to amend this Privacy Policy in any way regarding the processing of Personal Data, about which they shall inform Users who have user accounts or subscribed to the newsletter service, via e-mail within 7 days of amending the provisions. Continued use of the services shall be construed as familiarisation with and acceptance of the amendments to the Privacy Policy. In the event that the User does not agree with the amendments made, they shall be obliged to delete their account from the Website or unsubscribe from the Newsletter service.
  • The amendments made to the Privacy Policy will be published on this subpage of the Website.
  • The amendments shall come into force upon their publication.

 

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