2. Personal data
2.1 Personal Data Administrator
The administrator of Personal Data is Renata Blicharz running a business under the name Renata Blicharz – Let’s Scrum it at the address: ul. Hieronima Wietora 5/7, 31-067 Kraków, Poland, entered into the Central Register and Information on Economic Activity from: Sep 13, 2022, NIP: 7352812893, REGON: 367169499.
In terms of my profiles in social media, in accordance with the jurisprudence of the Court of Justice of the European Union, I am a joint data controller together with the provider of social networking sites in which I have profiles. Details regarding the processing of personal data by individual social network providers can be found here:
2.3. For what purposes do I process personal data?
There are more than one of these goals. Below is a list of them, along with a more detailed discussion. The respective legal grounds for processing have also been assigned to individual purposes.
- Newsletter support (Article 6(1)(f) of the GDPR)
By subscribing to the newsletter, you must provide the data necessary to receive it specified in the subscription form. Providing data is a condition for receiving the newsletter.
In addition, the mailing system saves your IP number that you used when subscribing to the newsletter, determines your approximate location, the e-mail client you use to handle e-mail and tracks your actions taken in connection with the messages sent to you. Therefore, we also have information about which messages you have opened, in which messages you have clicked on links, etc.
In the mailing system, we can also define, based on various criteria related to your activity, interests or other preferences, specific groups or segments of newsletter recipients that affect what kind of messages you receive as part of the newsletter.
The data provided by you in connection with subscribing to the newsletter is used to operate the newsletter, which is my legally justified interest, which in this case is the implementation of marketing goals.
As for the processing of information that does not come from you and has been collected automatically by the mailing system, we rely in this respect on our legitimate interest in analyzing the behavior of newsletter subscribers in order to optimize mailing activities.
You can unsubscribe from the newsletter at any time by clicking on the dedicated link in each message sent as part of the newsletter, or simply by contacting us.
Unsubscribing from the newsletter does not lead to the removal of your data from the mailing system. The data is stored in the archive for the purpose of possible determination, investigation or defense of claims related to the newsletter, as well as to ensure the possibility of demonstrating that the newsletter activities were conducted in accordance with the law.
All other policies related to the Newsletter can be found in the document Regulations of the Newsletter.
- Contact and correspondence handling (Article 6(1)(f) of the GDPR)
By contacting me via available means of communication, e.g. contact me form, e-mail, social messengers, chats, etc., you naturally provide your personal data contained in the correspondence.
Providing data is a condition for establishing contact.
In addition, the communication system saves your IP number that you used when sending the message.
The data is processed for the purpose of communication, which is my legitimate interest. After the communication is completed, the data is stored in the archive for the purpose of possible determination, investigation or defense of claims related to the conducted communication.
- Creating an archive (Article 6(1)(f) of the GDPR)
For the needs of my business, I can create archives in digital form. The archives contain personal data that I have processed in relation to you, and their scope may vary depending on what data I received and what scope of data is justified in terms of archiving. In this case, I rely on our legitimate interest in ordering and organizing personal data carriers.
- Defending, establishing or pursuing claims (Article 6(1)(f) of the GDPR)
Using my website may give rise to certain claims on your or my side in the future. Therefore, I am entitled to process personal data in order to defend, establish or pursue claims. As part of this purpose, I can process any personal data that is related to a given claim, therefore their scope may vary depending on what the given claim relates to. In this case, I rely on my legitimate interest to protect my interests.
- Creating ad audience groups (Article 6(1)(f) of the GDPR)
Your e-mail address stored in my database may be sent to a specific advertising system (e.g. Facebook Ads, LinkedIN Ads) in order to create a group of ad recipients using this e-mail address.
When using this feature, the email address is hashed before it is sent to the respective system to create a group of recipients.
The e-mail address will be used in the matching process conducted by the respective advertising system.
The advertising system does not share the email address with third parties or other advertisers and deletes the email address immediately after the matching process is completed.
The advertising system implements processes and procedures ensuring the confidentiality and security of the e-mail address and the set of user IDs sent to it, which make up the group of recipients created using the e-mail address, among others, through the use of technical and physical security measures.
Creating a group of advertising recipients using your e-mail address is my legitimate interest, which in this case is the implementation of my marketing goals.
- Social media support (Article 6(1)(f) of the GDPR)
If you follow my profiles on social networks or interact with the content I publish on social media, I naturally see your data that is publicly available on your social profile. I process this data only within a given social network and only for the purpose of operating a given social network, which is my legitimate interest.
If you contact me via private message, you naturally provide me with your personal data contained in the content of the correspondence, in particular your image and name and surname. Your data is processed in this case in order to contact you, and the basis for processing is my legitimate interest.
It may happen that I will be the party initiating contact with you via social media in order to offer cooperation, then your data will be processed in order to search for potential contractors, offer and establish cooperation, which is my legitimate interest.
Messages sent to me via social media are automatically archived through the tools available on individual social media sites and are available to me until you delete them. You can view all the messages exchanged with me in the private messages tab.
Your use of social networking sites is subject to the regulations and privacy policies of the administrators of these websites, and these administrators provide you with services by electronic means, fully independently and independently of me.
- Analysis and statistics using only Anonymous Information (Article 6(1)(f) of the GDPR)
I conduct analytical and statistical activities using tools provided by external suppliers. As part of the analytical tools, I have access only to Anonymous Information. I base the processing of Anonymous Information on a legitimate interest, which consists in creating, viewing and analyzing statistics related to the activity of users on the website in order to draw conclusions allowing for the subsequent optimization of my activities.
From the level of tools, I can only view a set of statistics and information not assigned to specific people.
The IP address transmitted by Google Analytics will not be merged with other data by Google. We use this tool to analyze and regularly improve the use of the website.
You can prevent the storage of cookies by setting your browser software accordingly or by using the appropriate browser plug-in.
Detailed information on third-party tools can be found in the section dedicated to the tools I use.
- Self-marketing using only Anonymous Information (Article 6(1)(f) of the GDPR)
I conduct marketing activities using tools provided by external suppliers. As part of marketing tools, I have access only to Anonymous Information. I base the processing of Anonymous Information on a legitimate interest, which consists in conducting marketing activities based on Anonymous Information and targeting advertisements within external systems based on Anonymous Information, for the purposes of marketing own products and services. From the level of tools, I can only view a set of statistics and information not assigned to specific people.
Detailed information on third-party tools can be found in the section dedicated to the tools I use.
- Providing additional functions using only Anonymous Information (Article 6(1)(f) of the GDPR)
I can embed video or audio players, social widgets, comments module, chat, newsletter forms or other tools provided by third parties on my website. All of these tools process Anonymous Information. I base the processing of Anonymous Information on a legitimate interest, which in this case consists in ensuring the possibility of using additional functions on the website. I do not have access to other information from the tools level, moreover, I do not need this information for anything – Anonymous Information is processed only so that additional functions can work. Detailed information on third-party tools can be found in the section dedicated to the tools I use.
- Fulfillment of obligations related to the protection of personal data (Article 6(1)(c) of the GDPR, Article 6(1)(f) of the GDPR)
As the administrator of personal data, I am obliged to fulfill the obligations related to the protection of personal data. Therefore, I can process your personal data, as long as it is necessary to perform these duties (e.g. when considering your request regarding your personal data). The scope of data depends on what data is needed to fulfill the obligation and prove compliance with the GDPR. In addition, in this case, I also rely on my legitimate interest, which consists in securing the data necessary to demonstrate accountability.
2.4. What information do I have about you?
- e-mail adress,
- IP address,
- data collected in the mailing system
- information visible in social media profiles,
- information contained in correspondence,
- Anonymous Information.
2.5. What is „Anonymous Information”?
I use tools that collect a range of information about you related to the use of my website. This includes in particular the following information • information about the operating system and web browser,
• viewed subpages,
• time spent on the website,
• transitions between individual subpages,
• clicks on individual links,
• mouse movements,
• page scrolling,
• the source from which you come to the website,
• the age range you are in,
• your gender,
• Your approximate location limited to the city.
• Your interests or other preferences based on your online activity.
I am unable to provide you with access to Anonymous Information about you, because I am unable to assign any Anonymous Information to any specific user. From the level of tools collecting Anonymous Information, I have access only to a set of statistics and information not assigned to specific persons.
The processing of Anonymous Information allows you to use the functionalities available on the website. In addition, Anonymous Information is used for analytical, statistical and marketing purposes, such as setting and targeting advertisements.
Anonymous Information is also processed by tool providers on the terms resulting from their regulations and privacy policies. They may be used by these providers to provide and improve services, manage them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, as well as personalize the content and advertising displayed on individual services, sites and applications. Detailed information related to this can be found in the section dedicated to the tools we use.
2.6. Where do I get your personal information from?
In most cases, you pass them on yourself. For example, this happens when you subscribe to the newsletter, contact via e-mail or chat, and use the functionalities available on the website or in external websites (e.g. social networks).
In addition, some information about you may be automatically collected by the tools I use. For details on third-party tools, see the tools used section.
2.7. Is the data safe?
I care about the security of your personal data. I analyzed the risks associated with individual processes of processing your data, and then implemented appropriate security and personal data protection measures. I monitor the condition of the technical infrastructure on an ongoing basis, look at the procedures used, and introduce the necessary improvements.
2.8. How long is your personal data processed?
I process your personal data for as long as it is justified within the given purpose of personal data processing, therefore the processing periods vary depending on the purpose. Remember that the end of the processing of your data for one purpose does not necessarily lead to the complete deletion or destruction of your personal data, because the same set of data may be processed for another purpose, for the period indicated for it. Complete deletion or destruction of data takes place when I complete the implementation of all purposes and in other cases indicated in the GDPR.
Below you will find a description of the processing periods: • Newsletter – data related to the newsletter will be processed for the duration of your use of the newsletter;
• Contact and correspondence handling – data related to correspondence handling will be processed for the duration of the contact between us;
• Archive – data related to the archive will be processed until the information contained in the archive is no longer useful;
• Determination, investigation and defense of claims – data related to claims will be processed until the claims expire, the limitation period for claims may vary in the light of applicable law (e.g. in the case of entrepreneurs it may be 3 years, and in the case of consumers 6 years) ;
• Groups of recipients – data related to groups of recipients will be processed until they become useless or you successfully raise an objection;
• Analysis and statistics – data related to analytics and statistics will be processed until they become useless or you successfully raise an objection;
• Own marketing – data related to own marketing will be processed until it becomes useless or you successfully raise an objection;
• Additional tools – data related to additional tools will be processed until they become useless or you successfully raise an objection;
• Obligations related to the protection of personal data – data related to the protection of personal data will be processed until they become useless, you successfully raise an objection or the limitation period of my responsibility as the administrator of personal data expires.
If I process your personal data on the basis of your consent, you can withdraw such consent at any time: either by your actions or by contacting me using the contact details provided. Remember that withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.
2.9. Who are the recipients of personal data?
I would venture to say that modern business cannot do without services provided by third parties. I also use these services. Some of these services involve the processing of your personal data. External service providers that are involved in the processing of your personal data are: • hosting provider – for the purpose of storing data on the server;
• mailing system provider – for the purposes of using the mailing system;
• provider of a landing page management tool – for the purpose of collecting data via landing pages;
• provider of cloud computing – for the use of cloud solutions;
• accounting office – for the purposes of using accounting services;
• other subcontractors, in particular providers of IT solutions – for the purposes of cooperation with various subcontractors who may have access to your personal data if they provide services related to such access.
If necessary, your data may be made available to a legal adviser or advocate bound by professional secrecy. The need may result from the need to use legal assistance that requires access to your personal data.
In addition, if necessary, your personal data may be made available to entities, authorities or institutions authorized to access data under the law, such as police, security services, courts, prosecutor’s offices.
As far as Anonymous Information is concerned, it is available to providers of tools or plug-ins that collect Anonymous Information. The providers of these tools are independent administrators of the data collected in them and may share this data on the terms set out in their own regulations and privacy policies, which I have no influence on.
2.10. When and how are personal data shared with third parties? Do we transfer data to third countries?
We transfer personal data to others only when permitted by law. In this case, in the relevant contract concluded with a third party, we provide for provisions and security mechanisms to protect data and maintain standards in the field of data protection, confidentiality and security.
In a situation where we transfer personal data, of which we are the administrator, to other entities for the performance of specific activities on our behalf, we conclude a special agreement with such entity. Such agreements are called personal data processing agreements (Article 28 of the GDPR), thanks to which we have control over how and to what extent the entity entrusted with the processing of certain categories of personal data processes this data.
You have certain rights regarding your personal data, and we, as their administrator, are responsible for the implementation of these rights in accordance with applicable law. For any questions and requests regarding the scope and exercise of your rights, you can contact us under the following details:
Renata Blicharz – Let’s Scrum it – e-mail: email@example.com
We will respond to the message we receive from you as soon as we verify your identity.
2.11. Access to personal data
You have the right to access your data that we store as an administrator. You can exercise this right by sending me an e-mail.
- Change of personal data, rectification or deletion
Changes, including updating, rectifying or deleting your personal data that we process, can be made by sending us an e-mail.
You can use the right to delete data, for example, when your data is no longer necessary for the purposes for which it was collected by us or when you withdraw your consent to data processing.
- Withdrawal of consent
In the case of processing personal data on the basis of consent, you can withdraw this consent at any time. We inform you about this almost at any time when collecting consent and we make it possible to withdraw consent as easily as it was granted. To withdraw your consent, please send us an e-mail.
The right to limit the processing or object to the processing of personal data You have the right to limit the processing or object to the processing of your personal data at any time, due to a special situation, unless the processing is required in accordance with the law.
You can object to the processing of your personal data when:
– the processing of personal data takes place on the basis of a legitimate interest or for statistical purposes, and the objection is justified by a specific situation; – personal data is processed for direct marketing purposes, including profiling for this purpose.
In turn, with regard to the request to limit data processing, we would like to inform you that it is due when:
– you question the correctness of personal data – for a period that allows us to check the correctness of this data;
– the processing is unlawful, and you oppose the deletion of personal data, requesting the restriction of their use instead;
– we no longer need personal data for the purposes of processing, but you need them to establish, assert or defend claims;
– you have objected under Art. 21 sec. 1 GDPR against the processing of data by us until we determine whether the legitimate grounds on our part override your grounds for objection.
- Right to data portability
You have the right to transfer the data concerning you and you have the right to transfer this data through us to another administrator if:
– processing is based on consent, pursuant to art. 6 sec. 1 lit. a GDPR or art. 9 sec. 2 lit. a GDPR; or
– processing is based on a contract, pursuant to Art. 6 sec. 1 lit. b GDPR; and
– processing is carried out in an automated manner.
When exercising the right to data portability, you may request that personal data be sent by us directly to another administrator, if technically possible.
The right to data portability may not adversely affect the rights and freedoms of others. If you wish to exercise these rights, please send us an e-mail.
- Any other questions, concerns or complaints
You also have the right to lodge a complaint with the supervisory body, which is the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw.
2.12. Do I use profiling?
I do not make decisions based solely on automated processing, including profiling, which would have legal effects on you or similarly significantly affect you. Yes, I use tools that can take specific actions depending on the information collected as part of tracking mechanisms, but I believe that these actions do not have a significant impact on you, because they do not differentiate your situation as a customer, do not affect the terms of the contract that you can to conclude etc.
Using certain tools, I can, for example, direct personalized advertisements to you based on your previous actions on a given website or suggest products that may interest you. This is the so-called behavioral advertising. I encourage you to deepen your knowledge of behavioral advertising, in particular in terms of privacy issues. Detailed information, along with the ability to manage settings in the field of behavioral advertising, can be found here .
3. Cookie files (cookies)
As indicated in this document, Cookies are used on this website. Therefore, we inform you about the most important elements of cookies, so that the use of our website is clear and understandable for you.
3.1. What are cookies ?
Cookie files (cookies) are small files saved on your electronic device by the websites you visit. Cookies contain various information that is often necessary for the website to function properly. Cookies are encrypted in such a way that unauthorized persons cannot access them. The information collected on the basis of cookies can only be read by us and – for technical reasons – trusted partners whose services we use. Most importantly, cookies cannot run programs or transmit viruses to electronic devices.
Basic cookies – installed if consent has been given using the software settings installed on your electronic device. The basic cookies are technical and analytical.
Technical cookies – they are necessary for the website to function properly.
Cookies are used to: – ensure the proper display of the website – depending on the device you use,
– adapt the content to your choices which are technically important for the operation of the website, e.g. selected language,
– remember whether you have consented to the display of certain content.
Analytical cookies – they are necessary to settle accounts with business partners or measure the effectiveness of marketing activities without identifying personal data and to improve the functioning of the website. They can be used to:
– study traffic statistics on the website and check traffic sources (redirection directions),
– detect various types of abuse, e.g. artificial Internet traffic (bots).
3.3. How long are cookies used?
Session cookies – they remain on your device until you leave the website or turn off the software (web browser). These are primarily technical cookies.
Permanent cookies – they remain on your device for the time specified in the file parameters or until you manually delete them.
3.4. Can I opt out of accepting cookies?
You can always change your browser settings and decline requests to install cookies. However, before you decide to change the settings, please note that cookies serve your convenience when using the website. Disabling cookies may cause the website to be displayed incorrectly in your browser.
3.5. How to disable cookies?
You can delete cookies from your browser at any time and block the possibility of their reinstallation.
Depending on the browser you use, the option to delete or withdraw consent to the installation of cookies may differ. In this case, please refer to the user manual available as part of a given browser on your electronic device.
3.6. List of tools using Cookies
- Google Analytics (publisher: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA) – to create statistics and analyze them for website optimization,
- Google Adwords (publisher: Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA) – to promote the website,
- Facebook Pixel (publisher: Facebook Inc., 1601 S. California Ave. Palo Alto, CA 94304, USA) – to advertise the website on Facebook,
- Mailerlite – Inc., a Delaware corporation at 548 Market St, PMB 98174, San Francisco, CA 94104-5401, United States Infakt, ul. Szlak 49, Kraków 31-153 – in order to manage invoicing.
3.7. For what purposes do I use my own cookies?
Own cookies are used to ensure the proper functioning of individual website mechanisms, such as the correct submission of the form visible on the website, support for newsletter forms, etc. Own cookies also store information about the cookie settings defined by you made from the level of the cookie management mechanism.
3.8. Do I track your behavior on the site?
Yes, I use third-party tools (mentoned in 3.7) that collect information about your activity on the website.
3.9. Do I target you with targeted advertising?
Yes, I use tools from external suppliers, under which I can target ads to specific target groups defined on the basis of various criteria such as age, gender, interests, profession, work, actions previously taken on the website. These tools are described in detail in 3.7.
3.10. How can you manage your privacy?
• browser plug-ins supporting cookie file management, eg Ghostery;
• additional cookie management software;
• incognito mode in the web browser;
• behavioral advertising settings, such as youronlinechoices.com;
• mechanism for managing cookies from my website;
• Google Analytics Opt-out;
• Google Ads Settings;
• Facebook Ads Settings;
• LinkedIN Privacy Settings.
3.11. Is there anything else you should know?
In order to ensure the best possible contact regarding the protection of personal data, we enable contact by letter (by post) or e-mail using the following contact details:
Renata Blicharz – Let’s Scrum it
ul. Wietora 5/7, 31-067 Kraków