PRIVACY POLICY FORNAX DC SP. Z O.O.

  1. DEFINITIONS

Administrator – Fornax DC Sp. z o.o. with its registered office in Warsaw, 45 Domaniewska St., 02-672 Warsaw, entered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register under KRS number: 0001040151, NIP: 9512569914, REGON: 52549916000000.

User – any natural person visiting the Service or using the services or functionalities described in the Policy.

Service – the website operated by the Administrator at: https://fornaxdc.com/

Personal Data – information about an identified or identifiable natural person through one of the factors including device IP, location data, Internet ID and information collected through cookies and other similar technology.

Policy – this Privacy Policy.

RODO – 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.

 

  1. DATA PROCESSING IN CONNECTION WITH THE USE OF THE SERVICE

The Administrator collects data to the extent necessary for the provision of the individual services offered, as well as information on the User’s activity on the Website.

The detailed principles and purposes of the processing of Personal Data collected during the use of the Website by the User are indicated below. The Administrator respects the privacy of the persons whose personal data he processes, including those who visit the Website and use the services provided electronically, and makes every effort to properly secure such data and ensure its confidentiality with regard to the regulations.

 

  1. PURPOSES AND LEGAL BASIS OF DATA PROCESSING 

Personal data of all persons using the Website (including IP address or other identifiers and information collected through cookies or other similar technologies) are processed by the Administrator: 

-for the purpose of providing services electronically in terms of providing Users with access to the content collected on the Website – in which case the legal basis for the processing is the necessity of the processing for the performance of the contract (Article 6(1)(b) RODO); 

-for analytical and statistical purposes – in which case the legal basis of the processing is the Administrator’s legitimate interest (Article 6(1)(f) RODO), consisting of conducting analyses of the Users’ activities, as well as their preferences in order to improve the applied functionalities and provided services; 

-for possible establishment and investigation of claims or defence against claims – the legal basis of the processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO), consisting in the protection of their rights; 

-for marketing purposes of the Administrator and other related entities, in particular related to the presentation of behavioural advertising – the principles of processing of Personal Data for marketing purposes are described below.

User activity on the Website, including his/her Personal Data, are recorded in system logs (a special computer program used for storing a chronological record containing information on events and activities concerning the IT system used for providing services by the Administrator). The information collected in the logs is processed primarily for purposes related to the provision of services. The Administrator also processes them for technical, administrative purposes, for the purposes of ensuring the security of the IT system and the management of this system, as well as for analytical and statistical purposes – in this regard, the legal basis for processing is the Administrator’s legitimate interest (Article 6(1)(f) RODO). 

 

CONTACT FORM

 

Contact with the Administrator is possible via an electronic contact form after providing personal data necessary to contact the User and respond to the enquiry. Additional data provided by the User is not required but facilitates the contact or handling of the enquiry. The data provided can be divided into:

a) mandatory data, the provision of which is required in order to receive and handle the enquiry and the failure to provide such data will result in the impossibility of handling, and

b) voluntary data which facilitate contact with the User or the handling of the enquiry.

If the form is used, personal data will be processed for:

-to handle requests in the contact form for cooperation and to establish possible cooperation – the legal basis for processing is to take action at the request of the data subject prior to the conclusion of a contract (Art. 6(1)(b) RODO); as regards optional data processing, the legal basis for processing is the consent given (Art. 6(1)(a) RODO);

-for the investigation or defence of claims – the legal basis of the processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO) to protect your rights.

 

  1. ADVERTISING

In order to carry out marketing activities, the Administrator processes the Users’ Personal Data in the manner described in this Policy. The Administrator’s processing of the Users’ Personal Data may consist in:

a) displaying marketing content to the User that is not tailored to the User’s preferences (contextual advertising). The Administrator processes the Users’ Personal Data for marketing purposes in connection with directing contextual advertising (i.e. advertising that is not tailored to the User’s preferences) to the Users. The processing of Personal Data is then carried out in connection with the fulfilment of the Administrator’s legitimate interest (Article 6(1)(f) RODO).

b) Displaying marketing content to the User that corresponds to the User’s interests (behavioural advertising). The Administrator and its partners process Personal Data of Users, including Personal Data collected through cookies and other similar technologies, for marketing purposes in connection with targeting Users with behavioural advertising (i.e. advertising that is tailored to the User’s preferences). The processing of Personal Data then also includes profiling of Users. 

 

E_MAIL ADVERTISING WHEN SUBSCRIBING TO THE NEWSLETTER 

Any User may subscribe to the newsletter. In this case, the Administrator will use the data necessary for this purpose or provided to the Administrator separately by the User in order to send the User the newsletter by e-mail on a regular basis on the basis of the consent given.

By subscribing to the newsletter, the User consents to:

– to process his/her personal data for marketing purposes and to receive commercial information electronically at the e-mail address he/she has indicated.

– to receive personalised communications concerning recommended products or services, etc.

– to receive personalised communications concerning discounts on services and products provided.

 

The User may unsubscribe from the newsletter at any time by sending a message with the relevant information or by using the relevant link provided in the newsletter. After unsubscribing, the Administrator will delete the e-mail address, unless the User expressly agrees to further use of the data for other purposes or the Administrator reserves the right to further use the data in legally permitted cases, of which in such a situation the Administrator will inform the User in an appropriate statement.

The newsletter is sent within the scope of entrusting data processing on behalf of the Administrator by a service provider to whom the Administrator transfers the User’s e-mail address for this purpose.

The User’s personal data are made available to external marketing service providers who support the Administrator in the delivery of marketing messages and the implementation of promotional campaigns. 

 

  1. SOCIAL MEDIA

The Administrator processes Personal Data of Users visiting the Administrator’s profiles maintained on social media (Facebook, Instagram, LinkedIn). This data is processed exclusively in connection with the running of the profile, including for the purpose of informing Users about the Administrator’s activities and promoting various events, services and products. The legal basis for the Administrator’s processing of Personal Data for this purpose is its legitimate interest (Article 6(1)(f) RODO) in promoting its own brand.

The above information does not apply to the processing of data by social network administrators (Facebook, Instagram, LinkedIn). For detailed information on this purpose and scope of data collection by social networks, please follow the links below:

Facebook: https://www.facebook.com/policy.php

Instagram: https://help.instagram.com/519522125107875/?maybe_redirect_pol=0

LinkedIn: https://www.linkedin.com/legal/privacy-policy?_l=pl_PL

dedicated to these sites.

 

  1. COOKIES 

Cookies are text files which are placed on the computer by websites visited and stored on the Service User’s terminal equipment. Cookies collect information facilitating the use of the website – e.g. by remembering information about the User e.g. concerning login or language preferences. The administrator of data processed in connection with the use of cookies is Fornax DC Sp. z o.o. The Administrator uses its own files on the Website, which are installed directly by the Website. Third-party cookies – which are cookies from a domain other than the domain of the visited website – are also used, primarily for analytical and advertising activities.

The Website uses cookies primarily to ensure the proper functioning of the website, to remember the User’s choices on the site – and, if the User gives the appropriate consent, also to analyse and track traffic on the Website and to match advertising content to interests. 

The Administrator uses the following cookies on the Website. 

ESSENTIAL COOKIES

The Administrator’s use of essential cookies is necessary for the proper functioning of the Website. These files are installed in particular for the purposes of remembering login sessions or filling in forms, as well as for the purposes of setting privacy options.

The legal basis for the processing of data in connection with the use of essential cookies is the necessity of the processing for the performance of the contract (Article 6(1)(b) of the DPA). 

 

FUNCTIONAL AND ANALYTICAL COOKIES

Functional cookies are used in order to remember and adapt the Website to the User’s choices, inter alia in terms of language preferences. Functional cookies may be installed by the Administrator and its partners through the Website.  

Analytical cookies make it possible to obtain information such as the number of visits and traffic sources on the Website. They are used to determine which pages are more and which are less popular and to understand how Users navigate the Website by keeping statistics on traffic on the Website. The processing is done to improve the performance of the Website. The information collected by these cookies is aggregated and is therefore not intended to establish the identity of the User. Analytical cookies may be installed by the Administrator through the Service. 

The legal basis for the processing of Personal Data in connection with the use of functional and analytical cookies by the Administrator is its legitimate interest (Article 6(1)(f) RODO), consisting in ensuring the quality of the services provided on the Website, in connection with the User’s consent to their storage (separate for analytical cookies, separate for functional cookies). 

The processing of Personal Data in connection with the use of functional and analytical cookies is subject to the User’s consent to the use (separately) of functional and analytical cookies

 

ADVERTISING COOKIES 

Advertising cookies allow the adaptation of the advertising content displayed to the User’s interests within and outside the Website. Based on the information from these cookies and the User’s activity on other services, a profile of the User’s interests is built. Advertising cookies may be installed by the Administrator and its partners through our Service. 

The legal basis for the processing of Personal Data in connection with the use of advertising cookies by the Administrator for this purpose is the Administrator’s legitimate interest (Article 6(1)(f) of the RODO), consisting of promoting the Administrator’s brand and informing about the Administrator’s current offer, including through directing marketing information to Service Users corresponding to their interests, in connection with the User’s consent to the storing of advertising cookies. 

The processing of Personal Data in connection with the use of advertising cookies is possible after obtaining the User’s consent to the use of consent through the consent management platform. This consent can be withdrawn at any time through this platform. 

 

  1. ANALYTICAL AND MARKETING TOOLS USED BY THE ADMINISTRATOR

The Administrator applies various tools used for analytical and marketing purposes such as:

 

GOOGLE ANALYTICS 

 

Google Analytics cookies are cookies used by Google to analyse your use of the Website, to compile statistics and reports on how the Website works. Google does not use the data collected to identify the User, nor does it combine this information to enable identification. Detailed information on the scope and principles of data collection in connection with this service can be found at the following link: https://www.google.com/intl/pl/policies/privacy/partners.

GOOGLE TAG MANAGER

 

Google Tag Manager is a tool for managing scripts on the website. It can be used to install various types of scripts on a website. This includes scripts related to the consents given by the User, scripts that track User behaviour through analytical tools such as Google Analytics, or conversion tracking from advertising systems such as Google Ads. In connection with the use of the tool, Google collects aggregated data on the running of these scripts, without being able to identify a specific User. Detailed information on the scope and principles of data collection in connection with this service can be found at the following link: https://www.google.com/analytics/terms/tag-manager/. 

 

GOOGLE ADS

 

Google Ads is a tool that allows us to measure the effectiveness of advertising campaigns carried out by the Administrator, allowing us to analyse data such as keywords or the number of unique users. The Google Ads platform also allows our ads to be displayed to people who have visited the Website in the past. Information on the processing of data by Google in respect of the above service is available at the following link: https://policies.google.com/technologies/ads?hl=pl.  

 

SOCIAL PLUG-INS

The Service uses social networking plug-ins (Facebook, Instagram, LinkedIn). The plug-ins allow the User to share the content published on the Service with the social network of his/her choice. If the User uses the social network plug-ins available on the Website, the social network in question, receives information about the User’s IP address and browser ID and can assign them to the User’s profile created on the social network in question. The Administrator does not determine the purposes of the processing of the Users’ personal data carried out by the social networks after the data transmission referred to in the previous sentence and has no knowledge of the extent of data processing by the social networks for purposes other than the use of the social plug-in available on the Website. 

 

  1. MANAGEMENT OF COOKIE SETTINGS

Each time the User gives their consent to the use of cookies to collect data through them, including gaining access to the data stored on the User’s device. Consent is collected from the User via the cookie consent management platform. This consent can be withdrawn at any time.

Consent is not required only for cookies whose use is necessary for the provision of the telecommunications service (data transmission to display content) – the User does not have the possibility to opt out of these cookies if he or she wishes to use the Website.

In order to receive advertising tailored to the User’s preferences, in addition to agreeing to the installation of cookies through the cookie consent management platform, it is necessary to maintain appropriate browser settings that allow the storage in the User’s terminal equipment of cookies originating from the Service.

Withdrawal of consent for the collection of cookies on the Website is possible through the platform for managing the consent of cookies. The User can return to the banner by clicking on the button available in the footer of each sub-page of the Website.

Once the banner is displayed, the User can withdraw consent by clicking on the ‘MANAGE COOKIES’ button. Then, move the slider next to the selected category of cookies and press the ‘SAVE SETTINGS AND CLOSE’ button.

 

It is also possible to withdraw your consent to the use of cookies via your browser settings. Detailed information on this can be found under the following links:

Internet Explorer: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies

Mozilla Firefox: http://support.mozilla.org/pl/kb/ciasteczka

Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647

Opera: http://help.opera.com/Windows/12.10/pl/cookies.html

Safari: https://support.apple.com/kb/PH5042?locale=en-GB

The user can at any time verify the status of their current privacy settings for the browser used using the tools available at the following links:

http://www.youronlinechoices.com/pl/twojewybory 

http://optout.aboutads.info/?c=2&lang=EN 

 

  1. PERIOD OF PERSONAL DATA PROCESSING

The period of data processing by the Administrator depends on the type of service provided and the purpose of the processing. As a rule, the data shall be processed for the duration of the service provision or order fulfilment, or the filing of an effective objection to the data processing in cases where the legal basis of the data processing is the legitimate interest of the Administrator. 

The period of data processing may be extended where the processing is necessary for the establishment and assertion of possible claims or the defence against claims, and thereafter only if and to the extent required by law. After the expiry of the processing period, the data shall be irreversibly deleted or anonymised. 

 

  1. USER RIGHTS

The user has the right:

a) to be informed about the processing of personal data – on this basis, the Administrator shall provide the individual making the request with information about the processing of data, including, in particular, the purposes and legal grounds for the processing, the scope of the data held, the entities to which the data are disclosed and the planned date of deletion;

b) to obtain a copy of the data – on this basis the Administrator shall provide a copy of the processed data concerning the individual making the request;

c) to rectification – the Administrator is obliged to remove any inconsistencies or errors in the processed Personal Data and to complete them if they are incomplete;

d) to erasure – on this basis, the erasure of Data whose processing is no longer necessary for the performance of any of the purposes for which they were collected may be requested;

e) to restriction of processing – if such a request is made, the Controller shall cease performing operations on the Personal Data – with the exception of operations to which the Data Subject has given his/her consent – and their storage, in accordance with the retention rules adopted or until the reasons for the restriction of processing cease to exist (e.g. a decision is issued by a supervisory authority authorising further processing);

f) to data portability – on this basis – insofar as the data are processed by automated means in connection with a contract concluded or consent given – the Controller shall issue the data provided by the data subject in a computer-readable format. It is also possible to request that this data be sent to another entity, provided, however, that the technical capacity to do so exists both on the part of the Administrator and the designated entity;

 

g) objection – the User may object to the processing of data for marketing purposes if the processing is carried out in connection with the legitimate interest of the Administrator, and also – for reasons related to the User’s specific situation – in other cases where the legal basis of data processing is the Administrator’s legitimate interest (e.g. in connection with the performance of analytical and statistical purposes);

h) to withdraw consent – if the data are processed on the basis of the consent given, the User has the right to withdraw it at any time, which, however, does not affect the lawfulness of the processing performed before the withdrawal of the consent; 

i) to lodge a complaint – if the processing of Personal Data is considered to be in breach of the provisions of the RODO or other provisions relating to the protection of Personal Data, the User may lodge a complaint with the supervisory authority for the processing of Personal Data having jurisdiction over the Data Subject’s habitual place of residence, place of work or place where the alleged breach has been committed. In Poland, the supervisory authority is the President of the Office for Personal Data Protection.

 

  1. RECIPIENTS OF THE DATA

The Users’ personal data will be disclosed to external entities, including in particular those providing legal and accounting services to the Administrator, the Administrator’s subcontractors providing IT and network maintenance services, payment services to insurance companies, marketing and advertising agencies, providers of analytical and marketing tools and entities related to the Administrator, including companies from its capital group or other entities authorised under legal regulations such as courts, law enforcement agencies or bailiffs. 

The Administrator reserves the right to disclose selected information concerning the User to competent authorities or third parties, who will submit a request for such information in accordance with applicable law and on the basis of the consent granted.

 

  1. CONTACT INFORMATION

Contact with the Administrator is possible via e-mail address: administracja@fornaxdc.com or through the correspondence address: …………………………………………………

 

  1. FINAL PROVISIONS

Any change to the privacy policy, you will be informed of on our pages.

Any correspondence regarding the processing of your personal data should be addressed to the Administrator or to Customer Service at kontakt@fornaxdc.com