The Controller of personal data is Academy47 Sp. z o.o. with its registered office in Warsaw, ul. Krucza 50, 00-025 Warszawa, entered in the register of businesses held by the District Court for the capital city of Warsaw in Warsaw, 12th Economic Division of the National Court Register under KRS number: 0000927172
, represented by Ewa Wysocka – the President of the Management Board, (hereinafter referred to as “the Controller” or “Academy47). Contact with the Controller is possible by post to the above address of the Controller’s registered office or by e-mail: firstname.lastname@example.orgII. Data processing
In connection with its business activity, the Controller collects and processes personal data, making every effort to ensure that the processed personal data is adequately secured. Data is collected directly from data subjects, can be obtained from the person or entity that applied for your participation in training, can be obtained from online resources, including social networks, in which you have independently posted your professional profiles and publicly available registers subject to applicable law, in particular, the 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 (“the GDPR”).III. Purposes and legal basis for data processing and the range of data
The legal basis for personal data processing is defined in Article 6 of the GDPR which governs general rules on the compliance of the personal data processing. In any case, the Controller shall process the data relevant to a given case and for the purpose for which it was collected, ensuring its appropriate protection.
The controller processes the personal data for the purposes related to the conducted business activity in particular in order to:
- establish contact with you, if you want to use our services or products, receive information about them or ask us a question and you provide Academy47 with your personal data by means of contact forms available on our websites pursuant to Article 6 (1) point f of the GDPR, i.e. the Controller's legitimate interest which is in providing answers to the question asked, sending an offer about product and services or undertaking activities aimed at concluding an agreement when you consider purchasing services offered by Academy47.
- marketing, promote and advertise activities, products, and own services offered by Academy47 by sending commercial information by means of electronic communication to the e-mail address provided, in the case of persons who have given their consent based on the consent and no longer than until they withdraw their consent;
- send the newsletter from Training Platform, the website www.academy47.com, provided that you subscribe to the newsletter, pursuant to art. 6 sec. 1 lit. b) GDPR and no longer than until you unsubscribe from the newsletter service;
- marketing, promote and advertise activities, products, and services offered by our business partners, i.e. Tribe47 Sp. z o.o. with its registered office in Warsaw and Talent47 Sp. z o.o. with its registered office in Warsaw by sending commercial information also newsletters by means of electronic communication to the e-mail address provided, in the case of persons who have given their consent based on the consent and no longer than until they withdraw their consent;
- conclude and properly perform the agreement for the provision of services concluded between Us and to handle complaints - on the basis of Article 6 (1) (b) of the GDPR and not further than until the expiry of those agreements;
- make automated decisions in relation to you in individual cases, including decisions based on profiling - only if you have given your consent to such action, on the basis of Article 6(1)(a) of the GDPR and no longer than until you withdraw your consent;
- ensure security and proper functioning of the Training Platform located at https://academy47.com, which is our justified legal interest - on the basis of Article 6(1)(f) of the GDPR - the Controller's legitimate interest and no longer than for the time necessary to realize the indicated purpose or to object to the processing of data in a situation where the Controller is unable to prove the grounds overriding the rights and freedoms of the person making the objection;
- determine the target groups of advertisements and other activities as a user of the Training Platform using tools to measure the effectiveness of online marketing activities - on the basis of Article 6(1)(f) of the GDPR -the Controller's legitimate interest but no longer than until you raise an objection;
- monitor your activity on https://academy47.com and on Academy47's social media accounts and in order to adapt the content displayed to your needs and to improve the services, for this purpose in some cases, we use profiling - on the basis of Article 6(1)(f) of the GDPR- the Controller's legitimate interest , but no longer than until you raise an objection;
- fulfill legal obligations incumbent on the Controller on the basis of Article 6(1)(c) of the GDPR not longer until these obligations are fulfilled ;
- protect against claims and vindication of possible claims on the basis of Article 6(1)(f) the GDPR - the Controller's legitimate interest not longer than until the expiry of the right to defense or pursuing any claims;
- archival and evidential purposes, in order to secure information that can be used to prove facts - on the basis of Article 6(1)(f) of the GDPR - the Controller's legitimate interest and no longer than for the time necessary to realize the indicated purpose or to object to the processing of data in a situation where the Controller is unable to prove the grounds overriding the rights and freedoms of the person making the objection;
- manage the Controller's Website and the Training Platform user accounts - on the basis of Article 6(1)(f)GDPR - the Controller's legitimate interest and no longer than for the time necessary to realize the indicated purpose or to object to the processing of data in a situation where the Controller is unable to prove the grounds overriding the rights and freedoms of the person making the objection;
- create Users' own databases - on the basis of Article 6(1)(f ) of the GDPR - the Controller's legitimate interest and no longer than for the time necessary to realize the indicated purpose or to object to the processing of data in a situation where the Controller is unable to prove the grounds overriding the rights and freedoms of the person making the objection;
- handle external online payment channels for the Controller's purchased services - on the basis of Article 6(1)(f) of the GDPR - the Controller's legitimate interest and no longer than for the time necessary to realize the indicated purpose or to object to the processing of data in a situation where the Controller is unable to prove the grounds overriding the rights and freedoms of the person making the objection.
Where the processing of your personal data is based on your consent, you have the right to withdraw that consent at any time, but this will not affect the lawfulness of the processing that was carried out on the basis of consent before its withdrawal.
The processing of data to tailor content by Academy 47 to your interests and expectations, including profiling is necessary to ensure that our services are relevant. Failure to collect your personal data for these purposes may prevent us from properly providing our services.
We may process the following range of your personal data: name, surname, email address, IP address, residential address , telephone number, payment details provided by the Orderer or other Training Platform user to create an account on the Training Platform. We may also process orders placed, history of orders placed, complaints, as well as other data that may be additionally voluntarily provided by you and included in surveys completed and sent to the Controller, in particular information about your place of work, specialization, job role, professional experience, professional interests.
IV Requirement to provide data
Providing data in order to provide services is voluntary, however, in the extent to which data is processed in order to perform the contract - the provision of services, providing data is a condition for the conclusion of the contract. In case of failure to provide personal data, the contract may not be concluded.
Giving consent for automated decisions to be taken with regard to you in individual cases, including decisions based on profiling, is voluntary.
Providing some information is also a legal obligation, e.g. necessary to issue an invoice, settle the fees paid.V. Data recipients
In connection with the conducted business activity the Controller discloses the data to bodies of the Controller, employees and associates and in some cases to third parties, in particular, to legal and accounting service providers, couriers and transport companies, providers of IT systems and equipment on the basis of relevant contracts for entrusting the processing of personal data and ensuring by the above-mentioned entities of adequate technical and organizational measures ensuring data protection. We disclose your personal data if requested by authorized public authorities in connection with their legal obligation to perform a public function. We provide data only upon a written, justified request of an authority in an individual case.
We cooperate with entities that do not act solely on our behalf and set the purposes and methods of processing your personal data or non-personal data themselves, for example payment institutions that enable you to make payments for the Service.
The Controller declares that it also uses the platform offered by Stripe Payments Europe, Ltd. which provides some or all of the services from systems located in the United States or other countries.VI. Data processing period
If personal data is collected for the purpose of concluding an agreement , the personal data is stored from the moment of data collecting until the contract termination or contract performance after the moment of its termination. In the case of personal data collection in order to fulfil obligations resulting from the law, the data shall be kept for the period of fulfilling obligations and tasks resulting from individual law provisions. In the case of personal data processing for the purposes of the legitimate Controller’s interests, the data shall be kept for no longer than is necessary to achieve these aims or until a reasoned objection is raised to the processing for such purposes.
In the case of personal data collected on the basis of consent, until the consent is revoked.
If personal data is processed for direct marketing purposes, including profiling until objection is raised .
The period of personal data processing may be extended when the processing is necessary to establish, assert or defend against a possible claim, and after that period only if required by law and to the extent required by law.VII. Rights related to personal data processing
- The provision of personal data by you is voluntary. However, failure to provide personal data will prevent Academy47 from providing services and offering products with regard to the purposes of the processing, or from receiving commercial and marketing information.
- As a data subject, you have the following rights:
- to withdraw consent at any time but the withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal (Article 7 (3) of the GDPR). The consent may be revoked at any time by sending an e-mail to the following address: email@example.com;
- access - to obtain confirmation from the Controller as to whether your personal data are being processed. If your data are processed, you are entitled to access them and obtain the following information: about the purposes of the processing, the categories of personal data, the recipients or categories of recipients to whom the data have been or will be disclosed, the period of data retention or the criteria for their determination, the data subject's right to request rectification, erasure or restriction of personal data processing and to object to such processing (Article 15 of the GDPR);
- to obtain a copy of the data - to obtain a copy of the Data undergoing processing, where the first copy is free of charge, and for subsequent copies the controller may charge a reasonable fee arising from the administrative costs (Article 15(3) of the GDPR)
- to rectification - request rectification of personal data concerning you that is inaccurate or completion of incomplete data (Article 16 of the GDPR ;
- to erasure - to request the erasure of your personal data if the Controller no longer has a legal basis for processing them or the data is no longer necessary for the purposes of the processing (Article 17 of the GDPR)
- to restriction of processing - request to restrict the processing of your personal data (Article 18 of the GDPR) when:
- you question the correctness of the personal data - for a period allowing the Controller to check the correctness of the data,
- the processing is unlawful and you object to the erasure of the data by requesting the restriction of its use,
- Academy47 no longer needs the data, but they are needed to establish, assert or defend claims,
- you have objected to the processing - until it is established whether the Controller's legitimate grounds override the grounds for the objection;
g. to data portability - to receive personal data concerning you that you have provided to Academy47 in a structured, commonly used and machine-readable format and to request that these data are sent to another Data Controller, if the data are processed on the basis of your consent or a concluded agreement and if the data are processed by automated means (Article 20 of the GDPR);
h. to object to the processing of personal data for the legitimate purposes of the Controller, on grounds related to your particular situation, including profiling. The Academy47 shall then assess the existence of valid legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defence of claims. If, according to the assessment, your interests outweigh the interests of the Controller, Academy47 shall be obliged to cease processing the data for these purposes.If personal data are processed for direct marketing purposes on the basis of the Controller's legitimate interest (Article 6 (1) (f) of the GDPR), you have the right to object at any time to the processing of personal data for the purposes of such marketing, including profiling, to the extent which processing is related to such direct marketing and your data will not be processed for these purposes (Article 21 of the GDPR).
VIII. Transfer of your personal data
- In addition, you have the right to lodge a complaint with a supervisory authority. In Poland, since 25 May 2018, the supervisory authority is the President of the Office for Personal Data Protection.
Academy47 uses services (tools) offered by global providers such as Google LLC (address: 1600 Amphitheatre Parkway Mountain View, CA 94043, USA), Google Ireland Limited (address: Gordon House Barrow St Dublin 4, Ireland), Facebook Ireland (address: Facebook Ireland (Hanover Reach 5-7 Hanover Quay, Dublin 2, Ireland) Facebook, Inc. (address; 1601 Willow Road Menlo Park, CA 94025, USA), ActiveCampaign LLC. (address: 1 North Dearborn St 5th Floor, Chicago, IL 60602, USA) based in the USA.
Your personal data may therefore be made available outside the European Economic Area (EEA), in particular to the United States. The above entities warrant that they have implemented an adequate level of protection and appropriate safeguards under the GDPR. An adequate level of protection for the processing of personal data outside the EEA is guaranteed by entering into agreements on data processing based on standard contractual clauses approved by the European Union. If you have any questions about the transfer of data outside the European Economic Area, please contact Us at firstname.lastname@example.org.IX. Form of processing
Your personal data will be profiled and also profiled automatically. Your data will be processed automatically to evaluate some of your information, in particular, to analyze your personal preferences, behaviors, and interests. In addition, when profiling, we take into account statistical data on the behavior on our websites and social media.
Your personal data will be processed automatically, as will the form of its profiling, however, it will not have any legal effect or similar effect on your situation and making decisions. X. COOKIES POLICY
We would also like to inform you that the data contained in the cookies do not allow for the direct identification of an individual. They allow only to identify the device you use. If you do not want any cookies to be stored on your device, you can change this in the settings of your web browser. You can also delete all data stored in the form of cookies.XI. Contact with Academy47 regarding your Personal Data
In matters relating to the processing of personal data, please contact us at the e-mail address email@example.com or in writing to the Controller’s address.XII. Final information
Information about the processing of personal data is updated to conform to the Controller’s business activities.
The Training Platform includes external links leading to external websites or social networking websites such as Youtube, Facebook, Instagram, which does not belong to Academy47. Academy47 does not interfere and is not responsible for the processing of personal data by entities that own these social websites. Persons who use the redirect shall also be bound by the privacy and cookie policies published by controllers of the external websites The Controller is not responsible for the processing of data, including their transfer to others controllers especially by Youtube, Facebook, Instagram, their private policy , personal data security of processing by Youtube, Facebook, Instagram.