effective since 20 March 2020
WHO IS THE CONTROLLER OF THE USER’S PERSONAL DATA?
- The owner of the Website and the controller of the personal data is Cubic Orb sp. z o.o. a limited liability located in Wroclaw, address: 74 Pilsudskiego Street, apt. 320, 50-020 Wroclaw, entered into the register of entrepreneurs held by District Court for Wrocław-Fabryczna, IX Commercial Division under no: 0000761654, tax identification number (NIP): 8842794921, statistical number (REGON): 382009077, share capital in amount of PLN 9,000 (“Cubic Orb”).
WHAT ARE PERSONAL DATA AND WHAT DOES THEIR PROCESSING MEAN?
- Personal data are all information about an identified or identifiable natural person, for instance name and surname, personal identification number, email address, telephone number.
- Processing of the personal data is any activity performed on personal data, for instance their collecting, recording, organizing, structuring, storing, modifying, disseminating and erasing or destructing. Personal data processing may take place by automatic or not automatic means.
WHAT ARE THE RULES WE COMPLY WITH WHEN PROCESSING PERSONAL DATA?
- Cubic Orb respects and complies with the Users’ right to privacy and ensures adequate means of protection of their personal data. One of the most significant rules guiding our business is processing the personal data with the highest standards and in accordance with the applicable law.
- Personal data collected by Cubic Orb through the Website are processed in accordance with 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 (General Data Protection Regulation) (the “GDPR”).
- In the course of personal data processing we apply in particular the following principles:
- lawfulness – taking care to process personal data in compliance with legal rules;
- fairness – processing the personal data in a fair manner;
- transparency – informing how the personal data are processed;
- appropriateness – collecting the personal data only in specified, explicit and legitimate purposes and ensuring that they will not be further processed in a manner incompatible with these purposes;
- proportionality – processing the personal data only within the scope adequate and necessary to fulfil our justified purposes;
- accuracy – ensuring that the personal data processed by us are accurate and updating them if necessary;
- limitation of their storage in time – storing the personal data no longer than it is necessary for the purposes for which these data are processed.
- We process personal data in a manner which ensures the adequate level of their security in particular against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures.
WHICH PERSONAL DATA DO WE PROCESS?
- We collected personal data of: (i) natural persons who act for the purposes outside the scope of their commercial or professional activities, (ii) natural persons carrying out the commercial or professional activity in their own name, (iii) natural persons representing legal persons or organizational units (the “Users”).
- Depending on the purpose of the personal data processing, Cubic Orb processes in particular the following categories of personal data: (i) name and surname, (ii) tax identification number, (iii) personal identification number, (iv) email address, (v) telephone number, (vi) IP address, (vii) date of birth, (viii) address of residency, domicile or conducting business activity.
- Cubic Orb does not process sensitive data, that is personal data revealing the User’s racial or ethnical origin, his/her political views, religious or philosophical beliefs, trade union membership, genetic and biometric data, data concerning health, sex life and sexual orientation.
WHAT IS THE AIM AND ON WHICH BASIS DO WE PROCESS PERSONAL DATA?
- We are entitled to process personal data for the following purposes:
- sending an offer or commercial information to the User concerning the goods or services chosen by him/her – on the basis and within the scope of the User’s consent (legal basis: Article 6 paragraph 1 letter a of the GDPR);
- contact with the User for the purpose chosen by him/her in the contact form – on the basis and within the scope of the User’s consent (legal basis: Article 6 paragraph 1 letter a of the GDPR);
- opening the User’s account on the Website – on the basis and within the scope of the User’s consent (legal basis: Article 6 paragraph 1 letter a of the GDPR);
- subscription of the newsletter – on the basis and within the scope of the User’s consent (legal basis: Article 6 paragraph 1 letter a of the GDPR);
- direct marketing of Cubic Orb’s goods and services (including the contact through the phone) – on the basis and within the scope of the User’s consent (legal basis: Article 6 paragraph 1 letter a of the GDPR);
- current or future recruitment for a position in Cubic Orb or initiating a cooperation with Cubic Orb – on the basis and within the scope of the User’s consent (legal basis: Article 6 paragraph 1 letter a of the GDPR);
- initiating activities which are necessary to make an agreement on acquiring Cubic Orb’s goods or services (which also applies if the User intends to acquire goods or services of third parties if they are offered by Cubic Orb) – legal basis: Article 6 paragraph 1 letter b of the GDPR;
- performing the agreement which Cubic Orb made with the User – legal basis: Article 6 paragraph 1 letter b of the GDPR;
- complying with a legal obligation to which we are subject – legal basis: Article 6 paragraph 1 letter c of the GDPR;
- if it is necessary for the purpose of legitimate interest of Cubic Orb or a third party – legal basis: Article 6 paragraph 1 letter f of the GDPR.
- If personal data are processed on the basis of the User’s consent, the User will have right to withdraw the consent in any moment which does not affect the lawfulness of the processing based on the consent before its withdrawal.
- Giving a consent for personal data processing is voluntary, however necessary for performing activities to which this consent applies, that is, depending on circumstances, introducing an offer or commercial information by us, contact through the contact form, opening the User’s account, sending the newsletter, providing marketing services or making an agreement.
- If personal data are processed for the purpose of direct marketing, the User will be entitled in any moment to object the processing of his/her personal data for the purpose of marketing and within the scope this processing is connected with the marketing.
- Cubic Orb will not process the User’s personal data if our interest (or third party’s interests) is overridden by the interests or fundamental rights and freedoms of the User.
- Realising our legitimate interest we are entitled to process personal data for the following purposes:
- marketing – which comprises adjusting the content and advertisement on the Website or over the Internet;
- analytical surveys for marketing purposes (including surveys of the User’s satisfaction);
- verifying if the User or other person uses the services rendered by us correctly;
- asserting or settling of our claims as well as defending against third parties’ claims
- evidential and archival;
- ensuring security, adequate quality and proper functioning of the Website, including the User’s account.
WHAT RIGHTS DOES THE USER HAVE?
- The User has the following rights:
- the right to access to his/her personal data and receive its chargeable copy;
- the right to rectify his/her personal data if they are inaccurate and complete them if they are uncomplete;
- the right to erase his/her personal data;
- the right to restrict the processing of his/her personal data;
- the right to object the processing of his/her personal data;
- the right to transmit his/her personal data;
- the right to submit a complaint to a supervisory authority.
WHOM AND ON WHICH BASIS CAN WE DISCLOSE PERSONAL DATA?
- Personal data of the User may be sometimes disclosed to third parties in particular to:
- our authorized employees and associates to whom we will disclose personal data only for the purpose of carrying out their duties;
- entities which goods or services may be acquired through Cubic Orb or are distributed by Cubic Orb;
- entities which services are necessary for the operation of the Website (for instance hosting service providers);
- entities to which we commission performance of the services connected with personal data processing (processors), for instance entities providing analytical services, conducting opinion surveys, carrying out marketing campaigns, advertising agencies;
- other recipients such as our sub-contractors, banks, accountants, tax or legal advisors, delivery companies.
- Cubic Orb discloses personal data only to these entities which ensure due protection of personal data, in particular comply with requirements set forth in the GDPR.
- Entities to which we disclose personal data are located mostly in Poland or other countries of European Economic Area (EEA).
HOW LONG DO WE STORE YOUR PERSONAL DATA?
- Personal data are stored within the time necessary to fulfil the purpose for which they are processed.
- In case of the agreements made with Cubic Orb, the time for storing personal data is the time in which the agreement is effective, but, in the extent necessary, these data may be processed by us from the moment of expiring of the agreement to the moment when claims which may arise from such an agreement become time-barred.
- In case of withdrawal of the consent by the User, his/her personal data will be removed immediately after receiving such a request, we may however, in the extent necessary, process such personal data to the moment when claims which we may have against the User or the User may have against us become time-barred.
- Cubic Orb may also use other technologies which have functions similar or identical to cookies. In such a case information and rules concerning cookies are applicable also to these similar technologies on the Website.
- Cookies may be used by us or our providers of external tools to monitor movement and activeness on the Website, in particular to:
- measure the statistic of audience of the Website’s content;
- personalize the services supplied through the Website;
- maintain the User’s session;
- authenticate persons using the Website;
- provide the User with personalized advertising contents.
- We use the following types of cookies:
- “essential” cookies, which enable using the services located on the Website for instance using of a session;
- “functional” cookies, which enable “remembering” settings chosen by the User and personalizing the User’s interface, for instance about the chosen version of the Website (mobile/classic), last phrases written by the User, outlook of the Website, tab status etc.;
- “analytic” cookies, which enable monitoring the User’s activity on the Website.
- The User can individually determine the conditions of cookies application and may disable them in any moment using the settings of his/her browser or service configuration. It may result in non-functioning or improper functioning of the Website. In some situations it is possible to set a browser so as to screen the request for consent for cookies each time. It gives the User possibility to control over cookies but may slow down the browser.
- Lack of changes of cookies settings means that they will be inserted to the User’s terminal equipment which means that Cubic Orb will store such information on the User’s terminal equipment and have an access to them.
WITH WHOM CAN YOU CONTACT IN THE MATTERS CONCERNING PRIVACY AND PERSONAL DATA PROTECTION?
- Cubic Orb has not appointed a data protection officer, since, pursuant to existent law, it does not have such an obligation.
- In case of any questions, doubts or complaints connected with personal data processing, using cookies or privacy protection please contact us at: firstname.lastname@example.org.