PRIVACY POLICY

Introduction

The protection of personal data is a necessary aspect of the activities of SK Legal with its registered office in Warsaw ("SK Legal"). At SK Legal, we feel responsible for the security of personal data processed in connection with our ongoing consulting activities, pursuant to 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 (the "GDPR"). In this document, we inform about the legal grounds for the processing of personal data by SK Legal, about the methods of collecting and using them, as well as about the rights of entities whose data SK Legal processes.

This Privacy Policy applies to all cases in which SK Legal is the controller of personal data and processes personal data. This applies both to cases in which SK Legal processes personal data obtained directly from the data subject, as well as cases in which personal data has been obtained from other sources. SK Legal fulfils its information obligations in both of the above cases, specified in Article 13 and Article 14 of the GDPR respectively in accordance with these provisions.

Below we indicate full details of SK Legal as the administrator of personal data:

Attorney Leszek Kot Law Firm with its registered office in Warsaw (01-355), at "Osiedle Przyjaźń" No. 79 apt. 1-4, VAT UE No.: PL7742718340, REGON No.: 146419326. The person responsible for personal data protection at SK Legal is Mr. Leszek Kot (leszek.kot@sklegal.pl).

SK Legal wants to be transparent about the methods and legal grounds for processing personal data, as well as the purposes for which SK Legal processes personal data. SK Legal makes sure that each time it provides the necessary information in this regard to each person whose personal data it processes as a data controller. Below is a list of personal data processing operations.

At the same time, we point out that whenever SK Legal processes personal data on the basis of the legitimate interest of the data controller, it tries to analyze and balance its interest and potential impact on the data subject (positive or negative) and the rights of that person under the provisions on the protection of personal data. SKLegal does not process personal data based on its legitimate interest if it comes to the conclusion that the impact on the data subject would outweigh the interests of SK Legal (then SK Legal may process personal data if, for example, it has the appropriate consent or is required or permitted by law).

Processing of personal data of persons visiting websites run by SK Legal or using services provided electronically.

Natural persons visiting SK Legal websites or using services provided by SKLegal electronically (hereinafter jointly the "Services”) have control over the personal information they provide to SK Legal. The websites limit the collection and use of information about their users to the minimum necessary to provide them with services at the desired level, pursuant to art. 18 of the Act of July 18, 2002 on the provision of electronic services (Journal of Laws of 2020, item 344, as amended).

To a limited extent, SK Legal may collect personal data automatically via cookies located on websites about the provision of electronic services. Cookies are small text files saved on the user's computer or other mobile device while using websites. These files are used e.g. using various functions provided on a given website or confirming that a given user has seen certain content from a given website. Among the cookies, one can distinguish those that are necessary for the operation of websites for the provision of electronic services. Cookies belonging to this category are used to ensure:

maintaining the user's session;
saving the user's session state;
enabling authorization using the login service;
saving information that allows the user to log in anonymously;
service availability monitoring.

Another category of cookies are files that are not necessary to use the Websites, but facilitate their use. They are used to enable:

remembering the user's choice to stop displaying a selected message or to display it a certain number of times;
restoring the user's session;
checking whether saving cookies works properly;
enabling automatic login to the Website ("remember me" option);
matching the content of the Websites to the preferences of users;
setting the preferred language, font size and other such properties to facilitate working with the application.

SK Legal uses only necessary cookies (so-called session cookies).

SK Legal also uses the services of third parties, the list of which is constantly changing, and which use cookies for the following purposes:

monitoring traffic on SK Legal websites;
collecting anonymous, aggregate statistics that allow SK Legal to understand how users use the SK Legal website and which enable continuous improvement of SK Legal Services;
determining the number of anonymous users of SK Legal websites - needed to analyze the use of the Websites;
controlling how often selected content is shown to users;
controlling how often users choose a particular service;
use of a communication tool;
integration with a social networking site.

These entities as at the date of preparation of this document include:

Facebook (more information at: facebook.com).

The user can manage cookies used by SK Legal or by any other external providers by changing the settings of his web browser. At the same time, SK Legal stipulates that after rejecting cookies, some functions offered by the Websites may not work properly, and even in some cases it is associated with complete disabling of the use of the selected product.

SK Legal collects information on the use of the Services by their users and their IP addresses based on the analysis of access logs. We use this information to diagnose problems related to server operation, analyze possible security breaches and to manage the website. The IP address may also be used by SK Legal for statistical purposes, i.e. to collect and analyze demographic data of website visitors (e.g. information about the region from which the connection was made). On the basis of the above-mentioned in particular cases, collective, general statistical statements are prepared, disclosed to third parties cooperating with SK Legal. They usually include information about the viewership of the Website. However, these lists do not contain any data allowing for the identification (determination of identity) of a given Website user.

SK Legal may be required to disclose information regarding the IP number of a given Website user at the request of authorized state authorities in connection with proceedings conducted by them, on the basis of the relevant provisions of generally applicable law.

As a rule, only when it is really necessary to provide a given service in some cases, e.g. when subscribing to free newsletters, surveys or order forms, SKLegal collects more detailed information about users, such as e-mail addresses or other personal data.

Information that SK Legal collects in connection with the use of the Websites may be processed in an automated manner, however, this will not cause any legal effects on a natural person or significantly affect their situation in a similar way.

Legal bases for processing

In the case of processing personal data in connection with the use of SK Legal Services by users, we may have different legal grounds for processing, depending on the category of personal data that we process and the purpose of processing. For example:

we process personal data of people visiting SK Legal websites on the basis of the legitimate interest of the data controller, e.g. by matching the displayed advertisements or on the basis of consent if we asked the data subject for such consent;
when the relevant provisions of generally applicable law require the processing of certain personal data for tax or accounting purposes.

Processing of personal data of persons contacting SK Legal in order to obtain information about the offer or to share comments on SK Legal services, as well as those contacting SK Legal to conclude a contract.

Apart from the above data from natural persons who contact SK Legal in order to obtain information about the offer or share comments on SK Legal services, as well as those who contact SK Legal to conclude a contract, we collect the following personal data: name and surname, e-mail address email or phone number. In particular, these persons may send us an e-mail via the website. Such messages contain the set user name and e-mail address as well as additional information that the user wants to include in the message.

We ask you not to provide information from special categories of personal data via websites (such as information about race or ethnic origin, political views, religious or philosophical beliefs, trade union membership, information about physical or mental health, genetic data, biometrics, sex life, sexual orientation or criminal record). If you provide such information for any reason, SK Legal will consider this to be your express consent to our collection and use of such information as set forth herein or as specified where such information is disclosed.

SK Legal collects the above data on the basis of the consent expressed by the user directing the request to SKLegal or in order to perform the contract (execution of the request) submitted by a given person. We may also process the data provided on the basis of the so-called justified purpose of the data controller.

Processing personal data of SK Legal clients and potential clients

SK Legal processes personal data of its clients and potential customers. This data may also include personal data of persons associated with SK Legal's clients who are not natural persons (e.g. contact persons). Personal data of this type are processed in IT systems used by SK Legal (e.g. CRM system). Personal data processed for these purposes includes, among others: name and surname, employer's name, position of contact person, telephone number, e-mail address or other business contact details. What's more, in the case of customers who have concluded paid contracts with SKLegal, we can also process payment data, including bank account numbers. Personal data of business contacts may be disclosed to regular associates of SK Legal and used by them to conduct business activity of SK Legal.

Automatic processing of personal data

The information that we collect in connection with the use of our online services may be processed in an automated manner (including in the form of profiling), however, this will not have any legal effects on the natural person or similarly significantly affect his situation. We attach particular importance to the issue of profiling and indicate that: for the purposes of profiling we do not process any sensitive data, for the purposes of profiling we process data that were previously subject to pseudonymization or such data that have been aggregated by us, if we cannot achieve the purpose otherwise than by profiling personal data not pseudonymized or non-aggregated, we use typical data for this: e-mail and IP address or cookies, we profile in order to analyze or forecast personal preferences and interests of people using our Services or services and adjust the content on our Websites or products to these preferences, we profile for marketing purposes, i.e. matching the marketing offer to the above preferences.

The processing of personal data of natural persons who are our clients is based on:

justified interest of SK Legal as a data controller (e.g. in the scope of database creation, analytical and profiling activities, including activities related to the analysis of the use of products, securing documentation for the purpose of defending against possible claims or for the purpose of pursuing claims);
consent (including in particular consent to e-mail marketing);
performance of the concluded contract;
obligations arising from the provisions of generally applicable law (e.g. tax law or accounting regulations).

The processing of personal data of natural persons who are potential customers is based on:

justified interest of SK Legal as a data controller (e.g. in the scope of creating a database),
consent (including in particular consent to e-mail marketing).

How long SK Legal processes personal data

The time for which we can process personal data depends on the legal basis constituting a legal premise for the processing of personal data by SK Legal. We are not allowed to process personal data for a longer period than it results from the above-mentioned. legal basis. Accordingly, we inform you that:

if SK Legal processes personal data on the basis of consent, the processing period lasts until the user withdraws this consent;
in the event that SK Legal processes personal data on the basis of the legitimate interest of the data controller, the processing period lasts until the termination of the above-mentioned interest (e.g. the period of limitation of civil law claims) or until the data subject objects to further such processing - in situations where such an objection is entitled in accordance with the provisions of generally applicable law;
if SK Legal processes personal data because it is necessary due to applicable law, the periods of data processing for this purpose are specified in these regulations;
in the absence of specific legal provisions or contractual regulations, the basic period of data storage in the case of records and other documentary evidence prepared during the performance of the contract is not more than 10 years.

When and how we share personal data with third parties

We only share personal information with others when we are permitted to do so by law. In such a case, in the relevant agreement concluded with a third party, we provide security provisions and mechanisms to protect data and maintain our standards in the field of data protection, confidentiality and security. Agreements of this type are called personal data processing entrustment agreements, and SK Legal has control over how and to what extent the entity entrusted by SK Legal with the processing of certain categories of personal data processes these data. In connection with the above, we indicate that the recipients of personal data that SK Legal processes as a personal data administrator may be:

above entities processing personal data under personal data processing agreements (so-called processors);
entities providing hosting services to SK Legal;
entities implementing marketing or sales campaigns for SK Legal;
other subcontractors of SK Legal, providing services in the field of software delivery, software or hardware maintenance services used by SK Legal, as well as suppliers of goods that we use;
entities providing services in the field of survey research, including NPS (customer satisfaction) research;
debt collection companies (we transfer personal data only to the extent that it is actually necessary to achieve a given goal);
auditors and statutory auditors, legal advisors, tax advisors;
authorities supervising compliance with the law, regulatory authorities and other public administration authorities (whereas in the last two cases, we transfer data only if and only to the extent that it is actually necessary and required under the mandatory provisions of law and in a manner consistent with these regulations).

In the case of personal data subject to EU law, we indicate that: cross-border transfers may concern countries outside the European Economic Area (the "EEA") and countries where there are no provisions specifying the special protection of personal data. We take steps to ensure that all personal data is adequately protected and that the transfer of personal data outside the EEA is lawful. In the case of transferring personal data outside the EEA to a country which, according to the European Commission, does not ensure an adequate level of personal data protection, the transfer takes place only on the basis of an agreement that takes into account the EU requirements for the transfer of personal data outside the EEA.

What rights do data subjects have and how to exercise them

Natural persons have the rights specified in the provisions regarding their personal data, and SK Legal as the data controller is responsible for the implementation of these rights in accordance with the relevant provisions of generally applicable law. In case of any questions and requests regarding the scope and implementation of rights, as well as in order to contact us to exercise a specific right in the field of personal data protection, please contact us at the following e-mail address: leszek.kot@sklegal.pl. SK Legal reserves the right to exercise the following rights after positive verification of the identity of the person applying for a given activity.

Access to personal data

Natural persons have the right to access data that SK Legal stores as a data controller. This right can be exercised by sending an e-mail to the following address:leszek.kot@sklegal.pl.

Change of personal data

Changes, including updating of personal data processed by SK Legal, can be made by sending an e-mail to the following e-mail address:leszek.kot@sklegal.pl or by contacting SK Legal via the relevant registration page or application, or via regular mail.

Withdrawal of consent

Where personal data is processed on the basis of consent, individuals have the right to withdraw that consent at any time. SK Legal informs about it almost at any time of collecting consents and allows you to withdraw consent in the same way as it was granted. If SK Legal has not provided a different address or contact number to withdraw consent, please send an e-mail to leszek.kot@sklegal.pl.

The right to limit processing or object to the processing of personal data

Natural persons have the right to limit the processing or object to the processing of their personal data at any time, due to their particular situation, unless the processing is required in accordance with the provisions of generally applicable law.

A natural person may object to the processing of their personal data when:

the processing of personal data is based on a legitimate interest or for statistical purposes, and the objection is justified by the particular situation in which it found itself;
personal data is processed for the purposes of direct marketing, including profiling for this purpose.

In turn, with regard to the request to limit data processing, SK Legal indicates that it is entitled, among others, when a given person notices that their data is incorrect. In such a case, you can request the restriction of personal data processing for a period allowing SK Legal to check the correctness of this data.

Other rights: the right to request deletion of data and the right to transfer data

Whenever you wish to exercise any of these rights, please send an e-mail to leszek.kot@sklegal.pl.

The right to delete data can be exercised, inter alia, when the data of a natural person are no longer necessary for the purposes for which they were collected by SK Legal or when a natural person withdraws his consent to the processing of data by SK Legal, and also when a natural person reports objection to the processing of her data or when her data will be processed unlawfully. The data should also be deleted in order to fulfill the obligation resulting from the relevant legal provision.

The right to transfer data applies when the processing of a person's data is based on the consent of a natural person or a contract concluded with him, and when the processing is carried out automatically.

Any other questions, concerns or complaints

If you have any questions, doubts about the content of this Privacy Policy or the way in which SK Legal processes personal data, as well as in the event of complaints regarding these matters (regardless of the fact that we sincerely hope that it will not be necessary to file such complaints), please to send an e-mail with detailed information regarding the complaint to leszek.kot@sklegal.pl. Any complaints received will be considered by SK Legal, and the person jamming the question, doubt or complaint will receive a response from SK Legal.

Persons whose personal data is processed by SK Legal also have the right to lodge a complaint with the supervisory body, which is currently the Office for Personal Data Protection (address: Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw; https://uodo.gov .pl/pl/p/contact).

We enable direct contact at the headquarters of SK Legal, as well as contact by letter (e-mail and traditional mail) or telephone contact, and for this purpose we provide the following contact details:

Advocate Leszek Kot Law Firm

Osiedle "Przyjaźń" No. 79 apt. 1-4
01-355 Warsaw, Poland
mob. +48 604 808 715

Whether and when changes to this Privacy Policy are possible

We undertake to review this Privacy Policy on a regular basis and to amend it when it proves necessary or desirable due to the new provisions of generally applicable law, new guidelines of the authorities responsible for the supervision of personal data protection processes, best practices in the area of personal data protection (i.e. codes of good practice; if SK Legal is bound by such codes, we will inform you about this fact). We reserve the right to change this Privacy Policy in the event of changes in the technology used to process personal data (provided that the change affects the wording of this document), as well as in the event of a change in the methods, purposes or legal grounds for processing personal data by SK Legal.

This document was last updated on January 1, 2022.