Privacy policy - Semguru

We respect your privacy and make every effort to protect your personal information.

This Privacy Policy will provide you with information about how we handle and use your personal information.

This Privacy Policy indicates your rights relating to the personal information you provide and informs you of the applicable laws protecting your personal information.

Please read the Privacy Policy carefully before using our Services.

DEFINITIONS
1. Administrator - semguru sp. z o.o. based in Poznań, 4B/48 Czarnieckiego St., 61-538 Poznań, KRS: 0000749179, NIP: 7831788307,
  1. Services - any product, service, content, functionality, technology or feature, all related websites and applications that we provide to you - either continuously or occasionally,
  2. Website - www.it-heroes.pl,
  3. RODO - Regulation of the European Parliament and of the Council (EU) of April 27, 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,
  4. User - any person using the Services offered by the Administrator using the Site.
BACKGROUND INFORMATION
1. We are the Controller within the meaning of the RODO with respect to the personal data of Users who are natural persons.
2. The Administrator determines the purposes and means of processing Users' personal data on its own and at its own risk. We do not have a Data Protection Officer.
3. If you have questions or concerns about how your personal information is protected, please contact us:
  
  +48 727 777 722
  
  przemek@semguru.pl
4. Personal information is any information that can be used to identify an individual, for example, name, phone number, email address, delivery address.
5. When we refer to the term "process" or "processing" in this Privacy Policy, we mean any activity or operation performed on your personal data (such as storing or analyzing it for the purpose of providing services).
6. By clicking on the links provided on the Site, you may be redirected to websites or services that constitute a service provided by entities other than the Administrator and thus beyond any direct or indirect control of the Administrator, in which the process of processing, including the collection of personal data, is carried out in accordance with the rules laid down by these entities, e.g. in the privacy policy specific to these services or applications. The Administrator recommends becoming familiar with the regulations and privacy policies adopted by the entities in question.
COLLECTION OF PERSONAL DATA
1. Collecting personal data directly from the user
  1. The Site offers the possibility to contact the Administrator through the possibility of e-mail or telephone contact, as well as through such functionalities as the contact form on the Site and the live chat service.
  2. If you are contacted using the sources referred to in paragraph 1 above, we collect all the information you choose to provide during a conversation or during correspondence with our representatives.
  3. Please be advised that in the case of telephone contacts, all conversations are recorded. If you object to the recording of telephone conversations, the conversation will not continue and you may use other available forms of communication.
2. Data collected automatically when you use the Services
  1. When you use the Site, the following information is automatically collected:
    1. Device data - we collect information about the device you are using, such as operating system version and unique identifiers,
    2. location information - depending on the privacy settings of the device you use, we automatically collect and process information about your current location. We use a variety of technologies to determine your location, including IP address, GPS, Wi-Fi access points and cell phone stations. Your location data allows us to tailor a more personalized (local) offer if you are interested in the Services provided by the Administrator, and, based on your prior consent, to send you commercial and marketing information, including about contests or events held by the Administrator near your location,
    3. login data - we collect technical details, including the Internet protocol address (IP address) of your device, time zone and operating system information. We also store information about your login and the type and type of web browser you use.
    4. Site activity data - we collect information about your activity on the Site, in particular information about the pages from which you arrive at our Site, the date of each visit, the results of your searches, the duration of your visit to the Site, as well as the order in which sections (subpages) of our Site are visited.
    5. cookies - The site uses cookies. For more information on the purposes and uses of cookies, please refer to the following section of this Privacy Policy.
3. Data obtained from third parties or publicly available sources
  1. We do not exclude the possibility that your personal data may also be obtained in other ways, such as:
    1. obtaining from analytics providers (e.g. Google, Facebook) certain information of a technical nature and resulting from usage,
    2. Obtaining address and contact data related to your business from information providers, such as business intelligence agencies and entities that build databases of potential contractors, and from publicly available registers (e.g., the Central Register and Information on Business Activity), publicly available accounts on social networks, websites you run, blogs, etc..,
    3. other Users, to the extent that they correspond with us regarding our Services (e.g., an email with an inquiry regarding an issue previously agreed upon with you, and a subsequent reference to those issues - including personal information - by a third party).
4. Collection of personal data from children
  1. Our Services are not directed to children under the age of 16 and we do not knowingly obtain information about them. If we determine that a person under the age of 16 has provided us with their personal information, we will delete it immediately if we are unable to determine whether the child's parent or guardian has consented or allowed the child to use our Services.
PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA
1. Your personal data will be used by us only when it is in accordance with the law. Most often, the processing of your personal data will take place when:
  1. it is necessary for the conclusion or performance of a contract (including, please note that by using our Services you are entering into a contract for the provision of electronic services),
  2. it is necessary for the purposes of our legitimate interests in improving our Services and providing you with access to a safe and efficient Site, and in being able to contact you, e.g. in connection with submitting an inquiry through the Site,
  3. it is necessary to fulfill our legal obligation.
2. Please be informed that we process your personal data when you visit the Administrator's profiles maintained on social media (e.g. Facebook, Instagram, Linkedin). This data is processed solely in connection with the operation of the profile, including for the purpose of informing Users about the Administrator's activities and promoting various events, services and products, as well as for the purpose of communicating with Users through the functionalities available on social media. The legal basis for the Administrator's processing of personal data for this purpose is its legitimate interest in promoting its own brand and building and maintaining a brand-related community.
3. Under certain circumstances, we may also process your personal data on the basis of consent obtained from you. In such cases, we will inform you at the time of obtaining your consent about the purpose of the processing and the category of personal data processed.
USER RIGHTS
1. Applicable laws grant you a number of rights related to the processing of your personal data.
2. If you wish to exercise any of the rights described below, you should contact the Administrator for this purpose by email at the address indicated in Part II, item 3.
3. In connection with the processing of your personal data, the RODO provides for the following rights for persons whose personal data is affected by the processing:
  1. The right of access to personal data - this right allows you to be informed whether we process personal data about you, and if so, the right to receive a copy of the personal data we process. The right of access to personal data allows you to verify that we are processing your personal data in accordance with the law,
  2. The right to rectification of personal data - this right provides the ability to request the correction of incomplete, untrue or outdated data that we process. In some cases, in fulfilling the reported request, we will have to verify the correctness of the new data we receive,
  3. The right to restrict the processing of your personal data - this right allows you to request us to stop the processing of your personal data in the following situations: (i) when it is your will that we verify the accuracy of your data; (ii) when our processing is unlawful; (iii) when you have objected to our processing, but we need to verify that we still have an overriding and legitimate basis to continue processing your personal data,
  4. The right to erasure of personal data - this right allows you to request the erasure of your personal data if it is no longer necessary for the purposes for which it was collected. You can also demand that we erase your personal data if you have successfully exercised your right to object to processing (see below), if we process your data unlawfully, or if we are obliged to erase your personal data in order to comply with a legal obligation indicated by applicable law. Please note that in some cases, we are obliged to process your data on the basis of applicable laws and we are unable to comply with the request.
  5. The right to object to the processing of data concerning you when we process the data on the premise of legitimate interests (ours or those of third parties) - you can file a right to object on grounds related to your particular situation, when in your opinion the processing affects your rights or freedoms. You also have the right to object if we process your data for direct marketing purposes. In some cases, we can demonstrate that we have a legitimate basis for processing that overrides your rights and freedoms (e.g., the need to ensure the security of the Service and to prevent fraud). In such cases, the right to object is not combined with the deletion of your personal data.
  6. The right to portability of personal data - in exercising this right, we will provide you or a third party you designate with your personal data in a structured, commonly used, machine-readable format. You have this right only with respect to data processed on the basis of consent or a prerequisite for the performance of a contract concluded with us, and the processing itself is carried out by automated means (in computer systems).
4. If you have given us consent to process your personal data, you have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing that was carried out on the basis of consent before its withdrawal. You can withdraw your consent by directing your request to the email address indicated in Part II, item 3 of this Policy, or each time by clicking on the link in the email sent as a result of obtaining your prior consent.
5. The exercise of rights is, as a rule, free of charge - there is no need to pay a fee for the exercise of the right of access to your personal data (or for the exercise of any other rights). However, we may charge a reasonable fee if the request made is manifestly unreasonable or excessive, in particular due to their continuing nature. In such cases, we may also refuse to comply with the request.
6. We endeavor to respond to all legally legitimate requests within one month. If the request is particularly complicated or several requests have been made, it may take us longer than one month to recognize them. In this case, we will inform you of the extension of the deadline and provide you with ongoing information regarding the fulfillment of the request.
7. You also have the right to file a complaint with the relevant supervisory authority at any time. We would appreciate it if, before filing a complaint with a supervisory authority, you would give us a chance to address your case and concerns about our operations. For this reason, please contact us by email at the address indicated in Part II, item 3.
SHARING OF PERSONAL DATA
1. We may share your personal data with the following categories of recipients for the purposes indicated in Part IV:
  1. Third-party service providers - we use third-party service providers to help provide us with certain solutions related to our Services, e.g., cloud storage, hosting service providers, marketing campaign providers on our behalf. Providers of such services may be based both inside and outside the "EEA".
  2. Marketing and analytics providers - in order to improve our Services, we sometimes share information about you in non-identifiable form with analytics providers who help us analyze how Users use our Site. For the purposes of monitoring and reporting on the effectiveness of our business partners' campaigns and for internal business analysis purposes, we share information with them in a way that does not identify Users.
  3. Law enforcement, supervisory authorities and others - we may disclose your personal data to law enforcement agencies, supervisory authorities, public authorities, entities performing public tasks or acting on behalf of public authorities, and other third parties. Disclosure of such data is made in connection with the performance of legal obligations.
2. We may decide to sell, transfer or merge parts of our business or our assets. We may also seek to acquire or merge with other companies. In the event of any change, the new owner will be able to use your personal information as described in this Privacy Policy.
TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
1. We do not exclude the possibility of situations in which your personal data will be transferred outside the "EEA". In such a situation, we guarantee that a similar level of protection will be provided by implementing one or more of the following safeguards:
  1. transfer of personal data only to countries that the European Commission has recognized as providing an adequate level of personal data protection. Detailed information is available here: European Commission: Adequacy of the protection of personal data in non-EU countries
  2. when using certain providers, we may use agreements approved by the European Commission that provide personal data with the same protection as it has in the European Union. Detailed information is available here: European Commission: Model contracts for the transfer of personal data to third countries
  3. if our service providers are based in the United States of America, we may transfer data to them if they are covered by Privacy Shield, which requires them to provide similar protection for data transferred between Europe and the United States. Details are available here: European Commission: EU-US Privacy Shield
PERIOD AND PLACE OF STORAGE OF PERSONAL DATA
1. The data we collect about you will be stored and processed both within and outside the "EEA" on appropriately secured servers in order to provide you with the best possible service.
2. We keep your data for as long as necessary to fulfill the purposes for which they were collected, including in fulfillment of legal, tax and accounting obligations or for reporting purposes.
3. In order to determine the appropriate retention period for personal data, we take into account the amount and nature of the data processed, including the nature of special category data. We also take into account the potential risk of unauthorized use or unauthorized disclosure of your personal data, the possibility of achieving the purposes of the processing by other means, and the content of the regulations relating to the personal data processed.
4. Personal data related to cookie technology are stored for a period of time corresponding to the life cycle of cookies or until they are deleted by the User.
ORGANIZATIONAL AND TECHNICAL MEASURES AND SECURITY OF PERSONAL DATA PROCESSING
1. The information we obtain about you, including information containing personal data, is stored on properly secured servers.
2. In order to ensure the security of personal data processing, appropriate and necessary technical and organizational measures for the protection of personal data have also been implemented. In particular, we ensure that the personal data we process are:
  1. correct and processed in a lawful manner,
  2. obtained only for specific purposes and not further processed in a manner incompatible with those purposes,
  3. Adequate, appropriate and not redundant to the purposes of their processing,
  4. accurate and up-to-date,
  5. not kept longer than necessary,
  6. safely stored,
  7. not transferred to a country outside the EEA without adequate protection.
3. Despite the data protection measures we have implemented, your sharing of information via the Internet or publicly accessible networks can never be considered completely secure and there is a risk that unauthorized third parties will gain access to your personal information.
AUTOMATED PROCESSING OF PERSONAL DATA AND PROFILING
1. The information we collect in connection with your use of our Website online may be processed by automated means (including profiling), but this will not have any legal effect on you or similarly materially affect you.
2. Referring to the issue of profiling, we inform you that:
  1. We do not process any sensitive data for profiling purposes,
  2. for the purposes of profiling, we generally process data that has previously been pseudonymized or such data that we have aggregated,
  3. if we cannot achieve the purpose other than by profiling non-speudonymized or non-aggregated personal data, we use typical data for this purpose: email address and IP address or cookies,
  4. we profile to analyze or predict the personal preferences and interests of individuals using our Site and Services and to tailor the content on our Site to those preferences,
  5. we profile for marketing purposes, i.e. matching marketing offers to the above preferences.
COOKIE POLICY
1. Cookies are IT data, in particular text files, stored in the Users' terminal devices intended for use on the Site. These files allow the Site to recognize the User's device and appropriately display the Site tailored to the User's individual preferences. Cookies usually contain the name of the website they come from, the time they are stored on the User's terminal device and a unique number.
2. Cookies are used to adapt the content of the Site to the User's preferences and to optimize the use of the Site. They are also used to create anonymous, aggregated statistics, which help to understand how the user uses the websites, which allows to improve their structure and content, excluding personal identification of the User.
3. As a rule, two types of cookies are used - "session" and "permanent". The former are temporary files that remain on the User's device until the Site is turned off. "Permanent" files remain on the User's device for the time specified in the parameters of the cookies or until they are manually deleted by the User. Cookies used by the Website operator's partners, including in particular the Website Users, are subject to their own privacy policies.
4. There is a detailed division of cookies, due to:
  1. necessity for the service:
    1. Functional - are important for the operation of the Site - are used to enrich the functionality of the Site, without them the Site will work properly, but will not be tailored to the User's preferences, are used to ensure a high level of functionality of the Site, without the settings stored in cookies, the level of functionality of the Site may decrease, but should not prevent the complete use of the Site, are used for very important functionalities of the site, blocking them will result in selected functions not working properly,
    2. indispensable - these are cookies necessary for the proper functioning of the Site or functionality that the User wants to use,
    3. business - they enable the implementation of the business model on the basis of which the Site is made available, their blocking will not result in the unavailability of the entire functionality of the Site, but may reduce the level of service provision due to the inability of the Site owner to realize revenues that subsidize the operation of the Site. This category includes, for example, advertising cookies.
  2. the time for which cookies will be placed on the User's terminal device:
    1. temporary (session) cookies - cookies placed for the duration of the use of the browser (session), they are deleted when the browser is closed,
    2. permanent cookies - they are not deleted when the browser is closed and remain on the User's device for a certain period of time or without expiration depending on the settings of the Site owner.
  3. origin - from the Site Administrator, who manages the cookies:
    1. own cookies - cookies placed directly by the owner of the Site which was visited,
    2. External cookies - cookies placed by external entities whose website components have been called by the owner of the Site. Cookies can be called by the Administrator with the help of scripts, components that are located on the partner's servers, located in another location - another country or even a completely different legal system. In the case of calling by the Administrator of the Site components coming from outside the Administrator's system, the standard rules of the cookie policy other than this Policy may apply.
  4. the purpose they serve:
    1. Site configuration - allow you to set features and services on the Site,
    2. security and reliability of the Site - enable verification of authenticity and optimization of Site performance,
    3. session status - allow recording information about how Users use the Site. Cookies used to record the so-called "session state" help improve services and enhance the browsing experience on the Site,
    4. processes - enable the smooth operation of the Site itself and the functions available on it,
    5. Ads - allow displaying ads that are more interesting for Users and at the same time more valuable for publishers and advertisers, personalize ads, can also be used to display ads outside the Site,
    6. Location - allow you to customize the information displayed to your location, which also depends on the location settings you have selected on the device you use,
    7. audience analysis (statistics) - allow the owner of the Site to better understand the preferences of Users and, through analysis, improve and develop products and services. Typically, the owner of the Site or an external entity with which it cooperates collects information anonymously and processes trend data without identifying the personal data of individual Users.
  5. Interference with the User's privacy:
    1. harmless - these are cookies necessary for the proper operation of the Site, needed to enable the functionality of the Site, but their operation has nothing to do with tracking the User,
    2. Researching - used to track Users, however, does not include information to identify the data of a specific User.
5. We would like to inform you that we store cookies on your end device and then access the information contained therein for statistical purposes, for marketing purposes (remarketing) and to ensure proper operation of the Site. We also inform you that there may be a need or legitimate interest in using other types of cookies than those mentioned above.
6. Personal data collected using cookies may be collected only for the purpose of performing certain functions for the User.
7. Web browsers allow cookies to be placed on the end device by default.
8. These settings can be changed in such a way as to block the automatic handling of cookies in the settings of your web browser or inform you each time they are sent to your device.
9. Information about the possibility and methods of handling cookies is available in the settings of the Internet browser used by the User.
10. Restricting the use of cookies may affect some of the functionality available on the Site.
OTHER TECHNOLOGIES
1. Please be advised that we also use technologies that track your activities on the Site:
  1. Facebook conversion pixel - to manage Facebook ads and conduct remarketing activities,
  2. Google Analytics tracking code - in order to analyze the statistics of the Site.
SERVER LOGS
1. Use of the Site involves sending requests to the server on which the Site is stored.
2. Each request to the server is recorded in the server logs.
3. The logs include, among other things, the User's IP address, the date and time of the server, information about the Internet browser and the operating system the User is using.
4. The data recorded in the server logs are not associated with specific individuals using the Site and are not used by us to identify you.
5. Logs are saved and stored on the server.
6. The server logs are only auxiliary material for the administration of the Site, and their contents are not disclosed to anyone except those authorized to administer the server.
PRIVACY POLICY CHANGES
1. The policy is reviewed on an ongoing basis and updated as necessary.