Privacy Policy Netbulls

1. Privacy and processing information
   1. The administrator of personal data is Netbulls Sp. z o.o. with its registered office in Białystok (15-540), Żurawia st. 71A/1.51, entered into the register of entrepreneurs of the National Court Register under KRS number: 0000469017, NIP: 5423232507, share capital of 10.000 PLN.
   2. Netbulls as a personal data administrator (hereinafter referred to as "Administrator").
   3. Administrator shall with due diligence select and apply appropriate technical and organizational measures to protect personal data being processed. Full access to databases is granted only to persons authorized by the Administrator. The Administrator protects personal data against unauthorized access and processing in violation of applicable regulations.
   4. Visitors to Netbulls.io can browse through subpages of the website without providing personal data.
2. Grounds for processing personal data
   1. Personal data shall be processed by the Controller in accordance with the law, in particular 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 (hereinafter referred to as 'GDPR').
   2. Personal data are processed to:
      1. answer questions addressed to the Administrator through the contact form available on Netbulls.io website, including interactive windows available on each subpage of the website (according to article 6.1.f of the GDPR);
      2. dispatch of marketing content, including information about planned events and workshops, business information, newsletter or dispatch of eBooks and other information on the basis of the consent given (Article 6(1)(a) of the GDPR);
      3. recruitment, including:
         • to establish and maintain contact with the Candidate in relation to the application documents submitted, pursuant to Article 6(1)(b) of the GDPR, i.e. in relation to taking action at the request of the data subject before concluding a contract,
         • carrying out and resolving the recruitment process based on Article 6(1)(b) of the GDPR, i.e. taking the necessary actions at the request of the data subject before concluding the contract - in the scope of data indicated in Article 221 §1 of the Labor Code and on the basis of the Candidate's consent, i.e. Article 6(1)(a) of the GDPR and in the scope of data beyond the catalog indicated in Article 221 §1 of the Labor Code,
         • to take account of the Candidate's application documents in future recruitment processes on the basis of his/her voluntary agreement (Article 6(1)(a) of the GDPR).
         • establishing contact in order to prepare, at the Customer's request, an offer of the Administrator's services and/or products tailored to the Customer's needs (Art. 6.1.b of the GDPR),
      4. adapting and developing the website's functionalities, including its structure and content to Your needs, creating aggregated statistics, and preserving the security and quality of services provided by the service - based on the legitimate interest of the administrator (Article 6(1)(f) of the GDPR);
      5. investigation or safeguard against possible claims (according to Article 6(1)(f) of the GDPR).
   3. Regardless of the purpose of the processing, providing the data is voluntary, however, failure to do so may prevent, depending on the specific case, the conclusion of a contract, use of selected services within the service and its functionality or receipt of marketing content.
3. Scope of processing of personal data
   1. The Administrator processes personal data only to the extent necessary to achieve a strictly defined purpose, in accordance with the information indicated below:
   2. Sending a message through the contact form, among others: e-mail address and telephone number and all other information that the You will provide of his own free will in the addressed message;
      1. Sending newsletters, commercial and business information and e-books: name and surname, e-mail address, telephone number, among others;
      2. Recruitment: the e-mail address from which the message was sent and the information contained in the application form;
      3. Preparation of offers: name and surname, e-mail address, telephone number, and other information contained in the message sent through the contact form;
      4. Customization and development of website functionality: IP addresses collected during Internet connections for technical purposes related to server administration.
   3. The Administrator does not make automated decisions on the basis of data collected about You.
4. Data retention period
   1. Personal data shall be kept only for the time necessary to achieve the specific purpose for which it was transmitted or to ensure compliance, as set out below:
   2. Personal data collected for the purpose of answering questions asked via the contact form will be processed no longer than 6 months after the last contact;
   3. Data collected for the purpose of sending marketing content, newsletters, commercial and business information and e-books will be processed until the withdrawal of Your consent;
   4. Personal data collected for the purposes of recruitment will be processed for the duration of the recruitment process, and if the Candidate agrees to leave the data for the purposes of future recruitments, they will be stored until the withdrawal of the consent, but not longer than 24 months from the date of its granting;
   5. Personal data collected for the purposes of preparing a personalized offer for products and/or services will be processed for the duration of the offer negotiation, and after its completion for 12 months counted from the date of the last contact, or they will feed the Administrator's customer database in order to execute the concluded agreement.
5. Recipients of personal data
   1. Your data may be made available to entities authorized to receive data in accordance with applicable laws, including relevant judicial authorities.
   2. Personal data may be transferred to entities cooperating with the Administrator on the basis of appropriate agreements, including selected marketing agencies and partners providing technical services (development and maintenance of IT systems and websites).
   3. Personal data may be transferred to a third country/international organization, as described in the points below:
      1. Your personal data may be processed on servers located outside their country of residence;
      2. Your personal data may be transferred outside the European Economic Area (EEA) to a third country, i.e. the USA, to entities meeting the required level of protection under the European Commission's decision of 12 July 2016, the so-called Privacy Shield. These entities comply with the rules established by the U.S. Department of Commerce under the EU-US Privacy Shield Framework Programs governing the collection, use and retention of personal data from European Union Member States.
6. Your rights
   1. Here we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
   2. Your principal rights under data protection law are:
      1. the right to access;
      2. the right to rectification;
      3. the right to erasure;
      4. the right to restrict processing;
      5. the right to object to processing;
      6. the right to data portability;
      7. the right to complain to a supervisory authority; and
      8. the right to withdraw consent.
   3. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Providing the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
   4. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
   5. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
   6. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
   7. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
   8. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
   9. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
   10. To the extent that the legal basis for our processing of your personal data is: (i) consent; or (ii) that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract, and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
   11. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
   12. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
   13. You may exercise any of your rights in relation to your personal data by written notice to us.
7. Changes to This Privacy Policy
   1. We may update our Privacy Policy from time to time. Thus, you are advised to review this page periodically for any changes. We will notify you of any changes by posting the new Privacy Policy on this page. These changes are effective immediately after they are posted on this page.
8. Information Collection and Use
   1. We may process data about your use of our website and services ("usage data"). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is our analytics tracking system. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is consent or our legitimate interests, namely monitoring and improving our website and services.
   2. We may process your account data ("account data"). The account data may include your name and email address. The source of the account data is you or your employer. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is consent or our legitimate interests, namely the proper administration of our website and business or [the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. The legal basis for this processing account data for the purpose of sending marketing materials, allowing you to participate in promotions, conducting customer surveys is your consent.
   3. We may process information contained in or relating to any communication that you send to us ("correspondence data"). The correspondence data may include the communication content and metadata associated with the communication. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of service and our website and communications with users.
   4. Link to privacy policy of third party service providers used by the app
      Google Analytics
      Google Ads
      Youtube.com
      Mailchimp
      Hotjar
   5. We want to inform you that whenever you use our service, in a case of an error in the app we collect data and information (through third party products) on your phone called Log Data. This Log Data may include information such as your device Internet Protocol (“IP”) address, device name, operating system version, the configuration of the app when utilizing our service, the time and date of your use of the service, and other statistics.
9. Cookies
   1. Cookies are files with a small amount of data that are commonly used as anonymous unique identifiers. These are sent to your browser from the websites that you visit and are stored on your device's internal memory.
   2. This service does not use these “cookies” explicitly. However, the app may use third party code and libraries that use “cookies” to collect information and improve their services. You have the option to either accept or refuse these cookies and know when a cookie is being sent to your device. If you choose to refuse our cookies, you may not be able to use some portions of this service.
10. Service Providers
    1. We may employ third-party companies and individuals due to the following reasons:
       • To facilitate our SERVICE;
       • To provide the SERVICE on our behalf;
       • To perform SERVICE-related services; or
       • To assist us in analyzing how our SERVICE is used.
       We want to inform users of this SERVICE that these third parties have access to your Personal Information. The reason is to perform the tasks assigned to them on our behalf. However, they are obligated not to disclose or use the information for any other purpose.
11. Links to Other Sites
    1. This SERVICE may contain links to other sites. If you click on a third-party link, you will be directed to that site. Note that these external sites are not operated by us. Therefore, we strongly advise you to review the Privacy Policy of these websites. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.
12. Children's Privacy
    1. These service do not address anyone under the age of 13. We do not knowingly collect personally identifiable information from children under 13. In the case we discover that a child under 13 has provided us with personal information, we immediately delete this from our servers. If you are a parent or guardian and you are aware that your child has provided us with personal information, please contact us so that we will be able to do necessary actions.
13. Contact Us
    1. If you have any questions or suggestions about our Privacy Policy, do not hesitate to contact us at contact@netbulls.io.