PRIVACY POLICY

1. INTRODUCTION

This Policy was adopted on May 8, 2024 in order to fulfill the obligation of transparent data processing, in particular to fulfill the information obligation concerning the purposes and other rules of processing personal data with respect to natural persons in accordance with Article 13 of 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, hereinafter referred to as GDPR.

Please note that since May 25, 2018, the provisions of the General Data Protection Regulation (GDPR) have been in force in Poland.

This Privacy Policy describes the rules of processing information about you, including personal data and cookies.

The data we process are: DATA OF CLIENTS of WR DIGITAL Sp. z o.o. These are the data of recipients of services and products of WR DIGITAL Sp. z o.o., processed in order to perform a sales agreement, consisting of providing clients with products and services.

Your data will be properly secured. The Data Administrator makes every effort to ensure all physical, technical, and organizational measures to protect personal data against accidental or intentional destruction, accidental loss, alteration, unauthorized disclosure, use, or access, in accordance with all applicable laws.

You have the right to change your consent regarding the scope of data processing or to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing based on your consent before its withdrawal.

In accordance with GDPR, you have the right to:
• access your data and obtain a copy of it;
• rectify, correct, and supplement your data;
• restrict data processing and review the data;
• delete your data;
• object to data processing;
• transfer your data.

2. DEFINITIONS

Administrator – the administrator of your personal data is WR DIGITAL Sp. z o.o. with its registered office at ul. Stefana Batorego 18, unit 108, 02-591 Warsaw, entered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw, XII Commercial Division of the National Court Register under KRS No. 0001093319, NIP No. 7011193762, REGON No. 528031635.

Personal data – all information about an identified or identifiable natural person through one or several specific factors determining physical, physiological, genetic, psychological, economic, cultural, or social identity, including image, voice recordings, contact details, location data, information contained in correspondence, information collected through recording devices or other similar technologies.

Policy – this Privacy Policy.

Regulation 2016/679, GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.

Data subject – any natural person whose personal data is processed by the Administrator, e.g., a person visiting the Administrator’s premises or sending a query via e-mail.

Profiling – any form of automated processing of personal data consisting of using personal data to evaluate certain personal factors, in particular to analyze or predict aspects regarding work performance, economic situation, health, personal preferences, interests, reliability, behavior, location, or movement.

Potential clients – entities to which the services offered by the Administrator are promoted, including sole proprietors, representatives, employees, collaborators of potential clients, regardless of their legal form.

Clients – entities using the services offered by the Administrator in the course of its business activity, including sole proprietors, representatives, employees, collaborators of clients, regardless of their legal form.

Contractors – entities whose services are used by the Administrator, including sole proprietors, representatives, employees, collaborators of contractors, regardless of their legal form.

3. GENERAL INFORMATION REGARDING DATA PROCESSING BY THE ADMINISTRATOR

Below is general information regarding data processing by the Administrator. They apply to all data subjects whose data are processed. Detailed purposes of processing can be found in section 4 of the Policy.

3.1. The Administrator of your personal data is WR DIGITAL Sp. z o.o., ul. Stefana Batorego 18, unit 108, 02-591 Warsaw, e-mail: info@wrdigital.pl

3.2. You have the right to access your data and request their rectification, deletion, restriction of processing, as well as the right to data portability.

3.3. You have the right to object to processing based on the legitimate interest of the Administrator, on grounds relating to your particular situation.

3.4. You have the right to lodge a complaint with the supervisory authority for data protection if you consider that the processing of your personal data violates Regulation 2016/679.

3.5. Your data will not be subject to profiling.

4. DETAILED INFORMATION REGARDING DATA PROCESSING

Your personal data will be processed:

4.1. For the purpose of performing a contract with the Administrator – legal basis: necessity to perform the contract (Art. 6(1)(b) GDPR).

4.2. For the purpose of fulfilling the Administrator’s legal obligations, in particular arising from tax and accounting regulations – legal basis: compliance with legal obligations (Art. 6(1)(c) GDPR).

4.3. For the purpose of direct marketing of the Administrator’s own products – legal basis: legitimate interest of the Administrator (Art. 6(1)(f) GDPR).

4.4. For the purpose of establishing, pursuing, or defending legal claims – legal basis: legitimate interest of the Administrator (Art. 6(1)(f) GDPR).

4.5. For the purpose of participation in conferences/trainings/seminars organized by the Administrator – legal basis: legitimate interest of the Administrator (Art. 6(1)(f) GDPR).

4.6. For handling inquiries – legal basis: legitimate interest of the Administrator (Art. 6(1)(f) GDPR).

4.7. For other purposes necessary to fulfill obligations towards clients and contractors of WR DIGITAL Sp. z o.o.

4.8. Personal data will be transferred to entities providing services to the Administrator, such as: accounting and tax services, HR and payroll, consulting, IT systems providers and IT services, postal operators and couriers, legal services, marketing services, conference/event participants.

4.9. Personal data will be processed until the contract is completed or, in the case of direct marketing, until you object. The processing period may be extended by the limitation period for claims if processing is necessary for the establishment or defense of claims. After that, data will be processed only as required by law (e.g., tax and accounting regulations).

4.10. Providing personal data is required by the Administrator for the purpose of concluding a contract and ongoing cooperation. The consequence of not providing the data is the inability to conclude a contract.

4.11. Providing personal data is voluntary. Not providing them prevents the Administrator from conducting marketing activities.

4.12. Personal data provided by data subjects in contact forms or via e-mail to info@wrdigital.pl

5. EXERCISING DATA SUBJECTS’ RIGHTS

5.1. Proceedings regarding the exercise of data subjects’ rights are free of charge.

5.2. A request may be submitted in writing to: WR DIGITAL Sp. z o.o., ul. Stefana Batorego 18, unit 108, 02-591 Warsaw, or via e-mail: info@wrdigital.pl

5.3. If the Administrator cannot identify the applicant based on the request, additional information or a specific form of request may be required.

5.4. A response should be given within one month of receipt. If it is necessary to extend this period, the Administrator will inform the applicant of the reasons for the delay.

5.5. The response is provided by traditional mail unless the request was submitted by e-mail and the Administrator decides to respond in the same form.

6. ADMINISTRATOR’S LOGS

Information about user activity on the website may be logged. These data are used for site administration.

7. IMPORTANT MARKETING TECHNIQUES

The operator uses statistical analysis of site traffic via Google Analytics (Google Inc., USA). No personal data are transmitted — only anonymized information.

7.1. Remarketing techniques may be used to adjust advertising messages. No personal data are transferred to advertisers. Cookies must be enabled for these actions.

7.2. The operator uses the Facebook Pixel. This means Facebook Inc. (USA) knows that a registered person uses the website. The operator does not provide Facebook with any additional personal data.

7.3. The operator uses tools for analyzing user behavior (e.g., heatmaps, session recordings). This information is anonymized before being sent. Passwords and other sensitive data are not recorded.

7.4. The operator uses automation tools, e.g., sending an e-mail after visiting a specific subpage, if the user has consented to receive commercial correspondence.

8. COOKIES INFORMATION

8.1. The website uses cookies.

8.2. Cookies are text files stored on the user’s device. They usually include the website name, storage time, and a unique ID.

8.3. Cookies are placed by and accessible to the website operator.

8.4. Cookies are used to:
• maintain user sessions (after logging in),
• achieve marketing and analytical purposes.

8.5. The site uses session cookies and persistent cookies.

8.6. Browsers usually allow cookies by default, but settings can be changed.

8.7. Restricting cookies may affect site functionality.

8.8. Cookies may also be used by partners of the site operator, e.g., Google, Facebook, Twitter.

9. MANAGING COOKIES – EXPRESSING AND WITHDRAWING CONSENT

9.1. If the user does not wish to receive cookies, browser settings can be adjusted. Blocking essential cookies may make using the website difficult or impossible.

9.2. Instructions for managing cookies are available in browser documentation (Edge, Internet Explorer, Chrome, Safari, Firefox, Opera, Android, iOS, Windows Phone).

10. FINAL PROVISIONS

10.1. To ensure integrity and confidentiality of data, the Administrator provides access only to authorized persons, in a scope necessary for their tasks.

10.2. The Administrator reserves the right to amend this Privacy Policy. Changes are effective upon publication on wrdigital.pl. Users are encouraged to review the Policy periodically.

10.3. The Administrator is not responsible for the content, functioning, or security of external websites linked from this site. Users should review the privacy policies of such external websites.