Privacy Policy

PRIVACY POLICY OF SIMPLITO SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ

We operate in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (General Data Protection Regulation, hereinafter: Regulation). That is why we have created this privacy policy, in which we have outlined the most important principles related to the processing of your personal data.

1. Who is the controller of your personal data?

The data controller of your personal data is Simplito spółka z ograniczoną odpowiedzialnością with its registered office in Toruń, address: ul. Grudziądzka 1-3, 87-100 Toruń, entered in the Register of Entrepreneurs of the National Court Register by the District Court in Toruń, 7th Commercial Division of the National Court Register, under KRS number: 0000305883, NIP (Tax Identification Number): 9562217643, REGON (National Business Registry Number): 340400555, share capital: PLN 336 073,60.

2. How can you contact the Data Controller?

You can contact the Data Controller in the following ways:

by sending an email to: office@simplito.com,
by post, by sending a letter to the following address: Simplito sp. z o.o., ul. Grudziądzka 1-3, 87-100 Toruń.

3. On what basis and for what purpose do we process your personal data?

We may process personal data for the following purposes and on the following legal bases:

Scope of processing	Purpose of processing	Legal basis
If you visit the website	We process your personal data in order to ensure the proper functioning of the website, to counteract any activities that are contrary to generally applicable laws and, if you consent to analytical cookies, to analyze website traffic and create statistics concerning the use of the website with the use of Google Analytics. We may process, in particular, data contained in website visit logs and cookies or similar technologies, such as your IP address, information about your device and browser, identifiers, and information about your activity on the website.	The legal basis for processing data necessary to ensure the proper and secure functioning of the website and to prevent fraud and violations of law is Article 6(1)(f) of the Regulation. The legitimate interest of the controller is to operate and secure the website and prevent abuse. To the extent that Google Analytics uses analytical cookies or similar technologies, the legal basis for processing is your consent pursuant to Article 6(1)(a) of the Regulation. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before its withdrawal.
If you use the contact form or chat feature on the website, send us a message to the email address provided on the website, or contact us by mail	We process your personal data for the purpose of contacting you and exchanging messages.	The legal basis for data processing in this regard is Article 6(1)(f) of the Regulation, which allows data processing when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. The legitimate interest of the controller in this case is the need to process data in order to contact individuals and respond to their questions.
If you contact us to establish cooperation or are already our Customer, Supplier, Service Provider, or cooperate with us on the basis of a civil law contract	We process your personal data for the purpose of concluding or performing a contract between us and you—our Customer, Supplier, or Service Provider. If you contact us to establish cooperation with us, we process your personal data in order to take action at your request prior to entering into a contract. If you are already our Contractor, we process your personal data for the purpose of performing our contract. In addition, in such a case, we process your data in order to fulfill our legal obligations in connection with the conclusion and performance of contracts, in particular accounting and tax obligations.	The legal basis for the processing of personal data is Article 6(1)(b) of the Regulation, which allows for the processing of data when it is necessary for the conclusion and performance of a contract to which the data subject is party, or for taking action at the request of the data subject prior to entering into a contract. To the extent that data processing relates to the fulfillment of our tax and accounting obligations, we process it on the basis of Article 6(1)(c) of the Regulation, which allows for the processing of data when it is necessary for compliance with a legal obligation to which the controller is subject.
If you subscribe to our newsletter or otherwise request marketing or informational communications from us	We process your personal data, in particular your email address and any other data provided during subscription, in order to manage the subscriber list, send you the newsletter and other requested communications, and analyze the delivery and use of such communications. We use MailerLite to manage the subscriber list and distribute the newsletter. You may unsubscribe at any time by using the unsubscribe link included in each newsletter or by contacting us.	The legal basis for processing your personal data for newsletter purposes is your consent pursuant to Article 6(1)(a) of the Regulation. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before its withdrawal.
If you register for or use any of our services, create a user account, or otherwise provide your personal data in order to obtain access to a service or its functionality	We process your personal data in order to create and maintain your account, verify your identity where necessary, provide access to the service and its functionality, communicate with you in matters relating to your account or the service, and provide the service requested by you.	The legal basis for processing your personal data is Article 6(1)(b) of the Regulation, as processing is necessary to take action at your request before entering into a contract or to perform a contract concerning the use of the service.
If you request access to software made available free of charge under a licence that requires account registration and obtaining or activating a licence key	We process your personal data in order to register your account, verify your entitlement to use the software, generate, issue, activate and manage the licence key, provide access to the software, and provide support relating to the licence.	The legal basis for processing your personal data is Article 6(1)(b) of the Regulation, as processing is necessary to take action at your request or to perform a licence agreement concerning the use of the software.
If you register for or participate in an event, presentation, conference, webinar, workshop, or another event organized or co-organized by us	We process your personal data in order to register participants, organize and conduct the event, communicate organizational information, confirm attendance, provide access to the event or event materials, and handle matters relating to participation.	The legal basis for processing your personal data is Article 6(1)(f) of the Regulation. The legitimate interest of the controller is to efficiently organize and conduct events, communicate with participants, document participation where necessary, and ensure the proper organization and security of the event.
If you are a person acting on behalf of our Customer, Supplier, or Service Provider (i.e., an entity that has entered into a contract with us) and are therefore contacting us as a representative of the Customer, Supplier, or Service Provider (e.g., as a member of the management board, employee, or associate).	We process your personal data for the purpose of concluding or performing a contract between us and the Customer, Supplier, or Service Provider.	The legal basis for the processing of your personal data is Article 6(1)(f) of the Regulation, which states that data processing is permissible when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. The legitimate interest of the controller in this case is precisely the performance of the agreement between us and our Customer, Supplier, or Service Provider, which requires contacting representatives of the Customer, Supplier, or Service Provider.
If you contact us to participate in the recruitment process, you fill out our recruitment form or send us your CV.	We process your personal data for the purpose of conducting the recruitment process. Additionally, if you agree, we process your data to contact you in future recruitment processes.	The legal basis for the processing of personal data in the recruitment process is Article 6(1)(b) of the Regulation, which allows the processing of personal data when it is necessary for the conclusion of a contract with the data subject. The scope of the data processed is based on the provisions of the Labor Code, which specifies the basic data that an employer may require in the recruitment process. If you provide other data that is not covered by the provisions of the Labor Code, the legal basis for the processing of personal data is Article 6(1)(a) of the Regulation, which allows for the processing of personal data on the basis of the consent of the data subject. If you express your willingness to participate in future recruitment processes, the legal basis for the processing of personal data is also your consent.

4. Who may have access to your personal data?

In order to properly provide our services and conduct the activities described in this Privacy Policy, we use the assistance of third parties. Depending on the purpose and scope of processing, your personal data may be disclosed or entrusted, to the extent necessary, to:

providers of IT, cloud, maintenance, cybersecurity, communication, and other technical services, as well as subcontractors whose services we use in connection with our business;
the entity providing hosting services for us — OVH sp. z o.o. with its registered office in Wrocław, ul. Swobodna 1, 50-088 Wrocław;
Google Ireland Limited and Google LLC, with its registered office in Mountain View, California, USA, as entities involved in the provision of the Google Analytics service used to analyze website traffic;
MailerLite Limited with its registered office at 88 Harcourt Street, Dublin 2, D02 DK18, Ireland, as the provider of the system used to manage the subscriber list and distribute the newsletter;
providers of legal, tax, accounting, auditing, and other professional advisory services.

In connection with our use of Google Analytics, personal data may be transferred to Google LLC in the United States. The transfer of personal data to the United States is based on the adequacy decision adopted by the European Commission under the EU–U.S. Data Privacy Framework.

5. How long do we store your personal data?

We strive to store your personal data only for as long as it is actually necessary, and we delete it after that time. The storage period for your personal data depends on how you interact with us:

If you are a visitor to our website, we process your personal data for as long as you use the website and for up to 6 months after you leave it.
- If you contact us via the contact form, by phone, by email, or by regular mail, we process your personal data for as long as the contact between us lasts and for a period of 2 consecutive months.
- If you subscribe to our newsletter, we process your personal data until you withdraw your consent or unsubscribe from the newsletter. After that time, we may retain only the data necessary to demonstrate compliance with legal requirements or to establish, pursue, or defend legal claims for the applicable limitation period.
If you create an account, register for or use our services, or obtain software under a licence requiring registration and a licence key, we process your personal data for the period during which the account, service, or licence remains active and until the claims expire (up to 3 years after the account is closed or the service or licence ends).
If you register for or participate in an event, we process your personal data for the time necessary to organize and conduct the event and complete the related communications, and until the claims expire (up to 3 years after the event ends).
If you are our Customer, Supplier, or Partner (a person who has entered into a contract with us) or their representative, we process your personal data for as long as the contract between us is valid and until the claims expire (up to 3 years after the termination or expiry of the contract).
Data processed for the purpose of fulfilling accounting and tax obligations will be processed for a period of 5 years from the end of the tax year in which the tax liability payment deadline expired.
- If you are participating in the recruitment process, in the case of processing within the framework of the recruitment process, we process your data until the end of the recruitment process. However, if you have consented to participate in future recruitment processes, we will process your data for a period of up to 1 year from the date of submission of your recruitment documents.

6. What are your rights in relation to the processing of personal data?

Right of access: You may request confirmation from us that your personal data is being processed and obtain relevant information about it, including what data is being processed and for what purpose.
Right to rectification: You have the right to request the immediate rectification of inaccurate personal data and the completion of incomplete personal data.
Right to erasure: You have the right to request the immediate erasure of personal data if one of the following circumstances applies:

personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
you withdraw your consent (if the processing is based on consent) and there is no other legal basis for the processing;
you have objected to the processing and there are no overriding legitimate grounds for the processing;
the personal data has been processed unlawfully;
the personal data must be erased to comply with a legal obligation;
the personal data has been collected in relation to the offer of information society services to a child.

Right to restrict processing: You have the right to request that the processing of your personal data be restricted if:
- you contest the accuracy of the personal data;
- the processing is unlawful, but you oppose the erasure of the personal data and request the restriction of its use instead;
- we no longer need the personal data for processing purposes, but you need it to establish, pursue, or defend legal claims;
- you have objected to the processing of the data.
Right to data portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit those personal data to another controller, where the processing is based on consent or on a contract and is carried out by automated means. You also have the right to request that we transfer this data directly to another controller, if technically feasible.
Right to lodge a complaint: You have the right to lodge a complaint about unlawful processing of personal data with the supervisory authority – the President of the Personal Data Protection Office (at the address of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw).
Right to object: You have the right to object to the extent that the processing is based on our legitimate interest.
Right to withdraw consent: If personal data is processed on the basis of consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing that was carried out on the basis of consent before its withdrawal.

7. What else is worth knowing?

Your personal data will not be used for automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation.

Providing personal data is voluntary, but in the case of data processing for the purpose of concluding or performing a contract with us, failure to provide data may result in our inability to provide services. In the case of participation in recruitment, failure to provide personal data specified in the Labor Code may result in the candidate not being considered in the recruitment process.

Providing certain personal data may also be necessary in order to create or maintain an account, use a service, obtain or activate a licence key, or register for and participate in an event. Failure to provide the required data may make it impossible for us to perform the relevant activities or provide the requested service, software, licence, or access.

8. Cookies

Cookies are small files that enable or facilitate the use of certain website features. They may be stored on your device directly by us or by third parties with whom we cooperate. When using cookies, we may process personal data, in particular such as your IP address, website usage history, or information about the device or software you are using. The cookies we use are related to the functioning of our website and are used to control traffic on the website, compile statistics on the use of the website by its users, prevent errors and technical malfunctions, ensure the security of the website, and prevent abuse and violations of the law.

The following cookies are distinguished:

Session cookies: these are stored on your device while you are using our website (they are deleted when you close your browser). Session cookies enable the proper use of our website. Blocking them may result in errors or prevent you from using the website.
Persistent cookies: these are stored on your device until you delete them or until they expire.

Our website uses technical cookies. These files are necessary for the proper display, security, and functioning of the website. They may also detect irregularities in the functioning of the website, help correct errors, prevent abuse, and record or verify the scope of the user's cookie choices. Because they are necessary for the website to function properly, their use does not depend on consent. Blocking them may cause the website to malfunction.

Our website also uses analytical cookies and similar technologies connected with Google Analytics. They are used to collect information about how visitors use the website, distinguish users and sessions, measure website traffic, and prepare statistics concerning the use of the website. Analytical cookies are used only after you have given your consent.

You may give, refuse, withdraw, or change your consent to analytical cookies at any time using the cookie settings available on our website. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

Please note that you can restrict or disable cookies on your device using your web browser settings. Web browsers allow you to disable all cookies or some of them (e.g., those from third parties). If you disable some cookies, cookies generated by our website may still be stored on your device to ensure that the website functions properly. However, if you restrict the use of cookies, your use of our individual services may be limited and, in some cases, may not be possible.

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