PRIVACY POLICY

1. Our Privacy Policy (“Privacy Policy”) advises in what way we gather, use and protect the personal data that You provide to us, and informs about Your rights connected with the personal data we process (“You”, “Your Data”).

2. Your Data is managed by A.J. Żmuda-Trzebiatowscy Doradztwo Podatkowe Spółka z ograniczoną odpowiedzialnością, registered in Warsaw, ul. Piękna 15 (“Administrator”)

3. The Administrator respects privacy of all visitors to our Website and all sub websites (“Website”).

4. The Administrator undertakes to comply with the confidential character of the data collected in the course of visiting the Website.

5. Your Personal data shall be processed pursuant to requirements of law, including the Personal Data Protection Act of 10 May 2018 (Journal of Laws of 2018, item 1000), and requirements laid down in 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 (OJ L 119, 4.5.2016, p. 1; “GDPR”).

6. The Administrator collects data if, amongst other things, You have registered on the Website via a dedicated registration form, contact form, application form, or signed up to a newsletter, etc.

7. Your personal data is processed for the purpose of
(i) site use monitoring and enforcing of compliance with the terms of use of the Website
(ii) website administration and management
(iii) data aggregation for the purposes of analysis and Website improvement
(iv) communication with You, including marketing activities, and for any other reason that is in conformity with the statutory requirements, where such communication is necessary to discharge contractual provisions, and for the purposes of direct marketing involving the Administrator’s own services, pursuant to art 6, para 1, pt b and pt f of the GDPR
(v) providing services through the Website and for the purposes listed in the relevant dedicated forms available on our website, including (i) subscription to an information distribution service, including commercial information and personal targeting of such information which might involve data analysis and profiling for marketing purposes (ii) business enquiries (iii) requests for a quote (iv) distribution of publications / materials (v) registration for events (conferences, webinars etc.) (vi) participation in recruitment processes including in particular submission of recruitment documents, as CV.

8. Depending on how you use the Website, You may be asked to provide more or less information, including personal data, necessary to fulfill Your wishes / requests.

9. If You wish to use the services provided by the Website, You may be asked to provide data that will facilitate contact, in particular Your full name, position, electronic mail address and telephone number.

10. Your Personal data will be kept only for a period which is necessary. The Administrator will process the personal data provided by You for direct marketing purposes as long as it is necessary to fulfill Your request / demand, unless You provide a prior objection to the processing of Your personal data for this purpose. Providing personal data is voluntary, but necessary for the provision of the services.

11. Depending on the decision made when completing the given form on the Website, the personal data provided, in particular an e-mail address and a mobile phone number, may be used by the Administrator to send periodical marketing information, commercial information within the meaning of the Act of 18 July 2002 on the provision of electronic services (Journal of Laws of 2017, item 1219 – consolidated text as amended) and the Act of 16 July 2004 – Telecommunications Law (Journal of Laws of 2017, item 1907 – consolidated text as amended).

12. In disseminating any marketing information and our newsletter we aim to adapt our marketing information as much as possible to the user’s business and professional preferences. The Administrator does not make any automated decisions as set out in art 22 of the GDPR. The Administrator analyses Your business and professional preferences in order to ensure an optimal fit between Your preferences and any marketing information or any services offered by the Administrator.

13. The Administrator does not collect Your personal data for the purpose of their transfer or sale to external entities for marketing purposes. The personal data stored by us may be transferred for other strictly necessary purposes to the following entities (i) law enforcement authorities, regulatory authorities and other government authorities or third parties if the requirement to transfer data results from applicable law (ii) external organizations providing applications / functionalities or providing data processing services or IT services,

14. You are entitled to submit a request to exercise Your rights in written or electronic form on the contact form available on the Website. This does not exclude the right to submit a request in a different form, which is acceptable and can be documented by the Administrator. Your request should always indicate what personal data and actions are involved in the scope of the request. In a situation when the lodged request is not specified precisely the Administrator shall ask You to specify Your request. If the request is left unspecified, the Administrator has the right to suspend the fulfillment of the request until he obtains sufficient information from You. The submitted request is processed in accordance with this Privacy Policy, within a reasonable period taking into account the costs, the level of difficulty of the request and the principles set out in this Privacy Policy. A response to the request will be given with no undue delay, no later than one month after receipt of the request, and will contain information on the action taken in connection therewith. If it is necessary to extend this deadline, at the latest within one month of receipt of the request, the Administrator provides You with information about the extension of the deadline for considering the request and provides reasons for the delay. The extension cannot take more than two months. If Your request is not granted, at the latest within one month of receipt of the request, the Administrator will provide information about refusal to take action in relation to the request, reasons for inaction, possibility of lodging a complaint to the supervisory body and using legal protection measures before the court. The Administrator communicates with You in Polish. If a language other than Polish is used normally in communication with You, the Administrator will answer in that language.

15. You are entitled to obtain from the Administrator confirmation whether the Administrator processes Your personal data, and if this is the case, You are entitled to access the data and the following information (i) the purpose of processing (ii) categories of the processed personal data (iii) recipients or categories of recipients to whom the personal data have been or may be disclosed, in particular recipients in third countries or international organizations (iv) the planned period of personal data processing, if possible, and when this is not possible, the criteria for determining this period, assuming that this period is limited to the necessary minimum (v) the right to require the Administrator to rectify, delete or limit the processing of Your Data and to raise objections to such processing (vi) the right to lodge a complaint to the supervisory body with regard to personal data if You believe that the processing violates Your rights (vii) if personal data have not been collected from You – all information about their source (viii) information on automated decision-making, including profiling, relevant information on the rules of decision-making, and on the importance and anticipated consequences of such processing for You.

16. You have the right to request the Administrator to immediately correct personal data concerning him which are incorrect. You have the right to request supplementing incomplete personal data, also by submitting an additional statement.

17. In the event that the You want to exercise the right to request the erasure of Your data, such a request should be expressed in the form of a clear statement indicating the scope of the request.

18. The Administrator may not grant the data erasure request resulting from the withdrawal of consent You, if Your consent was not the only condition for the processing of Your data, in particular when the purpose of data processing remains to be the implementation of the contract binding You and the Administrator, or processing of these data is necessary to fulfill the legal obligation of the Administrator.

19. The processing of personal data by the Administrator despite the request for erasure is legal, if it is necessary in particular to comply with the legal obligation for the Administrator, to perform by the Administrator tasks in the public interest, for statistical purposes or for the establishment, exercise or defense of claims.

20. You have the right to request the Administrator to limit his data processing, expressed in the form of an explicit statement indicating the scope of the request. The restriction of data processing by the Administrator may be effected, in particular, by marking stored personal data in the system in order to restrict their future processing. Personal data the processing of which has been restricted may be processed by the Administrator, with the exception of storage, only (i) based on Your consent (ii) to establish, exercise or defend claims, or to protect the rights of another natural or legal person (iii) due to important reasons of public interest of the European Union or a Member State. You receive personal data, which You have provided to the Administrator, in a structured, commonly used and machine-readable format and You have the right to request that those data be transmitted to another controller. You have the right to transmit those data to another controller without hindrance from the Administrator.

21. You have the right to request the transfer of data only in relation to the data that You provided to the Administrator Yourself. The data to be transferred are (i) data processed by the Administrator in an automated manner. Data in paper collections are not transferred (ii) data that has been provided to the You knowingly and actively. The Administrator will ensure the possibility of obtaining a file containing data to be transferred to Your private device.

22. If You have an objection, You should indicate the specific purpose of data processing You oppose to and explain Your particular situation.

23. The Administrator grants the objection or refuses to grant it, after analyzing whether the particular situation of You is overriding the legitimate grounds for processing by the Administrator. Pending the analysis, the Administrator, at the explicit request of You, applies the processing restriction on the basis of Article 18(1) GDPR. When refusing to grant the objection, the Administrator explains to You in an accessible way the reasons for which he believes that the interests, rights and freedoms of You are not overriding.

24. The Administrator may process data for direct marketing purposes (including profiling) based on his legitimate interest. If You submit an objection to such type of processing, the Administrator will not process data for this purpose anymore.

25. The Administrator grants Your objection to the processing, filed in accordance with Article 21(1) GDPR, unless there are legitimate grounds for processing that override the right of opposition and the interests of the opponent.

26. If You believe that the processing of Your personal data violates Your rights, You may file a complaint with the supervisory body regarding personal data protection.

27. Subject to Your prior consent, the Administrator can store some information on the user’s computer using cookies.

28. Cookies are used, among other things, to: help the user log in; store selected user preferences; support the user with a view to improving the website.

29. Within the Website, two basic types of cookies are used (i) session cookies – temporary files that are stored on the user’s end device until logging out, leaving the Website or turning off the software (ii) persistent cookies – they are stored in the user’s end device for the time specified in the cookie file parameters or until they are removed by the user. In many cases, web browsers allow cookies to be stored in the user’s end device by default. The Website’s users may change their cookie settings at any time. These settings may be changed in particular in such a way as to block the automatic handling of cookies in the web browser’s settings or to inform about their every posting in the device of the Website’s user. The user may give the aforementioned consent by means of the software settings installed in the telecommunications terminal equipment used by him or by the service configuration – that is in order to disable or limit the use of cookies, You may change the settings of Your web browser. However, the consequence of such action may be malfunctioning or loss of access to certain subpages of the Website

30. The following types of cookies are used on the Website (i) enabling the use of services available on the Website (ii) used to ensure security (iii) enabling the collection of information on the use of the Website (iv) allowing remembering the settings selected by the user and personalizing the user interface (v) enabling users to provide advertising content more tailored to their interests (vi) collecting information about the use of a given website, such as pages visited by a given user and any error messages, they do not collect information enabling identification of the user, and the collected data are aggregated in such a way that they become anonymous, they are used to improve the Website’s performance. The Website uses cookies from the following suppliers: Linkedin, Google Analytics, Google Adwords, The Administrator informs that restrictions on the use of cookies may affect some of the functionalities available on the Website.

31. The user should be aware that the data transmitted on the public telecommunications network between Your device and the Website are not completely secure. The Administrator is not able to provide full protection and security of these data when communicating with the Website. Nevertheless, the Administrator guarantees that it will take appropriate actions to secure data sent to it electronically, in particular personal data provided by the user through electronic forms.

32. The Website may contain links to websites or sites of third parties. These third-party links may be related to their own service activities provided electronically and privacy principles, to which compliance the user undertakes after clicking on the link and leaving the Website.

33. Any amendment hereof will be published on the Website.

34. Should you have any questions with regard to the processing of personal data by the Administrator, please contact the Administrator at info@zt.tax.