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ALEET’S Privacy Policy
We have updated our Privacy Policy to provide even better protection for your data. Last update: 26.01.2024.
The Privacy Policy is informative and fulfills the information obligations imposed on the data controller by RODO, i.e. Regulation 2016/679 of April 27, 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 (General Data Protection Regulation).
Anyone who uses the website at www.aleet.co and the Aleet application should read the Privacy Policy. The Privacy Policy sets forth the rules for the processing of personal data of persons using the aforementioned website or Aleet application and the use of cookies and other tracking technologies used in connection with the operation of the website.
1. Administrator of personal data
- The controller of personal data is ALEET Sp. Z O.O. with its registered office in Lublin (20-109) at Królewska 3, entered in the Register of Entrepreneurs of the National Court Register under KRS number: 0000720768, NIP: 7010805080, REGON: 369567896, with share capital of PLN 49 400,00 (hereinafter referred to as “Aleet”).
- Any data subject may contact Aleet, which is the controller of his/her personal data, by sending a message to the e-mail address: gdpr@aleet.co or by letter sent to the address indicated in paragraph 1.1. above.
2. Method of data processing
- The purpose and scope of processing of personal data is determined by the scope of consents and data provided by the data subject in an e-mail message, contact form or otherwise. The processing of personal data that Aleet processes may concern, in particular: first and last name, electronic mail (e-mail) address, telephone number, computer IP address, as well as other data voluntarily provided.
- The scope, purposes and legal grounds for processing personal data are presented in the table below.
| Purpose of processing | Range of data | Legal basis | Data processing time |
|---|---|---|---|
| providing access to the website | IP address | Article 6(1)(b) of the RODO – processing is necessary for the performance of a contract to which the data subject is a party, or to take action at the request of the data subject prior to entering into a contract | Until the expiration of the statute of limitations for claims related to access to the website |
| conducting correspondence in the form of electronic messages | e-mail address, first name, last name, organization name, other personal data voluntarily provided by the data subject | Article 6(1)(f) of the RODO – the legitimate interest of the controller in handling inquiries and correspondence addressed directly by data subjects | Until the correspondence is terminated or the data subject objects |
| telephone contact With data subjects; conducting telephone calls |
telephone number, other personal data voluntarily provided by the data subject | Article 6(1)(f) of the RODO – the legitimate interest of the controller in handling inquiries and correspondence addressed directly by data subjects | Until such time as the discussions are concluded or the data subject objects |
| undertaking marketing activities | email address | Article 6(1)(f) RODO – the administrator’s legitimate interest in providing information about its activities | Until the data is no longer useful or the data subject objects |
| website traffic survey | IP address, cookies like: _utma, _utmb, _utmc, _utmz , PHPSESSID | Article 6(1)(a) of the RODO – consent of the data subject | Until the data is no longer useful or the data subject withdraws consent |
| Newsletter mailing | email address | Article 6(1)(b) RODO – performance of a contract or taking action at the request of the data subject prior to entering into a contract | Until the data is no longer useful or the contract the subject of which is the sending of the Newsletter is terminated |
| protection from claims, referral of claims | e-mail address, first name, last name, other data voluntarily provided by the data subject | Article 6(1)(f) of the RODO – legitimate interest of the administrator to protect against claims and to direct claims | until the expiration of the statute of limitations for claims related to access to the website and users’ activities on the website, calculated from the last time the user in question visited the website |
| conclusion of the agreement with Aleet | name, surname, address, e-mail address, billing information, tax ID number | Article 6(1)(b) of the RODO – processing is necessary for the performance of a contract to which the data subject is a party, or to take action at the request of the data subject prior to entering into a contract | to the expiration of the statute of limitations for claims related to access to the Aleet application |
| providing access to the Aleet application | login or e-mail address, first name and surname | Article 6(1)(b) RODO – processing is necessary for the performance of the contract | to the expiration of the statute of limitations for claims related to access to the Aleet application |
| Automatic matching language of the website to users. | IP address,email address, user language preferences | Article 6(1)(b) RODO – performance of a contract or taking action at the request of the data subject prior to entering into a contract | Until the data is no longer useful or the data subject withdraws consent |
- Aleet does not process personal data within this website for the purpose of automated decision-making, including profiling.
- In order to fulfill some of the processing purposes indicated in the table above, Aleet may transfer personal data to third countries. In this case, this will always be done on the basis of standard contractual clauses in accordance with the European Commission’s decision, in which both Aleet and its contractors undertake to ensure an adequate degree of security for the personal data transferred. Before signing the standard contractual clauses, Aleet verifies each of its contractors that will have access to personal data, as well as assesses whether the country receiving the personal data allows for the enforcement of rights and provides data subjects with effective legal remedies.
- If the European Commission issues a decision on whether a third country provides an adequate level of protection for personal data, then transfers of personal data to that country may also proceed on the basis of that decision.
- If it is not possible to apply the standard contractual clauses and there is no decision of the European Commission, then the transfer of personal data will only take place in specific situations, by which is meant the need to perform a contract that has been concluded between the data subject and Aleet, or the implementation of pre-contractual measures. Also in this situation, Aleet shall thoroughly vet each of its contractors who will have access to the data subject’s personal data to ensure maximum security.
- In any case of transfer of personal data to a third country, the data subject is entitled to obtain a copy of the data.
3. Data recipients
- Aleet may entrust the processing of personal data to third parties to perform certain activities. Then the recipients of individual data may be: a hosting provider for Aleet, an email service provider, an IT company, a software provider, an email service provider, a law firm, an accounting firm, entities providing cloud solutions, and other solutions used by Aleet in its day-to-day operations that involve the processing of personal data.
- Personal data collected by Aleet may also be made available: to relevant state authorities upon their request under relevant laws, or to other persons and entities – in cases provided by law.
- Each entity to which Aleet entrusts personal data for processing, based on the entrustment agreement for the processing of personal data (hereinafter “Entrustment Agreement”) guarantees an adequate level in terms of security and confidentiality of personal data processing. An entity that processes personal data of data subjects based on the Entrustment Agreement may process personal data of such data subjects, through another entity, only on the basis of Aleet’s prior consent.
- Sharing of personal data with unauthorized entities according to this Privacy Policy, may only take place with the prior consent of the data subject.
4. Rights of data subjects
- Every data subject has the right to: (a) to have the personal data collected about him/her erased both from the system belonging to Aleet and from the databases of entities with which Aleet cooperates or has cooperated, (b) to have the processing restricted, (c) to have the personal data collected by Aleet transferred, including to receive it in a structured form, (d) to request from Aleet access to his/her personal data and to have it rectified, (e) to object to the processing, (f) to revoke Aleet’s consent at any time without affecting the legality of the processing performed on the basis of consent before its revocation; (g) lodge a complaint against Aleet to the supervisory authority (President of the Office for Personal Data Protection).
- The exercise of the rights of data subjects may be carried out in particular through the communication channels referred to in paragraph 1.2. of this Privacy Policy.
5. Other data
- Aleet may store http requests, and therefore some information may be stored in the server log files, including the IP address of the computer from which the request came, the station name of the data subject – identification carried out by the http protocol, if possible, the date and system time of registration on the Aleet site and arrival of the request, the number of bytes sent by the server, the URL of the site previously visited by the data subject if he/she entered the Aleet site using a link, information about the browser, information about errors that occurred during the execution of the http transaction. Logs may be collected as material for the proper administration of Aleet. Only persons authorized to administer the computer system have access to the information. Log files may be analyzed to compile statistics of traffic on the Aleet website and errors that occur. A summary of such information does not identify an individual.
- Aleet may use Google Analytics and other analytical tools, whereby it has access to anonymized information about Users, including: information about the operating system and web browser, time spent on the website age range, gender, approximate location, interests, based on its activity on the Internet. The information referred to in the preceding sentence is not combined with personal data and does not allow for its identification and is not personal data within the meaning of the provisions of the RODO.
6. Security
- Aleet cares about the security of personal data. In particular, Aleet uses technical and organizational measures to ensure the protection of the processed personal data appropriate to the risks and categories of protected data, including technical and organizational protection of data against their access to unauthorized persons, taking by an unauthorized person, processing in violation of the Act, and change, loss, damage or destruction, among others, SSL certificates are used. The collection of collected personal data is stored on a secure server, and data is also protected by Aleet’s internal procedures on personal data processing and information security policy.
- Aleet has also implemented appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and to give the processing the necessary safeguards to meet the requirements of the RODO and protect the rights of data subjects.
- Notwithstanding the above, Aleet points out that the use of the Internet and electronically provided services may be at risk of malicious software (malware) entering the ICT system and device of the user in question, as well as unauthorized access to data, including personal data, by third parties. In order to minimize these risks, the data subject should use appropriate technical safeguards, e.g. using up-to-date anti-virus software or protecting his/her identification on the Internet. In order to obtain detailed and professional information regarding the preservation of security on the Internet, Aleet recommends seeking it from entities specializing in such IT services.
7. Cookies
- In order for the website to function properly, Aleet uses cookie technology. Cookies are text information stored on a given user’s device (computer, tablet, smartphone), via Aleet, usually containing information consistent with the purpose of the file, by means of which a given user uses the Aleet website – these are usually: service address, date of posting, expiration date, unique number and additional information consistent with the purpose of the file.
- Aleet uses two types of cookies: (a) session cookies, which are deleted permanently when the browser session ends; (b) persistent cookies, which remain after the browser session ends until they are deleted.
- Based on Cookies, both session and permanent, it is not possible to determine the identity of a given user. The Cookies mechanism does not allow the collection of any personal data.
- Aleet Cookies are safe for the device of a given user, in particular, they do not allow viruses or other software to enter the device.
- Cookies generated directly by Aleet cannot be read by other services. External Cookies (i.e. Cookies placed by entities cooperating with Aleet) can be read by an external server.
- A given user may change his/her own settings regarding Cookies at any time, specifying the conditions for their storage, through the settings of the Internet browser or through the configuration of the service.
- First of all, the given user may disable the storage of Cookies on his/her device, according to the instructions of the browser manufacturer, but this may result in the unavailability of some or all of the functions of the Aleet website.
- The given user may also delete the Cookies stored on his/her device at any time on his/her own, according to the instructions of the browser manufacturer.
- Aleet uses its own Cookies for the following purposes: to configure the website and adapt the content of the pages to the preferences or behavior of the respective user; to analyze and study the audience, the number of clicks and the path through the website in order to improve the design and organization of the content on the website, the time spent on the website, the number and frequency of visitors to the Aleet website.
- Aleet uses external cookies to create anonymous statistics to optimize the website, through analytical tools in the for of Google Analytics, referred to paragraph 5b) above.
- Detailed information on the handling of Cookies is available in the settings of the Internet browser used by the data subject.
- The website www.aleet.co is constructed using specialized software that translates the website into a specific language to facilitate its construction. Simultaneously, the plugin retrieves language preferences stored in the user’s web browser. The program checks the recently used language to tailor and memorize the preferences of the last logged-in user, making it easier for them to access the website. The WPML Translation Management plugin transmits the email address, name of each manager, assigned translator, as well as the content itself to the Advanced Translation Editor and the translation services used.
8. Final provisions
- This Privacy Policy is effective as of 9.02.2022.