PRIVACY POLICY OF ZROZUMIAŁA KOMUNIKACJA SP. Z O.O.

 

  • DATA CONTROLLER

The controller of personal data for:

  1. individuals visiting and using the website https://samuirs.com;
  2. individuals contacting Zrozumiała Komunikacja Sp. z o.o. via the contact form or other available communication channels;
  3. newsletter subscribers;
  4. clients, potential clients, and contractors/business partners;

is Zrozumiała Komunikacja spółka z ograniczoną odpowiedzialnością with its registered office in Gdynia, Al. Zwycięstwa 241/13, 81-521 Gdynia, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court Gdańsk-Północ in Gdańsk, VIII Commercial Department of the National Court Register, under number 0001118038, REGON: 529274200, NIP (Tax Identification Number): 5862408380 (“ZK”, “we”, “our”, “us”).

Regarding questions about data processing, you can contact us by e-mail at: team@samuirs.com.

  • PURPOSES AND LEGAL BASES FOR DATA PROCESSING

We process personal data for the following purposes:

  1. For individuals visiting and using the website https://samuirs.com:
  • ensuring the proper technical functioning of the website (Article 6(1)(b) of the GDPR);
  • profiling for the analysis of website usage statistics (Article 6(1)(f) of the GDPR).

Providing your personal data is necessary to use our website.

  1. For individuals contacting ZK via the contact form or other available communication channels:
  • responding to inquiries received (Article 6(1)(f) of the GDPR).

Providing your personal data is necessary to respond to your inquiries.

  1. For newsletter subscribers:
  • providing you with information about free educational materials, training sessions, events, and other information about our activities (Article 6(1)(f) of the GDPR).

Providing your personal data is necessary to fulfill your newsletter subscription.

  1. For clients, potential clients, and contractors/business partners:
  • pursuing our legitimate interests such as direct marketing, and the establishment, exercise, or defense of legal claims (Article 6(1)(f) of the GDPR);
  • if a decision is made to purchase real estate – performance of a contract or taking steps prior to entering into a contract to which they are a party (Article 6(1)(b) of the GDPR);
  • fulfilling our legal obligations arising from applicable law (Article 6(1)(c) of the GDPR).

Providing your personal data is necessary:

  • to the extent that processing is based on the conclusion and performance of a contract, it is necessary for purposes related to the conclusion and performance of the contract;
  • to the extent that processing is based on a legal obligation, it is a statutory requirement;
  • to the extent that processing is based on your consent, it is voluntary, and not providing such data does not result in any negative consequences for you;
  • in other respects, providing your personal data is voluntary.

We have received your personal data directly from you or from another company affiliated with us through personal or capital ties, which obtained your prior consent to share your personal data with us.

In the case of:

  1. individuals visiting and using the website https://samuirs.com, we process: IP address, data stored in cookies;
  2. individuals contacting ZK via the contact form or other available communication channels, we process: first name, last name, phone number, email address;
  3. newsletter subscribers, we process: first name and last name, email address;
  4. clients, potential clients, and contractors/business partners, we process: first name and last name, contact details, address of residence, personal data contained in the passport, personal data contained in the ID card.
  • DATA RETENTION PERIOD

We store the collected personal data for the following period:

  1. For individuals visiting and using the website:
  • we store information about your IP address for as long as the archival period in the server logs where the website is located requires.
  1. For individuals contacting ZK via the contact form or other available communication channels:
  • we store data necessary to respond to your inquiries for as long as necessary to resolve your matter;
  • additionally, we store personal data needed for the defense or pursuit of claims for as long as required by the limitation periods for claims specified in the law.
  1. For newsletter subscribers:
  • we store data necessary for fulfilling the newsletter subscription until you withdraw your consent to receive it.
  1. For clients, potential clients, and contractors/business partners:
  • we process data based on our legitimate interest until you object to such processing or until potential claims become time-barred;
  • we process data in connection with the performance of a contract or taking steps before its conclusion for the duration of said contract, for the period specified by law, and subsequently for the limitation period of potential claims;
  • we store data processed based on your consent until you withdraw that consent.
  • WHO MAY WE DISCLOSE YOUR PERSONAL DATA TO?

Below is a list of entities to whom we may disclose your personal data:

  1. For individuals visiting and using the website https://samuirs.com:
  • providers of IT services and systems that we use to operate our website;
  • legal advisors and consultants serving ZK, to the extent that disclosure of data is necessary to use their services;
  1. For individuals contacting ZK via the contact form or other available communication channels:
  • email service operators/providers;
  • postal operators and couriers;
  • providers of IT services and systems that we use for email and our website;
  • legal advisors and consultants serving ZK, to the extent that disclosure of data is necessary to use their services;
  1. For newsletter subscribers:
  • providers of IT services and systems that we use to send the newsletter;
  1. For clients, potential clients, and contractors/business partners:
  • ZK's contractors with whom we cooperate, including entities processing personal data on our behalf, also located outside the European Economic Area;
  • entities providing business support services to ZK, such as HR and accounting services, legal and advisory services, electronic equipment servicing, financial and insurance services;
  • providers of IT services and systems that we use to conduct our business;
  • entities affiliated with ZK through capital or personal ties.

Your personal data may be transferred outside the European Economic Area (EEA). If you are interested in purchasing real estate in Thailand, your personal data may be processed in Thailand by our associates (data processor). To safeguard this transfer of personal data, we have implemented appropriate safeguards, concluded Standard Contractual Clauses (SCCs), and conducted a Transfer Impact Assessment (TIA). In other cases, we may process your personal data outside the EEA, particularly in the USA, in connection with the use of various IT tools and software, based on a European Commission adequacy decision or Standard Contractual Clauses. You can always request a copy of the safeguards for data processed outside the EEA by sending an email to team@samuirs.com.

  • YOUR RIGHTS

Every individual whose data is processed by ZK has the right to:

  • request access to their personal data;
  • rectify, erase or restrict the processing of their personal data;
  • where personal data is processed automatically for the performance of a contract (Article 6(1)(b) of the GDPR): the right to data portability;
  • where personal data is processed for the conclusion and performance of a contract or based on consent - provided such data is processed automatically - the right to data portability;
  • where personal data is processed for the purposes of ZK's legitimate interests: the right to object to the processing of personal data;
  • where personal data is processed based on consent – the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal;
  • the right to lodge a complaint with the supervisory authority, i.e., the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych) in Warsaw.
  • AUTOMATED DECISION-MAKING

We do not use any information provided by you for automated decision-making purposes.

  • ANALYTICAL AND MARKETING TOOLS

We and our business partners use various solutions and tools for analytical and marketing purposes. Below is basic information about these tools. Detailed information can be found in the privacy policies of the respective partners.

GOOGLE ANALYTICS

On our website and Training Platform, we use Google Analytics. Google Analytics cookies are files used by Google to analyze how our websites and Training Platform are used, and to create statistics and reports about their functioning. Google does not use the collected data to identify users, nor does it combine this information to enable identification. Detailed information about the scope and principles of data collection in connection with this service can be found here. 

FACEBOOK PIXEL

On our websites and Training Platform, we use Facebook Pixel. Facebook Pixels is a tool that allows measuring the effectiveness of information campaigns carried out by ZK on Facebook. The tool allows for advanced data analytics to optimize our activities, also using other tools offered by Facebook. Detailed information about data processing by Facebook can be found here. 

  • COOKIES

On our websites https://samuirs.com, we use cookie technology ("cookies") and similar technologies (e.g., pixel tags).

Cookies are small packets of information saved on end devices, usually containing the website address, placement date, expiration date, a unique number, and additional information according to the purpose of the given file.

The cookies we use can be divided into 2 categories:

  • statistical and analytical files, which allow us to understand how users behave on our website using aggregated and anonymous statistical information;
  • marketing and remarketing files, which allow us to track users of our website and advertise our products online. 

You can disable the saving of cookies directly on the device used to connect to our website, according to the browser manufacturer's instructions: 

Information regarding the configuration and deletion of cookies in other web browsers can be found on their manufacturers' websites.

  • CHANGES TO THE PRIVACY POLICY

The provisions of the Privacy Policy may be subject to improvements and changes, and the latest versions will always be published on our website and marked with the date of the last update.