Personal data administrator
The administrator of your personal data is FUNDACJA SZTUKI LUTNICZEJ IM. WŁODZIMIERZA KAMIŃSKIEGO I HELENA HARAJDY, based in Poznań, UL. JÓZWY BUTRYMA 27, NIP 7792544095, KRS number 0000991377.
Hereafter, the aforementioned entity will be referred to as the “Administrator” or the “Foundation”.
What type of your data do we process?
It depends on how you use our website. This may include data such as:
– your name (if you have provided us with this data),
– data contained in correspondence addressed to us,
– your bank account number (if you have ordered something online and provided us with this email),
– your IP address,
– details of any orders you may have placed,
– your image (if you have interacted with our site via social media),
– information about your operating system and browser,
– time spent on the website,
– clicks on links,
– how you came to know of our website,
– age range,
– approximate location,
– your interests (based on your online activities).
Where from do we get this data?
You usually give it to us voluntarily, e.g. by registering for an account, placing an order, writing us an email, subscribing to our newsletter, contacting us by phone, adding a comment.
Some of the data is collected automatically if you visit our website: the website mechanism collects your IP number as well as information about the pages you visit, google analytics or fb pixel (if we use it) may collect details about your age, interests, location.
Purposes and basis of processing
We do not always use the same legal basis for processing and the same purpose.
You decide whether you buy a product from us, write us an email or just browse our website.
Below are the most common purposes for processing personal data:
– order processing – article 6(1)(b) GDPR,
– sending newsletters – article 6(1)(a) GDPR (consent),
– handling of correspondence – article 6(1)(f) GDPR,
– fulfilment of tax obligations – article 6(1)(c) GDPR,
– marketing – article 6(1)(f) GDPR,
– analysis, statistics – article 6(1)(f) GDPR,
– archiving (evidential) purposes in the event of a legal need to prove facts and for the possible establishment, investigation or defence of claims, which is our legitimate interest (Art. 6(1)(f) GDPR),
– the performance of the contractual relationship (Article 6(1)(b) GDPR), in the case of a contract with the Foundation.
User account, order
When you create an account with us, you provide at least an e-mail address and a password. We may also require more detailed data for tax and accounting purposes. If you create an account via social media, we will gain access to the data that is provided by the respective portal.
The above also applies to placing orders for our products and services (if we need to physically ship the product, for example, we also need to know your postal address and, if you are purchasing for a company, your business details.
Your personal data is then used for the performance of the contract (Article 6(1)(b) GDPR), the issuing of an invoice (Article 6(1)(c) GDPR) and for the purposes of any need to defend, establish or assert a claim, identify a returning customer (Article 6(1)(f GDPR).
You may also find that you are advertising our service/product or withdrawing from the contract – in which case you will also need to provide us with details such as your email, name, home address or bank account number to which we are to return the funds (e.g. in the event of a successful withdrawal).
Contact by email, telephone or social media naturally involves providing us with your personal data (e.g. email address, nickname, name). This data is processed by us for the purpose of contacting you, and the legal basis for the processing is our legitimate interest (Article 6(1)(f) GDPR).
For the same purposes, we archive the data provided, also in order to be able to carry out any future defence, to establish or assert claims, to identify the returning customer (Art. 6(1)(f) GDPR).
If we issue an invoice or bill to you or your organisation then we will have to store your data for the period required by law. Your data is processed to fulfil our tax and accounting obligations (Art. 1(c) GDPR). Accounting documents may also be used for the possible defence, establishment or assertion of claims, identification of a returning customer (Article 6(1)(f) GDPR).
Analysis, statistics, marketing
We collect (as everyone does) statistical data on, among other things, clicks on links, time spent on our website, time spent on sub-pages.
We use this data for website optimisation, to determine the effectiveness of our actions and also – for marketing purposes.
In most cases, the data collected is not even personal (e.g., only the time spent on the website and your location is not personal data if it is not possible to attribute this data directly to you).
Exceptionally, the aforementioned data may be personal data if, for example, you register with us.
We carry out the above activities on the basis of our legitimate interest (Article 6(1)(f) GDPR).
Recipients of data
We may share your personal data with entities with which the Foundation cooperates in the field of IT services, accounting services, cloud services, as well as the Foundation’s collaborators.
Below is the list of the most important entities with whom the Foundation cooperates and to whom your personal data may be shared:
– home.pl (home.pl limited liability company with its registered office in Kraków), for the purpose of storing data on the server where the Foundation has its mailbox (e-mail),
– Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA – in order to use Google services, in particular Google Drive and Google Docs, as part of the company’s Google Workspace (email, calendar or google meet messenger service),
– accounting company,
– possible order processing software.
The Administrator enters into personal data entrustment agreements with processors and authorises those who have access to the data on the basis of written authorisations.
Your personal data may also be transferred to Tax Offices as part of fulfilling tax obligations, and may also be transferred to other institutions (e.g. the Social Security Office) or other entities (e.g. a bank) in the event that this would be necessary to fulfil obligations imposed by law or to pursue rights.
Should there be a need for legal assistance, personal data may also be transferred to a law firm (regarding the investigation of claims or defence against claims).
Transfer of data to third countries
The Foundation uses cloud services of companies that are based outside the European Union (Google, Microsoft). As far as possible, the Administrator chooses the location of the servers so that the stored data is located exclusively within the European Union. In other cases, cloud service providers provide an adequate level of protection for personal data stored outside the EU.
Data storage period
This depends on what data we have at our disposal.
If you have provided us with data yourself (product purchase, registration) then your data will be stored until the service through which the product/service was purchased is operational, but no less than until the statute of limitations for any claims.
Invoice data will be processed until the end of the period for which accounting records are required by law to be kept. In addition, some of the data may also be processed after the expiry of the previously indicated periods for the duration of our business activities for archiving, analytical and statistical purposes as described in more detail above (purposes and grounds for processing).
Rights in relation to processing
You have the following rights in relation to the processing of your personal data:
– the right to access your data and to receive a copy of it,
– the right to rectify (amend) your data,
– the right to delete your data (if, in your opinion, there are no grounds for the Foundation to process your data, you may request that your data be deleted. Remember, however, that any such request will be verified),
– the right to restrict the processing of your data (you can request that the Foundation restricts the processing of your data only to the storage of your data or the performance of activities agreed with you, if the Foundation holds your incorrect data or processes your data unduly),
– the right to object to the processing of your data (you have the right to object to the processing of your data on the basis of a legitimate interest; you should indicate your particular situation which, in your opinion, justifies the Foundation stopping the processing covered by your objection. The Foundation will stop processing your data for these purposes unless you can demonstrate that the Foundation’s grounds for processing your data override your rights or that your data is necessary for us to establish, assert or defend claims),
– the right to data portability (you have the right to receive from us in a structured, commonly used machine-readable format the personal data you have provided to the Foundation under a contract or your consent. You can instruct us to send this data directly to another entity),
– the right to lodge a complaint with a supervisory authority (if you find that the Foundation is processing your data unlawfully, you may lodge a complaint about this with the General Data Protection Authority or another competent supervisory authority within the EU).
If you wish to exercise your rights, please address your request to the email address firstname.lastname@example.org, stating “GDPR” in the subject line of the email. If it is not possible to address e-mails, please address your requests in writing to the Foundation’s address, i.e., FUNDACJA SZTUKI LUTNICZEJ IM. WŁODZIMIERZA KAMIŃSKIEGO I HELENA HARAJDY, UL. JÓZWY BUTRYMA 27, 60 – 177 POZNAŃ
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