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Privacy Policy

Hello,

If you have landed on this page, it is a sign that the protection of your personal data is important to you. We want to assure you that we care about your privacy and it is important to us. For this purpose, we have implemented not only legal but also technical measures to further strengthen its protection.

In accordance with the GDPR, below we present the rules for the processing of your personal data by us. Familiarize yourself with the most important questions regarding your personal data, and in case of any doubts or additional questions regarding the privacy policy, please contact us at: hello@twofoldefl.com

 

PRIVACY POLICY

 §1 Who is the Administrator of your personal data?

The data administrator is Sylwia Clayton running a business under the name of Sylwia Clayton Szkolenia NIP 6381652888, REGON: 241312833 address: ul. Morcinka 9/57, 43-100 Tychy, Poland. You can contact the Administrator by e-mail by writing to the following e-mail address: hello@twofoldefl.com

 

 §2 For what purpose do we collect your data and how long do we store it?

We may process your data for the following purposes:

  1. Communicating with you, including answering questions submitted via the contact form, e-mail, etc.

The data will be processed based on the legitimate interest of the Administrator in the form of communication with the Users of the Website (Article 6(1)(f) of the GDPR). Your data will be processed no longer than until you raise an objection or the business purpose ceases. Providing this data is voluntary, but necessary for communication with you. Data may also be processed for archiving purposes for internal purposes based on the Administrator's legitimate interest (Article 6(1)(f) of the GDPR) until an objection is raised or the business purpose ceases.

  1. Conclusion of the contract and its implementation (placing an order).
  2. Determining, defending and pursuing claims
  3. Implementation of legal obligations incumbent on the Administrator (including tax and archiving obligations).

The data necessary for the conclusion and performance of the contract will be processed for the duration of the contract, including the time of exercising the rights arising from the contract, such as the right to complaint under the warranty (Article 6(1)(b) and (f) of the GDPR). Providing this data is voluntary, but necessary to conclude and perform the contract.

Additional data provided in order to, among others, improving the performance of the contract will be processed no longer than until you raise an objection or the business purpose ceases to exist based on a legitimate interest in the form of customer service (Article 6(1)(f) of the GDPR).

After this period, the data will be processed for the period of limitation of claims based on the Administrator's legitimate interest in order to defend against claims, as well as to establish and pursue claims (Article 6(1)(f) of the GDPR).

If the data is necessary to fulfill the legal obligations incumbent on the Administrator (such as issuing and storing invoices) - the data will be processed for this purpose for no longer than 6 years (archiving obligations regarding accounting documents), unless the law requires a longer period (Article 6(1)(c) of the GDPR).

The data may also be archived for internal and statistical purposes until you raise an objection or the business purpose ceases based on the Administrator's legitimate interest (Article 6(1)(f) of the GDPR).

 

  1. Providing marketing information (e.g. sending a newsletter and information about services, products, promotions, free content using other tools, e.g. chatbot, by phone).

The data will be processed based on the legitimate interest of the Administrator in the form of marketing of the Administrator's products and services (Article 6(1)(f) of the GDPR). Your data will be processed no longer than until you raise an objection or the business purpose ceases to exist - whichever comes first. Providing data is voluntary, but necessary to receive marketing/commercial information.

 

For the purposes of commercial and telephone communication, I need your consent in accordance with art. 10 of the Act on the provision of electronic services. You can withdraw it at any time by clicking the link in the footer of the e-mail or by writing to me at the address given above.

 

  1. Administration and management of the website and groups on social platforms (including Facebook (Meta), Instagram, LinkedIn) in the case of data processing on social platforms, including communication with you, directing marketing content to you.

These data will be processed only when you decide to like the page / join the group / select the "Follow" option or otherwise leave your data on the platform managed by me, e.g. in the form of posting or commenting. The data will be processed for the period of existence of the page/group or until you raise an objection, which may be done by clicking the "Like", "Follow" option, deleting the comment/entry or in another way provided within the platform/page or by contacting with us. Please be advised that the rules relating to the page/fanpage/group are determined by the Administrator, while the rules of using the social networking site on which the page/fanpage/group is placed are determined by the entity managing these portals.

 

  1. Analytical and static

Data processed for analytical and statistical purposes, consisting in particular in the analysis of data obtained automatically when using the website, including cookies, are processed based on the Administrator's legitimate interest in adapting the content of the Website to the User's preferences and optimizing the use of the Website; creating statistics that help to understand how Users use the Website, which allows improving its structure and content (Article 6(1)(f) of the GDPR). The data may also be archived for internal and statistical purposes until you raise an objection or the business purpose ceases based on the Administrator's legitimate interest (Article 6(1)(f) of the GDPR).

  1. Recovering rejected carts.

In a situation where you do not complete the order, you will receive a reminder about the started but not finalized order. The data will be processed based on the legitimate interest of the Administrator in the form of servicing potential Customers and Customers (Article 6(1)(f) of the GDPR). These data will be processed for the time necessary to achieve business goals or raise an objection.

  1. Posting comments.

In relation to the data visible on our Website with the comment posted, these data are processed by us in order to administer and operate the Website and communicate with you based on the Administrator's legitimate interest (Article 6(1)(f) for the time necessary to to achieve business goals or raise objections.

  1. Promotion and marketing

If you provide us with your data, in particular in the form of an opinion on a product or service, including image data, these data will be processed based on the legitimate interest of the Administrator in the form of marketing of the Administrator's services and products and improving their quality. These data will be processed for the time necessary to achieve business goals or raise an objection. Providing data is voluntary.

  1. Collecting sensitive data

Sensitive data is collected in order to perform the contract and its proper performance based on your informed and voluntary consent (Article 9(2)(a) of the GDPR) - until the business purpose ceases to exist or consent is withdrawn. Providing data is voluntary, but it is necessary for the proper performance of the contract.

  1. Recruitment

The data may be processed for the time necessary for the recruitment process and conclusion of the contract (Article 6(1)(b) and 6(1)(c) of the GDPR), and in the case of additional data provided voluntarily - based on your consent; for the purposes of future recruitment - based on your consent, for a maximum period of 3 years (this period is counted from the end of the year in which the application was obtained). Providing personal data is voluntary, however, providing some data may be necessary to conduct recruitment, as well as to conclude a contract. The consequence of not providing this data will be the lack of implementation of the above. activities.

 

 §3 Who can we transfer your data to?

We transfer your data to other entities only when it is necessary to achieve the purposes of processing referred to in §2 and only to the extent necessary to achieve this goal. As a rule, we collect and process only the data that you have provided to us, subject to the data collected automatically (cookies). More about cookies can be found in §7.

 

If necessary, your data may be transferred to entities with which we cooperate in the implementation of the above. purposes, in particular a hosting company, a company providing the Saas selling platform, an IT company/entity managing the website, a company providing accounting and bookkeeping services, a company providing an invoicing program, a company providing newsletter services, a company providing cloud services, entities providing marketing services, entities providing administrative services, entities providing services consulting, subcontractors, lawyers, training platform, social platform, customer service platform, platform for arranging visits, platform for sharing products or providing services, other entities that support the Administrator in achieving the purposes of processing.

 

As a rule, data will not be transferred outside the EEA, subject to the situations described below. In other cases, if the data is transferred outside the EEA, it will be based on your consent, standard contractual clauses or based on other safeguards provided for in the GDPR after meeting, among others, information obligation.

Services provided by Google or Facebook (META) are generally provided by entities based in the European Union. However, due to the global nature of these entities' operations, your data may be transferred to the USA in connection with their storage on American servers (in whole or in part). Regardless, Google and Facebook have implemented safeguards provided for by the GDPR to protect personal data in accordance with the requirements of the GDPR through the use of standard contractual clauses. More information on the principles of data processing by the above-mentioned providers can be found in the Privacy Policies of each entity.

 

 §4 What rights do you have?

In connection with the GDPR, you have the right to:

  • access to your personal data,
  • rectification of personal data,
  • deletion of personal data,
  • restrictions on the processing of personal data,
  • objection to the processing of personal data,
  • transfer of personal data,
  • withdrawal of consent; withdrawal of consent does not affect the lawfulness of the processing carried out before its withdrawal.

 

If you believe that your personal data is processed contrary to applicable law, you have the right to lodge a complaint with the President of the Office for Personal Data Protection. In this case, however, I encourage you to contact me in advance to clarify your doubts.

 

§5 Is your data profiled?

The administrator analyses personal data in an automated manner using tools provided by software providers (e.g. using statistics, history) only to the extent that does not have any legal effects on you or similarly significantly affects your situation, including rights or freedoms. The purpose of data processing in an automated manner is to get to know Users' preferences (more about the analysis is indicated in the Cookie Policy chapter).

 

§6 Legal provisions applicable in the field of personal data

In matters not regulated, the relevant provisions of law, including European law (e.g. GDPR), shall apply.

 

§7 Cookies policy

The website does not automatically collect any information, except for information contained in cookie files. These data are collected in a way that prevents identification of the User, the so-called Anonymous Data.

Cookie files (so-called "cookies") are IT data, in particular text files, which are stored on the Website User's end device and are intended for using the Website. Cookies usually contain the name of the website they come from, their storage time on the end device and a unique number.

Cookies are used to adjust the content of the Website to the User's preferences and to optimize the use of the Website; creating statistics that help to understand how Users use the Website, which allows improving its structure and content.

You can make changes to your cookie settings yourself. In many cases, the web browser allows cookies to be stored on the User's end device by default. Detailed information on the possibilities and ways of handling cookies are available in the software (web browser) settings. Failure to consent to cookies may limit the operation of some functionalities on the Website.

 

The Administrator uses technologies that monitor actions taken by the User within the Website:

  • Facebook conversion pixel (Meta) provided by Meta Platforms Ireland Limited - to manage ads on Meta and conduct remarketing activities; Facebook Pixel is a piece of code published on a website that allows you to reach a target group based on the data of people who have used the website. As part of the Facebook Pixel function, it is therefore possible to display published advertisements on the Meta portal only to users of the portal who have shown interest in products or services or have common factors for the above. people. These data are processed based on the Administrator's legitimate interest (Article 6(1)(f) of the GDPR). Detailed information on the Facebook Pixel can be found on the Facebook Privacy Policy (Meta) page.

 

  • Google tools, including Google Analytics provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. Data obtained as part of the use of the above-mentioned I use the tools to analyze the statistics of the Website. Google Analytics uses its own cookies to analyze the actions and behavior of Website Users. These files are used to store information, e.g. from which page the User came to the current website. Help to improve the Site; These data are processed based on the Administrator's legitimate interest (Article 6(1)(f) of the GDPR). Detailed information on the Facebook Pixel can be found on the page on the rules of using Google tools.

 

§8 Social plugins

The Website uses plug-ins, widgets and other social tools provided by portals such as: Facebook (Meta), Instagram, Google, YouTube, LinkedIn. The rules regarding the processing of personal data are described directly on the pages of the abovementioned websites. service providers.

 

§9 Joint administration

The data processed for the purposes of statistics collected within the Facebook (Meta) platform are co-administered by the Administrator and Meta Platforms Ireland Limited, with its registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland, hereinafter referred to as the Co-Administrator. Detailed rules regarding the co-administration of data, including information on the rights, are described on the Privacy Policy page.

 

The data processed within the LinkedIn platform are co-administered by the Administrator and LinkedIn Ireland Unlimited Company, address: Legal Dept. (Privacy Policy and User Agreement), Wilton Place, Dublin 2, Ireland, hereinafter referred to as the Joint Controller. Detailed rules regarding the co-administration of data, including information on the rights, are described on the Privacy Policy page.

 

The Administrator processes data based on the Administrator's legitimate interest in conducting analyses of Users' activity, as well as their preferences, in order to improve the functionalities and services provided. In matters relating to personal data, you can contact both the Administrator and the Co-administrator.

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