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PRIVACY POLICY v.1.0.0

We take the confidentiality of the data entrusted to us for processing and the protection of our clients’ privacy extremely seriously. That is why, in accordance with Article 13(1) and (2) of 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 (“GDPR”), we inform you that we process your personal data.

Who are we?

Our full details are: 25WAT spółka z ograniczoną odpowiedzialnością, with its registered office in Wrocław, ul. Kościerzyńska 32A, 51-430 Wrocław, Poland, entered in the Register of Entrepreneurs of the National Court Register (KRS) kept by the District Court in Wrocław, VI Commercial Division of the National Court Register, under KRS number 0000628003, REGON 364949624, Tax ID (NIP) 8982222308 (“25WAT”).

For what purposes and on what basis do we process your personal data?

When processing your data, we follow these principles:

(a) we do not collect more information than we need; (b) we do not use data for purposes other than those listed in this Privacy Policy; (c) we do not keep data longer than necessary; (d) we do not disclose data to third parties in situations other than those set out in this Privacy Policy.

● If, when visiting www.25wat.com, you decide to use our contact service, add a comment or contact us through the contact form available on our website, you thereby consent to receiving commercial information from 25WAT by electronic means of communication, choosing email as the form of contact.

● If, when visiting www.25wat.com, you do not use the project quote service, add a comment or contact us through the contact form available on our website, we do not process any information about you except your IP address. Recording your IP address is necessary for technical reasons related to administering our servers. We will use your IP address to collect general statistical information about you (e.g., about the location you connect from). Please note, however, that we cannot identify you based on your IP address alone.

● We process the data collected through the contact forms available on our website in order to answer your question. The only data we need is your email address and phone number. The personal data you provide will be deleted once our communication with you has ended. The legal basis for processing your personal data is your consent. Providing your personal data is necessary for us to answer your questions.

● We process the personal data you provide when using the project quote service available on our website in order to exchange information between 25WAT and you, answer your questions and prepare a contract proposal. The only data we need is your email address and phone number. In addition, if your business name includes your first or last name, we will also process that data. The legal basis for processing your personal data is taking steps at your request prior to entering into a contract. Providing your personal data is necessary to enter into a contract with you.

● When you leave a comment at https://25wat.com/news/, https://25wat.com/pl/nowosci or https://25wat.com/es/noticias, we collect the data shown in the comment form and your IP address. However, to leave a comment, you must register with Disqus, which will be the controller of your personal data comprising your first name, last name, date of birth, email address or phone number. This data is stored by Disqus, and we have no access to it. Disqus is responsible for the purposes and duration of the processing. You can read its privacy policy at https://help.disqus.com/en/articles/1717103-disqus-privacy-policy

● If you decide to contact us and give the relevant consent, we may also process your personal data so that you can receive our newsletter and other marketing materials. The legal basis for processing your personal data, comprising your email address and phone number, will be your consent. Giving this consent is entirely voluntary.

● Your personal data may also be processed for financial and accounting purposes and to defend or pursue claims. The basis for processing your personal data is our legitimate interest in protecting or enforcing 25WAT’s rights in court or administrative proceedings.

How long do we keep your personal data?

● If you decide to contact us, we will process the personal data you provide in the contact form for as long as necessary to answer your question and for two years after we answer it, in order to protect our rights. After this period, your data will be deleted.
● If you decide to use the project quote service available on our website, we will process your personal data for the statutory limitation period for claims arising from your intention to enter into a contract, but no longer than three years. Once the limitation period expires, your data will be deleted.
● If you decide to leave a comment on our blog, your personal data will be processed until you delete your comment. Please note, however, that Disqus is responsible for how long the data is processed.
● Your personal data will be processed for marketing purposes until you withdraw your consent to the processing of your personal data.

Who may we disclose your personal data to?

● We protect all of your personal data and do not share this information with third parties in cases other than those listed below, unless we obtain your consent or the disclosure is required by a legal obligation imposed on us.

● However, we may disclose the information you provide to us in connection with your use of the Services to:

(a) providers of IT services and systems used to maintain our website and to enable the use of its features, including: Disqus, Tytani24, Google Analytics, Google Ads, Cloudflare, Wordfence, Smartlook;

(b) entities providing services necessary to send transactional and product information by email or text message (SMS), to the extent the disclosure is necessary to automate, simplify and analyze these processes, including Link Mobility Poland sp. z o.o.;

● We will not disclose your personal data to entities located outside the European Economic Area unless adequate data protection standards are ensured.

● If you wish, you can also read the privacy policies of the providers whose services we may use: Google (https://www.google.pl/intl/pl/policies), Disqus (https://help.disqus.com/en/articles/1717103-disqus-privacy-policy), Facebook (https://www.facebook.com/about/privacy/cookies), Smartlook (https://www.smartlook.com/pl/privacy), Cloudflare (https://www.cloudflare.com/privacypolicy/), Tytani24 (https://tytani24.com/regulamin/), Wordfence (https://www.wordfence.com/privacy-policy/).

Recruitment: candidate data

This section applies to people who apply to 25WAT, e.g., by sending a CV to praca@25wat.com.

● Controller. The controller of your data is 25WAT spółka z ograniczoną odpowiedzialnością, with its registered office in Wrocław, ul. Kościerzyńska 32A, 51-430 Wrocław, Poland (you will find full details in the “Who are we?” section). For recruitment matters, write to praca@25wat.com.

● Data required by law. We process your first and last name, date of birth and contact details and, where the position requires it, also your education, professional qualifications and employment history in order to carry out the recruitment process for the position you are applying for. The legal basis is Article 6(1)(c) GDPR in conjunction with Article 22¹ of the Polish Labor Code (Kodeks pracy). If the recruitment concerns cooperation on a basis other than an employment contract, the legal basis is Article 6(1)(b) GDPR, i.e., steps taken at your request prior to entering into a contract.

● Additional data. We process any other data you provide on your own initiative (e.g., a photo or your interests) based on your consent (Article 6(1)(a) GDPR). You give this consent by sending us that data. Please do not send us special categories of personal data, e.g., health data. If you provide such data on your own initiative, the legal basis will be your explicit consent (Article 9(2)(a) GDPR).

● Future recruitment. If you want us to consider you in future recruitment processes as well, add a consent statement to your CV or email, e.g.: “I consent to the processing of my personal data by 25WAT sp. z o.o. for the purposes of future recruitment processes.” In that case, the legal basis is your consent (Article 6(1)(a) GDPR).

● How long do we keep the data? We keep data from a given recruitment process until that process ends. If you consent to taking part in future recruitment processes, we keep it until you withdraw your consent, but no longer than 12 months from when you gave it. After that, we delete it.

● Who do we share the data with? The data may be shared with the IT service providers we use for recruitment (e.g., email and hosting), only to the extent necessary to provide those services. The rules for transferring data outside the European Economic Area are described in the “Who may we disclose your personal data to?” section.

● Your rights. You have the right of access to your data and the right to rectification, erasure and restriction of processing. You also have the right to data portability and the right to object, in the cases described in Articles 20 and 21 GDPR. You can withdraw your consent at any time. Withdrawal does not affect the lawfulness of processing carried out before the withdrawal. Not giving consent or withdrawing it cannot be grounds for unfavorable treatment. To exercise these rights, write to praca@25wat.com or support@25wat.com. You also have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO).

● Do you have to provide your data? Providing data is voluntary. However, the data required by law is necessary to take part in the recruitment process. You provide any other data solely of your own free will.

● Automated decisions. We do not use automated decision-making with regard to candidates, including profiling.

Your rights

You have a number of rights in connection with the processing of your personal data. In the section below, we explain in detail what they involve and how you can exercise them.

• Right of access to personal data
At any time, you have the right to access the information we process about you. You can exercise this right by contacting us by email at support@25wat.com.

• Right to rectification of the personal data we hold about you
At any time, you have the right to have the information we process about you rectified. You can exercise this right by contacting us by email at support@25wat.com.

• Right to erasure of the personal data we hold about you and right to restriction of its processing
We will delete the data collected about you once the purpose for which it was collected has been fulfilled. You have the right to request at any time that we erase your data or restrict its processing. You can exercise these rights by contacting us by email at support@25wat.com.

• Right to object to the processing of personal data
If we process your data on the grounds of 25WAT’s legitimate interest, you have the right to object at any time. You can exercise this right by contacting us by email at support@25wat.com.

• Right to data portability
You have the right to ask us to send the data we have collected about you. Where technically feasible, we will send your data in a commonly used format, in the manner and to the address you specify. You can exercise this right by contacting us by email at support@25wat.com.

• Right to withdraw consent to the processing of personal data
If we process your data based on your consent, you can withdraw that consent at any time. Please remember that withdrawing consent does not make the processing carried out before the withdrawal unlawful. You can exercise this right by contacting us by email at support@25wat.com.

Profiling

We do not use any information you provide for automated decision-making, including profiling.

Cookies

25WAT uses cookies, i.e., files saved and stored on the device you use to connect to the internet during your visits to our website. They allow us to better match our services to your individual needs and preferences and to collect and process statistical data on how our website is used.

We use cookies for the following purposes:

● to better match our services to your individual needs and preferences,
● to enable the collection and processing of statistical data on how our website is used,
● to advertise 25WAT’s Services online.

If you do not set your browser (e.g., Mozilla Firefox or Google Chrome) to block cookies, it will accept them. You can disable cookies in your browser settings at any time, even if you have previously consented to their use. You can also delete the cookies stored on your computer at any time. Please remember, however, that disabling cookies may adversely affect functionality or make it completely impossible to use the Services.

Changes to the privacy policy

The provisions of this Privacy Policy may be subject to improvements and changes, and its latest version will always be published on our website at:

PL — 25wat.com/pl/polityka-prywatnosciEN — 25wat.com/privacy-policy

Contacting 25WAT and FINAL PROVISIONS

If you have any questions or concerns about this Privacy Policy, you can contact 25WAT by sending an inquiry to support@25wat.com.

We hope we will be able to answer your questions about personal data protection to your satisfaction. However, if you believe that our actions have at any time violated your rights, you have the right to lodge a complaint with the supervisory authority, i.e., the President of the Personal Data Protection Office (UODO), based in Warsaw.

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