PRIVACY POLICY ON SENTIONE.COM

1. PRIVACY POLICY OBJECTIVES

   This Privacy Policy defines the rules of processing and protecting the personal data provided by users in connection with their use of the Sentione.com site.

2. TERMS DEFINITIONS

   1. Data Controller – the following personal data controller:
      • for all Users – SentiOne Spółka Akcyjna with its registered office in Gdańsk, ul. Lęborska 3B, 80-386 Gdańsk, entered in the Register of Enterprises of the National Court Register kept by the District Court for Gdańsk-Północ in Gdańsk, 7th Commercial Division of the National Court Register, at KRS No. 0000904567, with NIP No.: 5252520285, REGON No.: 145863272;
      • additionally, for those who use the Site from the area of the Czech Republic, exclusively in terms of billing and invoicing – SentiOne Česká Republika s.r.o. Výstavní 2968 / 108, 703 00 Ostrava, Czech Republic, DIČ/Tax identity: CZ01807650, IČO: 01807650;
      • additionally, for those who use the Site from the area of the Netherlands, exclusively in terms of billing and invoicing – SentiOne Nederland B.V. Scherpakkerweg 6, 5616HP Eindhoven, Kingdom of the Netherlands, Tax ID 854192074B01;
      • additionally, for those who use the Site in Germany in terms of billing and invoicing – SentiOne Deutschland GmbH, Leopoldstrasse 154, 80804 München, German Federal Republic, Steueridentifikationsnummer 301500365.
   2. User Account – a scope of rights defined on the Site and assigned to a User to allow the User to use the services provided by the Data Controller through the Site. The User uses the User Account through an individual username and password.
   3. Site – the Sentione.com website.
   4. User – a natural person using the Site. Using the site shall mean both use of the User Account by registered users and use of the Site without registering or logging in.

3. GENERAL

   1. The User’s personal data are processed within the Site in accordance with the Polish Personal Data Protection Act of 29 August 1997 (Journal of Laws of 2016, item 922, consolidated text as amended) and, as of 25 May 2018, in accordance with the 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 and on the free movement of such data, and repealing Directive 95/46/EC (OJ L 119, p. 1).
   2. By using the Site and possibly registering a User Account, the User agrees to this Privacy Policy and to the detailed provisions thereof.
   3. The User shall provide their actual and true personal data. The Data Controller shall not be liable for the User giving incorrect or wrong personal data.

4. TYPES OF PERSONAL DATA PROCESSED

   1. The Site use, and in particular the registration procedure and the User Account creation, involves processing of the following personal data of Users:
      • full name;
      • date of birth;
      • telephone number;
      • e-mail address;
      • contact address;
      • IP address;
      • tax identification number.

5. PERSONAL DATA RECIPIENTS

   1. The Users’ personal data can be transmitted or provided by the Data Controller to PayLane Sp. z o.o. with its registered office in Gdańsk, ul. Arkońska 6/A3, zip code: 80-387, KRS No.: 0000227278 (hereinafter “PayLane”) if this is necessary to process online payments.
   2. The Data Controller transmits or provides the Users’ personal data to PayLane in line with the Users’ rights and based on personal data processing agreements consistent with applicable laws.
   3. The Users’ personal data can be transmitted or provided to other entities on the terms arising from applicable laws.

6. PURPOSES OF PERSONAL DATA PROCESSING

   1. The Users’ personal data are processed for the purpose of User Account management, and in particular to:
      • register the Users on the Site, which includes creating a User Account and verifying the User on the phone, via text message or by e-mail;
      • keep the User Accounts to a full extent in line with the SentiOne System Terms & Conditions;
      • provide services through the SentiOne System;
      • send direct mail with information to Users and to directly contact the Users (whether by e-mail, on the phone or via text message) in connection with the services.
   2. Furthermore, the User’s personal data are processed for marketing or other purposes to which the User agrees while registering on the Site or creating or using a User Account. Marketing purposes include in particular:
      • preparing and sending individually selected information about the Data Controller’s goods and services;
      • preparing and sending individually selected information about services;
      • market research carried out by the Data Controller;
      • preparing and sending commercial information about the Site and the services provided by the Data Controller on its own behalf or at a request of its business partners.
   3. While registering on the Site or creating or using the User Account, the User also agrees to the sharing and processing of their personal data by PayLane under a personal data processing agreement entered into by and between the Data Controller and PayLane – for purposes connected with the processing of electronic payments.

7. BASES FOR PERSONAL DATA PROCESSING

   1. The Users give their data on a voluntary basis. Using the services provided by the Administrator may require giving one’s data.
   2. The Data Controller processes the personal data based on applicable legislation or the User’s consent granted in the process of registering or using the User Account. Creating a User Account and using the Data Controller’s services to the full extent requires giving the consent to the processing of personal data for the purpose of managing User Accounts and providing the services and the consent to the provision of the personal data to PayLane – failure to provide the data or to give the consent makes it impossible to create the User Account and fully use the Data Controller’s services.
   3. Every User may at any time withdraw their consent to the processing of their personal data. Withdrawing the consent does not affect the lawfulness of any processing that took place based on any prior consent given before the withdrawal, nor does it affect the processing of personal data arising from any basis other than the User’s consent.

8. PERSONAL DATA RETENTION PERIOD

   1. The Users’ personal data will be retained for as along as the services are provided and the User Account exists, and for one calendar year following the date when the services are terminated and the User Account is deleted.
   2. The personal data retention period referred to in clause 8.1 above may be extended if any claims arise or are filed in connection with the Data Controller’s provision of services or with the use of the Site or the User Account.
   3. Upon the expiry of the personal data retention period, the data will be promptly deleted by the Data Controller, except for any personal data provided to the Data Controller for marketing purposes – they will be processed until the User withdraws the consent or objects to the processing of such data.

9. PERSONAL DATA PROTECTION MEASURES

   1. The Data Controller protects the Users’ personal data against unauthorised access by third parties and provides the organisational and legal measures consistent with applicable laws to guarantee that the Users’ data remain confidential and are used in a manner preventing any unauthorised access thereto.
   2. The Data Controller implements and applies appropriate technical solutions to protect the Users’ personal data. In particular, the Data Controller uses top-class technical and IT security measures, as well as physical security measures.

10. USERS’ RIGHTS IN RESPECT OF PERSONAL DATA

    1. The Users rights in respect of personal data plus the complaint procedure are described in a separate document – Personal Data Complaint Procedure.

11. COOKIE POLICY

    1. The Data Controller uses cookies, i.e. IT data, especially text files saved by servers on the User’s end devices, that can be read by the servers whenever the latter connects to that end device.
    2. The software used to browse websites (web browser) allows the storage of cookies on the User’s end device by default. Users may at any time change their cookie settings, especially to block automatic cookie support in their web browser settings or to be notified whenever they are saved on a device of the site user. Such a change may result in certain obstacles in the use of the Site.
    3. For more details on how to manage cookies, see the web browser settings.
    4. The majority of cookies are session cookies, which are automatically deleted from the hard drive after the session, i.e. after the User logs out or closes the browser. Some cookies allow to identify the User when the User revisits the website because they are not deleted automatically.
    5. The Data Controller uses cookies for the following purposes:
       • informative purposes, to improve the functioning of the Site and facilitate its use;
       • gathering anonymous, aggregated statistics of how Users use the Site, which is to help improve the functionality and the content of the Site;
       • personalising messages on the Site and e-mail correspondence;
       • profiling Users for marketing purposes and the advertisement of products and services of the Data Controller, including targeting Users for advertisement purposes;
       • adjusting marketing messages and advertising content to the needs and interests of a particular User.

12. CHANGES TO THE PRIVACY POLICY

    1. This Privacy Policy is in effect as of 1 May 2018.
    2. The Data Controller reserves the right to amend this Privacy Policy for a valid reason, especially if:
       • the Privacy Policy needs to be adapted to legislation or to decisions or judgements of courts or public authorities;
       • the Site or User Account functionalities change;
       • any details, including names, addresses, identification numbers presented in the Privacy Policy change;
       • it wishes to improve User service.
    3. The User will be informed about any changes to the Privacy Policy while logging in to the Site or to the User Account and through a notice about changes to the Privacy Policy sent to the e-mail address specified in the User Account (along with an amended Privacy Policy in a PDF format).
    4. An amended Privacy Policy is binding upon a User who does not terminate the User Account management agreement and does not stop using the Site before the effective date of such a new Privacy Policy.
    5. Changes to the Privacy Policy do not affect any personal data processing effected before the change.

13. MISCELLANEOUS

    1. For questions or issues connected with the processing and protection of personal data, contact the Data Controller in writing, by e-mail or by phone using the following details:
       SentiOne Spółka Akcyjna
       ul. Lęborska 3B, 80-386 Gdańsk
       contact e-mail address: privacy@sentione.com;
       • additionally, for Users who use the Site in the Czech Republic, any questions or issues connected with the processing and protection of personal data can be sent to SentiOne Česká Republika s.r.o. Výstavní 2968 / 108, 703 00 Ostrava or to privacy@sentione.com;
       • additionally, for Users who use the Site in Hungary, any questions or issues connected with the processing and protection of personal data can be sent to SentiOne Česká Republika s.r.o. Výstavní 2968 / 108, 703 00 Ostrava or to privacy@sentione.com;
       • additionally, for Users who use the Site in Germany, any questions or issues connected with the processing and protection of personal data can be sent to SentiOne Česká Republika s.r.o. Výstavní 2968 / 108, 703 00 Ostrava or to privacy@sentione.com;
       • additionally, for Users who use the Site in the Netherlands, any questions or issues connected with the processing and protection of personal data can be sent to SentiOne Nederland B.V. Scherpakkerweg 6, 5616HP Eindhoven or to privacy@sentione.com.
    2. On the Site and in User Accounts, the Data Controller posts links redirecting the Users to other websites. This Privacy Policy does not include any websites managed by any third parties beyond the Data Controller’s control, and the Data Controller shall not be liable for any personal data processing by such third parties managing other websites.