Information obligation under Art. 13 of the GDPR
§1. Who is the administrator of your personal data?
The administrator of your personal data, i.e. the entity deciding how it will be used, is Headway Sp. z o.o. with its registered office in Wrocław przy ul. Prosta 36, NIP 8942611446, KRS 13071, REGON 932182436 (hereinafter referred to as “Headway”).
§2. How to contact us for more information on the processing of your personal data?
Write to us at the firstname.lastname@example.org or postal address Headway Sp. z o.o., ul. Prosta 36, 53-508 Wrocław.
§3. Where did we get your data from?
We received it from you during the conclusion of the contract, and also later, in connection with its execution.
§4. What is the purpose and legal basis for the processing of your personal data by Headway Sp. z o.o.?
We process your personal data because it is necessary to execute the contract concluded with you, including:
- enabling the provision of the service by electronic means, in particular the service consisting in: website lease, online store lease, domain lease;
- handling requests that you send to us (e.g. via the contact form);
- handling a complaint in the event you make such a complaint;
- contacting you, including for purposes related to the provision of services.
In addition, the law requires us to process your data for tax and accounting purposes.
We also process your personal data for the purposes set out below, based on the legitimate interest of Headway, which is:
- contacting you, including for purposes related to permitted marketing activities, through available communication channels, in particular and with your consent – via e-mail and telephone;
- handling your requests, in particular sent to the customer service department and via the contact form in a situation where they are not directly related to the execution of the contract;
- ensuring the safety of the services we provide you by electronic means, including enforcing compliance with internal rules of Headway and counteracting fraud and abuse as well as ensuring traffic safety;
- debt collection; conducting court proceedings;
- organisation of loyalty programs, competitions and promotional campaigns in which you can take part;
- conducting statistical analyses;
- storing data for archiving purposes and ensuring accountability (showing compliance with our obligations resulting from legal provisions).
If you agree, we process your personal data in order to save data in cookies, and collect data from websites; You can withdraw your consent to the processing of personal data at any time in the same way as you have expressed it. We will process your personal data until you withdraw your consent.
§5. Do you have to provide us with your personal data?
We require you to provide the following personal data in order to be able to conclude and execute the contract concluded with you, and thus provide you with the service:
- name, surname or information about your company,
- address data,
- e-mail address and phone number.
If required by law, we may require you to provide other data necessary, for example, for accounting reasons. Apart from these cases, providing your data is voluntary.
§6. What are your entitlements towards Headway in terms of the processed data ?
We guarantee the fulfilment of all your rights under the general Data Protection Regulation, i.e. the right to access, rectify and delete your data, limit its processing, the right to transfer its, not to be subject to automated decision making, including profiling, and the right to object to the processing of your personal data.
You can use these entitlements:
- regarding the request for rectification: when you notice that your data is incorrect or incomplete;
- regarding the request to delete data: When your data is no longer necessary for the purposes for which it was collected by Headway; you withdraw your consent to the processing of your data; you object to the processing of your data; Your data is processed unlawfully; data should be deleted in order to fulfil the obligation arising from the law;
- regarding the request to limit the processing of data: when you notice that your data is incorrect – you may request to limit the processing of your data for a period allowing us to check the correctness of this data; Your data is processed unlawfully, but you do not want it to be removed; We will no longer need your data, but you may need it to defend or pursue claims; or you object to the processing of the data – until the time of determination whether the legitimate grounds on our side override the grounds of objection;
- regarding the request for transfer of data: when the processing of your data is carried out on the basis of your consent or contract concluded with you and when this processing takes place automatically.
You have the right to file a complaint regarding the processing of your personal data to the supervisory authority, which is the General Inspector for Personal Data Protection (address: General Inspector for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw
§7 In what situations can you object the processing of your data?
You have the right to object to the processing of your personal data when:
- the processing of your personal data takes place on the basis of a legitimate interest or for statistical purposes, and the objection is justified by the particular situation in which you have found yourself,
- b. Your personal data is processed for direct marketing purposes, including profiling for this purpose.
Remember that you can exercise your right of objection since 25 May 2018.
§8. Who do we share your personal data with?
We provide your personal data to entities supporting us in the provision of electronic services, i.e. those that provide accounting, consulting or auditing services, support the service of Headway users, support the promotion of offers, and cooperate in marketing campaigns. We may pass on your personal data to public authorities fighting against fraud and abuse.
§9. How long do we keep your personal data?
We store your personal data for the duration of the contract concluded with you as well as after its completion for the following purposes:
- pursuing claims in connection with the execution of the contract,
- performance of obligations resulting from legal provisions, including in particular tax and accounting obligations,
- preventing abuse and fraud,
- statistical and archiving,
- maximum for a period of 10 years from the date of termination of the contract.
We store your personal data for marketing purposes for the duration of the contract or until you object to such processing, depending on which of these events occurs earlier.
§10. Do we transfer your data to countries outside the European Economic Area?
Your personal data will be transferred outside the European Economic Area to Google LLC based on appropriate legal safeguards, which are standard clauses of personal data protection approved by the European Commission.
§11. Do we process your personal data automatically (including through profiling) in a way that affects your rights?
Your personal data will be processed in an automated way (including in the form of profiling), however, it will not cause any legal effects to you or substantially affect your situation. Profiling of personal data by Headway consists in processing your data (also in an automated way) by using it to evaluate some of information concerning you, especially to analyse or forecast your personal preferences and interests.