The Policy is for information purposes and serves satisfaction of information obligations imposed on the data controller under the GDPR, i.e. 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.
1. PERSONAL DATA CONTROLLER
- The Controller of Users’ personal data is the Service Provider, i.e. LiveCall Software sp. z o.o. with its registered office in Warsaw, (postal code 03–922), ul. Międzynarodowa 55/3, entered in the Register of Entrepreneurs of the National Court Register (KRS) maintained by the District Court for the capital city of Warsaw in Warsaw, 13th Commercial Division of the National Court Register under number KRS: 0000597585, Tax Identification Number NIP: 5252642120, share capital: PLN 10,000.00.
- You may contact the Personal Data Controller in particular via e-mail at firstname.lastname@example.org
- The Data Controller has also appointed the Data Protection Officer. Contact details of the Data Protection Officer – name: Piotr Bator, e-mail address: email@example.com.
2. DATA PROCESSING METHOD
- The purpose and scope of the processed personal data is determined by the scope of your consents and data provided by you sent by means of a relevant form. Thus, we may process the following personal data: first and last name, e-mail address, phone number, computer IP address, Tax Identification Number NIP or VAT number, place of business activity, data concerning you collected by Google Analytics, Google AdWords, Crisp chat, Facebook Pixel and other data necessary for provision of services in accordance with the Terms of Service.
- Providing the personal data is voluntary, but the lack of consent to process personal data marked in the form as obligatory will prevent us from performing Services. Due to the nature of our services, they cannot be provided anonymously.
- We process Users’ personal data for the following purposes:
- implementation of legal provisions—the legal basis in this case is the statutory authorisation to process data necessary to act in line with the law (Article 6.1(c) of the GDPR);
- performance of Agreements and provision of services by electronic means through LiveCall—the legal basis in this case is the statutory authorization to process data which are necessary to perform an agreement if the data subject is a party to such agreement, or if it is essential for undertaking certain actions prior to conclusion of an agreement upon request of the data subject (Article 6.1(b) of the GDPR);
- consideration of filed claims and complaints and optimisation of performances of LiveCall—the legal basis for processing is a legally legitimate interest executed by us as the Service Provider (Article 6.1.(f) of the GDPR) which consists in due conduct of business activity;
- promotional and commercial actions carried out by the Service Provider—the legal basis is again a legitimate interest executed by us as the Service Provider (Article 6.1.(f) of the GDPR) or voluntary consent of the Customer (Article 6.1(a) of the GDPR);
- If we are advised that you use LiveCall in violation of the Terms of Service or applicable provisions of law (unauthorized use), then we may also process your personal data in a scope required for establishing your liability.
- Your personal data will be processed for a time necessary to prove that we provided the Service correctly (such time corresponds to the period of limitation of claims) or in the case of an Agreement against charge—the time prescribed by accounting provisions, and will be deleted upon the lapse of the said time, unless their processing is necessary on the basis of another legal basis. In the case of marketing actions, personal data will be processed until you object to further processing of your personal data for marketing purposes or until you withdraw the consent to be sent messages with such content.
- Your data will be transferred to countries beyond the European Economic Area, i.e. to the United States in compliance with the Standard Contractual Clauses as established by the European Commission in Decision 2010/87/EU Commission Decision of 5 February 2010 on standard contractual clauses for the transfer of personal data to processors established in third countries.
- LiveCall involves profiling for the purposes of marketing, market research and improving Services by analysing Users’ conduct on LiveCall, in order to adjust the Services to the preferences of you and other Users. Profiling will result in personalisation of the website and our communication with you (e.g. by displaying appropriate content while visiting the LiveCall website or within communication with us), as well as display of appropriate offers and advertisements adjusted to your preferences and interests on the LiveCall pages and through third-party websites and social networks. Your profile may also be used in campaigns of other companies on the LiveCall pages. You may raise an objection against such profiling at any time by sending an e-mail to: firstname.lastname@example.org.
4. RECIPIENTS OF DATA
- Personal data collected by us may also be disclosed to: competent state authorities upon their request on the basis of relevant provisions of law or other persons and entities—in the cases prescribed in the provisions of law.
- Each entity to which we transfer personal data for processing on the basis of a personal data transfer agreement (“Transfer Agreement”) guarantees an adequate level of security and confidentiality of the processing of personal data. The entity processing your personal data on the basis of the Transfer Agreement may process Users’ personal data through another entity only upon our prior written consent.
5. YOUR RIGHTS
- Each User, including you, has the right to: (a) delete the collected personal data referring to him/her/you both from the system belonging to us as well as from bases of entities with which we have co-operated, (b) restrict the processing of data, (c) portability of the personal data collected by us and referring to you, in this to receive them in a structured form, (d) request us to enable you access to your personal data and to rectify them, (e) object to processing, (f) withdraw the consent towards us at any time without affecting the legality of processing carried out on the basis of the consent before it is withdrawn, (g) lodge a complaint about us to the supervisory authority (President of the Personal Data Protection Office).
6. OTHER DATA
- LiveCall may store http enquiries, therefore the files containing web server logs may store certain data, including the IP address of the computer sending the enquiry, the name of your station—identification through http protocol, if possible, date and system time of registration on the LiveCall website and receipt of the enquiry, number of bytes sent by the server, the URL address of the site visited by you before, information concerning your browser, information concerning errors occurred by realization of the http transaction. Web server logs may be collected for the purpose of proper administration of LiveCall. Only persons authorized to administer our IT system have access to data. Files containing web server logs may be analyzed for the purposes of preparing statistics concerning traffic on the LiveCall website and occurring errors. Summary of such details does not identify you.
- We apply technological and organizational means in order to secure the processed personal data corresponding to the threats and category of data to be secured, in particular, through technical and organizational means we secure data against being published to unauthorized persons, taken over by an unauthorized person, processed in violation of the law and changes, lost, damaged or destroyed; among others the SSL certificates are applied. Users’ personal data are collected and stored on a secured server, moreover, the data are secured by Service Provider’s internal procedures related to the processing of personal data and information security policy.
- We have also implemented appropriate technical and organizational means, such as pseudonymisation, designed to effectively enforce the data protection principles, such as data minimisation, and for the purpose of providing the processing with necessary safeguards, so as to meet the GDPR requirements and protect the rights of data subjects.
- At the same time, we also warn you that using the Internet and services provided by electronic means may pose a threat of malware breaking into your teleinformatic system and device, as well as any other unauthorized access to your data, including personal details, by third parties. In order to minimize such threats, you should use appropriate technical safeguards, e.g. use updated antivirus programs or programs securing your identification in the Internet. In order to obtain detailed and professional information related to security in the Internet, we recommend taking advice from entities specializing in such IT services.
- For the purposes of correct operation of LiveCall, we use the cookie support technology. Cookies are packages of information stored on the Users’ devices through LiveCall, usually containing information corresponding to the intended use of a particular file, by means of which you use LiveCall—these are usually: address of the website, date of publishing, lifetime of a cookie, unique number, and additional information corresponding to the intended use of the file.
- We use two types of cookies: (a) session cookies, which are permanently deleted upon closing the session of your browser; (b) permanent cookies, which remain on your device after closing the session until they are deleted.
- It is not possible to identify you on the basis of cookie files used by us, whether session or permanent. The cookie mechanism prevents collection of any personal data.
- LiveCall’s cookies are safe for your device, in particular they prevent viruses or other software from breaking into to the device.
- Files generated directly by us may not be read by other websites. Third-party cookies (i.e. cookies provided by our partners) may be read by an external server.
- You may individually change the cookies settings at any time, stating the conditions of their storage, through the Internet browser settings or configuration of the service.
- First and foremost, you may delete cookies or disable their storage on your device in accordance with the instructions of the browser producer, but this may disable certain parts of or the entire operation of the LiveCall functions.
- We use own cookies for the following purposes: authentication of Users within LiveCall and preserving Users’ sessions; configuration of LiveCall and adjustment of page content to the preferences or conduct of Users; analysis and research of views, click number and path taken on the website to improve the appearance and organisation of content on the website, time spent on the website, number and frequency of visits on LiveCall, as well as display of appropriate content by external partners providing affiliation services.
- In turn, we use third-party cookies for the following purposes:
Tool: Purpose of storing
Google Ads: Analysis of movement and behaviour of Users on the LiveCall website and display of advertisements adjusted to content browsed by Users in the Internet, as well as collecting information on user’s activity upon clicking an Google Ads ad.
Google Analytics: Analysis of movement and behaviour of Users on the LiveCall website for statistic purposes and optimisation of LiveCall
Facebook Pixel: Analysis of movement on the LiveCall website and display of LiveCall ads on Facebook to the Users of Facebook who expressed their interest in LiveCall
Crisp chat: Analysis of movement and conduct of registered Users on the LiveCall website which results in sending personalised messages, offers, advertisements, as well as choice of language
- Details concerning cookies support are available in the settings of your browser.
9. FINAL PROVISIONS