The basic principles of data collection
1. General Principles
This personal data processing policy is drawn up in accordance with the requirements of the General Data Protection Regulation (GDPR; Regulation (European Union) 2016/679, Polish data) and defines the procedure for processing personal data and measures to ensure the security of personal data implemented by LegaLux Company Olha Terebova (hereinafter referred to as the Operator).
1.1. The Operator sets as its most important goal and condition for the implementation of its activities the observance of the rights and freedoms of a person and a citizen when processing his personal data, including the protection of the right to privacy, personal and family secrets.
1.2. This Operator’s policy on the processing of personal data (hereinafter - the Policy) applies to all information that the Operator may obtain about visitors to the website www.legalux.pl.
2. Basic Concepts Used in the Policy
2.1. Automated processing of personal data refers to the handling of personal data using computer technology.
2.2. Blocking of personal data involves the temporary suspension of the processing of personal data, except when processing is necessary for the clarification of personal data.
2.3. The website is a collection of graphic and informational materials, as well as computer programs and databases which ensures their availability on the Internet at www.legalux.pl.
2.4. The information system of personal data is a set of personal data contained in databases. Their processing is provided by information technologies and technical means.
2.5. Depersonalization of personal data - actions in which it is impossible to determine the ownershipp of personal data to a specific User or another subject of personal data without the use of additional information.
2.6. The processing of personal data encompasses any action or set of actions, whether automated or not, involving personal data. These actions include, but are not limited to, the collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
2.7. The Operator is defined as a state body, municipal body, legal entity, or natural person who, either independently or in collaboration with others, organizes and conducts the processing of personal data. Additionally, the Operator determines the purposes of processing personal data, the scope of personal data subject to processing, and the actions (operations) performed with personal data.
2.8. Personal data - any information relating directly or indirectly to a specific or determined User of the website www.legalux.pl.
2.9. Personal Data Authorized by the Data Subject for Distribution. This category refers to personal data for which the data subject has granted access to an unrestricted audience. The data subject provides this authorization by giving consent to the processing of personal data, following the procedures outlined in the Law on Personal Data. (Hereinafter, this type of personal data is referred to as Permitted-to-distribute data)
2.10. A user is any visitor to the website www.legalux.pl
2.11. The principles of personal data refer to actions intended to disclose personal data to specific individuals or a defined group of persons.
2.12. The dissemination of personal data involves any actions directed at disclosing personal data to an unspecified number of persons (transfer of personal data) or allowing access to personal data by an unlimited number of individuals. This includes actions such as publication in mass media, placement in information and telecommunication networks, or any other means of providing access to personal data.
2.13. The cross-border transfer of personal data refers to the transmission of personal data to the territory of a foreign state, encompassing the authority of a foreign state, foreign individuals, or foreign legal entities.
2.14. The Destruction of Personal Data involves any actions that result in the irreversible destruction of personal data. This process makes it impossible to restore the content of personal data in the information system, and it may also include the destruction of material carriers of personal data.
3. Basic Rights and Responsibilities of the Operator
3.1. Operator’s Rights:
- The Operator has the right to receive accurate information and/or documents containing personal data from the data subject.
- In the event of the data subject’s withdrawal of consent for the processing of personal data, the Operator has the right to continue processing personal data without the data subject’s consent if there are grounds specified in the Law on Personal Data.
- The Operator has the right to autonomously establish the composition and list of measures necessary and sufficient to fulfill obligations as outlined in the Law on Personal Data and regulatory legal acts adopted in accordance with it, unless specified otherwise by the Law on Personal Data or other applicable laws.
3.2. Operator’s Responsibilities:
- To provide, upon the data subject’s request, information regarding the processing of their personal data.
- To organize the processing of personal data in accordance with the current legislation of the Republic of Poland and the EU.
- To respond to inquiries and requests from data subjects and their legal representatives in accordance with the requirements of the Law on Personal Data.
- To provide necessary information to the authorized data protection authority upon request.
- To publish or ensure unrestricted access to this Privacy Policy on the processing of personal data.
- To implement legal, organizational, and technical measures safeguarding personal data from unauthorized or accidental access, destruction, alteration, blocking, copying, provision, distribution, and other unlawful actions.
- To halt the transfer (distribution, provision, access) of personal data, discontinue processing, and destroy personal data in the manner and cases stipulated by the Law on Personal Data.
- Perform other duties provided for by the Personal Data Law.
4. Basic rights and obligations of personal data subjects
4.1. Personal data subjects have the right to:
- Receive information about the processing of their personal data, except in cases provided by law. Information is provided to the subject of personal data by the Operator in an accessible form, and it should not contain personal data belonging to other personal data subjects, except in cases where there are legal grounds for disclosing such personal data. The list of information and the procedure for obtaining it are established by the Personal Data Protection Law;
- Impose a condition of prior consent when processing personal data for the purpose of promoting goods, works and services on the market;
- Withdraw consent for the processing of personal data.
- To withdraw consent to the processing of personal data;
- Exercise other rights provided by the legislation of the Republic of Poland and the EU.
- to organize the processing of personal data in accordance with the current legislation of the Republic of Poland and the EU.
4.2. Personal data subjects are obliged to:
- Provide the Operator with accurate data about themselves.
- Inform the Operator about the clarification (update, change) of their personal data.
4.3. Persons who provided the Operator with inaccurate information about themselves or information about another personal data subject without the latter’s consent bear responsibility according to the legislation of the Republic of Poland and the EU.
5. The Operator may process the following personal data of the User:
5.1. Surname, first name, and patronymic.
5.2. E-mail address.
5.3. Phone numbers.
5.4. The website also collects and processes anonymized data about visitors (including cookie files) through internet statistics services (Facebook Pixel, Google Analytics, and others).
5.5. Data referred to in the text of the Policy are collectively referred to by the general term “Personal Data.”
5.6. The processing of special categories of personal data regarding race, nationality, political views, religious or philosophical beliefs, and intimate life is not carried out by the Operator.
5.7. The processing of personal data allowed for dissemination, among special categories of personal data specified in the Personal Data Protection Law, is allowed if the prohibitions and conditions stipulated in the Personal Data Protection Law are observed.
5.8. The User’s consent to the processing of personal data allowed for dissemination is formalized separately from other consents to the processing of their personal data. The conditions specified in the Personal Data Protection Law, among others, are observed. The requirements for the content of such consent are established by the authorized body for the protection of the rights of personal data subjects.
5.8.1 The consent to the processing of personal data allowed for dissemination is provided by the User directly to the Operator.
5.8.2 The Operator is obligated, no later than three working days from the moment of receiving the User’s consent, to publish information about the processing conditions, the existence of prohibitions, and conditions for processing of personal data authorized for distribution by an unlimited number of persons.
5.8.3 The transfer (dissemination, provision, access) of personal data allowed by the personal data subject for dissemination must be terminated at any time upon the request of the personal data subject. This request must include the surname, first name, patronymic (if any), contact information (phone number, email address, or postal address) of the personal data subject, as well as a list of personal data, the processing of which is subject to termination. The personal data specified in this request can only be processed by the Operator to whom it is sent.
5.8.4 The consent to the processing of personal data allowed for dissemination ceases its effect from the moment the Operator receives the request specified in clause 5.8.3 of this Policy regarding the processing of personal data.
6. Principles of personal data processing
6.1. Personal data processing is carried out on a lawful and fair basis.
6.2. The processing of personal data is limited to the achievement of specific, predetermined, and lawful purposes. Processing of personal data that is incompatible with the purpose of data collection is not allowed.
6.3. The merging of databases containing personal data processed for incompatible purposes is not permitted.
6.4. Only personal data that corresponds to the purposes of its processing is subject to processing.
6.5. Only personal data that corresponds to the purposes of its processing is subject to processing.
6.6. Accuracy, sufficiency, and, where necessary, relevance of personal data is ensured during the processing of personal data. The Operator takes necessary measures and/or ensures their implementation to delete or clarify incomplete or inaccurate data.
6.7. Storage of personal data is carried out in a form that allows identifying the subject of personal data, no longer than required by the purposes of personal data processing, unless the storage period is established by legislation, a contract, or an agreement with the beneficiary or guarantor for whom the data subject acts. The processed personal data is destroyed or depersonalized after the goals of the processing have been achieved or in the event of the loss of the need to achieve these goals, unless otherwise provided by law.
7. Purposes of personal data processing
7.1. The purpose of processing the User’s personal data includes:
- Informing the User by sending e-mails;
- Providing the User with access to services, information, and/or materials available on the website www.legalux.pl.
- Contacting the User for the purpose of providing him with consultations
7.2. Additionally, the Operator has the right to send the User notifications about new products and services, special offers, and various events. The User can always refuse to receive informational messages by sending an email to the Operator at the e-mail address info.legalux@gmail.com with the subject “Rejection of notifications about new products and services and special offers.”
7.3. Depersonalized data of Users collected through internet statistics services serve to gather information about Users’ actions on the website, improve the quality of the site and its content.
8. Legal bases for personal data processing
8.1. The legal bases for processing personal data by the Operator include:
- General Data Protection Regulation (GDPR; Regulation (European Union) 2016/679), Polish. Rozporządzenie o ochronie danych osobowych (RODO));
- Other legal acts in the field of personal data protection
- User consent for the processing of their personal data, including the processing of personal data allowed for dissemination.
8.2. The Operator processes the User’s personal data only if it is provided and/or sent by the User independently through special forms on the website www.legalux.pl or sent to the Operator via email. By filling out the relevant forms and/or sending their personal data to the Operator, the User expresses consent to this Policy.
8.3. The Operator processes anonymized data about the User if it is allowed in the User’s browser settings (cookies are enabled).
8.4. The personal data subject independently decides on the provision of their personal data and gives consent freely, voluntarily, and in their own interest.
9. Terms of personal data processing
9.1. The processing of personal data is carried out with the consent of the personal data subject for the processing of their personal data.
9.2. The processing of personal data is necessary to achieve the purposes provided by an international agreement between the Republic of Poland and the EU or by law, to fulfill the functions, powers, and obligations imposed on the operator by the legislation of the Republic of Poland and the EU.
9.3. The processing of personal data is necessary for the administration of justice, the execution of a court order, an act of another authority, or a public official, subject to execution according to the legislation of the Republic of Poland and the EU on executive proceedings.
9.4. The processing of personal data is necessary for the performance of a contract, where the data subject is a party, beneficiary, or guarantor, as well as for the conclusion of a contract at the initiative of the data subject or a contract where the data subject will be a beneficiary or guarantor.
9.5. The processing of personal data is necessary for the realization of the legal and legitimate interests of the operator or third parties or to achieve socially significant goals, provided that the legal rights and freedoms of the data subject are not violated.
9.6. Processing is carried out for personal data that is publicly accessible, with access provided by the data subject or at their request (hereinafter - publicly available personal data).
9.7. Processing is carried out for personal data that is subject to publication or mandatory disclosure according to the legislation.
10. The procedure for the collection, storage, transfer, and other types of processing of personal data
The security of personal data processed by the Operator is ensured through the implementation of legal, organizational, and technical measures necessary for the full implementation of the requirements of the current legislation in the field of personal data protection.
10.1. The Operator ensures the preservation of personal data and takes all possible measures to prevent unauthorized access to personal data.
10.2. The User’s personal data will never, under any circumstances, be transferred to third parties, except in cases related to the fulfillment of current legislation or if the data subject has given consent to the Operator for the transfer of data to a third party to fulfill obligations under a civil contract.
10.3. In case of inaccuracies in personal data, the User can update them independently by sending a notification to the Operator via email at info.legalux@gmail.com with the subject “Update of Personal Data.”
10.4. The processing period of personal data is determined by the achievement of the purposes for which personal data was collected, unless another period is stipulated by the contract or current legislation.
Users may revoke their consent to the processing of personal data at any time by sending a message to the Operator via email at info.legalux@gmail.com with the subject “Withdrawal of Consent to the Processing of Personal Data.”
10.5. All information collected by third-party services, including payment systems, communication tools, and other service providers, is stored and processed by the specified persons (Operators) in accordance with their User Agreement and Privacy Policy. The data subject or User is responsible for timely familiarization with these documents. The Operator is not responsible for the actions of third parties, including service providers mentioned in this section.
10.6. Prohibitions on the transfer (except for providing access) and processing conditions (except for accessing) of personal data allowed for dissemination, established by the data subject, are not applicable in cases of processing personal data for state and public interests as defined by the legislation of the Republic of Poland and the EU.
10.7. The Operator ensures the confidentiality of personal data during processing.
10.8. The Operator stores personal data in a form that allows identification of the data subject, no longer than required by the purposes of processing personal data, unless the storage period is established by legislation, a contract, or a party for whom the data subject is a beneficiary or guarantor.
10.9. The cessation of processing personal data may occur upon achieving the purposes of processing personal data, expiration of the consent period given by the data subject, or withdrawal of consent by the data subject, as well as the identification of unlawful processing of personal data.
11. List of Actions Performed by the Operator with Obtained Personal Data
11.1. The Operator performs the collection, recording, systematization, accumulation, storage, clarification (updating, modification), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, and destruction of personal data.
11.2. The Operator carries out automated processing of personal data, including obtaining and/or transmitting information through information and telecommunication networks or without them.
12. Cross-border transfer of personal data
12.1. Before initiating the cross-border transfer of personal data, the Operator must ensure that the foreign state, the territory of which is intended to receive the transfer of personal data, provides reliable protection of the rights of data subjects.
12.2. Cross-border transfer of personal data to the territories of foreign states that do not meet the above requirements may be carried out only with the written consent of the data subject for the cross-border transfer of their personal data and/or the execution of a contract, to which the subject of personal data is a party.
13. Confidentiality of personal data
The Operator and other persons who have access to personal data are obligated not to disclose to third parties and not to distribute personal data without the consent of the data subject, unless otherwise provided by law.
14. Final provisions
14.1 The User can obtain any clarifications regarding issues related to the processing of their personal data by contacting the Operator via email at info.legalux@gmail.com.
14.2. Any changes to the policy for the processing of personal data by the Operator will be reflected in this document. The policy is valid indefinitely until it is replaced by a new version.