A. Introduction

1. Privacy of the SONIAKH digest website users is very important to us and we are committed to safeguarding it. This policy applies where we determine the purposes and means of the processing of your personal data.
2. By consenting to the use of cookies on your first visit to our website, in accordance with the provisions of this policy, you give us permission to use cookies on each of your subsequent visits.

B. Credit

1. This document was created using a template from SEQ Legal (seqlegal.com) and edited with the Website Planet (www.websiteplanet.com).

C. The personal data that we collect

We have set out the general categories of personal data that we may collect, save and process:

1. Data on your computer that may include your IP address, geographical location, browser type and version, and operating system;
2. Data on your visiting and using of the website that may include referral source, length of visit, page views and website navigation paths;
3. Data, such as your name and email address, that you provide when you subscribe to our mailings and/or newsletters;
4. Data generated when you use our website including information about the timing, frequency and conditions of the use; 
5. Data you post on our website for the purpose of publishing it online including your username, profile picture, and the content of your post;
6. Data contained in any communications you send to us by email or through our website including message content and metadata; 
7. Any other personal data you send to us.

According to this policy, before disclosing a third party’s personal data to us, you must obtain that person’s consent both to the disclosure and to the processing of that data.

D. Purposes of processing your personal data

Personal data you provide to us through our website will be used for the purposes set out in this policy or on the relevant pages of the website. We may use your personal data for the following purposes:

1. operating our website;
2. personalizing our website for you;
3. enabling you to use the services available on our website;
4. sending you our newsletter (you can inform us at any time that you no longer wish to receive emails from us);
5. providing third parties with statistical information about our users (however, they will not be able to identify any individual user from the data received);
6. processing inquiries and complaints relating to our website that are sent by you;
7. ensuring the security of our website and preventing fraud;
8. verifying compliance with the terms and conditions governing the use of our website;
9.  for other purposes that will require changes to this policy.

If you have provided your personal data for publication on our website, we will publish it. Otherwise, we will use this data in accordance with the permissions you have given us. 

Your privacy settings may be used to restrict the publication of your personal data on our website and may be adjusted through the website’s privacy controls.

Without your express consent, we will not share your personal data with any third party company for direct marketing use.

E. Disclosure of personal data

We may disclose your personal data to any of our employees, managers, policyholders, professional advisors, agents, suppliers or subcontractors to the extent and for the purposes specified in this policy.

We may disclose your personal data to any member of our NGO within the scope and purposes specified in this policy.

We reserve the right to disclose your personal data in the following cases:

1. when the Law of Poland on Personal Data Protection requires us to do so;
2. due to any current or future legal proceedings;
3. to any person who, in our reasonable opinion, may apply to a court or other authorized body for the disclosure of that personal data and, in our reasonable opinion, that court or authorized body will issue an order for the disclosure of that personal data and/or upon request authorized bodies, such as the National Police of Poland, etc.

We will not disclose your personal data to third parties, except as specified in this policy.

F. International transfers of your personal data

The data we collect may be stored, processed and transferred between any countries in which we operate in order to enable us to use the data in accordance with this policy.

By agreeing to this policy, you consent to the transfer of your personal information specified in section F.

G. Retaining personal data

1. This Section G sets out our data retention policies and procedures, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
2. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
3. Notwithstanding the other provisions of this Section G, we may retain documents (including the electronic ones) containing personal data:
   • for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person;
   • in the cases where it is required by the law;
   • if we believe that the documents may be relevant to any current or future legal proceedings;
   • to establish, exercise or protect our legal rights (including providing information to other parties to prevent fraud or reduce credit risks).

H. Personal data protection

We will take adequate technical and organizational measures to prevent the loss, unlawful use or falsification of your personal data. 

All personal data provided by you will be stored on servers protected by both passwords and firewalls.

You acknowledge that transferring the data over the Internet is inherently insecure and we cannot guarantee the security of data sent over the World Wide Web.

I. Changes and amendments

We reserve the right to periodically make changes and amendments to this policy and to publish their new version on our website. You should check this web page periodically to make sure you understand the changes made to this policy. We may also notify you of changes to this policy by sending you an email or through our website’s private messaging system.

J. Your rights

You can object to the processing of your personal data for marketing purposes.

In practice, you will usually either consent in advance to us using your personal data for marketing purposes, or we will provide you with an opportunity to opt out of using your data for marketing purposes.

K. Third party websites

Our website contains hyperlinks to third party websites and their details. We have no control tools and are not responsible for the privacy policies and practices of third parties and companies in this industry.

L. Data update

Please notify us promptly if your personal data we hold needs to be updated or changed.

M. About cookies

Our website uses cookies. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed. Cookies usually don’t contain any information that personally identifies a user, but personal data that we store about you may be linked to the information stored in and obtained from cookies. Our website uses both persistent and session cookies.

We use cookies for the following purposes:

1. On our website, we use Google Analytics and Adwords to recognize the computer when the user visits the website / track user navigation on the website / improve the usability of the website / analyze website usage / manage the website / prevent fraud and improve website security / personalize the website for each user / target advertising that may be of interest to individual users;
2. Most browsers allow you to refuse to accept cookies. Blocking all cookies will have a negative impact upon the usability of many websites. Blocking cookies will make certain functions of our website unavailable to you.
3. You may delete cookies that are already stored on your computer.
4. Deleting cookies will have a negative impact upon the usability of many websites.