PRIVACY POLICY FOR THE SUPLIFT.IO WEBSITE

TABLE OF CONTENTS:

GENERAL PROVISIONS
GROUNDS FOR DATA PROCESSING
PURPOSE, BASIS AND DURATION OF DATA PROCESSING ON THE WEBSITE
RECIPIENTS OF DATA ON THE WEBSITE
PROFILING ON THE WEBSITE
RIGHTS OF THE DATA SUBJECT
COOKIES ON THE WEBSITE AND ANALYTICS
FINAL PROVISIONS

GENERAL PROVISIONS

This Privacy Policy of the Website is for information purposes only, which means that it does not create any obligations for the Users of the Website. The Privacy Policy primarily contains rules concerning the processing of personal data by the Administrator in the Website, including the grounds, purposes and duration of personal data processing and the rights of data subjects, as well as information concerning the use of cookies, other similar technologies and analytical tools in the Website.
The Administrator of the personal data collected through the Website is SUPLIFT SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with its registered office in Kraków (registered office and correspondence address: ul. Zabawa 28/LU1, 30-653 Kraków, Poland), entered in the Register of Entrepreneurs of the National Court Register under number: 0000909031; the registration court where the company’s documentation is kept: District Court for Kraków – Śródmieście in Kraków, XI Economic Division of the National Court Register; share capital amounting to: 5000,00 PLN; TIN: 6793219534, Company ID: 389335791, e-mail address: contact@suplift.io – hereinafter referred to as “Administrator” and being at the same time the Internet Service Provider.
Personal data on the Website are processed by the Administrator in accordance with the applicable legal provisions, in particular in accordance with 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 (General Data Protection Regulation) – hereinafter referred to as “GDPR” or “GDPR Regulation“. Official text of the GDPR Regulation: https://eur-lex.europa.eu/legal-content/EN/TXT/HTML/?uri=CELEX:32016R0679&from=PL
The use of the Website is voluntary. Similarly, the related provision of personal data by the User using the Website is voluntary, subject to two exceptions: (1) use of Suplift.io Services – failure to provide, in the cases and to the extent indicated on the website of the Internet Service, in the Regulations and in this Privacy Policy, personal data necessary for the use of a specific Suplift.io Service results in the impossibility to use this service. Providing personal data in such a case is a contractual requirement, and if the data subject wishes to enter into an agreement with the Administrator and use the Suplift.io Services provided by the Administrator, he or she is obliged to provide the required data. Each time, the scope of data required in order to use Suplift.io Services is indicated previously on the website of the Internet Service and in the Terms and Conditions of the Internet Service; (2) statutory obligations of the Administrator – providing personal data is a statutory requirement resulting from universally applicable provisions of law, which impose an obligation on the Administrator to process personal data (e.g. processing of data provided during the purchase of Subscription in order to keep the accounts), and failure to provide such data will prevent the Administrator from performing those obligations.
The Administrator shall take particular care to protect the interests of persons to whom the personal data processed by him/her relate, and in particular he/she shall be responsible and ensure that the data collected by him/her are (1) processed lawfully; (2) collected for specified, legitimate purposes and not subject to further processing incompatible with those purposes; (3) substantively correct and adequate in relation to the purposes for which they are processed; (4) kept in a form which permits identification of data subjects for no longer than is necessary to achieve the purpose of processing; and (5) processed in a manner which ensures adequate security of personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage, by means of appropriate technical or organisational measures (e.g. SSL certificate, data encryption, access to the User Account only after providing the individual password).
Taking into account the nature, scope, context and purposes of the processing and the risk of violation of the rights or freedoms of natural persons with different probability and severity of the threat, the Administrator implements appropriate technical and organisational measures to ensure that the processing is carried out in accordance with the GDPR Regulation and to be able to demonstrate this. These measures shall be reviewed and updated as necessary. The Administrator shall apply technical measures to prevent unauthorised persons from obtaining and modifying personal data transmitted electronically.
All words, expressions and acronyms appearing in this Privacy Policy and beginning with a capital letter (e.g. Service Provider, Website, Suplift.io Services) shall be understood as defined in the Terms and Conditions of the Website available on the Website.

GROUNDS FOR DATA PROCESSING

The Administrator is entitled to process personal data in cases where, and to the extent that, at least one of the following conditions is met: (1) the data subject has given his or her consent to the processing of his or her personal data for one or more specified purposes; (2) the processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract; (3) the processing is necessary for compliance with a legal obligation to which the Administrator is subject; or (4) processing is necessary for the purposes of legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data.
The processing of personal data by the Administrator requires in each case the existence of at least one of the grounds indicated in Point. 2.1 of the Privacy Policy. Specific grounds for processing the personal data of the Users of the Internet Service by the Administrator are indicated in the next point of the privacy policy – with reference to the given purpose of processing of personal data by the Administrator.

PURPOSE, BASIS AND DURATION OF DATA PROCESSING ON THE WEBSITE

Each time, the purpose, basis, period and recipients of the personal data processed by the Administrator result from the activities undertaken by the given User on the Website.

The Administrator may process personal data on the Website for the following purposes, on the following grounds and for the following period:

Purpose of data processing	Legal basis of data processing	Duration of data storage
Use of the Suplift.io Services available on the website	Article 6(1)(b) of the GDPR Regulation (contract) – processing is necessary for entering into and performing the contract for the use of the Suplift.io Services to which the data subject is a party, or for taking steps at the request of the data subject prior to entering into the contract	The data shall be stored for the period necessary for the performance, termination or expiration of the otherwise concluded contract with the Administrator.
Direct marketing	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the Administrator) – processing is necessary for the purposes arising from the Administrator’s legally justified interests – consisting in taking care of the interests and good image of the Administrator, its Website and striving to provide Suplift.io Services	The data are stored for the period of existence of the legally justified interest pursued by the Administrator, however, not longer than for the period of limitation of the Administrator’s claims against the data subject on account of the Administrator’s economic activity. The period of limitation shall be determined by law, in particular civil law (the basic limitation period for claims related to the running of a business activity is three years). The Administrator shall not process data for the purposes of direct marketing in the case of an effective objection to this effect expressed by the data subject.
Running a newsletter	Article 6(1)(a) of the GDPR Regulation (consent) – the data subject has given consent for his/her personal data to be processed for marketing purposes by the Administrator	The data is stored until the data subject withdraws his/her consent to further processing of his/her data for these purposes.
Bookkeeping	Article 6(1)(c) of the GDPR Regulation in conjunction with Article 74(2) of the Accounting Act, i.e. of 30 January 2018. (Journal of Laws of 2018, item 395 as amended) – processing is necessary for the fulfilment of a legal obligation incumbent on the Administrator	The data are stored for the period required by legal regulations requiring the Administrator to keep accounting books (5 years, counting from the beginning of the year following the financial year to which the data refer).
Determining, asserting or defending claims which may be raised by the Administrator or which may be raised against the Administrator	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the Administrator) – processing is necessary for the purposes deriving from the Administrator’s legitimate interests – consisting of determining, asserting or defending claims which may be raised by the Administrator or which may be raised against the Administrator	The data shall be stored for the period of existence of the legally justified interest pursued by the Administrator, however no longer than for the period of limitation of claims that may be raised against the Administrator (the basic limitation period for claims against the Administrator is six years).
Use of the Website page and ensuring its proper operation	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the Administrator) – processing is necessary for the purposes resulting from the Administrator’s legally justified interests – consisting in running and maintaining the Website	The data shall be stored for the period of existence of the legally justified interest pursued by the Administrator, however, no longer than for the period within which the Administrator’s claims against the data subject by virtue of the Administrator’s economic activity are time-barred. The period of limitation shall be determined by law, in particular civil law (the basic limitation period for claims related to business activities is three yesrs).
Conducting statistics and analysis of traffic on the Website	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the Administrator) – processing is necessary for purposes stemming from the Administrator’s legally justified interests – consisting in conducting statistics and analysis of traffic on the Website in order to improve functioning of the Website and increase reach of the provided Suplift.io Services	The data shall be stored for the period of existence of the legally justified interest pursued by the Administrator, however, no longer than for the period within which the Administrator’s claims against the data subject by virtue of the Administrator’s economic activity are time-barred. The period of limitation shall be determined by law, in particular civil law (the basic limitation period for claims related to business activities is three years).

RECIPIENTS OF DATA ON THE WEBSITE

For the proper functioning of the Website, including the proper provision of the Suplift.io Services by the Administrator, it is necessary that the Administrator uses services of external entities (such as e.g. a software or server provider). The Administrator shall only use the services of such processors who provide sufficient guarantees to implement appropriate technical and organisational measures so that the processing meets the requirements of the GDPR Regulation and protects the rights of data subjects.
Personal data may be transferred by the Administrator to a third country, whereby the Administrator shall ensure that, in such case, this shall be done in relation to a country ensuring an adequate level of protection and, in the absence of an appropriate decision confirming its adequacy, at least on the basis of standard data protection clauses – in accordance with the GDPR Regulation, and the data subject shall be able to obtain a copy of his/her data. The Administrator shall transfer the collected personal data only in the case and to the extent necessary to fulfil the given purpose of the processing in accordance with this Privacy Policy.
Transfer of data by the Administrator does not take place in every case and not to all recipients or categories of recipients indicated in the Privacy Policy – the Administrator transfers data only if it is necessary for the realization of a given purpose of personal data processing and only to the extent necessary for its realization.
Personal data of the Users of the Website may be transferred to the following recipients or categories of recipients:
1. entities servicing electronic or credit card payments – in case of a User who purchases Subscription on the Website and uses electronic or credit card payments, the Administrator makes the collected personal data of the User available to the chosen entity servicing the aforementioned payments in the Website at the request of the Administrator to the extent necessary to handle the payment made by the User.
2. providers of marketing and advertising services (e.g. providers of e-mailing solutions and optimisation of marketing campaigns) – the Administrator shall make the collected User personal data available to a chosen provider acting on his/her order only in the case and to the extent necessary to realize a given purpose of data processing compliant with this privacy policy, e.g. in the case when the User expressed his/her consent to receive the newsletter or when undertaking some actions is dictated by the Administrator’s lawful interest.
3. service providers supplying the Administrator with technical, IT and organisational solutions enabling him to run his business, including the Internet Service and Suplift.io Services provided by means of it (in particular, providers of computer software for running the Internet Service, e-mail and hosting providers, as well as providers of business management and technical support software for the Administrator) – the Administrator shall make the collected personal data of the User available to the chosen provider acting on its behalf only in the case and to the extent necessary to realize the given purpose of data processing in accordance with this privacy policy.
4. providers of accounting, legal and advisory services providing the Administrator with accounting, legal or advisory support (in particular an accounting office, a law firm or a debt collection company) – the Administrator shall make the collected personal data of the User available to the chosen provider acting on his behalf only in the case and to the extent necessary to realize the given purpose of data processing in accordance with this privacy policy.

PROFILING ON THE WEBSITE

The GDPR Regulation imposes an obligation on the Administrator to provide information on automated decision-making, including profiling as referred to in Article 22(1) and (4) of the GDPR Regulation, and, at least in these cases, relevant information on the modalities of such decision-making, as well as about the significance and foreseeable consequences of such processing for the data subject. With this in mind, the Administrator provides information on possible profiling in this section of the privacy policy.
The Administrator may use profiling on the Website for direct marketing purposes, but decisions taken on its basis by the Administrator shall not concern the conclusion or refusal of an agreement with the Administrator, or the possibility of using the Suplift.io Services on the Website. The effect of using profiling on the Website may be, for example, reminding about unfinished actions on the Website, granting a discount, sending a proposal for a service that may match the person’s interests or preferences or offering better conditions compared to the standard offer of the Website. Despite profiling, it is the person who decides freely whether he or she wishes to use e.g. a discount or an offer received by the Administrator in this way.
Profiling in the Website consists in automatic analysis or forecast of a given person’s behaviour on the Website, e.g. through analysis of the previous history of activities undertaken in the Website. The condition of such profiling is that the Administrator has the personal data of the person concerned in order to be able to send him/her e.g. a discount or an offer.
The data subject has the right not to be subject to a decision which is based solely on automated processing, including profiling, and produces legal effects concerning that person, or significantly affects him or her in a similar manner

RIGHTS OF THE DATA SUBJECT

Right of access, rectification, restriction, erasure or portability – the data subject shall have the right to request from the Administrator access to his/her personal data, their rectification, erasure (“right to be forgotten”) or restriction of processing and shall have the right to object to the processing, as well as the right to portability of his/her data. The detailed conditions for exercising the rights indicated above are indicated in Articles 15-21 of the GDPR Regulation.
Right to withdraw consent at any time – the person whose data are processed by the Administrator on the basis of expressed consent (pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR Regulation) has the right to withdraw consent at any time without affecting the legality of the processing performed on the basis of consent before its withdrawal.
Right to lodge a complaint to a supervisory authority – the person whose data are processed by the Administrator has the right to lodge a complaint to a supervisory authority in the manner and mode specified in the provisions of the GDPR Regulation.
Right to object – the data subject shall have the right to object at any time – on grounds relating to his/her particular situation – to the processing of personal data concerning him/her based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interest of the Administrator), including profiling under these provisions. The Administrator shall in that case no longer be permitted to process such personal data unless the Administrator demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defence of claims.
Right to object to direct marketing – where personal data are processed for the purposes of direct marketing, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, including profiling, insofar as the processing is related to such direct marketing.
In order to exercise the rights referred to in this section of the privacy policy, the Administrator may be contacted by sending an appropriate message in writing or by e-mail to the address of the Administrator indicated at the beginning of the privacy policy.

COOKIES ON THE WEBSITE AND ANALYTICS

Cookies are small pieces of information in the form of text files sent by a server and stored on the website visitor’s side (e.g. on the hard drive of a computer, laptop or smartphone memory card – depending on the device used by the website visitor). Detailed information on cookies, as well as the history of their creation can be found, among others, here: https://en.wikipedia.org/wiki/HTTP_cookie
Cookies that may be sent by the Website can be divided into different types, according to the following criteria:

According to their provider:

1. own (created by the Administrator’s website) and

2. belonging to third parties (other than Administrator)

On account of their storage period on the device of a person visiting the website:

1. session (stored until logout from the Website or switching off the web browser) and

2. permanent (stored for a specified period of time, defined by the parameters of each file or until manual removal)

Due to the purpose of their use:

1. necessary (enabling proper functioning of the Website),

2. functional/preferential (enabling adjustment of the website to the visitor’s preferences),

3. analytical and efficiency (gathering information on the manner of using the website),

4. marketing, advertising and social networking (gathering information about the person visiting the Website in order to display personalised advertising to that person and to conduct other marketing activities, including on websites separate from the Website, such as social networking sites).

3. The Administrator may process the data contained in cookies when visitors use the Website for the following specific purposes:

Purposes of using cookies on the Administrator’s Website	To identify Users as logged in to the Website and to show that they are logged in (essential cookies)
	memorizing data from filled forms, surveys or login data to the Website (necessary cookies and/or functional/preferential cookies)
	adjusting the content of the Website to individual User preferences (e.g. concerning colours, font size, page layout) and optimisation of use of the Website’s pages (functional/preference cookies)
	Conducting anonymous statistics presenting the manner of use of the Website’s pages (analytical and efficiency cookies)
	displaying and rendering advertisements, limiting the number of advertisements displayed and ignoring advertisements which the User does not want to see, measuring the effectiveness of advertisements, as well as personalisation of advertisements, i.e. research into the behaviour of visitors to the Website through anonymous analysis of their actions (e.g. repeated visits to specific sites, keywords etc.) in order to create their profile and provide them with advertisements tailored to their predicted interests, also when they visit other websites in the advertising network of Google Ireland Ltd. and Facebook Ireland Ltd. (marketing, advertising and social networking cookies)

4. Checking in the most popular web browsers which cookies (including the duration of cookies and their provider) are being sent at a given moment by the Website is possible in the following way:

In the Chrome browser::

(1) in the address bar click on the padlock icon on the left, (2) go to the “Cookies” tab

In Firefox browser:

(1) in the address bar, click on the shield icon on the left, (2) go to the “Allowed” or “Blocked” tab, (3) click on the box “Tracking cookies between sites”, “Social network tracking elements” or “Content with tracking elements””

In Internet Explorer browser:

(1) click the “Tools” menu, (2) go to the “Internet Options” tab, (3) go to the “General” tab, (4) go to the “Settings” tab, (5) click the “View Files” box

In the Opera browser:

(1) in the address bar click on the padlock icon on the left, (2) go to the “Cookies” tab

In the Safari browser:

(1) click on the “Preferences” menu, (2) go to the “Privacy” tab, (3) click on the “Manage site data” box

Irrespective of the browser, using the tools available, for example, at: https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/

5. By default, most web browsers on the market accept the storage of cookies. You can determine the conditions for the use of cookies by means of your browser settings. This means that you can, for example, partially limit (e.g. temporarily) or completely disable the possibility to save cookies – in the latter case, however, this may affect some of the functionalities of the Website.

6. The settings of your Internet browser regarding cookies are important from the point of view of your consent to the use of cookies by our Website – in accordance with the regulations, such consent may also be expressed through the settings of your Internet browser. Detailed information about changing the settings for cookies and their independent deletion in the most popular web browsers is available in the help section of your web browser and on the following pages (just click on the link):

Chrome

Firefox

Internet Explorer

Opera

Safari

Microsoft Edge

7. The Administrator may use Google Analytics and Universal Analytics services on the Website provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). These services help the Administrator keep statistics and analyse traffic on the Website. The data collected are processed by the above services to generate statistics that help administer the Website and analyse Website traffic. The data are of an aggregate nature. The Administrator, using the above services in the Website, collects such data as sources and medium of obtaining persons visiting the Website and their behaviour on the Website, information on devices and browsers from which they visit the Website, IP and domain, geographical data and demographic data (age, gender) and interests.

8. It is possible for a person to easily block the release of information to Google Analytics about their activities on the Website – for this purpose, for example, you can install a browser add-on provided by Google Ireland Ltd. available here: https://tools.google.com/dlpage/gaoptout?hl=en.

9. In connection with the Administrator’s possibility to use advertising and analytical services provided by Google Ireland Ltd. on the Website, the Administrator informs that full information on the principles of processing of the data of the Website visitors by Google Ireland Ltd. (including the information saved in cookies) can be found in Google’s privacy policy: https://policies.google.com/technologies/partner-sites.

FINAL PROVISIONS

The Website may contain links to other websites. The Administrator encourages the users to familiarise themselves with the privacy policy of other websites after having visited them. This privacy policy applies only to the Administrator’s website

Cookie	Duration	Description
cookielawinfo-checkbox-advertisement	1 year	Set by the GDPR Cookie Consent plugin, this cookie is used to record the user consent for the cookies in the "Advertisement" category .
cookielawinfo-checkbox-analytics	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Analytics".
cookielawinfo-checkbox-functional	11 months	The cookie is set by GDPR cookie consent to record the user consent for the cookies in the category "Functional".
cookielawinfo-checkbox-necessary	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookies is used to store the user consent for the cookies in the category "Necessary".
cookielawinfo-checkbox-others	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Other.
cookielawinfo-checkbox-performance	11 months	This cookie is set by GDPR Cookie Consent plugin. The cookie is used to store the user consent for the cookies in the category "Performance".
viewed_cookie_policy	11 months	The cookie is set by the GDPR Cookie Consent plugin and is used to store whether or not user has consented to the use of cookies. It does not store any personal data.

Cookie	Duration	Description
_ga	2 years	The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
_gat_UA-188023538-1	1 minute	A variation of the _gat cookie set by Google Analytics and Google Tag Manager to allow website owners to track visitor behaviour and measure site performance. The pattern element in the name contains the unique identity number of the account or website it relates to.
_gid	1 day	Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.
CONSENT	2 years	YouTube sets this cookie via embedded youtube-videos and registers anonymous statistical data.

Cookie	Duration	Description
VISITOR_INFO1_LIVE	5 months 27 days	A cookie set by YouTube to measure bandwidth that determines whether the user gets the new or old player interface.
YSC	session	YSC cookie is set by Youtube and is used to track the views of embedded videos on Youtube pages.
yt-remote-connected-devices	never	YouTube sets this cookie to store the video preferences of the user using embedded YouTube video.
yt-remote-device-id	never	YouTube sets this cookie to store the video preferences of the user using embedded YouTube video.

PRIVACY POLICY FOR THE SUPLIFT.IO WEBSITE

GENERAL PROVISIONS

GROUNDS FOR DATA PROCESSING

PURPOSE, BASIS AND DURATION OF DATA PROCESSING ON THE WEBSITE

RECIPIENTS OF DATA ON THE WEBSITE

PROFILING ON THE WEBSITE

RIGHTS OF THE DATA SUBJECT

COOKIES ON THE WEBSITE AND ANALYTICS