Basic information

The administrator of the personal data, the processing rules of which we describe in this document, is the fundcja digitalpoland (hereinafter: the Foundation, we) with its registered office at 10 Pilotów Street, Krakow, 31-462, Poland and operational HQ at Warsaw Spire, 35.p, Plac Europejski 1, 00-844, Warsaw, Poland

Contact details of the portal organizer

E-mail: [email protected]

Address for correspondence: Fundacja digitalpoland, ul. Plac Europejski 1, 00-844 Warszawa, Polska.

What is governed by the privacy policy

In this Privacy Policy you will find all the necessary information on how we process the personal data you have entrusted to us, to what extent, for what purpose, for how long, and what your rights under this title are.

We make every effort to ensure that all our activities related to personal data are in accordance with the law and the statute, mission and values that the digitalpoland Foundation represents, and that they are based on respect for the privacy and autonomy of the persons whose data we process.

Where and how we process data

Most of the data is stored in electronic form: mainly on a rented Microsoft office365 and Google Drive server, and – to a limited extent – on office computers, external drives and phones. We process the data using IT tools used by the team: primarily e-mails and clouds to store the files. We store some of the data in the form of paper documentation.

Data processing agreemnts

We entrust personal data for processing to entities with which we permanently cooperate:

the entity responsible for providing accounting services to the Foundation (concerns the data of persons making donations to the Foundation and making payments as part of our services).  This entity acts on the basis of an entrustment agreement and is obliged to protect personal data on an equal footing with us.

to postal intermediaries in the case of using traditional mail communication (Polish Post and other companies operating under the postal law) on the basis of entrustment agreements and/or service regulations.

in some situations we provide data to other recipients (e.g. those cooperating with us in the organization of workshops or other events). In such cases we always inform about it in advance, e.g. during registration.

If we state in form, or any other electronic place, that we do not send your data to 3rd parties than this information is excluded from data processing agreements. We use this data for a specific form.

Rights of persons whose data we process

All persons whose data we process are entitled to access the content of their data, the right to obtain a copy of their data, as well as the right to demand rectification and, in certain cases, the removal or restriction of their processing.

Persons whose data we process on the basis of our legitimate interest may object by declaring that they do not wish us to use their data in this way.

If we process your data for the purpose of fulfilling a contract that consists of sending you pre-solicited materials (e.g. newsletter), you can cancel it at any time (see below). Other contracts (e.g. donations) can be terminated according to the terms of law or the contract itself. If we process data on the basis of your consent, you can withdraw your consent at any time. In these two cases (where we process data on the basis of a contract or consent), the persons whose data we process are also entitled to request the transfer of their data.

Your comfort, also in taking into account your rights from the processing of your personal data, is very important to us. However, for security reasons, before we exercise your right to inspect your data, we may ask you to provide additional information to ensure that we are making it available to its actual owner.

If you believe your rights have been infringed, you have the right to complain to the President of the Data Protection Authority in Poland. However, we encourage you to contact us anyway. We will use our best endeavours to clarify any doubts and at the same time eliminate any possible irregularities, so as to ensure the security of your personal data, but also of other users of our services.

Whose data are we processing and under what conditions

• Newsletter subscribers’ data
  We process the e-mail addresses of newsletter subscribers in order to send you the information you have ordered – this is necessary to fulfil the contract you have concluded with us by subscribing to the newsletter on our website. Providing the data is voluntary, but necessary to order mailing. We record clicks in our newsletters, i.e. we have access to information about who opens which links. We need this data in order to know how many people are familiar with the content we offer. However, we only analyse aggregate information, not the activity of individual recipients. You can unsubscribe from the newsletter at any time by clicking on the unsubscribe link in the email footer. If necessary, you can always contact us by email or post and submit your comments. We process the data of former subscribers to a given list on the basis of our legitimate interest to manage the relationship for 4 years from the end of the calendar year in which we recorded the last interaction with the person concerned (e.g. we received a donation, recorded the cancellation of the newsletter or participation in an event organised by us requiring registration). If you want us to remove earlier the information that you have ever subscribed to any of the letters, please send your objection to: [email protected].
• Website user data
  We process the data of users of the www.digitalinnovationcee.org website. Through our website we collect data only to the extent necessary to manage these sites, ensure the smooth operation of the offered functionality and analyze the effectiveness of communication. The described rules apply only to services located in the domain www.digitalinnovationcee.org. We are not responsible for the privacy policy of other websites to which links are provided on our sites.
  
• Data of hackathon and other contest participants
  When organizing a contest or hackathon the scope of information that we will proces, will be stated in its regulations. Usually we limit ourselves to collecting the participants’ email address and name, mailing address and the winner’s prize sent. We process the data e.g. for the purpose of contest settlement and sending the prizes – this is necessary to fulfill the agreement. Providing data is voluntary, but necessary to take part in the competition.After the contest, we process the data on the basis of our legitimate interest in order to manage the relationship. We process the data of contest participants for 5 years from the end of the calendar year in which we recorded the last interaction with a given person (e.g. we received a donation, we recorded resignation from the newsletter or participation in an event organised by us).

  If you want us to remove them earlier, please send your objection to [email protected].

• Data of persons filling in questionnaires and competition entries
  We consult with the people of the institutions and companies for which we operate. That is why we publish questionnaires, e.g. asking how the Foundation, its projects or any problem we deal with is perceived. Such surveys do not collect any additional data (including e.g. IP addresses). We also collect data for the purpose of posting information about contests and projects. Please do not provide any personal information in surveys. However, if you choose to provide it, we will process it on the basis of our legitimate interest for archiving purposes, until the end of the Foundation’s activities. 

  If you want us to delete it earlier, please send your objection to [email protected].

• Data of participants and participants in public events
  In case of organizing open public events we do not ask for personal data. In case of events requiring registration, as a rule, we ask for: first and last name, e-mail address, telephone number, unless the nature of the event (e.g. workshops) will require gathering other information. In this case, providing data is voluntary, but necessary to register for the event. We process these data for the purpose of organizing the event – this is necessary to fulfill the contract. After the event, we process the data on the basis of our legitimate interest to manage the relationship. 

  We process the data of qualified and other persons registering for events requiring registration for 5 years from the end of the calendar year in which we recorded the last interaction with a given person (e.g. we received a donation, we recorded resignation from the newsletter or participation in an event organised by us).If you want us to remove them earlier, please send your objection to [email protected]. In the case of events organised with the grantors’ funds requiring us to keep the documentation for a longer period of time, the relevant information will be made available when signing up for the event. When organizing some events, we additionally ask for permission to inform about other initiatives of similar nature. The person who gave it can withdraw it at any time and has the right to request the transfer of their data. If he does not do so, we will keep his data until the end of the Foundation’s activity.

• Data of persons using non-public communication channels
  The data of persons whom we contact by e-mail (addresses in the domain digitalpoland.org), by phone, SMS or letter, are processed on the basis of a legitimate interest, for the purpose of handling correspondence, for the purposes resulting from the content of the communication or to establish contact in the future. This data may include your name, address, e-mail address, telephone number and any other information contained in the content of the message. The provision of this data is voluntary. 

  We process the data for archiving purposes and for the purpose of managing relations until the end of the Foundation’s activities, with the exception of data of a sensitive nature (e.g. information from whistleblowers), which we delete or anonymize immediately after the closure of the case. We encourage you to send us interesting information. When writing or calling us, try not to provide unnecessary data. If we need additional information, we will ask for it.We reserve the right to make public (e.g. by posting on the website) the information sent to us in relation to the topics dealt with by the Foundation, but without disclosing personal data.

• Data of persons communicating with the portal through social networking sites
  Facebook, Linkedin and Twitter are the controllers of your personal data and process them according to their own rules. When you interact with us via Facebook, Linkedin or Twitter (liking/watching the site, reactions to posts, shares/retweets, comments, private messages), in addition to Facebook, Twitter, Linkedin and the Portal Foundation, the administrator of your personal data becomes the Portal Foundation. We process data such as name, surname/nick, image, public profile and other information provided in messages or comments, based on our legitimate interest, to respond to comments and messages, to maintain relations with people interacting with us, and to analyse the effectiveness of communication. As a general rule, we do not link your interactions with us on Facebook with information you provide to us in other ways (e.g., by e-mail), unless something else is relevant to the circumstances (e.g., you wrote us a private message on Facebook asking us to contact you). We do not pass on your personal data to anyone. Please note, however, that all information about you can be accessed by Facebook or Twitter as administrators respectively. If you want your data to be processed in accordance with our Privacy Policy (cf. Data of persons contacting us by e-mail, telephone or letter), we encourage you to contact us via channels other than social networks. If you write to us by email, for example, we have control over what happens to this information and who reads it.
  

Cookies files

On our websites we use text cookies (cookie fields) which are necessary for the technical operation of the websites and use of the offered functionalities. Cookies are not used by us to track user navigation. We do not place cookies on our websites of other entities, e.g. companies from the behavioural advertising industry. www.digitalinnovationcee.org only uses cookies to create anonymous statistics about visits to these websites, respecting the “Do not track” setting in your browser. You can manage cookies through your browser settings. Registration for our mailing lists (e.g. newsletter) takes place through forms on our sites or partners. These websites use a cookie to ensure the functionality of the forms and cookies to store information about the completion of the form.

This Privacy Policy is effective from 25 May 2018.