Privacy Policy of Hustro sp. z.o.o.

OF 15 Feb 2021.

basis of your interaction with us or our offers, including data obtained using the so-called cookies and any other tracking technologies. We also collect your personal data from third parties.

Information, including personal data, that you provide to us:

We collect information directly from you, for example when registering to create an account in the application or on our website or to use our offer, register a product or service, interactions related to one from our events, surveys, activities or social media, visiting our facilities or otherwise contacting us. The types of information we may collect from you include:

1. Identifiers such as your name, telephone number, physical address and/or e-mail address, the IP address of the device from which you log in, your account username, and your account password.
2. Professional information, such as occupation, industry, professional licenses, work experience, and employment history, and other qualifications.
3. Commercial information, such as details of your subscription plans, licenses, offers you have purchased, used and/or expressed interest in, and events you have attended.
4. Account-related financial information, such as payment information that you provide when making a purchase or in response to an offer.
5. Education information such as your education (e.g. engineering degree),
6. Visual, audio, and electronic information such as your photo or signature; records of our interactions, such as the content of correspondence, details of complaints and their resolution, records of services; Your preferences, including your preferred tools, experience, language, and how often you want to receive marketing communications.

Information, including personal information, that we create:

We automatically collect or create personal information about you based on your interaction with us, for example when you use our application or website, so we may associate this information with your account. The information we collect includes:

1. Identifiers such as unique application user IDs, unique device identifiers, IP addresses of the device from which you log in, cookie IDs, product license information, and user names.
2. Electronic information, such as information about operating systems, device types, browser information, information about automatic updates and technical errors, information about your use of our offer, including your preferred tools and experiences, and your involvement in our actions.
3. Commercial information, such as the register of your interest in our offers or purchases of our products and services.
4. Data inferred from any personal data available to us and information regarding your use of our offer.

When you visit our website and use our application, we use various technologies to collect your personal information that helps to improve the functionality of our services, user experience, and service delivery. For this purpose, we use the so-called cookies. Cookies are text files that contain small amounts of information that are stored on your web browser or device when you visit a website and can be traced back to the original website on each subsequent visit or directed to another website that recognizes the stored cookies.

Information, including personal data, that we collect from third parties:

We receive and process information, including personal data, from third parties such as employers, business contact databases, data enrichment services, business partners, marketing service providers, external data aggPrivacy Policy of Hustro Sp. z o. o. indicates how personal data is processed for the Company’s own purposes. At the same time, Hustro Sp. z o. o. processes personal data also on behalf of its clients on the basis of a written agreement to entrust the processing of personal data, which is part of the license agreement. Hustro Sp. z o. o. does not directly control the practices of processing and protection of personal data of its clients, which may differ from those set out in this privacy policy, nor does it directly affect such practices.

Who is the administrator of your personal data?

The administrator, i.e. the entity deciding how your personal data will be used, is Hustro Sp. z o. o. with its seat in Wrocław at ul. Wyspa Słodowa 7, 50-266 Wrocław (hereinafter “Hustro” or “Company”).

How to contact us for more information on the processing of your personal data?

e-mail address: [email protected]

postal address: ul. Wyspa Słodowa 7, 50-266 Wrocław

What personal data does Hustro collect about you? How does Hustro use the information collected about you?

The company obtains personal data through various methods and sources. We collect some personal data directly from you. Other data is automatically collected or created and relates to the manner, time, andregators, and social networking services and platforms. At the same time, we obtain information from publicly available sources (such as e.g. relevant business registers). The categories of personal information we collect from these sources include:

1. Identifiers such as names, phone numbers, email addresses.
2. Occupational information such as occupations, industries, job licenses, work experience, and employment history, and other qualifications.
3. Educational information, such as education received (e.g. engineering degree).
4. Commercial information, such as events or activities in which you have participated.
5. Inferred data, such as e.g. information on how the application is used and your preferences, behavior, and other attributes.

The provisions of generally applicable law allow you to combine your personal data with information collected from third parties in order to update and increase the accuracy of our databases and provide you with a better-tailored offer.

Do we require you to provide us with your personal data?

We require you to provide the following personal data in order to be able to conclude and perform the concluded contract:

• Data identifying you, including your postal address and address and data to which invoices and bills are to be issued, telephone addresses, telephone numbers, your courtesy form (e.g. Mr. / Mrs.), tax identification number (in the case of sole proprietorship and civil partnerships).

If for some reason you do not provide this personal data, unfortunately, we will not be able to conclude a contract with you, and consequently, you will not be able to use our services.

Some personal data is necessary for us to increase the functionality of our services for you. This includes uploading photos with images of people, providing information such as professional title, work experience, etc. Then, in order to fully use our services, you must provide us with the required personal data. 

If required by law, we may require you to provide other data necessary, for example for accounting or tax reasons. Apart from these cases, providing your data is voluntary. 

How does Hustro use your personal data? 

Your personal data is used in accordance with the purpose of processing them, including in order to:

1. Verify the identity for the proper performance of the contract.
2. Providing services, products, and other offers to fulfill the contract.
3. Send up-to-date information related to the performance of the contract, the method of using the application or our website, also at your request or when sending such information is consistent with the legitimate interest of Hustro.
4. Ensuring the security of our services and its further improvement.  
5. Create anonymized sets of your personal data so that they can no longer be used to identify you, due to our legitimate interest in conducting research and analysis.
6. Improving existing and creating new offers, including through the use of automated systems (machine learning and automated analytical techniques), with your consent.
7. Knowing how to use our offers and the people who use them, with your consent.
8. Analyze information about how you interact with us or may interact with us or use our offers, with your consent.
9. Making strategic decisions about our business.
10. Sending promotional offers, advertisements, or other marketing content, with your consent.
11. Detect, prevent, or otherwise respond to misuses such as fraud or computer piracy.
12. Enforce and verify compliance with legal conditions governing our offers in relation to our legitimate interest.
13. Fulfilling Hustro’s legal obligations resulting from generally applicable provisions.
14. Protect the rights, safety, and property of the Company, our clients, or any third party.
15. For other purposes for which we will obtain your consent.

 

What are your rights to Hustro regarding the processed data?

We guarantee the fulfillment of all your rights under the general data protection regulation, i.e. the right to access, rectify and delete your data, limit their processing, the right to transfer them, not to be subject to automated decision making, including profiling, and the right to object to processing Your personal data. 

You can exercise these rights when:

1. in relation to the request for data rectification: you notice that your data is incorrect or incomplete;
2. in relation to the request to delete data: your data will no longer be necessary for the purposes for which it was collected by the Company; you withdraw your consent to data processing; you object to the processing of your data; Your data are processed unlawfully; the data should be deleted in order to fulfill the obligation resulting from the law or the data has been collected in connection with the provision of electronic services offered to the child;
3. in relation to the request to limit the processing of data: you will notice that your data is incorrect – you may request the restriction of the processing of your data for a period allowing the Company to check the correctness of this data; Your data will be processed unlawfully, but you will not want it to be deleted; Your data will no longer be needed for us, but you may need it to defend or pursue claims; or you object to the processing of data – until it is determined whether the legitimate grounds on our side override the grounds of objection;
4. in relation to a request for data transfer: the processing of your data takes place on the basis of your consent or a contract concluded with you and when this processing is carried out automatically.

You have the right to lodge a complaint in relation to the processing of your personal data by the Company to the supervisory body, which is the President of the Personal Data Protection Office (address: President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw).

In what situations can you object to the processing of your data?

You have the right to object to the processing of your personal data when: the

1. processing of your personal data is carried out on the basis of a legitimate interest or for statistical purposes, and the objection is justified by the particular situation in which you have found yourself;
2. Your personal data is processed for direct marketing purposes, including profiling for this purpose.

The right to object may be exercised from May 25, 2018.

 

How does the company disclose your personal data?

We disclose the above-described categories of information to persons belonging to the following categories:

We share your personal data with our service providers and business partners. We work with carefully selected service providers and business partners who perform certain functions on our behalf. These include, for example, entities that provide us with:

1. technology and software services, i.e. for example, support for our websites, applications, and other business and marketing systems that we use to provide and improve our services;
2. data storage, combination, and analysis services;
3. Courier services;
4. accounting and bookkeeping services of the Company;
5. legal services, including debt collection and other specialized legal services,
6. services and social networking platforms for publicly sharing information or contacting service providers or with you through accounts on or on such services.

As well as entities to which we are required to provide information by law, for example, government, local government, fiscal authorities, common courts or law enforcement agencies.

We only provide our service providers and business partners with the personal data that enables them to provide services to us.

We may share aggregated, anonymous or de-identified demographic, statistical and other information regarding the use of our offer with third parties for marketing, analytical, planning and other purposes. Such information will not uniquely identify any individual user.

How does Hustro protect your data?

We use a combination of a variety of reasonable physical and technical controls to protect your personal data from unauthorized access or malicious activity. The access of employees and associates to your personal data is limited to those persons who need this data to perform their duties and only to the extent necessary for this.

How long do we keep your personal data?

We store your personal data for the duration of the contract concluded with you, as well as after its termination for the purposes of:

1. pursuing claims in connection with the performance of the contract,
2. performance of obligations under the law, including in particular tax and accounting,
3. prevention of fraud and fraud,
4. statistical and archiving, for a

maximum of 10 years from the date of termination of the contract.

We store your personal data for marketing purposes for the duration of the contract or until you object to such processing, depending on which of these events occurs first. 

In order to ensure accountability, i.e. proving compliance with the provisions on the processing of personal data, we will store data for the period in which the Company is obliged to keep data or documents containing them to document the fulfillment of legal requirements and enable control of their fulfillment by public authorities.

Do we transfer your data to countries outside the European Economic Area?

Your personal data will not be transferred outside the European Economic Area (we only use servers located in the European Economic Area). At the same time, we assure you that we never sell your personal data.

Do we process your personal data automatically (including through profiling) in a way that affects your rights?

Yes. Your personal data will be processed in an automated manner (including in the form of profiling).