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Simplito sp. z o.o.

1-3 Grudziądzka

87-100 Toruń, Poland

KRS 0000305883

VAT EU: PL9562217643

Share Capital: 336 100 PLN

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Privacy Policy

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PRIVACY POLICY OF SIMPLITO SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ 1. Who is the controller of your personal data? 2. How can you contact the Data Controller? 3. On what basis and for what purpose do we process your personal data? 4. Who may have access to your personal data? 5. How long do we store your personal data? 6. What are your rights in relation to the processing of personal data? 7. What else is worth knowing?8. Cookies

PRIVACY POLICY OF SIMPLITO SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ

As an internet company that creates secure IT tools, we take privacy issues very seriously. We highly value your personal information and always treat it with the utmost confidentiality. We understand that you may require the highest standard of confidentiality and compliance with rules concerning personal data processing. We operate in accordance with the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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: the Regulation). That is why we have created this privacy policy, in which we have outlined the most important principles related to the processing of your personal data.

 1. Who is the controller of your personal data?

This Privacy Policy concerns various cases of our processing of Personal Data. In each of the cases described in this Privacy Policy, we, Simplito sp. z o.o., with its registered office in Toruń, address: ul. Grudziądzka 1-3, 87-100 Toruń, Poland, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court in Toruń, VII Commercial Division of the National Court Register, under KRS No.: 0000305883, NIP: 9562217643, REGON: 340400555, share capital: PLN 336 073,60, are the data controller of your Personal Data.

In this Privacy Policy, the term "Personal Data" means any information relating to an identified or identifiable natural person, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier (such as an IP address) or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

 2. How can you contact the Data Controller?

You can contact the Data Controller in the following ways:

  • by sending an email to: office@simplito.com,
  • by post, by sending a letter to the following address: Simplito sp. z o.o., ul. Grudziądzka 1-3, 87-100 Toruń.

 3. On what basis and for what purpose do we process your personal data?

We may process personal data for the following purposes and on the following legal bases:

Scope of processing       Purpose of processing       Legal basis Duration of the processing
If you visit one of our websites, such as simplito.com, privmx.com, privmx.dev or one of our other websites. We process your personal data to ensure the proper functioning of the website, to analyze website traffic, and to create statistics concerning the use of the website using analytical tools. We also process personal data to ensure the security of the websites, to counteract any activities that are contrary to generally applicable laws, as well as to prevent abuse and other violations. We may process, in particular, data contained in website visit logs and cookies or similar technologies, such as your IP address, information about your device and browser, identifiers, and information about your activity on the website. We may also collect data regarding how you were referred to our sites via other websites. The legal basis for processing the data necessary to ensure the proper and secure functioning of the website and to prevent fraud and violations of law is Article 6(1)(f) of the Regulation. The legitimate interest of the controller is to operate and secure the website and prevent abuse.We process your personal data for as long as you use the website and for up to six months after your last visit."
If you use the contact form or chat feature on the website, send us a message to the email address provided on the website, or contact us by phone or by mail. We process your personal data for the purpose of answering your questions, contacting you, and exchanging messages.The legal basis for data processing in this regard is Article 6(1)(f) of the Regulation, which allows data processing when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. The legitimate interest of the controller in this case is the need to process data in order to answer individuals' messages, maintain contact with them, and respond to their questions.We process your personal data for as long as the contact between us lasts and for a period of 2 consecutive months.
If you contact us to establish cooperation with us as a potencial customer or business partner.If you contact us to establish cooperation with us, we process your personal data in order to take action at your request prior to entering into a contract. This may cover processing your your personal data for the purpose of getting information about your requirements or propositions, presenting you an offer, negotiating with you or concluding a contract between us and you - our customer or business partner.The legal basis for the processing of personal data is Article 6(1)(b) of the Regulation, which allows for the processing of data when it is necessary for taking action at the request of the data subject prior to entering into a contract or for the conclusion and performance of a contract to which the data subject is party.We process your personal data for the duration of our communication and negotiations between us. If we conclude an agreement and begin our cooperation, we will process your personal data in accordance with the information below regarding concluded contracts.
If you are our customer, supplier, service provider, business partner, or if you cooperate with us on the basis of a civil law contract. We process your personal data for the purpose of performing a contract between us and you — our customer, supplier, service provider, or business partner. This may include the provision of services to you, financial settlements, or using services or products provided by you, in accordance with our mutual arrangements and the content of contracts concluded between us. In addition, in such a case, we process your data in order to fulfill our legal obligations in connection with the conclusion and performance of contracts, in particular accounting and tax obligations.The legal basis for the processing of personal data is Article 6(1)(b) of the Regulation, which allows for the processing of data when it is necessary for the conclusion and performance of a contract to which the data subject is a party, or for taking steps at the request of the data subject prior to entering into a contract. To the extent that data processing relates to the fulfillment of our tax and accounting obligations, we process it on the basis of Article 6(1)(c) of the Regulation, which allows for the processing of data when it is necessary for compliance with a legal obligation to which the controller is subject.We process your personal data for as long as the contract between us is valid and until the claims expire (up to 3 years after the termination or expiry of the contract). Data processed for the purpose of fulfilling accounting and tax obligations will be processed for a period of 5 years from the end of the tax year in which the tax liability payment deadline expired.  
If you are a person acting on behalf of our customer, supplier, service provider, or business partner (i.e., an entity that has entered into a contract with us) and are therefore contacting us as a representative of the customer, supplier, service provider, or business partner (e.g., as a member of the management board, employee, or associate). We process your personal data for the purpose of concluding or performing a contract between us and the customer, supplier, service provider, or business partner.The legal basis for the processing of your personal data is Article 6(1)(f) of the Regulation, which states that data processing is permissible when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. The legitimate interest of the controller in this case is specifically the performance of the agreement between us and our customer, supplier, service provider, or business partner, which requires contacting representatives of that entity.We process your personal data for as long as the contract between us and an organization you represent is valid and until the claims expire (up to 3 years after the termination or expiry of the contract).  
If you register for our service, accept our Terms of Service, and use our online services. We process your personal data for the purpose of the provision of services, in particular to register and manage your account, provide access to our online services, generate and manage the licence key, and provide related user support. We may also process your personal data to fulfill our legal duties, in particular those related to tax, accounting, and financial reporting requirements arising from the services provided to you.The legal basis for processing your personal data is Article 6(1)(b) of the Regulation, stating that processing is allowed when it is necessary for the performance of a contract (Terms of Service) to which you are a party. To the extent that data processing relates to the fulfillment of our legal obligations, we process it on the basis of Article 6(1)(c) of the Regulation, which allows for the processing of data when it is necessary for compliance with a legal obligation to which the controller is subject (e.g. tax and accounting laws).We process your personal data for as long as you are a user of our services and for three years after you stop using them.
If you request access to software made available free of charge under a license that requires registering an account and obtaining or activating a license key. We process your personal data to register your account, verify your entitlement to use the software, generate, issue, activate, and manage the license key, provide access to the software, and provide support related to the license.The legal basis for processing your personal data is Article 6(1)(b) of the Regulation, as processing is necessary to take steps at your request or to perform a license agreement concerning the use of the software.We process your personal data as long as you use our software and for three years after you cease to use it.
If you use our online services e.g., when you browse one of our online platforms, interact with its features, or log into your account. We process your personal data to monitor the way in which our online services are being used. This includes processing of personal data for statistical purposes and the developing our services, preventing errors and bugs, ensuring an appropriate level of security, and creating updates or possible fixes. This may also include processing personal data to prevent actions which are not in accordance with our Terms of Service or generally applicable law.The legal basis for processing your personal data is Article 6(1)(f) of the Regulation, as the processing is necessary to achieve the objectives of our legitimate interests, which consist of ensuring network and information security, improving the quality of our software, and protecting our services against abuse or unlawful activities. We process your personal data for as long as you are a user of our services and for three years after you stop using them.
If you register for or participate in an event, presentation, conference, webinar, workshop, or another event organized or co-organized by us We process your personal data in order to register participants, organize and conduct the event, communicate organizational information, confirm attendance, provide access to the event or event materials, and handle matters relating to participation.The legal basis for processing your personal data is Article 6(1)(f) of the Regulation. The legitimate interest of the controller is to efficiently organize and conduct events, communicate with participants, document participation where necessary, and ensure the proper organization and security of the event.We process your personal data for the time necessary to organize and conduct the event and complete the related communications, and until the claims expire (up to 3 years after the event ends).
If you subscribe to our newsletter or otherwise request marketing or informational communications from us We process your personal data, in particular your email address and any other data provided during subscription, in order to manage the subscriber list, send you the newsletter and other requested communications, and analyze the delivery and use of such communications. We use MailerLite to manage the subscriber list and distribute the newsletter. You may unsubscribe at any time by using the unsubscribe link included in each newsletter or by contacting us. The legal basis for processing your personal data for newsletter purposes is your consent pursuant to Article 6(1)(a) of the Regulation. You may withdraw your consent at any time without affecting the lawfulness of processing carried out before its withdrawal.If you subscribe to our newsletter, we process your personal data until you withdraw your consent or unsubscribe from the newsletter. After that time, we may retain only the data necessary to demonstrate compliance with legal requirements or to establish, pursue, or defend legal claims for the applicable limitation period.
If you contact us to participate in the recruitment process, you fill out our recruitment form or send us your CV.We process your personal data for the purpose of conducting the recruitment process. Additionally, if you agree, we process your data to contact you in future recruitment processes.The legal basis for the processing of personal data in the recruitment process is Article 6(1)(b) of the Regulation, which allows the processing of personal data when it is necessary for the conclusion of a contract with the data subject. The scope of the data processed is based on the provisions of the Labor Code, which specifies the basic data that an employer may require in the recruitment process. If you provide other data that is not covered by the provisions of the Labor Code, the legal basis for the processing of personal data is Article 6(1)(a) of the Regulation, which allows for the processing of personal data on the basis of the consent of the data subject. If you express your willingness to participate in future recruitment processes, the legal basis for the processing of personal data is also your consent.If you are participating in the recruitment process, in the case of processing within the framework of the recruitment process, we process your data until the end of the recruitment process. However, if you have consented to participate in future recruitment processes, we will process your data for a period of up to 1 year from the date of submission of your recruitment documents.
If you contact us to participate in the recruitment process, you fill out our recruitment form or send us your CV.We process your personal data for the purpose of conducting the recruitment process. Additionally, if you agree, we process your data to contact you in future recruitment processes.The legal basis for the processing of personal data in the recruitment process is Article 6(1)(b) of the Regulation, which allows the processing of personal data when it is necessary for the conclusion of a contract with the data subject. The scope of the data processed is based on the provisions of the Labor Code, which specifies the basic data that an employer may require in the recruitment process. If you provide other data that is not covered by the provisions of the Labor Code, the legal basis for the processing of personal data is Article 6(1)(a) of the Regulation, which allows for the processing of personal data on the basis of the consent of the data subject. If you express your willingness to participate in future recruitment processes, the legal basis for the processing of personal data is also your consent.If you are participating in the recruitment process, in the case of processing within the framework of the recruitment process, we process your data until the end of the recruitment process. However, if you have consented to participate in future recruitment processes, we will process your data for a period of up to 1 year from the date of submission of your recruitment documents.
If you interact with our social media profiles (e.g., follow our page, like or comment on our posts, send us a message) or use social media plug-ins on our website.We process your personal data (such as name, surname, contact details, and content of interaction) in order to promote our services and company, manage our social media fanpages or communicate with you and respond to your inquiries.The legal basis for processing your personal data is Article 6(1)(f) of the Regulation, as the processing is necessary to achieve the objectives of our legitimate interests, which consist of marketing our services, building a brand image, and ensuring easy communication with users. Due to the nature of social media, we act as joint controllers of your data together with the social media platform providers. Detailed information about their data processing can be found in their respective privacy policies.We process your personal data for as long as you interact with our social media profiles.

| The legal basis for the processing of personal data in the recruitment process is Article 6(1)(b) of the Regulation, which allows the processing of personal data when it is necessary for the conclusion of a contract with the data subject. The scope of the data processed is based on the provisions of the Labor Code, which specifies the basic data that an employer may require in the recruitment process. If you provide other data that is not covered by the provisions of the Labor Code, the legal basis for the processing of personal data is Article 6(1)(a) of the Regulation, which allows for the processing of personal data on the basis of the consent of the data subject. If you express your willingness to participate in future recruitment processes, the legal basis for the processing of personal data is also your consent. | If you are participating in the recruitment process, in the case of processing within the framework of the recruitment process, we process your data until the end of the recruitment process. However, if you have consented to participate in future recruitment processes, we will process your data for a period of up to 1 year from the date of submission of your recruitment documents. |
| In the event of a dispute, complaint, or potential legal issue. | We may process your personal data for the establishment, exercise, or defence of legal claims. | The legal basis for processing your personal data is Article 6(1)(f) of the Regulation, as the processing is necessary to achieve the objectives of our legitimate interests, which consist of protecting our legal and economic rights, pursuing claims, and defending our company in any out-of-court, legal, or administrative proceedings. | We process your personal data for the duration of the dispute or legal or court proceedings and up to six years after the end of such proceedings. |

 4. Who may have access to your personal data?

we inform you that we do not sell your Personal Data to any third parties. However, in order to properly provide our services and conduct the activities described in this Privacy Policy, we use the assistance of third parties. Depending on the purpose and scope of processing, your personal data may be disclosed or entrusted, to the extent necessary, to:

  • providers of IT, cloud, maintenance, cybersecurity, communication, and other technical services, as well as subcontractors whose services we use in connection with our business;
  • the entity providing hosting services for us — OVH sp. z o.o. with its registered office in Wrocław, ul. Swobodna 1, 50-088 Wrocław;
  • Google Ireland Limited and Google LLC, with its registered office in Mountain View, California, USA, as entities involved in the provision of the Google Analytics service used to analyze website traffic;
  • MailerLite Limited with its registered office at 88 Harcourt Street, Dublin 2, D02 DK18, Ireland, as the provider of the system used to manage the subscriber list and distribute the newsletter;
  • providers of legal, tax, accounting, auditing, and other professional advisory services.

In connection with our use of Google Analytics, personal data may be transferred to Google LLC in the United States. The transfer of personal data to the United States is based on the adequacy decision adopted by the European Commission under the EU–U.S. Data Privacy Framework.

In connection with visiting our profile on LinkedIn, your personal data may be transferred to LinkedIn Corp., with its registered office in San Francisco, California, USA. The transfer of personal data to the United States is based on the adequacy decision adopted by the European Commission under the EU–U.S. Data Privacy Framework.

 5. How long do we store your personal data?

 We strive to store your personal data only for as long as it is actually necessary, and we delete it after that time. The detailed storage period for your personal data depends on how you interact with us and each of the case is described in point 3 of this privacy policy.

 6. What are your rights in relation to the processing of personal data?

  1. Right of access: You may request confirmation from us that your personal data is being processed and obtain relevant information about it, including what data is being processed and for what purpose.
  2. Right to rectification: You have the right to request the immediate rectification of inaccurate personal data and the completion of incomplete personal data.
  3. Right to erasure: You have the right to request the immediate erasure of personal data if one of the following circumstances applies:
  •  personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
  • you withdraw your consent (if the processing is based on consent) and there is no other legal basis for the processing;
  • you have objected to the processing and there are no overriding legitimate grounds for the processing;
  • the personal data has been processed unlawfully;
  • the personal data must be erased to comply with a legal obligation;
  • the personal data has been collected in relation to the offer of information society services to a child.
  1. Right to restrict processing: You have the right to request that the processing of your personal data be restricted if:
    - you contest the accuracy of the personal data;
    - the processing is unlawful, but you oppose the erasure of the personal data and request the restriction of its use instead;
    - we no longer need the personal data for processing purposes, but you need it to establish, pursue, or defend legal claims;
    - you have objected to the processing of the data.
  2. Right to data portability: You have the right to receive your personal data in a structured, commonly used, machine-readable format and to transmit those personal data to another controller, where the processing is based on consent or on a contract and is carried out by automated means. You also have the right to request that we transfer this data directly to another controller, if technically feasible.
  3. Right to lodge a complaint: You have the right to lodge a complaint about unlawful processing of personal data with the supervisory authority – the President of the Personal Data Protection Office (at the address of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw).
  4. Right to object: You have the right to object to the extent that the processing is based on our legitimate interest.
  5. Right to withdraw consent: If personal data is processed on the basis of consent, you have the right to withdraw your consent at any time without affecting the lawfulness of the processing that was carried out on the basis of consent before its withdrawal.

 7. What else is worth knowing?

Your personal data will not be used for automated decision-making, including profiling, referred to in Article 22(1) and (4) of the Regulation.

Providing personal data is voluntary, but in the case of data processing for the purpose of concluding or performing a contract with us, failure to provide data may result in our inability to provide services. In the case of participation in recruitment, failure to provide personal data specified in the Labor Code may result in the candidate not being considered in the recruitment process.

Providing certain personal data may also be necessary in order to create or maintain an account, use a service, obtain or activate a licence key, or register for and participate in an event. Failure to provide the required data may make it impossible for us to perform the relevant activities or provide the requested service, software, licence, or access.

8. Cookies

Cookies are small files that enable or facilitate the use of certain website features. They may be stored on your device directly by us or by third parties with whom we cooperate. When using cookies, we may process personal data, in particular such as your IP address, website usage history, or information about the device or software you are using. The cookies we use are related to the functioning of our website and are used to control traffic on the website, compile statistics on the use of the website by its users, prevent errors and technical malfunctions, ensure the security of the website, and prevent abuse and violations of the law.

The following cookies are distinguished:

  • Session cookies: these are stored on your device while you are using our website (they are deleted when you close your browser). Session cookies enable the proper use of our website. Blocking them may result in errors or prevent you from using the website.
  • Persistent cookies: these are stored on your device until you delete them or until they expire.

Our website uses technical cookies. These files are necessary for the proper display, security, and functioning of the website. They may also detect irregularities in the functioning of the website, help correct errors, prevent abuse, and record or verify the scope of the user's cookie choices. Because they are necessary for the website to function properly, their use does not depend on consent. Blocking them may cause the website to malfunction.

Our website also uses analytical cookies and similar technologies connected with Google Analytics. They are used to collect information about how visitors use the website, distinguish users and sessions, measure website traffic, and prepare statistics concerning the use of the website. Analytical cookies are used only after you have given your consent.

You may give, refuse, withdraw, or change your consent to analytical cookies at any time using the cookie settings available on our website. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal.

Please note that you can restrict or disable cookies on your device using your web browser settings. Web browsers allow you to disable all cookies or some of them (e.g., those from third parties). If you disable some cookies, cookies generated by our website may still be stored on your device to ensure that the website functions properly. However, if you restrict the use of cookies, your use of our individual services may be limited and, in some cases, may not be possible.