1 Introduction

This Privacy Policy (called hereinafter "Policy") determines issues related to processing by  company Element Zone LTD headquarters in United Kingdom under address: 85 Great Portland Street, 1st Floor, London, United Kingdom, W1W 7LT entered to proper registry i.e. Companies House under number 10834668 ( called hereinafter "PDA"), Users’ personal data on Website (defined in Terms and conditions). Any terms written in Policy with a capital letter have the meaning that was given them in Terms and conditions indicated under address [*].

2 Data Administrator

  1. The administrator of users' personal data is PDA (Personal Data Administrator).
  2. PDA did not appoint an inspector of Personal Data protection.

3 Legal basis of processing users' data, retention period

  1. Users’ personal data is processing accordingly to Regulation of European Parliament and Council (UE) 2016/679 from April 27, 2016. on the protection of natural people in relation to the processing of personal data and a free flow of such data and repeal of Directive 95/46/EC (hereinafter as GDPR).
  2. The legal basis of processing users' personal data by PDA is:
    1. the need to implement agreements concluded by users and PDA, also taking actions before the conclusion of appointed agreements on users' request (Art.6, para.1 lit. b GDPR);
    2. processing is necessary to fulfill the legal obligation of PDA (Art.6, para.1 lit. c GDPR);
    3. consent of a person whose data apply to process data for marketing purposes, in this sending the commercial information (art.6, para.1 lit. a GDPR).
  3. Provision of users' personal data processed on basis of para.2 point a) is voluntary and is a condition of agreement conclusion i.e. refusal of providing data prevent the user from the use of Website, Services, Account, Electronically Supplied Services and in para.2 point c) Newsletter.
  4. Provision of users' personal data processed on basis of para.2 point c) is voluntary and is a condition of the use of Newsletter and i.e. refusal of providing data will result in lack of possibility to provide by PDA this Electronically Supplied Service for the user.
  5. Provision of users' personal data on basis of para.2 point b) is a statutory requirement.
  6. Users’ personal data processed on basis of para.2 point a) will be processed for the period necessary to conclude and execute the Account Agreement and Agreement, also expiry of the time limits for claims for given agreements.
  7. Users’ personal data processed on basis of para. 2 point b) will be processed for five years counting from the end of the year, in which the PDA tax obligations for the previous year have been met.
  8. Users’ personal data processed on basis of para.2 point c) will be processed for period indefinite from the moment of withdrawal of granted users' consent and withdrawal of Newsletter agreement.
  9. Granted consent, referred to in para.2 point c) of this section can be withdrawn by the user at any given moment, and given personal data will be deleted both independently by the user and through sending to PDA such request to the address [*]. Withdrawal of users' consent will not have the impact on the legality of processing by PDA users' personal data in the period from the moment of consent granted till the moment of its withdrawal.

4 Goal and range of processing users' data

  1. Provided by users personal data will be processed for the and in the range of necessary in relation to conclusion and execution of Agreement, Account Agreement, Agreements about the provision of electronically supplied services, Newsletter Agreement, fulfillment by PDA legal obligations and for purposes of the direct marketing for goods and services provided by PDA.
  2. In order to conclude and execute the agreement PDA will process given by users following data: name, surname, address of residence, email address, data about professional experience, skills, education, added friends, projects to which user is assigned, photo, age, range of services that the Service Provider uses, selected Subscription Plan and information associated with it, entrepreneur’s logotype, description of activity subject.
  3. In order to fulfill the legal obligations, PDA will process following users’ data: name, surname, company, address, email address, Subscription price, selected Subscription Plan, number NIP.
  4. In order to send the user an information and commercial materials in form of newsletter PDA will process given by users email address.

5 Sharing

  1. Users’ personal data will be available to the appropriate state authorities or third party people if such obligation will result from commonly applicable regulations.
  2. PDA provides users’ personal data [*] in order to implement these payments.

6 Permissions

  1. Users are authorized to demand from administrator an access to personal data, copies of personal data, its rectification, deletion or processing restrictions, rights to transfer the data   and to raise the objections to the processing, and also to withdrawal of the consent on processing at any given moment without affecting compatibility with processing law to the moment of its withdrawal.
  2. Users are authorized to submit complaints to supervisory authority when they recognize, that processing of personal data violates the regulations of GDPR.

7 Principles of personal data protection

  1. PDA applied organizational and technical resources providing protection of processing of the personal data appropriate to threats and data categories falling under protection, in particular, secured users’ personal data before it was made available to unauthorized people, taken away by an unauthorized person, processed with law violation and changed, lost, damaged or destroyed.
  2. Only people who have authorization from PDA, who are trained in personal data protection and obliged to keep users’ personal data a secret, are allowed to process users’ personal data.

8 Cookies

  1. The website uses cookies technology with maintaining conditions mentioned below.
  2. By cookies we mean IT data stored in users’ end devices intended for using the website. This could be cookies sessional or permanent (session or persistent cookies) and can use the technology such as JavaScript or Flash. Those files allow to recognize user’s device and accordingly show a web page in a way adjusted to user’s individual preferences.
  3. Cookies used within the website are:
    1. "necessary" files - enable use of services and functions of the website, support session, and also authentication files,
    2. "functional" files with which help PDA personalizes page functions for the user, e.g. remembers his settings, such as acceptance of usage of cookies,
    3. "analytical" files - monitor users’ activity on the website, collecting data about them allowing PDA to modify the website and better match it with the users’ expectations,
    4. "security" files - used to detect abuse and guarantee secure use of the website for all users.
  4. Cookies are used by PDA only with the permission of website users. In order to express the permission on sending and using by PDA cookies files, the user should perform appropriate changes in settings of the browser which is used or leave settings default allowing processing of the data. In order to introduce the changes, the user should use the instructions, available under the "Help" button in the browser menu.
  5. The decision on granting the permission to send and use cookies by PDA should be taken immediately after entering the Website. If the user expresses the permission on sending and using the cookies by PDA, PDA will then have access to cookies files saved on user’s computer during another use of the website, that will allow PDA to ease the use of the website and adjust it to needs and individual preferences of the user. If the user will not express the permission on sending and using the cookies by PDA or will decide on its later removal or blocking, some areas or functions of the website can be not available or use of them will be difficult.

9 Final Provisions

  1. PDA reserves the right to change Privacy Policy at any given moment by placing the changed Policy under address [...].
  2. Policy in the new wording will be effective from the date it was placed under address indicated in para.1 of this paragraph.