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Privacy Policy

Neontri (“we”, “our”, “us”) is committed to protect and respect your privacy, particularly in compliance with EU- General Data Protection Regulation (GDPR) 2016/679 of 27 April 2016. Thus, this Privacy Policy is aimed to provide you with significant information about our procedures with regards to the processing of the data provided by you to us.

This Privacy Policy applies to the use of our websites, software, services, products, and all of our marketing, sales and client contract fulfillment activities (“Services”). It also applies to individuals seeking a job at Neontri.

1. Personal Data Controller

The personal data controller is Neontri Spółka z ograniczoną odpowiedzialnością Spółka komandytowa, a company incorporated in Poland with registered number KRS 0000456095 held by the XIII Commercial Division of the National Court Register of District Court for the capital city of Warsaw, whose registered address is Puławska 2, 02-566 Warsaw, Poland.

2. Contact Details

If you have any questions about this Privacy Policy or how we use your data, you can contact us using the following details:

  • by phone: +48 577 757 721
  • by sending an-email to the address: contact@neontri.com;
  • at our main office: ul. Puławska 2, 02-566 Warsaw, Poland.
3. Purposes and Legal Basis for Data Processing

We may use the collected data to comply with legal obligations to which the personal data controller is subject on the basis of Article 6 (1) (c) of the GDPR, resulting from the EU or Polish law. The obligation to provide the data in this scope constitutes a statutory requirement.

We may also use the collected data to enter into and perform a contract, i.e. on the basis of Article 6 (1) (b) of the GDPR. The provision of data in this scope is voluntary, however necessary to enter into and perform a contract with us.

Furthermore, we may also use the collected data for the purposes stemming from the legitimate interests pursued by the controller or a third party on the basis of Article 6 (1) (f) of the GDPR. The provision of data in this scope is voluntary.

We recognize the following cases as legitimate interests:

  1. Providing and maintaining the Services,
  2. Notifying you about changes to our Services,
  3. Allowing you to participate in interactive features of our Services when you choose to do so,
  4. Sending you marketing communications which you have requested,
  5. Replying to your inquiries and follow-up after incoming requests,
  6. Providing customer care and support,
  7. Providing analysis or valuable information so that we can improve the Services,
  8. Monitoring the usage of the Services,
  9. Detecting, preventing and addressing technical issues,
  10. Processing job applications,
  11. Establishment, exercise, and defence of legal claims,
  12. Preventing fraud,
  13. Ensuring ICT environment security,
  14. Applying internal control systems,
  15. Establishing conflicts of interests and breaches of ethical rules to the extent necessary to prevent misuse,
  16. Archiving and statistical purposes,
  17. Providing Services to a client when the client’s interest overrides the interests, rights, and freedoms of the data subject.
4. Categories of Processed Personal Data

We shall process the following Personal Data categories:

  • Data serving the purpose of confirming identity, such as first and last name, PESEL number, ID document number, date of birth,
  • Contact details such as telephone number, e-mail address, place of residence,
  • Tax identification data,
  • Information about education and professional experience – if necessary from the point of view of the Services provided or the type of contract between us and the person whose data is being processed,
  • Information about the economic and financial situation – if necessary from the point of view of the Services provided or the type of concluded contract,
  • Information about professional and business activities.
5. Automatically Collected Data
Usage Data

We may collect information on how our websites are accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our websites that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Cookies

We use cookies and similar tracking technologies to track the activity on our websites and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our websites.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. You can also opt out of several ad tracking cookies placed by major social media sites and other ad tracking services on the site provided by the Digital Advertising Alliance.

Please note that if you do not accept cookies, you may not be able to use all portions of our websites or all functionalities of our websites.

6. Categories of Recipients

The data recipients may include the following categories of entities:

  • Software developers, project managers, analysts, testers, and other specialists cooperating with us and taking independent decisions with regards to the purposes and manners of data processing,
  • Entities authorized on the basis of the applicable law regulations (in particular courts and state bodies),
  • Economic information bureaus,
  • Entities providing:
    • Services in the field of IT and new technology,
    • Payment services,
    • Accounting and financial services,
    • Audit and control services,
    • Recovery services,
    • Printing services,
    • Services consisting of destroying documents,
    • Postal and courier services.
7. Data Retention Period

We store the data for as long as we find it necessary to fulfill the purpose for which the data were collected, while also considering our need to answer your queries or resolve possible problems. This helps us to comply with legal requirements under applicable laws, to attend to any legal claims/complaints, and for safeguarding purposes.

This means that we may retain your data for a reasonable period after your last interaction with us. When the data that we have collected is no longer required, we will delete it securely. We may process data for statistical purposes, but in such cases, data will be anonymized.

8. Rights of the Data Subject

You have the following rights concerning your personal data:

  • Right of access to the contents of the data subject’s personal data, rectifying and completing them, restricting their processing and deleting them,
  • Right of personal data portability with regard to the data provided by you to us, i.e. right to receive them in a structured and commonly used format and to send them to another controller. This right may be exercised only where the processing takes place on the basis of a consent or agreement and where it is fully automated,
  • Right to lodge a complaint with the supervisory body handling personal data protection where the data subject believes that the processing of personal data breaches the GDPR,
  • Right to object to the processing of personal data if the processing is carried out for the purposes resulting from the legitimate interests pursued by the controller or a third party, i.e. on the basis of Article 6 (1) (f) of the GDPR.
  • Such an objection must be based on your particular situation. Upon receipt of the objection, we shall cease to process your personal data for the purposes indicated above to which you have objected, unless we demonstrate that there is a compelling legitimate interest in the processing which overrides your interests, rights, or freedoms, or there are grounds for establishing, exercising and defending against claims.
  • Where personal data are processed on the basis of the consent of the data subject, the data subject may revoke their consent at any time, whereby the revocation of consent shall be without prejudice to the legal compliance of the processing carried out before the revocation on the basis of such consent.
9. Disclosure Of Data
Legal Requirements

We may disclose your Personal Data in the good faith belief that such action is necessary when it is needed from the legal perspective, in particular to:

  • Comply with a legal obligation
  • Protect and defend our rights or property
  • Prevent or investigate possible wrongdoing in connection with the Services
  • Protect the personal safety of users of the Services or the public
  • Protect against legal liability
Service Providers

We may employ third party companies and individuals to facilitate our Services ("Service Providers"), to provide the Services on our behalf, to perform Services-related services or to assist us in analyzing how our Services is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Google Analytics

To gather and analyze the data about the usage of our websites, we use Google Analytics. It employs cookies that are stored to your computer in order to facilitate an analysis of your use of our websites. The information generated by these cookies, such as time, place and frequency of your visits to our site, including your IP address, is transmitted to Google’s location in the US and stored there.

You can opt-out of your data being used by Google Analytics by using a special browser add-on developed by Google. You can find additional information on how to install the browser add-on referenced above under this link.

Hotjar

To better understand the needs of the users of our websites and to optimize their user experience, we use Hotjar. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices (in particular device's IP address (captured and stored only in anonymized form), device screen size, device type (unique device identifiers), browser information, geographic location (country only), preferred language used to display our website).

Hotjar stores this information in a pseudonymized user profile. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on an individual user. For further details, please see Hotjar’s privacy policy by clicking on this link.

You can opt-out of the creation of Hotjar’s user profile, Hotjar’s storing data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.

Business Transfers

We may sell, transfer or otherwise share some or all of our assets, including your Personal Information, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

10. Transfer of Data

If you are located outside Poland and choose to provide any information to us, please note that we transfer the data, including Personal Data, to Poland and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

In general, we shall not transfer personal data outside the European Economic Area. However, we may commission the provision of specific IT services or tasks to a service provider having its registered office outside the European Economic Area. In such a case data shall be transferred to a third state for which an adequacy decision was taken by the European Commission.

You can find up-to-date decisions from the European Commision regarding the adequate level of data protection under this link.

At any time, you may request further information and copies of relevant safeguards.

11. Security of Data

We are very concerned with safeguarding your information. We employ reasonable physical, technological, and administrative security measures intended to safeguard and help prevent unauthorized access to sensitive information. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored “personal data” (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on our websites in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

12. Children's Privacy

Our Services are not directed towards persons under the age of 18 ("Children").

We do not knowingly collect personally identifiable information from anyone under the age of 18.

If you are a parent or guardian and you are aware that your Children has provided us with Personal Data, please contact us.

If we become aware that we have collected Personal Data from Children without verification of parental consent, we take steps to remove that information from our servers and files.

13. Changes to the Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page.

We will let you know about the changes via prominent notice on our websites, prior to the change becoming effective and update the date ("Effective Date") at the bottom of this Privacy Policy.

We advise you to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Effective Date: 01.07.2019