3What Personal Data We Collect, the Purpose, Period, and Legal Basis for Processing
3.1Visit to the Website
When you visit the Website, we may use cookies and other related technological solutions (detailed information is provided in section 6 of the Privacy and Cookies Policy), which allow us to ensure the proper functioning of the Website, as well as analyze information about your activity on the Website. We process this data to improve the quality of the services we offer and enhance the Website to your interests (profiling). We may use certain cookies for marketing purposes, both within the Website and on the websites of our business partners.
The legal basis for the use of cookies and similar technologies is, as a rule, your consent.
The legal basis for processing data collected using cookies is our legitimate interest or the legitimate interest of a “third party” (Article 6(1)(f) GDPR — including the need to ensure the highest quality of presented content, and in some cases, also marketing of products and services of ours or our partners; however, in such cases, partners do not participate in processing your data. To the extent that our partners may have direct access to this information, the legal basis for such processing is your voluntary consent (Article 6(1)(a) GDPR).
We process Personal Data based on your consent for a period of time until it is revoked. Personal Data processed on the basis of our legitimate interest may be stored until you object to its processing, except where, despite your objection, we conclude that there are important, legally justified grounds for processing, which override your interests, rights, and freedoms, or grounds for the establishment, exercise, or defense of claims.
This does not apply to cases where the use of cookies and similar technologies is necessary for the proper functioning of the Service (providing you with the electronic service), in which case we rely on legal provisions and, accordingly, on the necessity of processing for the performance of the Service Agreement (Article 6(1)(b) GDPR). Your Personal Data will then be processed for the period necessary to achieve these purposes.
Information about recipients of your Personal Data, including the potential transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section 5 below.
Your rights related to the processing of your Personal Data are detailed in section 7 below.
3.2Registration in the Service (Account)
To create an Account in our Website, we will require the provision of certain Personal Data, such as your first name, last name, and email address. Providing all information is voluntary; however, some data is necessary to enter into a Service Agreement, and failure to provide such data may mean that entering into such an agreement will not be possible.
Personal Data that is not required may help us improve the Service. We may also use this data for statistical purposes.
The purpose, as well as the legal basis for processing, is to conclude and properly perform the Service Agreement (Article 6(1)(b) GDPR) — e.g., to create your Account and store your Order history within the Account.
Your data may also be processed for marketing activities, such as displaying advertisements and offers (discounts), including those tailored to your interests based on profiling (the legal basis for these activities: Article 6(1)(f) GDPR, i.e., legitimate interest of the Controller or a third party (the Controller’s or partners’ direct marketing).
We may also process your Personal Data to detect any threats to privacy, fraud, or other malicious activities, as well as to prevent them and to establish, resolve, and pursue claims that may arise from the relationship between you and the Controller. In such a case, the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR).
We process your Personal Data for the duration of the Service Agreement. This period may be extended appropriately in connection with any claims (within the limitation period under the provisions of law, primarily the Civil Code) or legal proceedings — for the duration of such proceedings and settlement. In every case, a longer retention period for Personal Data applies.
Personal Data processed on the basis of our legitimate interest may be processed until you object to its processing, except where, despite your objection, we conclude that there are important, legally justified grounds for processing, which override your interests, rights, and freedoms, or grounds for the establishment, exercise, or defense of claims.
Information about recipients of your Personal Data, including the potential transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section 5 below.
Your rights related to the processing of your Personal Data are detailed in section 7 below.
3.2.1Registration via Google Sign-In
We offer the option to register and log in to the Service using your Google account (“Google Sign-In”). If you choose this authentication method, we receive certain data from Google, including your first name, last name, and email address as provided by your Google account profile. We do not receive your Google account password at any time.
The data obtained via Google Sign-In is used solely to create and maintain your Account in the Service and to authenticate your identity upon subsequent logins. We do not use data obtained from Google Sign-In for advertising, profiling unrelated to the Service, or any purpose other than providing the Service to you.
The legal basis for this processing is the performance of the Service Agreement (Article 6(1)(b) GDPR).
Data obtained via Google APIs is used strictly to provide user-facing features of the Service. We do not sell, transfer to third parties, or use such data for advertising platforms, data brokers, retargeting, interest-based advertising, or to determine creditworthiness.
Your use of Google Sign-In is also governed by Google’s Terms of Service and Privacy Policy, available at
https://policies.google.com/privacy.
3.3Placing Orders
When you place Orders through our Website, we process information related to the placement and fulfillment of Orders. For the purpose of placing an Order and entering into a Service Agreement (hereinafter: the “Agreement”), we will require the provision of certain Personal Data, such as your first name, last name, email address, postal address, and billing details. Providing all information is voluntary; however, some data is necessary to conclude the Agreement, and failure to provide such data may mean that entering into such an agreement will not be possible.
Personal Data that is not required may help us in improving our Service. We may also use this data for statistical purposes.
The purpose, as well as the legal basis for processing, is to conclude and properly perform the Agreement (Article 6(1)(b) GDPR) — e.g., delivering the Products you have ordered.
Your data may also be processed for marketing activities, such as displaying advertisements and offers (discounts), including those tailored to your interests based on profiling (the legal basis for these activities: Article 6(1)(f) GDPR, i.e., the legitimate interest of the Controller or a third party (the Controller’s or partners’ direct marketing).
Some of your Personal Data may also be processed for the purpose of handling and pursuing claims, as well as fulfilling legal obligations arising from applicable laws, e.g., tax and accounting obligations — the legal basis for processing is, accordingly, our legitimate interest (Article 6(1)(f) GDPR) or the necessity to fulfill a legal obligation (Article 6(1)(c) GDPR).
If you have concluded an Agreement with us, we process your Personal Data for the period necessary to perform it and usually for up to 7 years following the conclusion of the Agreement, as required, in particular, by tax regulations.
The processing periods described above may be appropriately extended in connection with any claims, including legal proceedings — for the duration of such proceedings and settlement, as well as if the law obliges us in some cases to process certain types of data for a longer period. In every case, a longer period of Personal Data storage applies.
Personal Data processed on the basis of our legitimate interest may be stored until you object to its processing, except where, despite your objection, we conclude that there are important, legally justified grounds for processing, which override your interests, rights, and freedoms, or grounds for the establishment, exercise, or defense of claims.
Information about recipients of your Personal Data, including the potential transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section 5 below.
Your rights related to the processing of your Personal Data are detailed in section 7 below.
3.4Contacting Us
When you contact us, for example by using email, available forms, social media, etc., examples of Personal Data we may process include: Personal Data that identifies you (e.g., email address, IP number, etc.), metadata related to the contact (e.g., contact date, duration of our conversation), as well as the content of our communication (e.g., email content). Your Personal Data is processed to respond to your inquiry, improve our communication, enhance customer service, and also for marketing purposes. The purpose of processing depends on the context of our communication; therefore, sometimes your Personal Data will be used to conclude the appropriate contract with you, and if we already have a contract in place, to ensure proper care during our cooperation (e.g., handling your complaint).
In such cases, the legal basis for processing depends on the context of the communication. If you contact us solely to obtain general information, for example about the Service, we process your Personal Data based on our legitimate interest (arising from the aforementioned purposes; Article 6(1)(f) GDPR). However, if your inquiry leads to the conclusion of an Agreement, the legal basis for processing will be Article 6(1)(b) GDPR — taking steps at the request of the data subject before entering into the contract. If we already have an Agreement in place and you contact us regarding its execution, the legal basis for our actions is Article 6(1)(b) GDPR — necessity for the performance of the contract.
Your Personal Data may also be processed for the purpose of handling and pursuing claims — the legal basis for processing is, accordingly, our legitimate interest (Article 6(1)(f) GDPR).
Providing Personal Data is voluntary, but necessary for effective communication with us.
If your Personal Data has been collected solely in connection with our current communication, we may process it, depending on the category of the information, for a period ranging from a few days to several months (more detailed inquiries and conversations that may be relevant for our future contact).
Personal Data processed on the basis of our legitimate interest may be stored until you object to its processing, except where, despite your objection, we conclude that there are important, legally justified grounds for processing, which override your interests, rights, and freedoms, or grounds for the establishment, exercise, or defense of claims.
The principles of protection and use of Personal Data through social media, which you may use to contact us, are described in their privacy policies. For example, information about the processing of Personal Data by Facebook is available at:
https://www.facebook.com/policy.php.
Information about the recipients of your Personal Data, including the potential transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section 5 below.
Your rights related to the processing of your Personal Data are detailed in section 7 below.
3.5Newsletter
We may send you commercial information about us and our Services (or our partners) through chosen communication channel, but only with your prior consent, also tailored to your interests based on profiling. The legal basis for processing your Personal Data for this purpose is our legitimate interest or the legitimate interest of our partners (Article 6(1)(f) of the GDPR) — ours or a third party’s marketing purposes.
Providing Personal Data is voluntary, but necessary to subscribe to the Newsletter.
Your Personal Data may also be processed for the purpose of handling and pursuing claims — the legal basis for processing is, accordingly, our legitimate interest (Article 6(1)(f) GDPR).
Your Personal Data may be processed for the period during which it is necessary for our marketing activities, unless you object to its processing. A longer retention period may apply if the data is stored in case of potential claims, for the limitation period defined by law, particularly the Civil Code, or for the duration and settlement of legal proceedings. In any case, the longer retention period for Personal Data will prevail.
Information about the recipients of your Personal Data, including the potential transfer of your Personal Data to third countries (outside the European Economic Area), is detailed in section 5 below.
Your rights related to the processing of your Personal Data are detailed in section 7 below.
3.6Processing Data of Our Contractors and Their Employees / Collaborators
If you are our Contractor or Representative, we may process your identification, contact, and contract-related data, including but not limited to your name and surname, the name of your employer, telephone number, email address, job title/qualifications, and our possible correspondence. If you are a party to an agreement concluded with us, we will also process your registration data and information related to our financial settlements.
We process Personal Data for the proper execution of the contract between us and the Contractor, including documentation of its conclusion and the identification of persons authorized to perform tasks specified in the agreement. This is necessary to fulfill the Controller’s legitimate interest (Article 6(1)(f) GDPR), which is the performance of a contract with our Contractor. If you, as a natural person, are a party to an agreement with us, your Personal Data will be processed for the purpose of performance of that agreement (Article 6(1)(b) GDPR).
Additionally, if we process your Personal Data for the following purposes:
- compliance with legal obligations (e.g., tax and accounting obligations), the legal basis for processing will be compliance with a legal obligation imposed on the Controller (Article 6(1)(c) GDPR);
- statistical, analytical, and marketing purposes, the legal basis for processing in such cases will be the legitimate interest of the Controller (Article 6(1)(f) GDPR). If the processing is conducted for marketing purposes, the legitimate interest arises from your consent to be contacted for marketing purposes via a specified communication channel;
- exercising, or defending against potential legal claims, the legal basis for processing will be our legitimate interest (Article 6(1)(f) GDPR).
Your data has been obtained either directly from you or from your employer/entity for whom you act as a Representative. The provision of Personal Data is voluntary; however, providing such data is a prerequisite for entering into a contract or for allowing you to perform tasks specified in the contract (failure to provide such data will prevent cooperation between us).
Information regarding the recipients of your Personal Data is detailed in Section 5 below.
The rights you are entitled to in relation to the processing of your Personal Data are described in Section 7 below.
3.7Business Relations
The scope of data we process depends on the information you or, for example, your employer provides to us, the method of communication you choose, and the information necessary for our business relationship. This scope primarily includes the content of documents, our correspondence/communication, and potentially other information obtained from publicly available sources related to our business relationship (e.g., industry platforms).
In particular, this includes:
- identification data, such as first and last name;
- contact details, including mailing address, phone number, email address, or other contact information.
If you use our hotline, electronic messengers, or email, we will process your identifying data (such as phone number, email address, or IP address), metadata related to the communication (such as the date of contact and call duration), and the content of our communication (such as chat history, email content, or call recordings, if you have been informed about such recordings in advance). We process this information to respond to your inquiries, improve our communication, enhance customer service quality, and for marketing purposes related to our services or the conclusion of a contract with you.
The legal basis for these activities depends on the context of the communication. If the communication involves general inquiries or discussions, the processing is based on our legitimate interest as the Controller (arising from the purposes mentioned above, Article 6(1)(f) GDPR). If your inquiry aims to conclude a contract or relates to an already concluded contract, the processing is based on taking steps at your request prior to entering into a contract or on the necessity of processing for the performance of a contract (Article 6(1)(b) GDPR).
Some of your data may have been obtained during a conference or industry event attended by our representatives, or from the event organizer. In such cases, business card details, inquiries, or participant list information may be processed in our database to send you information that may be of interest to you, respond to your inquiry and maintain future correspondence/contact on this matter, or send a thank-you message for the meeting or your participation in the event. In these cases, our legitimate interest serves as the legal basis of our actions (Article 6(1)(f) GDPR).
Regardless of the above, your Personal Data — primarily your first and last name, mailing address, or email address — may be used by us to send you occasional correspondence (e.g., holiday greetings) or to contact you regarding the promotion of the Controller’s products or services. The legal basis for processing your Personal Data for this purpose is our legitimate interest (Article 6(1)(f) GDPR), which consists of maintaining our business relationship, building a positive image of the Controller, and marketing its products or services.
Additionally, in the case of processing your Personal Data for the following purposes:
- defense against potential claims, as well as the possible pursuit of claims, the legal basis for processing your personal data for this purpose is our legitimate interest (Article 6(1)(f) GDPR);
- compliance with the Controller’s legal obligations (e.g., tax or accounting obligations), the legal basis for processing your Personal Data for this purpose is the fulfillment of legal obligations imposed on the Controller (Article 6(1)(c) GDPR).
In all cases, commercial information will only be sent to electronic addresses (email/phone) if you have provided your prior consent.
Personal Data collected solely in connection with ongoing communication, where you are not our Contractor, is stored depending on the category of information: for two years (in cases of more detailed inquiries and conversations that may be relevant for future contact) or until the limitation period for potential claims expires.
Providing your Personal Data is voluntary, but in certain cases, it may be necessary for our cooperation, e.g., for concluding or performing a contract, responding to an inquiry, or maintaining correspondence. This means that failure to provide such data may, in some situations, result in the Controller’s refusal to establish cooperation or the initiation of legal steps to terminate a potential contract.
If data processing is based on your consent, please note that you may withdraw your consent at any time without affecting the lawfulness of processing carried out prior to withdrawal. However, if your data is processed based on the Controller’s legitimate interest, you have the right to object to such processing.
Information about the recipients of your Personal Data is detailed in Section 5 below.
The rights you have regarding the processing of your Personal Data are outlined in Section 7 below.
3.8Use of Our Services — Purposes and Legal Bases for Processing
When you use our services, we also process information related to the provision of our services, such as data about usage, how the services are used, and the progress of the performance of the agreement, as well as any communication you may have with us. The purpose, as well as the legal basis for processing, is the proper performance of the concluded agreement (Article 6(1)(b) GDPR) — e.g., adjusting the parameters of infrastructure, generating invoices. The scope of data we may process, in addition to GDPR, also results specifically from Article 18 of the Act on the Electronic Provision of Services. At the registration stage, the data necessary to create an account are appropriately marked. Providing all the information is voluntary, but some data (appropriately marked at the registration stage) are necessary to conclude the agreement and for us to begin providing services.
If you have been added as a user of services by our client (including, for example, as a contact person or someone authorized to make changes to the service configuration), we process your data, such as email address, other contact details, data about the usage of services, the progress of the agreement, and any communication you have with us. The legal basis for our actions is our legitimate interest (Article 6(1)(f) GDPR), namely the performance of the agreement with our client.
Additionally, we may analyze information about traffic to/from your virtual machines that we provide to you, to ensure the security of the Cloud and prevent abuse. In this case, the legal basis for our actions is our legitimate interest (Article 6(1)(f) GDPR).
Some information is processed to fulfill legal obligations imposed by law — this mainly applies to data related to our settlements (tax regulations; Article 6(1)(c) GDPR). As a rule, we do not analyze or review the content that you store on our servers. Moreover, such actions will be impossible for us if you appropriately encrypt the data.
3.9OAuth Tokens and Google API Data
When you use Google Sign-In to authenticate with the Service, Google issues OAuth 2.0 tokens on your behalf. These tokens are used exclusively to verify your identity and maintain your authenticated session within the Service.
We store OAuth tokens in encrypted form, both in transit and at rest, in accordance with industry-standard security practices. Access to tokens is restricted to authorized systems and personnel acting on the Controller’s behalf.
We revoke and permanently delete your OAuth tokens in the following circumstances:
- you delete your Account in the Service;
- you disconnect your Google account from the Service via your account settings;
- we no longer require the token to provide the Service.
Data obtained from Google APIs is used strictly and exclusively to provide or improve user-facing features of the Service that are visible and prominent in its interface. Specifically, we do
not:
- transfer or sell Google user data to third parties, advertising platforms, or data brokers;
- use Google user data for serving ads, retargeting, or interest-based advertising;
- use Google user data to determine creditworthiness or for lending purposes;
- allow any human access to Google user data except where required for security investigations, legal compliance, or with your explicit prior consent.
These commitments apply to raw data obtained from Google APIs as well as any data aggregated, anonymized, or derived from it.