Table of Contents
- DEFINITIONS
II. INTRODUCTION
III. INFORMATION ON THE PROCESSING OF PERSONAL DATA OF USERS
- DATA CONTROLLER
2. DATA PROTECTION OFFICER
3. PURPOSE AND LEGAL BASIS OF PROTECTING PERSONAL DATA IN THE SITE
3.1. USE OF THE SITE
3.2. CONTACT FORM
3.3. LEGAL TAX LEVEL MONTHLY NEWSLETTER
3.4. INFORMATION ABOUT PLANNED EVENTS ORGANIZED BY LEGAL TAX LEVEL SP. Z O.O.
3.5. COOKIES
3.6. SOCIAL MEDIA SITES
- INFORMATION ABOUT REQUIRED/VOLUNTARY SUBMISSION OF DATA
5. RECIPIENTS OF PERSONAL DATA
6. THE TIME FOR WHICH PERSONAL DATA ARE STORED
7. INFORMATION ABOUT AUTOMATED DECISION-MAKING, INCLUDING PROFILING
8. RIGHTS OF DATA SUBJECTS
9. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
- INFORMATION ABOUT THE USAGE OF COOKIES
V. CHANGES OF THE POLICY
I. DEFINITIONS
- Controller or LEGAL TAX LEVEL SP. Z O.O. – the controller of personal data described herein is LEGAL TAX LEVEL Spółka z Ograniczoną Odpowiedzialnością with its seat in Gdansk at ul. Wały Piastowskie 1/813 (80-854 Gdańsk), entered into the register of entrepreneurs of the National Court Register by the District Court in Gdańsk, under the number KRS 0001038103 (hereinafter the “Controller”);
- GDPR – Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data repealing Directive 95/46/EC (General Data Protection Regulation) (OJ EU L 119 of 04.05.2016, p. 1);
- Policy – This Privacy Policy of LEGAL TAX LEVEL Spółka z Ograniczoną Odpowiedzialnością;
- Personal data – any information relating to a natural person who is or can be identified by one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity, including device IP address, location data, Internet handle and information collected through cookies or similar technology;
- Processing of personal data – any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means (in particular collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction);
- Website – an online site managed by the Controller under the address https://www.legaltaxlevel.pl and other addresses specified in clauses of the Policy;
- Site or Sites – any Internet site managed by the Controller;
- User – any natural person visiting the Site or using one or more services or functionalities described in the Policy.
II. INTRODUCTION
- LEGAL TAX LEVEL SP. Z O.O. is particularly committed to protecting the privacy of Users who visit Internet sites managed by LEGAL TAX LEVEL SP. Z O.O.
- This Privacy Policy defines the rules of processing of personal data of Site Users.
- Addresses and domains owned by LEGAL TAX LEVEL SP. Z O.O.
1.1. This Policy applies to all Websites, Sites and information society services offered by LEGAL TAX LEVEL SP. Z O.O., including websites located in the following domains:
- a) legaltaxlevel.pl
- b) legaltaxlevel.com
- The LEGAL TAX LEVEL SP. Z O.O. social network:
2.1. In addition, LEGAL TAX LEVEL Sp. z o.o. uses social media, and consequently has official accounts in the following social media sites:
- a) https://www.facebook.com/legaltaxlevel
- b) https://www.instagram.com/legal_tax_level
- c) https://www.linkedin.com/company/legal-tax-level
2.2. The Sites and Websites owned byLEGAL TAX LEVEL Sp. z o.o. contain links to third party social media sites listed in point 2.1, subpoints a)-c).
- Information for the User concerning the LEGAL TAX LEVEL Sp. z o.o. accounts in social media sites
3.1. If the User clicks a specific link while visiting Websites owned by LEGAL TAX LEVEL Sp. z o.o., then by activating a so-called social media site plug-in the User submits their data for processing to the social media site.
3.2. The purposes and scope of processing of personal data by social media sites and the related rights and duties of the site’s controller to protect the privacy of Users can be found in the “protection of personal data” section of the relevant site. Responsibility for personal data processing that occurs after clicking the social media site link lies with the owner of the site.
3.3. Detailed information:
- a) Detailed information about the manner in which User data are used by Google can be found on:
- i) https://policies.google.com/terms?hl=en&gl=be;
- ii) https://www.youtube.com/t/terms;
- b) Detailed information about the manner in which User data are used by Facebook can be found on: https://www.facebook.com/privacy/explanation;
- c) Detailed information about the manner in which User data are used by Twitter can be found on: https://twitter.com/en/tos#intlTerms;
- d) Detailed information about the manner in which User data are used by LinkedIn can be found on: https://pl.linkedin.com/legal/user-agreement;
- e) Detailed information about the manner in which User data are used by Anchor can be found on: https://anchor.fm/privacy.
3.4. If the User does not want the above social media sites to collect data about their activity on websites and sites owned by LEGAL TAX LEVEL Sp. z o.o., they should log out of their account (profile) in the site before they click the relevant link.
III. INFORMATION ON THE PROCESSING OF PERSONAL DATA OF USERS
The Controller processes the personal data of Users in accordance with personal data protection provisions, in particular the provisions of the GDPR and the Personal Data Protection Act of 10 May 2018 (Dz. U. 2019, item 1781).
1. DATA CONTROLLER
The controller of personal data of Users is LEGAL TAX LEVEL Sp. z o.o. with its seat in Gdansk at ul. Straganiarska 20-22/35 (80-837 Gdańsk), entered into the register of entrepreneurs of the National Court Register by the District Court in Gdańsk, under the number KRS 0000942149 (hereinafter the “Controller”);
The Controller can be reached via the contact form on https://www.legaltaxlevel.pl , by sending an email to v.g@legaltaxlevel.pl , or by traditional mail at the address of the Controller’s seat stated above.
2. DATA PROTECTION OFFICER
The Controller appointed a person responsible for protecting personal data, i.e. Data Protection Officer, who can be contacted at v.g@legaltaxlevel.pl or by traditional mail at the address of the Controller’s seat stated above, with a note saying “care of the Data Protection Officer”.
3. PURPOSE AND LEGAL BASIS OF PROTECTING PERSONAL DATA IN THE SITE
3.1. USE OF THE SITE
The personal data of all persons using the Site (including IP addresses or other identifiers or information collected through cookies or other similar technology) are processed by the Controller:
- a) in order to provide services electronically as regards offering the contents of the Site to users, the legal basis for processing is Article 6(1)(f) of the GDPR – legitimate interest of the Controller consisting in offering Users content found in the Site, advising them about actions taken and events organized by the Controller, and communicating, including for marketing purposes, with entities relying on the Controller for support,
- b) for the potential establishment, exercise or defense of legal claims, the legal basis for processing is Article 6(1)(f) of the GDPR – legitimate interest of the Controller consisting in the possibility of establishment, exercise or defense of legal claims.
3.2. CONTACT FORM
- a) for identifying the sender and handling their inquiry sent by the provided contact form, including answering questions posed by the Users, the legal basis for processing is Article 6(1)(a) of the GDPR – consent of the data subject. The data subject is entitled to withdraw their consent at any time. Withdrawing consent does not affect the lawfulness of processing based on the consent prior to withdrawal,
- b) for the potential establishment, exercise or defence of legal claims, the legal basis for processing is Article 6(1)(f) of the GDPR – legitimate interest of the Controller consisting in the possibility of establishment, exercise or defence of legal claims,
- c) for analytical and statistical purposes, the legal basis for processing is Article 6(1)(f) of the GDPR – legitimate interest of the Controller consisting in maintaining statistics of inquiries made by Users through the Site in order to improve its functionality.
3.3. LEGAL TAX LEVEL MONTHLY NEWSLETTER
- a) for marketing the Controller’s products and services, that is sending the LEGAL TAX LEVEL monthly newsletter, the legal basis for processing is Article 6(1)(a) of the GDPR – consent of the data subject. The data subject is entitled to withdraw their consent at any time. Withdrawing consent does not affect the lawfulness of processing based on the consent prior to withdrawal,
- b) for the potential establishment, exercise or defense of legal claims, the legal basis for processing is Article 6(1)(f) of the GDPR – legitimate interest of the Controller consisting in the possibility of establishment, exercise or defense of legal claims.
3.4. INFORMATION ABOUT PLANNED EVENTS ORGANIZED BY LEGAL TAX LEVEL Sp. z o.o.
- a) for marketing the Controller’s products and services, that is sending information of a marketing nature, i.e. information about planned events of an informational and promotional nature organized by LEGAL TAX LEVEL Sp. z o.o. and information about LEGAL TAX LEVEL Sp. z o.o. services and success stories, the legal basis for processing is Article 6(1)(a) of the GDPR – consent of the data subject. The data subject is entitled to withdraw their consent at any time. Withdrawing consent does not affect the lawfulness of processing based on the consent prior to withdrawal,
- b) for analytical and statistical purposes, the legal basis for processing is Article 6(1)(f) of the GDPR – legitimate interest of the Controller consisting in analyzing the activities and preferences of Users in order to improve the functionalities used and services provided,
- c) for the potential establishment, exercise or defense of legal claims, the legal basis for processing is Article 6(1)(f) of the GDPR – legitimate interest of the Controller consisting in the possibility of establishment, exercise or defense of legal claims.
3.5. COOKIES
- a) for adjusting the content of Sites to User preferences and optimizing use of websites; in particular, allowing to recognise the device of the User and display a website in accordance with the User’s individual needs, the legal basis for processing is Article 6(1)(a) of the GDPR – consent of the data subject. The data subject is entitled to withdraw their consent at any time. Withdrawing consent does not affect the lawfulness of processing based on the consent prior to withdrawal,
- b) for compiling statistics helping to understand how Users are using websites and to improve their structure and contents, the legal basis for processing is Article 6(1)(f) of the GDPR – the legitimate interest of the Controller consisting in analyzing the activities and preferences of Users in order to improve the functionalities used and services provided,
- c) for maintaining the User’s session (after logging in), which allows the User to avoid entering their login and password on each subpage of the Site, the legal basis for processing is Article 6(1)(f) of the GDPR – legitimate interest of the Controller consisting in adjusting the functionality and services provided to the needs of the User.
3.6. SOCIAL MEDIA SITES
- a) for advising Users about the activities of the Controller and promoting various kinds of products and services, the legal basis for processing is Article 6(1)(f) of the GDPR – legitimate interest of the Controller consisting in promoting events organized by the Controller, advising about activities undertaken by the Controller, and communicating, including for marketing purposes, with entities using the Controller’s support.
Users can unsubscribe from LEGAL TAX LEVEL profiles in social media sites at any time. This option is available on the social media site (platform) you are using.
4. INFORMATION ABOUT REQUIRED/VOLUNTARY SUBMISSION OF DATA
4.1. Submitting your personal data is voluntary, but required both to use the Sites and to engage in communication. If you refuse to submit your personal data, LEGAL TAX LEVEL Sp. z o.o. will be unable to conduct the above activities.
5. RECIPIENTS OF PERSONAL DATA
5.1. The Controller may transfer your personal data to entities providing specific services requested by LEGAL TAX LEVEL Sp. z o.o., such as hosting or IT services.
5.2. In some cases, third party entities providing services requested by LEGAL TAX LEVEL Sp. z o.o. may act as independent controllers whose personal data are shared by LEGAL TAX LEVEL Sp. z o.o. – examples include telecommunication operators, the Polish Post or other postal operators, including courier services.
5.3. Your personal data may also be shared with entities and authorities that have the right to receive your data, but only in justified cases and in compliance with applicable provisions of law.
6. THE TIME FOR WHICH PERSONAL DATA ARE STORED
6.1. The time for which personal data are processed by the Controller depends on the type of service provided and the purpose of processing.
6.2. The Controller processes your personal data:
- a) when the basis for processing is your consent – until you withdraw it;
- b) when the basis for processing is the need to establish or defend against a legal claim – until the claim is time-barred;
- c) when the basis for processing is the legitimate interest of the Controller – until such interest is achieved or until you object to the processing of data;
- d) until the obligation to retain personal data under generally applicable provisions of law expires.
7. INFORMATION ABOUT AUTOMATED DECISION-MAKING, INCLUDING PROFILING
The Controller will not use personal data to make automated decisions, including decisions which are the result of profiling.
8. RIGHTS OF DATA SUBJECTS
Due to the processing of personal data, a data subject has the following rights: right to access data, right to rectify data, right to erase data, right to restrict the processing of data, right to object to the processing of data, right to transfer data, and the right to file a complaint with the Chairman of the Personal Data Protection Office. You are entitled to these rights in the scope provided for in generally applicable provisions of law.
9. TRANSFERRING PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
9.1. Personal data may be transferred solely to third countries or third parties which were recognised by a decision of the European Commission as offering an adequate level of data protection.
9.2. The list of countries confirmed by a decision of the European Commission to offer an adequate level of protection can be found at: https://ec.europa.eu/info/law/law-topic/data-protection/international-dimension-data-protection/adequacy-decisions_en
9.3. If no decision of the European Commission confirming an adequate level of protection referred to in Article 45(3) of the GDPR has been issued, personal data may be transferred to a third country solely on the basis of: binding corporate rules, standard data protection clauses adopted by the European Commission, standard data protection clauses adopted by a Polish supervisory authority and approved by the Commission, an approved code of conduct, or an approved certification mechanism (Article 46 of the GDPR).
9.4. If no decision of the European Commission confirming an adequate level of protection referred to in Article 45(3) of the GDPR has been issued and in the absence of the safeguards listed in Article of the 46 of the GDPR, LEGAL TAX LEVEL Sp. z o.o. will ask you to grant your express consent for a transfer to a third country or international organization after advising you about the possible risks of such transfer pursuant to Article 49(1)(a) of the GDPR.
9.5. In connection with the transfer of your data outside the EEA you may request information about safeguards used in this respect, obtain a copy of such safeguards or information about the place in which they are shared by contacting us at the LEGAL TAX LEVEL Sp. z o.o. correspondence address stated in chapter II.
IV. INFORMATION ABOUT THE USAGE OF COOKIES
- The Sites use tracking technologies, including cookies.
- Cookies are small text files sent by the Web server, stored by the browser software and installed in the User’s device when browsing Internet sites. When the browser reconnects to the site, the website recognises the type of device used by the User to connect. Cookie parameters allow information stored in cookies to be read only by the server that placed them. Thus, cookies make using previously visited sites easier.
- LEGAL TAX LEVEL Sp. z o.o. Sites use the following kinds of cookies:
3.1. “first party” cookies that allow the use of services available on the Sites, e.g. authenticating cookies used for services that require authentication;
3.2. cookies used for security purposes, for example to discover authentication abuses in the Sites;
3.3. «analytic and performance» cookies that allow to collect analytic data, count views and measure website traffic, permitting website operation to be assessed and improved. Such cookies may be set by LEGAL TAX LEVEL Sp. z o.o. or service providers (e.g. Google, Facebook);
3.4. «functional» cookies that allow to remember settings selected by the User and to customize the User’s interface by choosing the language or region of the User, font size, website appearance etc.;
3.5. «social media» cookies belonging to social media providers, such as Twitter, LinkedIn or Facebook, which LEGAL TAX LEVEL Sp. z o.o. added to its Sites to allow users to share their contents with friends and other networks. Such cookies allow to track the operation of the user’s browser on other sites and to profile their interests. This can affect the contents of announcements displayed to a user in other websites they visit.
- Cookies are a useful, and in some circumstances a necessary tool for the Controller in order to ensure, among others, the proper functioning of the website, proper configuration and security of the website, monitoring the status of sessions, or analyzing, testing and auditing website views.
- The data collected include the IP address, type of browser used, language, type of operating system, ISP, date and time, and location and information sent to the website via the contact form.
- Cookies identify the user, allowing to customise the contents of the website they visit to their needs. By remembering user preferences, cookies allow content displayed to the user to be adjusted accordingly. The Controller uses cookies to guarantee the highest standard of its sites and uses the collected data solely to optimize their operation.
- The User may disable or re-enable the collection of cookies by changing the browser settings at any time.
- More information about the nature of cookies can be found at:
8.1. Polish: http://wszystkoociasteczkach.pl/,
8.2. English: https://www.aboutcookies.org/.
- The User is able to manage cookies on their own. This is allowed by, among others, browsers used by the User. The most popular browser have the option to:
9.1. accept cookies, allowing the User to fully use the options offered by websites;
9.2. manage cookies on the level of individual websites selected by the User;
9.3. configure settings for various types of cookies, for example to treat persistent cookies as session cookies;
9.4. block or delete cookies.
- Managing and deleting cookies varies depending on the browser used. Detailed information on using cookies can be obtained using the browser’s help feature.
- Changing browser settings may, depending on the browser, prevent the User from accessing certain website functions.
- The following table contains detailed information on the use of cookies in LEGAL TAX LEVEL Sp. z o.o. Websites:
Website using the
cookie |
Entity using the cookie |
Subject |
Cookie name |
Cookie purpose |
Expiration date |
https://www.legaltaxlevel.pl |
Website
administrator |
LEGAL TAX LEVEL Sp. z o.o. |
PHPSESSID |
Managing the website |
Browsing session |
.legaltaxlevel.pl |
Third party |
postaffiliatepro |
PAPVisitorId |
This cookie is used by our pages to remember user operation of the site. |
10 years from the date that it was set |
.legaltaxlevel.pl |
Third party |
HubSpot |
__hs_opt_out |
Used by the opt-in privacy policy to remember not to ask the user to accept cookies again. This cookie is set when a site gives users the choice to opt out of cookies. |
13 months |
.legaltaxlevel.pl |
Third party |
HubSpot |
__hssc |
This cookie keeps track of sessions. This is used to determine if we should increment the session number and timestamps in the __hstc cookie. It contains the domain, viewCount (increments each pageView in a session), and session start timestamp. |
30 minutes |
.legaltaxlevel.pl |
Third party |
HubSpot |
__hssrc |
Whenever HubSpot changes the session cookie, this cookie is also set to the value “1”. Used to determine if the user has restarted their browser. If this cookie does not exist it’s assumed it is a new session. |
Session cookie |
.legaltaxlevel.pl |
Third party |
HubSpot |
__hstc |
The main HubSpot cookie for tracking visitors. It contains: the domain, utk, initial timestamp (first visit), last timestamp (last visit), current timestamp (this visit), and session number (increments for each subsequent session). |
13 months |
.legaltaxlevel.pl |
Third party |
Facebook |
_fbp |
Displaying ads on
Facebook after a visit to
.legaltaxlevel.pl |
3 months |
.legaltaxlevel.pl |
Third party |
Google Inc. |
_ga |
Collecting data on
number of visitors,
sessions, campaigns and traffic tracking |
2 years |
.legaltaxlevel.pl |
Third party |
HubSpot |
hubspotutk |
This cookie is used to keep track of a visitor’s identity. This cookie is passed to HubSpot on form submission and used when deduplicating contacts. |
10 years |
- The following links contain information on managing cookies and website data in selected browsers:
13.1. Google Chrome: https://support.google.com/chrome/answer/95647?hl=pl
13.2. Mozilla Firefox: https://support.mozilla.org/pl/kb/ciasteczka
13.3. Safari: https://help.opera.com/pl/latest/security-and-privacy/#deleteData
13.4. Opera: https://help.opera.com/pl/latest/web-preferences/
13.5. Microsoft Edge: https://support.microsoft.com/pl-pl/help/10607/microsoft-edge-view delete-browser-history
13.6. Internet Explorer: https://support.microsoft.com/pl-pl/help/17442/windows-internet explorer-deletemanage-cookies
V. Changes of the Policy
In order to ensure that the Policy complies with generally applicable provisions of law, we reserve the right to make changes to the Policy at any time. The date on which the Policy was last updated is displayed on the Site.