This document is based on Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/WE (general data protection regulation) on 27 April 2016 (Dz.Urz.UE.L No. 119, p. 1, as amended by Dz.Urz.UE.L 2018 No. 127, item 2 – hereinafter referred to as „GDPR”) and constitutes fulfillment of the obligations of Clickray Sp. z o. o. Set forth in Article 12 par. 1, Article 13 par.1 and par. 2 and Article 14 paragraphs 1-3 GDPR as an administrator of personal data processed in connection with the operation of the BrowserSpot.com portal.
1. Identity and contact details of the administrator of personal data.
The administrator of personal data collected through the Browserspot.com portal is Clickray Sp. z o. o.
|Post Office||Cracow (Kraków)|
|County||c. Cracow (Kraków)|
|Voivodship||Lesser Poland (Małopolska)|
|Legal Form||Limited lability company (Spółka z o. o.)|
|Register||KRS entry in the Register of Entrepreneurs|
|Date of origin||06.09.2012|
|Date of entry to REGON||13.09.2012|
|Date of commencement of operations||06.09.2012|
|Registration authority||District Court for Kraków Śródmieście in Kraków, XI Economic Department of the National Court Register|
Contact details of the administrator of personal data:
1) Clickray Sp. z o.o., Halicka 9, 31-036 Kraków
2. The purpose of the processing of personal data and the legal basis for the processing.
Personal data collected through the BrowserSpot.com portal are processed by Clickray Sp. z o. o. for the purpose of:
1) conclusion and performance of a contract for the provision of services offered through BrowserSpot.com portal (legal basis: art. 6, par. 1, lit. b of the GDPR),
2) fulfillment of tax obligations of Clickray Sp. z o. o. (legal basis: art. 6, par. 1, lit. c GDPR),
3) sending by e-mail information about services provided by the BrowserSpot.com portal, including changes in the offer of these services and promotions for these services (legal basis: art. 6, par. 1, lit. c GDPR) – applies only to personal data of natural persons who have consented to the processing of their data for this purpose.
The information about the system logs may contain different data e.g. an IP address, as a result of the general rules for Internet connections. Clickray uses them for technical purposes related to server administration and to collect general, statistical demographic information.
3. Data storage period.
Personal data is stored on the HubSpot platform for the duration of the contract, i.e. from the moment of creating an account on the BrowserSpot.com website until the deletion of the account by the user. If the user has consented to the processing of data for the purpose of sending information about services provided by the BorwserSpot.com portal via e-mail, including changes in the offer of these services and promotions of these services his/her data will be processed for this purpose also after deletion of the account on the BrowserSpot.com portal until such time as he/she requests deletion of his/her personal data.
4. The transmission of personal data.
Clickray reserves the rights to process your personal data after termination of the Agreement of withdrawal of consent only for the purpose of pursuing possible claims in court, or if national, EU or international law obliges Clickray to retain data.
Clickray has the right to share personal data of the user and other entities authorized under applicable laws. The above-mentioned information shall be provided only upon presentation of the appropriate documentation confirming the need to have such data for the conducted proceedings.
We will not share your personal data with anyone other than those authorized under applicable law and other than Google as part of your use of Google Analytics (pt. 17 of this document).
5. The right to access to personal data.
The data subject shall be entitled to obtain from the administrator confirmation whether personal data relating to him or her are being processed and, if so, to have access to them and to the following information:
a) the purposes of the processing;
b) the categories of relevant personal data;
c) information on the recipients or categories of recipients whom personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
d) as far as possible, the intended retention period for personal data and, where this is not possible, the criteria for determining that period;
e) information on the right to require the controller to rectify, erase or restrict the processing of personal data concerning the data subject and to object to such processing;
f) information on the right to lodge a complaint with the supervisory authority;
g) if the personal data have not been collected for the data subject, all available information on the source of the data;
h) information on automated decision-making, including profiling.
6. The right to rectification and supplementation of personal data.
The data subject shall have the right to have any inaccurate personal data relating to him/her corrected by the controller without delay. Subject to the purposes of the processing, the data subject shall have the right to request the supplementation of incomplete personal data, including by providing a supplementary statement.
7. The right to delete personal data.
The data subject shall have the right to require the administrator to delete personal data relating to him or her immediately and the administrator shall be obliged to delete personal data without undue delay in one of the following circumstances:
a) personal data are no longer necessary for the purpose for which they were collected or otherwise processed;
b) the data subject has withdrawn the consent on which the processing is based and there is no other legal basis for the processing;
c) the data subject lodges an objection under art. 21, par. 1 of the GDPR to the processing and there are no overriding legitimate grounds for the processing or the data subject lodges an objection under art. 21, par. 2 GDPR to the processing;
d) personal data have been unlawfully processed;
e) personal data must be deleted in order to comply with a legal obligation under Union law or the Member State law to which the administrator is subject.
8. Right to request the limitation of the processing of personal data.
The data subject shall have the right to require the administrator to restrict the processing in the following cases:
a) the data subject contests the accuracy of the personal data for a period sufficient to permit the administrator to verify the accuracy of the data;
b) the processing is unlawful and the data subject opposes the erasure of personal data and requests instead that their use be restricted;
c) the administrator no longer needs the personal data for the purposes of the processing, but they are necessary for the data subject to establish, enforce or defend his or her claims;
d) The data subjects object pursuant to art. 21 par. 1 GDPR to the processing- until it has been established whether the legitimate grounds of the administrator take precedence over those of the data subject’s objection.
9. The right to transfer personal data.
The data subject shall have the right to receive in a structured, machine-readable and commonly used format personal data relating to him or her which he or she has supplied to the administrator, and the right to send those personal data to another controller without hindrance from the controller to whom the personal data have been supplied, if:
a) processing is carried out on the basis of a consent pursuant to art. 6 par. 1 let. a) or art. 9 par. 2 let. a) or on the basis of a contract pursuant to art. 6 par. 1. let. b) GDPR; and
b) processing is carried out by automated means.
In exercising the right to data portability, the data subject shall have the right to request that personal data be sent by the controller directly to another controller, in so far as this is technically possible.
10. The right to object to the processing of personal data.
The data subject shall have the right at any time to object, on grounds relating to his or her particular circumstances, to the processing of personal data relating to him or her based on art.6 par. 1 let. e) or f) GDPR, including profiling pursuant to those provisions. The administrator may no longer process such personal data unless he proves that there are compelling legitimate grounds for the processing, overriding interests, rights and freedoms of the data subject or grounds for establishing, pursuing or defending claims.
Where personal data are processed for purpose of direct marketing, the data subject shall have the right at any time to object to the processing of personal data relating to him or her for the purposes of such marketing, including profiling, insofar as the processing is related to such directs marketing. If the data subject objects to the processing for the purposes of direct marketing, personal data must no longer be processed for such purposes.
11. The right to revoke consent.
Where the processing is based on consent, the data subject shall have the right to withdraw consent at any time. The withdrawal of consent shall not affect the lawfulness of processing operations carried out on the basis of consent prior to its withdrawal.
12. The right to lodge a complaint with the supervisory authority.
Without prejudice to other administrative or legal protection remedies before the court, any data subject shall have the right to lodge a complaint with the supervisory authority, in particular in the member state in which he has his habitual residence, his place of work or the place where he allegedly committed an infringement, if he considers the processing of personal data concerning him, violates the GDPR. The supervisory authority in the Republic of Poland is the President of the Office for Personal Data Protection (Office for Personal Data protection ul. Stawki 2, 00-193 Warsaw).
13. Whether the provision of personal data is a statutory or contractual requirement or condition for the conclusion of contact and whether the data subject is obliged to provide such data and what are the possible consequences of not providing the data.
Providing personal data during registration on the BrowserSpot.com portal is a condition of concluding a contract for the provision of services offered through the BrowserSpot.com portal. This is not a statutory obligation. The provision of such data is voluntary. The consequence of not providing personal data required for registration on the BrowserSpot.com portal is the impossibility to use the services offered by this portal. In accordance with the regulations for the provision of services through the BrowserSpot.com portal, a person creating an account for an entrepreneur is obliged to update the data provided during registration of the entrepreneur (in order to enable proper settlement of fees for services).
14. Information on automated decision-making, including profiling.
The data subject shall have the right not to be subject to a decision which is based solely on automated processing, including profiling, and which produces legal effects concerning him or her or similarly significantly affects him or her. The Administrator does not apply automatic decision-making systems, including profiling systems, to personal data obtained through the BrowserSpot.com portal.
The BrowserSpot.com website uses cookie technology. Cookies are small text information sent by a server and stored on your side (usually on your hard drive). They contain information that Clickray may need to adapt to how users use the site and to collect statistical information about the site, such as which sites have been visited, what items are collected, and the domain name of the Internet service provider or the country of origin.
Cookies are not harmful to the user or his/her data, so we recommend that you do not disable cookies in your browser.
You can at any time disable or restore the option of collecting cookies by changing the settings in your web browser. Instructions for managing cookies are available here.
16. Network server log
Clickray uses standard log files from the web server to count visitors to the BrowserSpot.com website and to evaluate its technical capabilities. The information obtained in this way is used to determine how many people visit the website and to modernize the website in such a way as to make it as user-friendly as possible. Data collected in this way, i.e. automatically, cannot be changed or deleted.
17. Google Analytics
Depending on your location, data transfer within Google Analytics may involve the transfer of your data to a country other than your own.
The user has the right to know the legal basis for the transfer of data to a country outside the European Union or to any international organization managed by public international law or established by two or more countries, and the security measures taken by Cickray to protect the user’s data.
18. Commercial information
Clickray reserves the right to send messages to users. This includes information directly related to the functioning of BrowserSpot (e.g. change in the functioning), system messages, commercial offers, advertising materials related to products/services offered by Clickray as part of the BrowserSpot service. The recipient has the right to stipulate that he/she does not wish to receive such notifications.
However, commercial information related to the commercial activity conducted by Clickray may be sent only with the user’s consent, in accordance with Article 10 the act of 18 July 2002 on electronic services (Journal of Laws 2002, No. 144, item 1204, as amended). The consent in this respect is revocable.
19. Final provisions
The services and functions offered by BrowserSpot may expand over time. This means, among others, that changes may be made to this document in the future.
In the event of any doubt or contradiction between the Policy and the consents given by the user, regardless of the provisions above, the basis for Clickray’s actions and the scope of its actions are the consents given by the user. This document is for information purposes only.