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PRIVACY POLICY
EDOLANDO.COM SERVICE


§ 1
GENERAL PROVISIONS


  1. This Privacy Policy uses the terms introduced and explained in the Edolando.com Regulations (hereinafter: the Regulations), which in this document have the same meaning as in the indicated Regulations, available at https://edolando.com/en/privacy-policy, unless the Privacy Policy explicitly indicates a different meaning.

  2. This Privacy Policy sets out the rules for the processing and protection of personal data provided to the Operator, hereinafter also referred to as the Data Administrator, by Users who are natural persons, which are processed for purposes other than those provided for by applicable law. Whenever the Privacy Policy mentions Users, regardless of their role - Business or Trainer, it should be understood to be only natural persons who have provided personal data in order to enable the Data Administrator to provide the Services offered by the Website to them.

  3. This Privacy Policy sets out the rules for the processing and protection of personal data provided to the Administrator by the Participants in relation to their use of the Website.

  4. This Privacy Policy also sets out the rules for the processing and protection of Users' personal data provided by Users in connection with their use of the Website.

  5. Personal data of Users and Participants are processed in accordance with the provisions of generally applicable law, including in particular Regulation of the European Parliament and of the Council (EU) 2016/679 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 / EC (hereinafter: GDPR) and national provisions adopted in implementation or in connection with the GDPR.

  6. This Privacy Policy is for information purposes only and does not constitute a source of obligations for Users and Participants.



§ 2
PERSONAL DATA


  1. The Data Administrator processes personal data made available by Users and Participants during Registration on the Website in order to use the Services offered by the Data Administrator. The Data Administrator processes the following data provided to it by Users and Participants: name and surname, address, telephone number and e-mail address, country (hereinafter: Personal data).

  2. The Data Administrator of personal data is the company Rdeo Sp.z o.o. with its registered office in Warsaw, ul. Złota 7/18, 00-019 Warsaw.

  3. Users can contact the Data Administrator via e-mail - info@edolando.com,

  4. The Data Administrator has appointed a Data Protection Officer in the person Ewa Pisarska (hereinafter: DPO). Users can contact the DPO via: email – privacy@edolando.com

  5. The recipient of Personal Data is the company GroMar Sp.z o.o. with headquarters in Łódź, ul. Tuszyńska 98, 93-305 Łódź, with which the Data Administrator cooperates in order to implement some of the Services offered by the Website.

  6. The recipient of personal data is ClickMeeting Sp. z o.o. with its registered office in Gdańsk, ul. Arkońska 6, 80-387 Gdańsk, with which the Data Controller cooperates in order to implement some of the Services offered by the Website. The agreement for entrusting the processing of personal data concluded with the company ClickMeeting Sp.z o.o. provides for the possibility of further entrusting the processing of personal data.

  7. ClickMeeting Sp.z o.o., as a processing entity, may further entrust the processing of personal data to a third country, i.e. outside the European Economic Area, in order to provide services offered by the Website.

  8. The Data Administrator may entrust the processing of collected Personal Data of Users and Participants to another entity based on the contract entrusted with it for processing personal data (Data Recipient), while these entities will be obliged to observe the rules of confidentiality and security, in particular not to disclose Personal Data to unauthorized persons, and to apply organizational, technical and physical security measures appropriate to the way these data are processed.

  9. In order to ensure high quality of the service provided, as well as usability and optimization of the Website, the Data Administrator may use external analytical tools on the basis of automated collection of some data about Website users, including, but not limited to, using tools like: smsapi, google analytics, userengage.com

  10. The websites of these tools contain regulations, privacy policies and other internal documents that Website users can read and whose content they accept by accepting these Regulations.

  11. The User may submit to the Operator a request to remove some of the external tools, this request is not binding for the Operator, and the User will be notified of the final decision by e-mail.



§ 3


  1. The Data Administrator processes the personal data of Users and Participants only for the purpose and to the extent necessary to perform the Services offered through the Website.

  2. An exemplary catalog of Services provided as part of the Website has been indicated in § 4 para. 1-5 of the Regulations.

  3. Providing Personal Data is voluntary, but necessary to grant Users and Participants access to the Services selected by them offered by the Data Administrator on the Website.

  4. Personal Data of Users registering on the Trainer's Website, limited to the telephone number and e-mail address, will be provided to the Trainer in order to enable him to contact this User. The basis for processing the indicated Personal Data is the consent of the data subject - Art. 6(1)(a) GDPR.

  5. Independent of the content of the provision contained in § 3 para. 4, processing Personal Data is necessary, among others, for the:

  1. performance of the contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract - Art. 6(1)(b) GDPR,

  2. Administrator's compliance with accounting obligations arising in the event of providing paid services to Users and Participants - Art. 6(1)(c) GDPR.

  1. If Users give their additional and voluntary consent, their Personal Data may be processed for marketing purposes related to services offered by the Data Administrator. In the event of consent, Personal Data will be processed for marketing purposes until it is withdrawn, which may occur at any time, in the manner indicated in § 3 para. 8. When processing Personal Data for marketing purposes, the Data Administrator respects all control rights of Users that can be implemented in the manner and under the principles set out in § 4 para. 1-5.

  2. If Users give additional and voluntary consent, their Personal Data may be used to provide commercial information about the services offered by the Data Administrator, by means of electronic communication within the meaning of the Act of 18 July 2002 on the provision of electronic services, in the form of text messages (sms) and via email about the services offered by Rdeo Sp. z o.o. In the event of consent, commercial information will be forwarded by electronic means of communication until it is withdrawn, which may occur at any time, in the manner indicated in § 3 para. 8. By using Personal Data to provide commercial information in the manner indicated above, the Data Administrator respects all control rights of Users, which can be implemented in the manner and on the terms set out in § 4 para. 1-5.

  3. Consent expressed by Users, referred to in § 3 para. 6 and 7, may be revoked by them at any time, without affecting the lawfulness of processing, by sending a relevant request via e-mail to the email address info@edolando.com

  4. As part of the Website, activities are carried out to automatically adjust the content to the anticipated interests and needs of Users and Participants for whom Personal Data and competences made available by Users and Participants are used - profiling. At the same time, the Data Administrator informs that as part of the Website it does not perform profiling, based on which decisions are made that cause legal effects for Users and Participants or in another significant way affecting their legal situation.

  5. The Data Administrator uses systems for automated decision making. The decisions that are taken in an automated way relate to profiling, which is carried out on the basis of the data held, in particular regarding services rendered, information obtained through cookies, including transmission data and location data.

  6. If Users express consent referred to in § 3 para. 6 and 7, profiling will be able to affect marketing offers and commercial information that Users will receive from the Data Administrator.

  7. In the event of providing Personal Data solely for the purpose of accessing selected Services offered by the Data Administrator through the Website, Personal Data will be processed for the time necessary for the proper performance of these Services, unless the User and/or Participant agree to the continuation of processing of the Personal Data provided by them after termination of the Services provided to them by the Data Administrator.

  8. The data processing period may be extended if the processing is necessary to establish, investigate or defend against any claims, and after that period, only if and to the extent required by law.



§ 4

CONTROL RIGHTS


  1. Each User and Participant has the right to access their Personal Data and amend it at any time.

  2. The Data Administrator respects all the rights of Users and Participants, in particular the right to request the updating of Personal Data, their correction and deletion, which can be implemented by Users and Participants at any time, unless their implementation is prevented by applicable law.

  3. Users and Participants also have the right to object in the cases specified in the provisions of the GDPR, as well as the right to limit data processing and data transfer, as well as the right to withdraw consent given at any time without affecting the lawfulness of processing.

  4. The rights indicated in § 4 para. 2 and 3 may be implemented by sending a relevant request via e-mail to info@edolando.com

  5. If it is considered that the processing of Personal Data is in violation of applicable provisions, each User and Participant shall have the right to lodge a complaint with the supervisory body, i.e. the President of the Office for Personal Data Protection.



§ 5
SECURITY


  1. The Data Administrator applies appropriate organizational, technical and physical safeguards to protect Personal Data against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use.

  2. The Data Administrator ensures that access to Personal Data is restricted to persons authorized by him and only to the extent necessary due to the tasks they perform.



§ 6
COOKIE FILES


  1. The website uses cookies. Cookie files (so-called "cookies") are IT data, in particular text files, which are stored in the Service Users’ end devices and are intended for using the Service Website. These files usually contain the name of the website from which they originate, their storage time on the end device and a unique number.

  2. Cookies are used on the Website only with the consent of the User, expressed by setting the appropriate software, in particular the web browser installed on the electronic device used by the User. Cookies are used in particular for statistical and functional purposes

  3. The Website uses two types of cookies:

  1. session – remain saved on the user's computer or mobile device until they leave the website or turn off the web browser,

  2. persistent – remain on the user's device for the time specified in the cookie file parameters or until they are manually deleted in the web browser.

  1. The website additionally uses data in LocalStorage and SessionStorage (expires after closing the session/browser).

  2. Restricting or disabling the use of cookies by the User is possible at any time, however, it will have a negative impact on some of the functions available on the Website or completely prevent its proper display and operation. In order to maintain the full possibility of using the Services, the Data Administrator recommends that you do not modify the cookie settings.



§ 7
FINAL PROVISIONS


  1. This privacy policy is valid from August 1, 2019.

  2. This Privacy Policy is reviewed on an ongoing basis and updated as necessary.

  3. In the event of a change to the content of the Privacy Policy, the Data Administrator will each time inform Users and Participants of this fact by posting information about the changes on the Website. Appropriate information will appear at least seven days in advance of implementing changes to the content of the Privacy Policy.