Privacy Policy and Cookies

Last updated: August 14, 2023

This privacy policy for Sprobuj Sp. z o.o.  (eng. Sprobuj LLC.) (“Company,” “we,” “us,” or “our“), describes how and why we might collect, store, use, and/or share (“process“) your information when you use our services (“Services“), such as when you:

• • Visit our website at https://sprobuj.com, or any website of ours that links to this privacy policy

• • Engage with us in other related ways, including any sales, marketing, or events

Questions or concerns? Reading this privacy notice will help you understand your privacy rights and choices. If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@sprobuj.com.

SUMMARY OF KEY POINTS

In Short:  We respect your time, here are the key data protection principles in a summarized version.

1. In connection with your use of the website SPROBUJ, we collect the necessary data for providing various offered services and information about your activity on the website. We assure you that this data remains confidential, secure, and will not be shared with any third parties without your explicit consent.
2. We entrust the processing of personal data only to verified and trusted entities providing services related to data processing. We do so only when such services are necessary for the proper functioning of the website SPROBUJ.
3. We collect information about your visits to the Sprobuj website through Google Analytics analytical tools. These details include, among others, the subpages displayed on your screen, the time the website was open, and transitions between specific subpages. You can disable cookie collection in your browser settings or clear them right after leaving the SPROBUJ website.
4. We use Hotjar to better understand your needs and optimize our website for your browsing experiences. To use Hotjar, we have implemented special tracking code within our website’s code. Hotjar records visitors to our site and allows us to replay video recordings of their interactions. However, we do not have access to any information enabling your identification because Hotjar does not record form submissions. Data collected through cookies are stored by Hotjar under a pseudonymous user profile. Neither Hotjar nor we use this information for your identification. You can disable cookie collection in your browser settings or clear them right after leaving the SPROBUJ website.
5. We use Meta Pixel, a marketing tool, which enables us to deliver personalized advertisements to you on the Facebook social media platform. You can disable cookie collection in your browser settings or clear them right after leaving the SPROBUJ website.
6. We use Google Ads to draw attention to our content and offers through advertising materials on external websites. We analyze data from advertising campaigns for optimizing our advertising activities. We do not collect or process any personal data based on the aforementioned advertising methods. We don’t acquire other data, and we cannot identify users based on obtained information. You can disable cookie collection in your browser settings or clear them right after leaving the SPROBUJ website.
7. For web analytics purposes, we also use Google Signals, an extension of Google Analytics services that enables “cross-device tracking,” identifying users using multiple devices. This means if your internet-connected devices are linked to your Google account and you have enabled “personalized advertising” on your Google account, then Google can generate reports about how our site is used (particularly the number of users across different devices), even if you switch devices. We do not process your personal data in this regard; we only receive statistics based on Google Signals features and technologies. You can disable cookie collection in your browser settings or clear them right after leaving the SPROBUJ website.
8. We also use the LinkedIn Insight Tag tool, which enables tracking conversions, retargeting website visitors, and viewing demographic data of LinkedIn members who visit the website. You can disable cookie collection in your browser settings, your LinkedIn account, or clear them right after leaving the SPROBUJ website.
9. On the SPROBUJ website, you have the option to use social features such as sharing content on various social platforms. This may involve the use of cookies by administrators of social platforms connected to the SPROBUJ website.
10. Occasionally, we embed videos from YouTube on our pages. For this purpose, Google’s YouTube service cookies are used. Cookies are only loaded when you initiate video playback.
11. We also use our own cookies to ensure the proper functioning of the SPROBUJ website.

1. PERSONAL DATA ADMINISTRATOR

The administrator of personal data is the agency Spróbuj Sp. z o.o. with registered office in Warsaw at st. Świeradowska 47, 02-662 Warsaw, Poland, whose registration files are kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register under KRS number: 0000885372, with NIP number: 5213920721, with a share capital of PLN 5,000.00.

2. WHAT INFORMATION DO WE COLLECT?

2.1. Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. Personal data is all information about a natural person identified or identifiable by one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, online identifier and information collected via cookies and other similar technology.

2.2. Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies. 

The information we collect includes:

• 1. Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called “crash dumps”), and hardware settings).
  2. Device Data. We collect device data such as information about your computer, phone, tablet, or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system, and system configuration information.
  3. Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services.

3. WHAT LEGAL BASES DO WE RELY ON TO PROCESS YOUR INFORMATION?

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to comply with laws, to provide you with services to enter into or fulfill our contractual obligations, to protect your rights, or to fulfill our legitimate business interests.

3.1. If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

1. 1. Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. You can withdraw your consent at any time. Learn more about withdrawing your consent.
   2. Performance of a Contract. We may process your personal information when we believe it is necessary to fulfill our contractual obligations to you, including providing our Services or at your request prior to entering into a contract with you.
   3. Legitimate Interests. We may process your information when we believe it is reasonably necessary to achieve our legitimate business interests and those interests do not outweigh your interests and fundamental rights and freedoms. For example, we may process your personal information for some of the purposes described in order to:
      1. • Send users information about special offers and discounts on our products and services
         • Develop and display personalized and relevant advertising content for our users
         • Support our marketing activities
   4. Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
   5. Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

• 3.2. If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• • If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
  • For investigations and fraud detection and prevention
  • For business transactions provided certain conditions are met
  • If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
  • For identifying injured, ill, or deceased persons and communicating with next of kin
  • If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
  • If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
  • If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
  • If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
  • If the collection is solely for journalistic, artistic, or literary purposes

• • If the information is publicly available and is specified by the regulations

4. HOW DO WE PROCESS YOUR INFORMATION?

In Short: We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

4.1. Using on site

We process personal data of all individuals using the Website (including IP address or other identifiers, and information collected through cookies or similar technologies), for the following purposes: 

• 1. To provide electronic services regarding the content available on the Website to users – in this case, the legal basis for processing is the necessity of processing to perform a contract (Article 6(1)(b) GDPR);
  2. For analytical and statistical purposes – in this case, the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR)  in conducting analyses of user activities and preferences to improve functionalities and services provided;
  3. For potential establishment and assertion of claims or defense against claims – the legal basis for processing is our legitimate interest (Article 6(1)(f) GDPR) in protecting our rights;
  4. For marketing purposes (ours and our partners’), especially related to behavioral advertising.

4.2. Contact Us / Brief

4.6. Social Media Platforms

We process your personal data when you visit our profiles on social media platforms. This data is processed solely in connection with managing the profile, including informing you about our activities and promoting various events, services, and products. The legal basis for processing personal data for this purpose is our legitimate interest (Article 6(1)(f) GDPR) in promoting our brand. 

5. HOW LONG DO WE KEEP YOUR INFORMATION?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

6. WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

In Short: We may share information in specific situations described in this section and/or with the following categories of third parties.

Vendors, Consultants, and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors, or agents (“third parties“) who perform services for us or on our behalf and require access to such information to do that work. The categories of third parties we may share personal information with are as follows:

• • HOSTINGER operations, UAB – to store personal data on website server, including mailbox server SPROBUJ;

  • Google LLC – in order to use Google Analytics, Google Ads, Google Signals services;

  • Hotjar Ltd. – to use Hotjar services to optimize our website;

  • Sendinblue Inc. – in order to send a newsletter to people who have agreed to it;

  • Fakturownia Sp. z o.o. – for the purposes and invoices, it applies to customers from Poland;

  • Meta, Inc. – in order to use remarketing tools, including the possibility of directing advertisements to people from uploaded e-mail databases;

  • Notion Labs Inc. – for internal communication and CRM;

  • Communication & Collaboration Tools

We also may need to share your personal information in the following situations:

• • Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

• • Affiliates. We may share your information with our affiliates, in which case we will require those affiliates to honor this privacy notice. Affiliates include our parent company and any subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

7. WHAT ARE YOUR PRIVACY RIGHTS?

In Short: In some regions, such as the European Economic Area (EEA), United Kingdom (UK), and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the EEA, UK, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section “

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section “

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by clicking on the unsubscribe link in the emails that we send, or by contacting us at info@sprobuj.com. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

Cookies and similar technologies: Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Services. You may also opt out of interest-based advertising by advertiserson our Services. 

If you have questions or comments about your privacy rights, you may email us at info@sprobuj.com.

8. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?

In Short: Yes, if you are a resident of California, you are granted specific rights regarding access to your personal information.

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

9. DO WE USE COOKIES AND OTHER TRACKING TECHNOLOGIES?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to customer needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not.

A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but (to protect your privacy) your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites.

The Company reserves the right to use technological equivalents of cookies, including social media pixels. These pixels allow social media sites to track visitors to outside websites so as to tailor advertising messages users see while visiting that social media website. The Company reserves the right to use these pixels in compliance with the policies of the various social media sites.

10. THIRD PARTY USE OF COOKIES

In Short: Website use third parties cookies: YouTube, advertisements, etc.

Some content or applications, including YouTube Videos, advertisements, on the Website, are served by third parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly

11. MANAGING COOKIES

1. If you do not want to receive cookies, you can change your browser settings. We reserve that disabling cookies necessary for authentication processes, security, maintaining user preferences may make it difficult, and in extreme cases may prevent the use of the Website.
2. In order to manage cookie settings, select the web browser you use from the list below and follow the instructions:
   • • Edge
     • Internet Explorer
     • Chrome
     • Safari
     • Firefox
     • Opera
3. Mobile devices:
   • • Android
     • Safari (iOS)
     • Windows Phone

12. LINKS TO OTHER WEBSITES

In Short: We do not have any control over that other website.

Our website may contain links to other websites of interest. However, once you have used these links to leave our site, you should note that we do not have any control over that other website. Therefore, we cannot be responsible for the protection and privacy of any information which you provide whilst visiting such sites and such sites are not governed by this privacy statement. You should exercise caution and look at the privacy statement applicable to the website in question.

13. DO WE COLLECT INFORMATION FROM MINORS?

In Short: We do not knowingly collect data from or market to children under 18 years of age.

We do not knowingly solicit data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Services. If we learn that personal information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18, please contact us at info@sprobuj.com.

14. CONTROLS FOR DO-NOT-TRACK FEATURES

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this privacy notice.

15. DO WE MAKE UPDATES TO THIS PRIVACY POLICY?

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this privacy notice from time to time. The updated version will be indicated by an updated “Revised” date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

16. HOW CAN YOU CONTACT US ABOUT THIS PRIVACY POLICY?

If you have questions or comments regarding the Privacy Policy, you may email us at info@sprobuj.com 

17. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?

Based on the applicable laws of your country, you may have the right to request access to the personal information we collect from you, change that information, or delete it. To request to review, update, or delete your personal information, please email us at: info@sprobuj.com