Privacy Policy

Effective date: April 3, 2023

Definitions

Controller (Us) – EDUWEB SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ Aleja Rzeczypospolitej 10/46 Warszawa 02972 Warszawa
Personal data – any information relating to a natural person, identified or identifiable by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity, including the device's IP, location data, an online identifier and information collected through cookies and other similar technology.
Policy – this Privacy Policy
GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council 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, and repealing Directive 95/46/EC.
Website – the website we operate at heyalice.app
User (You) – any natural person visiting the Website or using one or more services or functionalities described in the Policy.

Data processing in connection with the use of the website

In connection with your use of the Website, we collect your data to the extent necessary for the provision of the individual services offered, as well as information about your activity on the Website. The detailed principles and purposes of the processing of personal data collected in connection with your use of the Website are described below.

Purposes and legal ground for data processing on the website

Use of the website

We process personal data of all the persons who use the Website (including: first name, last name, e-mail address), IP address or other identifiers and information collected through cookies or other similar technologies), and who are not registered Users (i.e. persons who do not have a profile on the Website) for the following purposes:
1. for the purpose of providing electronic services in the scope of making the content collected on the Website available to the Users - then the legal ground for processing is the necessity of processing for the performance of a contract (Article 6 (1)(b) of the GDPR);
2. for analytical and statistical purposes - then the legal ground for the processing is our legitimate interest (Article 6 (1)(f) of the GDPR) consisting in conducting analyses of the Users' activity, as well as of their preferences in order to improve the functionalities used and the services provided;
3. for the purpose of potential establishment and pursuing of claims or defending against them - the legal ground for the processing is our legitimate interest (Article 6 (1)(f) of the GDPR) consisting in the protection of our rights;
4. for marketing purposes (our own and of our partners), in particular related to the presentation of behavioral advertising - the principles of processing personal data for marketing purposes are described in the "MARKETING" section.
Your activity on the Website, including your personal data, is recorded in system logs. The information collected in the logs is processed primarily for the purposes related to the provision of services. We also process it for technical, administrative purposes, for the purpose of ensuring the security of the IT system and managing this system, as well as for analytical and statistical purposes - in this regard the legal ground for processing is our legitimate interest (Article 6(1)(f) of the GDPR).

Registration on the website

During registration on the Website you will be asked to provide data necessary to create and operate the account. In order to facilitate the service, you can provide additional data, thereby giving your consent to their processing. Such data can be erased at any time. The provision of data marked as mandatory is required to create and operate the account, and its failure will result in us not being able to create your account. The provision of other data is voluntary.
Your personal data are processed:
1. for the purpose of providing services related to managing and operating the Website - the legal ground for processing is the necessity of processing for the performance of a contract (Article 6 (1)(b) of the GDPR) and in terms of data provided optionally – the legal ground for processing is consent (Article 6 (1)(a) of the GDPR);
2. for analytical and statistical purposes - the legal ground for the processing is our legitimate interest (Article 6 (1)(f) of the GDPR) consisting in conducting analyses of the Users' activity on the Website and the way of using the account, as well as of their preferences in order to improve the functionalities used and the services provided;
3. for the purpose of potential establishment and pursuing of claims or defending against them - the legal ground for the processing is our legitimate interest (Article 6 (1)(f) of the GDPR) consisting in the protection of our rights;
4. for marketing purposes (our own and of our partners) - the principles of processing personal data for marketing purposes are described in the "MARKETING" section.
If the Website enables logging in through other portals (e.g. Facebook, Google, Instagram, Twitter, Apple), the Website will collect from your account, within a given portal, only the data necessary for registration and account operation. By changing the plug-in settings on your own, you can easily extend the scope of the collected data by data that may be useful while using the Website account's functionalities.

Use of paid services on the website

If you place an order (purchase of goods or services) on the Website, we will process your personal data for the following purposes:
1. for the purpose of implementation of the order placed - the legal ground for processing is the necessity of processing for the performance of a contract (Article 6 (1)(b) of the GDPR); in terms of data provided optionally – the legal ground for processing is consent (Article 6 (1)(a) of the GDPR);
2. for the purpose of complying with our statutory obligations, resulting in particular from the tax and accounting provisions of law - the legal ground for processing is a legal obligation (Article 6 (1)(c) of the GDPR);
3. for analytical and statistical purposes - the legal ground for the processing is our legitimate interest (Article 6 (1)(f) of the GDPR) consisting in conducting analyses of your activity on the Website, as well as of your shopping preferences in order to improve the functionalities used;
4. for the purpose of potential establishment and pursuing of claims or defending against them - the legal ground for the processing is our legitimate interest (Article 6 (1)(f) of the GDPR) consisting in the protection of our rights;

Contact forms

On the Website we enable contacting us with the use of the electronic contact forms. The use of the form requires providing your personal data, which is necessary for us to contact you and answer your question. In the form you can also provide other data in order to facilitate the contact or processing of your inquiry. Providing data marked as obligatory is required in order to receive and process your inquiry, and its failure will result in us not being able to process your inquiry. Providing other data is voluntary.
Personal data you send us through the contact form are processed:
1. for the purpose of identifying you as the sender and processing your inquiry sent through the form provided - the legal ground for the processing is the necessity of processing for the performance of a contract for the provision of services (Article 6 (1)(b) of the GDPR);
2. for analytical and statistical purposes - the legal ground for the processing is our legitimate interest (Article 6 (1)(f) of the GDPR) consisting in conducting statistics on inquiries submitted by the Users via the Website in order to improve its functionalities.

Marketing

We process your personal data for the purpose of undertaking marketing activities, which may include:
1. displaying marketing content that is not tailored to your preferences (contextual advertising);
2. displaying marketing content matching your interests (behavioral advertising);
3. sending e-mail notifications of interesting offers or content, which in some cases contain commercial information (newsletter service);
4. conducting other activities related to direct marketing of goods and services (sending commercial information by electronic means of communication and telemarketing activities).
In order to carry out marketing activities, in some cases we use profiling (if you have given your consent). This means that, through the automated data processing, we evaluate the selected factors about natural persons in order to analyze their behavior or make predictions for the future.

Contextual advertising

We process your personal data for marketing purposes, related to targeting you with contextual advertising, i.e. advertising that is not tailored to your preferences. The processing of your personal data is then carried out in connection with the implementation of our legitimate interest (Article 6 (1)(f) of the GDPR).

Behavioral advertising

We and our trusted partners process your personal data, including personal data collected through cookies and other similar technologies, for marketing purposes, related to targeting you with behavioral advertising, i.e. advertising that is tailored to your preferences. In such case the processing of personal data also includes profiling. The use of personal data collected through this technology for marketing purposes, in particular the promotion of the services and goods of third parties, requires your consent, which you can withdraw at any time.

Newsletter

We provide the newsletter service under the conditions specified in the terms and conditions only if you provide us with your e-mail address for this purpose. The provision of data is required in order to provide the newsletter service, and failure to do so results in the inability to send the newsletter.
Personal data collected for the purposes of the newsletter are processed:
1. for the purpose of providing the service of sending the newsletter - the legal ground for the processing is the necessity of processing for the performance of a contract (Article 6 (1)(b) of the GDPR);
2. in the case of targeting you with the marketing content as part of the newsletter - the legal ground for processing, including profiling, is our legitimate interest (Article 6 (1)(f) of the GDPR) in connection with the consent you gave to receive the newsletter;
3. for analytical and statistical purposes - the legal ground for the processing is our legitimate interest (Article 6 (1)(f) of the GDPR) consisting in conducting analysis of your activity on the Website in order to improve the functionalities used.
4. for the purpose of potential establishment and pursuing of claims or defending against them - the legal ground for the processing is our legitimate interest (Article 6 (1)(f) of the GDPR);

Direct marketing

We may also use your personal data to allow us to target marketing content to you through various channels, i.e. by e-mail, by MMS / SMS or by telephone. We only undertake such activities if you have given us your consent, which can be withdrawn at any time.

Social Media

We process your personal data when you visit our social media profiles (Facebook, YouTube, Instagram, Twitter). These data are processed exclusively in connection with operating the profile, including to inform you about our activities and to promote various events, services and products. The legal ground for processing personal data for this purpose is our legitimate interest (Article 6 (1)(f) of the GDPR) consisting in promoting our own brand.

Cookies and similar technology

Cookies are small text files installed on your device when you browse the Website. Cookies collect information facilitating the use of the website, e.g. by recording your visits to the Website and your actions. Within the Website we may use the following types of cookies:

'Service' cookies

We use the so-called service cookies primarily to provide you with electronic services and to improve the quality of those services. In this regard, we and other entities that provide analytical and statistical services to us, use the cookies to store information or access information already stored in your telecommunications end device (computer, phone, tablet, etc.). Cookies used for this purpose include:
1. cookies with the data you enter (session ID) for the duration of the session (user input cookies);
2. authentication cookies used for services that require authentication for the duration of the session (authentication cookies);
3. cookies serving to provide security, e.g. used for detecting authentication abuse (user centric security cookies);
4. multimedia player session cookies (e.g. flash player cookies), for the duration of the session (multimedia player session cookies);
5. persistent cookies used to personalize the User interface for the duration of the session or slightly longer (user interface customization cookies);
6. cookies used for monitoring website traffic, i.e. data analytics, including Google Analytics cookies (these are cookies used by Google to analyze how you use the Website, to create statistics and reports on the Website's operation). Google does not use the collected data to identify the User, nor does it combine this information to enable identification. The detailed information on the scope and principles of data collection in connection with this service can be found under the link: https://www.google.com/intl/pl/policies/privacy/partners.

'Marketing' cookies

We and our trusted partners also use cookies for marketing purposes, including in connection with targeting you with behavioral advertising. For that purpose we and our trusted partners store information or access information already stored on your telecommunications end device (computer, phone, tablet etc.). The use of cookies and personal data collected through them for marketing purposes, in particular to promote the services and goods of third parties, requires your consent, which can be withdrawn at any time.

Management of cookies

If you do not want to receive cookies, you can change your browser settings. We stipulate that disabling cookies necessary for authentication processes, security, maintaining user preferences may hinder the use of the Website.
To manage your cookie settings, select the web browser you are using from the list below and follow the instructions:
1. Edge
2. Internet Explorer
3. Chrome
4. Safari
5. Firefox
6. Opera
7. Mobile devices:
8. Android
9. Safari (iOS)
10. Windows Phone

Essential marketing techniques

We use statistical analysis of website traffic via Google Analytics (Google Inc. based in the USA). We do not transmit personal data to the operator of this service, only anonymized information. The service is based on the use of cookies on your end user device. With regard to the information on user preferences collected by the Google advertising network, the user can view and edit the information obtained from cookies using the following tool: https://www.google.com/ads/preferences/
We use Facebook pixel as part of the Website. This technology enables Facebook (Facebook Inc. based in the USA) to know that a given person registered there is using the Website. In such a case, it relies on the data of which it is the controller. We do not pass on any additional personal data about you to Facebook. The service is based on the use of cookies on your end device.
We use X pixel as part of the Website. This technology enables X (X Corp. based in the USA) to know that a given person registered there is using the Website. In such a case, it relies on the data of which it is the controller. We do not pass on any additional personal data about you to X. The service is based on the use of cookies on your end device.
We use Linkedin pixel as part of the Website. This technology enables Linkedin (Linkedin Corp. based in the USA) to know that a given person registered there is using the Website. In such a case, it relies on the data of which it is the controller. We do not pass on any additional personal data about you to Linkedin. The service is based on the use of cookies on your end device.
The purpose and scope of data collection and its further processing and use by the service providers, as well as the possibility of contact and the User’s rights in this regard have been described in the privacy policy of the service providers. We may use:
We may use remarketing techniques to tailor advertising messages to your activity on the Website, which may give the illusion that your personal data are being used for tracking purposes, but in practice we do not share any of your personal data with advertising operators. A technological prerequisite for such activities is that cookies are enabled.
We may use a solution consisting in studying user behavior by creating heat maps and recording the activities on the Website. This information is anonymized before it is sent to the service provider so that the service provider does not know which natural person it relates to. In particular, the passwords typed in and other personal data are not recorded.

Duration of personal data processing

The duration of our processing of your data depends on the type of service provided and the purpose of the processing. As a general rule, your data is processed for the duration of the service or order processing, until you withdraw your consent or express an effective objection to the data processing (in cases where the legal ground for data processing is our legitimate interest).
The duration of processing may be extended if the processing is necessary for the establishment and pursuing of potential claims or defending against them, and thereafter only if and to the extent required by law.
After the end of the processing period, your data is irreversibly erased or anonymized.

Your rights

Due to the fact that we process your personal data, you have the following rights:
1. right to information about the processing of personal data - on this basis, at your request, we will provide you with information about data processing, including in particular about the purposes and legal ground for the processing, the scope of data held, the entities to which they are disclosed, and the planned date of erasure of data;
2. right to obtain a copy of data - on this basis, at your request, we will provide you with a copy of the processed data relating to the person making the request;
3. right to rectify - at your request we are obliged to rectify any potential inconsistencies or errors in personal data we process and to complete them if they are incomplete;
4. right to erase data - on this basis, you can request the erasure of data the processing of which is no longer necessary for any of the purposes for which they were collected;
5. right to restrict the processing - on this basis, at your request, we will stop performing operations on your personal data - except for the operations you have given your consent for - and storing them, in accordance with the retention rules adopted or until the reasons for restricting the processing cease to exist;
6. right to data portability - on this basis - to the extent that your data are processed in connection with the concluded agreement or consent given - we will provide you with the data we received from you in a computer readable format. You may also request that we transfer these data to another party, provided that we have the technical capacity to do so.
7. right to object to processing for marketing purposes - you may object to the processing of your personal data for marketing purposes at any time, without having to justify such objection;
8. right to object to other purposes of processing - you may object to the processing of personal data carried out on the basis of our legitimate interest at any time (e.g. for analytical or statistical purposes or for reasons relating to the protection of property); an objection in this respect should contain a justification;
9. right to withdraw consent - if data are processed on the basis of your consent, you have the right to withdraw it at any time, which, however, does not affect the legality of the processing carried out before the withdrawal of consent;
10. right to lodge a complaint - if you believe that the way we process your personal data breaches the GDPR provisions or other regulations on data protection, you can lodge a complaint with the President of the Personal Data Protection Office.

Data recipients

Due to the fact that we want to provide you with the best possible services, we will disclose your personal data to our trusted partners, including in particular to the IT system providers, entities such as banks and payment operators, accounting providers, couriers (in connection with the processing of the order), marketing agencies (for marketing services) and our affiliates.
Your personal data will be shared with other entities for their own purposes, including marketing purposes only if you have given your consent.

Transfer of data outside the EEA

The level of personal data protection outside the European Economic Area (EEA) may differ from that provided by European law. For this reason, we will transfer your personal data outside the EEA only when it is necessary and with an adequate level of protection. You will be notified of this each time.

Security of personal data

Be aware that we take all the steps to ensure that we process your personal data in a secure manner – ensuring, in particular, that only the authorized persons have access to your data and only to the extent necessary for the performance of their tasks.
We take all the necessary steps to ensure that our subcontractors and other entities we cooperate with ensure that the appropriate security measures are applied whenever they process your personal data on our behalf.

Contact details

For all the matters referred to in this policy, in particular relating to the processing of your personal data, you can contact us:
1. by e-mail alice@techsistence.com
2. by mail to the address EDUWEB SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ Aleja Rzeczypospolitej 10/46 Warszawa 02972 Warszawa