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CLOUDMIZER PRIVACY POLICY

This Privacy Policy is a document related to the Cloudmizer Terms of Use available at https://cloudmizer.com/terms-of-use (“Terms of Use”). Definitions of the terms used in this Privacy Policy were included in the Terms of Use. The provisions of the Terms of Use are applied accordingly.

The Policy is for information purposes and serves satisfaction of information obligations imposed on the data controller under the GDPR, i.e. Regulation (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, and repealing Directive 95/46/EC (General Data Protection Regulation).

1. PERSONAL DATA CONTROLLER

1.1 The controller of personal data of the Users and persons visiting the website https://app.cloudmizer.com or contacting the Service Provider is Cloud Partners sp. z o.o. with its registered office in Gdynia (81-521), Al. Zwycięstwa 241/13, entered in the register of entrepreneurs of the National Court Register (KRS) under number KRS: 0000802127, Tax Identification Number NIP: 6572947169, National Business Registry Number REGON: 384283931, share capital in the amount of PLN 6,250.
1.2 Contact details of the data controller: rodo@cloudpartners.pl

2. DATA PROCESSING METHOD

2.1. The scope, purposes, and legal grounds for the processing of the Users’ personal data are presented in the table below.

Purpose

Scope of data

Legal ground

Processing period

providing access to Cloudmizer

 

IP address

 

Article 6(1)(b) of the GDPR – processing is necessary for the performance of the Agreement or undertaking actions upon request of the data subject prior to concluding the Agreement

 

until lapse of the period of limitation applicable to claims connected with access to Cloudmizer and the User’s actions within Cloudmizer, calculated from the time of the User’s last visit on Cloudmizer

 

setting up the Account Cloudmizer, performing the Agreement, providing Services against charge

          

e-mail address, first and last name, Tax Identification Number NIP, address, position, business name, name of employer or principal, bank account number 

contact with the Users, responding to queries

 

e-mail address, first and last name, other data provided voluntarily in the form

 

Article 6(1)(f) of the GDPR – legitimate interest of the controller that consists in responding to queries and correspondence provided directly by data subjects

until correspondence ends or the User objects

issuing invoices and other accounting documents

 

first and last name, Tax Identification Number NIP, National Business Registry Number REGON, place of business

 

Article 6(1)(c) of the GDPR –

for the term for which accounting documents have to be kept as prescribed by legal provisions

 

analysing traffic on the website

 

IP address, cookie files: Hubspot, Google Ads, LinkedIn Ads, and Facebook Ads

 

article 6(1)(a) of the GDPR – consent given by the User

until the data cease to be useful or the User withdraws the consent

displaying personalised advertising or other advertising messages

 

IP address, cookie files: Google Ads, Facebook Ads, LinkedIn Ads, Hubspot

protection against claims, raising claims

e-mail address, first and last name, other data voluntarily provided by the data subject

Article 6.1.(f) of the GDPR – legitimate interest of the controller that consists in informing about its activity and raising claims

until lapse of the period of limitation applicable to claims connected with access to Cloudmizer and the User’s actions within Cloudmizer, calculated from the time of the User’s last visit on Cloudmizer

2.2. If the Service Provider is advised that the User uses the Services in violation of the Terms of Use or applicable provisions of the law (unauthorised use), then the Service Provider may process the User’s personal data in a scope required for establishing the liability of the User.
2.3. The provision of personal data as part of the Services is voluntary, but failure to provide them will prevent their provision.
2.4. The Service Provider may in certain cases transfer the Users' personal data to third countries (beyond the European Economic Area), in particular to the United States. In such a case, the Service Provider acts on the basis of the standard contractual clauses prescribed by the Commission Implementing Decision. Furthermore, the Service Provider ensures that, prior to the transfer of data to a third country, it verifies the safeguards applied by the entity used to effect the transfer, as well as the provisions applicable to the data recipient.
2.5. In each case of transfer of personal data, the Service Provider guarantees that the degree of protection of the natural persons whose data have been covered by the transfer is not less than that resulting from the GDPR.
2.6. The Service Provider will not carry out automated decision-making based on the User's personal data.
2.7. The Service Provider may carry out profiling of the Users for the purpose of displaying personalised messages of an advertising or marketing nature, customised to the preferences and behaviour of individual Users. v 2.8. The User may object to profiling at any time by using the e-mail address stated in the Privacy Policy or by sending a letter to the correspondence address of the Service Provider.

3. RECIPIENTS OF DATA

3.1. The Service Provider may entrust the processing of personal data to third parties for the purpose of performing the activities indicated in the Terms of Use and supporting the User. In such a case, the recipients of the User’s data may involve: the provider of hosting for Cloudmizer, the provider of an instant messenger, the e-mail operator, the company providing technical support for the purpose of providing the Services (a software development company), the provider of an e-mail sending service, the law firm, the entities providing solutions for researching traffic on the website and marketing solutions.
3.2. The personal data collected by the Service Provider may also be disclosed to: competent state bodies upon their request on the basis of relevant provisions of the law or other persons and entities – in the cases prescribed in the law.
3.3. Each entity to which the Service Provider transfers the User’s personal data for processing on the basis of a personal data transfer agreement (hereinafter referred to as “Data Transfer Agreement”) guarantees an adequate level of security and confidentiality of the processing of personal data. The entity processing the User’s personal data on the basis of the Data Transfer Agreement may process the User’s personal data through another entity only upon prior consent of the Service Provider.
3.4. Disclosure of personal data to unauthorised entities under this Privacy Policy may take place only upon prior consent of the User to whom such data refer.

4. RIGHTS OF DATA SUBJECT

4.1. Each User has the right to: (a) delete the collected personal data referring to him/her both from the system belonging to the Service Provider as well as from bases of entities that have co-operated with the Service Provider, (b) restrict the processing of data, (c) portability of the personal data collected by the Service Provider and referring to the User, in this to receive them in a structured form, (d) request the Service Provider to enable him/her access to his/her personal data and to rectify them, (e) object to processing, (f) withdraw the consent towards the Service Provider at any time without affecting the legality of the processing carried out on the basis of the consent before it is withdrawn, (g) lodge a complaint about the Service Provider to the supervisory authority (President of the Personal Data Protection Office).

5. OTHER DATA

5.1. Cloudmizer may store http enquiries, therefore the files containing web server logs may store certain data, including the IP address of the computer sending the enquiry, the name of the User’s station – identification through http protocol, if possible, date and system time of registration in the Cloudmizer application and receipt of the enquiry, number of bytes sent by the server, the URL address of the site visited by the User before if the User has entered the service through a link, information concerning the User’s browser, information concerning errors that occurred during the http transaction. Web server logs may be collected for the purposes of proper administration of Cloudmizer. Only persons authorised to administer the IT system have access to data. The files containing web server logs may be analysed for the purpose of preparing statistics concerning traffic in the Cloudmizer application and occurring errors. Summary of such details does not identify the User.

6. SECURITY

6.1. The Service Provider applies technological and organisational means in order to provide for protection of the processed personal data corresponding to the threats and category of data to be secured, in particular, through technical and organisational means the Service Provider secures data against being published to unauthorised persons, taken over by an unauthorised person, processed in violation of the law, and changed, lost, damaged, or destroyed; among others the SSL certificates are applied. The set of collected Users’ personal data is stored on a secured server, moreover, the data are also secured by the Service Provider’s internal procedures related to the processing of personal data and information security policy.
6.2. The Service Provider has also implemented appropriate technical and organisational means, such as pseudonymisation, designed to effectively enforce the data protection principles, such as data minimisation, and for the purpose of providing the processing with necessary safeguards, so as to meet the GDPR requirements and protect the rights of data subjects.
6.3. At the same time, the Service Provider states that using the Internet and services provided by electronic means may pose a threat of malware breaking into the User’s teleinformatic system and device, as well as any other unauthorised access to the User’s data, including personal details, by third parties. In order to minimise such threats, the User should use appropriate technical safeguards, e.g. using updated antivirus programs or programs securing identification of the User in the Internet. In order to obtain detailed and professional information related to security in the Internet, the Service Provider recommends taking advice from entities specializing in such IT services.

7. COOKIES

7.1. For the purposes of correct operation of Cloudmizer, the Service Provider uses the Cookie support technology. Cookies are packages of information stored on the User’s device through Cloudmizer, usually containing information corresponding to the intended use of a particular file, by means of which the User uses Cloudmizer – these are usually: address of the website, date of publishing, lifetime of a cookie, unique number, and additional information corresponding to the intended use of a particular file.
7.2. The Service Provider uses two types of Cookies: (a) session cookies, which are permanently deleted upon closing the session of the User’s browser; (b) permanent cookies, which remain on the User’s device after closing the session until they are deleted.
7.3. It is not possible to identify the User on the basis of cookie files, whether session or permanent. The Cookie mechanism prevents collection of any personal data.
7.4. Cookies used by Cloudmizer are safe for the User’s device, in particular they prevent viruses or other software from breaking into the device.
7.5. Files generated directly by the Service Provider may not be read by other websites. Third-party cookies (i.e. Cookies provided by entities co-operating with the Service Provider) may be read by an external server.
7.6. The User may individually change the cookie settings at any time, stating the conditions of their storage, through the Internet browser settings or configuration of the service, as well as by means of the functionalities of the website.
7.7. First of all, the User may disable storing cookies on his/her device in accordance with the instructions of the browser producer, but this may disable certain parts of or the entire operation of Cloudmizer.
7.8. The User may also individually remove cookies stored on his/her device at any time in accordance with the instructions of the browser producer.

7.9. The Service Provider uses own cookies for the following purposes: authentication of the User in Cloudmizer and maintaining the User’s session; configuration of Cloudmizer and adjustment of page content to the preferences or conduct of the User; analysis and research of views, click number, and path taken on the website to improve the appearance and organisation of content on the website, time spent on the website, number and frequency of visits in Cloudmizer.
7.10. The Service Provider uses Third-party Cookies for the following purposes: preparing statistics (anonymous) for the purposes of optimising the functionality of Cloudmizer, by means of analytic tools.
7.11. The scope of Cookies used by Cloudmizer depends on the consents given by the User within the website.
7.12. Details concerning Cookie support are available in the settings of the browser used by the User.

8. FINAL PROVISIONS

8.1. This Privacy Policy comes into effect on 1.01.2023.