PRIVACY POLICY
Article 1 - Introduction
of the Way2Send Website available at www.way2send.pl
Article 2 - Controller of personal data
The Controller of your personal data is Way2Send Sp. z o.o. with its registered office in Warsaw, ul. Bernardyńska 16A/U1 (postal code: 02-904 Warszawa), NIP No. 9182162309, entered with KRS No. 0000485721 in the Register of Entrepreneurs of the National Court Register (hereinafter referred to as the “Controller”). The Controller may be contacted by post to: Bernardyńska 16B/U4 (postal code: 02-904 Warszawa), or by e-mail to: ksykula@way2send.pl, or by telephone at: +48 508 261 823.
Article 3 - Data Protection Officer
We have designated a Data Protection Officer. This person may be contacted in any matters relating to the processing of personal data or the exercise of rights connected with the processing of data. The Data Protection Officer may be contacted by post to: Bernardyńska 16B/U4 (postal code: 02-904 Warszawa), or by e-mail to: iod@way2send.pl, or by telephone at: +48 539 329 692.
Article 4 - Purposes, legal basis and period of processing of data, voluntary provision of data
PERFORMANCE OF A CONTRACT
If you entered into a cooperation contract with us regarding operation of a user account, in particular provision of a comprehensive order management service and operation of your user account, we process your data on the basis of Article 6(1)(b) of the GDPR, i.e. in connection with the contract for the purpose of performance of the contract, communication by e-mail, telephone and post. If you are a representative of a contact person acting on behalf of our client or counterparty, we process your personal data for the purpose of official contacts, which constitutes our legitimate interest (Article 6(1)(f) of the GDPR). Official contacts are understood as any electronic or hard-copy correspondence as well as telephone conversations relating to our cooperation and the service provided, in particular making arrangements, making official appointments, replying to enquiries, providing information by us.
We store any data processed for contact purposes for a period required for making contact / replying to an enquiry, and thereafter until the end of the calendar year following the year in which the matter was resolved or contact was stopped. We process data required for performance of a contract / handling of a complaint for a period required for performing/handling the same, and thereafter until any mutual claims which may arise from entering into the contract become time-barred.
Provision of data is necessary for performance of the contract. If you do not provide data, we will not be able to execute the order. Provision of personal data of the client’s/counterparty’s representatives is voluntary, but if such data are not provided, we will not be able to make contact regarding execution of the order.
COMPLIANCE WITH STATUTORY OBLIGATIONS
We also process data relating to the contract for tax and accounting purposes. In such case, the basis of processing is Article 6(1)(c) of the GDPR in connection with the Accounting Act of 29 September 1994, the Tax Ordinance Act of 29 August 1997 and the Value Added Tax Act of 11 March 2004. We process such data for periods specified in the relevant Act. Provision of data is necessary. If you do not provide data, we will not be able to comply with our legal obligations.
REPLY TO ENQUIRY CONNECTED WITH OUR ACTIVITY
If you contact us by e-mail, telephone or contact form for the purpose of arranging a presentation, meeting, obtaining more information about our offer, we process your personal data on the basis of the Controller’s legitimate interest provided for in Article 6(1)(f) of the GDPR, which is replying to an enquiry, maintaining a conversation, providing information. We store any data processed for contact purposes for a period required for making contact / replying to an enquiry / sending ordered materials, and thereafter until the end of the calendar year following the year in which the matter was resolved or contact was stopped. We store correspondence for such period of time for evidentiary purposes and for the purpose of establishment or defence of legal claims, which constitutes our legitimate interest referred to in Article 6(1)(f) of the GDPR. Provision of data is voluntary, but if you do not provide them, we will not be able to pursue the purposes of replying to your enquiry, etc.
COLLECTION OF DATA AS PART OF BUSINESS CONTACTS
In connection with its business activity, the Controller collects personal data, e.g. during business meetings or by exchanging business cards, by LinkedIn, GoldenLine, etc. – for purposes connected with initiating and maintaining business contacts. Such personal data are processed for the purpose of pursuing legitimate interest of the Controller and its counterparty provided for in Article 6(1)(f) of the GDPR, consisting in building a network of contacts in connection with their business activity. We process data for a period of pursuit of the Controller’s legitimate interest, unless you object earlier to the processing of data. Provision of data is voluntary, but if you do not provide them, we will not be able to make contact.
SENDING OF COMMERCIAL AND MARKETING INFORMATION
If you give consent to receiving from the Controller marketing/commercial information by electronic means and/or by telephone, personal data are processed for the purpose of providing such information. The basis of processing of personal data is consent to processing of data provided for in Article 6(1)(a) of the GDPR in connection with Section 10 of the Act on Provision of Services by Electronic Means and Section 172 et seq. of the Telecommunications Law Act in respect of certain forms of contact, and the Controller’s legitimate interest provided for in Article 6(1)(f) of the GDPR in connection with direct marketing. Where personal data are processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of his or her personal data for such purposes, to the extent that the processing is related to such direct marketing. Personal data processed on the basis of consent will be processed by us until consent is withdrawn. You may withdraw your consent at any time by sending an e-mail to the e-mail address indicated in Article 3 hereinabove. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. Data connected with the above-mentioned purpose will be processed by us until the processing is objected to or until the above-mentioned consent is withdrawn. Provision of data is voluntary, but if you do not provide your data, we will not be able to send marketing communications, as a result of which you will not have the knowledge of our latest offers, promotional campaigns, marketing campaigns.
HANDLING OF COMPLAINTS
Personal data processed in connection with a complaint will be processed by us on the basis of Article 6(1)(f) of the GDPR, which constitutes our legitimate interest consisting in reasonable handling of complaints and legal claims. If a complaint contains personal data of a special category, such data will be processed by us on the basis of Article 9(2)(f) of the GDPR. Such data will be processed by us by the time the complaint is resolved and for a period required after completion of the complaint-handling procedure for evidentiary purposes. Provision of data is necessary for the complaint-handling procedure. If you do not provide your data, we will not be able to handle your complaint.
DEFENCE OF LEGAL CLAIMS
If necessary, we may process personal data for the purposes of establishing, exercising or defending legal claims – on the basis of Article 6(1)(f) of the GDPR – which is to be understood as pursuing the Controller’s legitimate interest consisting in establishing its proprietary or non-proprietary rights or defending against legal claims raised against the Controller – until any legal claims become time-barred or, if proceedings are initiated, until final and non-appealable closure of such proceedings. Provision of data is necessary, if you do not provide them, we will not be able to pursue our legitimate interest.
SOCIAL MEDIA
We use Facebook, Instagram, LinkedIn social media plugins to contact users of such social media, present in such social media content prepared by the Company, and promote the Company’s activity (including: providing information on new events), as well as for analytical and statistical purposes, which constitutes the Company’s legitimate interest provided for in Article 6(1)(f) of the GDPR consisting in allowing contacts with users of such social media, promoting the Company’s activity and providing information on such activity, and for other purposes indicated hereinbelow. Personal data of users of such social media are be processed by us when they visit our profiles or interact with us (likes, comments, messages). Please remember that if you like or comment our post, it will be visible for other users. Personal data are stored by us until you object to further processing of such data by clicking “dislike”, unliking a post or removing a comment under a post, and thereafter for a period required by obligations imposed by the provisions of law and/or until any legal claims connected with the purposes of processing become time-barred. Provision of data is completely voluntary, if data are not provided, no negative consequences will entail.
| Social media | Category of persons | Purpose of data processing | Legal basis for and period of data processing | Additional information | |
| 1. | Facebook, Instagram | We process data of persons who liked our profile, subscribed for the Fanpage by clicking the “Like” or “Follow” button, published a comment under a post on the Fanpage and/or Instagram, published a post on our Fanpage, indicated a like or other reaction to a post or comment on the Fanpage and/or Instagram, contacted us by sending us a message, shared a post on our Fanpage and/or Instagram with another user, data of persons participating in a competition | - operating a profile, - providing information on our activity, - promoting events, products, - replying to reactions, comments, messages, - running a competition |
We process data on the basis of the Controller’s legitimate interest for the purposes indicated in the neighbouring column until the processing of personal data is objected to or until the purposes of processing cease to exist. | Personal data may be shared with the entities indicated in Article 5 hereinbelow and with the controller of Facebook, Instagram, i.e. Meta Platforms Ireland Limited (address: 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland). We do not transfer data outside the EEA; however, transfer of data by Facebook is beyond our control. |
| FACEBOOK JOINT CONTROL As part of processing of personal data of fanpage visitors and users, personal data of fanpage / Facebook profile users are controlled jointly as they share a common purpose and manner of processing of data, i.e. making their own marketing efforts and keeping their own statistics. On the basis of its own terms and conditions, Facebook may collect and process information contained in cookies of fanpage visitors. On the basis of data so collected, Facebook may create anonymised statements and statistics (e.g. relating to the number or profile of fanpage visitors) which may be shared with the Foundation as the fanpage operator. In this scope, Way2Send and Meta Platforms Ireland Limited are joint controllers of your data, in accordance with Article 26 of the GDPR in respect of processing of data for statistical purposes. Detailed information about mutual arrangements between the Foundation and Facebook (including information on the purpose of joint control, scopes of responsibility) is available at: https://www.facebook.com/legal/terms/page_controller_addendum |
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| Data of persons who visit the profile, like or comment on our activity | managing the profile, replying to reactions (comments, posts, messages) | as above | If you are logged in as a LinkedIn user while viewing our website and then you share our post on LinkedIn, LinkedIn will record the activity on your profile. Up-to-date information on the LinkedIn privacy policy is available at: https://www.linkedin.com/legal/privacy-policy and https://privacy.linkedin.com/. | ||
We encourage you to read the privacy policies in detail:
Facebook – https://www.facebook.com/legal/FB_Work_Privacy,
Instagram – https://help.instagram.com/519522125107875?helpref=page_content,
Google – https://policies.google.com/privacy?hl=pl,
Social media have their own privacy policies, terms and conditions of data processing which bind their users and with which we are required to comply. If you are a user of such social media, the processing of your personal data is also subject to such policies and terms and conditions and you may exercise your rights thereunder.
COOKIES
Personal data obtained with the use of cookies will be processed by us on the basis of the Controller’s legitimate interest provided for in Article 6(1)(f) of the GDPR which we believe is the necessity to maintain our website, intent to properly display the website to users or controlling the number of website visitors. We process data on the basis of the Controller’s legitimate interests, therefore you have the right to object to the processing of personal data; you may find more information on that right (and other rights) in Article 7 of the Privacy Policy and/or by contacting our Data Protection Officer by sending an e-mail to the e-mail address indicated in Article 3 of the Privacy Policy. We process data for a period of pursuit of the Controller’s legitimate interest, but not longer than by the time you object to the processing of data. Provision of data is completely voluntary, if data are not provided, no negative consequences will entail.
When you visit our website, you are asked to consent to installation of cookies on your device, as provided for in Section 173 of the Telecommunications Law Act, other than those which are necessary for the functioning of the website. You may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal. In order to exercise your rights, please contact our Data Protection Officer by sending an e-mail to the e-mail address indicated in Article 3 of the Privacy Policy. Provision of data is completely voluntary, if data are not provided, no negative consequences will entail.
Article 5 - Data recipients
We will share your personal data with entities processing data under a contract with us and only in accordance with our instructions, i.e.:
Furthermore, we will provide personal data to relevant state and/or public institutions, if required for compliance with our legal obligations.
Recipients of data may be entities authorised to receive them under the provisions of law. We use Microsoft services (e.g. e-mail), but data are processed by servers located within the EEA and, as a matter of principle, we do not transfer data outside the EEA.
Article 6 - Transfer of data to third countries or international organisations
Your personal data will not be transferred to third countries or international organisations.
Article 7 - Your rights connected with processing of personal data
You have the following rights connected with processing of personal data:
Article 8 - Information on automated decision-making
We do not use automated decision-making tools. The Website automatically collects information contained in cookies only. The manner in which we use cookies is described in the Cookies Policy hereinbelow.
Article 9 - Final provisions
The Privacy Policy takes effect on 15 September 2022. You will be informed about any amendments one week before the updated Policy takes effect.
COOKIES POLICY
Necessary (6)
Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.
| Name | Provider | Purpose | Expiry | Type |
| __cf_bm | Hubspot | This cookie is used to distinguish between humans and bots. This is beneficial for the website, in order to make valid reports on the use of their website. | 1 day | HTTP Cookie |
| CookieConsent | Cookiebot | Stores the user's cookie consent state for the current domain | 1 year | HTTP Cookie |
| embed/v3/counters.gif | Hubspot | Used to implement forms on the website. | Session | Pixel Tracker |
| JSESSIONID | New Relic | Preserves users states across page requests. | Session | HTTP Cookie |
| li_gc | Stores the user's cookie consent state for the current domain | 2 years | HTTP Cookie | |
| test_cookie | Used to check if the user's browser supports cookies. | 1 day | HTTP Cookie |
Preferences (4)
Preference cookies enable a website to remember information that changes the way the website behaves or looks, like your preferred language or the region that you are in.
| Name | Provider | Purpose | Expiry | Type |
| lang [x2] | Remembers the user's selected language version of a website | Session | HTTP Cookie | |
| messagesUtk | Hubspot | Stores a unique ID string for each chat-box session. This allows the website-support to see previous issues and reconnect with the previous supporter. | 179 days | HTTP Cookie |
| pll_language | way2send.pl | This cookie is used to determine the preferred language of the visitor and sets the language accordingly on the website, if possible. | 1 year | HTTP Cookie |
Statistics (8)
Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.
| Name | Provider | Purpose | Expiry | Type |
| __hssc | Hubspot | Identifies if the cookie data needs to be updated in the visitor's browser. | 1 day | HTTP Cookie |
| __hssrc | Hubspot | Used to recognise the visitor's browser upon reentry on the website. | Session | HTTP Cookie |
| __hstc | Hubspot | Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes. | 179 days | HTTP Cookie |
| _ga | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 2 years | HTTP Cookie | |
| _gat | Used by Google Analytics to throttle request rate | 1 day | HTTP Cookie | |
| _gid | Registers a unique ID that is used to generate statistical data on how the visitor uses the website. | 1 day | HTTP Cookie | |
| AnalyticsSyncHistory | Used in connection with data-synchronization with third-party analysis service. | 29 days | HTTP Cookie | |
| hubspotutk | Hubspot | Sets a unique ID for the session. This allows the website to obtain data on visitor behaviour for statistical purposes. | 179 days | HTTP Cookie |
Marketing (14)
Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.
| Name | Provider | Purpose | Expiry | Type |
| __ptq.gif | Hubspot | Sends data to the marketing platform Hubspot about the visitor's device and behaviour. Tracks the visitor across devices and marketing channels. | Session | Pixel Tracker |
| _fbp | Meta Platforms, Inc. | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. | 3 months | HTTP Cookie |
| _gcl_au | Used by Google AdSense for experimenting with advertisement efficiency across websites using their services. | 3 months | HTTP Cookie | |
| ads/ga-audiences | Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor's online behaviour across websites. | Session | Pixel Tracker | |
| bcookie | Used by the social networking service, LinkedIn, for tracking the use of embedded services. | 2 years | HTTP Cookie | |
| bscookie | Used by the social networking service, LinkedIn, for tracking the use of embedded services. | 2 years | HTTP Cookie | |
| fr | Meta Platforms, Inc. | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. | 3 months | HTTP Cookie |
| IDE | Used by Google DoubleClick to register and report the website user's actions after viewing or clicking one of the advertiser's ads with the purpose of measuring the efficacy of an ad and to present targeted ads to the user. | 1 year | HTTP Cookie | |
| lidc | Used by the social networking service, LinkedIn, for tracking the use of embedded services. | 1 day | HTTP Cookie | |
| pagead/1p-user-list/# | Tracks if the user has shown interest in specific products or events across multiple websites and detects how the user navigates between sites. This is used for measurement of advertisement efforts and facilitates payment of referral-fees between websites. | Session | Pixel Tracker | |
| pagead/landing [x2] | Collects data on visitor behaviour from multiple websites, in order to present more relevant advertisement - This also allows the website to limit the number of times that they are shown the same advertisement. | Session | Pixel Tracker | |
| tr | Meta Platforms, Inc. | Used by Facebook to deliver a series of advertisement products such as real time bidding from third party advertisers. | Session | Pixel Tracker |
| UserMatchHistory | Ensures visitor browsing-security by preventing cross-site request forgery. This cookie is essential for the security of the website and visitor. | 29 days | HTTP Cookie |
| Name | Provider | Purpose | Expiry | Type |
| HubsSpot | ||||
| _hssrc – hubspot
__hssc + __hstc – hubspot hubspotutk – hubspot messagesUtk - hubspot |
Session
30 minutes 13 months 13 months |
Save the user’s session
Save the user’s session Track the user Used for storing browser data, website actions | ||
| _fbp - Facebook - | 30 days | Track visits across websites. This cookie is set by Facebook to deliver advertisement when they are on Facebook or a digital platform powered by Facebook advertising after visiting this website.. |
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| pll_language | 1 year | Saves language settings | ||
| _ gid
_gcl_au – _gat_UA-163781820-1 _ga |
1 day
1 hour 1 year |
Used to distinguish users. Analyses traffic on the website.
Optimises and measures the advertisement conversion rate, downloading Measures the conversion rate, downloading Measures the conversion rate, downloading |
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