PRIVACY POLICY

1. CONTROLLER OF PERSONAL DATA

The administrator of your personal data is Altkom Software & Consulting Ltd and Altkom Experts Ltd with its registered office in Warsaw, 51 Chłodna Street, 00-867 Warsaw, hereinafter referred to as the joint co-administrators (Administrator). Should you have any questions concerning the manner and scope of processing of your personal data by us, as well as questions concerning your rights in relation to your personal data processed by us, please contact us:

• by mail to the following address Altkom Software & Consulting Ltd, 51 Chłodna Street, 00867, Warsaw,
• By phone at : (+48 22) 460 99 31,
• e-mail asc@altkomsoftware.com

• by mail to the address: Altkom Experts Ltd, 51 Chłodna Street, 00867 ‑Warsaw,
• By phone at : (+48 22) 460 99 40,
• e-mail office@altkomexperts.pl

2. THE CONTROLLER HAS APPOINTED A DATA PROTECTION OFFICER

The Supervisor of Personal Data Protection is Mr. Mariusz Zajkiewicz, to contact the Supervisor, you can use the following communication channels:

• by post to the company’s address with the notation Personal Data Protection Inspector or personally at the address: 51 Chłodna Street, 00-867 Warsaw.
• e-mail: iod@altkomsoftware.com

3. WHAT ARE THE PURPOSES FOR WHICH YOUR PERSONAL DATA ARE PROCESSED, THE LEGAL BASIS FOR THE PROCESSING AND THE DURATION OF DATA RETENTION?

Below we indicate the purposes for which we process your personal data, the legal basis for the processing, as well as the period for which we will keep your personal data in relation to the specific purpose:

• Responding to your enquiry via an electronic form on the Company’s website or in another form (e.g. e-mail, telephone),

The legal basis for data processing in this case is Article 6(1)(a) of the GDPR, i.e. your consent,

We will retain your personal data until we have provided a final response and completed the correspondence, in the event of no response to the Company’s response for no longer than 2 months.

• Presentation of an offer or establishment of cooperation,

The legal basis for the processing in this case is Art 6(1)(b) of the GDPR – i.e. taking action before entering into a contract at the request of the person contacting the Company and Art 6(1)(f) of the GDPR – because the Company also wants to be able to present an offer or enter into cooperation. The data storage period in the event that the parties are not interested in any cooperation will last up to 6 months from the time the contact ends. If cooperation is established, the storage period for the entrusted data is specified in the following paragraphs,

• the conclusion and performance of a contract or order. The legal basis for processing personal data in this case is Art 6(1)(b) of the GDPR. Personal data will be stored for the period of performance of obligations and the period of limitation of claims resulting from the legislation. If a contract or order is concluded between you and the Company, the data provided by you will be processed for the purpose of performing such contract or order and their settlement,
• fulfilment of the legal obligation to draw up and keep records.

The legal basis for data processing in this case is: Art 6.(1)(c) GDPR. Personal data will be stored for the period of storage of accounting documents and documents confirming the conclusion and performance of the contract resulting from the national legislation of the administrator. In the case of performance of a contract or order on your behalf, the Company will process personal data contained in invoices, accounting books or other documentation confirming the conclusion and performance of the contract in order to draw up and store documents in accordance with applicable laws,

• confirmation of the fulfilment of obligations and the assertion or defence against claims. The legal basis for the processing of personal data in this case is Article 6(1)(f) GDPR. Personal data will be stored for the period of performance of obligations and the period of limitation of claims resulting from the regulations. Data entered on an electronic form, made available as part of a contract or order, or otherwise made available to the Company may be processed for the purpose of archiving information or documents confirming the performance of the Company’s obligations and for the purpose of asserting possible claims or defending against claims made against the Company. This applies if you are a party to the contract or order, as well as if your employer or an entity with which you do business is a party to the contract or order, and if the Company was obliged to perform a service to you or exercise your rights on any basis. Data processing will be undertaken in such a case in order to pursue the legitimate interests of the controller, such as the protection of rights, confirmation of the fulfilment of obligations and obtaining the remuneration due therefor.

4. WITH WHOM DO WE SHARE YOUR PERSONAL DATA?

We may share your personal data, to the extent necessary:

• to entities entitled to receive them on the basis of legal provisions (e.g. courts, legal protection authorities, administrative bodies, supervisory bodies),
• entities processing your personal data on our behalf (e.g. service providers, entities operating our ICT systems or providing us with ICT tools, entities providing consultancy, advisory services, etc.).

Whenever we share or entrust your personal data, we will ensure that only the minimum information necessary to fulfil the purpose of the processing is provided.

5. WHAT RIGHTS DO YOU HAVE IN RELATION TO THE PROCESSING OF YOUR PERSONAL DATA BY THE COMPANY?

In relation to the Company’s processing of your personal data, you have the following rights:

• pursuant to Art 15 of the GDPR, the right of access to your personal data, including the right to obtain a copy of the personal data being processed,
• pursuant to Art 16 of the GDPR, the right to rectify your personal data that is incorrect: outdated or inaccurate, and the right to have it completed if it is incomplete,
• pursuant to Art 17 GDPR, in the cases mentioned therein – the right to erasure of personal data (the so-called “right to be forgotten”). As a general rule, this right consists of requesting the controller to immediately delete personal data concerning you; however, pursuant to Art 17 GDPR, there are exceptions to this right (in particular for the purpose of establishing, asserting or defending claims),
• pursuant to Art 18 GDPR – the right to request the controller to restrict the processing of your personal data. In practical terms, this right may consist in temporarily blocking access to your personal data or transferring it to another system,
• The right to lodge a complaint to the supervisory authority dealing with personal data protection, i.e. the President of the Office for Personal Data Protection – in case the processing of personal data is considered to violate the GDPR,
• Under Art 21 of the GDPR, the right to object to the processing of your personal data.

In order to exercise the above rights, you should contact the Company or the Data Protection Officer stated in paragraph 1.

Your requests will be dealt with without undue delay, but no later than 30 days after receipt. This period may be extended by another 30 days due to the complexity of the request or the number of requests, of which we will inform you.

Insofar as the processing of personal data is based on your consent, you have the possibility to withdraw your consent at any time, whereby withdrawal of consent shall not affect the lawfulness of the processing carried out on the basis of that consent before its withdrawal.

If you withdraw your consent, your data will be deleted from our database.

6. SECURITY OF PERSONAL DATA

The Company takes technical and organisational measures to protect your personal data against unlawful or unauthorised access or use, as well as against accidental destruction, loss or compromise of its integrity.

The principle of providing security has guided us in the design of our IT infrastructure, standards development and business practice. Our security procedures include in particular: access security, backup system, monitoring, review and maintenance, security incident management.

As part of ensuring the security of the personal data we process, we undertake to take into account:

• confidentiality – we will protect your personal information from accidental disclosure to third parties,
• integrity – we will protect your personal data from unauthorised modification,
• availability – we will ensure that authorised persons have access to your data where necessary.

Any employee or associate who has access to your personal data has the appropriate authorisation and is bound by a duty of confidentiality.

COOKIE POLICY

1. ACCESSIBILITY OF THE WEBSITE

The website https://www.altkomsoftware.com/ can be viewed on any device with internet access using any web browser (the latest version of the browser is recommended).

2. WHAT ARE COOKIES AND WHAT ARE THEIR FUNCTIONS?

Cookies are small text files sent by a web server and stored on your computer. Cookies allow the information contained in them to be read only by the server that created them. Cookies contain various information about the user of a website and his/her connection history with the website. Thanks to this information, the owner of the server which sent the cookies can find out which pages the user visited before entering the website, learn the user’s IP address, as well as check for any error messages when viewing the website. It should be noted, however, that this data is not associated with a specific person browsing the site, but only with the computer connected to the Internet on which the cookie was stored.

3. PRIVACY

Page encryption (SSL/ TLS):

• A *.altkom.pl certificate has been issued for the https://www.altkomsoftware.com/ domain. The certificate ensures confidentiality and integrity of data transmission as well as authentication of the server.
• Encryption of communications is enabled throughout the domain to ensure user security. Communications are encrypted with a 256 bit key and an independent certificate issuer – Certum Domain Validation CA SHA2 – provides the guarantee that you are on the authentic, genuine https://www.altkomsoftware.com/ website.
• Detailed information about the certificate can be obtained by clicking on “More information” in the browser bar and then “View certificate”.
• Your browser may tell you that your connection is not secure if the website contains graphics that originate not at “https://” but at “http://”.

There are currently no such elements on the website. They should not be feared, as they are not in any way dangerous to the user.

The website has Google Analytics code embedded.

This tool is used for web analytics and helps to improve the website for users. Google Analytics collects anonymous information and records website trends without identifying individual users. Like many other services, Google Analytics uses its own cookies to analyse the actions of website users. These cookies are used to store information, such as when your current visit began and whether you have visited the site before and from which site you came to the current site.

Google Analytics on the blog uses the following types of cookies, which are permanent cookies except for the cookie “__utmc”, which is a temporary cookie. The stated expiry date of the cookies is a maximum. In fact, this date depends on the user’s actions – e.g. deleting cookies, changing device, reinstalling browser:

• Name: __utma

Expiry date: 2 years after initial creation or resetting. Description: Google Analytics cookie to determine the number of unique users (defined as a specific browser on a specific computer) who visit the site. The cookie reads the number of visits to the site, the time of the first visit, the previous visit and the current visit.

• Name: __utmb

Expiry date: 30 minutes after initial creation or reset. Description: Google Analytics cookie to determine the number of times a unique user visits the site (specific browser on a specific computer). Used in conjunction with the __utmc cookie (described below). The cookie examines the length of the visit – its beginning and end.

• Name: __utmc

Expiry date: 30 minutes after initial creation or reset. Description: Google Analytics cookie to determine the number of times a unique user visits the site (specific browser on a specific computer). Used in conjunction with the __utmb cookie (described above). The cookie examines the length of the visit – its beginning and end.

• Name: __utmz

Expiry date: 6 months after initial creation or re-setting. Description: Google Analytics cookie to determine how a unique user visits the site (a specific browser on a specific computer). The cookie examines the source of visits to the blog and how it is explored.

If you do not consent to the collection of anonymised statistical data about your activity on the website, you can disable the Google Analytics tool in your browser by downloading and installing an add-on (available for Mozilla Firefox, Google Chrome, Apple Safari, Opera, Microsoft Internet Explorer) or disable cookies in your browser.

The website has User.com code embedded.

This tool is used for marketing automation activities and helps to improve the website for users. Data is collected automatically and can be used to adjust website content dynamically to become more appropriate for users. Like many other services, User.com uses its own cookies to analyse the actions of website users. These cookies are used to store information, such as when your current visit began and whether you have visited the site before and from which site you came to the current site.

If you do not change your browser settings, you agree to the use of Cookies.

There are two types of forms on the blog maintained by the Company:

• A form to participate in the discussion. Provision of data is voluntary. The e-mail address is used to exclude spam and/or to display the user’s avatar. Comments on the blog are made for personal purposes. The e-mail address is not made available to third parties.
• Form for sending a message to Altkom Software & Consulting Ltd Provision of data is voluntary. Each person has the right to access their personal data and correct them. Messages sent via the form shall be processed by the Company in order to answer them. The data is not disclosed to third parties.

4. HOW DO WE USE THE INFORMATION OBTAINED FROM COOKIES?

Usually the data is used for automatic recognition of a particular user by the server, which can then generate a page intended for that user. This makes it possible, for example, to adapt websites and webpages, the handling of logins and certain contact forms.

The company, publisher of the website https://www.altkomsoftware.com/ uses cookies to optimise the use of the website and to adapt its content to the user’s preferences. It also uses them to create anonymous, aggregated statistics, excluding personal identification of the user. This helps us understand how users use the website and allows us to improve its structure and content. In addition, the Company may place or allow a third party to place cookies on your device in order to ensure the proper functioning of the website. This helps to monitor and check its operation. This entity may include, but is not limited to, Google, which collects the data the Company needs.

You may set your browser in such a way that cookies are not stored on your device or are automatically deleted at a given time. These settings can therefore be changed in such a way as to block the automatic handling of cookies in the browser settings or inform on their sending to the user’s device each time. Unfortunately, as a consequence, this may lead to problems with displaying some websites, inaccessibility of some services.

5. HOW THE SETTINGS OF THE MOST POPULAR SEARCH ENGINES ARE CHANGED:

1. Google Chrome

Click on the menu (top right corner), tab Settings > Show advanced settings. In the “Privacy” section, you need to click on the Content settings button. In the “Cookies” section, you can change the following cookie settings:

Deleting cookies,

Cookie blocking by default,

Allowing cookies by default,

Retain cookies and page data by default until browser is closed

Specifying exceptions for cookies from specific sites or domains

• Mozilla Firefox

From the browser menu: Tools > Options > Privacy. Activate the Firefox box: “will use user settings”. About cookies, check – or not – the box Accept cookies. Internet Explorer 6.0 and 7.0

From the browser menu (top right corner): Tools > Internet Options > Privacy, button Sites. Use the slider to set the level, confirm the change with OK.

• Opera

From the browser menu: Utility > Preferences > Advanced. Cookies are decided by checking – or not – the Cookies item.

• Safari

In the Safari drop-down menu, you need to select Preferences and click the Security icon.

Here you select the security level under “Accept cookies”.

6. BLOG COMMENTS:

Comments on the blog are moderated by the Company and their content cannot be contrary to the law in force in Poland or violate in any way the rights of third parties. Comments violating the current netiquette and culture of speech will not be published.

If any entity believes that your comment violates the law, including, but not limited to, violating the rights of an entity, you should contact the Company to have your comment removed.

The Company does not recommend including links in the body of comments.

The site settings allow for “trackback” and “pingback” of a page. However, a moderator may disallow them or remove the backlink.

7. WHOSE PERSONAL DATA ARE WE PROCESSING?

The Controller(s) (Joint Controllers) process, inter alia, personal data:

• users of the website owned by the Company – https://www.altkomsoftware.com/ – i.e. natural persons asking questions via the Company’s website (electronic forms);
• clients who are natural persons;
• in the case of customers who are legal persons or organisational entities without legal personality, personal data of persons authorised to represent such entities, employees and associates of such customers;
• service providers who are natural persons, as well as employees and associates of service providers;
• potential employees or collaborators;
• potential customers – including, but not limited to, those received by representatives of the Company in the course of sales or marketing activities (e.g. in the course of meetings or business correspondence, in the course of conferences or other events, tenders, negotiations, etc.).

8. PROVISION OF PERSONAL DATA

Regardless of how you provide the Company with your personal data, you will receive detailed information in relation to the processing of your personal data in each case.

In the case of data collected by representatives of the Company in the scope of purchasing, sales or marketing activities – providing data is fully voluntary, however, the consequence of failing to provide such data may be the inability to contact you in the future.

The provision of personal data by you in any case is fully voluntary, but necessary in order to take action at your request, as data subjects, prior to the conclusion of a contract, and failure to provide data will prevent the Company from taking the requested action (including, for example, preventing the processing of a request for the provision of services), and will prevent the conclusion and performance of a contract.

Policy of -1 April 2022.