Privacy Policy

Introduction

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 protectionof natural persons with regard to the processing of personal data and on the free movement of suchdata, and repealing Directive 95/46/EC (General Data Protection Regulation). Anyone who uses the website available at www.blazity.com (“Website”) or uses our electronic services in accordance with Website Terms Use, should become acquainted with the Privacy Policy. The Privacy Policy determines the rules for processing personal data of persons using the Website and using Cookie filesand other tracking technologies used in connection with operation of the Website.

I. Personal data controller

1. The Controller of Users’ personal data is Blazity sp. z o.o. with its registered office in Warsaw, ul. Marszałkowska 89, 00-693 Warsaw, Poland, entered into the Register of Entrepreneurskept by the District Court for the Capital City of Warsaw, XIII Commercial Division of the National Court Register  under number KRS: 0000743458, Tax Identification Number NIP: 9512467349, National Business Registry Number REGON: 38093625300000, share capital in the amount of PLN 5,000.00 (“Blazity” or “Controler”).

2. To contact us, please send an e-mail to: contact@blazity.com.

II. Purpose and scope of data processing

1. In every case providing personal data is voluntary, but failure to provide the personal data marked in appropriate forms as obligatory will prevent providing the electronic services on User’s request.

2. Personal data of Users will be processed for the following purposes:

Providing access to the website

  • Scope of data: IP address
  • Legal ground: Article 6.1(b) of the GDPR – statutoryauthorisation to process data necessaryto perform anagreement
  • Processing period: until lapse of the period of limitation of claimsconnected with access to the website

Analysing traffic on the website

  • Scope of data: IP address, Cookie files of the following type: _utma; _utmb; _utmc; _utmz; PHPSESSID
  • Legal ground: Article 6(1)(a) of the GDPR – consent givenby the data subject
  • Processing period: until data cease to be useful or the data subject withdraws the consent

Correspondence in electronic form (after the data subject uses the contact form)

  • Scope of data: e-mail address, first and last name, organisation name, other personal data voluntarily provided by the data subject
  • Legal ground: Article 6(1)(f) of the GDPR – legitimate interest of the controller which consists in responding to queries and correspondence provided directly by data subjects
  • Processing period: until correspondence ends or the data subject objects

Marketing activities (after the data subjectu ses the sales form)

  • Scope of data: e-mail address
  • Legal ground: Article 6(1)(f) of the GDPR – legitimate interest of the controller which consists in informing about itsactivity
  • Processing period: for the duration of your subscription and until you withdraw your consent

Providing Newsletter or ebooks

  • Scope of data: e-mail address, position
  • Legal ground: Article 6.1(b) of the GDPR – statutory authorisation to process data necessary to perform anagreement
  • Processing period: throughout the duration of the agreement, and untillapse of the period of limitation of claimsconnected with access to the website

Conducting the recruitment process for positions offered by Blazity sp. z o.o., (under B2B contracts or civil law agreements)

  • Scope of data: first and last name, e-mail address, social media identifiers, phone number, work place, past work experience, language skills, as well as any other data voluntarily provided by the data subject
  • Legal ground: Article 6(1)(b) of the GDPR – processing necessary for the performance of a contract or to take steps prior to entering into a contract and, for data not required, the legalbasis for processing isconsent (Article 6(1)(a) RODO).
  • Processing period: for the duration of the recruitment process, and after its conclusion, for the period necessary to defend against potential claims, but no longer than 3 years from the end of the recruitment process

Conducting future recruitment processes, provided you have given your consent in appropriate form

  • Scope of data: first and last name, e-mail address, social media identifiers, phone number, work place, past work experience, language skills, as well as any other data voluntarily provided by the data subject
  • Legal ground: Article 6(1)(a) of the GDPR – consent of the data subject
  • Processing period: until the data subject withdraws consent

Organizing the Meetup and Webinar

  • Scope of data: first name, last name, company  email, company name
  • Legal ground: Article 6.1(b) of the GDPR – statutory authorisation to process data necessary to perform anagreement
  • Processing period: throughout the duration of the agreement, and until lapse of the period of limitation of claims

Protection against claims, raising claims

  • Scope of data: e-mail address, first and last name, other data voluntarily provided by the data subject in the course of co-operation
  • Legal ground: Article 6(1)(f) of the GDPR – legitimate interest of the controller which consists in protecting against claims and raising claims
  • Processing period: until lapse of the period of limitation applicable to claims connected with access to the Website and users actions within the website, calculated from the time of the user’s last visiton the website

Providing the Controler’s social media

  • Scope of data: first name, last name, image, others public information,  and, in the case of sending messages, data provided voluntarily in the content of the message or activity
  • Legal ground: Article 6(1)(a) of the GDPR – consent of the data subject
  • Processing period: until the data subjectwithdraws consent

3. If Blazity is advised that the person uses the services provided by Blazity or the Websitefunctionalities in violation of applicable legal provisions, then Blazity may process user’spersonal data in a scope required for establishing his/her liability.

4. Blazity will not make automated decisions against data subjects. Blazity will carry out profilingof data subjects in a scope necessary to present them personalised content of marketing nature adjusted to needs, preferences and conduct of particular Users

III. Transfer of personal data

1. Blazity transfers data outside the European Economic Area (“EEA”) only when it is necessaryfor the performance of services. Should it become necessary, Blazity will immediately informeach data subject.

2. Transferring users’ personal data to third parties will be governed by model contractual clauses, where both Blazity and its counterparties undertake to ensure appropriate level of security of users’ personal data. Prior to signing model contractual clauses, Blazity verifies each of itscounterparties which would have access to users’ personal data and assesses whether the country to which users’ personal data would be transferred enables enforcement of rights and provides the users with effective legal remedies.

3. If the European Commission issues a decision in which it determines whether the relevant third country ensures the appropriate level of protection of personal data, then transferring users’ personal data to such country may also proceed on the basis of such decision.

IV. Newsletter

1. Blazity transfers personal data outside the EEA for the purpose of delivering the Newsletter to the Rocket Science Group LLC with its registered office in Atlanta, USA – the provider of the tool for sending e-mail message (Mailchimp), based on model contractual clauses.

2. The provider of Mailchimp declares that it complies with the conditions for complianceof data processing with the GDPR. For more information https://mailchimp.com/gdpr/.

3. The United States is not part of the European Economic Area, and therefore the provisions of the General Data Protection Regulation (GDPR) do not apply to itsterritory. Nor has the United States been subject to a decision by the EuropeanCommission finding an adequate level of protection for personal data. This may resultin increased risks in connection with the processing of User’s personal data by theseentities, particularly due to the lack of a supervisory authority in the United States. Youmay file any complaints related to compliance with data protection regulations with the national supervisory authority for Blazity, i.e. the President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw, Poland.

4. The transfer of User’s personal data to recipients in the United States is based on standard data protection clauses (model contractual clauses), which have beenapproved and adopted by the European Commission. Users may obtain a copy of the standard contractual clauses at address: https://mailchimp.com/legal/data-processing-addendum/.

V. Recipients of data

1. Blazity may transfer users’ personal data to third parties for the purpose of performance of the activities stated in the Terms of Service. The recipients of User’s data are: hosting provider, e-mail operator, software development company, provider of the CRM software, provider of the service connected with sending e-mails, accounting firm, law firm, entities providing cloud and other solutions used by Blazity in its current operations which involve personal data processing.

2. Personal data collected by Blazity may also be disclosed to competent state bodies orinstitutions (law enforcement authorities, courts, security service) authorised to gain access to them on the basis of the respective generally applicable legal provisions, or other persons and entities – in the cases prescribed by the generally applicable legal provisions.

3. Each entity to which Blazity transfers personal data for processing on the basis of a personaldata transfer agreement (“Data Transfer Agreement”) guarantees an adequate level of security and confidentiality of the processing of personal data. An entity processing personaldata on the basis of the Transfer Agreement may process personal data through anotherentity only upon prior written consent of Blazity.

4. Disclosure of Users’ personal data to unauthorised entities under the Privacy Policy may takeplace only upon prior written consent of the data subject.

VI. Rights of data subjects

1. With regard to the data that Blazity processes on the basis of your consent, you have the rightto access your data, as well as the right to rectify, delete, or restrict its processing, the right to data portability, and the right to withdraw your consent for data processing at any time. Withdrawal of consent does not affect the lawfulness of processing carried out based on consent before its withdrawal.

2. With respect to data that Blazity processes on a basis other than the consent you have given, you have the right to access your data, as well as the right to rectify, delete, or restrict itsprocessing, the right to data portability, and the right to object to the processing of data basedon legal grounds other than consent, in cases provided for by law. Exercising these rightsdoes not affect the lawfulness of processing carried out before the rights were exercised.

3. Users have the right to object at any time to the processing of your personal data on grounds relating to User’s particular situation in cases where the legal basis for the processing is the legitimate interest of the Blazity. If Blazity concludes that there arecompelling legitimate grounds for processing overriding User’s interests, rights and freedoms, or grounds for establishing, asserting or defending claims, Blazity will continue to process yourobjected data.

4. If personal data is processed for direct marketing purposes, the data subject has the right to object at any time.

5. To exercise your rights, please contact us at contact@blazity.com or in writing at our registeredoffice address.

VII. Social media

1. We use the "social plug-in", i.e. the X or LinkedIn banners posted on the Website, which redirect to, respectively:

a) The Controller’s page maintained by him on LinkedIn [..] (hereinafter: https://pl.linkedin.com/company/blazity)

b) The Controller’s page maintained by him on X […] (hereinafter: "https://x.com/blazity").

2. In connection with the Controller’s X Profile and LinkedIn Profile, as well as the posting of social plug-ins on the Website, if you are an EEA user, the co-controller of the User data is also, respectively:

a) LinkedIn Ireland Unlimited Company with registered office in Dublin (Ireland), address: Wilton Place, Dublin 2, Ireland (hereinafter: "LinkedIn"),

b) Twitter International Unlimited Company Inc. based in Dublin, Ireland, address: Fenian Street Dublin 2, D02 AX07 Ireland (hereinafter: "X")

and together with the Controller as: "Co-Controllers").

3. The Co-Controllers include aggregate data analysis, the purpose of which is to display X Profile and LinkedIn Profile user activity statistics and advertising activities using the tools available there. For more information about Linkedin and X and the arrangements between the Joint Controllers (including their responsibilities), please refer to:

a) Linkedin's privacy policy at: https://pl.linkedin.com/legal/privacy-policy?src=li-other&veh=www.linkedin.com%7Cli-other#other,

b) X privacy policy at: https://twitter.com/en/privacy.

VIII. Other data

1. Blazity may store http enquiries, therefore the files containing web server logs may store certaindata related to users, including the IP address of the computer sending the enquiry, the nameof user’s station – identification through http protocol, date and system time of registration on the website and receipt of the enquiry, number of bytes sent by the server, the URL addressof the site visited by the user before (if the user has entered the website through a link), information concerning user’s browser, information concerning errors occurred by realizationof the http transaction. Web server logs may be collected for the purposes of properadministration by Blazity. Only persons authorised to administer the IT system have access to the data referred to above. Files containing web server logs may be analysed for the purposesof preparing statistics concerning traffic on the website and occurring errors. Summary of suchdetails does not identify the user.

2. Blazity may use analytics and marketing tools, in particular ActiveCampaign, Hotjar, Google Analytics and Facebook Pixel, Google Tag Manager, as part of which it has access to anonymised information on users, including: information on the operating system and Internet browser used by the user, time spent on the website, user’s age range, gender, approximatelocation, interests determined on the basis of his/her activity in the Internet. The detailsreferred to in the preceding sentence are not combined with users’ personal data and do not enable their identification and are not personal data within the meaning of the GDPR.

IX. Security

1. Blazity takes care of security of users’ personal data. For this purpose Blazity has implementedappropriate safeguards and means of protection of personal data taking into account risksconnected with the process of personal data processing. In particular, Blazity appliestechnological and organisational means in order to secure personal data against beingdisclosed to unauthorised persons, taken over by an unauthorised person, changed, lost, damaged or destroyed, as well as processed in violation of the GDPR by using, among otherthings, SSL certificates. The compilation of personal data collected by Blazity is stored on secured servers, moreover, personal data are also secured by internal procedures of Blazityrelated to the processing of personal data and information security policy.

2. Irrespective of the foregoing, Blazity states that using the Internet and services provided by electronic means may pose a threat of malware breaking into the teleinformatic system and device of the relevant person, as well as a third party gaining access to data, includingpersonal data. In order to minimise such threats, each person should use appropriatetechnical safeguards (antivirus programs) or programs securing identification in the Internet.

X. Cookies

1. For the purposes of the correct operation of the website, Blazity uses a cookie supporttechnology. Cookies are packages of information stored on the device of a relevant userthrough Blazity, usually containing information corresponding to the intended use of a particular file, by means of which the user uses the Blazity website – these are usually: website address, date of publishing, lifetime of a cookie, unique number, and additionalinformation corresponding to the intended use of a particular file.

2. Blazity 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'sdevice after closing the session until they are deleted.

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.

4. Cookies used by Blazity are safe for the user's device, in particular they prevent viruses orother software from breaking into the device.

5. Files generated directly by Blazity may not be read by other websites. Third-Party Cookies (i.e. Cookies provided by entities co-operating with Blazity) may be read by an external server.

6. The user may individually change the cookie settings at any time, stating the conditions of theirstorage, through the Internet browser settings or configuration of the service.

7. The user may also individually remove Cookies stored on his/her device at any time in accordance with the instructions of the browser producer.

8. Blazity uses own Cookies for the following purposes: configuration of the website and adjustment of the 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 and number and frequency of visits on the Blazity’s website, as well as determination of Website user’s needs.

9. Details concerning Cookie support are available in the cookie banner visible after the userenters the website.