Privacy Policy

Scope

This privacy policy describes how we handle the personal data that you supply to us for the sole purposes of Vodeno Sp. z o.o. sales and marketing communications (the “Purpose”) based on an indicated interest in our products and services. By accepting this Privacy Policy, you expressly consent to our collection, storage and use for the Purpose.

This Privacy Policy is effective as of the 5th of August 2024 for all users.

Who are we?

The owner of the website as well as the controller of personal data is Vodeno Sp. z o.o., Dobra Street 40, 00-344 Warsaw, Poland, entered in the Entrepreneurs Register of the National Court Register maintained by the District Court for the capital city of Warsaw, XII Economic Department of the National Court, Register under number KRS 0000728418, with share capital PLN 218 655 400 entirely paid, NIP (Tax Identification Number) 5223122470.

Vodeno has appointed a Data Protection Officer – Maciej Łukaszewicz, who can be reached at dpo@vodeno.com.

Collection

We only collect personal data and never sensitive personal data such as gender, home contact details, ethnicity, religion, political affiliation or sexuality. Our method of collection is one of the following Vodeno:

  • Online via Vodeno website (the “Site”),
  • An enquiry directly via the Site or to a Vodeno employee,
  • Direct personal receipt of your business card,
  • Through an express ‘opt-in’ related to an industry event,
  • Registrations for Vodeno webinars, white papers, etc.

All of the above data collection methods are based on a legitimate interest of Vodeno or your direct and voluntary consent.

You can browse the Site without telling us who you are or revealing any personal data about yourself. Once you give us your personal data via the Site contact form or otherwise, you are not anonymous to us. If you choose to provide us with your personal data this will only be used for the Purpose and never distributed to third parties other than those that Vodeno uses for the Purpose. We may collect and store the following Personal Data:

  • Your name and surname;
  • Your business or work email address;
  • Your business address;
  • Your mobile phone number for business purposes;
  • Your business landline phone number;
  • Your job title or role;
  • Your company name;
  • Your areas of business interest; and
  • Your communication preferences with Vodeno.

Marketing

We don’t sell or rent the personal data that you share with Vodeno to third parties for any purpose without your explicit consent. If you don’t wish to receive sales and marketing communications from Vodeno, you may unsubscribe by clicking on the “unsubscribe” link located at the end of any marketing communication from Vodeno or contact us at dpo@vodeno.com.

Legal basis and purpose of data use

The Data Controller processes Users’ personal data for the following purposes, based on the following legal bases:

  • Respond to an inquiry related to our business

If you contact us by e-mail, call us or use contact forms to arrange a presentation, meeting, obtain more information about our offer, we process your personal data on the basis of the legitimate interest of the administrator under Article 6(1)(f) of the GDPR, which we consider to be a response to the inquiry, maintaining conversation, providing information. We store the data processed for contact purposes for the time necessary to make contact/answer questions/send the ordered material, and then until the end of the calendar year following the year in which the case was resolved or the contact was completed. We store correspondence for such a period of time for the purposes of evidence, securing claims or defending against them, which is our legitimate interest referred to in Article 6(1)(f) of the GDPR.

Providing data is voluntary, however, failure to provide them will result in the fact that we will not be able to achieve the objectives in the form of responding to your inquiry, etc.

  • Conclusion and performance of a contract in connection with our business/ processing of personal data of contractors/customers, representatives of contractors/customers

If you are our customer or contractor and you enter into a contract with us, we process the personal data necessary for this purpose in order to conclude and perform this contract, i.e. on the basis of Article 6(1)(b) of the GDPR. In addition, we process personal data related to the contract for tax and accounting purposes, then the legal basis is Article 6(1)(c) of the GDPR in connection with the Accounting Act of 29 September 1994, the Act of 29 August 1997. Tax Ordinance and the Act of 11 March 2004 on the tax on goods and services. If you are a representative or contact person acting on behalf of our client or contractor, we process your personal data for the purpose of business contact, which is our legitimate interest (Article 6(1)(f) of the GDPR). For us, business contact is all correspondence (electronic, paper), as well as telephone contact regarding the concluded cooperation and the service provided, in particular: making arrangements, arranging business meetings, answering questions, directing information from our side. 

The obtained personal data for accounting and tax purposes will be processed for 5 years from the end of the accounting year in which the accounting document was issued. We store the data processed for contact purposes for the time necessary to complete the contact, and then until the end of the calendar year following the year in which the contract was terminated, unless there are circumstances causing us to process the data longer, e.g. a dispute between the parties to the contract. The data necessary for the performance of the contract/consideration of the complaint are processed for the time necessary for its performance, and then until the expiry of the statute of limitations for mutual claims that may arise from the conclusion of the contract.

Providing the above-mentioned personal data is necessary for the conclusion and performance of the contract. If you do not provide your data, we will not be able to perform the contract or contact you. Providing data processed for tax and accounting purposes is mandatory, as otherwise we will not be able to comply with our legal obligations. 

  • Correspondence via the form from the website, e-mail and traditional as well as telephone contact

We process data for the purposes of ongoing contact, conducting conversations, responding to inquiries, providing information – pursuant to Article 6(1)(f) of the GDPR – which should be understood as the implementation of the legitimate interest of the Administrator.

We store the data processed for contact purposes for the time necessary to make contact/answer questions/send the ordered material, and then until the end of the calendar year following the year in which the case was resolved or the contact was completed. We store correspondence for such a period of time for the purposes of evidence, securing claims or defending against them, which is our legitimate interest referred to in Article 6(1)(f) of the GDPR.

Providing personal data for the above purposes is fully voluntary. Failure to provide data will prevent us from contacting you on an ongoing basis and answering your question. 

  • Collecting data as part of business contacts

In connection with its business activity, the Data Controller collects personal data, e.g. during business meetings or through the exchange of business cards, using LinkedIn, X, etc. – for purposes related to initiating and maintaining business contacts. Such personal data is processed in order to pursue the legitimate interest of the Administrator and its contractor under Article 6(1)(f) of the GDPR, consisting in creating a network of contacts in connection with the conducted business activity. We process the data for the duration of the legitimate interest of the administrator, unless you object to the processing of data earlier. 

Providing personal data for the above purposes is fully voluntary. Failure to provide data will prevent us from contacting you on an ongoing basis.

  • Sending commercial/marketing information  

In the event of consent to receive marketing/commercial information from the Data Controller by electronic and/or telephone means, personal data is processed in order to provide the above-mentioned information. The legal basis for the processing of personal data is the consent to the processing of data in accordance with Article 6(1)(a) of the GDPR in connection with Article 10 of the Act on the provision of services by electronic means and Article 172 of the Telecommunications Law in the scope of certain forms of contact and the legitimate interest of the controller under Article 6(1)(f) of the GDPR in connection with direct marketing. If personal data is processed for direct marketing purposes, the data subject has the right to object at any time to the processing of personal data concerning him or her for the purposes of such marketing, to the extent that the processing is related to such direct marketing. We process data processed on the basis of consent until its withdrawal. The consent may be withdrawn at any time by writing to the e-mail address indicated above. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal. We process the data related to the above-mentioned purpose until you object to the processing or withdraw the consent referred to above. 

Providing data is voluntary, failure to provide data will prevent us from sending marketing messages, which will lead to a lack of knowledge about our latest offers, promotional and marketing campaigns.

  • Sending the newsletter

With regard to newsletter subscribers, we process data on the basis of Article 6(1)(a) of the GDPR (consent of the data subject) in connection with Article 10 of the Act on the provision of electronic services in order to send commercial information related to the Controller’s activity by electronic means. We process the data until the consent is withdrawn. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal

Providing data is fully voluntary. Failure to provide data will prevent us from sending you the newsletter and you will not be able to obtain information about our business activities. 

  • Defence of claims

If such a need arises, we may process personal data for the purposes of asserting, establishing claims or defending against claims – pursuant to Article 6(1)(f) of the GDPR – which should be understood as the implementation of the legitimate interest of the administrator consisting in pursuing its property or non-property rights or protection against claims directed against the Administrator – until the expiry of the limitation periods for possible claims,  and in the case of initiating the proceedings, until their final conclusion. 

Providing data is necessary, failure to provide data will prevent us from pursuing our legitimate interest. 

  • Social networks

We are using social network profiles on LinkedIn and X, in order to contact their users and present content prepared by the Company on these portals and promote our own business, as well as for analytical and statistical purposes, which is the legitimate interest of the Company under Article 6(1)(f) of the GDPR, consisting in enabling contact with the users of the portals,  promoting and informing about their own business. We process personal data of users of these portals when they visit our profiles or interact with them (likes, comments, messages). If you like or comment on our post, remember that it is visible to other users. We store personal data until you object to their further processing by clicking “dislike”, disliking the post or deleting a comment to the post, and then for the period required by the obligations imposed by law and/or until the expiry of the limitation period for possible claims related to the purposes of processing. Providing data is fully voluntary, failure to provide data will not result in negative consequences. 

Social networks have their own privacy policies, terms and conditions and data processing rules that bind their users and which we are obliged to comply with. If you are a user of such a portal, the processing of your personal data is also subject to such terms and policies and you can exercise your rights under them.

  • Cookies

We process personal data obtained as a result of cookies on the basis of the legitimate interest of the administrator under Article 6(1)(f) of the GDPR, which we consider to be the need to receive our website, the desire to properly display the website to the user, or control of the number of people who visit the website. We process data on the basis of the legitimate interest of the administrator, therefore you have the right to object to the processing of personal data (further details below). We process the data for the duration of the legitimate interest of the administrator, but no longer than until the objection to the processing of data is filed. Providing data is fully voluntary, failure to provide data will not result in negative consequences. 

At the beginning of your visit to our website, you are asked for your consent to install cookies on your device under Article 173 of the Telecommunications Law, other than those necessary for the website to function. You can withdraw your consent at any time without affecting the processing of your data that took place before its withdrawal.  In order to exercise your rights, please contact our Data Protection Officer.  Providing data is fully voluntary, failure to provide data will not result in negative consequences.

  • Compliance with legal obligations, including obligations under the GDPR

We are obliged to comply with the obligations set out in the GDPR, i.e., m.in, the creation of registers and records related to the GDPR. We process personal data on the basis of Article 6(1)(c) of the GDPR in connection with a legal obligation to which we are subject and Article 6(1)(f) of the GDPR, i.e. on the basis of the legitimate interest of the controller.

Our disclosure of your data

We may disclose personal data to respond to legal requirements, enforce our policies, or protect anyone’s rights, property, or safety.

We may also share your personal data with:

  • Employees and agents of Vodeno;
  • Service providers under contract who help with our business operations;
  • Other third parties to whom you explicitly give consent to share your data with us;
  • Other business entities, should we plan to merge with, or be acquired by that business entity.

Without limiting the above, in an effort to respect your privacy we will not otherwise disclose your personal data except when we believe in good faith that the disclosure of information is necessary to prevent imminent physical harm or financial loss or to report suspected illegal activity.

Automated processing and profiling

Your data will not be processed by the Administrator in an automated manner, including in the form of profiling.

Data transfer

Your personal data will be stored in the European Economic Area. Your Personal Data may be accessed by Vodeno staff outside the European Economic Area. We will always take all the steps necessary to ensure that your Personal Data is treated securely and in accordance with this policy.

Your rights: Accessing, reviewing, changing and erasing your personal data

Any person can request details of what data Vodeno holds about them at any time by contacting us at dpo@vodeno.com.

In connection with the processing of personal data, You have the following rights: 

  • the right to access their personal data (Article 15 of the GDPR), including obtaining a copy of the data (Article 15(3) of the GDPR),
  • the right to rectify (correct) or supplement incomplete personal data (Article 16 of the GDPR), 
  • the right to request the deletion of personal data in cases provided for by law (Article 17 of the GDPR),
  • the right to request restriction of the processing of personal data (Article 18 of the GDPR),
  • the right to receive Your data in a structured, commonly used format and to transfer them when the processing is based on consent or a concluded contract, as well as when the processing is carried out by automated means (Article 20 of the GDPR),
  • the right to object to the processing of your data due to your special situation – in cases where we process your data on the basis of our legitimate interest, including profiling data. The data subject has the right to object at any time on grounds relating to his or her particular situation. The Controller is no longer permitted to process such personal data, unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims. Where personal data is processed for the purposes of direct marketing, the data subject has the right to object at any time to the processing of personal data concerning him or her for the purposes of such marketing, including profiling, to the extent that the processing is related to such direct marketing. The administrator will delete the data immediately. 
  • In cases where data processing is based on consent, the right to withdraw consents granted is available at any time, but without affecting the lawfulness of the processing that was carried out on the basis of these consents before their withdrawal. The consent may be withdrawn at any time.

in cases where it is found that the processing of personal data violates the provisions of the GDPR, the User has the right to lodge a complaint with the supervisory authority, i.e. the President of the Office for Personal Data Protection with its registered office in Warsaw (https://uodo.gov.pl/, ul. Stawki 2, 00-193 Warszawa, 22 531-03-00).

Contact us

For further information on our privacy policies and practices relating to the handling of Personal data, contact us by postal mail to Dobra 40, 00-344 Warsaw, Poland or by email to dpo@vodeno.com.

Changes to this policy

Vodeno reserves the right to amend this Privacy Policy at any time by posting the amended terms on the Site and notifying all consenting users for which Vodeno has contact details.

Cookies

Vodeno and the companies that help us run our business use cookies, as laid out in our Cookies Policy.