Privacy policy
PRIVACY AND COOKIES POLICY OF THE WEBSITE WWW.LUBELSKAAKADEMIAJEZYKOWA.PL
§ 1. General provisions
The privacy policy of the www.lubelskaakademiajezykowa.pl website (hereinafter the “Service”) forms part of the Terms and Conditions of use of the Service (hereinafter the “Regulations”), which enables Users to purchase selected language courses and, in this way, to achieve their personal development and personal, business and other goals.
The Privacy Policy sets out the rules for the privacy and processing of personal data of users of the Website based on the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council 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) (Official Journal of the EU L 119, p. 1) (hereinafter referred to as “RODO”) and the provisions of national law applicable to personal data.
The Website is operated by Edu Lub Rent Spółka z ograniczoną odpowiedzialnością with its registered office in Lublin, at ul. Boczna Lubomelska 11/4, 20-070 Lublin, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court Lublin Wschód in Lublin with its registered office in Świdnik, VI Economic Division of the National Court Register under KRS number: 0000995064, REGON: 523267965, NIP: 7123442360.
The Company is the Controller of the personal data (hereinafter the “Controller”) collected, processed and used in connection with the Users’ use of the Website (hereinafter the “Users”).
In matters of data protection, the Administrator can be contacted by e-mail: _________________ [1] and by mail to the Administrator’s registered office address.
§ 2. Personal data, purposes and grounds for processing
The use of the functionalities of the Website may involve the collection and processing of personal data of Users by the Company.
The Company collects information about Users. This may include information that is provided during the use of the Website, especially when filling in forms when enrolling in a selected language course. The Company also collects personal data from Users indirectly, through, among other things, the collection of information about traffic on the Website.
The Company may collect the following categories of personal data:
data related to a given User of the Website: The Company collects information linked to a User such as name, surname, e-mail address, telephone number, PESEL number or passport number and residential address (street, house number, apartment number, postal code, city, country), as well as nationality, gender, date of birth.
information about how Users use and connect to the Website: The Company collects information about how Users use the Website. This includes information such as the pages and sub-pages visited by Users, the duration of access to the Website (how long Users use the Website), as well as any choices Users make when using the Website. This also includes information about the computer, tablet, smartphone or other electronic device that Users use to connect to the Service. This information may include details of the type of device, unique device identifying numbers, operating systems, browsers and applications connected to the Service through the device, internet service providers or mobile network, IP address and device phone number (if applicable).
(4) The provision of personal data is voluntary, but necessary for the proper use of the functionalities of the Website consisting in the purchase of the selected language course, the execution of the completed order, the management of the sales and service process, including the conclusion of the Agreement with the User and the handling of enquiries by e-mail and telephone service provided by the Administrator. Failure to provide personal data in a given case will result in the lack of possibility to use the functionalities of the Service, as well as the Administrator’s inability to manage the sales and service process.
(5) User data entered into the Service are the property of the User. The use of the Service and its functionalities by Users, as well as the use of e-mail and telephone support, may involve data collection and processing by the Administrator – some of the data collected and processed by the Administrator constitutes personal data. The Administrator may also process aggregate information about Service Users.
(6) The Administrator collects and processes personal data to the following extent:
User data contained in the form filled in during the purchase of a selected language course available on the Website, such as: name, surname, e-mail address, telephone number, PESEL number or passport number and address of residence (street, house number, apartment number, postal code, city, country), including nationality, gender, date of birth
data relating to use of the Website, in particular IP address; type of browser used, language, type of operating system, internet service provider, time and date information, location;
data relating to use of the Website recorded in so-called cookies, such as click, navigation or browsing history, data relating to preferences or browsing behaviour on the Website;
data relating to the use of e-mail and telephone services;
other data related to users’ use of the Website’s functionalities, such as additional personal data concerning, for example, complaints submitted.
(7) Personal data of the User will be processed only to enable the use of the functionalities of the Service and to settle accounts between the Administrator and the User for the purchased courses, as well as for the purpose of possible establishment, investigation or defence against claims, for analytical, archival and accounting purposes, as well as for the purpose of offering products and services directly to the User by the Administrator (direct marketing), including selecting them according to the needs of Users with the use of profiling, which, however, will not significantly affect the situation or produce legal effects with regard to the User.
(8) Personal data in the field of ordinary data shall be processed by the Administrator for the following purposes:
to conclude and perform the Agreement or to take action at the request of the data subject prior to the conclusion of the Agreement, including the use of the functionalities of the Website by Users (legal basis: Article 6(1)(b) RODO);
fulfilment of the Administrator’s legal obligations (legal basis: Article 6(1)(c) RODO),
to fulfil the Administrator’s legitimate interests, in particular for archiving, evidential, statistical and reporting purposes, for the purposes of asserting or defending claims, as well as for the purposes of marketing and promoting the Administrator’s products and services (legal basis: Article 6(1)(f) RODO ),
in other cases, personal data in the scope of ordinary data will be processed only on the basis of previously granted consent, to the extent and for the purpose expressed therein (legal basis: Article 6(1)(a) RODO).
(9) The Administrator will process personal data for the period necessary to fulfil the purposes for which they were collected, i.e:
in terms of the performance of the contract concluded with the Administrator for the duration of the contract, and thereafter for the period resulting from the provisions of law or for the fulfilment of the Administrator’s legitimate interests, including the safeguarding and assertion of possible claims,
in the performance of a legal obligation incumbent on the Administrator for the period and to the extent required by law,
where personal data will be processed for the purposes of the Administrator’s legitimate interests referred to above for the period until such interests are fulfilled or an objection to such processing is raised,
where personal data will be processed on the basis of consent – until such consent is withdrawn. To the extent that the data are processed on the basis of a separate consent, the person who gave the consent has the right to withdraw the consent at any time. However, this will not affect the lawfulness of the processing that was carried out before the withdrawal.
(10) The performance of direct marketing by the Administrator by means of terminal equipment (in particular mobile and stationary telephones, tablets, computers) and automatic calling systems, to the telephone number and e-mail address provided by the User, consisting in the receipt of marketing messages about the Administrator’s products and services and marketing actions organised by the Administrator and the sending of commercial information concerning the goods or services offered by the Administrator to the e-mail address provided by the User, within the meaning of the Act of 18 July 2002 on the provision of services by electronic means (Dz.U. of 2020, item 344) is subject to the User’s separate consent. Such consent may be withdrawn at any time.
§ 3 Recipients of data
Personal data may be made available by the Administrator to the following categories of recipients:
authorised employees and associates of the Administrator;
service providers who supply the Administrator with technical and organisational solutions enabling the provision of services (in particular courier and postal companies, IT service providers – including entities providing hosting services, marketing entities, entities supporting accounting processes, banks, legal and advisory service providers and their authorised employees and co-workers);
entities performing data analytics for the purpose of personalising advertisements, developing remarketing campaigns and being separate controllers in this respect;
entities providing tools for the analysis, optimisation and efficient operation of the Administrator’s services, being separate administrators in this respect;
public authorities, insofar as they are authorised to do so by the applicable legislation (upon request by the authorities in question).
(2) The Administrator shall not transfer or authorise the transfer of personal data outside the EEA unless it takes the measures necessary to ensure that the transfer is in compliance with the RODO.
(3) In the course of operating the Service, the Administrator uses the services of Google, where Google is a separate controller of Users’ personal data. The Administrator promotes the Services using Google Ads, Facebook Ads. The data collected about the Users is helpful in better targeting the advertisements and promotion of the Service Owner, and is also used to develop remarketing campaigns. The Administrator makes a special effort to encourage Users to visit the Service. Therefore, in order to improve its Services and enhance the Website, it collects information about the User in an impersonal form using Google Analytics and Google Search Console.
4 The Administrator may collect statistical data on the popularity and use of the various Services offered by the Website, sharing them with other entities. This data will be shared only anonymously and collectively, without the possibility of extracting Users’ personal data on its basis. The Administrator may also use the collected statistical data for marketing, information, statistical purposes and publication in such media as the Internet, press, radio, television, mobile and landline telephony.
(5) This Service has also been designed for and is addressed to minors.
§ 4 Rights of Users
The data subject has the right to:
access to the content of his/her data and to receive a copy thereof,
to rectify (amend) his/her data,
to have his/her data deleted,
restriction of data processing,
to data portability
to object to the processing of his/her data for direct marketing purposes, including profiling, and the right to object to the processing of data on the basis of legitimate interests for purposes other than direct marketing for reasons justified by his/her particular situation,
to withdraw consent to the processing of personal data.
The withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal. In addition, if the Data Subject believes that the Administrator is processing his/her data unlawfully, he/she may lodge a complaint to this effect with the President of the Office for Personal Data Protection or other competent supervisory authority.
§ 5 Data retention period
The Company will keep personal data for the period necessary to fulfil the purposes for which they were collected, i.e:
in terms of the performance of the contracts concluded with the Users for the period of their validity, and thereafter for the period resulting from the provisions of the law or for the fulfilment of the Users’ legitimate interests, including the safeguarding and assertion of potential claims;
in the performance of a legal obligation incumbent on the Administrator for the period and to the extent required by law;
where personal data will be processed in order to pursue the legitimate interests of the Company or of third parties referred to in this Privacy Policy for a period until such interests are pursued or an objection to such processing is raised;
where personal data will be processed on the basis of consent, until such consent is withdrawn.
§ 6 Security measures
The Controller shall take particular care to protect the interests of the data subjects and, in particular, shall ensure that the data he/she collects are processed lawfully; collected for specified, legitimate purposes and not subjected to further processing incompatible with those purposes; substantively correct and adequate in relation to the purposes for which they are processed; and stored in a form that allows the identification of the data subjects for no longer than is necessary to achieve the purpose of the processing.
The Administrator shall comply with the principles set out in the RODO, including, in particular, adequately securing personal data against unlawful access to personal data by third parties, in particular encrypting personal data, archiving personal data, evaluating personal data security measures, ensuring confidentiality, integrity, availability and resilience of processing systems and services.
Personal data provided on the Website and its sub-domains are treated as confidential and are not visible to unauthorised persons. Data protection is carried out in accordance with the requirements of generally applicable laws, and data storage takes place on secure servers.
§ 7 Cookies
The Website uses cookies. User data may therefore also be collected via cookies. These are small text files sent by a web server and stored by your browser software. When the browser reconnects to the website, the website recognises the type of device from which the user is connecting. The parameters only allow the server that created them to read the information they contain. Cookies therefore facilitate the use of previously visited sites.
The information collected relates to the IP address, the type of browser used, the language, the type of operating system, the Internet service provider, the time and date information, the location, and the information sent to the website by the User via a particular form.
As a result of the User’s use of the Website, text files (so-called cookies) may be stored in the User’s devices, the purpose of which is to facilitate the User’s access to and use of the Website, as well as to study the User’s preferences and behaviour in order to enable the delivery of personalised content on the Website and to improve the functioning of the Website. Data is also collected by cookies for statistical purposes.
If cookies have not been deactivated, the User is deemed to have consented to the placement and storage of cookies on their devices. The User can disable the placement and storage of cookies from the level of the web browser they are using. How to disable cookies depends on the web browser used by the User. Disabling cookies may result in the Website, and consequently the ability to make Reservations on the Website, not working properly.
We use the data we collect to monitor and review how Users use our Sites in order to improve the Service by providing a more efficient and seamless navigation experience. We monitor User information using the Google Analytics tool, which records User behaviour on the Website.
The Administrator uses the following cookies:
“necessary” cookies to enable the use of services available on the Website, e.g. authentication cookies used for services requiring authentication on the Website;
cookies used to ensure security, e.g. used to detect abuse of authentication on the Website;
“performance” cookies, making it possible to collect information on how the Website’s pages are used;
“functional” cookies, making it possible to “remember” the user’s selected settings and to personalise the User’s interface, e.g. with regard to the chosen language or region of origin of the User, the font size, the appearance of the website, etc.; and
“advertising” cookies which make it possible to provide Users with advertising content more tailored to their interests.
(7) Cookies placed on a Service User’s terminal equipment and may also be used by advertisers cooperating with the Administrator. Cookies may also be used in particular by the Google network for the purpose of displaying advertisements tailored to the manner in which the User uses the Website. For this purpose, they may store information about the User’s navigation path or time spent on a given page. With regard to the information on User preferences collected by the Google advertising network, the User can view and edit the information resulting from cookies using the following tool: https://adssettings.google.com/authenticated?hl=pl. The Administrator additionally recommends that Users read the Google Analytics Privacy Policy to learn about the use of cookies used in statistics: Google Analytics Privacy Policy. https://www.google.com/analytics/learn/privacy.html?hl=pl
8 Users of the Website may change their settings regarding cookies at any time. These settings can be changed in particular in such a way as to block the automatic handling of cookies in the settings of a web browser or inform on their each time placement in the device of a User of the Service. Detailed information on the possibility and methods of handling cookies is available in the settings of your software (web browser).
(9) Information on the management of cookies in individual browsers can be found on pages dedicated to individual browsers:
FireFox: https://support.mozilla.org/pl/kb/ciasteczka,
Internet Explorer: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer-delete-manage-cookies,
Chrome: http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647,
Opera: http://help.opera.com/Linux/12.10/pl/cookies.html,
Safari: http://support.apple.com/kb/HT1677?viewlocale=pl_PL&locale=pl_PL.
10. the Administrator stipulates that restricting the use of cookies may affect some of the functionalities available on the Website, and in extreme cases may make it impossible to use the Website.
§ 8 Amendment of the Privacy Policy
From time to time, the Company may update this Privacy Policy, so you should review it periodically. When the Company makes a material change to the Privacy Policy, the Company will update the “last modified” date under the Privacy Policy. Changes made to this Privacy Policy are effective when published on the Service.
