Privacy policy

Our goal is to provide you with a sense of security while providing our services, which is why your privacy and protection of personal data are our priority. We assure you that your data will be processed in a manner consistent with the law, in a transparent manner and subject to your control.
The following Privacy Policy is intended to inform you about how we use your personal data, in accordance with the requirements of Regulation (EU) 2016/679 EU of the European Parliament and of the Council of 27 April 2016 (hereinafter: "RODO").

1. Administrator's data

The administrator of your personal data within the meaning of the RODO is VR Ltd with its registered office in Kraków, ul. Królowej Jadwigi 281, 30-234 Kraków, KRS 728940, NIP 6772433989 (hereinafter: Administrator). In matters relating to the protection of personal data, you can contact the Administrator via the email address: info@exa22.com.

2.Purposes and legal grounds for data processing

The scope of the collected data includes contact details, i.e. name and surname, e-mail address, telephone number, job position, profession, IT identifier, business contact details, type of business activity, tax identification number.
Your personal data may be processed by the Administrator on the basis of:
   a) indispensability to perform the contract or to take action before its conclusion (Article 6(1)(b) of the RODO), separately for the purpose of:

1. establishing commercial cooperation, determining the terms of cooperation, performance of the contract, including the implementation of warranty and guarantee rights after the performance of the contract and services
2.  sending telemetry data generated by devices connected to the Administrator's telemetry network, in accordance with the agreements concluded in this regard
3. organization of work, personnel management, keeping a list of tasks performed by the administrator's employees for the purposes of settlement with the client, drawing up a list of tasks performed
4. maintaining current professional and commercial relations, commercial cooperation, accepting and submitting offers 
      b) indispensability for the performance of legal obligations incumbent on the Administrator (Article 6(1)(c) of the RODO), including for the purpose of taking actions related to counteracting               money laundering and financing terrorism, meeting the requirements of tax and accounting regulations, confirmation of the administrator of its obligations under the provisions on the                       protection    of personal data,
      c) the legitimate interest of the Administrator (Article 6(1)(f) of the RODO), separately for the purpose of:
          (i) pursuing or defending against possible claims, where the Administrator's legitimate interest is to pursue or defend claims.
          (ii) marketing of the Administrator's own products and services, including for analytical purposes, where the legitimate interest of the Administrator is to conduct direct marketing of own                   products and services.

3. Transfer of personal data

This Privacy Policy applies to all cases where VR Ltd is the administrator of personal data and processes personal data. This applies both to cases where we process personal data obtained directly from the data subject and to cases where we have obtained personal data from other sources.

The data may be transferred to entities processing them on our behalf on the basis of contracts concluded with the Administrator, but only for the purpose and scope necessary for the implementation of the above-mentioned purposes. purposes, including entities providing us with IT services or other services ensuring the proper provision of services, and such entities process data only in accordance with the Administrator's instructions.

We transfer your data only to entities located within the European Economic Area and thus subject to strict EU data protection regulations, or those that are bound by an appropriate security standard. Data transfer to third countries is not currently practiced or planned by us.

4. Period of storing personal data

We process your personal data only for the period necessary to meet the purpose of their storage or as long as it is required of us by law, in particular until any claims expire or the archiving obligation under the law expires, including the obligation to store accounting documents.

In the event of processing personal data based on your consent, your data will be stored until it is withdrawn. At any time, it is possible to withdraw consents expressed on the website, including consent to the processing of data for marketing purposes of entities cooperating with the Administrator. Revocation of consent to processing will not affect the lawfulness of the processing that was carried out before its withdrawal.

In the case of processing your data on the basis of the legitimate interest of the Administrator, the Administrator will stop processing the data earlier if you object to the processing of data.

5. Your rights

Right of access to data

You have the right to obtain information about the personal data we hold about you, including a copy of this data.

Right to rectification

You have the right to request rectification of your personal data that is incorrect. Taking into account the purposes of processing, you have the right to request supplementation of incomplete personal data, including by submitting an additional statement.

The right to delete data

You have the right to request the erasure of your personal data stored by us in the following cases:

• your personal data is no longer necessary for the purposes for which it was collected,
• you have withdrawn your consent on which the processing is based and there is no other legal basis for the processing,
• you have objected to the processing and there are no overriding legitimate grounds for processing, or the objection concerns the processing of data for direct marketing purposes,
• personal data has been processed unlawfully,
• personal data must be deleted in order to comply with a legal obligation provided for in Union law or national law,
• personal data has been collected in connection with the offering of information society services referred to in art. 8 sec. 1 RODO.

Right to data portability

You have the right to receive, in a structured, commonly used, machine-readable format, personal data concerning you that you have provided to us, if the processing of such data is based on consent or a contract and in an automated manner.

If you request that these data be sent to another data controller, this will be done, provided that it is technically possible.

The right to limit data processing

You have the right to request that the processing of your personal data be restricted in the following cases:

• you question the correctness of the personal data - for a period enabling us to check the correctness of this data,
• the processing is unlawful and you oppose the deletion of personal data, requesting the restriction of their use instead,
• we no longer need personal data for the purposes of processing, but you need them to establish, pursue or defend claims,
• you have filed an objection pursuant to Art. 21 sec. 1 regarding processing - until it is determined whether the legitimate grounds on the part of the Administrator override the grounds for objection.

Right to object to processing

If your personal data is processed on the basis of the legitimate interest of the Administrator, you have the right to object to the processing at any time, in accordance with art. 21 RODO.

Right to withdraw consent

You have the right to withdraw your consent to the processing of personal data at any time. Revocation of consent to processing will not affect the lawfulness of the processing that was carried out before its withdrawal.

If you want to exercise your rights, please send us a message at: info@exa22.com.

The security of personal data is a priority for us, however, if you consider that by processing your personal data we violate the provisions of the RODO, you have the right to lodge a complaint with the President of the Office for Personal Data Protection.

6. Use of Cookies

Through cookies (so-called cookies), which are files saved by your web browser on your computer's hard drive, the Portal collects data related to the way you use the Portal in order to improve our services offered to visitors and users. Cookies do not identify your identity. The data saved in cookies contain information on which pages you have visited, the date and time of your visit and other information about your activity on the pages.

The collected information allows us to adapt the Portal to the needs of users in order to constantly improve the readability, transparency, intuitiveness and quality of online services. In order to carry out the aforementioned analysis, aggregated and anonymous statistical data is captured. This data is anonymized connection data and data on the sequence of launched links (clickstream data), relating to the browser used, the number of visits / visits to the website and the behavior of data of users visiting the Administrator's website. During the collection and processing of data, the shortened IP address of the visitor to the website may also be viewed.

The data is analyzed to calculate the number of visitors to the website, to track those areas of the website that are particularly attractive to a given website visitor, to analyze where the website visitors come from in order to optimize the services provided.

The above process includes the use of cookies. By adjusting their browser settings, users can block cookies at any time or indicate that cookies can only be set if they are explicitly accepted by the user.

The collected cookies are stored by the Administrator for an indefinite period of time only for auxiliary purposes, used to administer the website.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that in this case you may not be able to use all the functions of the website. You can also prevent Google from collecting the data generated by the cookie and related to your use of the website (including your IP address) and from processing this data by Google by downloading and installing the browser plug-in available at the following link. Current link: tools.google.com/dlpage/gaoptout. You can prevent the collection of your data by Google Analytics by clicking on the following link. An opt-out cookie will be set which prevents future collection of your data when visiting this website: Deactivate Google Analytics. Detailed information on the terms of use and data protection can be found at www.google.com/analytics/terms/pl.html or https://www.google.pl/intl/pl/policies/. Please note that on this website Google Analytics has been extended with the code "gat._anonymizeIp();" to ensure anonymous collection of IP addresses (so-called IP masking).

7. Links to Other Sites

The Portal also contains links to other websites. The rules of using websites and maintaining the privacy of users of websites to which the user is redirected via a link are posted on these websites. The administrator is not responsible for the privacy protection policy applied by the owners of the websites to which he publishes links on his website.

8. Method of securing data

The administrator applies a number of IT and organizational security measures aimed at minimizing the risk of data leakage, destruction or disintegration, such as: the website's protected protocol and internal procedures for access and data processing. The Administrator informs that using the Internet always carries the risk of certain security incidents, however, the security measures used by the Administrator serve to limit this risk as much as possible.

9. Changes to the Privacy Policy

In order to ensure that the Privacy Policy meets the current requirements imposed by law at all times, we reserve the right to make changes to it at any time. The above also applies in cases where the Privacy Policy requires changes to cover new or changed products or services of the Administrator.

Exa22 - RODO