Privacy Policy

 

INTRODUCTION

  1. This Privacy Policy stipulates in what way B INTERACTIVE uses the personal data of users who visit B INTERACTIVE websites, interact with them, and make use of B INTERACTIVE services. It also informs about the user’s rights, and how the law protects the user.
  2. It is important that each user reads this Privacy Policy so that they can use the websites and B INTERACTIVE services with full awareness (including knowing in what way and why the data is used).
  3. In the case of any questions or the desire to exercise the right to privacy, the instructions contained in this Privacy Policy should be followed. The B INTERACTIVE team is at your disposal.

 

DATA CONTROLLER

  1. The controller of personal data is B INTERACTIVE Spółka z ograniczoną odpowiedzialnością (Ltd.) with its registered office in Warsaw, Poland, ul. Grzybowska 87, 00 – 844 Warsaw, entered into the Register of Entrepreneurs of the National Court Register under the KRS number 0000800408, NIP 5272902995, REGON 384175638. B INTERACTIVE can be contacted by sending an email to [email protected]

STATEMENT CONCERNING COPPA

  1. The website and B INTERACTIVE services contain information that is not directed at children (persons under the age of 13). This website and all other related services and sites (including services and websites of B INTERACTIVE’s partners) are not intended for children, and thus B INTERACTIVE does not knowingly collect data relating to children.

COLLECTED DATA

  1. B INTERACTIVE collects various information about its customers and visitors when it is provided to B INTERACTIVE, when users make use of B INTERACTIVE’s services, or when B INTERACTIVE obtains it from a different source. The collected data can be classified into the following categories:

 

Identification DataName and surname, company name (affiliation) and address. In the case of contact by means of social media, also the username used on these platforms.
Contact DataName and surname, company name (affiliation) and address. In the case of contact by means of social media – also the username used on these platforms. In the case of subscribing to the newsletter, the Contact Details pertain only the given name and e-mail address.
Financial DataTransaction and Stripe account user data.
Technical Data Internet Protocol (IP) address, browser type and version, time zone settings and location, browser plug-in types and versions, operating system and platform, and other technologies used on devices that users use to access this website.
Usage DataInformation on the use of the website or services (behavioral tracking)
Tracking Data Information that B INTERACTIVE or other entities collect about users through cookies and similar tracking technologies such as web beacons, pixels and identifiers of mobile devices.

 

  1. B INTERACTIVE collects, makes available, and uses Aggregated Data (statistical or demographic data), which however, do not constitute personal data. If this data is combined by B INTERACTIVE with data enabling the user’s identification, then the aggregated data is treated by B INTERACTIVE as personal data.
  2. B INTERACTIVE does not collect sensitive data (data of a special category), including data revealing racial origin, ethnicity, religious beliefs, data concerning sex life and orientation, political views, information on health and diseases, as well as biometric and genetic data.
  3. If a given user decides not to share certain data with B INTERACTIVE, this may result in the inability to provide services provided by B INTERACTIVE. In cases where the law requires consent, it is always voluntary. However, B INTERACTIVE does not only rely on users’ consent when processing data, but also on other grounds for data processing.

 

DATA COLLECTION METHOD

  1. B INTERACTIVE uses various methods of collecting personal data, i.e.:

 

Direct interactionsThe user transfers the data directly to B INTERACTIVE. The transfer takes place with registration (conclusion of the contract), contact by post or telephone, and contact by means of social media or with the performance of the contract (software license in the SaaS model).
In this way, we collect Identification Data, Contact Data and Financial Data.
Automated activities Data is collected automatically when interacting with B INTERACTIVE (including by means of the website), through cookies and analytical tools.
This way, we collect Technical Data, Usage Data, and Tracking Data. We may also collect Aggregated Data.
We use automatic actions only in Google Analytics and Hotjar.
From third parties The data is transferred by entities external to B INTERACTIVE (including entities providing tracking and statistical services, etc.), so far as these entities have a legal basis for the transfer. This basis is usually the user’s consent.
This way, Technical Data, Usage Data, and Tracking Data is collected. We may also obtain Financial Data (payment operators).
Necessary personal data may be obtained by B INTERACTIVE also by means of API located on the portals of B INTERACTIVE’s business partners, and entities providing services to B INTERACTIVE.

 

DATA USAGE METHOD

  1. The way data is used by B INTERACTIVE depends on the purpose for which the data was transferred or obtained:
When we perform an already concluded contract or want to conclude it.For example, when the user logs in to conclude a software license agreement in the SaaS model
When it is justified by the interests of B INTERACTIVE or the interests of third parties, and the interests of the user do not overrideFor example, when we have a reasonable suspicion of fraud; when B INTERACTIVE wants to inform about new services
When B INTERACTIVE has to fulfill its legal obligationFor example, for tax settlements

 

In principle, however, B INTERACTIVE uses the data for: (a) the provision of services that are electronically provided, and in the case of users with whom the contract has been concluded – also for the performance of this contract; (b) the provision of other services; (c) the handling of inquiries, requests, and orders; (d) marketing activities (marketing of own products); (e) analytical purposes, and to improve the performance of websites and services provided by B INTERACTIVE; (f) the purposes of development, repair or testing of various functionalities;

 

LEGAL BASIS FOR DATA COLLECTION. RETENTION

  1. B INTERACTIVE may process personal data on the following legal grounds:
Performance of the contract, or activities prior to its conclusion

Article 6 (1) 1 letter b) of GDPR Regulations

 

The data is stored for the period necessary to perform, to terminate, or otherwise for the expiration of the concluded contract.

Identification Data, Contact Data, and Financial Data
Direct marketing

Article 6 (1) 1 letter f) of GDPR Regulations

 

The data is stored for the duration of the legitimate interest performed by B INTERACTIVE, however, in the event of exercising the right to object, or withdrawing consent to receive the newsletter, no longer, however, than for the period of limitation of claims after performance of such action. The limitation period is determined by the law, in particular the Civil Code (the basic limitation period for claims related to running a business is three years).

 

B INTERACTIVE cannot process data for the purpose of direct marketing in the event of an effective objection in this regard by the person whose data it concerns.

Contact Data
Bookkeeping

Article 6 (1) 1 letter c) of GDPR Regulations in connection with art. 74 sec. 2 of the Accounting Act

 

Data is stored for the period required by law requiring B INTERACTIVE to store accounting books (5 years from the beginning of the year following the financial year to which the data relates).

Identification Data, Contact Data and Financial Data, tax identification number
Providing an answer to the question asked

Article 6 (1) 1 letter f) of GDPR Regulations

 

Data is stored for the duration of the legitimate interest pursued by B INTERACTIVE, however, no longer than for the period necessary to answer the questions asked.

Identification Data, Contact Data
Establishing, pursuing, or defending claims

Article 6 (1) 1 letter f) of GDPR Regulations

 

Data is stored for the duration of the legitimate interest pursued by B INTERACTIVE, however, no longer than for the period of limitation of claims against the person whose data it concerns. The limitation period is determined by the law, in particular the Civil Code (the basic limitation period for claims related to running a business is three years).

Identification Data, Contact Data and Financial Data, tax identification number
Ensuring data security and protection, as well as protection against fraud

Article 6 (1) 1 letter f) of GDPR Regulations

 

Data is stored for the duration of the legitimate interest pursued by B INTERACTIVE, however, no longer than for the period of limitation of claims against the person whose data it concerns. The limitation period is determined by the law, in particular the Civil Code (the basic limitation period for claims related to running a business is three years).

Identification Data, Contact Data and Financial Data

 

RIGHTS OF PERSONS WHOM THE DATA CONCERNS

  1. The data subject (user) has the following rights:
Right of access, rectification, restriction, deletion, or transferthe person whose data it concerns has the right to request B INTERACTIVE to access their personal data, rectify it, delete it (“the right to be forgotten”), or to limit the processing, and has the right to object to the processing, and has the right to transfer their data. Detailed conditions for the exercise of the above-mentioned rights are set out in Art. 15-21 of the GDPR Regulation
The right to withdraw consent at any timea person whose data is processed by B INTERACTIVE on the basis of expressed consent (pursuant to art.6 (1) letter a) or art. 9 (2) letter a) of the GDPR Regulation) has the right to withdraw consent at any time without affecting the lawfulness of the processing which was carried out on the basis of consent before its withdrawal
The right to file a complaint with the supervisory authoritythe person whose data is processed by B INTERACTIVE has the right to file a complaint with the supervisory authority in the manner and mode specified in the provisions of the GDPR Regulation and Polish law, in particular the Act on the Protection of Personal Data. The supervisory authority in Poland is the President of the Personal Data Protection Office
The right to objectthe person whose data it concerns has the right to object at any time – for reasons related to their particular situation – to the processing of their personal data based on art. 6 (1) letter e) (public interest or tasks) or f) (legitimate interest), including profiling based on these provisions. B INTERACTIVE, in such case, is no longer allowed to process this personal data, unless it demonstrates the existence of valid legitimate grounds for processing, overriding the interests, rights, and freedoms of the person whose data it concerns, or grounds for establishing, investigating, or defending claims
The right to object in regards to direct marketingif personal data are processed for direct marketing purposes, the person whose data it concerns has the right to object at any time to the processing of their personal data for the purpose of such marketing, to the extent that the processing relates to such direct marketing

 

  1. Exercising the rights of the person whose data it concerns is done by contacting B INTERACTIVE using the contact details specified at the beginning of the policy.

 

PROFILING

  1. B INTERACTIVE does not perform profiling.

 

TRANSFER OF DATA

  1. Data collected by B INTERACTIVE, in principle, is not transferred to third parties. However, B INTERACTIVE can:
    a. transfer the data of persons who have used B INTERACTIVE services to entities supporting B INTERACTIVE in providing services, such as payment service providers or analytical tool providers (e.g., Google Analytics);
    b. transfer data to law enforcement authorities, supervisory authorities, entities performing public tasks or others, when the obligation to disclose data results from legal provisions.

The transfer of data must always take place on the basis of a legal provision or an appropriate contract (entrusting the processing of personal data).

  1. Data may be transferred outside the European Economic Area, with B INTERACTIVE ensuring that appropriate security measures are provided. In particular, B INTERACTIVE concludes appropriate contracts (standard contractual clauses) to secure the transferred personal data, and transfers the data to countries for which the European Commission has issued a decision declaring the appropriate level of protection.

 

COOKIES AND ANALYTICS

  1. Cookie files (cookies) are small text information in the form of text files, sent by the server and saved on the side of the person visiting the website (e.g., on the hard drive of the computer, laptop, or on the smartphone’s memory card – depending on the device which is used by the user).
  2. As a standard, most internet browsers available on the market accept cookies by default. Every person has the option to define the terms of using cookies by means of settings of their own web browser. This means that it is possible, for example, to partially limit (e.g., temporarily), or completely disable the option of saving cookies – in the latter case, however, it may affect some of the website functionalities.
  3. B INTERACTIVE uses the following cookies:
    a. Google Analytics;
    b. Hotjar;
    c. files necessary for the operation of the website.

These files are required for traffic analysis, and are not essential for the proper functioning of B INTERACTIVE websites. B INTERACTIVE provides an easy way to disable these files.

Google Analytics

B INTERACTIVE uses Google Analytics services and its functions provided by Google Inc. (1600 Amphitheater Parkway, Mountain View, CA 94043, USA). These services support B INTERACTIVE in analyzing and improving the websites and the services provided through them. Google Analytics, along with advertising functions, uses cookies to analyze the use of websites. The received data is processed in a collective and anonymized way (this means that they prevent the identification of a person. However, this data may be combined with other data. In such case, they constitute personal data for B INTERACTIVE). Every person has the option to block the transfer of data from electronic devices to Google Analytics by downloading and installing a free browser plug-in available here.

Hotjar

B INTERACTIVE uses Hotjar services provided by Hotjar Ltd (head office address: St Julian’s Business Center, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta) that monitor and record behavior on websites. This tool records behavior data such as navigation, page scrolling, cursor movement. Information on the location, operating system, browser, or cookies is also collected. The received data is processed in a collective and anonymized way (this means that they prevent the identification of a person. However, this data may be combined with other data. In such case, they constitute personal data for B INTERACTIVE). Everyone has the option to disable the activity measured by Hotjar using the functionality available here.

Necessary files

These are files that cannot be disabled with other functions, except by changing browser settings. These files guarantee the proper operation of B INTERACTIVE websites and can be used for (a) protection against abuse (security during login and authentication) and (b) maintaining the session (maintaining login when switching between tabs).