PRIVACY POLICY
The Privacy Policy (“Policy”) refers to the information that we gather on or through our websites www.witbee.com, www.cloud.witbee.com (collectively: the “Website”) and all related websites and services we provide where a link to this Policy is displayed, how we use and disclose such information, and the steps we take to protect such information. Visiting the Website, purchasing or using the Services, means the acceptance of the privacy practices described in this Policy as a whole. Otherwise, the use of the Website and the Services is forbidden.
Providing certain information, including personal data, is voluntary, but it is a necessary condition to use the Website and Services.
This Policy is incorporated into, and is subject to, the Terms, which forms an agreement between you and WITBEE. Capitalized terms used but not defined in this Policy have the meaning given to them in the Terms.
I. Definitions:
Website – www.witbee.com, www.cloud.witbee.com or its sub domains or domains with identical names under other top domains owned by the Supplier.
Witbee (or Supplier) - WITBEE spółka z ograniczoną odpowiedzialnością z siedzibą w Warszawie, address: ul. Ordynacka 9/33, 00-364 Warsaw, Poland, KRS: 0000623475, NIP: 5252662720, REGON: 364731210, registry court: Sąd Rejonowy dla m.st. Warszawy w Warszawie – XII Wydział Gospodarczy Krajowego Rejestru Sądowego, share capital: 30.000,00 PLN – the owner of the Website; Services provider.
Visitor - means an individual other than a Client, who uses the public area and has no access to the restricted areas of the Website or Services.
Client – means a natural or legal person who has accepted the Terms with the Supplier and has registered the Account; also, a representative of a Client, his employee or agent, who primarily uses the restricted areas of the Website for the purpose of accessing the Service.
Client Data - any digital data and information (including personal data) that Client submits to the Services, which are subject to the Services or otherwise provided, collected, processed or stored using the Services by the Client.
Public Website Area - means the area of the Website that can be accessed both by Clients and Visitors, with no need to log in.
Restricted Website Area - means the area of the Website that can be accessed only by Clients and where access requires logging in.
GDPR - 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 (General Data Protection Regulation)
II. Personal Data
1. Who will be the controller of personal data?
If we receive your personal data in connection with your use of the Website or Services, Witbee becomes the controller of your personal data for the purposes of GDPR.
If in connection with the use of Services as a Client you provide us with personal data of your customers, Witbee becomes the processor of this personal data for the purposes of GDPR. In this case, data processing contract is needed.
2. The purpose and legal basis of personal data processing
The personal data that you provide is processed and used only in a manner appropriate to the purpose for which it was collected. By providing personal data via the Website and Services, you give your consent to processing of personal data by Witbee in accordance with this Privacy Policy and/or any other additional contract between you and Witbee.
Witbee collects different types of information from or through the Website and Services. We will use personal data obtained through the Website or Services for the following purposes:
to enable the use of the Website, Services, Account registration, in particular handling, maintaining, improving and providing all functions of the Website or Services, providing requested services and information, responding to comments and questions and providing support to Clients and Visitors - in accordance with the Terms - legal basis: article 6 paragraph 1 point b) GDPR ("performance of the contract"),
performance of legal obligations imposed on us - legal basis: article 6 paragraph 1 point c) GDPR ("legal obligation"),
accountants, for claims, defense against claims - legal basis: article 6 paragraph 1 point f) GDPR ("legitimate interest"),
prevent fraud when using the Website or Services and verification of payment credibility - legal basis: article 6 paragraph 1 point f) GDPR ("legitimate interest"),
direct marketing of own products and services - legal basis: article 6 paragraph 1 point f) GDPR ("legitimate interest"),
creating collations, analyzes and statistics for our internal needs, which includes in particular: reporting, marketing research, development planning of the Website and Services, development work, surveying the opinions, needs and customer satisfaction, creation of statistical models - legal basis: article 6 paragraph 1 point f) GDPR ("legitimate interest").
In the cases specified in points 2-6 above, we can perform profiling, or automated processing of your data and development of predictions about preferences or future behaviors (e.g. in the case of marketing profiling, we can adapt advertising messages to your needs, using the information available to you about your behavior and preferences).
If you consent to the use of your data for other purposes, the content of this consent will specify the purpose for which we will process this data - legal basis: article 6 paragraph 1 point a) GDPR ("consent to data processing").
3. Which information we process?
To use certain functionalities of the Website and to use the Services, we require certain personal data (without providing them you can not use the functionality of the Website and the Services). Providing data is voluntary, it is not a statutory obligation. During the collection of this data, e.g. during the registration of the Account and the ordering of the Services, we will inform you which of the data mentioned in the form is necessary and which data is additional data, not affecting the registration or purchase of the Services.
Examples of personal data include name, address, email address, mobile phone number, credit card or other billing information. Personal data also includes other information, such as geographic area or preferences, where any such information is linked to information that identifies a specific individual. We may be provided with personal data in various ways (through the Website and Services) i.e., during the registration for an Account, or the use of the Services, or when you post Client Data or send us customer service-related requests.
Witbee may process the following categories of personal data:
contact details: name, surname, company name, telephone number, email, company website - especially when you create an Account or log in to our Website, buy the Services, ask for technical support or subscribe to our newsletter;
payment details: bank account number, card owner's details, payment card number, expiry date of the card – in particular when purchasing the Services and checking payment details;
content of messages between you and Witbee, such as e-mails, letters, chats, telephone conversations – when you contact us, also via social media;
your opinions about us – when you share your opinion about our Services with us;
IP number, cookies, and information how you use our Website and Services – when you use Website and the Services, in particular:
signs identifying the customer,
markings identifying the end of the telecommunications network or the IT system used by the customer,
information on the beginning, ending and scope of each use of the service provided electronically,
information on the use by the customer of services provided electronically.
In case of logging in to the Account via another platform that verifies and authenticates the Client, Witbee receives this personal data from entities providing such service, e.g. Google.
4. Personal data retention
Witbee stores personal data only for the time it takes to achieve the purposes for which the data has been collected, unless the law requires otherwise. We will retain and use information, if necessary, to comply with our legal obligations, resolve disputes, and enforce our agreements as follows:
personal data processed for the purpose of conclusion and performance of contracts will be kept for the period of their duration and after its expiry for the period necessary to pursue claims;
personal data collected and recorded for accounting purposes will be processed for the period specified in applicable law, including tax regulations;
personal data processed in pursuing the legitimate interests of Witbee will be kept until this interest is fulfilled, however, not longer than until you object,
personal data processed for purposes of direct marketing, including profiling, will be stored until you object,
personal data collected based on your consent (legal basis: article 6 paragraph 1 point a) GDPR) will be processed until you withdraw your consent.
5. To whom we disclose personal data
Except as described in this Policy, we will not intentionally disclose the personal data that we process to third parties without the consent of the applicable Visitor or Client. We may disclose information to third parties if you consent to us doing so, as well as in the following circumstances:
Third party service providers and subcontractors we work with who provide website, application development, hosting, maintenance, IT, electronic payments, accountancy, legal service and other services. These third parties may have access to, or process personal data as part of providing those services for us. We limit the information provided to these service providers to that which is reasonably necessary for them to perform their functions, and our contracts with them require them to maintain the confidentiality of such information.
We may disclose personal data or other information if required to do so by law or in the good-faith belief that such action is necessary to comply with applicable laws, in response to a facially valid court order, judicial or other government subpoena or warrant, or to otherwise cooperate with law enforcement or other governmental agencies.
We reserve the right to disclose personal data or other information that we believe, in good faith, is appropriate or necessary to (a) take precautions against liability, (b) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (c) investigate and defend ourselves against any third-party claims or allegations, (d) protect the security or integrity of the Website or Services and any facilities or equipment used to make them available, or e) protect our property or other legal rights, enforce our contracts, or protect the rights, property, or safety of others.
We may make certain automatically-collected, aggregated, or otherwise non-personally-identifiable information available to third parties for various purposes, including (a) compliance with various reporting obligations; (b) for business or marketing purposes; or (c) to assist such parties in understanding our Clients’ and Visitors’ interests, habits, and usage patterns for certain programs, content, services, and/or functionality available through the Website and Services.
Information about Clients and Visitors, including personal data, may be disclosed and otherwise transferred to an acquirer, successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets. Client Data may be physically or electronically transferred to an acquirer, or successor or assignee as part of any merger, acquisition, debt financing, sale of assets, or similar transaction, as well as in the event of an insolvency, bankruptcy, or receivership in which information is transferred to one or more third parties as one of our business assets, for the sole purpose of continuing providing the Services.
6. Marketing communication
Witbee may process your personal data for marketing purposes consisting in sending you information and commercial offers via e-mail or telephone, if you have agreed to such data processing.
If you agree to receive marketing messages, we will send you messages that you may be interested in or offer our products or services.
If you agree, Witbee may send you messages promoting products and services of our partners that may be related to your interests and needs in the field of data analysis.
If you do not want to receive marketing messages from us, you can unsubscribe at any time by clicking the appropriate unsubscribe link at the bottom of every marketing email, by managing your account preferences or sending your opt-out via email to: info@witbee.com.
7. Your rights related to the processing of personal data
You are entitled:
to obtain from the Supplier confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data,
to obtain from the Supplier the rectification of inaccurate personal data concerning him or her and to have incomplete personal data completed,
to obtain from the Supplier the erasure of personal data concerning you,
to obtain from the Supplier restriction of processing,
to obtain from the Supplier to transfer your personal data,
to lodge a complaint with a supervisory authority if you think that the processing of your personal data violates the law; the Polish competent authority: President of the Personal Data Protection Office,
where personal data are processed for direct marketing purposes, then you shall have the right to object at any time to processing of personal data concerning you for such marketing, which includes profiling to the extent that it is related to such direct marketing. In case of objection, we are obliged to stop processing the data for this purpose,
to object, on grounds relating to your particular situation, at any time to processing of personal data concerning you which is based on performance of a task carried out in the public interest, in the exercise of official authority vested in the controller or for the purposes of the legitimate interests pursued by the Supplier or by a third party, including profiling based on those provisions. The Supplier shall no longer process the personal data unless the Supplier 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.
You can exercise above rights by submitting an application to our address indicated in the contact details. To ensure that you are authorized to submit an application, we may ask you to provide additional information that allows us to identify you. The scope of each of above rights and the situations in which they can be exercised result from the law. The rights you can exercise will depend, among other things, on the legal basis of your use of your data and the purpose of their processing.
Provisions of this article do not apply to personal data that is part of Client Data. In this case, the processing of the Client Data is subject to the Client’s own privacy policy, and any request for access, correction or deletion should be made to the Client responsible for the uploading and storage of such data into the Website and Services.
8. Consent to the processing of personal data
If the processing of your personal data by us is not necessary for the performance of the contract, the fulfillment of the legal obligation or does not constitute our legitimate grounds, we may ask for your consent for certain processing of your data. You can withdraw your consent at any time. This will not affect the lawful processing of your data before withdrawal of such consent.
9. Client Data
Supplier has no direct relationship with the Client’s customers or third party whose personal data it may process on behalf of a Client. An individual who seeks access, or who seeks to correct, amend, delete inaccurate data or withdraw consent for further contact should direct his or her query to the Client they deal with directly. If the Client requests Supplier to remove the data, we will respond to its request immediately. We will delete, amend or block access to any personal data that we are storing only if we receive a written request to do so from the Client who is responsible for such personal data, unless we have a legal right to retain such personal data. We reserve the right to retain a copy of such data for archiving purposes, or to defend our rights in litigation. Any such request regarding Client Data should include sufficient information to identify the Client and the information to delete or amend.
Supplier is not responsible for the content of the personal data contained in the Client Data or other information stored on its servers (or its subcontractors’ servers) at the discretion of the Client nor is Supplier responsible for the manner in which the Client collects, handles disclosure, distributes or otherwise processes such information.
10. Third-party services
The Website and Services may contain features or links to websites and services provided by third parties, which are not managed by us. The information you provide on these websites or services will be subject to their own privacy policy and data processing practices. We are not responsible for procedures related to the processing of information and/or the policy of such independent websites and service providers. We encourage you to learn about third parties’ privacy and security policies before providing them with information.
11. Personal data Transfer
Your personal data may be accessed by and processed outside the European Economic Area (the European Economic Area being the European Union and Iceland, Liechtenstein and Norway, collectively “EEA”). Where your personal data are transferred outside of the EEA, Supplier requires that appropriate safeguards are in place. WITBEE will fulfill its obligations under Chapter V of the GDPR.
In particular, we inform you that we use hosting services, Google Analytics and other tools provided by Google LLC, whose infrastructure is in the USA.
12. Data security
We follow generally accepted standards to protect the information submitted to us, both during transmission and once we receive it. We maintain appropriate administrative, technical and physical safeguards to protect personal data against accidental or unlawful destruction, accidental loss, unauthorized alteration, unauthorized disclosure or access, misuse, and any other unlawful form of processing of the personal data in our possession. This includes, for example, firewalls, password protection and other access and authentication controls. We use SSL technology to encrypt data during transmission through public Internet.
Remember that no method of transmission over the Internet, or method of electronic storage, is 100% secure. We cannot ensure or warrant the security of any information you transmit to us or store, and you do so at your own risk. We also cannot guarantee that such information may not be accessed, disclosed, altered, or destroyed by breach of any of our physical, technical, or managerial safeguards. If you believe your personal data has been compromised, please contact us.
If we get to know of a security breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
13. Processing of children's personal data
The Website and Services are directed to persons over 18 years old. Therefore, Witbee does not process children's personal data.
III. Cookies and other tracking technologies
1. About cookies
In order to improve our services, to provide you with more relevant content and to analyze how Visitors and Clients use our Website and Services, we may use technologies, such as cookies, local storage and pixels.
We use cookies and local storage in our Website. These technologies are small pieces of information stored by your browser on your computer’s hard drive. On your further visits to that website, the information stored in the cookie is sent back to the Website. This allows the Website to recognize you and tailor its content to your needs.
You can obtain more information about cookies by visiting websites like: www.allaboutcookies.org.
2. What cookies do we use?
We use automatically collected information and other information collected through cookies and similar technologies to: (a) personalize our Website and Services, such as remembering a Client’s or Visitor’s information so that the Client or Visitor will not have to re-enter it during a visit or on subsequent visits; (b) provide customized advertisements, content, and information; (c) monitor and analyze the effectiveness of Website, Services and third-party marketing activities; (d) monitor aggregate site usage metrics such as total number of visitors and pages viewed; and (e) track your entries, submissions, and status in any promotions or other activities on the Website and Services.
Especially, we use the following types of cookies:
essential cookies, which are essential for the provision of access to our Websites and Services;
functionality cookies, which are used to personalize the content in accordance with your actions on our Website and Services;
performance cookies, which help us to evaluate the Website performance and its statistics;
targeting/advertising cookies, which help advertise offers and services on the other sites.
Cookies allow you to use the "remember me" option - with this option you have access to your Account on the Website without having to log in to the Website and Services each time. This access is provided if you connect to the Services from the terminal device that you used when you selected this option and put a cookie file. Please note that if you choose the "remember me" option, anyone who will use your terminal device can access your Account on the Website, including access to the Services and your data.
3. Third party cookies
Remember that we use analytics and similar services that collect third-party cookies. While using the Website and Services, third-party cookies may be used (for exemple: Google, Facebook, Twitter, LinkedIn, and other services), in order to enable you to use the functionality of our Website integrated with these websites or to enable the analysis of the effectiveness of the advertising campaign, and collecting anonymised information on the use of the Website for statistical purposes. This Privacy does not regulate the rules for the use of cookies by third parties. Each of the third parties defines the rules for the use of cookies in its privacy policy, in particular:
Google Analytics, Google Optimize, and Google AdWords (Google Privacy Policy is available at https://policies.google.com/technologies/ads?hl=en, text and URL may be changed by Google sole discretion),
Facebook Pixel, Facebook Lead Ads (Facebook Privacy Policy is available at https://www.facebook.com/policy.php, text and URL may be changed by Facebook sole discretion),
Twitter (Twitter Privacy Policy is available at https://twitter.com/en/privacy, text and URL may be changed by Twitter sole discretion),
LinkedIn (LinkedIn Privacy Policy is available at https://www.linkedin.com/legal/preview/privacy-policy, text and URL may be changed by LinkedIn sole discretion).
Our Website uses the Google Analytics tool. You can prevent the registration and processing of data about the use of the Site by Google by installing the browser plug-in at the following address: https://tools.google.com/dlpage/gaoptout. If you are interested in the details related to the processing of data in the framework of Google Analytics, read the explanations prepared by Google: https://support.google.com/analytics/answer/6004245.
We also use the marketing tools available on Facebook and provided by Facebook Inc., 1601 S. California Ave. Palo Alto, CA 94304, USA. As part of these tools, we send advertisements to you on Facebook. We implement this activity based on our legitimate interest in the marketing of our own products or services. You can search for information about the processing of your personal data via Facebook directly in the Facebook privacy policy: https://www.facebook.com/privacy/explanation. You can also manage your privacy settings from your Facebook account.
4. Cookies management
You can change the way cookies are used by your browser, as well as block or delete them. To do this, change your browser settings. Most browsers offer the option of accepting or rejecting all cookies, accepting only certain types, or informing the user every time a website attempts to save them. You can also easily delete cookies that have already been saved on your device. The management of cookies depends on the browser you use. You can find out how to do this for your particular browser by clicking «help» on your browser’s menu. You will find out there how to control and delete cookies step by step.
However, you must know that the lack of permission, deletion, blocking or limiting the placement of cookies may cause difficulties or even prevent the use of Website and Services.
By accepting the Terms and this Privacy Policy, you agree to our use of cookie technology, including third party cookies. Restricting the use of cookies may cause difficulties or even prevent the use of the Website and the Services.
IV. Other
1. Policy changes and updates
Please revisit this page periodically to stay aware of any changes to this Policy, which we may update from time to time. If we modify the Policy, we will make it available through the Service, and indicate the date of the latest revision, and will comply with applicable law. Your continued use of the Service after the revised Policy has become effective indicates that you have read, understood and agreed to the current version of the Policy.
2. Supplier’s contact details
Please contact us with any questions or comments about this Policy, your personal data, our use and disclosure practices, and your consent choices.
company registration data:
company name: Witbee spółka z ograniczoną odpowiedzialnością z siedzibą w Warszawie,
address: ul. Ordynacka 9 lok. 33, 00-364 Warszawa,
registry court: Sąd Rejonowy dla m.st. Warszawy w Warszawie – XII Wydział Gospodarczy Krajowego Rejestru Sądowego,
KRS number (registry number): 0000623475,
NIP (tax identification number): 5252662720,
REGON: 364731210,
share capital: 30.000,00 PLN
contact details:
You can contact us:
• in writing, addressing correspondence to: WitBee sp. z o.o. z siedzibą w Warszawie, address: ul. Ordynacka 9/33, 00-364 Warsaw,
• by e-mail, to the address: info@witbee.com and in a different way indicated on the website www.witbee.com