Privacy and Cookies Policy

1. General information

This Privacy and Cookies Policy (hereinafter referred to as the„Policy”) contains information about the processing of data collected when using the website www.socialresponsible.tech (hereinafter referred to as the„Website”or the „Site”).

When you use the website, various personal data are collected. Personal data are all those data from which your person can be identified. The policy explains what data we collect, what we use it for and how it is used.

Use of the site implies acceptance of the following terms of the Policy.

2. Information about the data controller

The data administrator responsible for the processing of data through the site is SOCIAL RESPONSIBLE TECHNOLOGIES SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ with its registered office in Nysa, 10 Tadeusza Kościuszki Street, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court in Opole VIII Economic Division of the National Court Register under KRS No. 0000897994, NIP 7532460094, REGON 388823643, (hereinafter referred to as the „Administrator”).

Contact with the Administrator is possible through:

mailing address,
email address: [email protected].

3. Principles of personal data processing

The User’s personal data on the website is processed in accordance with the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27.04.2016 on the protection of natural persons in relation to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (hereinafter referred to as „RODO”) and other legal provisions in force for the duration of data processing.

The controller shall take special care to protect the interests of data subjects, and in particular shall ensure that the data it collects are:

processed lawfully, fairly and transparently to the data subject;
collected for specific, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes;
adequate, relevant and limited to what is necessary for the purposes for which they are processed;
correct and updated as necessary;
kept in a form that allows identification of the data subject for no longer than necessary for the purposes for which the data are processed;
processed in a manner that ensures adequate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, by means of appropriate technical or organizational measures.

4. Data collection through the website

USE OF THE WEBSITE

Personal data of all persons using the Website, hereinafter referred to as „User” (including IP address or other identifiers and information collected through cookies or other similar technologies) are processed by the Administrator for purposes:

Providing services electronically in terms of providing users with access to content collected on the website (legal basis: Article 6(1)(b) of the RODO – the necessity of processing for the performance of the contract),
analytical and statistical purposes (legal basis: Article 6(1)(f) RODO – the Administrator’s legitimate interest in conducting analyses of the activity of people using the site, as well as their preferences in order to improve the functionality of the site and the services provided),
technical, administrative, ensuring the security of the information system and management of the information system (legal basis: Article 6(1)(f) RODO – the Administrator’s legitimate interest),
possible establishment and investigation of claims or defense against claims (legal basis: Article 6(1)(f) RODO – the Administrator’s legitimate interest in protecting its rights),
marketing of the Administrator and other entities, in particular related to the presentation of behavioral advertising – the principles of processing personal data for marketing purposes are described below under MARKETING.

CONTACT THROUGH FORMS

Use of the electronic contact form on the site requires the provision of personal data necessary to make contact and respond to the message content sent. Provision of data is voluntary but necessary in order to send and handle the message.

Personal data is processed, as the case may be, for the purpose of:

contact aimed at concluding a contract or in connection with a concluded contract (legal basis from Article 6(1)(b) of the DPA – necessity of processing to perform a contract or to take action before concluding a contract),
Identification of the sender and handling of his/her messages (legal basis Article 6(1)(f) RODO – legitimate interest of the Administrator),
proper customer service, including answering questions directed to the Administrator (legal basis Article 6(1)(f) RODO – the Administrator’s legitimate interest).

MARKETING

The Administrator processes Users’ Personal Data to carry out marketing activities, which may consist of:

Displaying marketing information to the User that is not tailored to the User’s preferences, so- called contextual advertising (legal basis: Article 6(1)(f) RODO – realization of the Administrator’s legitimate interest),
displaying to the User marketing information corresponding to the User’s interests, the so-called behavioral advertising (legal basis: Article 6(1)(f) RODO – realization of the Administrator’s legitimate interest. The User will not be subject to a decision that is based solely on automated data processing),
Sending e-mails to the User by the Administrator on its own behalf or on behalf of the Administrator’s business partners about oﬀers or information, which may include commercial information as part of a newsletter (legal basis: Article 6(1)(a) of the RODO – the User’s consent in connection with the Act on Provision of Electronic Services and the Telecommunications Law – consent),
use of Meta’s Pixel tool in order to target the User with personalized advertisements in terms of the User’s behavior on the website legal basis: Article 6(1)(a) RODO – User’s consent)
processing of personal data of Users who use the Administrator’s profiles in social media, in particular profiles in the Facebook and Instagram platform, including groups in Facebook, personal data will be processed in order to administer the profiles, communicate with Users, including interacting with them, answering their questions, informing them about: products oﬀered, events, promotions (legal basis: Article 6(1)(a) RODO – the User’s consent expressed by voluntarily liking, observing or subscribing to the Administrator’s profile in social media, interacting, commenting on posts, as well as voluntarily joining the User’s group), the User may withdraw consent at any time by ceasing to observe or blocking the Administrator’s profiles or groups in social media
other activities related to direct marketing of its services and products, among others, by means of sending commercial information by electronic means and telemarketing (legal basis: Article 6(1)(f) RODO – realization of the Administrator’s legitimate interest) in connection with the Act on providing services by electronic means and/or the Telecommunications Law – consent.

SOCIAL NETWORKS

The Administrator may process personal data of Users visiting the Administrator’s social media profiles, in particular YouTube, Facebook, Instagram, Twitter, LinkedIn, Google+. This data is processed in connection with the running of the profile, including for the purpose of promoting the Administrator’s activities and informing about its activities (legal basis: Article 6(1)(f) RODO – realization of the Administrator’s legitimate interest in promoting its own activities).

The Administrator, as part of its activities, may process the User’s personal data as part of remarketing on the social network Facebook. This process consists of:

promotion of the Administrator’s services/products directed to Users who are subscribed to the newsletter or who have given a diﬀerent kind of consent for commercial contact, in such a way that the given Users’ e-mail addresses are uploaded to the marketing tool oﬀered by Meta Platforms Ireland Limited (Facebook and Instagram), the so-called advertising manager, and then advertising created by the Administrator or the Administrator’s partners is directed to them, through the Administrator’s advertising account, provided that the Users are also users of the Facebook platform (they have an account set up there).

promotion of services/products directed to persons other than Users subscribed to the newsletter or who have given a diﬀerent kind of consent for commercial contact, in such a way that the given Users’ e-mail addresses are uploaded to the marketing tool oﬀered by Meta Platforms Ireland Limited (Facebook and Instagram), the so-called advertising manager, and then on their basis Meta creates a group of similar users to whom advertising created by the Administrator or the Administrator’s partners is directed, through the Administrator’s advertising account, provided that the aforementioned persons are also users of the Facebook platform (they have an account set up there).

Each time the data is deleted after the advertising campaign is completed. In the case of implementation of the next advertising campaign, the updated subscriber base is uploaded to the tool). Detailed information about the so-called non-standard groups of recipients, the rules of data hashing and data processing can be found in the privacy policy of Facebook, in particular at the following links: https://www.facebook.com/legal/terms/customaudience# and https://www.facebook.com/legal/terms/dataprocessing , and the Administrator recommends that each User and subscriber familiarize themselves with these rules.

COOKIES

Cookies and other tracking mechanisms may be used when using the site.

Cookies are IT data, in particular text files, which are stored on the User’s terminal device and are intended for the use of the website. Cookies usually contain the name of the website from which they come, the time they are stored on the end device and a unique number.

During the User’s first visit to the site, a message about the use of cookies is displayed, along with a question about consent to the use of cookies or consent to the use of selected cookies. By clicking on the „I agree”, „Consent”, „Agree” or equivalent button, the User consents to the use of cookies or selected cookies in accordance with this Privacy Policy. The User has the option to later disable cookies, despite the consent given, according to the settings of the browser used by the User. The User may refuse to consent to the use of cookies- by clicking on the „I do not consent”, „I do not agree” or equivalent button. In this situation, only proprietary cookies that are necessary for the proper functioning of the website will be used.

Each User has the ability to configure his/her Internet browser in such a way as to prevent the storage of cookies, according to the rules described under „managing cookie settings”below. The Administrator stipulates that this may impede the proper functioning of the website. The user may also use the incognito mode oﬀered by web browsers. In this case, cookies will be deleted when the browser is closed.

Cookies are used on the terms described in this Privacy Policy, and in particular for the following purpose:

to recognize the device used by the User for the purpose of displaying the content of the website accordingly,
Creating statistics that help to understand how Users use the site so that its content can be improved,
Maintain the User’s session on the site, so that the User does not have to re-enter data on each sub-page,
to customize the content and operation of the website by matching an anonymous, randomly generated tracking identifier, which makes it possible, among other things, to see where the user came from, what search engine he or she used, what link he or she clicked on, what keywords he or she typed in, and at what point he or she stopped using the website,
collection of general and anonymous data for the implementation of advertising campaigns through remarketing lists, allowing the display of advertising content tailored to preferences.

Analytical and marketing tools used by the Administrator’s Partners

Google Analytics

The information collected automatically during the user’s visit to the website is analyzed using the Google Analytics 4 tool provided by Google LLC to generate statistics and their analysis for the purpose of optimizing the website. The information is collected automatically, its generation is done by cookies on the use of the website (including anonymized IP address) will be transmitted and stored by Google on servers in the United States. The administrator informs that he has activated the function of IP address anonymization. This involves truncating IP addresses before passing them on, whereby in exceptional cases it may only be truncated on Google’s servers in the United States, noting that the IP address is not, as a rule, combined with other User data on Google’s website assigned to the User’s account. As part of the use of Google Analytics, the Administrator does not collect any data that allows the Administrator to identify the User. The data that the Administrator accesses include, among others: information about the web browser used by the User, the operating system uploaded to the User’s device, the use of subpages on the website, and data about the time spent on the website, including on subpages of the website, as well as information about the source from which the User entered the website. In using Google Analytics, the Administrator also uses advertising tools such as remarketing, demographic and interest reports, ad reporting, user-ID. The information the Administrator can access includes the age range of Users using the website, gender, approximate location (town without specific geolocation data), User interests as determined by Google based on the User’s online activity. The Administrator has implemented Google Analytics tracking code in the code of the website. The User can block the tracking code mentioned in the sentence above at any time by installing a dedicated Google plug-in available at the following link: https://tools.google.com/dlpage/gaoptout (Available for Google Chrome, Mozilla Firefox, Apple Safari and Microsof t Edge browsers) Detailed rules regarding Google Analytics privacy policy (including information on how to block data collection) can be found at: https://support.google.com/analytics/ answer/6004245?hl=pl

Facebook Pixel

The website uses the Facebook Pixel marketing tool provided by Facebook Inc. In order to target personalized Facebook ads to the User, the Administrator uses the Facebook Pixel tool, which collects information about the Client’s behavior on the website in an automated manner and displays Facebook ads on this basis. The information collected by the aforementioned tool does not allow the Administrator to identify the user, but it may be used directly by Facebook in the form of combining it with other information collected by Facebook and used for marketing purposes. Each user can, from the cookie settings available on the website, agree or disagree to the use of Facebook Pixels in their case. Information collected in this way will be transmitted to and stored by Facebook Inc. on servers in the United States. Detailed rules regarding Facebook’s privacy policy (including information on how you can block Facebook’s data collection) can be found at: https:// www.facebook.com/privacy/explanation.

Google Ads

The website has Google Ads service codes plugged in, which are used to create remarketing lists for the purpose of tailoring individualized ads on Google’s advertising network. The aforementioned advertising tool allows the Administrator to promote the website in search results and on third-party websites. Based on cookies and remarketing tags, advertisements are displayed on the basis of the User’s interests based on previously visited websites. Further processing of data for this purpose takes place if the User has given Google permission to use information from the individual Google account to personalize advertisements. In the

aforementioned situation, if the User is logged in when using a website on Google, Google uses the User’s data in combination with data from Google Analytics to create target groups used for remarketing on diﬀerent devices. At any time, it is possible to deactivate the display of ads in this way and the cookies used for remarketing through the Ads Preference Manager https://adssettings.google.com/authenticated. In addition, the User has the option to disable marketing cookies from the website.

For more information about Google Ads, please see Google’s privacy policy at: https://support.google.com/ adspolicy/answer/54817?hl=pl

Managing your cookie settings

You can set your browser so that cookies are not retained on your device, and that you are asked for permission each time before activating cookies. You can also delete cookies that have been reactivated at any time.

For more detailed information, please follow the links below:

Internet Explorer: https://support.microsoft.com/pl-pl/help/17442/windows-internet-explorer- delete-manage-cookies
Microsoft Edge: https://support.microsoft.com/pl-pl/help/4027947/microsoft-edge-delete- cookies
Mozilla Firefox: https://support.mozilla.org/pl/kb/ciasteczka
Google Chrome: https://support.google.com/chrome/answer/95647?hl=pl
Opera: https://help.opera.com/pl/latest/web-preferences/#cookies
Safari: https://support.apple.com/pl-pl/guide/safari/sfri11471/mac

or by using the ” Help” function in your browser.

Please note that deactivation of Cookies may lead to limitations of functionality on our website.

5. Storage period of personal data

The period of data processing by the Administrator depends on the type of service or product oﬀered and the purpose of processing. As a rule, data are processed for the duration of providing the service or fulfilling the order, until the withdrawal of the consent given or the filing of an eﬀective objection to data processing.

The processing time may be extended if the processing is necessary for the establishment and investigation of claims or defense against claims. After the expiration of the processing period, the data are irreversibly deleted or anonymized.

Users’ data will be stored for the following period:

data related to the execution of orders for services and products – for a period of 5 years from the end of the year in which the sale was made, unless further storage is justified by the statute of limitations for claims,
personal data obtained by the Administrator on the basis of consent – until the withdrawal of consent, unless further storage is justified by the statute of limitations for claims
data related to the implementation of marketing activities – until you object, unless further storage is justified by the statute of limitations for claims,
data related to responding to an inquiry – until the withdrawal of the granted consent, unless further data storage is justified by an overriding interest of the Administrator, such as defense against possible claims,
data related to the execution of a complaint or withdrawal from the contract – for a period of 5 years from the end of the year in which the complaint was handled or the contract was withdrawn, unless further storage is justified by the statute of limitations on claims
running the newsletter service-until you unsubscribe from the newsletter, unless further storage is justified by the statute of limitations on claims,
Keeping statistics – until an objection is raised,
Establish, assert or defend against claims – for the period necessary for this purpose,
archival purposes – for the period necessary for this purpose.

6. Data recipients

In connection with the implementation of services, personal data will be disclosed to external entities, including in particular suppliers responsible for the operation of ICT systems, entities such as banks and payment operators, accounting service providers, couriers (in connection with the implementation of the order), marketing agencies (for marketing services).

The Administrator entrusts the processing of personal data in particular to the following entities such as:

Google Inc with its registered office at: 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States – to use the features of the web analytics service provided by Google
Meta Platforms Ireland Ltd. based in Ireland and Meta Platforms, Inc. based in the United States, for the Administrator’s use of Meta Platforms’ advertising tools (Facebook and Instagram) in the use of the Custom Audience Group tools, as well as when measuring the eﬀectiveness and reach of advertising campaigns and returning statistics on who has viewed and acted upon the ads.

Recipients of selected personal data may also be authorities or third parties who will have a legal basis for obtaining them in accordance with the provisions of applicable law.

7. Co-administration

In connection with the use of the social media user targeting process to determine the target customer group that will be most interested in the advertised product, there may be situations in which the targeting entity together with the social media provider, i.e. Meta Platforms Ireland Ltd. based in Ireland and Meta Platforms, Inc. based in the United States, will be joint controllers of personal data.

Co-administration will take place especially in the situation:

Primary targeting involving a group of target users to be determined on the basis of available targeting criteria related to those users in order to reach an audience likely to be interested in advertising and provide them with more relevant advertising content – with respect to the processing of personal data resulting from the selection of appropriate targeting criteria and the display of advertising to the target group, and the processing of personal data by the social media provider to inform the targeting entity of the results of the targeting campaign;
Pixel targeting – with respect to the collection of personal data and its transmission through pixels, as well as with respect to the matching and subsequent display of advertising to the social media user, and with respect to any provision of information related to the targeting campaign.

8. Links to other sites

The Website may contain links to other sites outside the control of the Administrator and not covered by this Policy. If you access such sites through the links provided, the operators of those sites may collect information used later in accordance with their privacy policies, which may diﬀer from this Policy. Such external sites have their own privacy policies, and the Administrator is not responsible in connection with such policies.

9. Transfer of data outside the European Economic Area (EOG)

The Administrator, in the course of its business, cooperates with technology companies – Meta Platforms Ireland Ltd, Google Ireland Limited, conducting business of an international nature, whose headquarters or branches are located in the EEA, but due to the nature of their activities, there may be transfers of Users’ personal data to third countries. The Administrator itself may transfer personal data outside the EEA only when necessary, and guarantees an adequate degree of protection, primarily by:

Cooperation with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the determination of ensuring an adequate level of protection of Personal Data;
Use of standard contractual clauses issued by the European Commission;
application of binding corporate rules approved by the relevant supervisory authority.

Users’ personal data may be transferred to third countries in accordance with the regulations and privacy policies of Meta (Facebook and Instagram) and Google, for more information see the links:

Google – https://policies.google.com/privacy/frameworks?hl=pl

Facebook and Instagram https://www.facebook.com/privacy/policy/? entry_point=data_policy_redirect&entry=0

10. Rights of the person whose data is processed

Each person whose data is processed, within the limits of the law, has the right to access the content of their personal data and the right to rectify, delete, limit processing, the right to data portability, the right to object. Each User whose personal data is processed on the basis of expressed consent has the right to withdraw consent at any time without aﬀecting the legality of the processing performed on the basis of consent before its withdrawal.

Any person whose data is processed also has the right to lodge a complaint with the President of the Office for Personal Data Protection (PUODO) if he/she considers that the processing of personal data concerning that person violates the provisions of the RODO.

11. Automated decision-making including profiling

The Administrator may subject Users’ personal data, including, newsletter subscribers and Customers, to ongoing analysis in order for the Administrator to determine Users’ preferences, which will serve to accurately determine Users’ preferences and allow for the best matching of content on the website and on the Administrator’s social media profiles to potential recipients, as well as targeting Users with individualized advertising messages and e-mails. In addition, the activity of Users using the Administrator’s Facebook and Instagram profiles may be analyzed in an automated manner through tools provided by Meta. In addition, the aforementioned analysis will be performed by service providers, including Meta, and Google. The Administrator emphasizes that the aforementioned automated processing will not have any legal eﬀect on Users, or similarly significantly aﬀect the situation, rights or freedoms of Users. Users may object to profiling at any time.

12. Policy change

Periodically, we may update this Policy. When we do, the changes will be posted on the website. If you do not agree with the changes, you should stop using the website.