Privacy Policy

Last update: 09-11-2020

PRIVACY POLICY

1.   GENERAL

1.1.  The Controller of your personal data is Virbe sp. z o.o. with its seat in Lublin, address: ul. Tomasza Zana 11A, 20-601 Lublin, entered into the register of business entities of the National Court Register maintained by the District Court for Lublin-Wschód in Lublin with its seat in Świdnik, VI Commercial Department of the National Court Register under the number KRS 0000780459, NIP: 9462687906, REGON: 383015364, share capital: PLN 6,000 ("Virbe", "we", "us"). You can contact us at: [email protected].

1.2.  This Privacy Policy sets out the principles regarding processing your personal data that we collect from you or that you provide us by navigating and using this website (the "Website"). Please read it carefully in order to understand our approach to processing personal data.

1.3.  We process your personal data in accordance with applicable laws, including the General Data Protection Regulation (EU) 2016/679 ("GDPR").

1.4.  Website uses various types of cookie files. More information can be found in our Cookie Policy.

2.   COLLECTION OF INFORMATION

2.1.  We collect information about you when you use our website, including when you decide to contact us or sign up for our newsletter. We use this information in order to provide you with the information you request or to answer your questions. It is voluntary to provide us with your data, however, depending on the situation we may not be able to address your request if you refuse to give us your personal data.

2.2.  The information we collect falls into three categories:

2.2.1. information you provide us. You may provide us your data by completing the contact form on the Website, signing up for our newsletter, talking to our virtual being through text or voice on our Website, contacting us otherwise (for example by social media or via an email);

2.2.2. information we collect through automated methods: IP address, geo information (estimated location: country, city), age, used web browser (name & version).

2.2.3. information we collect from other sources which we may in some cases need.

2.3.  We may collect the following information:

2.3.1.  when you sign up for a newsletter: name and e-mail address;

2.3.2.  when you contact us via a contact form: name and e-mail address;

2.3.3.  when you chat to our virtual being on the Website through web plugin: name and e-mail address or any other information you willingly provide;

2.3.4. when you browse the Website: IP address, geo information (estimated location: country, city), age, used web browser (name & version).

2.4.  We shall not purposely collect personal data of minors under 18 years old. If we become aware that a minor has provided any information, we will immediately remove this information.

3.   PURPOSES OF DATA PROCESSING

3.1.  We collect and use your personal data for various reasons, including:

3.1.1. to be able to address your requests and contact you if you ask us to;

3.1.2.  for statistical purposes, 

3.1.3. to administer the Website (for example fix the bugs or run tests);

3.1.4. upon your consent for direct marketing purposes;

3.1.5. other purposes upon your consent.

4.   LEGAL BASIS FOR DATA PROCESSING

4.1.  Our legitimate interests. We have the right to process personal data if processing is necessary for the purposes of our legitimate interests, provided that it is not overridden by the interests or fundamental rights and freedoms of the data subject. We identify that we have legitimate interests to process your personal data in the following cases:

4.1.1.  where the purpose for data processing is better understanding of the persons visiting the Website;

4.1.2. where the purpose is to ensure proper functioning of the Website;

4.1.3. where the purpose is to maintain the security of our Website;

4.2.  Your consent. We have the right to process your personal data where you give us your consent to do so (for example for direct marketing purposes). In order to be valid, your consent must be freely given and informed. You have the right to withdraw your consent at any time. Detailed information can be found in point 8.2.

4.3.  Performance of a contract. We have the right to process your personal data where it is necessary for the performance of a contract to which you are a party or in order to take steps at your request prior to entering into the contract. For example we may process your e-mail address in order to answer your inquiry.

4.4.  Legal obligations. In some cases we may have obligations resulting from the provisions of the applicable laws, according to which we are entitled to process your personal data in order to fulfill those obligations.

5.   DATA RECIPIENTS

5.1.  We may transfer your personal data to the third parties in particular circumstances, namely:

5.1.1. we may disclose your personal data to the entities who provide services to us such as for example website support services, hosting services and other IT services. We forbid those third parties to use personal data or to disclose them for any purposes other than for provision of services on our behalf. We share with third parties only information that is necessary for them to perform the services for us;

5.1.2. in exceptional cases, we may disclose your personal data to third parties, if there is a statutory obligation to do so, or if we are obliged by a decision / order of a judicial or other competent authority;

5.1.3. if Virbe undergoes a corporate reorganization which will result in, for example, a merger with another company, we may transfer personal data to the owners of such a company or to potential other party of such a transaction (we will inform you about such transfer and make all efforts to duly protect your personal data).

5.2.  Personal Data may be transferred outside the European Economic Area only if it is in accordance with applicable data protection laws and under the appropriate safeguards, such as for example data processing agreement concluded with a third party containing Standard Contractual Clauses in case of the recipients in jurisdictions where there are no appropriate data protections laws.

5.3.  Users can ask for a copy of the appropriate safeguard by contacting us at [email protected].

6.   RETENTION PERIODS:

6.1.  We will store your personal data only for as long as it is necessary for the purposes we collect them for. We will store your personal data longer only if we are entitled to do so upon the applicable laws or other regulations (for example for tax purposes).

6.2.  Once we no longer have to store your personal data, we will remove them from our systems.

7.   DATA SECURITY

7.1.  We do our best to protect your personal data. In particular we use appropriate security and technical measures in accordance with the GDPR in order to prevent the data from unauthorized access or disclosure. However, please note that we cannot guarantee the safety of personal data you choose to send us via the Internet.

7.2.  If you suspect that your data has been improperly used, disclosed or accessed to, please contact us immediately at: [email protected].

8.   YOUR RIGHTS

8.1.  You may exercise certain rights regarding your personal data processed by Virbe. In particular,  under the applicable legislation, you have the right to do the following:

8.1.1. Object to processing of your data. You have the right to object to the processing of your data on grounds relating to your particular situation, if the processing is carried out on a legal basis of the Virbe’s legitimate interest;

8.1.2. Access your data. You have the right to learn if your data are being processed by Virbe, obtain disclosure regarding certain aspects of the processing and obtain a copy of the data undergoing processing;

8.1.3. Verify and seek rectification. You have the right to verify the accuracy of your data and ask for it to be updated or corrected;

8.1.4. Restrict the processing of your data. You have the right, under certain circumstances, to restrict the processing of your data. In this case, we will not process their Data for any purpose other than storing it;

8.1.5. Have your personal data deleted or otherwise removed. You have the right, under certain circumstances, to obtain the erasure of your data from us;

8.1.6. Receive your data and have it transferred to another controller (portability). You have the right to receive your data in a structured, commonly used and machine-readable format and, if technically feasible, to have it transmitted to another controller without any hindrance. This provision is applicable provided that the data are processed by automated means and that the processing is based on your consent, on a contract which you are part of or on pre-contractual obligations thereof.

8.2.  Where your personal data are processed based on your consent, you have the right to withdraw your consent at any time and we will no longer process your personal data. Withdrawals of the consent does not affect the lawfulness of processing based on consent before its withdrawal.

8.3.  If you deem that we process your personal data contrary to applicable laws, you have the right to lodge a complaint to the President of the Personal Data Protection Office (UODO), address: ul. Stawki 2, 00-193 Warsaw, Poland, website: uodo.gov.pl. 

8.4.  If you wish to exercise your rights under the GDPR as described above, withdraw your consent (in cases where your consent is the basis for processing of personal data) or know more about your rights, please contact us at [email protected].

9.   CHANGES TO THE PRIVACY POLICY

9.1.  We may amend this Privacy Policy from time to time. In this case, we will post the amended version here and change the "last updated" date (the effect date of the change) at the top of the Privacy Policy.

9.2.  Please visit the Website in order to obtain up to date information.

10. CONTACT US

10.1.           In case of any questions about this Privacy Policy or if you wish to exercise your rights as a data subject, please contact us at [email protected].