The policy, as amended below, is effective as of 24/03/2023.
| Privacy Policy and Cookies Policy
Good morning!
If you have ended up here, it is a reliable sign that you value your privacy. I understand this perfectly, so I am putting in your hands a document in which you will find in one place the rules for processing personal data and the use of cookies and other tracking technologies.
Formal information at the beginning: I am the administrator of your personal data - Damian Krawczyk, running a non-registered business, ul. Św. Jana 11/4, 40-012 Katowice, Poland.
I process your personal data primarily for purposes related to your use of my website and social media. These are purposes such as newsletter handling, comment handling, social media handling, message exchange, analysis, statistics, marketing, etc.
I will process your personal data for the period of time necessary for the respective purposes. You have the right to access, correct, delete or restrict processing of your personal data, to object to processing, as well as the right to data portability. In addition, you may file a complaint with the President of the Office for Personal Data Protection.
For detailed information on the principles of processing your personal data, please see the following Privacy Policy.
Table of contents
Suppose you have any concerns about the Privacy Policy. In that case, you can contact me at any time by sending an email to contact@itincor.com.
| Who is the administrator of personal data?
I am the administrator of your personal data - Damian Krawczyk, running a non-registered business, ul. Św. Jana 11/4, 40-012 Katowice, Poland.
This Privacy Policy applies to the website https://itincor.com.
Regarding my social media profiles, in accordance with the case law of the Court of Justice of the European Union, I am a joint data controller with the provider of the social networks on which I have profiles. You can find details about the processing of personal data by each social media provider here:
| Whom can you contact regarding the processing of personal data?
As part of the implementation of the data protection system, I have decided not to appoint a data protection officer due to the fact that it is not mandatory in my situation.
In matters related to data protection and privacy in the broadest sense, you can contact me by email at contact@itincor.com. In terms of social media, you can additionally contact directly the administrators of the social networks where I maintain my profiles.
| For what purposes do I process personal data?
There is more than one purpose. Below is a list of them, along with a more detailed description. The respective legal grounds for processing are also assigned to each purpose:
| Processing purpose | Description of processing purpose | Legal basis |
|---|---|---|
| Newsletter handling | When signing up for the newsletter, you must provide the data necessary to receive the newsletter specified in the sign-up form. Providing the data is a prerequisite for receiving the newsletter. In addition, the mailing system records your IP number that you used when signing up for the newsletter, determines your approximate location, the mail client you use for email, and tracks your actions taken in connection with messages sent to you. Accordingly, I also have information on which messages you have opened, within which messages you have clicked on links, etc. In the mailing system, I may also define, based on various criteria related to your activities, interests, or other preferences, specific groups or segments of newsletter recipients that influence what kind of messages you receive in the newsletter. The data provided by you in connection with your subscription to the newsletter is used for the purpose of operating the newsletter. My legitimate interest, in this case is the fulfillment of marketing purposes. As for the processing of information that does not come from you but is collected automatically by the mailing system, I rely on this respect on my legitimate interest to analyze the behavior of newsletter subscribers in order to optimize mailing activities. You can unsubscribe from the newsletter at any time by clicking on the dedicated link included in each message sent as part of the newsletter or by simply contacting me. Unsubscribing from the newsletter does not lead to the deletion of your data from the mailing system. The data is archived to determine, investigate, or defend claims related to the newsletter, as well as to ensure that it can be shown that the newsletter activities were conducted per the law. | Art. 6 (1)(f) GDPR |
| Comment handling | To add a comment on my website, you must provide the data necessary for the publication of the comment specified in the form intended for comment / opinion. Providing the data is a condition for publishing the comment. In addition, the comment system records your IP number that you used when submitting a comment. The comment system may be operated by an external provider. In such a situation, the use of the system is subject to the terms and conditions and privacy policy of the third-party provider. For details on third-party tool providers, please see the section on the tools I use. Data is processed for the purpose of publishing a comment, which is my legitimate interest. The comment you add, along with your data made public within the settings, will be visible on the website. You can modify and delete your comment at any time. The deleted comment, along with your data, will be placed in an archive for the purpose of possible determination, investigation or defense of claims related to the comment. | Art. 6 (1) (f) GDPR |
| Contact and mail handling | When you contact me through available means of communication, such as e-mail, social messaging, chat rooms, etc., you naturally provide your personal data contained in the content of your correspondence. Providing your data is a prerequisite for establishing contact. In addition, the communication system records your IP number that you used when sending a message. A third-party provider may operate the communication system (e.g., chat, instant messaging). In such a situation, the use of the system is subject to the third-party provider’s terms and conditions and privacy policy. For details on third-party tool providers, please see the section on the tools I use. Data is processed for the purpose of communication, which is my legitimate interest. Once the communication is completed, the data goes into an archive for the possible establishment, investigation, or defense of claims related to the communication. | Art. 6 (1) (f) GDPR |
| Creating the archive | For the purposes of my business, I may create archives in digital form. The archives include personal data that I have processed in connection with you. The scope of the archives may vary depending on what data has come to me and the scope of the data justified in terms of archiving. In this case, I rely on my legitimate interest in organizing and arranging personal data carriers. | Art. 6 (1) (f) GDPR |
| Defense, determination or prosecution of claims | The use of my website may give rise to certain claims in the future on your side or mine. Accordingly, I am entitled to process personal data for the purpose of defending, determining or investigating claims. As part of this purpose, I may process any personal data that is related to the claim in question, so the scope may vary depending on what the claim is about. In this case, I rely on my legitimate interest to protect my interests. | Art. 6 (1) (f) GDPR |
| Creating groups of advertising recipients | Your e-mail address stored in my database can be sent to a specific advertising system (e.g., Facebook Ads, LinkedIn Ads) in order to create a group of recipients for advertisements using that e-mail address. When using this feature, the e-mail address is hashed before being sent to the specific system to create an audience group. The e-mail address will be used in the matching process conducted by the respective advertising system. The advertising system does not share the e-mail address with third parties or other advertisement providers and deletes the e-mail address immediately after the matching process is completed. The advertising system implements processes and procedures to ensure the confidentiality and security of the e-mail address sent to it and the set of user identifiers forming the audience group created using the e-mail address by, among other things, applying technical and physical safeguards. The creation of an advertising group of recipients using your e-mail address constitutes my legitimate interest, which in this case, is the fulfillment of my marketing objectives. | Art. 6 (1) (f) GDPR |
| Social media handling | If you follow my social media profiles or interact with content I post on social media, I naturally see your data, which is publicly available in your social media profile. I process this data only within the respective social network and only for the purpose of operating the respective social network, which is my legitimate interest. If you contact me via private message, you naturally provide me with your personal data contained in the content of the correspondence, in particular your image and first name and last name. Your data is processed in this case for the purpose of contacting you, and the basis for processing is my legitimate interest. It may happen that I am the party initiating contact with you via social media in order to offer cooperation, in which case your data will be processed for the purpose of seeking potential contractors, offering and establishing cooperation, which is my legitimate interest. Messages sent to me via social media are subject to automatic archiving through tools available within the individual social networks and are available to me until deleted by you. You have access to all messages exchanged with me in the private messages tab. Your use of social media websites is subject to the rules and privacy policies of the administrators of those websites, and those administrators provide electronic services to you entirely independently and autonomously from me. | Art. 6 (1) (f) GDPR |
| Analysis and statistics using only Anonymous Information | I conduct analytical and statistical activities using tools provided by third-party vendors. I only have access to Anonymous Information as part of the analytical tools. The processing of Anonymous Information is based on my legitimate interest, which is to create, view and analyze statistics related to user activity on the website in order to draw conclusions that allow me to optimize my activities afterward. I can only access statistics and information not assigned to specific individuals from the tools. For details on third-party vendor tools, please see the section on the tools I use. | Art. 6 (1) (f) GDPR |
| Self-marketing using only Anonymous Information | I conduct marketing activities using tools provided by third-party vendors. Within the marketing tools, I only have access to Anonymous Information. I rely the processing of Anonymous Information on my legitimate interest, which is to conduct marketing activities based on Anonymous Information and to target advertisements within external systems based on Anonymous Information for the purpose of marketing my products and services. I can only access statistics and information not assigned to specific individuals from the tools. For details on third-party vendor tools, please see the section on the tools I use. | Art. 6 (1) (f) GDPR |
| Provide additional functions using only Anonymous Information | I may embed video or audio players, social widgets, comment module, chat, newsletter forms, or other tools provided by third parties on my website. All of these tools process Anonymous Information. I base the processing of Anonymous Information on my legitimate interest, which in this case is to provide you with the ability to use additional features on the website. I do not have access to other information from within the tools, moreover, I do not need this information for anything - Anonymous Information is processed only for additional functions to work. For details on third-party vendor tools, please see the section on the tools I use. | Art. 6 (1) (f) GDPR |
| Compliance with obligations related to the protection of personal data | As a personal data administrator, I am obligated to comply with data protection obligations. Accordingly, I may process your personal data insofar as necessary to fulfill these obligations (e.g., when processing your request for your personal data). The scope of the data depends on what data is needed to fulfil the obligation and prove compliance with GDPR. In this case, I also rely on my legitimate interest in securing the data necessary to demonstrate accountability. | Art. 6 (1) (c) GDPR, Art. 6 (1) (f) GDPR |
| What information about you do I have?
The scope of the processed data is described for each processing purpose. Information in this regard can be found above in Section 3 of the Privacy Policy. Among the data, there is information such as:
- name,
- e-mail address,
- IP address,
- data collected in the mailing system,
- data related to added comments,
- information visible on social media profiles,
- information contained in correspondence,
- Anonymous Information.
| What is “Anonymous Information”?
I use tools that collect a range of information about you related to your use of my website. This includes, in particular, the following information:
- information about your operating system and web browser,
- subpages viewed,
- time spent on the website,
- switching between individual subpages,
- clicks on individual links,
- mouse movements,
- page scrolls,
- the source from which you go to the website,
- the age range you are in,
- your gender,
- your approximate location limited to town.
- your interests or other preferences determined by your online activity.
This Privacy Policy refers to this information as “Anonymous Information”.
Anonymous Information by itself does not, in my judgment, have the character of personal information, as it does not allow me to identify you and I do not correlate it with the typical personal information I collect about you. Nevertheless, given the strict ruling of the Court of Justice of the European Union and the divided opinions among lawyers, as a precaution, in case Anonymous Information is assigned the character of personal data, detailed explanations are also included in the Privacy Policy regarding the processing of this information.
I am unable to provide you with access to Anonymous Information about you, as I am unable to associate any of the Anonymous Information with any specific user. From the tools that collect Anonymous Information, I only have access to a set of statistics and information not assigned to specific individuals.
The processing of Anonymous Information allows me to provide you with the functionality available on the website. In addition, Anonymous Information is used for analytical and statistical purposes, as well as for marketing purposes, such as setting and targeting advertisements.
Anonymous Information is also processed by tools providers under the terms of their terms of service and privacy policies. These providers may use it to provide and improve services, manage services, develop new services, measure the effectiveness of advertisements, protect against fraud and abuse, and personalize content and ads displayed on individual services, websites, and applications. For details related to this, please see the section on the tools I use.
| How did I get your personal information?
In most cases, you provide them yourself. For example, this is the case when you sign up for newsletters, contact me via e-mail or chat, and use features available on the website or external services (e.g., social media).
In addition, some information about you may be automatically collected by the tools I use. For details on external tools, please see the section on the tools I use.
| Is the data safe?
I take care of the security of your personal data. I have analyzed the risks involved in the various processes of processing your data, and then I have implemented appropriate security and personal data protection measures. I monitor the state of the technical infrastructure on an ongoing basis, look at the procedures in place, and make the necessary improvements.
| How long will I keep personal data?
I process your personal data for as long as it is reasonable within the scope of the given purpose of processing your personal data. Therefore, the processing periods vary depending on the purpose. Please note that the termination of the processing of your data for one purpose does not necessarily lead to the complete deletion or destruction of your personal data, as the same set of data may be processed for another purpose for the period indicated for it. Complete deletion or destruction of data occurs when I have completed all purposes and, in other cases, indicated in GDPR.
Below you will find a description of the processing periods:
- Newsletter – data related to the newsletter will be processed for the period of your use of the newsletter;
- Comments - data related to posting a comment will be processed until you delete the comment;
- Contact and correspondence handling - data related to correspondence handling will be processed for the duration of contact between us;
- Archive - data related to the archive will be processed until the information that is in the archive is no longer useful;
- Determination, investigation, and defense of claims - data related to claims will be processed until the statute of limitations for claims, whereby the period of limitations for claims may vary in light of applicable laws (e.g., for businesses, it may be three years, and for consumers six years);
- Audience groups - data related to audience groups will be processed until they are no longer relevant or you successfully object;
- Social media - in general, I have no control over the retention period of your personal data on social media. They are available on Facebook, Instagram, YouTube, or LinkedIn under the terms of these websites’ rules and privacy policies. I am not able to remove your data from Facebook, Instagram, YouTube, or LinkedIn - only you can do so;
- Analytics and statistics - data related to analytics and statistics will be processed until it is no longer useful or you successfully object;
- Own marketing - data related to own marketing will be processed until it is no longer useful or you successfully object;
- Additional tools - data related to additional tools will be processed until it is no longer useful or you successfully raise an objection;
- Data Protection Obligations - data related to data protection will be processed until it is no longer useful, you have successfully raised an objection or the expiration of the statute of limitations on my liability as a data controller.
In the event that I process your personal data based on your consent, you may withdraw such consent at any time: either by your action or by contacting me at the contact details provided. Please note that the withdrawal of consent does not affect the lawfulness of the processing that was carried out based on consent before its withdrawal.
| Who are the recipients of personal data?
I would venture to say that modern businesses cannot do without third-party services. I also use such services. Some of these services involve the processing of your personal data. Third-party service providers that are involved in the processing of your personal data are:
- hosting provider - for the purpose of storing data on the server;
- mailing system provider - for the purposes of using the mailing system;
- chat provider - for the purposes of contact via chat;
- pop-up display system provider - for the purpose of displaying pop-ups;
- landing page management tool provider - for the purpose of collecting data via landing pages;
- cloud computing provider - for the use of cloud solutions;
- accounting firm - for the purpose of using accounting services;
- law firm - for the purposes of providing me with legal services;
- technical support - for the purpose of carrying out technical work on those areas where data is processed;
- other subcontractors, in particular IT solution providers - for the purposes of working with various subcontractors who may have access to your personal data if they provide services to the extent related to such access.
If the need arises, your data may be shared with a legal advisor or attorney bound by professional secrecy. The need may arise from the necessity of legal assistance requiring access to your personal data.
In addition, if the need arises, your personal data may be shared with entities, authorities, or institutions entitled to access the data under the law, such as police, security services, courts, and prosecutors’ offices.
When it comes to Anonymous Information, access is granted to providers of tools or plug-ins that collect Anonymous Information. The providers of these tools are independent administrators of the data collected within them. They may share this data under the terms and conditions they set out in their own regulations and Privacy Policies, over which I have no control.
| Do I transfer data to third countries or international organizations?
Yes, part of your personal data processing operations may involve transferring them to third countries.
I transfer your personal data to third countries in connection with the use of tools using resources located in third countries, in particular in the USA. The providers of these tools guarantee an adequate level of personal data protection through the relevant compliance mechanisms provided by GDPR, in particular through the use of standard contractual clauses.
Currently, your personal data is transferred to third countries in connection with the use of the following solutions:
| Solution type | Solution provider | Third country |
|---|---|---|
| Comment system | Disqus | USA |
| Data backup | USA |
In addition to the above, Anonymous Information collected concerning the tools indicated in the Appendix to this Privacy Policy may be transferred to third countries, particularly the USA.
| Do I use profiling?
I do not make decisions towards you based exclusively on automated processing, including profiling, that produces legal effects towards you or similarly materially affects you. Yes, I do use tools that I may take certain actions depending on the information collected through tracking mechanisms. However, these actions do not materially affect you, as they do not differentiate your situation as a customer, do not affect the terms of a contract you may enter into, etc.
Using certain tools, I can, for example, target you with personalized advertisements based on previous actions you have taken on the website or suggest products that may interest you. We are talking here about so-called behavioral advertising. I encourage you to learn more about behavioral advertising, particularly with regard to privacy issues. You can find detailed information, including how to manage your behavioral advertising settings, here.
| What are your rights?
GDPR grants you the following potential rights related to the processing of your personal data:
- the right to access your data and to receive a copy of it;
- the right to correction (rectification) of your data;
- the right to erasure (if, in your opinion, there is no basis for me to process your data, you can demand that I erase it);
- the right to restrict the processing of your data (you can request that I restrict the processing of your data only to the storage of your data or the performance of activities agreed with you if, in your opinion, I have incorrect data or I am processing it unfoundedly);
- the right to object to data processing (you have the right to object to processing on the basis of legitimate interests; you should indicate the particular situation that you think justifies me stopping the processing covered by the objection; I will stop processing your data for these purposes unless I can demonstrate that the grounds for my processing override your rights, or that your data are necessary to establish, assert or defend claims);
- the right to data portability (you have the right to receive from me in a structured, commonly used machine-readable format the personal data you have provided under the contract or your consent; you can have this data sent directly to another entity);
- the right to withdraw your consent to the processing of personal data if you have previously given such consent;
- the right to file a complaint with a supervisory authority (if you find that I process your data unlawfully, you may file a complaint to this effect with the President of the Office for Personal Data Protection or other competent lead supervisory authority).
The rules related to the exercise of the rights indicated above are described in detail in Articles 16-21 of GDPR. I encourage you to familiarize yourself with these regulations. As for me, it is necessary to explain to you that the rights indicated above are not absolute, and you will not be entitled to all processing activities of your personal data.
I emphasize that one of the rights indicated above is always available to you: if you consider that I have committed a violation of data protection regulations in the processing of your personal data, you have the opportunity to file a complaint with the lead supervisory authority (President of the Office for Personal Data Protection).
| Do I use cookies and what are they actually?
My website, like almost all other websites, uses cookies.
Cookies are small information text stored on your terminal device (e.g., computer, tablet, smartphone), which can be read by my information and communication system (own cookies) or third-party information and communication systems (third-party cookies). Cookies may record and store certain information, which can be then accessed by information and communication systems for specific purposes.
Some of the cookies I use are deleted when the browser session ends, i.e., when you close it (so-called session cookies). Other cookies are retained on your terminal device and allow your browser to be recognized the next time you visit the website (persistent cookies). If you want to learn more about cookies as such, you can read, for example, this material.
| On what basis do I use cookies?
I use cookies based on your consent, except when cookies are necessary for the proper provision of the electronic service to you.
Cookies that are not necessary for the proper provision of the electronic service to you remain blocked until you consent to the use of cookies. During your first visit to the website, you are shown a message asking for your consent along with the option to manage cookies, i.e., decide which cookies you agree to and which you want to block.
| Can you disable cookies?
Yes, you can manage your cookie settings within your web browser. You can block all or selected cookies. You can block cookies of specific websites. You can also delete previously saved cookies and other websites and plug-ins data anytime.
Web browsers also offer the possibility to use incognito mode. You can use it if you want to avoid information about the websites you have visited and the files you have downloaded being saved in your browsing and download history. Cookies created in incognito mode are deleted when you close all windows in this mode.
Browser plug-ins are also available to control cookies. The option to control cookies may also be provided by additional software.
In addition, there are tools available on the Internet that allow you to control certain types of cookies, in particular to collectively manage behavioral advertising settings.
I also give you the ability to control cookies directly from my website. A special mechanism for managing cookies has been implemented, which allows you to block those cookies you do not wish. Please note that disabling or restricting cookies may prevent you from using some of the features available on the website and cause difficulties in using the website, as well as many other websites that use cookies. For example, if you block cookies of social networking plug-ins, buttons, widgets, and social features implemented on the website may not be available to you.
| For what purposes do I use my own cookies?
Own cookies are used to ensure the proper functioning of the various mechanisms of the website, such as the correct submission of the form visible on the website, handling of newsletter forms, etc. Own cookies also store information about your defined cookie settings made from the cookie management mechanism.
| What third-party cookies are used?
A list of tools that require the use of cookies and a description of the cookies used can be found in the Appendix to this Privacy Policy.
| Do I track your behaviors undertaken within the website?
Yes, I use tools from third-party vendors that involve collecting information about your activities on the website. These tools are described in detail in the Appendix to this Privacy Policy.
| Do I direct targeted advertisements to you?
Yes, I use tools from third-party vendors to target advertisements to specific target groups defined based on various criteria such as age, gender, interests, occupation, job, and activities previously undertaken on the website. These tools are described in detail in the Appendix to this Privacy Policy.
| How can you manage your privacy?
The answer to this question can be found in many places in this Privacy Policy when describing specific tools, behavioral advertising, cookie consent, etc. Nevertheless, I have once again gathered this information in one place for your convenience. Below you will find a list of options for managing your privacy.
- cookie settings within your web browser;
- browser plug-ins that support cookie management;
- additional software that manages cookies;
- incognito mode within your web browser;
- behavioral advertising settings, e.g., youronlinechoices.com;
- a mechanism for managing cookies within my website;
- Google Analytics Opt-out;
- Google Ads Settings;
- Facebook Ads Settings;
- LinkedIn Privacy Settings;
| Is there anything else you should know about?
As you can see, the topics of personal data processing, the use of cookies, and the management of privacy, in general, are pretty complex. I have done my best to ensure that this document provides you with as much knowledge as possible on important issues. If anything is unclear to you, you would like to learn more or discuss your privacy, please email me at contact@itincor.com.
| Is this Privacy Policy subject to change?
Yes, I may modify this Privacy Policy, mainly due to technological changes and changes in the law. If you are a registered user, you will receive a message about any change to the Privacy Policy. Changes to the Privacy Policy become effective after seven days at the earliest. All archived versions of the Privacy Policy are linked below.
| Appendix to Privacy Policy
| LIST OF TOOLS WHICH USE COOKIES
| Tool name | Operation and cookies description |
|---|---|
| Google Tag Manager | I use the Google Tag Manager tool provided by the American company Google LLC, which is used to manage the tags and loading of scripts within the website. Google Tag Manager, as a tool in itself, does not collect any information beyond what is necessary for its proper operation, but it is responsible for loading other scripts described below. |
| Google Analytics | I use the Google Analytics tool provided by the American company Google LLC. In order to use Google Analytics, a special Google Analytics tracking code is implemented in the website’s code. The tracking code uses cookies related to the Google Analytics service. You can block the Google Analytics tracking code anytime by installing a browser add-on provided by Google. Google Analytics automatically collects information about your activity on my website. Within Google Analytics, I only have access to Anonymous Information. Thanks to the information collected this way, I can conduct an analysis of user behavior on my website and keep statistics related to it, and then draw conclusions from these statistics to design solutions to improve the website’s efficiency. If you are interested in the details related to Google’s use of data from websites and applications that use Google services, I encourage you to read this information. |