I. INFORMATION ABOUT THE ADMINISTRATOR OF THE WEBSITE, CONTACT DATA OF THE COMPANY
The administrator of the Website, and thus also of your personal data, is us, i.e. Astra Leads, SL with registered office in C/ Hermosilla, 48 1D, 28001, Madrid, Spain, tax ID ESB16750440 (hereinafter: the Company).
If you have any questions regarding this policy, please contact the Data Protection Officer, who can be contacted via email: dpo@leadsastra.com.
II. SOURCE OF DATA ACQUISITION AND VOLUNTARINESS OF PROVIDING PERSONAL DATA
In connection with the operation of the website, we would like to inform you that we obtain your Personal Data in the form of: having the ability to identify information and contact data in particular in the form of device identifiers – cookies exclusively from you.
In connection with your use of the website’s functions, it is also possible for the Company to process the personal data you have provided in the form of: name, surname, home address, mailing address, telephone number, in connection with your use of the contact form provided on the website.
The administrator, with regard to the personal data collected in connection with the operation of the website, does not obtain your personal data from any other sources. We point out that your provision of the personal data in question is fully voluntary, but necessary, in order to enable you to use the website and its functions. If you do not provide them, it will not be possible to fulfill the above purpose as well as the rest of purposes specified below.
We would like to mention that with regard to personal data processed by the Company in connection with the conduct of its activities other than the functioning of the website, we would like to explain that you will find the details of personal data processing in a separate document – an information clause.
III. PURPOSES AND GROUNDS FOR PROCESSING PERSONAL DATA
Your personal data is processed in connection with the operation of the website and your use of the website is processed by the Company for the following purposes, and the legal basis for the processing is one or more of the following provisions:
6(1)(a) of the GDPR, i.e. on the basis of your consent, to enable you to use the Company’s website, in particular to enable you to learn more about the details of the programs and campaigns run by the Company;
6(1)(a) GDPR, i.e. on the basis of your consent, in order to enable you to contact the Company via the contact form, including obtaining detailed information on programs and campaigns conducted by the Company, consent – in order to provide your data to our business partners and enable you to participate in initiatives, programs, events, meetings carried out by the Company or its business partners, and to learn about the products and services offered by our business partners, which includes, in particular, telephone contact, and may also include sending you such information to the indicated mailing address, telephone contact or SMS;
6(1)(c) GDPR, i.e. for the purpose of correctly fulfilling the Administrator’s legal obligations, including responding to contact from you, especially with regard to the processing of complaints and requests, as well as answering your questions;
6(1)(f) GDPR, i.e. for the purpose of fulfilling the Administrator’s legitimate interests, including the fulfillment of the Company’s statutory objectives, the execution of concluded agreements, for statistical and training purposes, for the purpose of continuously improving the quality of the campaigns implemented as well as services provided, including through the creation and development of computer programs supporting the Administrator’s operations, including those based on an artificial intelligence system, as well as for the purpose of protecting the Administrator’s rights or those of third parties, including, for the purpose of asserting claims or protecting against them, and for the purpose of marketing of ours or our business partners. The Administrator does not plan further processing of your personal data for any purposes other than those indicated above.
If there is such necessity, the Administrator will inform you of the additional purposes and clarify any doubts and the Administrator will ask your consent in advance for the use of your personal data for the new purpose, to the extent required by law, if such consent is necessary for the processing for the new purpose.
IV. RECIPIENTS OF PERSONAL DATA
We transfer your Personal Data to:
entities or authorities authorized by law to obtain your data from us or to process them, and to entities to which the transfer of data will be necessary to protect the rights of the Administrator or third parties including, to assert claims or protect against them;
our business partners with whom we cooperate in connection with the operation of the website, including content providers, IT and software infrastructure providers, IT service providers related to the operation of the website;
our business partners in connection with activities commissioned by the Company and carried out on our behalf, in particular to the providers of necessary services, including in particular entities providing IT and programming services, entities operating IT systems and devices, entities providing legal, tax, entities providing postal or courier services, in case it is necessary to send you correspondence other than by e-mail, other contractors of the Administrator, to the extent resulting from the execution of the concluded agreement, on the basis of concluded agreements on entrusting the processing of personal data.
If, by filling out the contact form, you consented to the processing of your data for purposes related to the implementation of programs and campaigns carried out by the Company, including the transfer of your data to our business partners in connection with your desire to participate in initiatives, programs, events, meetings or interest in the products and services of our business partners carried out by the Company or its business partners, your data may be transferred to our business partners who are entrepreneurs conducting business in the field of direct sales or telemarketing departments.
V. RIGHT TO THE WITHDRAWAL OF THE CONSENT ON PROCESSING OF PERSONAL DATA AND OTHER RIGHTS
We inform you that you have the right to withdraw your consent on the processing of your personal data at any time. The withdrawal of consent shall not affect the lawfulness of the processing of your data that was carried out on the basis of the consent given before its withdrawal. Your consent is granted indefinitely and is valid until revoked. You may withdraw your consent by contacting the Administrator by means of an email or written statement sent to the Administrator’s data indicated early.
Independently of the abovementioned, you have the following rights:
The right to access your data and to receive a copy of your data – The data subject has the right to receive confirmation from the Administrator as to whether his/her personal data is being processed, and if this is the case, he/she has the right to be informed as to which of his/her personal data and for what purposes it is being processed, and to obtain a copy thereof.
Right to rectification (amendment) of one’s personal data – The data subject has the right to request that the Administrator rectify data concerning him/her that is inaccurate, as well as to supplement it.
Right to erasure of personal data – The data subject has the right to demand from the Administrator the erasure of data concerning him/her, indicating the circumstances justifying it, e.g. personal data are no longer necessary for the performance of the contract for which they were collected, or the data subject has withdrawn consent for processing and there are no other legal grounds for further processing, or the data are processed unlawfully.
Right to restrict processing of personal data – The data subject has the right to request the Administrator to restrict processing of data, e.g. when the Administrator does not need certain data, there are no prerequisites for further processing, as well as when the data subject requests that data operations be stopped or the data not be deleted. Right to object to processing – The data subject has the right to object at any time to the processing of his or her data because of his or her particular situation – in cases where the processing is based on the legitimate interests of the Controller, including profiling.
Right to data portability – The data subject has the right to receive in a structured, commonly used machine-readable format the personal data concerning him/her that he/she has provided to the Controller, and has the right to send this personal data to another Controller. You may exercise your rights using the contact routes indicated previously.
If you have doubts about the correctness of the processing, you have the right to lodge a complaint to the supervisory authority – the President of the Office for Personal Data Protection.
VI. DATA RETENTION PERIOD
The period for which your Personal Data is processed depends on the purpose for which the data is processed. The period for which your Personal Data will be stored is calculated based on the purpose and legal basis for processing:
the validity period of cookies – in accordance with the cookie policy; the period for which you have given your consent or until you withdraw it;
the period for which the Company carries out a given campaign and statutory objectives;
the period for which the Company cooperates with its business partners in direct sales and marketing, in accordance with the agreements concluded and in connection with the consent you have provided;
the period for which computer programs supporting the Administrator’s operations are created and developed, including those based on an artificial intelligence system; legal regulations that may oblige the Administrator to process data for a certain period of time or the need to fulfill the Company’s legal obligations;
the period that is necessary to defend the rights of the Administrator or third parties, including, to assert or protect against the claims.
After the latest of the aforementioned periods, your Personal Data will be permanently deleted by the Administrator.
VII. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
The Administrator of the personal data processed in connection with the functioning of the website and the usage of it by the users processes personal data in most cases on the territory of Poland, due to the realized cooperation with business partners, used software and ICT infrastructure, the Company may transfer your data outside of Poland and outside of the European Economic Area. Regarding this, we would like to point out that we take measures to ensure the security, integrity and inviolability of the transferred personal data by applying various protection mechanisms, in particular by implementing cooperation with such contractors based on standard contractual clauses approved by a decision of the European Commission.
VIII. AUTOMATIC DECISION-MAKING (INCLUDING PROFILING)
Personal data processed in connection with the operation of the website and your use of the website are not profiled by us, nor are any decisions based solely on automated processing of personal data made with respect to you based on such data.
IX. AMENDMENT OF THE DOCUMENT
In order to ensure that this document complies at all times with the current requirements imposed by law, we reserve the right to amend it at any time. If necessary, we will inform you of the changes made.
COOKIE POLICY
I. INFORMATION ABOUT THE ADMINISTRATOR OF THE WEBSITE, CONTACT DATA OF THE COMPANY
The administrator of the Website, and thus also of your personal data, is us, i.e. Astra Leads, SL with registered office in C/ Hermosilla, 48 1D, 28001, Madrid, Spain, tax ID ESB16750440 (hereinafter: the Company).
If you have any questions regarding this policy, please contact the Data Protection Officer, who can be contacted via email: dpo@leadsastra.com.
II. WHAT ARE COOKIES, WHAT ARE THEY USED FOR AND HOW DO WE DIVIDE COOKIES
Cookies are nothing more than small files stored on your device in connection with your visit to our website. These files are sent by the website to your browser and contain identifiers to identify your device. These identifiers are anonymous, but thanks to them we know, for example, that you have returned to our website. Thanks to this, we are able to customize the website selected to your previous preferences and to confirm/continue your previous actions. These files are saved for a certain period of time, after which they expire and are deleted.
Cookies, despite their assigned anonymous identifier, are treated as personal data. We inform you about the details of the processing of personal data in a separate document – privacy policy, there, you can read the rules on our handling of data and get information about your rights.
We can distinguish several types of the Cookies:
Session cookies – these are information stored in the browser’s memory until closing it. These files are used for the proper functioning of the website and some of its functions. Navigating the website may be difficult or impossible without such files.
Persistent cookies – these are cookies that are largely responsible for your early-selected display preferences, such as screen resolution or format and location of content displayed, they are also stored in connection with your choices made on the website. These cookies remain in your browser’s memory for an extended period of time – mainly for your convenience in navigating the website.
Proprietary cookies – These cookies are used to improve your use of the Portal and are saved by the website you are currently viewing.
Third-party cookies – These cookies are used by entities external to the Website Administrator, such as social networks, to track your visits to various websites, where they post advertisements, among other things.
Cookies can also be divided into certain categories:
Necessary/unnecessary cookies – a category of cookies, without which the website will not function properly and navigating through it will not be possible. Here we point out that the processing of these cookies takes place in connection with the legitimate interest of the Administrator, i.e. on the basis of Article 6(f) of the GDPR. Of course, you have the opportunity to object to our processing of such data, however, in practice this will entail preventing you from using the website.
Performance cookies – are responsible for optimizing the operation of the website, thanks to the information they collect, such as which subpages you use most often, we can improve and speed up the operation of the website and improve your experience of using it. At the moment, the Company’s website does not use this type of cookies, if we start using this type of cookies they will be processed only after obtaining your consent (i.e. under Article 6(a) of the GDPR) expressed by clicking the checkbox in the visible banner or selecting the button to accept all cookies. You can withdraw your consent at any time.
Functional cookies – cookies responsible for improving the user experience of the website including personalizing the view and recording actions taken on the website. At the moment, the Company’s website does not use this type of cookies, if we start using this type of cookies they will be processed only after obtaining your consent (i.e. on the basis of Article 6(a) GDPR) expressed by clicking the checkbox in the visible banner or selecting the button to accept all cookies. You may withdraw your consent at any time.
III. TIME OF STORING THE COOKIES
Depending on the type of cookies, they are stored for different periods of time. Session cookies are stored on your device until you close your browser, while permanent cookies are stored on your device for a maximum of 12 months.
IV. COOKIES MANAGEMENT
You can decide on the rules of collecting cookies on your device by selecting the appropriate settings in your web browser. We point out that blocking some cookies may be associated with the unavailability of some website functions or prevent you from navigating the website. There are different ways to configure browsers, so please refer to the “Help” section of the browser you are using to learn how to configure it and use the available options. You will also find information on how to configure the collection of cookies on the websites of your browser’s providers, including at the following addresses:
Google Chrome: https://support.google.com/chrome/answer/95647?hl=pl
Mozilla Firefox: https://support.mozilla.org/pl/kb/usuwanie-ciasteczek-i-danych-stron-firefox?redirectslug=usuwanie-ciasteczek&redirectlocale=pl
Microsoft Edge: https://support.microsoft.com/pl-pl/microsoft-edge/usuwanie-plik%C3%B3w-cookie-w-przegl%C4%85darce-microsoft-edge-63947406-40ac-c3b8-57b9-2a946a29ae09
V. CHANGES OF THE COOKIE POLICY
In order to ensure that this Cookie Policy meets the current requirements imposed by law at all times, we reserve the right to make changes to it at any time. If necessary, we will inform you of the changes prior to their implementation.
We would like to remind you that you can always get more information regarding the Cookie Policy by contacting the Company via e-mail: dpo@leadsastra.com.