When does this Privacy Policy apply?

The following privacy policy determines how we process personal data and ensure proper execution of the rules resulting from 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, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as “GDPR”). The privacy policy affects the personal data that is processed during and in relation to our activity. We hereby declare that we bring particular attention and care to protecting the privacy of the data we gathered regarding the people they affect, especially those that allow us to identify the person (“personal data”).

Who administers your personal data?

The administrator of your personal data is Social WiFi Sp. z o.o., with its registered office in Warsaw (02-661) at ul. Modra 96, registered by the District Court for the Capital City of Warsaw, 13th Commercial Division of the National Court Register under KRS entry No. 0000459078, with a share capital of PLN 181,350.00 fully paid in, having a Taxpayer’s ID [NIP] 5213645686 and statistical number [Regon] 146583215, (hereinafter referred to as “us” or “Social WiFi”). Our contact email: contact@socialwifi.com

How we gather your personal data?

We gather personal data by various forms of communication, depending on the needs and situations. This can especially take place during:

• Contacting us via email, phone and using the contact form located on our website, as well as by gathering the data used to log into Social WiFi service.
• Any cases concerning you personally as a result of a request put forward by you.
• Any correspondence with you regarding your requests, appeals, questions or concerns presented by you.
• Utilisation of our service by you, including our mobile application.
• Employment applications.

The personal data that allows us to identify or contact a specific person are gathered only when provided willingly. For example, we might gather this data in order to provide services with regards to you or respond to questions or concerns.

Should you not provide personal data, we will usually not be in position to provide the requested service or enter into any business relations. We also gather personal data whenever a specific person enters into talks with us, for example by looking for employment, offering services or by becoming our client or debtor.

Data gathered by using of our website

We gather data through our websites, www.socialwifi.pl and www.socialwifi.com. By utilising the website, we can gather your personal data when you agree to become a part of our mailing list or submit a request through our contact form. Our website gathers generic data, such as Internet Protocol address and the kind of browser the device is using in order to receive access. None of this information is being used in order to identify a specific user. We use them to monitor and improve our IT services. We also utilise cookie files (small files used in order to manage internet sessions in order to browse the internet) which can show us whether your internet device has visited our domain in the past. Many internet browsers allow a degree of control in utilising cookie files. In case they are disabled, some functions of our website might become unavailable.

Whenever you enter into an interaction with us by use of any social media channels, we will gather information regarding this interaction, as well as the social media account and the username which is being used.

More information regarding data gathering and processing through Facebook or Twitter, as well as privacy protection can be found on the sites below:

Data protection/advice regarding Facebook data privacy: http://www.facebook.com/policy.php

Data protection/advice regarding Twitter data privacy: https://twitter.com/privacy

Gathering special data

We do not gather any special data, such as e.g. health status.

Why do we process your data?

We process your personal data exclusively for the reasons they were provided to us and that are directly related to our activity.

The primary reasons for utilising your personal data include:

• marketing of our existing and future services,
• employment and recruiting,
• answering your questions and requests,
• protecting our interests, including any legal disputes.

What is the legal basis of us processing your personal data?

Your personal data, as described above, can be processed according to art. 6 (1)(b)(c) of 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, and repealing Directive 95/46/EC (General Data Protection Regulation).

Who can we transfer your data to?

Your data can be transferred to only three subjects:

• authorised subjects - our employees and coworkers that are required to have access to the data in order to perform their duties,
• processing entities - other subjects we entrust with data processing,
• subjects allowed to process the data on the basis of applicable law, such as judicial bodies or investigative authorities.

Is your data being sent outside of Europe?

We do not send your personal data outside of the European Economic Area (“EEA”) / third countries.

How long are we going to be processing your data?

We keep personal data for the period necessary in order to fulfill the goals specified in our privacy policy, unless a longer period of upkeep is required or allowed by the abiding law. We respect the rules and time frames specified by us in privacy policy. The maximum time frame of data upkeep might differ based on the kind of data we gather and how they are processed.

What are your rights regarding your data?

According to the current legislation you have the right to demand access to your data or demand to have them modified, to add any missing information, to have them removed, to limit its processing, to have them moved or to object to processing your personal data. In situations where the demand is clearly unjustified or excessive, especially regarding its repetitive nature, we are allowed to impose reasonable charges that take into account administrative costs of sharing the information, conducting communication, or undertaking the requested action, as well as to deny the request. If you would like to exercise your rights, contact us at the data provided above. In a situation where data processing violates GDPR rules you are also allowed to file a complaint with the President of Personal Data Protection Office.

If data processing is conducted on the basis of your consent, you are entitled to withdraw your consent, however its withdrawal will not affect law compliance of the processing prior to the withdrawal.

Are you obligated to provide your data?

In most cases you are not obligated to providing us your personal data. In some cases the necessity to provide specific data will result directly from the law, such as the Labour Code.

How do we protect your personal data?

We utilise technical and organisational means in order to protect your personal data against accidental or deliberate loss, damage, or unauthorized access. In case of personal data transfers all data is moved in encrypted form in order to prevent it from being used by third parties. Our security measures are consistently adapted to latest technology.

The rights of the person the data pertains to

Every person to which the data pertains to has the right to control its processing by the person’s administrator, Social WiFi Sp. z o.o., with its registered office in ul. Chmielna 73, 00-801 Warszawa, registered by the District Court for the Capital City of Warsaw, 13th Commercial Division of the National Court Register under KRS entry No. 0000459078, with a share capital of PLN 181,350.00 fully paid in, having a Taxpayer’s ID [NIP] 5213645686 and statistical number [Regon] 146583215, (hereinafter referred to as “us” or “Social WiFi”), and in particular:

The right to access the data

The person whom the data pertains to has the right to receive a confirmation from us regarding whether its data is being processed, receive access to the data and receive information about the reasons for processing, personal data categories, receivers or categories of the receivers to whom the data has been or will be revealed, in particular to receivers in other countries or international organisations. The person also has the right to receive information regarding the planned duration of storing the data whenever possible, the criteria for setting the duration if not possible, the right to request modification, removal or limiting of the data’s processing and to object to its processing, and the right to be informed about the possibility of filing a complaint with the supervisory authority, and in case the personal data has not been acquired from the person who the data pertains to - to receive all available information regarding their source.

The right to modify data

The person whom the data pertains to has the right to request immediate modification of personal data that is incorrect or to fill out incomplete personal data.

The right to remove the data (“the right to be forgotten”)

The person whom the data pertains to has the right to request immediate removal of its personal data in any case where the data is no longer necessary for the purposes it was gathered for, as well as in cases where the person retracted consent to personal data processing, filed an objection to processing its data or the data is being processed illegally.

The right to limit processing

The person whom the data pertains to has the right to order us to limit data processing if the person questions the correctness of the data, the processing is performed illegally, the data is no longer necessary for processing purposes or the person has filed an objection to processing.

The right to transfer data

If data processing occurs on the basis of an agreement or a contract and is automated in nature, the person who the data pertains to has the right to order us to convey the data it provided in a machine-readable format to the person in question.

The right to file an objection

The person whom the data pertains to has the right to file an objection regarding the processing of its personal data at any moment, based on our legally justified affairs. In case of filing such an objection we will not be able to further process your personal data, unless we prove the existence of an important and legally justified basis for processing which would override your affairs, rights and liberties.

The right to withdraw consent

The person who the data pertains to can at any moment withdraw its consent. Withdrawal will not affect law compliance of the processing prior to the withdrawal.

In order to exercise the rights mentioned above you can use the above contact information, the contact form available at socialwifi.com/contact-us/, or send a written message to our company: Social WiFi Sp. z o.o. with headquarters in Warsaw (address: ul. Modra 96, 02-661 Warsaw).