From this document you will learn how and on what basis we process your personal data when you use our univio.com website or when we process your personal data for marketing purposes.

In addition, here you will find detailed information on the processing of data in connection with our recruitment processes, including information on data processing dedicated to persons representing our clients or contact persons.

You will learn, among other things:

• Why we may process your data;
• for what purpose we process them;
• whether you are obliged to provide us with your data;
• how long we keep them;
• Whether there are other recipients of your personal data;
• whether we process your data outside the European Economic Area; and
• whether we process your data by automated means, including profiling.

The first part of the Privacy Policy contains general information that we need to provide to everyone, regardless of the purpose of the data processing.

The second part contains information for the person who uses our univio.com website, familiarising themselves with its content. In it we describe, among other things, the rules on the use of cookies.

The third part contains information for the person who contacts us by telephone, e-mail or through the contact forms available on our website to establish a relationship, including receiving an offer.

The fourth part contains information for the person who agrees to receive commercial information by e-mail (newsletter) or by telephone by ticking the appropriate checkbox on our website or by filling in a form in our Subscription Centre.

The fifth section contains information for the person who uses and communicates with us via our profiles on the social networks LinkedIn, Facebook, Instagram, Twitter or YouTube (referred to as “fanpages”). On our fanpages, we publish and share content, offers or information about interesting events on an ongoing basis.

Part I. General information

Contact details for the controller of your personal data

The administrator of your personal data in the processes described herein is We, i.e. Univio Spółka Akcyjna* with its seat in Wrocław at ul. Strzegomska 2-4, entered in the Register of Entrepreneurs of the National Court Register under KRS number: 0000004330.

We can be contacted at: contact@univio.com

The *Univio consists of the following companies: Univio S.A., Univio International Sp. z o.o., Univio Systems Sp. z o.o. and Global4Net Sp. z o.o.. In principle, the controller of your personal data is Univio S.A., with the understanding that if you are interested in establishing a relationship with another Group entity, the controller will be the agreed entity. Notwithstanding the above, your personal data may be shared with the aforementioned Univio entities on the basis of legitimate legal interest, which is the fulfilment of internal administrative purposes and optimisation of business operations.

Contact details of the Data Protection Officer

The Data Protection Officer at Univio S.A., Univio International Sp. z o.o., Univio Systems Sp. z o.o. and Global4Net sp. z o.o. is Maciej Bednarek.

The Data Protection Officer can be contacted via: iod@univio.com.

Where do we obtain your personal data from?

We generally obtain personal data directly from you. This is particularly the case when you browse the content of our website, send us an e-mail, contact us on the telephone number provided, fill in and submit a contact form.

We also obtain personal data indirectly from you. This is the case when we contact you using the data you have provided on your professional profile on LinkedIn or on other industry-specific services that are used to establish business relationships – in this respect, we only use your basic data to get in touch with you in order to start a business relationship.

What rights do you have in relation to the processing of your personal data?

Below we set out your rights relating to data protection and the fact that we process your data. The rights you have in a specific situation depend on the purpose for which and on what basis we process your personal data.

Right of access to data

You have the right to be informed about the personal data we hold about you. This entitlement applies to all processing of your data.

Right of rectification

You have the right to have the personal data held about you rectified and/or completed without delay. This right applies to all processing of your data.

Right to restrict processing

You have the right to ask us to restrict the processing of your personal data if you question the accuracy of the data held about you, if the processing is carried out without a legal basis, or if you have presented your objection to the processing, or if we no longer need the personal data for the purposes of the processing but you need it to establish, assert or defend your claims.

Right to erasure

You have the right to request the deletion of your personal data held by us, insofar as maintaining the data is not necessary to ensure freedom of expression, freedom of access to information, to comply with a legal obligation, for reasons of public interest, to report or defend against claims or to assert rights under the law.

Right to information

If you have requested the right to rectification, erasure or restriction of processing, we will notify all recipients of your personal data of how to rectify, erase or impose restrictions on the processing of that data, unless this is impossible to carry out or involves a disproportionate effort.

Right to data portability

You have the right to obtain a copy of the data you have provided to us, which will be sent to you or a third party in a structured, standard, machine-readable format. If you request that this data be sent to another data controller, this will be done as long as it is technically possible. This right only applies if we are processing your data on the basis of your consent or in connection with the performance of a contract.

Right to object

If your personal data is processed on the basis of our legitimate legal interest, you have the right to object at any time to further processing. We will consider your request in accordance with the rules under the law.

Right of withdrawal of consent

If your data is processed on the basis of consent, you have the right to withdraw it at any time, with future effect. This will not affect the legality of the data processed to date.You can withdraw your consent by writing to: hr@univio.com or iod@univio.com

Right to lodge a complaint with a supervisory authority

If the processing of your personal data violates data protection legislation or if your data protection rights have been violated in any other way, you may lodge a complaint with a supervisory authority. The supervisory authority with jurisdiction in Poland is the President of the Personal Data Protection Office in Warsaw (ul. Stawki 2). Before you exercise your right to lodge a complaint, we encourage you to contact us first so that we can clarify any doubts for you.

Processing of the request

If you make a request to us to exercise a particular right, we will respond to your request within one month of receiving it. If we need to extend this period, we will inform you of the reasons for the extension.

Your request will be answered at the e-mail address from which you send your request or, in the case of requests made by letter, by ordinary mail to the address you have indicated, unless it is clear from the content of the letter that you wish to receive feedback to your e-mail address (in which case you must provide your e-mail address).

Links to other sites

Where we provide links to websites of entities other than us (e.g. IT Corner, Clutch, social media, external publications), this Privacy Policy does not apply and does not describe how that entity processes your personal data. We encourage you to read the respective privacy policies of the relevant entities located on their websites.

Changes to the privacy policy of univio.com

The privacy policy is subject to periodic review and update as and when reasonably necessary. You can view the changes to date below.

October 2022

We have published a new and expanded version of the univio.com Privacy Policy.

Part II. Data processing as part of the use of univio.com, including cookies

Below we set out for you the principles for the processing of personal data (including your IP address or other identifiers and information collected through cookies or other similar technologies) that apply when you use univio.com by browsing its content.

For what purpose do we process your data?

We process your personal data to provide electronic services in terms of providing you with the content collected on the website, as well as for analytical, marketing and statistical purposes.

On what legal basis do we process your data?

The legal basis for processing your personal data is:

• for the purpose of providing electronic services in terms of making the content collected on our site available to you, in which case the legal basis for the processing is that the processing is necessary for the performance of the contract;
• for the purposes necessary for the proper functioning of our service – on the basis of our legitimate legal interest, we have an interest in taking the actions necessary for the proper functioning of univio.com;
• analytical, statistical, marketing – in which case the legal basis for processing is your consent given by actively ticking it in the Cookiebot panel available on the website.

How long do we process your data?

We will process your personal data for as long as is necessary for the purposes described in this Privacy Policy, with the provison that if the basis for processing is consent, then no longer than the retention period indicated in the Cookiebot panel for the cookie in question, and in any case no longer than the withdrawal of consent.

Who is the recipient of your personal data?

The recipients of your personal data, i.e. external parties who may be involved in the processing of your data, will be our trusted subcontractors – IT service providers for data hosting and business mail services and companies whose statistical, analytical and marketing tools we use. You will find detailed information in this regard later in this Privacy Policy.

Nature of data provision

Your personal data – including your IP address, other identifiers and other information, from the moment you connect to our site, is collected via cookies or other similar technologies where these are of a necessary nature. The IP may indicate the country, city or other geographical area where the device is located; the path of your visit to our site, your browser data. We acquire this data automatically, some of which you can block by blocking cookies in your browser. Other data processing, using non-essential cookies, is entirely voluntary.

Other relevant information

Your data is not processed by us outside the European Economic Area, but please note that the owners of analytics, marketing or preference tools, and Google in particular, may process information about your online activities on servers in the United States. In these cases, for example, Google may combine the information it collects about you with the information you provide using external portals, which may mean that your personal data will be processed outside the European Economic Area. This may take place on terms determined by the owners of these tools.

What rights do you have?

Your rights are indicated in Part I of this Privacy Policy.

What are cookies and similar technologies?

A cookie is a text file stored by a web server on a computer or mobile device. Its content can only be retrieved and read by the server that created the file. Cookies are unique to the browser or mobile application being used. The content of a cookie often consists of identifiers, website names and sequences of numbers and letters.

Necessary cookies

What are essential cookies and can they be rejected?

These cookies are necessary for the operation of the website and cannot be disabled without affecting the use of this website. These cookies are usually only placed in response to a specific action you take on the site. We use these cookies because we believe that it is in our and our users’ legitimate interests to enable this service to function properly.

Why do we use essential cookies?

We normally use these files to perform a specific function of the website, e.g. to remember your acceptance of the content of the Privacy Policy.

What data is collected and used by essential cookies?

Necessary cookies do not collect or use personal data.

How long do we keep this data?

Necessary cookies are usually session cookies, which only store data for the duration of the user’s visit to the site, but if the cookie supports the function to remember your acceptance of the Privacy Policy, the data is stored longer to remember you on subsequent visits.

Other cookies

We also use advertising, preference and analytics cookies to make our marketing activities more effective.

You can find all the up-to-date information about the cookies we use in the Cookie Settings panel visible at the bottom left of the website (the paperclip symbol).

How can I change my cookie settings?

You can find out more about how to manage cookies in the different browsers here:

• Google Chrome
• Microsoft Edge
• Mozilla Firefox
• Microsoft Internet Explorer
• Opera
• Apple Safari

Consent to the collection and collection of personal data can be withdrawn at any time with effect for the future, for example using the Google Analytics Opt-Out tool.

In order to prevent the data, generated by the cookie, relating to your use of the website (including your IP address) from being transmitted to Google and processed by Google, it is sufficient to download and install the blocking plug-ins available at the following address in your browser.

You can also withdraw your consents or change your cookie preferences at any time by changing your settings in Cookibot on our website.

Analytical and marketing tools we use

Google Analytics and Google Tag Manager

We use Google tools – Google Analytics and Google Tag Manager – provided by Google Ireland Limited, a company registered and operating under the laws of Ireland, with its registered office at Gordon House, Barrow Street, Dublin 4, Ireland.You can prevent the data collected by the cookies on your use of our website from being recorded by Google, as well as the processing of this data by Google, by installing the browser plug-in found at this address.

If you are interested in the details related to data processing within Google Analytics, we encourage you to read the explanations prepared by Google.

Google Tag Manager is a tool that allows us to control code snippets and tags placed on our website. Tags – i.e. code fragments on a page – allow various actions to be taken, including tracking user activity on the site, such as time spent on the site or scrolling through the site. Thanks to Google Tag Manager, we do not have to add each tag to the source code of a page, which, especially when there are a large number of tags, can cause some problems.

If you are interested in the details related to the processing of data within Google Tag Manager, we encourage you to read the explanations prepared by Google.

The above tools allow us to collect statistical information about your use of our site such as IP address, device type, browser type. We do this in order to know, among other things, the number of users using our site. This information is only processed in a way that does not allow us to directly identify anyone.

Facebook Pixel

We use marketing tools available through Facebook and provided by Facebook Ireland Limited, 4 Grand Canal Square, Dublin 2, Dublin. As part of these tools we target advertising to you on Facebook.

In order to target adverts personalised to your behaviour on our website, we have implemented the Facebook Pixel within our Service, which automatically collects information about your use of our website in terms of the pages you view.

The information collected within the Facebook Pixel is anonymous, i.e. it does not allow us to identify you. We only know what actions the user has taken within our Service.

Please be advised that Facebook may combine this information with other information about you collected through your use of Facebook and use it for its own purposes, including marketing. Such activities of Facebook are no longer dependent on us, and the user can seek information about them directly from Facebook’s privacy policy. From your Facebook account, you can also manage your privacy settings.

Linkedin Pixel

We use marketing tools available within LinkedIn and provided by LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2. The LinkedIn pixel is a JavaScript code that collects data from the website. As a result, it enables you to gain knowledge of your audience and plan your next actions more precisely.

The LinkedIn pixel enables segmentation of target users and where visitors come from, enabling teams to see how many clicks and referrals come from LinkedIn and how many are significant from the web.

Google Ads

We also use Google’s Google Ads tool on our site to track conversions. Information about the use of our service is recorded in conversion tracking tags, encrypted and then sent to Google and then used to match customers to the Google account they were logged into when interacting with one of the ads.

LeadForensics

We use Lead Forensics, a B2B sales and marketing tool operated by Lead Forensics (UK headquarters, Communication House, 26 York Street, London, W1U 6PZ, UK).

The Lead Forensics tool uses a tracking code to identify businesses visiting our sites based on their corporate IP addresses. This is not the same as cookies. The Lead Forensics tracking code only provides information that is readily available in the public domain. It does not and cannot provide individual, personal or sensitive data about our site visitors. Under no circumstances will the data be used to personally identify a specific visitor. If IP addresses are collected, they will be immediately anonymised. The information generated by the Lead Forensics tracking code is sent to the Lead Forensics tool and processed and stored in a secure environment in the UK.

The Lead Forensics tool does not provide us with IP addresses. It does provide us with information about which companies have visited our site, the date and duration of the visit and the pages visited. This information allows us to analyse the use of our site and possibly contact companies about their experience of using the site or for sales purposes. As an international company wishing to guarantee you the best service, we pass on data to our subsidiaries and distributors as required. Personal data is not passed on to third parties for any other purpose.

Part III. Data processing for the purpose of making an offer, establishing business cooperation

We set out below the principles for the processing of your personal data, which apply when you contact us by telephone, e-mail or via the contact forms available on our website to request an offer of cooperation.

The principles described above also apply if we are the ones who contact you using data from publicly available sources, such as LinkedIn or company websites, exclusively related to business activities, in order to establish a relationship.

Finally, the principles described apply when we send you market research surveys, e.g. after a service has been performed.

For what purpose do we process your data?

When you provide us with data yourself, we process your personal data in order to answer your questions, to make you an offer to cooperate, to enter into a business relationship with you, to measure your satisfaction with our services. The specific purpose of the data processing is determined by the nature of the communication.

When we obtain your contact details from publicly available sources, we process them in order to contact you and find out whether you are interested in mutual cooperation. In the case of a positive response, we process your data in order to offer you an offer of cooperation. In the event of a negative response, we stop processing your data.

On what legal basis do we process your data?

The legal basis for processing your personal data is:

• Your consent given by sending us a specific question via the contact form (under contact us), offer form (under offers/dedicated offer, quick call), using the contact details available on the website or obtained by other means;
• the indispensability of the contractual steps for the presentation of the offer and the communication aimed at concluding the contract;
• legitimate legal interest in the case of obtaining your data from publicly available sources for the purpose of establishing a business relationship in respect of basic contact details that you make publicly available on a professional profile on LinkedIn, on a website or that you provide to us directly in another form. We have a legitimate interest in contacting you and offering you the opportunity to cooperate with us.
• Your consent, given in the course of communication by telephone, email or via LinkedIn, for your data to be processed in the future for the purpose of making offers of cooperation to you.
• legitimate interest in the case of satisfaction surveys.

How long do we process your data?

We will process your data until your consent has been withdrawn and, in respect of activities aimed at concluding a contract, for the duration of the discussions or negotiations. Where the legal basis for processing your personal data is a legitimate legal interest, until you object. We only process basic contact data obtained directly from you or from publicly available sources for the period necessary to establish contact, but no longer than 3 months.

If you have consented to receive cooperation offers from us, we will process your data until you withdraw your consent.

Who is the recipient of your personal data?

The recipient of your personal data, i.e. the external entity that will be involved in the processing of your data, will be our trusted subcontractors supporting our operations, in particular Freshmail Sp. z o.o. or Woodpecker.co S.A. offering a tool for managing and sending bulk messages or Survicate Sp. z o.o. offering a tool for collecting feedback, including post-sale surveys. We also use a CRM from Hubspot Inc.

Nature of data provision

The provision of your data is voluntary, but necessary in order to answer your questions or to conclude a contract.

Other relevant information

Your data will not be subject to automated processing or profiling. Your data will not be processed outside the European Economic Area, subject to the data processed in our CRM. HubSpot Inc. is a U.S. company that may process data outside the EEA, but does so based on a mechanism of standard contractual clauses to ensure adequate security for your personal data.

What rights do you have?

Your rights are indicated in Part I of this Privacy Policy.

Part IV. Data processing for marketing purposes, including newsletter services

Below we set out the principles for the processing of your basic contact data, which apply when you agree to receive commercial information by e-mail (newsletter), by telephone, by ticking the appropriate checkbox on our website or by filling in a form in our Subscription Centre.

For what purpose do we process your data?

We process your personal data to present you with commercial information, in particular including information about our services, products or events we organise (e.g. Open Univio Tech Talks), as well as for other direct marketing activities. The purpose of processing your personal data is to establish a relationship and encourage you to use our services.

On what legal basis do we process your data?

The legal basis for processing your personal data is, in particular:

• consent given by ticking the checkbox next to the expected form of marketing contact (e-mail, telephone number) available on our website;
• consent given by providing a self-selected form of marketing contact (e-mail, telephone number) in the Subscription Centre form;
• consent given by you on univio.com for the purpose of obtaining a report or other valuable material produced by us;
• our legitimate legal interest in maintaining business relationships with the individuals and companies we work with.

Please note that you can withdraw your consent at any time by writing to: iod@univio.com. The withdrawal of consent will not affect the legality of the existing data processing.

How long do we process your data?

We will process your personal data until you withdraw your consent if the basis of processing is consent, or until you object if the basis of processing is legitimate legal interest.

Who is the recipient of your personal data?

The recipient of your personal data, i.e. the external entity that will be involved in the processing of your data, will be our trusted subcontractors supporting our operations, in particular Freshmail Ltd. which offers a tool for managing and sending bulk messages.

Nature of data provision

The provision of data is entirely voluntary. Failure to provide data will not entail any negative consequences.

Other relevant information

Your data will not be subject to automated processing or profiling. Your data will not be processed outside the European Economic Area.

What rights do you have?

Your rights are indicated in Part I of this Privacy Policy.

Part V. Data processing in social media marketing activities

Below, we set out for you the principles for the processing of personal data that apply when you use and communicate with us via our social media profiles on LinkedIn, Facebook, Instagram, Twitter or YouTube (referred to as “fanpages”). On our fanpages, we publish and share content, offers and recommendations of our services on an ongoing basis.

For what purpose is your data processed?

We only process your data in connection with the operation of our social media profiles, including to keep you informed of our activities and to promote various events, services and products, as well as to communicate with you via the social media functionalities.

Please note that social media administrators record your activity using cookies and other similar technologies every time you interact with our fanpages and other LinkedIn, Facebook, Instagram, Twitter or YouTube sites. The administrators of the fanpages have access to general statistics about your (as a visitor to the fanpages) interests and demographic data (such as age, gender, region). In the context of the use of social networks, the scope and purposes of data processing on social networks are defined by the administrators of these websites.

On what legal basis do we process your data?

The legal basis for processing your personal data is:

• our legitimate interest in promoting our own brand and building and maintaining a brand-related community.

How long do we process your data?

We will process your data for the following length of time:

• We plan to store the content and other data posted by you on our fanpages indefinitely. Remember that you can always delete your comments under our posts, stop following us or cancel your FB account.
• We plan to delete correspondence directly with us (e.g. on Messenger) 3 to 6 years after the last contact with us.

We process all personal data that we collect on our fanpages as a data controller in accordance with the RODO. Since you are a user of social media, the controller of your data is also the owner of the respective social media – Meta Platforms Ireland Ltd (Facebook, Instagram), YouTube (Google LLC), Twitter Inc. or LinkedIn Ireland.

This is because you have concluded a contract with specific providers which entitles you to use social media. You can find information about how the various platforms process your data on the relevant pages of LinkedIn, Facebook, Instagram, Twitter or YouTube.

Who is the recipient of your personal data?

On our own, we do not intend to transfer data to third countries (i.e. outside the European Economic Area) or to international organisations. On the other hand, the specific nature of social media, its public and international nature means that data on fan pages can be accessed from all over the world. Please note that the rules for data processing within the individual social media are regulated by the respective platforms.

Nature of data provision

The provision of your data is entirely voluntary and is linked to the use of the individual platforms, and failure to do so has no legal effect.

What rights do you have?

Your rights are indicated in Part I of this Privacy Policy.