Privacy Policy of Kellton Poland Sp. z o.o.
Definitions
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Controller – KELLTON POLAND limited liability company̨ with seat in Wrocław, ul. Wyścigowa 56g/2a, 53-012 Wrocław, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Wrocław-Fabryczna in Wrocław, VI Commercial Division of the National Court Register under no. KRS 0000466173, share capital: PLN 5,000.00, NIP: 8992744652, contact: biuro@kellton.com,
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Personal data – information about a natural person identified or identifiable by one or more specific factors determining physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, Internet identifier and information collected through cookies and other similar technology,
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Policy – the Privacy Policy,
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GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC,
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Service – eu.kellton.com
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User – any natural person using the Service,
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Cookies – small text files stored on the User's device when using the Service and any other similar technologies used to collect information about the User's activity on the Service. Cookies may come from the Controller or from the Controller's trusted partners.
I. Privacy Policy of the Service
- Basic information
In connection with the User's use of the Service, the Controller collects data to the extent necessary to provide the various services offered. Detailed rules and purposes of processing Personal Data collected during the User's use of the Service are described below.
| Purpose of processing | Legal basis | Retention period |
|---|---|---|
| Providing services electronically in terms of providing Users with access to content collected on the Service, including the use of Cookies when they contain information that constitutes Personal data of the User | Art. 6 (1) b) of the GDPR (necessity for the performance of the contract) and art. 6 (1) f) of the GDPR for analytical Cookies, when they contain information that identifies the User (legitimate interest to improve the efficiency of the Service) | The Personal data are stored for the duration of the service or the User can successfully object to the processing. In terms of cookies, the User has the option to delete them on his/her own |
| Providing an answer to a question submitted via the contact form | Art. 6 (1) f) of the GDPR (legitimate interest in handling an inquiry, including regarding a client project) | Data are kept until the inquiry is handled or an effective objection to processing is raised |
| To carry out the recruitment process on the basis of labor laws or for the purpose of establishing a civil law contract | Art. 6 (1) c) of the GDPR in connection with the Labor Code (obtaining data from the candidate is a legal requirement) | Personal data will be stored for one year after the end of the recruitment process |
| Art. 6 (1) b) of the GDPR (necessity to take action before entering into a contract) | Personal data will be stored for one year after the end of the recruitment process | |
| Art. 6 (1) a) of the GDPR (when personal data not required by the Controller is provided) | Personal data will be kept for one year from the end of recruitment or until consent is withdrawn | |
| Conducting future recruitment processes | Art. 6 (1) a) of the GDPR (User consent) | Personal data will be kept for one year from the moment of consent to conduct future recruitment or until consent is withdrawn |
| Establishment, defence, exercise of legal claims | Art. 6 (1) f) of the GDPR (legitimate interest in securing the Controller’ rights) | Data is kept until the statute of limitations for claims |
- Obligation to provide Personal data
Provision of personal data is:
1) voluntary in the case of use of the Service, participation in future recruitments, providing data not required by the Controller in the recruitment process and contacting via the contact form. However, failure to provide data may prevent the realisation of particular processing purposes (e.g., receiving an answer to a question asked via the form),
2) the condition of concluding a contract in the case of participation in the recruitment for the purpose of concluding a civil law contract. Failure to provide data prevents participation in the recruitment process,
3) a legal requirement in the case of participation in recruitment under labor law. Failure to provide data prevents participation in the recruitment process.
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The User’s rights in connection with the processing of Personal data
3.1. The User has the right to:
1) access to the content of the data, i.e. request a copy of the data,
2) request rectification of data,
3) request the deletion of data or its restriction,
4) data portability,
5) lodge a complaint to the supervisory authority (i.e. the President of the Personal Data Protection Office).
3.2. In addition, the User shall have the right to object to data processing that takes place on the basis of the legitimate interests of the Controller.
3.3. To the extent that the User's data are processed on the basis of consent (art. 6 (1) a) of the GDPR), the consent may be withdrawn at any time by contacting the Controller via biuro@kellton.com. The withdrawal of consent does not affect the legality of the processing that was performed before its withdrawal.
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The recipients of Personal data
4.1. Users' Personal Data may be accessed by information technology (IT) service providers, including mailing system providers, analytics service providers, and providers of systems and programs that enable proper use of the Service and its functions.
4.2. The Controller reserves the right to disclose selected information concerning the User to the competent authorities or third parties who submit a request for such information, based on the relevant legal basis and in accordance with the provisions of applicable law.
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Transfer of Personal Data outside the EEA
5.1. The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Controller will transfer Personal Data outside the EEA only when necessary and with an adequate level of protection, primarily by:
1) cooperating with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the determination of an adequate level of protection for Personal Data,
2) applying standard contractual clauses issued by the European Commission,
3) the application of binding corporate rules approved by the competent supervisory authority.
5.2. The Controller shall always inform of its intention to transfer Personal Data outside the EEA at the collection stage. Due to the fact that the Company uses the services of other suppliers, e.g. for ICT services, and also transfers certain information within the Group, Personal Data will be able to be transferred outside the European Economic Area. In such a case, this will always be done in such a way as to ensure data security - for example, based on standard data protection clauses adopted by the European Commission.
5.3. Information on the relevant safeguards can be obtained by writing to biuro@kellton.com.
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Security of Personal data
6.1. The Controller conducts a risk analysis on an ongoing basis to ensure that Personal Data is processed by the Controller in a secure manner - ensuring, first and foremost, that only authorized persons have access to the data and only to the extent necessary due to the tasks they perform. The Controller shall ensure that all operations on Personal Data are recorded and performed only by authorized employees and co-workers.
6.2. The Controller shall take all necessary measures to ensure that also its subcontractors and other cooperating entities provide a guarantee of the application of appropriate security measures whenever they process Personal Data on behalf of the Controller.
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Contact information
7.1. Contact with the Controller is possible by contacting: biuro@kellton.com.
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Changes to the Privacy Policy
8.1. The Policy shall be reviewed on an ongoing basis and updated as necessary.
8.2. The current version of the Policy has been adopted and is effective from 4 November 2024.
II. Cookie Policy
The site allows the collection of information about the user through cookies and similar technologies, the use of which most often involves the installation of this tool on the user's device (computer, smartphone, etc.). This information is used to remember the User's decisions (e.g. choice of font, contrast, acceptance of policies), maintain the User's session (e.g. after logging in), remember the password (with consent), collect information about the User's device and their visit for security purposes, but also to analyze visits and customize content.
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What are Cookies used for on the Service?
1.1. The Controller uses Cookies primarily to enable the User to access the Service and facilitate the User's use of the Service
1.2. The Controller also uses Cookies for analytical and marketing purposes - but only if the User agrees to this when using the Service for the first time.
1.3. The Controller also uses other technologies and technical solutions that allow access to information stored on the User's device or browser (e.g. Local Storage, through which the Controller gains access to information stored during the use of the Service in a separate part of the User's browser memory).
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What types of Cookies are used on the Service?
2.1. Cookies used on the Service are divided into the following categories:
TYPE DESCRIPTION Necessary Cookies These cookies are installed to provide the User with access to the Service and its basic functions, and therefore do not require the User's consent. Without the necessary Cookies, the Controller would not be able to provide Users with services on the Service. Optional Cookies These cookies are used by the Controller only if the User consents to them. These cookies are:
- Functional - allow us to remember Users' preferences or choices (such as username, language, text size or other customizable elements) and provide Users with personalized content on the Service;
- Analytical - they make it possible to check the number of visits and sources of traffic on the Service. They help identify which of its features are more or less popular and understand how users navigate the Service. This allows the Controller to improve the performance of the Service;
- Advertising - are used to provide advertisements in accordance with Users' interests and preferences. Based on the information from these files and activity on other Services or sites, a profile of Users' interests is built. -
Are Third Party Cookies used on the Service?
3.1. By using the Service, the User may receive Cookies from third parties cooperating with the Controller. More detailed information is provided below:
THIRD PARTY DESCRIPTION Analytics providers In order to better understand how the Service works, the Controller works with analytics providers such as Google. For more information on how they use User data, click here: https://support.google.com/analytics/answer/7318509?hl=en and here: Data privacy and security - Tag Manager Help. Advertising partners The Controller's advertising partners (Google) may use advertising cookies to display advertisements that they believe will be of most interest to the User, and to measure the effectiveness of such advertisements on the Service. -
How long are Cookies stored?
4.1. The Service uses permanent and session Cookies. Below you will find more information about how long they are kept:
TYPE DESCRIPTION Session Cookies Some cookies are temporary files, stored until you log out, leave the Service or turn it off. These types of cookies help analyze traffic, enable identification and troubleshooting of technical problems, and make it easier to navigate the Service. Permanent Cookies "Permanent" Cookies are stored for the time specified in their parameters or until the User deletes them. They help the Controller remember the User's settings and preferences in order to make the User's next visit more convenient or to provide tailored content. Below is a list of cookies along with their lifespan: Cookie Name Cookie Publishing Tool (GA/Adwords/One Trust etc.) Cookie Function Cookie Duration Google Optimize Adwords This tag is used for A/B testing for Landing pages 2 Months Quick Enquiry Form - Tracking GA4 Google Analytics This tag was used for tracking the form filled by quick enquiry on older website 6 Months enquiry Adwords This tag was used for form fill tracking 6 Months custom Google Analytics Tracking page view, custom HTML was there for tracking page view. 6 Months Sitelinks Searchbox Google Analytics Default tags for Sitelinks 6 Months Conversion Linker_import_1 Adwords These tags are used to measure click data so that conversions are measured correctly. 6 Months Contact Us - Thank You Page - GA4 Event Google Analytics Tracking Thankyou Page conversion from contact us page 6 Months PPC Conversion Tracking Google Analytics Tracking ThankYou page conversion on other pages 6 Months Contact Us Page Form Adwords PPC Contact us form tracking 7 Months Google Ads Conversion Tracking - New Pop-Up Form - kellton Adwords New Pop-up form tracking 7 Months Google Ads Conversion Tracking – Pop-Up Form - kellton Adwords Pop-up form tracking 7 Months Google Analytics GA4 Event – Pop-Up Form - kellton Google Analytics Pop-up form tracking 7 Months Kellton GA4 - Config Google Analytics GA4 Configuration 1 Year chat_start Adwords Google Ads Conversion Tracking 3 Years Conversion Linker Adwords These tags are used to measure click data so that conversions are measured correctly. 4 Years GA tag UA Universal Analytics Implementation Setup 4 Years Captcha Google ReCaptcha Captcha on Forms 6 Months _hjSessionUser Custom Cookie Track user session history 3 Months -
How can I change my Cookie settings?
5.1. The Service uses a Consent Management Platform (CMP) to help you manage your cookie preferences.
5.2. You may use the CMP to change your cookie settings. CMP allows:
5.2.1. obtain detailed information about the Cookies used on the Service and the Controller's trusted partners;
5.2.2. give and withdraw consent for the Controller and trusted partners to use optional Cookies
5.2.3. change previously selected settings.
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Changes to the Cookie Policy
6.1. The Cookie policy shall be reviewed on an ongoing basis and updated as necessary.
6.2. The current version of the Cookie policy has been adopted and is effective from 4 November 2024.