Dear Sirs,

With a view to ensuring your security and in order to process your personal data – during your use of our services – in a legal, reliable and transparent manner, we hereby adopt this document referred to as the Privacy Policy. The document applies to processing and protection of the Users’ personal data in connection with their use of the Website, and it has been drafted by the Service Provider.

To protect its Users’ personal data, the Service Provider applies appropriate organisational and technical measures that prevent interference with the Users’ privacy. These steps ensure security on a level prescribed by the applicable law, including:

1. the Personal Data Protection Act of 10 May 2018
2. the Regulation 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)
3. the Electronically Supplied Services Act of 18 July 2002
4. the Act of 16 July 2004 Telecommunications Law.

I. Terminology

1. User – a natural person, legal person or unincorporated business unit that may view information on the Website in line with its intended use, and may use other services.
2. Service Provider – Paweł Jędrzejewski running business activity under the name Sylius Paweł Jędrzejewski with registered office in Łódź (92-524), Poland, ul. Andrzeja Sacharowa 35/5, Tax Id. No. (NIP) 7282723120, Industry Id. No. (REGON) 101356204
3. Website – the website available in the sylius.com domain, owned and administrated by the Service Provider, through which the Users may use the services offered by the Service Provider.
4. Cookies – limited information saved by a server on the User’s computer that the server can read once the computer is re-connected.
5. SSL protocol – a special standard of online encrypted data transmission as opposed to standard transmission carried out via open text
6. GDPR – Regulation 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 (the General Data Protection Regulation)
7. Personal Data – any information relating to an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
8. Processing – any operations performed on the Personal Data, such as collection, recording, storage, structuring, alteration, making available and erasure, especially the ones performed in any IT systems

II. Cookies

1. The use of the Website is carried out via the secure SSL protocol which ensures the protection of online data transmission.
2. Pursuant to Art. 173 of the Act of 16 July 2004 Telecommunications Law, the Website uses the Cookies, i.e. IT data stored on the User’s terminal equipment. The Cookies are used to:

1. facilitate the use of the Website for the User;
2. subsequently recognise the User – in case of re-connection with the Website from the equipment on which they have been saved;
3. ensure security, and prevent fraud and abuse;
4. prepare statistics that help understand how the User uses web pages, which allows for the improvement of the web pages’ structure and content;
5. customise the Website’s content, and optimise the use of the customised web pages.

3. Usually, the Cookies contain a name of a webpage from which they originate, time for which they are stored in the terminal equipment, and a unique number. As part of the Website, we use the following types of the Cookies:

1. ‘session cookies’ – stored in the User’s terminal equipment until the User logs off, leaves a webpage or turns off a web browser;
2. ‘persistent cookies’ – stored in the User’s terminal equipment for a period specified in the Cookies’ parameters or until they are removed by the User;
3. ‘performance cookies’ – allowing for gathering information as to how the Website’s web pages are used;
4. ‘necessary cookies’ – allowing for the use of the services available as part of the Website;
5. ‘functionality cookies’ – allowing for saving the User’s selected settings and for the customisation of the User’s interface;
6. ‘own cookies’ – placed by the Website;
7. ‘external’ – originating from a third-party webpage;
8. ‘Facebook cookies’ – you should read cookies policy of Facebook available at the address: www.pl-pl.facebook.com/policies/cookies/;
9. ‘Google Analytics cookies’ – you should read the cookies policy available at the address: www.developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage;
10. ‘Other Google cookies’ – you should read cookies policy of Google available at the address:  www.google.com/policies/technologies/types/;
11. ‘Hotjar cookies’ – you should read the Hotjar cookies policy available at the address: www.hotjar.com/legal/policies/cookie-information;
12. ‘HubSpot cookies’ – you should read the HubSpot cookies policy available at the address: www.knowledge.hubspot.com/articles/kcs_article/account/hubspot-cookie-security-and-privacy;
13. ‘LinkedIn cookies’ – you should read the LinkedIn cookies policy available at the address: www.linkedin.com/legal/cookie-policy.

III.   Cookies’ Operation on the Website

1. Our Website uses the Cookies that facilitate the use of its resources. The Cookies contain useful information and are stored on the User’s computer; our server is able to read them only when re-connected with the computer. Most web browsers by default allow for the placement of the Cookies in the User’s terminal equipment. Each User of our Website has an option to change the Cookies-related settings in a web browser’s settings:

• Google Chrome – you should click menu (in the upper right corner), the ‘Settings’ tab > ‘Show advanced settings’. In the ‘Privacy’ section, you should click the ‘Content settings’ button.  In the ‘Cookies’ section, you can change the following settings with regard to the Cookies:

•  removing the Cookies,
•  blocking the Cookies by default,
•  default consent to the Cookies,
•  default operation of the Cookies and of web pages’ data until the closure of a browser,
•  defining exceptions for the Cookies originating from particular websites or domains;

• Internet Explorer 6.0 and 7.0 – from a browser’s menu (right upper corner): Tools > Internet Options > Privacy, the ‘Sites’ button. We determine the level with a slider, and confirm the change with the ‘OK’ button;

• Mozilla Firefox – from a browser’s menu: Tools > Options > Privacy. Activate the ‘Firefox Programme’ field: ‘will use user’s settings’. By marking – or not marking – of the ‘Accept cookies’ box, you will decide how the Cookies are handled;

• Opera – from a browser’s menu: Tools > Preferences > Advanced. By marking – or not marking – of the ‘Accept cookies’ box, you will decide how the Cookies are handled;

• Safari – in Safari drop-down menu, you should select ‘Preferences’ and click the ‘Security’ icon. Here, a security level can be selected by choosing the ‘Accept cookies’ option.

2. If the Cookies functionality is turned off in a browser, the User will still enjoy access to our Website’s resources. Software used to browse websites (a web browser) by default allows for storing of the Cookies in the User’s terminal equipment. The Website’s Users can change related settings The web browser allows for removing of the Cookies. It is also possible to automatically block the Cookies. Detailed information on this subject matter is presented in the help section or in the documentation of a web browser used by the User.
3. If the User does not want to receive the Cookies, they can change settings of their browsers.   However, if the Cookies necessary for authentication processes, security purposes or for maintaining of the User’s preferences are turned off, this may hinder, and in extreme cases also prevent, the use of the Website.

IV. Personal Data

1. Pursuant to Art. 13 of the General Data Protection Regulation of 27 April 2016 (EU OJ L 119 of 5 April 2016), we inform you that:

• The controller of your Personal Data is Paweł Jędrzejewski running business activity under the name Sylius Paweł Jędrzejewski with registered office in Łódź (92-524) Poland, ul. Andrzeja Sacharowa 35/5, Tax Id. No. (NIP) 7282723120, Industry Id. No. (REGON) 101356204;
• The Personal Data controller can be contacted at the e-mail address: privacy@sylius.com;

• Your Personal Data will be processed in order to enable the use of the Website’s functionalities, pursuant to Art. 6.1.a)-b) of the General Data Protection Regulation of 27 April 2016;
• If you agree to wider processing, your personal data will be processed to the extent compliant with the provided consent;
• The Personal Data provided by you will be processed for the term when the Website is used or until a request is filed to discontinue the processing of your data;
• You have the right to request from the controller access to and rectification or erasure of the Personal Data or restriction of processing, as well as the right to data portability, the right to object against processing and the right to withdraw consent;
• If you detect that your Personal Data are processed in breach of the GDPR, you have the right to file a complaint to the President of the Personal Data Protection Office;
• The submission of the specific Personal Data is voluntary, but if they are not provided, this may result in the inability to use these functionalities of the Website that require the provision of the specific Personal Data.

2. The Personal Data collected via forms on the Website to which the User has given consent will be processed for the purposes and period necessary for the proper discharge of relevant performance.  Details will be specified in applicable informative clauses and consent for the processing of the Users’ Personal Data placed under particular forms. The detailed list of the informative clauses and processing rules is available in the Terms of Service.

V.   Additional information

1. As part of the Website, external links may be placed that enable the Users direct access to other websites, or the Cookies from other entities may be additionally placed in your workstation during the use of the Website, in particular from such providers as Facebook, Google, Twitter or LinkedIn, in order to enable you the use of the Website’s functionalities integrated with these websites. Each provider sets rules for the use of the Cookies in its privacy policy; therefore, due to security reasons, we recommend reading their privacy policy prior to the use of such websites.
2. We reserve the right to amend the above Privacy Policy by publishing a new privacy policy on our Website. Once amended, the Privacy Policy shall be released on the Website with a new date.
3. More information concerning terms of service, in particular, the rules governing operation of the Website, manners and terms of concluding agreements, and terms of access to the Website’s content and of use of the Website, including the Personal Data protection rules, are presented in the Terms of Service.

Sylius Team