PRIVACY POLICY OF TUTEER

DATA PRIVACY STATEMENT

Please read our Privacy Policy, which explains the principles and method of collecting, processing, and using data about Users of the website available at www.tuteer.com/en and Clients using the educational services provided by TUTEER CONSULTING Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, ul. Hoża 86/410, 00-682 Warsaw.

On account of the above, TUTEER CONSULTING Sp. z o.o. undertakes to respect your privacy and will make every effort to properly secure any personal data it processes, acting in accordance with the provisions of the Regulation of the European Parliament and of the Council (EU) 2016/679 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.

1. Glossary:

Data Processing:

– The Controller of personal data is TUTEER CONSULTING spółka z ograniczoną odpowiedzialnością, with its registered office in Warsaw at ul. Hoża 86/410, 00-682 Warsaw, entered into the Register of Entrepreneurs kept by the District Court for the capital city of Warsaw in Warsaw, 12^th Commercial Division of the National Court Register under KRS number: 0001070500, Tax Identification Number (NIP): 7011175971 and REGON number: 527014296, with share capital of PLN 10,000.00.

The Controller can be contacted: 

• by email sent to: rodo@tuteer.com
• at the address ul. Hoża 86/410, 00-682 Warsaw.

The Controller processes Personal Data to the extent necessary to provide individual Educational Services offered on the Website. Providing data is voluntary, but necessary for the provision of Educational Services by the Controller.

3. The Purpose of and Legal Basis for the Processing of Personal Data:

Personal Data is processed by the Controller for the following purposes:

• Taking actions before the conclusion of the agreement and for the purpose of its performance to provide electronic services in the scope of providing the User with the content of the Website and providing Educational Services to the extent necessary to perform the agreement (Article 6(1)(b) of the GDPR);
• Fulfilling obligations arising from the provisions of the generally applicable law, including, among others, the tax law, the Accounting Act (Article 6(1)(c) of the GDPR);
• Pursuing legitimate interests of Tuteer, such as establishing, pursuing, or defending against claims and handling internal processes related to running a business (Article 6(1)(f) of the GDPR);
• Sending commercial information (Article 6(1)(a) of the GDPR);
• The User’s activity on the Website, including their personal data, is recorded in system logs, i.e. a special computer programme storing chronological records that contain information about events and activities related to the IT system used to provide services by the Controller. The information collected in the logs is processed for purposes related to the provision of services. The Controller also processes it for technical and administrative purposes, on account of the need to ensure the security of the IT system and to manage this system, and for analytical purposes (Article 6(1)(f) of the GDPR);
• Following a recruitment procedure in connection with recruitment concerning cooperation based on civil law agreements (Article 6(1)(b) of the GDPR – data are processed in order to enter into and perform an agreement, and pursuant to Article 6(1)(f) of the GDPR – data are processed for the purposes of the legitimate interests pursued by the Controller; the legitimate interest of TUTEER CONSULTING Sp. z o.o. is cooperation and communication to properly perform the agreement). 

4. “Cookies” – Types of Cookies, Their Storage Period, and the Way of Withdrawing Consent to Their Installation

1. Pursuant to the provisions of Articles 173 and 174 of the Telecommunications Law Act of 16 July 2004 (Journal of Laws of 2004 No. 171, item 1800, as amended), TUTEER CONSULTING Sp. z o.o. informs that the Website uses the technology of “cookie” files as part of its operation. Cookies are small text files saved on the User’s computer or mobile device when using the Website. For more information about cookies, please visit www.allaboutcookies.org.

The Website uses the following cookies:

1. 1. “Technical” cookies – these are cookies that are absolutely necessary for the proper functioning of the Website and the proper provision of the services requested by you, as well as for storing your consent for other categories of cookies. You can disable them in your browser settings, but this may affect the functioning of the Website.
   2. “Analytical” cookies – these are cookies that are installed by Google Analytics. They are used to improve our Website by collecting and providing information about how you use it. Cookies collect information in a way that does not allow direct identification of individuals. Installation of analytical cookies on the User’s end device requires the User’s consent.

2. If the User does not want to save cookies, they can change the browser settings. However, it should be emphasised that disabling cookies necessary for the processes of authentication, security, and maintaining User preferences may make it difficult, and in extreme cases event impossible, to use the Website.

3. The ways of configuring cookie settings in individual search engines can be found, among others, at the following addresses:

1. Firefox –browser settings guide
2. Chrome –browser settings guide
3. Internet Explorer –browser settings guide
4. Internet Explorer –browser settings guide
5. Safari –browser settings guide

4. The legal basis for the processing of technical cookies is Art. 6(1)(f) of the GDPR, the data is necessary for the proper functioning and display of the Website, establishing communication with the User’s device, and sending data to it.

5. The legal basis for the processing of analytical cookies is Article 6(1)(f) of the GDPR, after the User consents to their installation in accordance with Article 173(1)(2) of the Telecommunications Law Act of 16 July 2004 (uniform text in Journal of Laws of 2021, item 576). In addition, the legal basis for the transfer of data related to the processing of Google Analytics cookies (referred to below), which are transferred outside the European Economic Area (EEA), is the User’s consent expressed in accordance with Article 49(1)(a) of the GDPR by ticking a checkbox indicating consent on the “consent form” banner, displayed upon entering the Website. 

5. Transfer of Data to Third Countries Outside the European Economic Area

Data transfers outside the EEA may only take place in the manner provided for by law: 

– Pursuant to a decision of the European Commission establishing an adequate level of protection in the third country to which the data is transferred;

– Provided that appropriate safeguards are ensured, including: binding corporate rules (Art. 47 of the GDPR), standard data protection clauses adopted by the European Commission or a competent supervisory authority in the field of personal data (Article 46(2)(c) or (d) of the GDPR);

– In cases necessary on account of the legitimate interests of the Controller, provided that the requirements of Article 49(1) of the GDPR are met.

On account of the use of Google Analytics, Google Fonts, Google reCAPTCHA, and Adobe Fonts on the Website, which involves the transfer of data outside the European Economic Area (EEA), i.e. to the United States of America, where the headquarters of Google LLC and Adobe Systems Inc. are located, the data is transferred to a third country.

1. Google Analytics

As above in item 4, subitem 5.

2. Google Web Fonts

This website uses digital fonts provided by Google Ireland Limited for the purpose of displaying the content of the website in a uniform manner. When the Website is called up, the User’s device cache loads the fonts necessary to display the page correctly.

In order to achieve the above-described effect, the device must connect to Google servers using the User’s IP address. The use of Google Fonts is based on Art. 6(1)(f) of the GDPR. 

Further information about Google Web Fonts can be found at https://developers.google.com/fonts/faq and in Google’s Privacy Policy at https://policies.google.com/privacy?hl=pl.

3. Google reCAPTCHA

This Website uses the Google reCAPTCHA mechanism provided by Google Ireland Limited to verify that the data entered in the forms are entered by a human rather than a computer program. For this purpose, reCAPTCHA automatically analyses the way data is entered from the moment the User enters the Website. Data including IP address, cursor movements, and time spent on a given subpage are transmitted to Google Ireland Limited and its affiliates. 

The reCAPTCHA mechanism is used pursuant to Art. 6(1)(f) of the GDPR. The Website owner has a legitimate interest in protecting against abuse and spam. 

Further information about the reCAPTCHA mechanism can be found at https://developers.google.com/fonts/faq and in Google’s Privacy Policy at https://policies.google.com/privacy?hl=pl.

4. Adobe Fonts

This website uses digital fonts provided by Adobe Systems Inc for the purpose of displaying the content of the website in a uniform manner. When the Website is called up, the User’s device cache loads the fonts necessary to display the page correctly.

In order to achieve the above-described effect, the device must connect to Adobe servers using the User’s IP address. The use of Adobe Fonts is based on Art. 6(1)(f) of the GDPR. 

Further information about Adobe Fonts can be found at 

https://www.adobe.com/pl/privacy/policies/adobe-fonts.html 

and in Adobe’s Privacy Policy: https://www.adobe.com/pl/privacy/policy.html 

6. Data Processing Period: 

1. The period of data processing by the Controller depends on the type of services provided and the purpose of processing. As a rule, the data is processed: for the duration of the service or the execution of the order, until withdrawal of the consent given or until effective objection to the processing of data in cases where the basis for data processing is the legitimate interest of the Controller (Article 6(1)(f) of the GDPR). 

2. The data processing period may be extended if the processing is necessary to establish, pursue, or defend against potential claims, and after this time only in case and to the extent it is required by law. After the expiry of the processing period, the data is irreversibly deleted or anonymised.

7. Rights of the User:

1. The User has the right to:

1. Access the data and request its rectification;
2. Receive a copy of the data; 
3. Deletion of data;
4. Restriction of processing;
5. Data portability;
6. Object to the processing of data;
7. Lodge a complaint to the supervisory body, which is the President of the Personal Data Protection Office, in the event that the processing of data of the Data Subject violates the regulations; such a complaint can be submitted in writing: ul. Stawki 2, 00–193 Warsaw; or electronically: via ePUAP.

2. To the extent that the User’s data are processed pursuant to Article 6(1)(a) of the GDPR (processing of personal data on the basis of consent), this consent may be withdrawn at any time without affecting the lawfulness of the processing which was carried out on the basis of consent before its withdrawal.

8. Recipients of Data:

1. In connection with the provision of services, personal data may be provided to employees, associates of the Controller, and subcontractors cooperating with the Controller, in particular entities responsible for the operation of ICT systems and the Controller’s affiliated entities. 
2. The Controller has the right to transfer personal data to competent authorities or third parties who submit a request for such data, specifying the scope of data to be disclosed, as well as the legal basis of the request.

9. Privacy Policy Term and Amendments:

This Privacy Policy comes into effect on 19th of April 2024. The Controller shall update the Privacy Policy taking into account, among others, changes that may result from changes in Polish or international law, development of Internet technologies, or development and creation of new services offered by the Administrator.