§ 1. Contact details of the Data Controller
The Controller of personal data of the Users of the www.e-voiladigital.com website is Antoine SAUVAGE, the entrepreneur running a business activity under the name Antoine Sauvage e-Voila in Poznań, at Stanisława Szczepanowskiego street number 7/5, PIN number: 7812025330, REGON number: 389999723, hereinafter referred to as e-Voila.
§ 2. Data Protection Officer and contact
e-Voila has not appointed a Data Protection Officer. For all questions related to the protection of personal data, please contact e-Voila at the following e-mail address: firstname.lastname@example.org.
§ 3. Purposes and bases of the processing of personal data
In order to carry out its activity, e-Voila processes your personal data – for various purposes, but always in accordance with the law.
Below you will find the specified purposes for the processing of personal data as well as the bases for the processing.
If you contact e-Voila to ask a question, obtain an offer or establish cooperation, e-Voila will process the personal data you provide. e-Voila can process in particular:
- Last name
- First name
- E-mail address
- Phone number
- Contractor data such as name, address, NIP and REGON numbers.
Sometimes e-Voila also processes personal data such as:
- PESEL number
e-Voila processes personal data on the basis of Art. 6 sec. 1 point a) of the GDPR (when the data subject has consented to the processing of his or her personal data for one or more specific purposes) and point d) (when the processing is necessary to safeguard the vital interests of the data subject or of a other natural person).
In order to administer the website, e-Voila processes data such as:
- IP adress,
- date and location of the server,
- browser information,
- operating system information
— this data is automatically recorded each time you use our website. Administering the website without using the server and without this automatic backup would not be possible. If these data constitute personal data, the basis for their processing is Art. 6 sec. 1 point f of the GDPR, which allows the processing of personal data if in this way the Data Controller fulfills his legitimate interest (in this case the administration of the website is the interest of e-Voila).
For analytical purposes, i.e. research and analysis of activities on the website, e-Voila processes data such as:
- date and time of the visit;
- type of operating system;
- approximate location;
- time spent on site;
- visited sub-pages;
- type of web browser used to display the site.
If these data constitute personal data, the basis for their processing is art. 6 sec. 1 point f of the GDPR, which allows the processing of personal data if in this way the Personal Data Controller achieves his legitimate interest (in this case, the interest of e-Voila is to know the activity of the users of the site).
§ 4. Cookies
4.1. e-Voila uses so-called cookies on its website, i.e. short text information saved on a user’s computer, telephone, tablet or other device. They can be read by the e-Voila system, as well as by systems belonging to other entities (e.g. Facebook, Google).
4.2. Cookies perform many functions on the website, which are as follows:
- provide security – cookies are used to authenticate users. They are therefore used to protect your personal data against unauthorized access;
- impact on the processes and efficiency of using the website – cookies are used to ensure that the website works efficiently and that you can use the functions available on it, which is possible, among other things, by remembering the settings between subsequent visits to the website. Thanks to them, you can efficiently navigate the website and individual subpages;
- session state – information about how visitors use the website is often stored in cookies, for example which sub-pages are viewed most often. They are also used to identify errors displayed on certain sub-pages. Cookies used to save the so-called “session state” therefore allows to improve the services and to increase the comfort of navigation on the pages;
- creation of statistics – cookies are used to analyze how users use the website. Thanks to this, e-Voila can constantly improve the website and adapt its operation to user preferences. e-Voila uses Google tools such as Google Analytics to track activity and create statistics; in addition to reporting website usage statistics, the Google Analytics pixel may also be used, along with some of the cookies described above, to help display content that is more relevant to Google users (e.g., the engine Google search) and across the web;
4.3. Importantly, many cookies are anonymous to e-Voila – without additional information, e-Voila is unable to identify your identity based on them.
§ 5. Right to withdraw consent
5.1. If the processing of personal data is based on consent, you can withdraw your consent at any time – at your own discretion.
5.2. If you wish to withdraw your consent to the processing of personal data, simply send an e-mail to the address email@example.com.
5.3. If the processing of your personal data was based on consent, you have the right to withdraw your consent to the processing of personal data without affecting the lawfulness of the processing based on the consent made before the withdrawal of the consent.
§ 6. Obligation to provide personal data
The provision of personal data is voluntary, but their availability and their processing by e-Voila are necessary to navigate on the site as well as to meet your expectations concerning the use of the website or your requests.
§ 7. Automated decision making and profiling
e-Voila does not make automated decisions, including those based on profiling.
§ 8. Recipients of personal data
8.1. Like most entities, e-Voila uses the assistance of other companies in its operations, which often involves the need to provide personal data. Therefore, if necessary, e-Voila transfers your personal data to lawyers, accountants, as well as a hosting company.
8.2. In addition, it may happen that, for example, based on applicable law or the decision of the competent authority, e-Voila must also transfer your personal data to other entities, whether public or private. Therefore, it is extremely difficult to predict who may request personal data. However, e-Voila assures you that each case of a request for the provision of personal data is analyzed very carefully so as not to accidentally transmit information to an unauthorized person.
§ 9. Transfer of personal data to third countries
9.1. e-Voila does not directly transfer personal data to third countries or international organizations.
9.2. Like most entities, however, e-Voila uses various popular services and technologies offered by entities such as Facebook or Google. These companies are based outside the European Union and therefore, in light of the provisions of the GDPR, are treated as third countries. This means that, for example, if you contact e-Voila through its Facebook fanpage, your data may be transferred to a third country.
9.3. The GDPR introduces certain restrictions on the transfer of personal data to third countries, because, as a general rule, European rules do not apply there, the protection of personal data of citizens of the European Union can, unfortunately, be insufficient. Therefore, each personal data controller is required to determine the legal basis for such transfers.
9.4. For its part, e-Voila only uses services and technologies from entities that have joined the Privacy Shield program, based on the implementing decision of the European Commission of July 12, 2016 – more information on this subject can be read on the European Commission website. Entities that have joined the Privacy Shield program guarantee that they will comply with the high standards in the field of personal data protection that apply in the European Union, therefore, the use of their services and the technologies offered in the processing of personal data is lawful.
9.5. e-Voila will at all times provide you with further explanations regarding the transfer of personal data, especially when this matter raises your doubts.
9.6. You have the right to obtain at any time a copy of your personal data transferred to a third country.
§ 10. Duration of the processing of personal data
10.1. In accordance with the applicable legal provisions, e-Voila processes your personal data only for the time necessary to achieve the designated purpose. After this period, your personal data will be deleted or irreversibly destroyed.
10.2. In a situation where e-Voila does not need to perform operations other than storage on your personal data, e-Voila further secures it by deleting or destroying it permanently – by pseudonymization. Pseudonymization consists of such encryption of personal data or a set of personal data that they cannot be read without an additional key, and therefore this information becomes completely useless for an unauthorized person.
10.3. With respect to individual periods of processing personal data, e-Voila processes personal data for a period:
- until the consent is withdrawn or the purpose of the processing is achieved – in relation to personal data processed on the basis of consent;
- until an effective objection is raised or the purpose of the processing is achieved – with regard to personal data processed on the basis of the legitimate interest of the data subject;
10.4. Periods in years are counted from the end of the year in which e-Voila started processing personal data in order to improve the process of deleting or destroying personal data. Counting the deadline separately for each event would involve significant organizational and technical difficulties as well as significant financial outlay, so setting a date for the deletion or destruction of personal data allows us to manage this process more efficiently. Indeed, if you exercise your right to be forgotten, such situations are considered individually.
§ 11. Rights of data subjects
11.1 e-Voila informs you that you have the right:
- to request access to the data;
- to the rectification of data;
- to the erasure of data;
- to the restriction of data processing;
- to object to the processing of personal data;
- to the data portability.
11.2. e-Voila respects your rights arising from the provisions on the protection of personal data and tries to facilitate their implementation as far as possible.
11.3. e-Voila indicates that these rights are not absolute and, therefore, in certain situations, may legally refuse to respect them. However, e-Voila refuses to accept your request only after a thorough analysis and only if the refusal to accept the request is necessary.
11.4. With regard to the right to object, e-Voila clarifies that you have the right to object to the processing of personal data at any time on the basis of the legitimate interest of the Data Controller in relation to your particular situation. However, it should be pointed out that in accordance with legal provisions, e-Voila may refuse to accept your objection if:
- there are legitimate grounds for the processing which override your interests, rights and freedoms, or
- there are grounds for the establishment, exercise or defense of legal claims.
11.5. You can exercise your rights by sending an e-mail to firstname.lastname@example.org.
§ 12. Right to lodge a complaint
If you believe that your personal data is being processed contrary to applicable law, you have the right to lodge a complaint with the President of the Office for the Protection of Personal Data.
§ 13. Final provisions