Who are we?
Codewise spółka z ograniczoną odpowiedzialnością sp.k., a Krakow-based ad tech company, incorporated under the laws of Poland, with a registered office at Lubicz 17G, 31 – 503 Krakow, Poland, registered in the entrepreneurs register of the National Court Register held by the District Court for Krakow – Śródmieście in Krakow, XI Commercial Division of National Court Register (Sąd Rejonowy dla Krakowa – Śródmieścia w Krakowie, XI Wydział Gospodarczy Krajowego Rejestru Sądowego) under the number: KRS 0000402705, tax ID (NIP): 5213623147, further referred to as: “Codewise”, “us”.
How to contact us?
You can contact us using the contact form that can be found on our website (www.codewise.com/contact/) or via e-mail: email@example.com. You can also contact our data protection officer: firstname.lastname@example.org.
Why do we need your personal data and what is our legal basis to using them?
We process your personal data because it is necessary to conclude contract with you and to perform the contract concluded with you, i.e. to:
- registering your account,
- maintaining your customer account, providing you with our services and customer support, handling transaction and issuing invoices,
- handle with your requests and inquiries in relation to the provision of our services.
We also process your personal data for the purposes set out below, based on our legitimate interest, which is:
- improving our services, detecting frauds and monitoring compliance with our Terms & Conditions in order to provide you with the highest quality services,
- pursuing claims or defending against claims, e.g. when you are not satisfied with our services and we need to handle your claims or chargebacks,
- conducting surveys, analyse and storing data for archiving or statistical purposes, and ensuring accountability,
- marketing activities related to you, including direct marketing of our own services, as well as contacting with you for purposes related to permitted marketing activities.
In addition, the law requires us to process your data for tax and accounting purposes.
We also ask you for your voluntary consent for specific form of marketing: sending commercial information via e-mail/sending newsletter or communicating with you by phone or skype for marketing purposes in accordance with applicable law (law on telecommunications, act on provision of services by electronic means).
Is processing of personal data voluntary?
Yes, the processing of your personal data is voluntary but - to the extent to which we use your data for concluding the contract with you or performing services - it is also necessary. Without your data, we will not be able to do it.
To the extent we process your personal data because it is necessary for our legitimate interests (listed above) it is voluntary and you may object to it according to GDPR provisions by contacting us (as described in section “How to contact us?” above).
In what situations can you object to the processing of your personal data?
You have the right to object to the processing of your personal data when:
To whom we may disclose your data?
- the processing of your personal data is based on a legitimate interest or for statistical purposes, and the opposition is justified by the particular situation in which you have found yourself,
- your personal data is processed for direct marketing purposes, including profiling for this purpose.
We will make efforts to process your data on our own. However, we may need to disclose your personal data to our trusted vendors: payment services providers or service provider acting on our behalf, e.g. IT services, analytical services, advertising services, cloud or host services providers.
Do we transfer your data outside the EEA?
We may transfer your personal data outside the European Economic Area, i.e. to the territory of United States of America for which the European Commission has adopted an adequacy decision (Privacy Shield), in order to protect storage and processing of data using IT services, as well as operating the site and providing the services. The EU-U.S. Privacy Shield framework is a "partial" adequacy decision (concern only the companies committing to abiding by the binding Privacy Shield principles).
In such cases your personal data will be transferred to the territory of USA in accordance with applicable laws and with appropriate safeguards in place only to Privacy Shield certified vendors or by using standard contractual clauses adopted by the European Commission, or based on other applicable transborder data transfer mechanisms.
If you are located in the EEA, you may contact us and require a copy of the safeguards which we have put in place to protect your data transferred outside of the EEA and your privacy rights in these circumstances.
You may also learn more about Privacy Shield Program here https://www.privacyshield.gov/Program-Overview and about European Commission Decision on standard contractual clauses for the transfer of personal data to processors established in third countries here https://eur-lex.europa.eu/legal-content/EN/TXT/?uri=celex%3A32010D0087.
How long will we be processing your personal data?
We will be processing your data for a period of time required for the completion of the purposes for which it was collected, e.g.: with reference to our services your data will be processed for the period in which these services will be provided and, sometimes, after the end of their provision, but only if it is allowed or required under applicable law, e.g. for claims purposes. In this case, the data will be processed only for the period necessary to achieve such goals. In case of rest purposes of processing your data listed above (e.g. marketing of our products or services) your personal data will be processed also for a period it is needed for these purposes or until you object to it. Where you have consented to marketing communications via e-mail or other telecommunication means for our marketing purposes (e.g. you agree to receive our newsletter or contacting you by phone), you may withdraw your consent at any time by contacting as well as you may unsubscribe from newsletter at any time by clicking the unsubscribe link in an e-mail from us. In these circumstances, your personal data will be processed until your withdrawn of the consent.What are your rights?
Codewise will respect your legal rights to your data listed below:
- the right to access your personal data
- the right to rectify or erase your personal data (“right to be forgotten”)
- the right to restrict the processing of your personal data
- the right to object to the processing of your personal data (to the extent to which it is processed because it is necessary for our legitimate interests)
- the right to withdraw at any time your consent to processing of your personal data, however, the withdrawal of consent does not affect the compliance of the processing which was made on its basis before the withdrawal of consent
- the right to data portability.
You can manage and control your privacy rights by contacting our data protection officer: email@example.com.
You also have the right to lodge a complaint with a supervisory authority at any time you consider that the processing of your personal data infringes the GDPR.
Where can you learn more about processing of your personal data?