Privacy Policy & Personal Data Processing Information

  1. What is the scope of this Policy?

This Privacy Policy (“Policy“) contains the information about the processing of personal data by Joanna Socha running a business under the company name “Embark – Joanna Socha” in Warsaw (the “Company”), i.e.:

  • defines the types of personal data that the Company collects;
  • explains how and why the Company collects and uses your personal data;
  • explains when and why the Company will share your personal data with third parties; and
  • explains the rights and options that you have when it comes to your personal data.

The Policy applies when you are:

  • a Website User, i.e. when you use the www.w-insight.com website (“Website“), e.g. when you left a comment under one of the posts on the Website or filled out the contact form available on the Website;
  • a Donor, i.e. when you make a financial donation to the Company via the Website, intended for the Company’s own purposes, including the Company’s development purposes; 
  • a Candidate to work, i.e. when you are a person interested in taking up employment in the Company and taking part in the recruitment processes conducted by the Company, regardless of the form of employment;
  • a Potential Contractor of the Company, i.e. when you are a natural person interested in the Company’s offer and contacting the Company in order to obtain specific information or to conclude a contract or a Representative of Potential Contractor, i.e. when you represent or act on behalf of the Potential Contractor; 
  • a Contractor of the Company, i.e. when you are a natural person who cooperates with the Company or for whom the Company provides its services or a Contractor’s Representative, i.e. when you represent or act on behalf of the Contractor; 
  • a Service Provider, i.e. when you provide a services to the Company or a Representative of Service Provider, i.e. when you represent or act on behalf of the Service Provider;
  • a Recipient of marketing activities, i.e. when you are a recipient of e-mailing or marketing carried out by the Company (e.g. newsletter). 

We process your personal data in accordance with the Regulation (EU) 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 – “GDPR”).

  • Who is the personal data controller?

Your personal data controller is:

Joanna Socha running a business under the company name “Embark – Joanna Socha” 
Konstruktorska 11
02-673 Warsaw
(„Controller”, „we”)

In matters related to the processing of personal data, you can contact us at the above-mentioned correspondence address or at the following e-mail address: editors@w-insight.com.

  • What information and from what sources we collect?

If you are a Website User, we collect information obtained from you in connection with your activity on the Website. These are in particular information provided by you in contact form or in comments under the posts on the Website, the IP address and information contained in cookies. 

If you are a Donor, we collect information obtained in connection with the donation made to the Company, such as name, surname, e-mail address, payment amount, payment card details. 

If you are a Candidate to work, we collect information obtained from you during the recruitment for a job and participation in the recruitment process. These are in particular the data contained in the submitted application documents (CV, cover letter) and data provided during the recruitment meetings, telephone conversations and e-mail correspondence, including: name, surname, contact details, data on education, professional qualifications, the course of previous employment and others.

If you are a Potential Contractor, we collect information obtained from you during telephone conversations, e-mail correspondence and meetings. These are in particular: name and surname, position, company name, contact details, information about the need for the Company’s services and other data – if you facultatively decide to transfer them to the Company.

If you are a Contractor, we collect information obtained from you in connection with the conclusion and execution of the contract concluded with us. These are in particular: name and surname, name and address of the company, correspondence address, NIP number, REGON number, bank account number, contact details, information regarding the contract concluded with us or the services we provide. Your data may also come from publicly available sources.

If you are a Representative of Potential Contractor or Contractor’s Representative, we collect information provided to us by you or by the company you represent for the purpose of concluding and executing the contract with the company. These are in particular: name and surname, position, name of the company, correspondence address, e-mail address (business), telephone number (business).

If you are a Service Provider, we collect information provided to us by you in sent documents, during telephone conversations, e-mail correspondence and meetings. These are in particular information necessary for the conclusion and execution of the contract, including: name, surname, name and address of the company, correspondence address, NIP number, REGON number, bank account number, e-mail address, telephone number, information about the contract between us. Your data may also come from publicly available sources.

If you are a Representative of Service Provider, we collect information provided to us by you or by the Service Provider you represent for the purpose of concluding and executing the contract with the Service Provider. These are in particular: name and surname, position, name of the Service Provider you represent, correspondence address, e-mail address (business), telephone number (business).

If you are a Recipient of marketing activities, we collect information necessary for the Company to carry out specific marketing activities, including the newsletter. This is in particular the e-mail address.

  • What is the purpose and the basis on which we process your data?

If you are a Website User, we process your personal data:

  • on the basis of the legitimate interests pursued by the Controller (Article 6.1(f) of the GDPR), for the purposes of:
    • contact you and handle the message sent via the contact form,
    • leaving a comment under the post on the Website,
    • Website administration (management);
  • on the basis of your consent, in case of providing personal data that are not necessary to leave a comment or contact and handle the message sent via the contact form, including sending notifications about new comments and new posts on the Website (Article 6.1(a) of the GDPR).

If you are a Donor, we process your personal data:

  • in order to conclude and perform the donation agreement with you (Article 6.1(b) of the GDPR);
  • on the basis of the legitimate interests pursued by the Controller, such as maintaining business relationships, ongoing contact, as well as pursuing claims and defending against such claims (Article 6.1(f) of the GDPR).

If you are a Candidate to work, we process your personal data:

  • in order to comply with legal obligations to which we are subject, resulting from legal provisions, including labour law provisions (Article 6.1(c) of the GDPR);
  • on the basis of your consent, in case of providing personal data in broader scope than it is required by the law (including labour law) and for the purposes of future recruitment processes – as long as you have agreed to it (Article 6.1(a) of the GDPR, Article 9.2(a) of the GDPR);
  • to establish or pursue possible claims or defend against such claims (Article 6.1(f) of the GDPR).

If you are a Potential Contractor, we process your personal data:

  • on the basis of the legitimate interests pursued by the Controller, such as presenting an offer at your request, ongoing contact in connection with the offer, maintaining relations, establishing or pursuing possible claims or defending against such claims (Article 6.1(f) of the GDPR);  
  • in order to take actions at your request, necessary before concluding a contract (Article 6.1(b) of the GDPR).

If you are a Contractor or Service Provider, we process your personal data:

  • in order to conclude and perform the contract with you (Article 6.1(b) of the GDPR);
  • in order to comply with legal obligations to which we are subject (Article 6.1(c) of the GDPR), for example to store financial records;
  • on the basis of the legitimate interests pursued by the Controller, such as maintaining business relationships, ongoing contact, marketing activities, as well as pursuing claims and defending against such claims (Article 6.1(f) of the GDPR).

If you are a Contractor’s Representative, a Representative of Potential Contractor or a Representative of Service Provider, we process your personal data:

  • on the basis of the legitimate interests pursued by the Controller, such as taking necessary actions before concluding the contract with the entity you represent, concluding and executing the contract, maintaining business relationships and ongoing contact, conducting marketing activities, as well as pursuing claims and defending against them (Article 6.1(f) of the GDPR).

If you are a Recipient of marketing activities, we process your personal data:

  • on the basis of the legitimate interests pursued by the Controller, such as sending a newsletter or direct marketing (Article 6.1(f) of the GDPR);
  • on the basis of your consent, as long as it is an important and effective basis for data processing, for the purposes of our marketing (Article 6.1(a) of the GDPR).
  • Who do we share your data with?

When it is necessary to achieve the purposes in which we process your data, we can provide it to:

  1. entities authorized to receive data on the basis of legal regulations;
  2. entities that process your personal data on our behalf (for example entities providing consultancy, IT and other services).

Whenever we disclose your personal data, we will ensure that only the minimum information necessary to achieve the purpose of data processing is transferred.

Your personal data may be transferred outside the European Economic Area (EEA). In this case, we will ensure that cooperation with such entities will be based on an appropriate legal basis and that they ensure appropriate standards of protection.

  • Payment processing

If you wish to make a donation to a Company, we use services of Stripe Inc. (“Stripe“) for our payment processing. Thereby and unless otherwise indicated below, Stripe acts as a data processor and its affiliates act as the sub-processors.

During the payment process, if you choose to pay with your credit card, you will be asked to enter your card information, which will be securely transferred to and processed by Stripe. Company will not have access to such data.

To process and authenticate the online payment transactions, Stripe may use your Personal Data (e.g. credit card number, the amount and the date of payment).

During the transaction, Stripe might obtain and process personal information about you received through the services or from third parties in order to determine your identity and prevent fraudulent activities. In this case, Stripe acts as the controller of your personal data.

Stripe might transfer your personal data to third countries, including the United States. For information on which measures Stripe takes to ensure that any such transfers comply with applicable data protection laws, please see https://stripe.com/privacy-center/legal#data-transfers.

Stripe may also place Cookies in order to enable the transaction. For more information on how Stripe processes your personal data, please see Stripe’s Privacy Policy.

  • How long do we store your data?

If you are a Website User, we store your personal data for the period of their usefulness, but no longer than it is useful for the purpose for which the data was collected – e.g. contact and handling of the message sent via the contact form or administration (management) of the Website.

If you are a Donor, your personal data will be processed for the duration of the donation agreement concluded with you. After this period, we will keep your data to the necessary extent for a period of time resulting from legal requirements and rules on limitation of claims. In justified cases, we will store your personal data for as long as it is necessary to pursue our legitimate interests.

If you are a Candidate to work, we store your personal data until it is useful for the purpose for which the data was collected, i.e. conducting the recruitment process for which you applied. If you have consented to the processing of your personal data for the purposes of future recruitment, your personal data will be stored for a period of two years from the moment it is collected. If you decide to withdraw your consent, your personal data will be stored until that withdrawal. In justified cases, we will store your personal data for as long as it is necessary to pursue our legitimate interests.

If you are a Potential Contractor or its Representative, we will store your personal data as long as it is necessary to achieve the purpose for which the data was provided to us, but no longer than until you object to the processing of personal data for this purpose. 

If you are a Contractor, a Service Provider or a Representative of one of these entities, your personal data will be processed for the duration of the contract concluded with you or the entity you represent. After this period, we will keep your data to the necessary extent for a period of time resulting from legal requirements and rules on limitation of claims. In justified cases, we will store your personal data for as long as it is necessary to pursue our legitimate interests.

If you are a Recipient of marketing activities, your personal data will be processed as long as it is useful for the Company’s marketing goals. If you have consented to the processing of your personal data for the purposes of Company’s marketing, your personal data will be stored until the withdrawal of the consent.

  • What rights do you have?

You can exercise your data subject rights by sending us the following requests:

  1. if we process your personal data based on your consent, you can withdraw your consent at any time; the withdrawal of consent does not affect the lawfulness of the processing we have made on its basis until its withdrawal;
  2. you can request access to your personal data and obtain a copy thereof;
  3. you can exercise your right to data portability;
  4. you can request rectifying or completing your personal data if it is incorrect or incomplete;
  5. in connection with your special situation, you may object to the processing of your personal data if we process it by invoking our legitimate interest;
  6. in cases specified by law – for example if your data is out of date, unnecessary, unlawfully processed, and if you withdrew your consent to processing them (if consent was the basis for such processing) or successfully filed an objection to the processing of your personal data – you can request erasure of your personal data;
  7. you can also request a restriction of data processing.

In order to exercise the above rights, please contact us by mail or e-mail address indicated in point 2 of the Policy.  

In any case you believe that the processing of your personal data violates the provisions of GDPR, you also have the right to lodge a complaint to the data protection supervisory authority in your country of residence. 

  • Whether you need to provide us with your personal data and their source if they were not provided by you

Providing your personal data is voluntary in every case but remember that failing to provide them will prevent us from achieving the purposes for which the data are collected, for example: 

  1. it will prevent or significantly hinder contact with you;
  2. it will prevent you from leaving a comment;
  3. it will prevent the Company from carrying out its marketing activities. 

If you are a Contractor Representative, a Representative of Potential Contractor or a Representative of Service Provider and you do not provide us with your personal data, they come from the entity you represent or have been collected by us from public sources (for example from the website).

  1. Current version and changes to the Policy

The Policy is constantly reviewed and updated as necessary. The current version of the Policy has been adopted and is effective from March 8, 2022.