PRIVACY POLICY
This privacy policy applies to all aspects of the processing of personal data in the portal (hereinafter referred to as “PORTAL”) located at www.ecomfly.ai, operated by Advisly Hubert Misiąg, with its registered office at ul. Reymonta 3A in Jarosław (37-500 Jarosław), hereinafter referred to as the “ADMINISTRATOR”, with whom you can in all matters related to your personal data contact us at the head office or by e-mail at kontakt@ecomfly.ai.
WHAT DATA DO WE PROCESS?
Personal data is all information about a natural person by which he or she can be identified. During the use of the Portal, the User may be asked to provide selected personal data, e.g. by: entering information in the so-called “Chatbot” (located in the lower right corner of the Portal); registration on the portal, on the basis of which the Customer's account is created; entering the data necessary to purchase a subscription; saving Subscribers of the Newsletter, identified by email address, in the database and sending them an information newsletter (details of this processing are described below in the Rules of operation of the Newsletter); subscribing to offered trainings and courses; adding a comment under an article on the Blog — the User provides his data in the following scope: name, e-mail address, optionally the address of the website and the content of the comment, in addition, the IP address and the date and time of publication of the comment are saved; saving and storing files (so-called cookies) in the memory of the device used by the User to browse the Portal, cookies allow the identification of Users on subsequent visits However, they do not allow the Administrator to identify a specific person the physical person who used the device at that time (details of this processing are described in the Cookies Policy below; The provider of the Chatbox service is Tidio Poland Sp. z o. o. with its registered office in Szczecin, ul. Wojska Polskiego 81 (70-481, Szczecin, Poland), which is a separate administrator of personal data transmitted through this tool. The full content of the information obligation of the Chatbox provider is available
herein.
Any personal data entered is processed in a manner that complies with the requirements laid down by law, and in particular with the Regulation (EU) of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (“GDPR”).
PURPOSE OF PROCESSING
The purpose of processing your personal data is:in the case of the data of Users using the so-called “Chatbot” — to respond to the sent message or present the Administrator's offer of products and services, based on the consent expressed by sending the message, in accordance with Article 6 (1) (a) of the GDPR, later the data may also be processed for other purposes outside the Portal, about which the User will be informed accordingly; in the case of data of Users registering on Portal — creation of an account, based on the consent expressed by checking the checkbox, in accordance with Article 6 (1) (a) of the GDPR; in the case of data of Users purchasing subscriptions — its payment and activation for the User of other possibilities of the Portal, on the basis of consent expressed in accordance with Article 6 (1) (a) of the GDPR; in the case of data of Newsletter subscribers — sending them the requested commercial information, based on the consent expressed by saving the email address, in accordance with Article 6 (1) lit. a GDPR; in the case of data of Users who enroll in the offered trainings and courses — to enable them to be purchased; and granting access to them, on the basis of consent expressed in accordance with Article 6 (1) (a) of the GDPR; in the case of Users adding comments under an article on the Blog — their publication and moderation of the content of the comment, including possible contact with the User, in order to determine its final content, which constitutes a legitimate interest of the administrator, in accordance with Article 6 (1) (f) of the GDPR; in the case of cookies - the purposes of their storage described are the Cookies Policy below, based on the legitimate interest of the administrator, in accordance with Article 6 (1) (f) GDPR or the User's consent for certain more privacy-intrusive uses, which at the same time constitute the convenience of Users, as granted in accordance with Article 6 (1) (a) of the GDPR.
PERIOD OF PROCESSING OF PERSONAL DATA
We will process your personal data for the following periods: in the case of data processed on the basis of previously granted consent - until its withdrawal; in the case of data of Newsletter Subscribers - until they withdraw their consent in a documented manner to their processing (the standard mode of withdrawal of consent is described below in the Rules of operation of the Newsletter); in the case of data saved in connection with the publication and moderation of the content of the comments — until its publication or until the limitation of any claims arising from its in the case of cookies — the processing time depends on their type and on the User, as described in the Cookies Policy below.
TO WHOM DO WE TRANSFER PERSONAL DATA?
Your personal data may be transferred to: technical service providers performing the service of publishing and distributing our Newsletter; entities to whom the administrator has a legal obligation to provide personal data processed by them — including state bodies; entities processing personal data on behalf of the Administrator, including, among others, Chatbot service providers, IT companies, consulting or audit entities, whereas such entities process data on the basis of a contract with the controller;
PROFILING
Each Newsletter contains a randomly assigned ID. On the basis of this identification, we can determine whether and when the Newsletter was opened and which links were clicked and on this basis create pseudonymised user profiles. By clicking on the link in the Newsletter, we link this usage profile based on cookie technology with pseudonymous usage profiles that appear when you use the Online Store (e.g. surfing and shopping). We use this information in the form of a pseudonym in order to unify the personalization of our Newsletter, so that we can, for example, submit offers to you in the newsletter corresponding to the products you are looking for in our online store.
YOUR RIGHTS
Under the provisions of the GDPR, you have (subject to the basis of processing): the right to access your data and receive a copy thereof, the right to rectify (correct) or transfer the data, the right to request the deletion of data or limit their processing, the right to object to the processing, and the right to lodge a complaint with the supervisory authority, i.e. the President of the Office for Personal Data Protection, in case of recognition, that the processing of your personal data violates the provisions of the GDPR, as well as the right to withdraw consent at any time without affecting the the lawfulness of the processing carried out on the basis of consent before its withdrawal. You can withdraw your consent by sending a message to kontakt@ecomfly.ai. The reply will be sent to you to the e-mail address from which the request was sent, and in the case of requests sent by letter, by ordinary letter to the e-mail address indicated by you (unless the content of the letter indicates a desire to receive feedback to the e-mail address).
COOKIE POLICY
The cookies policy applies to both Customers of the Website and Visitors to the Website, i.e. users who view the content of the Website but do not make purchases.The cookie policy is a document that is an integral part of this Privacy Policy.The Website also uses functionalities similar to cookies. Therefore, the individual provisions of the Cookies Policy should also refer to these technologies accordingly. Selected cookies process your personal data. The processing of personal data from cookies or similar technologies on our Website is carried out for the purpose of ensuring the functioning of the Website, adapting the Website to the preferences of the Visitor and the Customer, or for analytical purposes. The processing takes place on the basis of our legitimate interest. The legal basis for the processing of personal data for advertising purposes will be your additional consent, expressed by making a selection and checking the checkbox during the process of giving consent to cookies.When a Visitor uses the Website, cookies are used to identify his/her browser or device — cookies collect various types of information, which in principle do not constitute personal data. However, some information, depending on its content and method of use, may be associated with a specific person — assigning certain behaviors to a specific Visitor or Customer, e.g. by linking it to the data provided when registering an Account on the Website or a specific e-mail address — and thus be considered personal data.In relation to the information collected by cookies, which can be associated with a specific person, the provisions apply Privacy Policy of the Website relating to personal data, in particular concerning the rights of the data subject.The website uses profiling. Thanks to the cookies used on the Website, it is possible for the Administrator to familiarize himself with the preferences of the Visitor/Client — e.g. by analyzing how often they visit the Website and whether and what content they viewed. The analysis of behavior on the Internet helps to better understand the habits and expectations of Customers and Visitors and adapt to their needs and interests. Thanks to this technology, it is possible to present Visitors with advertisements tailored to their needs and interests and to prepare better promotions and surprises for adult Visitors who have agreed to it
.
RULES OF OPERATION OF THE NEWSLETTER
The newsletter “Newsletter” contains, among others, articles concerning the services offered by the Administrator. The subscriber of the Newsletter becomes a person who has provided his email address and name and confirmed it by clicking the “Save” button. Providing email address and name means consent to the processing of personal data in this regard, in order to save them in the database and deliver the Newsletter. Personal data will be stored for the period of subscription to the Newsletter, i.e. until the withdrawal of consent to the processing of data for this purpose. The consent can be effectively withdrawn only in one of the following ways: by clicking on the link of the message containing the greeting of new subscribers of the Newsletter; or by sending a message to the address of the Administrator indicated above. In case of making changes to the Rules of operation of the Newsletter, the Administrator will make available the uniform text by publishing them within the Portal.
Changes to the Rules of the functioning of the Newsletter come into force after 14 days from the date of posting the information about the change.
CHANGE OF PRIVACY POLICY, COOKIE POLICY AND RULES OF OPERATION OF THE NEWSLETTERAny changes to the Privacy Policy, Cookie Policy, Rules of Operation of the Newsletter will be published on the website and will be valid from the date of their publication only for the future.