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Privacy Policy

PRIVACY AND COOKIES POLICY TWO-COLOURS

Use of the website https://two-colours.com/ implies acceptance of the following terms of the Privacy Policy and Cookies Policy.

As a User, familiarize yourself with its provisions. The table of contents below will help you do so. In it, we inform you about how we take care of Users' data, how we process it, to whom we entrust it and many other important issues related to personal data.

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§1 GENERAL PROVISIONS

This Privacy Policy and Cookies Policy sets out the rules for the processing and protection of personal data provided by Users and the policy of Cookies, as well as other technologies appearing on the website https://two-colours.com/.

The administrator of the website and personal data transmitted within it is TWO COLOURS AGENCY limited liability company with registered office in Krakow (31-234), Kuźnica Kołłątajowskiej 23g/48, registered in the Register of Entrepreneurs of the National Court Register under KRS: 0000763942, NIP: 5482712930, REGON: 382113461, share capital in the amount of PLN 10,000.00, according to the information corresponding to the current copy from the Register of Entrepreneurs contained in the Central Information of the National Court Register.

We care about the security of personal information and the privacy of the Site Users. We are glad that you have visited our Site.

If you have any concerns regarding the provisions of this Privacy Policy and the Cookies Policy, please contact the Administrator via e-mai kontakt@dwa-kolory.pl.

The Administrator reserves the right to make changes to the privacy policy, and each User of the Site is obliged to know the current privacy policy. The reason for changes may be the development of Internet technology, changes in generally applicable law or the development of the Site through, for example, the use of new tools by the Administrator. At the bottom of the page you will find the date of publication of the current Privacy Policy.

§2 DEFINITIONS

Administrator - TWO COLOURS AGENCY limited liability company with registered office in Krakow (31-234), Kuźnica Kołłątajowska 23g/48, entered in the Register of Entrepreneurs of the National Court Register under KRS: 0000763942, NIP: 5482712930, REGON: 382113461, share capital in the amount of PLN 10,000.00 ZŁ, according to the information corresponding to the current copy from the Register of Entrepreneurs contained in the Central Information of the National Court Register, represented by Dawid Kotrys - President of the Board.

User - Any entity residing on and using the site.

Website- website located at https://two-colours.com/.

Newsletter - means a free service provided electronically by the Administrator to the User by sending electronic letters (e-mails) through which the Administrator informs the User about events, services, products and other items relevant to the Administrator and / or for the purpose of fulfilling the Administrator's legitimate purpose, which is direct marketing. For detailed information on the dispatch of the Newsletter, please refer to the following section of this privacy policy.

Form or Forms - Places on the Site that allow the User to enter personal data, for the purposes indicated therein, e.g., to send the Newsletter, to place an order, to contact the User.

RODO - means Regulation EU 2016/679 of the European Parliament and of the Council of April 27, 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).

Personal Data Protection Act - Act of May 10, 2018 on the protection of personal data (Journal of Laws 2018, item 1000, as amended).

Law on provision of electronic services - Act of July 18, 2002 on providing services by electronic means (Journal of Laws No. 144, item 1204, as amended).

Telecommunications Law - Act of July 16, 2004. Telecommunications Law (Journal of Laws 2004 No. 171 item 1800, as amended).

§3 PERSONAL DATA AND PRINCIPLES OF THEIR PROCESSING

WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

The Administrator of the User's personal data is TWO COLOURS AGENCY limited liability company based in Krakow (31-234), Kuźnica Kołłątajowska 23g/48, registered in the Register of Entrepreneurs of the National Court Register under KRS: 0000763942, NIP: 5482712930, REGON: 382113461, share capital in the amount of PLN 10,000.00 PLN, according to the information corresponding to the current copy from the Register of Entrepreneurs contained in the Central Information of the National Court Register.

IS THE PROVISION OF DATA VOLUNTARY? WHAT ARE THE CONSEQUENCES OF NOT PROVIDING THEM?

Provision of data is voluntary, however, failure to provide certain information, as a rule marked as mandatory on the Administrator's pages, will be associated with the inability to perform a given service and achieve a certain purpose or take certain actions.

Provision by the User of data that is not mandatory or excess data that the Administrator does not need to process is based on the decision of the User himself leads to a situation where processing is carried out on the basis of the premise contained in Article 6(1)(a) of the RODO (consent). The User gives his consent to the processing of such data and to the anonymization of data that the Administrator does not require and does not want to process, but the User nevertheless provided it to the Administrator.

FOR WHAT PURPOSES AND ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA PROVIDED AS PART OF YOUR USE OF THE SITE?

The User's personal data on the Administrator's Site may be processed for the following purposes and on the following legal grounds:

  1. To provide a service or perform a concluded contract, to send an offer (e.g. advertising) at the request of the User - on the basis of Article 6(1)(b) of the DPA (necessity to conclude and/or perform a contract or to take action upon request);
  2. To issue an invoice, bill and fulfill other obligations under tax law- Based on Article 6(1)(c) of the RODO (legal obligation);
  3. in order to send the Newsletter - on the basis of Article 6(1)(f) of the RODO (the administrator's legitimate interest in processing data for direct marketing purposes) and on the basis of the Act on the Provision of Electronic Services (consent);
  4. inform about promotions and interesting offers of the Administrator or entities recommended by the Administrator - Based on Article 6(1)(a) of the RODO (consent);
  5. establish, assert or defend against claims - Based on Article 6(1)(f) RODO (legitimate interest of the administrator);
  6. telephone contact in matters related to the implementation of the service - Based on Article 6(1)(b) of the RODO (necessary for the conclusion and/or performance of the contract);
  7. telephone contact for the purpose of providing offers and direct marketing - on the basis of Article 6(1)(a) RODO (consent) and on the basis of Article 6(1)(f) RODO (legitimate interest of the administrator), if you are already our customer;
  8. Create records related to RODO and other regulations - based on Article 6(1)(c) of the RODO (legal obligation) and Article 6(1)(f) of the RODO (legitimate interest of the administrator);
  9. analytical, consisting, among other things, in the analysis of data collected automatically when using the website, including cookies, e.g. Google Analytics cookies, Facebook Pixel - on the basis of Article 6(1)(f) RODO (legitimate interest of the administrator);
  10. use of cookies on the Site and its subpages - Based on Article 6(1)(a) of the RODO (consent);
  11. satisfaction surveys on services offered - Based on Article 6(1)(f) RODO (legitimate interest of the administrator);
  12. posting of opinions about services by the User provided by Administrator- Based on Article 6(1)(a) of the RODO (consent);
  13. Management of the Website and the Administrator's pages on other platforms - Based on Article 6(1)(f) RODO (legitimate interest of the administrator);
  14. in order to tailor the content displayed on the Administrator's websites to individual needs and to continuously improve the quality of the services offered - Based on Article 6(1)(f) RODO (legitimate interest of the administrator);
  15. For the purpose of direct marketing to you of your own products or services or recommended products of third parties - Based on Article 6(1)(f) RODO (legitimate interest of the administrator);
  16. In order to create their own User databases - Based on Article 6(1)(f) RODO (legitimate interest of the administrator);
  17. In order to operate a fanpage under the name: Two Colours Agency On Facebook and interact with users - Based on Article 6(1)(f) RODO (legitimate interest of the administrator);
  18. in order to operate an account on LinkedIn under the name Two Colours Agency and interacting with users - Based on Article 6(1)(f) RODO (legitimate interest of the administrator);
  19. for the purpose of processing, capturing and disseminating the customer's image  - Based on Article 6(1)(a) of the RODO (consent);
  20. For targeting advertising on social media and websites, such as Facebook Leads Ads or Facebook Custom Audience and remarketing targeting -. on the basis of Article 6(1)(a) of the RODO (consent) and on the basis of Article 6(1)(f) of the RODO (legitimate interest of the Administrator) consisting in the promotion and advertising of the Administrator's services through remarketing directed to persons subscribed to the mailing or visitors to the relevant website).

Provision by the User of data that is not mandatory or excess data that the Administrator does not need to process is based on the User's own decision, in which case the processing takes place on the basis of the premise contained in Article 6(1)(a) of the RODO (consent). The User gives consent to the processing of such data and to the anonymization of data that the Administrator does not require and does not want to process, but the User has nevertheless provided to the Administrator.

HOW IS THE DATA COLLECTED?

Only the data that the User himself/herself provides is collected and processed (with the exception - in certain situations - of data collected automatically through cookies and login data, as discussed below).

When you visit the site, data on the visit itself is automatically collected, such as your IP address, domain name, browser type, operating system type, etc. (login data). Data collected automatically can be used to analyze User behavior on the website, collect demographic data about Users, or to personalize the content of the website in order to improve it. However, this data is processed only for the purposes of administering the site, providing efficient hosting services, or targeting marketing content, and is not associated with the data of individual Users. You can read more about cookies later in this policy.

Data may also be collected for the purpose of filling out forms on the Site, as discussed further in the privacy policy.

WHAT ARE THE USER RIGHTS?

The user is entitled at any time to the rights contained in Articles 15- 21 of the RODO, i.e.:

  • The right to access the content of his data,
  • The right to data portability,
  • The right to correct data,
  • The right to rectify data,
  • The right to delete data if there is no basis for processing,
  • The right to restrict the processing if it has occurred incorrectly or without legal basis,
  • The right to object to the processing of data on the basis of a legitimate interest of the controller,
  • The right to lodge a complaint to the supervisory authority - the President of the Office for Personal Data Protection (under the terms of the Personal Data Protection Act), if he/she considers that the processing of his/her data is incompatible with the current legal provisions on data protection.
  • The right to be forgotten, if further processing is not provided for by currently applicable laws.

The Administrator notes that these rights are not absolute and do not apply to all processing activities of the User's personal data. This applies, for example, to the right to obtain a copy of the data. This entitlement must not adversely affect the rights and freedoms of others, such as copyright, for example. To learn about the limitations on the User's rights, I refer you to the contents of the RODO.

However, the user always has the right to file a complaint with the supervisory authority.

In order to exercise his/her rights, the User may contact the Administrator via e-mail address: kontakt@dwa-kolory.pl or by letter to the Administrator's place of business address, if provided in this privacy policy, indicating the scope of his/her requests. A response will be provided no later than 30 days from the date of receipt of the request and its justification, unless an extension of this period is justified in accordance with the RODO.

CAN A USER REVOKE HIS/HER CONSENT?

If the User has consented to a certain action, such consent may be withdrawn at any time, which will result in termination of the processing of personal data processed by the Administrator on the basis of consent (e.g., in the case of the Newsletter, removal of the e-mail address from the Administrator's mailing list) and cessation of the indicated actions. Withdrawal of consent shall not affect the processing of data performed on the basis of consent before its withdrawal.

In some cases, the data may not be completely deleted and will be retained to defend against possible claims for a period of time in accordance with the provisions of the Civil Code Act or, for example, to comply with legal obligations imposed on the Administrator.

Each time, the Administrator will refer to the User's request, adequately justifying further actions arising from legal obligations.

DO WE TRANSFER YOUR DATA TO THIRD COUNTRIES?

User data may be transferred outside the European Union - to third countries.

Due to the fact that the Administrator uses third-party providers of various services, e.g. Facebook and subsidiaries, Google, OpenAI Ireland Ltd. etc., your data may be transferred to the United States of America (US) in connection with its storage on US servers (in whole or in part). Google, Facebook and OpenAI use the compliance mechanisms provided by the RODO (e.g. certificates) or standard contractual clauses for their services.They will only be transferred to recipients that guarantee the highest data protection and security, including by:

  1. cooperation with processors of personal data in countries for which a relevant decision of the European Commission has been issued,
  2. Use of standard contractual clauses issued by the European Commission,
  3. application of binding corporate rules approved by the relevant supervisory authority,

or to those whose personal data the User has consented to the transfer of.

Detailed information is available in the content of the privacy policy of each provider of these services, available on their websites. For example:

Google LLC: https://policies.google.com/privacy?hl=pl

Facebook Ireland Ltd: https://www.facebook.com/privacy/explanation

Eleven Labs Ltd. and Eleven Labs Poland sp. z o.o.: https://openai.com/policies/eu-terms-of-use/

ElevenLabs: https://elevenlabs.io

Currently, the services offered by Google, Facebook and OpenAI are mainly provided by entities located in the European Union. You should, however, each time read the privacy policies of these providers in order to receive up-to-date information on data protection.

HOW LONG DO WE KEEP USER DATA?

The User's data will be kept by the Administrator for the duration of the performance of the individual services/achievement of objectives and:

  1. for the period of service performance and cooperation, as well as for the period of the statute of limitations for claims under the law - with respect to data provided by contractors and customers or Users,
  2. for the period of discussions and negotiations preceding the conclusion of a contract or the performance of a service - with regard to the data provided in the request for proposal,
  3. for the period required by law, including tax law - for personal data involving compliance with obligations under applicable regulations,
  4. until such time as an effective objection is lodged under Article 21 RODO - with respect to personal data processed on the basis of the controller's legitimate interests, including for direct marketing purposes,
  5. until the withdrawal of consent or the achievement of the purpose of processing, business purpose - with regard to personal data processed on the basis of consent. After the withdrawal of consent, the data may still be processed for the purpose of defense against possible claims in accordance with the statute of limitations for such claims or the period (shorter) indicated to the User,
  6. for a period of up to 3 years in the case of persons who have unsubscribed from the newsletter for the purpose of defense against possible claims (e.g. information about the date of subscription and the date of unsubscribing from the newsletter, the number of newsletters received, actions taken and activity related to the messages received), or after a period of 1 year of lack of any activity by a given subscriber, e.g. not opening any message from the Administrator.
  7. Until obsolete or no longer useful - with respect to personal data processed primarily for analytical, statistical, cookie usage and administration of the Administrator's Sites.

Data retention periods indicated in years are counted at the end of each year in which data processing began. This is intended to streamline data processing and management.

Detailed processing periods of personal data, pertaining to individual processing activities, are found in the Register of Processing Activities and the Register of Categories of Processing Activities of the Administrator.

LINKS TO OTHER SITES

Links referring to other websites may appear on the Site. They will open in a new browser window or in the same window. The Administrator is not responsible for the content provided by these sites. The user is obliged to read the privacy policy or terms and conditions of these sites.

SOCIAL MEDIA ACTIVITY - FACEBOOK

The Administrator is the administrator of the User's personal data on the Facebook fanpage under the name "Two Colours Agency" on Facebook (hereinafter Fanpage).

The User's personal data provided on Fanpage will be processed for the purpose of administering and managing Fanpage, communicating with the User, interacting with the User, directing marketing content to the User and creating a Fanpage community.

Data processed under the Administrator's business account may be processed under the relevant personal data processing entrustment agreements.

The basis for their processing is the User's consent and the Administrator's legitimate interest in interacting with Users and Fanpage Observers. The User voluntarily chooses to like/observe the Fanpage.

The rules of the Fanpage are set by the Administrator, however, the rules of staying in the social network Facebook are based on the rules of Facebook.

At any time, the User may stop observing the Fanpage. However, the Administrator will not then display to the User any content coming from the Administrator and related to the Fanpage.

The Administrator sees the User's personal data, such as, for example, first name, last name or general information, which the User posts on his/her profiles as public. The processing of other personal data is carried out by the social network Facebook and under the terms of its regulations.

The User's personal data will be processed for the period of running/existence of the Fanpage based on the consent given by liking/clicking "Observe" the Fanpage or interacting, e.g. leaving a comment, sending a message, and for the purpose of realizing the Administrator's legitimate interests, i.e. marketing its own products or services or defending against claims.

User's personal data may be shared with other data recipients, such as Facebook, cooperating advertising agencies or other subcontractors operating the Administrator's Fanpage, IT service, virtual assistant, if there is contact outside Facebook.

Other rights of the User are described in this privacy policy.

User data may be transferred to third countries in accordance with Facebook's regulations.

The data may also be profiled, which helps to better personalize the advertising offer directed to the User. However, they will not be processed in an automated manner within the meaning of the RODO (having a negative impact on the User's rights and freedoms).

The administrator recommends reading both Facebook's terms and conditions: https://www.facebook.com/legal/terms.

SOCIAL MEDIA ACTIVITY - LINKEDIN

The Administrator is the administrator of the User's personal data on LinkedIn on the account "Two Colours Agency" (hereinafter referred to as LinkedIn account).

The personal information you provide on your LinkedIn account will be processed for the purposes of administering and managing your account, communicating with you, interacting with you, targeting you with marketing content and creating a community.

The basis for their processing is the User's consent and the Administrator's legitimate interest in interacting with Users and Observers of the LinkedIn account. The User voluntarily chooses to like content/observe the LinkedIn account.

The rules of the LinkedIn account are set by the Administrator, however, the rules of being on the LinkedIn social network are derived from LinkedIn's rules and regulations.

At any time, the User may stop observing the LinkedIn account belonging to the Administrator. However, the Administrator will not then display to the User any content originating from the Administrator and related to the LinkedIn account "Two Colours Agency".

The Administrator sees the User's personal data, such as, for example, first name, last name and general information, which the User posts on his/her profiles as public. The processing of other personal data is carried out by the social network LinkedIn and under the terms of its regulations.

The User's personal data will be processed for the period of maintenance/existence of the LinkedIn account based on the consent given by liking the content/clicking "Observe" or interacting, e.g. leaving a comment, sending a message, and for the purpose of realizing the Administrator's legitimate interests, i.e. marketing its own products or services or defending against claims.

Your personal data may be shared with other data recipients, such as the LinkedIn portal, cooperating advertising agencies or other subcontractors servicing the Administrator's LinkedIn account, IT service, virtual assistants, if contact is made outside the LinkedIn portal.

Other rights of the User are described in this privacy policy.

Administrator zaleca zapoznanie się z polityką prywatności LinkedIn: https://www.linkedin.com/legal/privacy-policy?src=li-other&veh=www.linkedin.com%7Cli-other.

DATA SECURITY

The User's personal information is stored and protected with due care, in accordance with the Administrator's implemented internal procedures. The Administrator processes User information using appropriate technical and organizational measures that meet the requirements of generally applicable laws, in particular the regulations on personal data protection. These measures are primarily aimed at securing the Users' personal data from access by unauthorized persons.

In particular, only authorized persons who are obliged to keep the data confidential or entities entrusted with the processing of personal data under a separate data entrustment agreement have access to Users' personal data.

At the same time, the user should be diligent in securing his/her personal data transmitted over the Internet, in particular, do not disclose his/her login information to third parties, use anti-virus protection and keep software up-to-date.

WHO MAY BE THE RECIPIENTS OF PERSONAL DATA?

The Administrator informs that he uses the services of external entities. Entities to which it entrusts the processing of personal data (such as, for example, courier companies, companies mediating electronic payments, companies offering accounting services, companies enabling the sending of newsletters) guarantee the application of appropriate measures for the protection and security of personal data required by law, in particular by the RODO.

The Administrator informs the User that he entrusts the processing of personal data to, among others, the following entities:

  1. ActiveCampaign, LLC ("ActiveCampaign") 1 North Dearborn St 5th Floor Chicago, IL 60602 - for the purpose of sending newsletters and using the mailing system
  2. "FINANSE 4D" Sp. z o.o., 7 Łaciarska Street, 50-104 Wrocław, KRS: 0000389149, NIP: 8992721208 - for the purpose of issuing accounting documents,
  3. Fakturownia Sp. z o.o., 6/8 Juliana Smulikowskiego St., 00-389 Warsaw, KRS: 0000572426, NIP 5213704420- to operate the invoicing system,
  4. Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (Google LLC) - for the use of Google services, including Gsuite,
  5. H88 joint-stock company, 22 Franklin Roosevelt Street, 60-829 Poznań, KRS: 0000612359, NIP: 7822622168 - the entity providing services to operate the domain and mail server,
  6. OpenAI Ireland Ltd., 10 Earlsfort Terrace, Dublin, D02 T380, Ireland - for the use of AI services, including data processing via API,
  7. other contractors or subcontractors engaged to provide technical, administrative, or legal assistance to the Administrator and its clients, e.g., courier companies, IT assistance, graphic design, copywriting, collection agencies, lawyers, etc.
  8. Offices, e.g., the tax office - in order to fulfill legal and tax obligations related to billing and accounting.

HAVE WE APPOINTED A DATA PROTECTION OFFICER?

The Personal Data Controller hereby informs that he has not appointed a Data Protection Officer (DPO) and performs the duties related to the processing of personal data independently.

The User acknowledges that his/her personal data may be transferred to authorized state authorities in connection with their proceedings, at their request and upon fulfillment of the prerequisites confirming the necessity of obtaining such data from the Administrator.

DO WE PROFILE YOUR DATA?

The User's personal data will not be used for automated decision-making affecting the User's rights and obligations or freedoms within the meaning of the RODO.

As part of the website and tracking technologies, the User's data may be profiled, which helps to better personalize the company's offerings that the Administrator directs to the User (mainly through so-called behavioral advertising). However, this should not have any impact on the User's legal situation, in particular on the terms of the contracts he has entered into or the contracts he intends to enter into. It can only help to better match the content and targeted advertising to the User's interests. The information used is anonymous and is not associated with personal data provided by the User, e.g. during the purchase process. They are derived from statistical data e.g. gender, age, interests, approximate location, behavior on the Site.

Each User has the right to object to profiling if it would adversely affect the User's rights and obligations.

More about behavioral advertising: https://www.youronlinechoices.com/pl/o-reklamie-behawioralnej

§4 FORMS

The Administrator uses the following types of forms on the Site:

1. Newsletter subscription form - requires you to enter your name and email address in the appropriate place. These fields are mandatory. Then the User, in order to add his e-mail address to the Administrator's subscriber database, must confirm his desire to subscribe. The data thus obtained is added to the mailing list for sending the Newsletter.

Subscription/subscribing means that the User agrees with this Privacy Policy and consents to the sending of marketing and commercial information to him/her by means of electronic communication, e.g. e-mail, within the meaning of the Act of July 18, 2002 on the provision of electronic services (Journal of Laws No. 144, item 1204, as amended).

By signing up for the Newsletter, the User also consents to the Administrator's use of the User's telecommunications terminal equipment (e.g. phone, tablet, computer) for the purpose of direct marketing of the Administrator's products and services and presentation of commercial information to the User in accordance with Article 172(1) of the Telecommunications Law (Journal of Laws of 2014, item 243, as amended).

The above consents are voluntary, but necessary for sending the Newsletter, including but not limited to information about services, new blog posts, products, promotions and discounts offered by the Administrator or third party products recommended by the Administrator. Consents may be withdrawn at any time, which will result in the discontinuation of sending the Newsletter in accordance with the rules contained in this Privacy Policy.

The newsletter is sent for an indefinite period of time, from the moment of activation until the withdrawal of consent. After the withdrawal of consent, the User's data may still be stored in the newsletter database for up to 3 years, in order to demonstrate the fact that the User has given his/her consent to communication through the newsletter, the User's actions (e-mail openings) and the moment of withdrawal, as well as possible related claims, which constitutes the Administrator's legitimate interest (Article 6(1)(f) RODO).

Sending of the Newsletter may be discontinued in case of the User's failure to show activity for a minimum of 1 year from the start of the Newsletter service or to read the last e-mail message (sent Newsletter). In such a case, the Administrator will remove the User's data from the Newsletter dispatching system (provider). The User will not be entitled to receive any message from the Administrator, unless the User decides to re-subscribe in the Newsletter subscription form or contacts the Administrator in another way chosen for this purpose.

The mailing system used to send the Newsletter records all activity and actions taken by the User related to the e-mails sent to him/her (date and time of opening the message, clicking on links, the moment of unsubscribing, etc.).

The Administrator may also conduct remarketing on the basis of Article 6(1)(f) of the RODO (legitimate interest of the Administrator, consisting of promotion and advertising of services directed to persons subscribed to the newsletter, in such a way that the given e-mail addresses of subscribers are uploaded to the marketing tool offered by Facebook Inc. the so-called advertising manager, and then an advertisement created by the Administrator or authorized persons is directed to them, through the Administrator's advertising account, provided that newsletter subscribers are also users of the Facebook platform (they have an account set up there). Each time the data is deleted after the advertising campaign is completed. In the case of implementation of the next advertising campaign, an updated subscriber base is uploaded to the tool). Detailed information about the so-called non-standard groups of recipients, the rules of data hashing and processing of this data can be found in Facebook's privacy policy at this link https://www.facebook.com/legal/terms/customaudience# and https://www.facebook.com/legal/terms/dataprocessing, and the Administrator recommends that each User and subscriber familiarize themselves with these rules.

Facebook ads may also be directed from the Administrator's business account on the basis of separate personal data processing entrustment agreements.

2. contact form - allows you to send a message to the Administrator and contact the Administrator electronically. Personal data in the form of name, surname, e-mail address, telephone number and data provided in the content of the message, are processed by the Administrator in accordance with this Privacy Policy in order to contact the User.

After the end of contact with you, data may be archived, which is a legitimate interest of the Administrator. The Administrator is unable to determine the exact period of archiving and thus deletion of messages. However, the maximum period will not be longer than the statute of limitations for claims under the law.

The Administrator may entrust the processing of personal data to third parties without the separate consent of the User (on the basis of an entrustment agreement). Data obtained from forms may not be transferred to third parties.

If you use third-party providers such as Google, you should read their privacy policies, available from the providers of these services on their websites.

§5 DISCLAIMER AND COPYRIGHT

  1. The content presented on the Site does not constitute expert advice or guidance (e.g. educational) and does not relate to a specific factual situation. If a User wishes to obtain assistance on a specific matter, he or she should contact a person authorized to provide such advice or the Administrator at the contact information provided. The Administrator is not responsible for the use of the content of the Site or actions or inactions taken on the basis of such content.
  2. All content posted on the Site may be subject to the copyrights of certain individuals and/or the Administrator (e.g. photos, texts, other materials, etc.). The Administrator does not consent to copying such content in whole or in part without its express prior consent.
  3. The Administrator hereby informs the User that any dissemination of the content provided by the Administrator constitutes a violation of the law and may give rise to civil or criminal liability. The Administrator may also demand appropriate compensation for any material or immaterial damages in accordance with applicable laws.
  4. The administrator is not responsible for the use of materials available on the site in an unlawful manner.
  5. Content posted on the Site is current as of the date of posting, unless otherwise indicated.

§6 TECHNOLOGIES

In order to use the Administrator's website, it is necessary to have:

  1. Devices with access to the Internet
  2. An active email inbox that receives emails
  3. A web browser capable of displaying web pages
  4. Software capable of reading content in the presented formats, e.g. pdf., video, mp3, mp4.

§7 COOKIE POLICY

  1. Like most websites, the Administrator's Site uses so-called tracking technologies, i.e. cookies ("cookies") which enables the Site to improve the needs of its visitors.
  2. The site does not automatically collect any information, except for the information contained in cookies.
  3. Cookies (so-called "cookies") are IT data, small text files that are stored on a terminal device, e.g. computer, tablet, smartphone, when a User uses the Administrator's Website.
  4. These may be the Administrator's own cookies (coming directly from the Administrator's Website) and third-party cookies (coming from websites other than the Administrator's Website).
  5. Cookies allow the content of the Administrator's Website to be customized to the individual needs of the User and the needs of other Users visiting the Website. They also make it possible to create statistics that show how Users use the Website and how they navigate through it. This allows the Administrator to improve the Website, its content, structure and appearance.
  6. The Administrator uses the following third-party cookies on the Site:

(a) Facebook conversion pixel and ads created through Facebook Facebook Ads (Facebook Custom Audiences). - in order to manage Facebook ads and conduct remarketing activities, which is a legitimate interest of the Administrator. The Administrator may also target advertising content to the User through the Facebook portal as part of contact ads.

The Facebook Pixel tool is provided by Facebook Inc. and its affiliates. It is an analytical tool that helps measure the effectiveness of ads, shows what actions Site Users take and helps reach a specific group of people (Facebook Ads, Facebook Insights). The Administrator may also target advertising content to the User through the Facebook portal as part of contact ads.

The Administrator may also conduct remarketing on the basis of Article 6(1)(f) of the RODO (the Administrator's legitimate interest in promoting and advertising services directed to persons who have agreed to send offers (or persons similar to them or users who have liked the Fanpage) in such a way that the e-mail addresses provided are uploaded to a marketing tool offered by Facebook Inc. the so-called advertising manager, and then advertising created by the Administrator or authorized persons is directed to them, through the Administrator's advertising account, provided that these persons are also users of the Facebook platform (they have an account set up there). Each time this data is deleted after the advertising campaign is completed. In the case of implementation of the next advertising campaign, an updated contact database is uploaded to the tool). Precise information about the so-called non-standard groups of recipients, the rules of data hashing and processing of this data can be found in the privacy policy of Facebook at this link https://www.facebook.com/legal/terms/customaudience# and https://www.facebook.com/legal/terms/dataprocessing, and the Administrator recommends that each User familiarizes himself with these rules.

The information collected through the use of Facebook Pixel is anonymous and does not identify the User. They show general data about Users: location, age, gender, interests. The Facebook Provider may combine this information with the information that the User provides to it within the framework of his or her Facebook account, and then use it in accordance with its own assumptions and purposes.

The administrator recommends reviewing the details related to the use of the Facebook Pixel tool and possibly asking questions of the tool's provider, as well as managing your Facebook privacy settings. For more information, see the link: https://www.facebook.com/privacy/explanation. At any time you can opt out of cookies responsible for displaying remarketing ads, e.g. on https://www.facebook.com/help/1075880512458213/.

By using the site, the user agrees to the installation of the indicated cookie on his/her terminal device.

(b) Google Analytics embedded code -. In order to analyze the statistics of the Site. Google Analytics uses its own cookies to analyze the activities and behaviors of Site Users. These cookies are used to store information, such as which page a User came from to the current website. They help to improve the Site.

This tool is provided by Google LLC. The actions taken in the use of the Google Analytics code are based on the legitimate interest of the Administrator to create and use statistics, which then enables the improvement of the Administrator's services and optimization of the Site.

As part of the use of the Google Analytics tool, the Administrator does not process any identifiable User data.

The administrator recommends reading the details related to the use of the Google Analytics tool, the possibility of disabling the tracking code and possibly asking questions to the provider of this tool at the link: https://support.google.com/analytics#topic=3544906.

(c) Social media referral plugins e.g. Facebook, LinkedIn.

The user, after clicking on the icon of a given plug-in, is sent to the site of an external provider, in this case the owner of a given social network, such as Facebook. He then has the option of clicking "Like" or "Share" and liking the Administrator's fanpage, located on Facebook, or directly sharing its content (post, article, video, etc.).

The administrator recommends reading Facebook's privacy policy before creating an account on this portal. The Administrator has no influence on the data processed by Facebook. From the moment the User clicks on the button of the social media referral plug-in, personal data is processed by the social network, e.g. Facebook, which also becomes its controller and decides the purposes and scope of its processing. Cookies left by the Facebook plug-in (or other third parties) may also be applied to the User's device upon entering the Site and then associated with data collected on the Facebook portal. By using the Site, the User accepts this fact. The Administrator has no influence on the processing of data by third parties in this way.

Facebook - fanpage located at URL: https://www.facebook.com/TwoColoursAgency,

The above tips should also be applied to service:

Accounts on LinkedIn located at the URL:

https://www.linkedin.com/company/two-colours-agency.

d) Tools for evaluating the effectiveness of Google Ads campaigns -. for the purpose of advertising and remarketing campaigns, which is a legitimate interest of the Administrator.

The Administrator does not collect any data that would allow identification of the User's personal information. The Administrator recommends reading Google's privacy policy to learn the details of how these features work and how to disable them, if necessary, from the User's browser.

Google Ads policies can be found at the URL:

https://support.google.com/adspolicy/answer/6008942?hl=pl

(e) Web push notifications, from the browser -. in order to better communicate with the User and provide him/her with valuable content or offers faster, the Administrator allows the User to agree to receive web push notifications from the User's browser.

In order to agree to receive web push notifications, the User should select "display notifications" or a close equivalent option on the message sent by their web browser (each browser may call this option differently).

Consent to receive the aforementioned notifications may be revoked at any time by changing the User's browser settings. The Administrator does not process any personal data of Users who use web push notifications. Users are identified solely on the basis of information that is stored by their web browsers, to which the Administrator does not have access.

(f) Online calendar

The Administrator, in order to allow the User to sign up for a free consultation, provides an online calendar through tools provided by third-party providers: appoint.ly and calendly, along with a form to facilitate the enrollment of the consultation. In this form, the User indicates his/her data: first name, last name, email address, phone number.

These entities use cookies. Please refer to the privacy policy for details:

https://appoint.ly/privacy-policy and https://calendly.com/pages/privacy.

  1. Again, the Administrator recommends reviewing the privacy policy of each of the providers of the above services in order to learn about the possibility of making changes and settings to ensure the protection of your rights.
  2. The site uses two types of cookies: session cookies, which are deleted after closing the browser, logging out or leaving the website, and permanent cookies, which are stored on the user's terminal device, allowing the browser to recognize them the next time the user accesses the site, for the time specified in the parameters of the cookies or until they are deleted by the user.
  3. In many cases, web browsing software (Internet browser) allows cookies to be stored on the User's terminal device by default. Users of the Website may change their settings regarding cookies at any time. These settings can be changed, in particular, in such a way as to block the automatic handling of cookies in the settings of the web browser or inform on their each time they are placed on the device of a User of the Website. Detailed information about the possibility and methods of handling cookies is available in the settings of your software (web browser).
  4. The Administrator informs that restrictions on the use of cookies (disabling them, limiting them) may affect some of the functionalities available on the Website and hinder its operation.
  5. More information about cookies is available at      http://wszystkoociasteczkach.pl/ or in the "Help" section of your web browser menu.

§8 CONSENT TO COOKIES

When entering the Site for the first time, the User must consent to cookies or take other possible actions indicated in the message in order to continue using the content of the Site. Using the Site implies consent. If the User does not want to give such consent - he/she should leave the Site. Also, he can always change his browser settings, disable or delete cookies. The "help" tab of the User's browser contains the necessary information.

§9 SERVER LOGS

  1. Use of the Site involves sending requests to the server on which the Site is stored.
  2. Each request made to the server is recorded in the server logs. The logs include, among other things, the User's IP address, the date and time of the server, information about the Internet browser and the operating system used by the User.
  3. Logs are saved and stored on the server.
  4. Server logs are used for the administration of the Site, and their contents are not disclosed to anyone other than persons and entities authorized to administer the server.
  5. The Administrator does not use server logs in any way to identify the User.

Date of publication of the Privacy Policy: 10.09.2020

Date of last update: 10.06.2021