Privacy & Cookies Policy

We ensure the confidentiality of all data provided to us, protect it from unauthorized access, and implement appropriate security measures and personal data protection as required by data protection regulations.

General Information

1.1. The data controller is Scalever Sp. z o.o., based in Warsaw at ul. Marszałkowska 58/15, 00-545; registered in the business register maintained by the District Court for Warsaw, XII Commercial Division of the National Court Register, under KRS number 0000695565, REGON: 368359144, NIP: 7010718228. If you have any questions regarding the privacy policy, you can contact us at any time by sending a message to info@scalever.com.

1.2. GDPR (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) grants you the following rights related to the processing of your personal data:

• right to access your data and receive a copy of it
• right to rectify (correct) your data
• right to delete data (if you believe there is no basis for us to process your data, you can request its deletion)
• right to restrict data processing (you can request limiting data processing only to storage or performing actions agreed with you)
• right to object to data processing (you have the right to object to data processing based on legitimate interest; you should indicate the specific situation that in your opinion justifies our cessation of processing covered by the objection. We will stop processing your data for these purposes unless we demonstrate that the grounds for processing your data override your rights or that your data is necessary for us to establish, pursue, or defend claims)
• right to data portability (you have the right to receive from us, in a structured, commonly used machine-readable format, the personal data you provided to us based on an agreement or your consent; you can instruct us to send this data directly to another entity)
• right to lodge a complaint with the supervisory authority (if you find that we are processing data unlawfully, you can file a complaint with the President of the Personal Data Protection Office or another appropriate supervisory authority)

The rules related to the implementation of the above rights are described in detail in Articles 16-21 of GDPR. Remember that you can also contact us requesting information about what data we have about you and for what purposes we process it. Simply send a message to info@scalever.com.

1.3. Your personal data may be processed by entities whose services we use. They may have access to your personal data if their services are or may be related to personal data processing, if they provide services in connection with such access. This particularly concerns entities such as hosting providers, email service providers, technical website maintenance service providers, law firms, accounting offices, cloud software providers, etc. Remember that your data is secure and processed only to the necessary extent. Additionally, if necessary, your personal data may be shared with entities, authorities, or institutions authorized to access data under the law, such as police services, security services, courts, prosecutors, as well as tax offices to the extent necessary for tax, settlement, and accounting obligations.

1.4. We transfer your personal data to third countries in connection with using tools that store personal data on servers located in third countries, particularly in the USA. The providers of these tools guarantee an adequate level of personal data protection through appropriate compliance mechanisms provided by GDPR, in particular by joining the Privacy Shield program or using standard contractual clauses. Personal data storage on servers located in third countries occurs within Google services (described in this privacy policy), provided by Google Ireland Limited.

1.5. We use tools that may take certain actions depending on information collected through tracking mechanisms (profiling and behavioral advertising). However, we believe these actions do not significantly affect you as they do not differentiate your situation as a customer or affect the terms of the agreement you may conclude with us.

2. Purposes and Processing Activities of Personal Data

2.1. Contact (email correspondence)

Data processed: name, email address, plus any data contained in the message content (providing data is voluntary but necessary to establish contact)

Processing purpose: establishing contact

Processing period: Correspondence content may be archived, and we cannot definitively determine when it will be deleted.

Legal basis: Article 6(1)(f) GDPR, i.e., our legitimate interest. The legal basis for processing after contact ends is also our justified purpose in archiving correspondence for internal needs.

Rights: You have the right to request the history of correspondence you had with us (if it was archived) and request its deletion unless its archiving is justified due to our overriding interests, e.g., defense against potential claims from you.

2.2. Clients

Data processed: name and surname, email address, phone number, residential address, company name, permanent place of business address, NIP (tax identification) number (providing data is voluntary but necessary to establish contact)

Processing purpose: concluding and performing the agreement, issuing invoices, including invoices in accounting documentation and fulfilling other accounting obligations imposed by law, establishing, pursuing, or defending claims related to the agreement, identifying returning customers, recreating the course of cooperation, exchanged correspondence, prepared documents, etc.

Processing period: Your personal data will be stored for the duration of our business activities unless you object to personal data processing earlier, which will result in data deletion. The objection will be effective after the expiration of the limitation period for claims under the concluded agreement. Until then, your personal data will be necessary for us to potentially establish, pursue, or defend claims.

Legal basis: conclusion and performance of the agreement (Article 6(1)(b) GDPR), issuing invoices, including invoices in accounting documentation and fulfilling other accounting obligations imposed by law (Article 6(1)(c) GDPR), as well as establishing, pursuing, or defending claims related to the agreement, identifying returning customers, recreating the course of cooperation, exchanged correspondence (Article 6(1)(f) GDPR, i.e., our legitimate interest)

Rights: You have the right to access your data and receive a copy, rectify your data, delete it, restrict data processing, object to data processing, and transfer data. Each request will be checked for the possibility of implementing these rights.

2.3. Newsletter

Data processed: name and email address (providing data is voluntary but necessary to subscribe to the newsletter)

Processing purpose: sending newsletters. Our mailing system tracks your actions taken in connection with messages sent to you. Therefore, we have information about which messages you opened, which links you clicked in messages, etc.

Processing period: duration of newsletter service provision and for archival purposes to demonstrate your past consent to receive the newsletter in the future

Legal basis: consent (Article 6(1)(a) GDPR) expressed when subscribing to the newsletter

Rights: You can unsubscribe from the newsletter at any time by clicking the dedicated link in each message sent as part of the newsletter or by simply contacting us. You can rectify your data or object to the processing of your personal data. Due to our legitimate interest (Article 6(1)(f) GDPR), we will not delete your data from the database. Deleting such data would prevent us from demonstrating, if necessary, the fact that you gave consent in the past to receive the newsletter.

2.4. Comments

When adding comments on our site, you use the Disqus system. Using the Disqus system is based on the Disqus terms of service, which you accept as its user. Within the Disqus system, we do not have access to your personal data, except for your nickname defined in the Disqus system and image if available as part of your user account in the Disqus system. The Disqus system provider is an independent controller of your personal data processed within the Disqus system.

3. Cookies

3.1. Cookies and other tracking technologies

Our website uses cookies. Cookies are small text information stored on your end device (e.g., computer, tablet, smartphone) that can be read by our IT system (own cookies) or third-party IT systems (third-party cookies). Some cookies we use are deleted after the end of the browser session, i.e., after closing it (session cookies). Other cookies are stored on your end device and allow us to recognize your browser on the next visit to the site (persistent cookies).

3.2. Cookie consent

During your first visit to the site, you are shown information about the use of cookies along with a request for consent to use these files. Thanks to a special tool, you can manage cookies from the site level, disabling individual cookies. You can always change cookie settings from your browser or delete cookies altogether. Browsers manage cookie settings in different ways. In the browser’s help menu, you will find explanations on how to change cookie settings. You can also manage cookie settings by installing special add-ons allowing control over cookies. Disabling or limiting cookie handling may cause difficulties in using our site, as well as many other websites that use cookies.

3.3. Server logs

Using the site involves sending requests to the server where the site is stored. Each request directed to the server is recorded in server logs. Logs include, among others, your IP address, server date and time, information about the web browser and operating system you use. Logs are recorded and stored on the server. Data saved in server logs is not associated with specific persons using the site and is not used by us to identify you. Server logs are only auxiliary material used to administer the site, and their content is not disclosed to anyone except persons authorized to administer the server.

3.4. Google Analytics

We use Google Analytics tool provided by Google LLC based in the USA. The purpose is to create statistics and analyze them to optimize our websites. The collected data is personal data but does not allow for your identification. The information we have access to through Google Analytics includes, in particular:

• information about your operating system and web browser
• subpages you browse within our service
• time spent on our service and its subpages
• source from which you access our service

Within Google Analytics, we use Advertising Features such as demographic and interest reports, age range you belong to, gender, approximate location, interests determined based on network activity. To use Google Analytics, we have implemented a special Google Analytics tracking code in our website code. The tracking code uses Google LLC cookies related to the Google Analytics service.

3.5. Google Ads

We use the Google Ads advertising program operated by Google LLC. The purpose is to conduct advertising campaigns, including remarketing campaigns, and the legal basis is legitimate interest, consisting of marketing our own products or services. The collected data is personal data but does not allow for your identification.

During visits to our website, a Google remarketing cookie is automatically left on your device, which, using a pseudonymous identifier (ID) and based on the pages you visit, enables the display of interest-based advertisements. Further processing of information occurs only if you have given Google consent to combine browsing history and app usage with your account and use information from your Google account to personalize ads displayed on websites.

If in such a case you are logged into your Google account during your visit to our website, Google will use your data together with Google Analytics data to create and define target group lists for remarketing across different devices. For this purpose, Google temporarily combines the collected information with Google Analytics data to create target groups.

To use Google Ads, we have implemented a special Google Ads conversion pixel in our website code. The pixel uses Google LLC cookies related to the Google Ads service. From our website, using the mechanism for managing cookies, you can disable these cookies. You can manage ad settings directly on Google’s side: https://adssettings.google.com/.

Details related to data processing within Google Ads can be found at: https://policies.google.com/privacy.

3.6. Facebook Ads and Insights

We use marketing and analytical tools available through Facebook (Facebook Inc.). The purpose is marketing our own products or services and analytics and statistics. We have implemented the Facebook Pixel on our website, which automatically collects information about your use of our website in terms of pages viewed, to target you with personalized ads based on your behavior on our site.

Information collected through Facebook Pixel does not allow for your identification. Thanks to them, we only have the ability to know what actions you took on our site. We can also check your age range, gender, where you connect to the Internet from. Details about Facebook’s privacy policy can be found at: https://www.facebook.com/privacy/explanation.

3.7. Social Tools

Our website uses plugins and other social tools provided by social networks such as Facebook. When displaying our website containing such a plugin, your browser will establish a direct connection with the servers of social network administrators (service providers). The plugin content is transferred by the service provider directly to your browser and integrated with the page.

Through this integration, service providers receive information that your browser displayed our page, even if you don’t have a profile with the service provider or aren’t currently logged in. This information (along with your IP address) is sent by your browser directly to the service provider’s server (some servers are located in the USA) and stored there.

If you are logged into one of the social networks, the service provider will be able to directly associate your visit to our page with your profile in that social network. You can also completely prevent plugins from loading on the page by using appropriate extensions for your browser, e.g., script blocking.

Logging out of the social network before visiting our website will prevent associating data collected during visits to our website directly with your profile in that network. If you use a plugin, e.g., clicking the “Like” or “Share” button, the relevant information will also be sent directly to the service provider’s server and stored there.

The purpose and scope of data collection and their further processing and use by service providers, as well as contact options and your rights in this regard and settings options for protecting your privacy, have been described in the privacy policy of individual service providers. Facebook – https://www.facebook.com/legal/FB_Work_Privacy

3.8. Google Tag Manager

We use Google Tag Manager tool provided by Google LLC. Google Tag Manager is used to manage website tags through an interface. With Google Tag Manager, we control our advertising campaigns and how you use our sites. Google Tool Manager only implements tags. Its use does not involve storing cookies or collecting personal data. The tool enables other tags to work, which in certain circumstances may collect data. However, Google Tool Manager does not access this data.

If cookie saving has been deactivated at the domain or cookie level, this will apply to all tracking tags implemented through Google Tag Manager. We carry out these activities based on our legitimate interest in marketing our own products or services and optimizing our websites.

3.9. Hotjar

We use Hotjar tool provided by Hotjar Limited. Hotjar records every visitor to our site and enables playback of video recording of their movement on our site, as well as generating so-called heat maps. The Hotjar tool does not record the form filling process, so we do not have access to information that allows us to identify you. We carry out these activities based on our legitimate interest, consisting of creating statistics and analyzing them to optimize our websites.

4.0. Disqus

We use the Disqus system, which allows leaving comments on our pages. The Disqus system is provided by Disqus Inc. The Disqus comment system uses cookies to ensure proper functioning of the comment system. Details regarding Disqus system privacy can be found here: https://help.disqus.com/terms-and-policies/disqus-privacy-policy. Disabling cookies will prevent you from using the comment system.

Remember that if any information we provided about privacy policy or cookies is unclear, we are available at info@scalever.com.