DEFINITIONS1.1Administrator - Legal Counsel Tatyana Koryakina is doing business as Kancelaria Radcy Prawnego Tatyana Koryakina (сorrespondence address: ul. Radzymińska 121, 03-560 Warsaw), NIP: 1132825152, REGON: 385576210.
1.2Personal Data means information about an individual who is identified or identifiable by one or more factors specific to his or her physical, physiological, genetic, mental, economic, cultural or social identity, including device IP address, location data, Internet identifier and information collected through cookies and other similar technologies.
1.3Policy - this Privacy and Cookie Policy.
1.4RODO - 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.
1.5Service means the website operated by the Administrator at www.virtuslegal.net.
1.6User - any natural person visiting the Website or using one or more of the services or functionality described in the Policy.
DATA PROCESSING IN CONNECTION WITH THE USE OF THE SERVICE1.7 In connection with the User's use of the Site, the Administrator collects data to the extent necessary to provide the specific services offered, as well as information about the User's activity on the Site. The data is processed for contact purposes, including to provide information on changes in regulations and practices of authorities, as well as on other matters, including events relating to current legal, economic and cultural issues, including through the distribution of the Administrator's newsletters. The above is carried out on the basis of legitimate interest, i.e. in accordance with Article 6(1)(f) RODO. Data may also be processed if this is necessary for the conclusion or execution of a contract and the fulfillment of the Administrator's legal obligations, i.e. on the basis of Article 6(1)(b) and (c) RODO. Data may be shared with organizations through which the Administrator fulfills the specified purposes, including IT infrastructure maintenance organizations. The provision of data is voluntary and, in contractual relationships, a mandatory condition for the conclusion and performance of the contract.
The following describes the specific principles and purposes of processing Personal Data obtained in the course of the User's use of the Site.
THE PURPOSES AND LEGAL BASIS FOR PROCESSING DATA ON THE SERVICE1.8 SERVICE UTILIZATION1.8.1Personal data of all persons using the Website (including IP address or other identifiers and information collected through cookies or other similar technologies) is processed by the Administrator:
1.8.2for the provision of services in electronic form in terms of providing Users with access to content collected on the Website - in this case, the legal basis for processing is the need for processing for the performance of the contract (Article 6(1)(b) RODO);
1.8.3for analytical and statistical purposes, in which case the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO), consisting in analyzing the activities of Users, as well as their preferences in order to improve the functionality used and the services provided;
1.8.4for the purpose of possibly establishing and investigating claims or defending against claims - the legal basis for processing is the legitimate interest of the administrator (Article 6(1)(f) RODO) to protect his rights;
1.9 ELECTRONIC CORRESPONDENCE1.9.1Where correspondence is sent to the Administrator by e-mail that is not related to services provided to the sender or to any other contract entered into with the sender, the Personal Data contained in that correspondence is processed solely for the purposes of communication and resolution of the matter to which the correspondence relates.
1.9.2The legal basis for processing is the legitimate interest of the Controller (Article 6(1)(f) DPA) to process correspondence addressed to him in connection with his business activities.
1.9.3The Administrator only processes Personal Data relating to the matter to which the correspondence relates. All correspondence is stored in such a way as to ensure the security of the Personal Data (and other information) contained therein, and is disclosed only to authorized persons.
COOKIES AND SIMILAR TECHNOLOGIES1.10 The Administrator uses cookies mainly to provide the User with services provided electronically and to improve the quality of these services. Thus, the Administrator and other organizations that provide it with analytical and statistical services use cookies by storing information or accessing information already stored in the User's telecommunications terminal equipment (computer, phone, tablet, etc.). The use of cookies on the Site is not intended to identify Users. This Policy regulates the processing of data related to the use of its own cookies.
1.11 BASIC COOKIES
1.11.1The Administrator uses necessary cookies mainly to provide Users with the services and functionalities of the Website that the User wishes to use. Necessary cookies can only be set by the Administrator through the Service.
1.11.2The legal basis for the processing of data in connection with the use of the necessary cookies is the need to process the data for the performance of the contract (Article 6(1)(b) DPA).
1.12 ANALYTICAL COOKIES
1.12.1Analytical cookies allow us to obtain information such as the number of visits and sources of traffic to the Website. They are used to determine which pages are more popular and which are less popular, and to understand how Users move around the Website by keeping statistics on Website traffic. Processing is carried out to improve the performance of the Website. The information collected by these cookies is aggregated and is not intended to identify the User. Analytical cookies may be set by the Administrator and its partners through the Website.
1.12.2The legal basis for processing Personal Data in connection with the Administrator's use of necessary and analytical cookies for these purposes is the Administrator's legitimate interest (Article 6(1)(f) RODO) in ensuring the high quality of the services provided on the Website.
1.12.3The processing of Personal Data in connection with the use of analytical cookies is subject to the User's consent to the use of analytical cookies through the cookie consent management platform. This consent can be withdrawn at any time through this platform.
1.13 ANALYTICAL TOOLS USED BY THE ADMINISTRATOR AND GOOGLE ANALYTICS
1.13.1The Administrator and its partners apply various solutions and tools used for analytical purposes. Below you will find basic information about these tools. For more detailed information, please refer to the data privacy settings and privacy policy of the respective partner.
1.13.2Google Analytics cookies are cookies used by Google to analyze your use of the Website and to compile statistics and reports about the Website's performance. Google will not use the data collected to identify you, nor will it combine this information to identify you. More information about the scope and principles of data collection in connection with this service can be found at:
https://www.google.com/intl/pl/policies/privacy/partners.
PERIOD OF PERSONAL DATA PROCESSING1.14 The period of data processing by the Controller depends on the purpose of the processing. Generally, data is processed for the duration of the provision of services, until revocation of this consent or until an effective objection to the data processing is received in cases where the legal basis for the data processing is the legitimate interest of the Administrator.
1.15 The processing period may be extended if the processing is necessary for the establishment and presentation of possible claims or defense against claims, and thereafter only if and to the extent required by law. At the end of the processing period, the data must be irretrievably deleted or anonymized.
USER RIGHTS1.16 The user has the right to access the content of the data and request rectification, erasure, restriction of processing, the right to data portability and the right to object to data processing, as well as the right to lodge a complaint with the supervisory authority responsible for the protection of personal data.
1.17 If the processing of User data is based on consent, this consent may be withdrawn at any time by contacting the Administrator by e-mail at t.koryakina@virtuslegal.net.
1.18 The User has the right to object to the processing of data for marketing purposes, if such processing is carried out in connection with the legitimate interests of the Administrator and - for reasons related to the specific situation of the User - in other cases where the legal basis for data processing is the legitimate interest of the Administrator (e.g. in connection with the realization of analytical and statistical purposes).
DATA RECIPIENTS1.19 In connection with the provision of the Services, Personal Data will be transferred to external organizations, including but not limited to vendors responsible for the operation of IT systems.
1.20 The Administrator reserves the right to disclose selected information about the User to competent authorities or third parties who make a request for such information on the appropriate legal basis and in accordance with the provisions of applicable law.
1.21 The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Administrator transfers Personal Data outside the EEA only if necessary and with an adequate level of protection in the first place:
1.21.1cooperate with Personal Data Processors in countries for which a relevant decision has been taken by the European Commission on whether an adequate level of protection of Personal Data is ensured;
1.21.2use of standard contractual clauses issued by the European Commission;
1.21.3application of mandatory corporate rules approved by the competent supervisory authority.
1.22 The Administrator will always inform you of its intention to transfer Personal Data outside the EEA at the point of collection.
PERSONAL DATA SECURITY1.23 The Administrator conducts risk analysis on an ongoing basis to ensure the secure processing of Personal Data, in particular by ensuring that only authorized persons have access to the data and only to the extent necessary to perform their tasks. The Administrator ensures that all operations involving Personal Data are recorded and performed only by authorized employees and assistants.
1.24 The Administrator shall take all necessary measures to ensure that its subcontractors and other cooperating organizations also ensure that appropriate security measures are applied when they process Personal Data on behalf of the Administrator.
PRIVACY POLICY CHANGES1.25 Policies are continually reviewed and updated as needed.
1.26 The current version of the Policy has been adopted and is effective January 01, 2023.