TABLE OF CONTENTS
- Personal information
- Use of information
- Performance of services
- Marketing and PR purposes
- Electronic advertisements
- System logs
- Cookies and similar technologies
- Modification of personal information
- Disclosure required by Law
- Data protection
- Links to websites of other companies/organisations
- Notices of Policy updates
- Questions and Complaints about Privacy
It is the policy of D-RAFT S.A. operating under the trade name of The Heart , hereinafter referred to as ‘TH’, to comply with applicable legal regulations concerning privacy and data protection.
Issues related to data processing as part of subscription or other services purchased from TH are regulated by separate procedures and agreements.
TH declares that it will make every effort to ensure adequate security of the data transmitted, and agrees to carry out measures to prevent third-party interference in the personal data and privacy of the data subjects. Personal data provided will be used for the purposes specified further in the document.
User – a data subject; a person who provides his/her personal data in connection with the use of TH websites.
TH websites – Internet websites operated by or on behalf of TH and its subsidiaries worldwide.
Commercial Information – any information intended directly or indirectly for promoting subscription, services or image of TH.
Data integrity – refers to a situation in which data consistency is maintained during such operations as reading, saving, transmission or storage.
Partner – an entity, in favour of whom TH provides services or an entity that provides its services in favour of TH.
Please be advised that the User may contact TH directly (by phone) or by accessing TH’s websites in order to get acquainted with information about the company, programmes and services and to view or listen to specific programmes, without the need to provide his/her personal information. Irrespective of the above, circumstances may arise when the User’s personal information is required to perform a requested service or process. In such cases the User shall be informed about the necessity to provide the data and the ways in which it will be used, thus enabling the User to decide whether to provide or refuse to provide his/her data. Making personal data available may be required when the User is interested in requesting performance of a particular service (for example preparation of an offer, receiving information about subscription) by an entity owned by TH or in situations when the User is interested in taking part in a process or event (for example participation in a conference). The User may then be asked to fill out and send a form/ questionnaire in which he/she will be clearly advised about what kind of personal data will be collected. In situations when the User discloses personal data of a third party (e.g. of a colleague) in a form/questionnaire, TH shall assume the User is in possession of an appropriate permission from the person whose data he/she has disclosed.
Data provided by the User in the abovementioned way is used by TH solely and exclusively for the purpose of performance of a service requested by the User, carrying out a process or arranging participation in an event.
Use of information
4.1 Performance of services
By informing TH about his/her willingness to get acquainted with commercial information, specifically including subscription offer, services, receipt of newsletters, the User agrees that he/she or a third party indicated by him/her may be contacted directly. TH has the right to share personal data with entities whose involvement in the execution of a service is absolutely necessary (e.g. technological partners, application developers, financial and government institutions, postal services, transport companies), provided that such entity has been entrusted with processing of personal data by TH as the personal data controller under separate agreement. Such entities are required to use personal data provided to them only for the purpose of rendering a service on behalf of TH and shall treat the User’s personal data as strictly confidential.
Data provided by the User may be used to maintain or develop business relations, as well as in order to ensure adequate provision of services. TH may contact the User in order to conduct customer satisfaction survey or market research.
4.2 Marketing purposes
Personal data and information shared by the User through TH websites or provided while attending a conference or an event, may be used by TH for marketing purposes. This data may be also made available to selected third parties with whom TH cooperates in providing products and services to its clients and with whom it cooperates in the field of marketing, provided that such entity has been entrusted with processing of personal data by TH as the personal data controller under separate agreement. Personal data shall be used in the abovementioned way only in the case when the User express his/her consent to such action. The User’s consent shall be understood as consent to receive commercial information.
TH provides its Partners with dedicated websites containing information necessary for cooperation with TH. Access to these websites requires registration and a proper logging of a registered User with each visit. Personal data and information provided through such services may be used by TH to manage business relations with the User or a Partner represented by the User, as well as with all Partners and to develop such relations, which may occur in particular by transferring commercial information, product information, marketing information and information about partnership programmes. TH reserves the right to share personal data and information with its Partners and suppliers in order to render a service or carry out a process, provided that such entity has been entrusted with processing of personal data by TH as the personal data controller under separate agreement unless additional obligations to keep the data confidential have been reserved.
TH provides its Tenants with dedicated websites which constitute a database of knowledge about services that the Tenants use. Access to these websites requires registration and a proper logging of a registered User with each visit Information provided through such services may be used by TH to manage business relations with the User or Tenants represented by the User, as well as with all Clients and to develop such relations, which may occur in particular by transferring commercial information, product information, marketing information and offers. TH reserves the right to share personal data and information with its Partners and suppliers in order to render a service or carry out a process, provided that such entity has been entrusted with processing of personal data by TH as the personal data controller under separate agreement, unless additional obligations to keep the data confidential have been reserved.
4.5 Electronic advertisements
TH uses services of external entities providing interactive electronic advertising (for example banner advertisements). These entities are authorised to collect and use information about Clients solely for the purpose of ensuring optimal service provision to TH, as well as in order to determine which offers, promotions and types of advertisements are best received by TH’s Clients. Information collected in such manner is aggregated and thus cannot be used to identify a single User.
Each User’s visit to the TH websites is automatically registered on the server, in the so called system logs. The data saved this way includes, among other things,: date, time of the visit and the IP address. The data from system logs is used solely for the purposes of administering the servers and gathering website traffic statistics.
Cookies and similar technologies
Cookie technology is used by most highly developed Internet sites in order to enhance the quality of service and perform certain functions, including
- creating individual content viewing statistics,
- personalization of services performed using the service,
- maintaining user sessions,
- authentication of people using the service,
- providing Users with personalised advertising content.
TH websites use the following types of cookies:
- ‘Essential’ cookies, which enable the use of our website services, for example to allow the use of sessions,
- ‘Functional’ cookies, used to remember the settings chosen by a User and to personalize the User’s interface, e.g. in terms of selected mobile/classic version, last phrases typed by the User, the appearance of a website, the state mechanism bookmarks, etc.
- ‘Analytical’ cookies, used to monitor the activity of Users on the site.
Cookies are not used for processing or storing personal details, they cannot be used for direct identification of a User and they do not change browser options or terminal device configuration. The User can independently determine and modify browser settings so that they will not accept cookies. If this option is selected many websites may not function properly or at all. It may be possible to set your browser to ask for the User’s consent before each cookie is used. This allows the User to have control over what is set on their device, however it may slow down the browser. In order to manage your cookies, please select your browser from the list below and follow the instructions:
- Internet Explorer,
- Windows Phone,
No change in cookies configuration means they will be stored in the User’s terminal device, and therefore TH will keep information regarding the User’s terminal device and gain access to this information.
Modification of Personal Information
The User is entitled to become acquainted with his/her data stored by TH, and to correct and update any inaccurate or incomplete personal data, should it be necessary. Moreover, the User is entitled at any time to request the removal of his/her personal data from TH’s database. In order to do the above, please send an email to the following address: firstname.lastname@example.org with a request to modify or remove personal data.
Disclosure required by Law
Under certain, limited circumstances, TH may make available or provide personal information to third parties not affiliated with TH. In particular, TH may transfer personal data to a third party: upon User’s request;
- in order to comply with legal requirements or a court order;
- in order to verify the possibility of committing an offense of identity theft;
- in connection with a sale, purchase, merger, reorganisation, liquidation or dissolution of TH;
- under other similar circumstances.
TH implements appropriate measures to protect the confidentiality of personal data and to preserve the integrity thereof. TH uses an encrypted connection for protecting the data being transmitted. TH is not responsible for data sent by third parties, and for data transmitted over unsecured connections.
Links to websites of other companies/organisations
TH’s website may include links to websites of other companies or organisations. TH shall not be liable for procedures and data protection mechanisms used by these companies/ organisations or the content of other websites.
Notices of Policy updates
Questions and complaints about Privacy
For potential questions or complaints on how TH uses personal data, please contact us at the following address: email@example.com
Date of publication: 2017.05. 19