PRIVACY POLICY 

We are committed to ensuring that your data, both personal data and other data stored in cookies and derived technologies, collected when you use our services or our website asist-xbrl.eu (hereinafter also: the “Website”) – is safe with us. To find out under what conditions your data will be processed, please read the following information clause. Below you will find out what personal data we process, on what legal basis we process this data, for what purposes we use it, to whom we may transfer it and what rights you have in relation to the processing of your personal data. To manage your cookie settings, go to privacy settings. 

The solutions we use comply with 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, and repealing Directive 95/46/EC (General Data Protection Regulation), or GDPR.

INFORMATION CLAUSE

A. FINGO as the data controller

FINGO sp. z o.o. with its registered office in Wrocław (53-329) at 7 Powstańców Śląskich Square, hereinafter referred to as the “Controller” or “FINGO” is the controller of the personal data provided by you while navigating our Website, email address of the Controller: hello@fingo.net. 

You can read more about the roles of other entities, including our Partners, in data processing in the section Who, besides us, processes your personal data and who are the recipients of your data? 

B. What personal data do we process?  

We may process the following personal data: 

a) identification data, in particular your name and surname, which you provide to us voluntarily via the contact form. We may also process your identification data if you are a contact person at a company that is a customer of ours. In addition, we will process your identification data, and other data such as your date of birth, when you provide us with your CV submitted with an application for a position of interest to you for which we are recruiting.  

b) contact data, i.e. personal data that enables us to contact you, in particular your email address, telephone number, the name of your position and company, and other contact data that you voluntarily provide to us via the contact form. We may also process your identification data if you are a contact person at a company that is a customer of ours. We will also process your contact data in the CV you submit if you participate in a recruitment exercise conducted by FINGO. Furthermore, if you like our pages on social networks, i.e. on: Facebook, LinkedIn and Google, the links to which are available on the Website, or you have contacted us via the instant messengers of these networks, we may process the contact to you on the social networks. 

c) data about your education, professional qualifications and previous employment history, as well as other data about you indicated by you in your CV, if you apply for a position of interest to which we are recruiting. 

d) your photograph – if you include it in your CV, if you are applying for a position of interest to you for which we are recruiting.

e) information about your online behaviour, in particular the products and services you view on our Website, the links you click on, the way you navigate and scroll through our Website, as well as information about the device you use to browse the Website, such as your IP address and its location, the identification of the device, the technical characteristics of the device, such as the operating system and its version, the screen resolution, the browser you use and its version, as well as data collected through cookies and similar technologies to identify the device.

f) information about your reading behaviour when you read the messages we send you, in particular the times at which the messages are opened, as well as information about the device on which you read the messages, such as your IP address and its location, identification of your device, its technical parameters such as operating system and its version, screen resolution, the browser used and its version, as well as data obtained from cookies and similar technologies.

g) derived data, which means personal data derived from your settings, information about the services you have requested from us, data about your online behaviour and information about your behaviour when reading the messages we send you; in particular, data about your gender, age.

h) data related to your communication with FINGO, thus the identification of the messages you send to us, including identifiers such as IP addresses.

C. Why do we process your personal data, how long do we process your data and what is our basis for doing so? 

In the course of our business, we process personal data for different purposes and to different extents on the basis that the processing is necessary for the conclusion or performance of the contract you enter into with us (Article 6(1)(b) GDPR) as well as for the purposes of our legitimate legal interests (Article 6(1)(f) GDPR). 

C.1. When you visit our Website  

C.1.1. Use of cookies and similar technologies 

When you visit our Website, we store on your device, and then read from it, small files called cookies. A cookie is a small set of letters and numbers that we store in your web browser or on your computer’s hard drive. Some cookies allow us to monitor your browsing behaviour on our Website from the time you open your web browser window until you close it. When you close your browser window, these cookies will be deleted. Others remain on your device for a set period of time and activate each time you visit the website that created the cookie.  

In addition, we use pixel tags (also known as web beacons), which are small images with a function similar to cookies. Unlike cookies stored on your computer’s hard drive, pixel tags are a permanent part of the website. We will refer to all these technologies as cookies in this clause for its simplicity. We store cookies on your device and we also have access to those cookies that our Website has stored on your device. For the sake of simplicity below we will only refer to the storage of cookies having in mind also access to them. 

Some cookies are necessary for the functioning of our Website. If you disable your browser’s permission for websites to save and read cookies, our Website may not function properly and we may not be able to provide our products and services to you. These cookies allow us to: 

• identify you when you switch between sub-pages of our Website and when you visit us again; 
• to record whether you have given us permission, for example, to store the cookies referred to in this clause; 
• provide security, for example to investigate whether someone has abused your connection to our Website and is performing an action instead of you; 
• record, investigate and eliminate failures and non-functional elements of our Website; 
• display different variations of our Website if we are testing new functionality. 

In addition, if you agree to this by clicking “I accept” on our Cookies notification when you first visit the Website or if you give the appropriate consent in the Privacy Settings:  

• we save on your device cookies from our Website, which allow us to:  

• • customise the content of our Website for you, for example to show offers/products you have already viewed first and display further customised suggestions on our Website; 
  •  record which version of our Website we should display if the Website offers more variations at any given time; 
  • monitor Website traffic and the traffic of its individual pages, generate statistics and reports and measure the effectiveness of advertising; 

• we allow cookies to be stored on your device by our Partners, who may use them to:  

• • collect information about your behaviour on our Website and on other websites; 
  • display tailored offers and tailored advertising within advertising and social networks on sites other than our Website; 
  • connect with social media such as Facebook, Linkedin, including automatic login, providing features such as a “Like” or “Share” button, and displaying tailored offers and targeted advertising on these social networks and other websites other than our Website. 

To display tailored offers and targeted advertisements within advertising and social networks on websites other than our Website, we pass on data about your behaviour on the Website to our Partners, i.e. advertising and social networks. However, we do not pass on your identification data to such Partners. For an list of the social and advertising networks we use, please see Who, besides us, processes your personal data and who are the recipients of your data?  

You can revoke your consent(s) referred to above at any time. 

C.1.2. Use of personal data of Website visitors 

If you visit www.fingo.pl, we process data about your behaviour on the Website on the basis of our legitimate interest (art. 6(1)(f) GDPR) in order to: 

• test new features and applications prior to their deployment, in particular to avoid problems with the functionality of these innovations during actual operation that could adversely affect the quality of our services; our legitimate interest is the smooth functioning of our services for you;  
• prevent attacks on our Website and breaches of its functionality and the security of your data; our legitimate interest is the smooth functioning of our services for you and the security of your data. 

For this purpose, we use your personal data for a maximum of 24 months. You have the right to object to this processing. 

We also process data about your behaviour on the Website based on your consent, in order to: 

• obtain information that will enable us to improve the Website in the future; 
• produce statistics and reports, in particular track traffic on our Website and its individual pages and measure the effectiveness of advertising; our legitimate interest here is to measure the effectiveness of our Website and the cost of advertising; for this purpose, we may collect additional derived data based on your behaviour and use it for this purpose;  
• to provide tailored offers and targeted advertisements that we offer on the Website. We also enrich the data for this purpose using analytics and extract derived data from it. 

We do not collect data on Website behaviour only from cookies. We also supplement this with the following data: 

• The IP address of your device (the address of your device with which you communicate with other devices on the Internet); 
• The operating system of your device, its version and language settings; 
• The browser you use on your device, its version and language settings; 
• The adress (URL) of the website from which you visit our Website. 

We use your personal data for this purpose for a maximum of 24 months. You can enable or disable this function at any time in the Privacy Settings section. 

C.2 If we speak to you through any channels 

If you contact us through any channels, in particular by phone, email, contact form, chat tools and instant messaging on social networks, we will process your identification and contact data and keep records of the conversations we have had on the basis of our legitimate interest (Art. 6(1)(f) GDPR) in order to: 

• handle your enquiries, as well as our enquiries made to you; if you are a party to a contract with us or if your enquiry relates to a contract we are about to enter into, then we may process your data on the basis that the processing is necessary for the performance of the contract you have entered into (and therefore also on the basis of Article 6(1)(b) GDPR); 
• keep a record of our correspondence including your enquiries and complaints and similar messages, so that we can check if we respond to them correctly and in a timely manner;
• demonstrate that we have responded to your message in order to defend against potential claims and protect our rights (Article 6(1)(f) GDPR); 
• analyse our correspondence in order to improve our service. 

C.3. If you sign up for our Newsletter 

If you sign up for the Newsletter we send to our Clients, we will process your contact data i.e. your email address in order to perform the service of our Newsletter for you (based on Article 6(1)(b) GDPR). You can unsubscribe from our mailing list at any time, in which case we will stop processing your email address for this purpose.  

C.4. If you are a contact person of our Client 

If you are a contact person of our Client for whom we provide IT services or a representative of that client, we process your identification and contact data in order to perform a service for our client, based on our legitimate interest to conclude and perform a contract with the entity you represent (based on Article 6(1)(f) GDPR). 

C.5. If you take part in a recruitment that we are carrying out  

We process the data you provide to us as part of your application and collected as part of the recruitment process for the purposes necessary for the recruitment process we are currently carrying out for our team and, if you have given your consent, for future recruitment processes for similar positions. 

In connection with a recruitment process, we may process your identification data, contact data, data about your education, professional qualifications and previous employment history, your photograph, as well as other data you voluntarily provide to us during the recruitment process.  

In connection with a recruitment exercise, we process your data for the following purposes: 

• the consideration of your application and the execution of the recruitment process – the basis for the processing is the provisions of the applicable law (in particular the Labour Code – in accordance with Article 6(1)(c) GDPR) and, to a greater extent than specified in the regulations, your consent (Article 6(1)(a) GDPR); 
• where you have given your consent (and therefore on the basis of Article 6(1)(a) GDPR), also for the purposes of future recruitment processes; 
• for the defence against potential claims and the protection of our rights (on the basis of Article 6(1)(f) GDPR). 

 D. Who, besides us, processes your personal data and who are the recipients of your data?  

We may transfer your personal data on the basis of your consent to other parties who act as a controller, i.e. advertising and social networks, as described in the section Use of cookies and other technologies, transfer of data to advertising and social networks: 

• LinkedIn Ireland Unlimited Company, based in Wilton Plaza, Wilton Place, Dublin 2, Irlandia, Privacy Policy available here:: https://linkedin.com/legal/privacy-policy?trk=hb_ft_priv;  
• Meta Platforms Ireland Limited, based in 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Irlandia; Privacy Policy available here: https://www.facebook.com/privacy/policy; 
• Google Ireland Limited, based in Gordon House, Barrow Street, Dublin 4, Irlandia; Privacy Policy available here: https://policies.google.com/technologies/ads.  

We also use the services of other processors who process personal data only in accordance with our instructions and for the purposes described in the part Why do we process your personal data, how long do we process your data and what is our basis for doing so?. Such processors are:

a) CRM service providers, in particular Pipedrive OÜ with its registered office at Mustamäe tee 3a, Tallinn 10615, Estonia;

b) Providers of other cloud, IT and technical services, such as Microsoft and Google;
c) Providers of research, analysis and statistics tools, as well as marketing action providers and operators of marketing tools, such as Google as part of the Google Analytics service, which help us to analyse, optimise the Website or personalise content and offers for you. 

Furthermore, the recipients of your data are service providers who supply us with technical, organisational and management solutions for our company (in particular courier and postal companies) and providers of accounting, legal and advisory services and these who support us in the assertion of due claims and the defence of our rights (in particular law firms, tax law firms, debt collection agencies).

E. Period of data processing 

We will only keep your data for as long as it is necessary.  

Unless otherwise indicated elsewhere in this document: 

• data processed on the basis of our legitimate interest will be processed until you object to its processing, and in the case of processing for the purpose of pursuing claims or defending against them, it will be processed for a period that does not exceed the period of limitation of those claims; 
• data processed on the basis of your consent will be processed until you withdraw your consent; 
• If you do not respond to our message, we will stop processing your personal data one month after you fail to respond.    

After the expiry of the periods mentioned in this document, your personal data will be deleted or anonymised. 

F. What are the sources that we receive your personal data from? 

In most cases, by visiting our Website or by filling in the relevant forms on our website, you provide us with the personal data we process.  

If you are an employee of our client designated to contact us, then we may also receive your data from our client for whom we provide services.

G. Transfers of personal data outside the European Economic Area 

Your personal data transferred to the entities referred to in the section Who, besides us, processes your personal data and who are the recipients of your data? may be transferred to these recipients of the data outside the European Economic Area to based on appropriate legal safeguards, which are the standard contractual clauses for the protection of personal data approved by the European Commission.

H. Voluntary data provision  

We do not oblige you to provide us with your personal data. You provide it to us voluntarily. However, please note that it is necessary if you want to contact us, to take part in a recruitment exercise that we are conducting or to use the Newsletter service.

I. Profiling and automation 

Neither your personal data collected as part of the recruitment process, contact between us or provision of the Newsletter service, nor your data as a contact person designated by our client, will be processed by automated means, including profiling. 

Only data from cookies may be processed by us in an automated manner, including profiling, but binding decisions will not be automated, nor will it have any legal effect on you or similarly significantly affect you. This means that the information that, for example, we show you on our Website and in the advertisements displayed to you may be linked to how you have used our Website. This allows us to better tailor the content of our electronically delivered services to your preferences, needs and interests. You can read more about this in the section: Why do we process your personal data, how long do we process your data and what is our basis for doing so?

J. What are your rights regarding the processing of your personal data? 

At any time, you have the right to request from us access to your personal data, rectification, erasure, restriction of processing, to object to the processing under the legitimate interest of the controller (Article 6(1)(f) GDPR) or for statistical purposes (Article 89(1) GDPR) on grounds related to your particular situation, as well as to the processing for direct marketing purposes and the right to data portability. As a person submitting a request or task regarding the processing of your personal data, you may be asked by us to answer a number of questions related to your personal data, which will enable us to verify your identity. 

If you believe that we are processing your personal data illegally or in violation of generally applicable laws, you may lodge a complaint with a supervisory authority. You can lodge a complaint against our processing of your personal data with the President of the Personal Data Protection Office based in Warsaw at 2 Stawki Street, 00-193 Warsaw.

K. How can individual rights be exercised?

For all matters relating to the processing of your personal data, you can contact us by email at  iod@fingo.net. We will process your request without undue delay, within a maximum of 30 days. In exceptional circumstances, especially due to the complexity of your request, we are entitled to extend this period by a further two months. We will, of course, inform you of any such extension and the reasons for it.