Valid from 21-07-2019.
SUNCO, SUNCO Language School, we, our – SUNCO sp. Z o.o. based in Łomianki Dolne Our clients – clients of SUNCO sp. O.o. , to which SUNCO sp. z o.o. provides educational services in the field of language training and translations.
GDPR – EU Regulation 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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).
Client – a natural adult person or legal person who has a valid contract with SUNCO Sp. z o.o.
User – a natural or legal person using the services offered by Sunco Language School (SUNCO sp. O.o.) on the www.sunco.edu.pl website.
Potential Client – a natural adult person or legal person interested in the offer of SUNCO Sp. z o.o.
Potential Employee – a natural adult person or legal person who is interested in cooperation with SUNCO Sp. z o.o.
You, yours – respectively the Client(‘s) or Potential Client(‘s)
SUNCO Website www.sunco.edu.pl
SUNCO Sp. z o.o. is the administrator of your personal data that you have provided to us by completing the forms contained on the Sunco website www.sunco.edu.pl and through the communicators used by SUNCO.
If you have any questions regarding the processing of your personal data and your rights, contact us by sending a message to firstname.lastname@example.org.
3.1. The basis for the processing of personal data by Sunco Language School relies on the consent of its clients, potential customers and users, as well as the statutory authorization to process personal the data of clients, potential customers, and website users in order to:
a. Allow the clients and users of its website to use the full functionality of its website,
b. fulfill of orders for Sunco Language School products and services,
c. responsd to information sent by Sunco Language School using its contact form,
d. subscribe to free electronic newsletters and courses,
e. administer the direct marketing of Sunco Language School products and services, as well as the products and services of Sunco Language School commercial partners, unless the customer, potential customer or website user withdraws the consent for this type of marketing.
3.3 Providing any personal data is voluntary.
3.4 Providing data required in the process of creating an account / using the contact form / subscription to the newsletter / ordering products or services is necessary for the proper performance of services by Sunco Language School.
3.5 Sunco Language School will only process data that is necessary for the proper execution and functionality of services by Sunco Language School (Sunco sp. Z o. O.), As well as for the realization of rights arising from any applicable laws, including for statistical purposes, consideration of possible complaints, issuing invoice, rectifying claims by Sunco Language School.
In order to provide you with the most transparent information, we have grouped this information referring to the purpose of processing your personal data.
Browsing the contents of the sunco.edu.pl website, not connected with the purchase of services or products, creating an account or using the contact form, does not require the Customer, the Potential Customer or the Website User to provide personal data.
6.1. Subscribing to any electronic and free newsletters / courses / challenges belonging to Sunco Language School and available at sunco.edu.pl requires entering the name and e-mail address in the appropriate form. These fields are mandatory.
6.2 The data obtained in this way is added to our newsletter / course / challenge mailing list. An email address is necessary so that you can send newsletters, courses, and/or challenges to a given user. Collecting the name or users allows Sunco Language School to address readers by their name.
7.1 Ordering products and services offered by Sunco Language School via sunco.edu.pl is only possible after creating an account. In the case of placing an order, it is necessary for the customer to provide his/her personal data in the form of name, email address, telephone number and address of residence.
7.2. The processing of personal data for the direct marketing of Sunco Language School products and services (does not apply to customers or website users who have withdrawn their personal data for purposes of direct marketing) and Sunco Language School’s business partners.
7.3 Sunco Language School reserves the right to send unannounced messages to clients or website users who have not withdrawn their consent to the processing of personal data for direct marketing of Sunco Language School products and services.
7.4. The term, unannounced messages, is understood as messages containing information relating directly to the sunco.edu.pl website, products and services (e.g. changes, internal promotions), non-commercial lists (eg holiday wishes, personal comments, etc.) and commercial information, whose dispatch was paid for by customers and partners of Sunco Language School and sunco.edu.pl.
7.5. Entities ordering commercial mailings do not have access to the contact details of people on sunco.edu.pl mailing lists. Commercial information is filtered to the extent that it is possible, its volume is limited and it is sent sporadically.
The scope of data. For this purpose, we process personal data provided by you in the application form, that is, e-mail address, first name, last name, telephone number and data which you voluntarily provide to us in the content of your inquiry.
Legal basis. Preparation and performance of the contract (Article 6 (1) (b) of the GDPR).
Types of contracts: contract for the provision of educational services individually or in groups.
The scope of data. For this purpose, we process personal data provided by you in the application form and in the process of purchasing our products and services, that is, e-mail address, first name, last name, telephone number, address, and data which you voluntarily provide to us in the content of your inquiry or in email correspondence.
Legal basis. Preparation and performance of the contract (Article 6 (1) (b) of the GDPR).
For this purpose, we process personal data provided by you in the application form or sent to us by e-mail, that is your e-mail address, name, telephone number, education, employment history, availability and data that you voluntarily provide to us in the query .
Legal basis. Your consent to the processing of data.
11.1. Personal data provided on sites belonging to Sunco Language School when sending comments to articles, forum replies, etc. are available to all visitors of sites containing these data.
In addition to the data provided by clients, potential customers or users as part of the website browsing process, account registration, purchase of Sunco Language School products and services, using our contact forms, newsletter / course / challenge subscriptions on the sunco.edu.pl collect and store with the following information:
b. using server logs – data such as: IP address, where the query for displaying the web page come from, browser type, browser language, date and time of the event, information about errors that occurred during the execution of the HTTP transaction, if the transition to the sunco.edu.pl website was followed by a link (link) – the URL address of the page from which the Customer, the Potential Customer or the Website User was redirected to the sunco.edu.pl website.
The scope of data. For these purposes, we process personal data about your activity on our website, such as: visited pages and sub pages and the amount of time spent on each of them.
Legal basis. Our legitimate interest (Article 6 (1) (f) of the GDPR), consisting in facilitating the use of our website and improving the offer of our services.
The scope of data. For this purpose, we may process some of the personal data provided by you in the form, as well as data on the use of our services, which is the reason for the complaint or application, as well as data contained in the documents attached to the complaint or application.
Legal basis. Our legitimate interest (Article 6 (1) letter f) of the GDPR, which consists of improving the functionality of services and building positive relationships with customers and potential clients based on reliability and loyalty.
The scope of data. For this purpose, we process your personal data including: email address and information about the date of the sent message, as well as your answers to the questions we have prepared, included in the surveys and forms used in our satisfaction survey.
Legal basis. Our legally legitimate interest (Article 6 (1) (f) of the GDPR), consisting of improving the matching and quality of services and assessing the satisfaction of customers and potential customers.
The scope of data. For this purpose, we process personal data provided by you when completing the form or any of your applications to us, e.g. subscribing to the newsletter / course / challenge or downloading free materials to your e-mail address from our website on the SUNCO website and data about your activity on the SUNCO website, recorded and stored via cookies. Activity data related in particular to such data as: search history, clicks on the website, visits to the home page and subpages, as well as history and your activity related to our e-mail communication with you.
Sunco Language School only requires data that is necessary for the proper operation of the website and the provision of services. Failure to provide the required data will prevent the performance of the activity to which this data pertains. The data necessary for Sunco Language School to provide functional includes:
a. Name and email address
b. For the purchase of Sunco Language School products or services (Sunco sp. o.o.): Name and surname, email address, telephone number, and home address.
Sunco Language School may use personal data of clients, potential customers and website users for direct marketing of products and the services of commercial partners of Sunco Language School (Sunco sp. Z o. o.), Unless the Customer, the Potential Customer or the Website User requests withdrawal of consents for receiving marketing messages.
Profiling. We use the above data to create a profile for you that suits your interests, expectations and preferences. Later, we adjust marketing information about our products and services that may interest you in order to fit the profile we created for you.
Legal basis. Our legitimate interest (Article 6 (1) (f) of the GDPR), consisting of the marketing of our products and services.
Balance of interests. After weighing your interest and ours, as well as rights and freedoms, we believe that our marketing combined with profiling will not excessively interfere with your privacy or will not be too disturbing to you. We respect your will and facilitate the realization of your rights. For this purpose, we provide the ability to easily withdraw consents to receive marketing messages. You may express your disapproval to this by writing to us at email@example.com. At the same time, we treat withdrawal of consent to receive such messages as a refusal against profiling for marketing purposes.
16.2. Providing data to third parties: Sunco Language School will not sell personal data of customers, potential customers or service users to other entities.
16.3. During the progress of and for the purpose of providing services to clients, potential customers or website users, the personal data of clients, potential customers or users may be transferred to other entities with whom relevant agreements bind the administrator. This will not affect the security of personal data of customers or website users.
16.4 We provide your personal data to the following categories of recipients: our accounting office, the department of revenue.
We share your data with our employees and colleagues so that they can contact you for the purpose for which you have agreed.
We pass your personal information to the service providers we use. Service providers to whom we pass your personal data to, depending on contractual arrangements and circumstances, or are subject to our directives as to the purposes and methods of processing these data (processors) or independently determine the purposes and ways of processing them (administrators). The list of suppliers, which services we use, you will find here: (www.fakturownia.pl, www.home.pl, www.clickmeeting.com, www.zoom.us ). This list is constantly updated.
We use suppliers who process your personal data only in accordance with our instructions. They provide us with a cloud computing services, online marketing systems, displaying web push notifications, sending e-mails, analyzing website traffic, and analyzing the effectiveness of marketing campaigns.
We provide your personal data to state authorities upon their request, particularly organizations such as: the prosecutor’s office, the Police, the General Inspector for Personal Data Protection (the future Director of the Office of Personal Data Protection), the Director of the Office of Competition and Consumer Protection or the Director of the Electronic Communications Bureau.
The storage period of your data depends on the purpose:
1. recruitment – Your data will remain with us until your consent is withdrawn.
2. offer – until your consent is withdrawn
3. formulating a contract – from the date of notification until you withdraw your consent
4. marketing our services and products – until you withdraw your consent
5. for other purposes listed in point 3 of this policy – until your consent is withdrawn.
We ensure the enactment of your rights in the list below. You can exercise your rights by submitting a request to firstname.lastname@example.org.
The right to withdraw consent
You have the right to withdraw any consent you gave when submitting a form, as well as the data that you provided to us by sending an e-mail. Withdrawal of consent has effect from the withdrawal of consent. Withdrawal of consent does not affect the processing we perform in accordance with the law before its withdrawal. Withdrawal of consent does not entail any negative consequences to you. It may, however, prevent further use of services that we can legally provide only with consent (eg. opportunities to participate in further recruitment or receive commercial information).
Legal basis: art. 7 par. 3 GDPR
The right to object data usage
You have the right to object at any time to the use of your personal data, including profiling, if we process your data based on our legitimate interest, marketing our services, keeping statistics on the use of the website or satisfaction testing. If your objection turns out to be well founded and we have no other legal basis to process your personal data, we will delete your information to which you objected.
Legal basis: art. 21 GDPR
The right to delete data (“the right to be forgotten”)
You have the right to request the removal of all or some of your personal information. You have the right to request deletion of personal data if: a) you withdrew your specific consent to the extent to which personal data were processed based on your consent; b) Your personal data has ceased to be necessary for the purposes for which they were collected or processed; c) You objected to the use of your data for marketing purposes; d) You objected to the use of your data for the purpose of statistics of website usage and satisfaction testing, and opposition was considered justified; e) The unlawful processing of your personal data. Despite the request to delete personal data, in connection with opposition or withdrawal of consent, we may retain certain personal data to the extent necessary to establish, assert or defend claims. This applies in particular to personal data including: name, surname, e-mail address and history of the application, which we retain for the purpose of handling complaints and claims.
Legal basis: art. 17 GDPR
The right to limit data processing
You have the right to request a restriction on the processing of your personal data. You can do this in one of the following cases:
a) when you question the correctness of your personal data – we will limit its use for the time needed to verify the accuracy of your data, but no longer than 7 days;
b) if the processing of your data is against the law, and instead of removing the data, you will demand restriction of its use;
c) when your personal information has ceased to be necessary for the purposes for which we have collected or used it, but it is necessary for you to determine, assert or defend claims;
d) if you object to the use of your data – then the restriction occurs for the time needed to consider whether, due to your specific situation, protection of your interests, rights and freedoms outweighs the interests that we process when processing your personal data. Legal basis: art. 18 GDPR
The right to access data
You have the right to obtain confirmation from us whether we process your personal data, and if this is the case, you have the right to:
a) get access to your personal data;
b) obtain information about the purposes of processing, categories of personal data being processed, the recipients or categories of recipients of this data, the planned period of storage of your data or criteria for determining this period, about your rights under the GDPR and the right to file a complaint to the supervisory authority, the source of this data, on automated decision-making, including profiling and safeguards applied in connection with the transfer of this data outside the European Union;
c) obtain a copy of your personal data.
Legal basis: art. 15 GDPR
The right to rectify data
You have the right to rectify and supplement your personal data. You can do it yourself in the My Account – My Profile tab if you are logged in to our sunco.edu.pl website. With regard to other personal data, you have the right to request that we correct this data (if it is incorrect) and to supplement it (if it is incomplete).
Legal basis: art. 16 GDPR
The right to transfer data
You have the right to receive the personal information that you provided to us and then send it to another personal data administrator of your choice, e.g. to another operator of similar websites. You also have the right to request that personal data be sent by us directly to such other administrator, if it is technically possible.We will send your personal data in the form of a pdf file.
Legal basis: art. 20 GDPR
When do we complete your request?
If, by exercising the aforementioned rights, you make a request to us, we comply with this request or refuse to comply with it without delay, but no later than within 14 days of receipt. However, if – due to the complex nature of the request or the number of requests – we will not be able to complete your request within 14 days, we will complete them within the next month informing you in advance about the intended extension.
Reporting complaints, enquiries and applications
You can complain to us about complaints, queries and requests regarding the processing of your personal data and the exercising of your rights.
If you believe that your right to the protection of personal data or other rights granted to you by virtue of the GDPR have been violated, you have the right to file a complaint with the General Inspector for Personal Data Protection (the future President of the Personal Data Protection Office).
In the event that Sunco Language School receives information about the use of sunco.edu.pl by a customer, potential customer or website user in breach of the regulations or applicable laws, Sunco Language School may take necessary steps in processing the personal data of a customer, potential customer or website user in order to determine the liability of a customer, potential customer or website user.
We strive to ensure the security of your personal data through modern cloud solutions, anti-virus programs, firewalls, and all of our telecommunications and devices are password protected.
What are cookies? Cookies are files that store browsing data for your browser, on the User’s device. Cookies allow our website to remember user preferences, during the next visit to our website. Cookie files do not contain or collect any personal user information.
What kind of cookies do we use? – Session cookies – work only when browsing our website, thus enabling its proper functionality. They are also used by our server to store information about activities, in the event that the user loses connection with our server, the user can return to the same place on our website. – Permanent cookies – remain on the device after visiting our website, which means that our website is able to remember the user’s settings the next time they visit. Thanks to this. Our website is easier to navigate and remembers user preferences.
Deleting “cookies” By default, the browsers allow “cookies” to be placed on a user’s device. These settings can be changed to block the automatic handling of “cookies” in the settings of the user’s web browser. The user may also opt to allow “cookies” on the condition that they are informed prior to being transfered to the user’s device. Detailed information about the possibilities and ways of handling “cookies” are available in your web browser settings.
Limiting the use of “cookies” may affect some of the functionalities available on our website.