At Fliko, we know that your personal information is important to you and we understand that you can expect us to protect it. Therefore, we respect your rights and fulfill the obligations imposed on us. We process your personal data in accordance with the provisions of 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) (hereinafter “Regulation”).

1. Who is the Controller of your personal data?

The administrator of your personal data is FLIKO P.S.A. with its registered office in Olsztyn, ul. Grunwaldzka 4a lok. 1, 10-124 Olsztyn, entered in the register of entrepreneurs of the National Court Register, maintained by the District Court in Olsztyn, VIII Commercial Division of the National Court Register under KRS no.: 0000935385, NIP: 5213949386, REGON: 520674090, share capital: 172 535.04 PLN.

2. How can you contact the Administrator?

It is possible to contact the Administrator in the following ways, selected by you:

• by means of the contact form located on the website at: www.fliko.pl
• by e-mail at: kontakt@fliko.pl
• by mail, by sending a parcel to the address: Fliko P.S.A., Grunwaldzka 4a lok. 1, 10-124 Olsztyn.

3. On what basis do we process your personal data?

We process your personal data for different purposes, depending on the relationship between us. Therefore, the legal basis for processing your personal data varies depending on the situations described below:

If you visit our website www.fliko.pl and browse the content therein, or use the contact form, or send us a message to the email address provided within the website, contact us by phone, or sign up for our newsletter, we process your personal data for the following purposes:

• in order to ensure the proper operation of the website, to monitor traffic, to verify the use of the website by visitors, and possibly to counteract user activities that do not comply with generally applicable laws. In particular, we record this data as part of cookies and logs relating to the website. The legal basis for the processing of data in this regard is the provision of Article 6(1)(f) of the Regulation, allowing the processing of data when it is necessary for the purposes of legitimate interests pursued by the controller or by a third party, the controller’s legitimate interests in this case being to ensure the proper operation of the website, to keep statistics on the the operation of the website, or to prevent fraud and violations of the law,
• for the purpose of contacting people who use the contact form on our website, send messages via e-mail or call the phone number provided on the website – the legal basis for processing data in this regard is the provision of Article 6(1)(f) of the Regulation, allowing processing of data when it is necessary for the purposes of the legitimate interests pursued by the controller or by a third party. The controller’s legitimate interest in this case is the need to process data in order to contact people and answer their questions,
• in order to conduct marketing activities concerning the Administrator’s products and services. In this case, the personal data is processed on the basis of the provision of Article 6(1)(f) of the Regulation, allowing the processing of data when it is necessary for the realization of purposes arising from the legitimate interests pursued by the Administrator or by a third party. The Administrator’s legitimate interest in this case is to conduct marketing activities. These activities may include, for example, allowing you to sign up for a newsletter and sending such a newsletter. Notwithstanding this, in situations where the law requires the data subject to give separate consent, e.g. for the purpose of making an offer to the data subject by means of electronic communication or telecommunication devices, the Administrator shall obtain such consent as required by law. Such consent is required under the Telecommunications Law with respect to the sending of marketing messages, such as newsletters.

If you use our Fliko or Fliko Service application we process your personal data for the following purposes:

• in order to perform the provisions of the contract concluded between you and the Administrator, including in particular to enable you to log in to the application and use the functionalities provided to customers – the legal basis for processing data in this regard is the provision of Article 6(1)(b) of the Regulation allowing processing of data when it is necessary to conclude and perform a contract to which the data subject is a party, or to take action at the request of the data subject prior to the conclusion of a contract,
• if you are a person who acts on behalf of our Client (i.e. a person who has signed a contract with us) and therefore you contact us, acting as a representative or agent of the Client (e.g. as a board member, employee or associate), we process your personal data for the purpose of concluding and performing a contract between us and the Client – in this case, the legal basis for data processing is the provision of Article 6(1)(f) of the Regulation, which indicates that data processing is allowed in a situation where it is necessary for the realization of purposes arising from the legitimate interests pursued by the controller or by a third party. The legitimate interest of the administrator in this case is precisely the performance of the contract between us and our client, which requires contacting the client’s representatives,
• in order to ensure the proper operation of the application, to monitor traffic, to verify the use of the application by persons using the application, to ensure security and possibly to prevent users’ actions that do not comply with generally applicable laws. The legal basis for the processing of data in this regard is the provision of Article 6(1)(f) of the Regulation, allowing the processing of data in situations where this is necessary for the purposes of legitimate interests pursued by the controller or by a third party, the controller’s legitimate interests in this case being to ensure the proper operation of the application, to keep statistics on the operation of the application, to prevent fraud and violations of the law. We would like to draw your attention to the fact that data is processed by us as an administrator to a limited extent, concerning the realization of the purposes indicated above – we process most of the personal data of application users on the basis of data processing entrustment agreements concluded between us and our clients.

If you access, observe or respond to our Facebook fanpage, fanpage on LinkedIn or profile on Instagram, we process your personal data to the following extent:

• to monitor traffic and conduct marketing activities for the Administrator’s products and services. Within these social networks, we may target you with marketing content (display posts marked as sponsored) in accordance with the rules of Facebook, LinkedIna or Instagram. Our Facebook fanpage is connected to our website via a Facebook plug-in, placed within the website. This means that by accessing our website, Facebook can obtain information that you have visited it. We process data related to the activities of our fanpage on Instagram or Facebook and the Facebook plug-in on the website on the basis of the provision of Article 6(1)(f) of the Ordinance, i.e. on the basis of our legitimate interest, the controller’s legitimate interest in this case being to conduct statistics and marketing activities.

4. To whom may your personal data be shared?

In order for us to properly provide our services, we use some third parties. Therefore, the personal data you provide may be transferred to:

• to entities providing hosting services on our behalf – home.pl Joint Stock Company with its registered office in Szczecin at 4 Zbożowa Street, 70-653 Szczecin, registered in the Register of Entrepreneurs of the National Court Register, kept by the District Court Szczecin – Centrum in Szczecin XIII Economic Department of the National Court Register under KRS 0000431335, REGON 811158242, NIP 8522103252,
• to an entity providing analytical services to us (Google Analytics, Google Firebase) – Google Ireland Ltd. and Google LLC with headquarters in Mountain View, California. The legal basis for the transfer of data to the United States is the Standard Contractual Clauses, approved by the European Commission, found in the contract between Google Ireland Ltd. and Google LLC,
• to the entity that manages the social networking sites Facebook and Instagram – Facebook Ireland Limited and Facebook Inc. based in Mountain View, California, USA – to the extent that the processing of your personal data relates to marketing activities regarding the Site undertaken through the Facebook platform, we and Facebook are joint controllers of your personal data. This means that you can direct questions about data processing in this regard to both us and Facebook. The legal basis for transferring your data to the US is the conclusion of an agreement containing the Standard Contractual Clauses approved by the European Commission,
• to the entity that operates the social networking site LinkedIn – LinkedIn Corp., Sunnyvale, California, USA. The legal basis for the transfer of data to the United States is the Standard Contractual Clauses, approved by the European Commission.

5. How long do we keep your data?

We endeavor to keep your personal data only for as long as we actually need it, after which time we delete it. The length of time we keep your data depends on the interaction you have with us:

• if you are a person who entered our website, we process your personal data for as long as you use the website and for up to 12 months after you leave it,
• if you are a person who wrote to us using the contact form on our website or contacted us by phone or email – we process your personal data for as long as the contact between us and you lasts and for a period of 3 consecutive months,
• if you are a person who has entered into a contract with us and uses the Fliko application, your data is processed for the duration of this contract and after its termination – for a period of up to 3 years from the end of the year in which you ended using our service, in accordance with the statute of limitations for claims. This also applies if you are an agent or representative of our client,
• if you use our Fliko application as a user, i.e. in connection with the fact that the entity with which you are associated has entered into an agreement with us for the use of the Fliko application, we process your personal data for as long as you are a user of the application,
• if you have expressed a wish to receive newsletters or other marketing materials from us, we process your personal data for this purpose until you unsubscribe from our mailing list or until we stop conducting promotional activities,
• if you observe us on a social network, respond to our posts or contact us via our fanpage on Facebook, LinkedIn or profile on Instagram, we process your personal data for the duration of the interaction between you and our fanpage and until one year after the interaction ends.

6. What rights do you have in connection with the processing of your personal data?

In connection with the processing of your personal data, you have rights to:

• request confirmation from the Administrator that your personal data is being processed by the Administrator and access to your personal data,
• request rectification of your personal data,
• demand the deletion of your personal data,
• demand restriction of the processing of your personal data,
• to object to the processing of your personal data – to the extent that the processing is based on the legitimate interests of the Administrator,
• demand the transfer of data that concerns you – to the extent that processing is carried out on the basis of a contract,
• lodge a complaint about the unlawful processing of your personal data to the supervisory authority (President of the Office for Personal Data Protection) at the address of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw).

In addition, you can withdraw your consent for activities that involve the processing of personal data (e.g. sending a newsletter), which will not affect the correctness of data processing prior to the withdrawal of consent.

7. What else is worth knowing?

Your personal data will not be used for profiling purposes, including automated decision-making.

The provision of personal data is voluntary, but in the case of data processing for the purpose of entering into or performing a contract with us for the use of the Fliko application, failure to provide data may result in our inability to provide services.

Information about cookies

Cookies are small files that enable or facilitate the use of certain website features. They may be stored on your device directly by us or by third parties with whom we cooperate. As part of our use of cookies, we may process your personal data, in particular such as your IP address, your history of use of the website, or information about the device or software you are using. The cookies we use are related to the operation of our website, and are used to control traffic on our website, to create statistics on the use of the website by its users, to undertake marketing activities, to prevent technical errors and malfunctions, to ensure the security of the website, or to prevent abuse and violations of the law.

The following cookies are distinguished:

Session cookies: they are stored on your device during the time you use our website (they are deleted when you close your browser). Session cookies enable proper use of our website. Blocking them may result in errors or prevent you from using our website or the Fliko application.

Persistent cookies: they are stored on your device until you delete them or until they expire.

The use of cookies is based on your consent, given in accordance with the provisions of Article 173 § 1 of the Telecommunications Law. We point out that the lack of such consent or the subsequent deletion of cookies may result in the inability to use the functionality of the website.

You have the ability to restrict or disable cookies within your device. Settings regarding the use of cookies can be found in the settings of your web browser. Web browsers allow you to disable all cookies or a part of them (e.g. from third parties). If you disable cookies in part, cookies generated by our website may be stored on your device to enable the website to function properly. However, this will result in the fact that you will not be able to use all the functionality of the site.

Please note that if you restrict the use of cookies, the use of particular services provided by us may be limited, and in some cases may not be possible.