Majewski Business Consulting
Bringing order & operational separation to medium and small companies.
Bringing order & operational separation to medium and small companies.
Majewski Business Consulting Piotr Majewski, headquartered in Gdansk at ul. Warszawska 100/15, NIP PL5851392623, email: office@majewskibc.com ("MBC"), acts as the data controller (DC) as well as the data processor (DP) with respect to its Clients and Users of the products and services offered by MBC (collectively, "Clients").
MBC acts as the DC pursuant to Article 6(1)(a) of the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (the "Regulation") – i.e., based on the consent provided by the data owner.
MBC acts as the DP based on an agreement with the DC, processing data in accordance with the Regulation.
MBC does not knowingly process personal data of persons under 16 years of age unless the legal guardian of such person has given consent.
If you do not agree with the Privacy Policy, do not visit MBC’s websites, do not use MBC’s services, do not purchase MBC’s products or services, and do not subscribe to MBC’s publications.
MBC processes the personal data of its Clients as a DC for the purpose of delivering products and providing services that support business operations and online marketing, invoicing, and communication with Clients justified by the nature of the product or service.
MBC, through the provided services supporting online business, processes the personal data of other entities’ Clients as a DP.
With the additional consent of Clients, MBC processes their personal data as a DC for the purpose of direct marketing of products and services via electronic communications, mobile telephony, profiling, and making automated decisions (marketing automation), as well as offering and selling services and products (the "Marketing Consent").
With additional consent from Clients, MBC processes their personal data as a DC for the purpose of sending commercial information by electronic means (in accordance with the Act on the Provision of Electronic Services) or via telephone calls (in accordance with the Telecommunications Act).
MBC processes personal data indefinitely until a request to cease processing or delete the data is made, unless further processing is a legal obligation of MBC.
The data subject may:
The actions described in Article 2(5) may be performed by the data owner after prior verification of their identity via automated systems or through contacting MBC or the supervisory authority in the case of point (d).
MBC makes every effort to ensure that the data subject can exercise their rights in the simplest and most automated manner possible. MBC does not hinder the exercise of these rights unless such hindrance is in the essential interest of the data owner – for example, the deletion of an account in a service which may be of significant importance to the account owner.
In the case of a request for data deletion, MBC may retain a portion of the data necessary for statistical analyses or evidentiary purposes after anonymization. Deletion or anonymization of data in active databases is carried out without undue delay within the timeframes described in the Regulation. Deletion or anonymization of data in archival databases is carried out over several months due to the need to maintain continuity of services.
In very rare cases – for example, as a result of a major failure or breach of database integrity – restoring data from an archive may result in the reprocessing of data for which the owner had withdrawn consent or requested deletion or correction in a form other than requested. In such an event, MBC will make every effort to notify the data owners about the situation along with a request to renew any necessary requests.
While using the websites and services owned or used by MBC, you may be asked to provide certain personal data by filling out a form or by other means.
The data requested will mostly be your first name and email address. The email address is essential for communication with the Client and for verifying their identity in the case of a request for data change or deletion. The first name facilitates communication and does not necessarily have to be your real name.
In the case of order forms, you will be asked to provide personal data in a scope appropriate to the type of product or service – e.g., postal address, telephone number where justified by the nature of the product or service.
In cases of cooperation agreements or for providing MBC services for the purpose of delivering one's own services, you will additionally be required to provide unique identifiers assigned to you by the country in which you reside – e.g., NIP, REGON, PESEL in the case of private individuals.
MBC always strives to require only the minimum data necessary to provide a specific service.
Providing personal data is always voluntary, but it may be essential for the execution of the service.
MBC does not sell or provide Clients' personal data to third parties for purposes other than supporting its own processing procedures, unless the Client has provided separate consent – for example, by becoming a Client of one of the services offered by MBC.
MBC provides personal data of Clients for whom it is acting as a DC or DP to other DPs for the purpose of delivering services and supplying ordered products. Such data transfers are carried out based on separate agreements. A list of these DPs is available at: https://www.imple.com/dataprocessors.
DPs acting on behalf of MBC are located in Poland, other European Union (EU) countries, and in other countries, or they are international organizations. In the case of countries outside the EU, the legislation of those countries meets the requirements of the Regulation or appropriate security measures have been implemented to ensure compliance with the Regulation.
DPs acting on behalf of MBC do not have the right to process the personal data entrusted to them for purposes other than supporting MBC’s services, unless the Client independently provides such consent to the specific DP – for example, by simultaneously being a user of that entity’s service.
In the case of payment by credit card, customer service is provided by a certified payment operator. Unless otherwise indicated, only the payment operator is aware of and responsible for the data provided in its forms. The payment operator’s forms are hosted on its server and are secured by appropriate technologies.
On MBC’s websites, a form or other functionality may appear that serves to transfer personal data to a DC other than MBC – for example, a user of a service provided by MBC for that user.
A Client who provides their data to an external DC via an MBC service or website does so knowingly and voluntarily to that DC, and MBC is not responsible for the way that DC processes the data. Where MBC has influence, it ensures the data is transferred in a secure and efficient manner.
Some MBC services provide users with complete freedom to create forms, therefore MBC is not responsible for the security and correctness of forms that the user of an MBC service has created themselves.
MBC makes every effort to ensure that DCs using MBC’s websites and services comply with the Regulation and other applicable laws.
MBC reserves the right to send unsolicited messages to Clients whose contact details it possesses and who have agreed to this Privacy Policy.
By unsolicited messages, MBC understands electronic messages (emails and messages sent through other forms of electronic communication), SMS messages, automated or non-automated telephone communications, messages sent to a physical address, and others.
Unsolicited messages have the following nature:
MBC initiates the sending of unsolicited marketing or commercial messages only to those Clients who have provided their consent to such communications.
MBC does not initiate the sending of marketing or commercial messages to external DC Clients who use MBC’s services, but as a DP, it may technically execute and manage such message sending on behalf of those DCs.
MBC limits the initiation of non-commercial unsolicited messages to external DC Clients using MBC’s services to situations that are absolutely required by law, by the way the service operates (e.g., a subscription confirmation request), or due to the significant interest of the recipients.
Entities commissioning the sending of marketing or commercial messages to MBC’s Clients do not have access to the contact data of the persons on MBC’s mailing lists.
The marketing and commercial information directed to MBC’s Clients is checked and filtered for the reliability of the message and the sender, to the extent possible; its volume is limited, and the messages are sent sporadically.
Information sent by external DCs via MBC’s services is not checked or approved for content, but it may be monitored to detect activities inconsistent with MBC’s regulations or the law.
Personal data provided on websites owned by MBC when sending comments to articles, responses to forum posts, etc., may be accessible to all visitors of the pages containing such data. MBC cannot safeguard Clients against private individuals or companies who might use this data to send unspecified information.
Public personal data include the Client’s provided first and last name, website address, city of residence, a photo shared in an MBC service or otherwise publicized, and usernames on social networks and internet messengers.
Any personal data provided by the Client in form fields not intended for such data – e.g., the content of a comment, forum post, profile description, or forum signature – will be made public at the Client’s risk, and MBC assumes no responsibility for this.
MBC may also publicize other data if the user consents or if required by law – e.g., the address or telephone number of a Client who is also a DC using MBC’s service.
Some areas of websites owned by MBC may use cookies, i.e., small text files sent to the Client’s computer to identify them in a way necessary to simplify or waive a particular operation. Cookies are harmless to both the computer and its user and their data.
The operation of cookies is conditional on their acceptance by the browser and not being removed from the disk.
The Client may disable cookies in the browser settings or use the so-called incognito mode in the browser. Disabling or limiting cookies may restrict or prevent the use of some parts of the website.
MBC uses cookies for statistical purposes, marketing profiling, user authorization on websites, tailoring the appearance of websites to the Client’s preferences and browsing history, and for other marketing purposes.
Cookies may contain personal data of the user, although in most cases this will be only the email address. This data is available only to the Client of that particular computer as well as to our websites.
Bringing order & operational separation to medium and small companies.