Version binding from: 19/05/2021
Demoboost Sp. z o.o. a limited liability company incorporated in Poland, with its principal place of business at Warsaw, ul. Stawki 2, 00-964, Demoboost Sp. z o. o. registered at the District Court of Warsaw, Poland created this policy in line with its commitment to your privacy as a website user of https://demoboost.com (and any related site or mobile device application designated by us, hereinafter referred to as the Website)), as may be updated by us from time to time and/or a person with whom we cooperate, including our clients, business partners, and their representatives (hereinafter referred to as “Users” “You” and “Yours”). Unless specifically referred to a given category of data subjects, the below provisions apply to all of them. For the terms of this policy, Demoboost Sp. z o. o. is a controller in the meaning of art. 4 of GDPR of any data in particular personal data collected in connection with Website and our business. The terms “we”, “us”, “our” refer to Demoboost Sp. z o. o. (hereinafter referred to as “Demoboost” or “DB”). If you have any questions regarding the processing of your personal data, please contact us at: email@example.com.
Terms Used in the Policy
The terms given below have a following meaning:
GDPR – refers to the European Parliament and Council Regulation (EU) 2016/679 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 (a General Data Protection Regulation).
Personal Data − refers to any information relating to an identified or identifiable natural person. An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an email address or a telephone number of the person and other data when combined with the above.
--Sensitive Personal Data__ – refers to special categories of Personal Data mentioned in Art. 9 of the GDPR and Personal Data mentioned in Art. 10 of the GDPR include: racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, criminal convictions and offences or related security measures, genetic data, biometric data for the purpose of uniquely identifying a person, health, sex life or sexual orientation.
Processing – refers to any operation or set of operations which is performed on Personal Data or on sets of Personal Data, by automated means or otherwise, such as: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
Contractor – refers to a business partner of DB that provides services to DB clients based on DB orders.
Purposes & Legal Basis of Processing
We process Personal Data in order to:
- Execute the agreement concluded by You as our business partner, Contractor, client or in order to undertake actions on your request before the conclusion of the agreement with regards to the processing of Your data as a sole entrepreneur or Your company’s representatives authorized to conclude the agreement with us (Art. 6.1.b of the GDPR) and to make cooperation/execution of the agreement easier with regards to the processing of your contact persons’/representatives’ personal data (Art. 6.1.f of the GDPR).
- Provide responses to your inquiries sent through the website contact form, e-mail or phone. In such a case the legal basis for the processing of your Personal Data is our legitimate interest in contacting You about Your inquiry (Art. 6.1.f of the GDPR).
- Send direct marketing information (including the Demoboost newsletter) to users, clients, and business partners (Contractors), via e-mail addresses they provide on the legal basis of their consent (Art. 6.1.a of the GDPR) and in case we have already a relevant relation with You, based on our legitimate interest (Art. 6.1.f of the GDPR). In cases where we will do marketing profiling, we shall process Your Personal Data based on Your consent, if required. (Art. 6.1.a of the GDPR). Consent/s for sending marketing information in accordance with Art. 10 of the act on rendering services by electronic means and / or Art. 172 of Polish Telecommunications Act, is expressed by You independently and separately.
- Organize competitions by Demoboost, conferences or other events. Your Personal Data will be processed only if You have registered as a participant to above-mentioned. The legal basis for the organization of competitions is consent (Art. 6.1.a of the GDPR).
- Organize and conduct open and dedicated training sessions. In the case of training sessions, the legal basis for the processing of Personal Data is an agreement for the provision of training services conducted with Demoboost by sending electronically the respective order form (Art. 6.1.b of the GDPR).
- If consent is required for the processing in question, it will be sought from You separately to ensure that it is freely given and informed. To the extent that Demoboost relies on Your consent to process Your Personal Data, You have the right to withdraw Your consent to such processing at any time. You can do this by contacting our data protection team at: firstname.lastname@example.org. The withdrawal of Your consent does not affect the lawfulness of its processing based on consent before its withdrawal.
- Please note that we may keep certain information within our measurement tools such as tests, games You take part in, that does not constitute Your Personal Data and that is gathered, stored, and processed according to scientific research standards and can be used in scientific publications and conference presentations. Note that this information does not constitute Your Personal Data and if You withdraw your consent to participate in such skills testing it will be impossible to remove Your anonymized data from the aggregate, anonymized pool.
The Provision of Your Data
Whenever you provide us directly with Your Personal Data, the provision of Your Personal Data, in each case is voluntary, however without its provision, You won’t be able to receive certain information (e.g. marketing newsletters) or take part in training, conferences, competitions, events or we won’t be able to address your enquiry. We may not always receive Your Personal Data directly from You in the case when You are a representative/ contact person of our business partner (Contractor) or client, and your contact details such as name, surname, business title, business email, business phone number are obtained via our client, business partner (Contractor). We may also get such information from other person/entity who recommended You as a Potential Client and Your LinkedIn profile.
Sensitive Personal Data
Demoboost does not process Sensitive Personal Data unless:
- The processing is required or permitted by law or;
- Demoboost has obtained Your explicit consent, such as for the measurement of Your personal characteristics, where relying on consent is permitted or appropriate under applicable law.
You may have certain rights in relation to Your Personal Data. Some of these rights apply only in certain circumstances. If You would like to exercise any of these rights, please contact us at: email@example.com.
- Access: You are entitled to request access to Your Personal Data that we process.
- Correction: You are entitled to ask that any incomplete or inaccurate Personal Data we hold about You is corrected.
- Erasure: You are entitled to ask us to delete or remove Your Personal Data in certain circumstances. There are also certain exceptions where we may refuse a request for erasure, for example, where the Personal Data is still required in relation to the purposes for which it was collected.
- Restriction: In some circumstances, You are entitled to ask us to suspend the processing of some of Your Personal Data, for example, if You want us to establish its accuracy or the reason for processing it.
- Data Portability: In some circumstances, You may ask us to transfer Your Personal Data to another party.
- Objection: Where we are processing Your personal data based on our legitimate interests (or those of a third party), You may object to its processing. However, we may be entitled to continue processing Your Personal Data if we can demonstrate compelling legitimate grounds for its processing.
- Withdrawing Your Consent: Where Your Personal Data is processed with Your consent, You have the right to withdraw Your consent at any time. The withdrawal of consent will not affect the lawfulness of its processing based on consent before its withdrawal.
You also have the right to file a complaint to a Data Protection Authority. In Poland You can make a complaint to Prezes Urzędu Ochrony Danych Osobowych, ul. Stawki 2, 00-193, Warsaw, Poland.
How Long We Keep Your Personal Data
Demoboost retains personal data to meet the purposes for which the data was collected or in order to ensure compliance with applicable laws or to protect legitimate company interests (e.g. statute of limitations periods). We will store Your personal data for the purposes of:
The execution of the agreement throughout the period of our cooperation with You and the lapse of the statute of limitations period. Answering your enquiries – for the time period of our correspondence and longer if justified to ensure we have an adequate log of our correspondences. Sending marketing materials – for the period of sending You our materials up to the period you shall file your objection to such processing. Keeping the results of Your tests, games, questionnaires in which You participated within our measurement tools, for the period necessary to match You to project opportunities on the Demoboost Platform and Your eventual placement in a project, however no longer than the time required for this purpose. Measuring the effectiveness of the measurement tools we use for the period of time necessary to verify the adequacy and usefulness of these tools within our business model, however no longer than the time required for this purpose.
With Whom Do We Share Your Personal Data
Your data provided to us can be disclosed to:
- Our Business Partners;
- Entities authorized by law to obtain Your Personal Data.
The Transfer of Personal Data to Third Countries
Demoboost does not transfer Your Personal Data to third countries. In case of data transfers to third parties established outside the EEA or Switzerland; in countries which are not deemed by the European Commission to provide adequate data protection (non-adequate third countries), Demoboost shall rely on transfer mechanisms in accordance with applicable laws, which includes (1.) the EU “Standard Contractual Clauses”, (2.) and the Privacy Shield Certification of the third party (if established in the U.S.). When the third party is established in a country that is deemed by the EU Commission to provide adequate data protection, we rely on the protections available under local law.
For more information about, or to obtain a copy of specific transfer mechanisms, including information on any of the existing safeguards implemented by Demoboost in case such transfers occur, please contact firstname.lastname@example.org.
How We Secure Your Personal Data
Demoboost maintains appropriate administrative, technical and physical safeguards designed to protect Your Personal Data against accidental or unlawful destruction, accidental loss, alteration, unauthorized disclosure or access, use, and all other unlawful forms of processing of personal data in our possession.