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Privacy Policy

This Website https://astriva.pl/ (hereinafter “Website”), is the property of Astriva Sp. z o.o. with its registered office in Przybysławice 5A, 63-440 Raszków, Poland, hereinafter referred to as the “Administrator”. The privacy policy defines the principles of obtaining, processing and sharing personal data for the implementation of services provided electronically by the Administrator. The use of the Website is equivalent to the User familiarizing himself with the content of this document and expressing his consent to the provisions contained therein. Acceptance of the Privacy Policy does not exclude or replace the consent to the processing of personal data, necessary for the correct execution of contracts concluded through the Website. If you have any questions, comments or requests regarding this Privacy Policy, please contact us at the address provided below.

Designation of the responsible entity

The entity responsible for the implementation of the tasks indicated in the Privacy Policy and the Administrator of personal data is Astriva Sp. z o.o. with its registered office in Przybysławice 5A, 63-440 Raszków, Poland.

Definitions

  1. Administrator — Astriva Sp. z o.o. with registered office in Przybysławice 5A, 63-440 Raszków, Poland.
  2. Personal data — all information about a natural person identified or identifiable by one or more specific factors determining physical, physiological, genetic, psychological, economic, cultural or social identity, including device IP, location data, web identifier and information collected through cookies and other similar technology.
  3. Processing of personal data — this is any action on personal data, whether it is carried out in an automated manner or not, e.g. collection, storage, fixation, ordering, modification, viewing, use, sharing, restriction, deletion or destruction.
  4. Policy — this Privacy Policy.
  5. GDPR — Regulation (EU) 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.
  6. Website — Website maintained by the Administrator at [astriva.pl]
  7. User — a natural person, legal entity or organizational unit without legal personality, having at least limited legal capacity, visiting the Website or using one or more services or functionalities described in the Policy.
  8. Cookies — IT data, including small text files, saved and stored on devices used for electronic contact with the Service, using a web browser, through which the User uses the Website's websites.
  9. Administrator's cookies — cookies placed by the Administrator, related to the provision of electronic services by the Administrator via the Website.
  10. Device — an electronic device used by the User to use the functionality of the Website.

When does this Privacy Policy apply?

This privacy policy applies to all cases in which Astriva Sp. z o.o., is the administrator of personal data and processes personal data as part of sales or service activities. This applies both to cases in which the processing of personal data takes place after obtaining them directly from the data subject, as well as when personal data have been obtained from other sources.

Data processing in connection with the use of the Website

In connection with the User's use of the Website, the Administrator obtains, stores and processes data to the extent necessary for the provision of individual services offered. The Administrator also obtains information about the User's activity on the Website. The collection, processing and storage of personal data is carried out in accordance with the purposes indicated below.

Purposes and legal bases of data processing on the Website

  1. The collected personal data of Website Users (including IP address or other identifiers and information collected through cookies or other similar technologies) and non-registered Users (i.e. persons without a profile on the Website) are processed by the Administrator:
    • for the purpose of providing electronic services in the scope of providing Users with content collected on the Website, providing a contact form and a form for consenting to receive commercial information electronically, in accordance with Article 6 (1) (b) GDPR, i.e. processing is necessary for the performance of a contract to which the data subject is a party or to take action at the request of the data subject before concluding a contract;
    • for the purpose of handling registrations (including meetings, registrations for groups, for therapies, examinations, etc.) made on the Website, in accordance with Art. 6 (1) (b) GDPR, i.e. the processing is necessary for the performance of 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 the contract;
    • for the purpose of handling complaints, in accordance with Article 6 (1) (b) of the GDPR, i.e. the processing is necessary for the performance of 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 the contract;
    • for analytical, statistical and optimization purposes, consisting in conducting analyses of Users' activity, as well as their preferences in order to improve the functionalities used and services provided in accordance with Article 6 (1) (f) of the GDPR, i.e. processing is necessary for the purposes arising from the legitimate interests pursued by the Controller.
  1. The User's activity in connection with the use of the Website, including his personal data, is recorded in the logs of the system monitoring and imaging the activity of users on the Website (internal or external computer program used to store a chronological record containing information about events and activities within the Service). The data collected in the logs, information processed in connection with the provision of services, is also processed by the Administrator for technical purposes, including in order to ensure the security and correct functioning of IT systems, e.g. in connection with making backup copies, testing changes in IT systems, detecting irregularities or protection against abuse and attacks.

Purchase of a good or service

  1. The purchase of goods or services by the Website User is associated with the processing of his personal data. Mandatory data (duly marked on the form) is required in order to accept and process the reservation. Refusal to provide them results in non-fulfillment of the reservation. The provision of other data is optional (optional).
  2. Purposes of personal data processing:
    • for the purpose of completing a reservation — for mandatory data: the necessity of processing for the performance of the contract, in accordance with Article 6 (1) (b) of the GDPR in conjunction with Article 9 (2) (b) and (h) GDPR; for optional data: the consent of the holder of personal data, in accordance with Article 6 (1) (a) (a) of the GDPR in conjunction with Article 9 (1) (a) and (h) of the GDPR;
    • in order to fulfill the statutory obligations incumbent on the Controller, resulting in particular from tax regulations and accounting regulations, in accordance with Article 6 (1) (c) of the GDPR, i.e. the processing is necessary to fulfill the legal obligation incumbent on the Controller;
    • for analytical, statistical and optimization purposes, consisting in conducting analyses of Users' activity, as well as their preferences in order to improve the functionalities used and services provided in accordance with Article 6 (1) (f) of the GDPR, i.e. the processing is necessary for the purposes arising from the legitimate interests pursued by the Controller;
    • in order to establish and assert claims or defend against them, in accordance with Article 6 (1) (f) GDPR in conjunction with Article 9 (2) (f) and (g) GDPR, i.e. the processing is necessary for the purposes arising from the legitimate interests pursued by the Controller.

Contact forms

  1. As part of the functionality of the Website, the Administrator provides the opportunity to contact him, using electronic contact forms. The use of the form by the User requires the provision of personal data necessary for the feedback and response to the sent inquiry. The user is also entitled to provide other data in order to facilitate contact or to handle the enquiry. Providing personal data (appropriately marked in the form) is required in order to accept and handle the inquiry. Refusal to provide them results in the inability to respond to the submitted query. The provision of other data is optional (optional).
  2. Purposes of personal data processing:
    • for the purpose of identifying the sender and handling the sent inquiry, in accordance with Article 6 (1) (b) GDPR, i.e. the processing is necessary for the performance of the service to which the data subject is a party or to take action at the request of the data subject prior to the provision of the service;
    • for analytical, statistical and optimization purposes by keeping statistics of queries submitted by Users via the Website and in order to improve its functionality and improve the customer service process, in accordance with Article 6 (1) (f) of the GDPR, i.e. processing is necessary for the purposes arising from the legitimate interests pursued by the Administrator.

Marketing

  1. The Administrator processes personal data of Users in order to carry out marketing activities, consisting of;
    • sending to Users, with their express, prior and revocable consent at any time, e-mail and/or text message reminders about reserved visits, notifications about current events within the Service, changes in the offer and planned promotional actions, which in some cases contain commercial information;
    • conducting other types of activities related to direct marketing of goods and services (sending commercial information by electronic means and telemarketing activities).
  1. Marketing activities are carried out with the prior, express and direct consent of the User expressed by ticking the appropriate box of the form. The consent granted may be revoked or modified by the User at any time. Upon withdrawal of the given consent, the Administrator ceases to use the User's personal data for marketing purposes.

Automatic processing of personal data

  1. The information collected by the Administrator in connection with the use of the Website may be processed in an automated manner (including in the form of profiling), however, this will not cause any legal consequences for a natural person or similarly significantly affect his situation. The Administrator attaches particular importance to the issue of profiling and indicates that:
    • for profiling purposes, it does not process any sensitive (sensitive) data,
    • for profiling purposes, as a rule, processes data that have previously been pseudonymized or such data that have been aggregated,
    • if it is not possible to achieve the purpose other than by profiling personal data not pseudonymized or not aggregated, typical data are used for this purpose: e-mail address and IP address or cookies
    • profiling is carried out in order to analyze or predict the personal preferences and interests of people using the Website or products or services and to match the content found on the Website or products to these preferences
    • profiling is carried out for marketing purposes, i.e. matching the offer of services and marketing to the aforementioned preferences.

Period of processing of personal data

  1. The period of processing of personal data by the Administrator depends on the type of service provided and the purpose of processing. Personal data are processed for the duration of the provision of the service, the execution of the order or the execution of the application. The termination of the processing of personal data occurs at the time of withdrawal of the consent given to their processing or the notification by the User of an effective objection to the processing of personal data in cases where the legal basis for data processing is the legitimate interest of the Administrator. The termination of the processing of personal data also occurs automatically, if the purpose for which they were collected and processed is fulfilled.
  2. The period of data processing may be extended in connection with the implementation of legal obligations incumbent on the Administrator, as well as in the case of processing personal data in order to establish and pursue possible claims or defend against them. After the end of the processing period, the data is irretrievably deleted or anonymized.
  3. In general, the time for which personal data are processed depends on the legal basis constituting the legal basis for the processing of personal data by the Administrator.
  4. As a general rule, the Administrator will not process personal data for more than a period longer than is due to the legal basis and/or consent of the Users. And so:
    • in the event that the Administrator processes personal data on the basis of consent, the processing period lasts until the User withdraws this consent;
    • in the event that the Controller processes personal data on the basis of the legitimate interest of the Data Controller, the processing period lasts until the aforementioned interest ceases (e.g. the limitation period for civil claims) or until the data subject objects to further such processing — in a situation where such objection is justified in accordance with the provisions of law;
    • in the event that the Controller processes personal data because it is necessary due to the applicable legal provisions, the periods of data processing for this purpose are determined by these provisions;
    • in the absence of specific legal or contractual requirements, the basic data retention period in the case of records and other supporting documentation drawn up in the course of the performance of the contract is a maximum of 10 years.

User Permissions

  1. The subjects to whom the personal data transferred and processed are entitled to the following rights:
    • the right to information about the processing of personal data — the holder of personal data, by submitting a request addressed to the Administrator, receives information about the processing of his personal data, about the purposes and legal bases of processing, the scope of the data held by the Administrator and about the entities to which the personal data of the controller are disclosed. This information also contains a mention of the planned date of deletion of the data held by the Administrator;
    • the right to obtain a copy of the data — the holder of personal data by submitting a request addressed to the Administrator receives a copy of the processed data concerning the person making the request;
    • the right to rectification — the holder of personal data by submitting a request addressed to the Controller may request the removal of possible inconsistencies or errors concerning the personal data processed, and to supplement or update them if these data are complete or have changed;
    • the right to delete data — the holder of personal data by submitting a request addressed to the Administrator may request the deletion of data, the processing of which is no longer necessary to achieve any of the purposes for which they were collected;
    • the right to restriction of processing — the holder of personal data, by submitting a request addressed to the Controller, may demand the cessation of operations on personal data, with the exception of operations to which the controller has consented and their storage, in accordance with the adopted retention rules, or until the reasons for the restriction of data processing cease (e.g. until the competent decision of the supervisory authority authorizing further processing of the data) ceases;
    • the right to data portability — the holder of personal data, by submitting a request addressed to the Controller, may request the issuance of the processed personal data in a format that allows them to be read by the computer to the holder, or to a third party indicated by the controller, provided that there are technical possibilities in this regard both on the part of the Administrator and the entity indicated by the controller to whom the data is to be transferred;
    • the right to object to the processing of data for marketing purposes — the holder of personal data by submitting a request addressed to the Administrator may at any time object to the processing of his personal data for marketing purposes. The objection does not require justification;
    • the right to object to other purposes of data processing — the holder of personal data by submitting a request addressed to the Administrator may at any time object to the processing of his personal data on the basis of the Controller's legitimate interest (e.g. for analytical or statistical purposes or for reasons related to the protection of property). The objection requires justification and is subject to consideration by the Administrator;
    • the right to withdraw consent — the holder of personal data by submitting a request addressed to the Administrator may at any time revoke the consent granted to the processing of his personal data. The withdrawal of consent does not affect the lawfulness of the processing carried out before the withdrawal of consent by the controller;
    • right to complain — if it is considered that the processing of personal data violates the provisions of the GDPR or other provisions on the protection of personal data, the controller of personal data to whom the data relate is entitled to lodge a complaint with the President of the Office for Personal Data Protection.
    • A request regarding the exercise of the rights of the holders of personal data can be submitted electronically to the following address: [biuro@astriva.pl]
  1. The request should indicate the holder of the personal data and indicate what the request relates to, in particular:
    • indicate which right the applicant wishes to exercise;
    • indicate which processing process the request relates to;
    • specify the processing purposes for which the request relates.
  2. In the event that the Administrator is unable to determine the content of the request or identify the applicant based on the application made, he will ask the applicant for additional information.
  3. The administrator provides a response within 30 days from the date of receipt of the request. If it is necessary to obtain additional information referred to in paragraph 4, this period shall run from obtaining it from the holder. If it is necessary to extend the period of consideration of the application, the Administrator will inform the applicant of the reasons for such extension.
  4. The Administrator shall provide a response in the form in which the controller submitted the request to the Administrator, unless this request specifies the form that the response should have.

Recipients of data

  1. In connection with the provision of services, Users' personal data will be disclosed to external entities, including in particular suppliers responsible for the operation of IT systems, entities such as banks and payment operators, entities providing services (accounting, legal, audit, consulting), couriers, postal operators.
  2. The Administrator reserves the right to disclose selected information concerning the User to competent authorities or third parties who request such information, based on an appropriate legal basis and in accordance with the provisions of applicable law.

Security of personal data

  1. The Controller conducts a risk analysis on an ongoing basis in order to ensure that Users' personal data are processed by him in a secure manner — ensuring, first of all, that only authorized persons have access to the data and only to the extent that it is necessary due to the tasks performed by them.
  2. The Administrator takes all necessary measures in order to ensure an adequate level of security of personal data transferred and processed on the Controller's orders by third parties.

Cookies policy

  1. Automatic data collection:
    • data transmitted by the user's device, used for communication with the Administrator's servers, are subject to automatic collection.
    • the data referred to in the preceding paragraph include, inter alia:
    • IP address;
    • geolocation data;
    • information about the system and web browser used;
    • other data used to create and display internet traffic statistics on the Services.
    • the data specified in the preceding paragraph are collected and processed in order to analyze the scope and attendance and optimize the structure and content of the Website.
  2. Types of cookies used:
    • Cookies used by the Administrator are safe for the User's device.
    • Through the files indicated in the preceding paragraph, it is not possible for viruses or other unwanted software or malware to enter the Users' devices.
    • The Administrator's cookies allow to identify the software used by the User on the devices used by him and to adapt the Service individually to the hardware and software configuration used by the Users.
    • The cookies used contain the name of the domain from which they come, the duration of their storage on the User's device and the assigned value.
    • The administrator uses the following types of cookies:
    • session cookies (temporary) — stored on the User's device, remaining on it until the end of the session of the given browser. Closing the browser permanently deletes saved files from the device's memory;
    • persistent cookies — stored on the User's device and remaining there until they are deleted by the proper functionality of the browser. Terminating a browser session or shutting down your device does not delete them.
    • The mechanism of cookies specified in the preceding paragraph does not allow the downloading of any personal data or any confidential information from the User's device.
    • The user has the possibility to limit or disable the access of cookies to his device by appropriately configuring the browser used.
    • Disabling or limiting the use of cookies may result in partial or complete unavailability of the Website.
  3. The purposes for which cookies are used:
    • The administrator uses cookies for the following purposes:
    • configuration of the Website, understood as adapting the content of the Website to the User's preferences and optimizing the use of the Website's websites;
    • analysis and research and audience auditing, by collecting general and anonymous statistical data, creating anonymous statistics through analytical tools that help to understand how the Website Users use the Website's websites, which makes it possible to improve their structure and content;
    • providing advertising services by presenting advertising messages tailored to the User's preferences.
  4. Determining the conditions of storage or access by cookies:
    • The User may independently and at any time change the settings concerning cookies, specifying the conditions for their storage and access by Cookies to the User's device;
    • changes to the settings referred to in the preceding paragraph can be made by the User through the appropriate settings of the Internet browser or by means of the configuration of the service used;
    • The User has the possibility to change the settings used, in particular in a way that allows blocking the automatic use of cookies or informing the User about each time cookies are placed on the device used by him;
    • detailed information on the possibilities and methods of handling cookies are available in the software settings (web browser), as well as in the technical support files;
    • The user has the right to delete cookies at any time using the available functions in the web browser.
  5. Links to Third Party Websites:
    • the links posted on the Website may redirect the User to other websites, also to the Services of other companies affiliated or cooperating with the Administrator;
    • In the case of Third Party Services, a different privacy policy may apply from this one.

Change of privacy policy

  1. The Administrator reserves the right to modify this document in accordance with the currently maintained Privacy Policy. The document in modified form is valid from the date of its publication on the Website.
  2. This Privacy Policy is effective as of the date of its announcement.

Other questions, doubts

If you have any questions, reservations or doubts regarding the content of this Privacy Policy or the way the Controller processes personal data, please send a message with detailed information to the following address: [biuro@astriva.pl]. Any messages received will be considered and answered.