Section I. General provisions
- We make all reasonable efforts to safeguard the privacy of all Users who visit the Website. We believe that it is important to ensure that personal data is processed in a secure, reliable and lawful manner that is transparent to you.
- We provide you with a secure, encrypted connection when transmitting personal data. We use an SSL certificate.
Section II. Key terms
- “Data Controller” or “we” means Aleksandra Becker of ul. Sokola 24A, 80-654 Gdańsk, NIP (taxpayer ID) 583-317-20-12 and Patryk Becker of ul. Sokola 24A, 80-654 Gdańsk, NIP (taxpayer ID) 583-317-20-12, operating jointly as Project Smile Spółka Cywilna Aleksandra Becker, Patryk Becker, a private partnership with its registered office at ul. Sokola 24A, 80-654 Gdańsk, NIP (taxpayer ID) 583-317-20-12.
- “GDPR” and “Personal Data Protection Act” mean Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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) and the Polish Personal Data Protection Act of May 10, 2018, respectively.
Section III. Types of data processed; purpose and legal basis of processing; retention period
Your personal data will be collected for the following purposes:
- administration of the Website, including statistical and analytical activities associated with the operation of the Website – for that purpose, we process such data as your IP address, Request submission time, amount of data transferred, referrer website, and information regarding your browser and operating system (including browser version and language). The data will be processed for as long as it is available on the Website, that is for five years. The legal basis for processing is our legitimate interest (Article 6(1)(f) of the GDPR);
- performance of the Online Service Agreement referred to in Section I(6) of the Website Terms of Service, which includes without limitation: accepting and responding to your Request and enabling you to view the Provider’s offerings and information regarding the available dental services; facilitating communication between you and the Provider (which includes sending and presenting the Quote and treatment plan in response to your Request); providing assistance in arranging airport transfers and booking accommodation; providing the ability to post ratings and Comments regarding the Provider; and providing the ability to send inquiries to patients who have used the Provider’s services – for that purpose, we process such personal data as first name, last name, PESEL (civil registration number – for Polish citizens only), identity card number or other identity document number, e-mail address, phone number, data concerning health and additional information provided by you in the Request). The data will be processed until the Online Service Agreement has been performed and then for a period equal to the limitations period. The legal basis for processing is the performance of the Online Service Agreement, the acceptance of the Website Terms of Service (Article 6(1)(b) of the GDPR) and, with respect to data concerning health, your consent (Article 9(2)(a) of the GDPR);
- processing of complaints – for that purpose, we process such personal data as first name, last name, correspondence address, phone number, e-mail address and any other data necessary to process the complaint. The data will be processed for a period equal to the limitations period. The legal basis for processing is the performance of the Online Service Agreement and the acceptance of the Website Terms of Service (Article 6(1)(b) of the GDPR);
- determination of, assertion of or defense against claims – for that purpose, we process such personal data as first name, last name, correspondence address, e-mail address, phone number and other personal data which you provide when you use the functionality available on the Website. The data will be processed for a period equal to the limitations period of such claims. The legal basis for processing is our legitimate interest (Article 6(1)(f) of the GDPR).
Section IV. Consent to process personal data
- In order to use the Services presented on the Website, you provide your personal data (including data concerning health) by submitting a Request.
- While the personal data you provide is entered freely on the basis of your consent, it is also required in order to use the Services provided on the Website.
- Your personal data is made available to a Provider in connection with the performance of the Online Service Agreement.
- If you do not provide specific personal data in the Request, it will not be possible to submit and process the Request, and you will not be able to use the Services presented on the Website.
Section V. Disclosure of personal data (recipients of personal data)
- Your personal data may be made available (without limitation) to:
- the service providers that we use in the operation of the Website, including the hosting service provider;
- our employees and associates (including without limitation the entities that assist us in our business activities by providing IT support and telecommunications, marketing, auditing, legal and other services) who process personal data on our behalf under data processing agreements signed with us;
- the entities authorized to receive personal data pursuant to applicable laws and regulations, decisions of government agencies or court orders; and
- the Provider referred to in Section I(8) of the Website Terms of Service.
- Your personal data will not be transferred to third countries.
Section VI. Your rights
- The right to be informed: you have the right to receive clear, concise and transparent information on how we use your personal data and what rights you have in that respect.
- The right to withdraw consent to process personal data (Article 7(3) of the GDPR): to the extent the processing of your personal data is based on your consent, you have the right to withdraw such consent at any time, without affecting the lawfulness of any processing based on that consent before its withdrawal.
- The right to access your personal data and obtain a copy of the data (Article 15 of the GDPR): you have the right to access your personal data that we are processing and to verify whether we are using such data in a lawful manner.
- The right to rectification of your personal data (Article 16 of the GDPR): you may request the rectification of any inaccurate personal data that concerns you.
- The right to erasure of personal data when the processing is not necessary for compliance with a legal obligation (Article 17 of the GDPR): you have the right to have your personal data erased if there are no legitimate grounds for the use of such data.
- The right to restriction of processing of personal data (Article 18 of the GDPR): you have the right to request the restriction of any further use of your personal data.
- The right to personal data portability (Article 20 of the GDPR): you have the right to reuse your personal data if the processing of such data is based on your consent or on a contract and is carried out by automated means.
- The right to object against the processing of personal data (Article 21 of the GDPR): have the right to object to the processing of your personal data at any time on grounds relating to your particular situation.
- The right to complain: you have the right to lodge a complaint with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warszawa) if you believe that we have infringed your rights as regards personal data protection.
Section VII. Cookies
- A cookie is a small piece of text that is sent to your browser by the Website when you visit it. It helps the Website remember information about your browser settings, thus streamlining you experience during the next visit to the site and making it easier to log on to our services.
- The cookie mechanism is safe to Website User’s computers. In particular, it cannot be used by viruses or other unwanted or malicious software to infect your computer. Nevertheless, you have the option in your browser to restrict or disable the ability for cookies to access your computer. If you use this option, you will be able to use the Website with the exception of any features which, by their nature, require cookies.
- We may process the data contained in cookies in order to:
- customize the functionality we provide (including advertising content) to your expectations;
- present you with banner advertisements, that is advertisements in the form of a graphic which, when clicked, will take you to our webpage or a landing page;
- keep statistics without identifying any person (anonymously);
- fill in the Request Form and/or Contact Form; and
- collect general and anonymous statistics using Google Analytics.
- We may collect your IP addresses.
- If the Website contains links and references to other web pages, we will not be responsible for the privacy terms and conditions that apply to these pages.
Section VIII. Final considerations
- For any issues associated with our processing of your personal data, you can contact us by e-mail at the following address: email@example.com.