Privacy Policy

This Privacy Policy sets out the rules for saving and accessing data on Users’ Devices using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing Users’ personal data, which have been provided by them personally and voluntarily via tools available in the Service.

§1 Definitions

Service – the “ewaaffek.com” website operating at https://ewaaffek.com
External Service – websites of partners, service providers, or service recipients cooperating with the Administrator
Service/Data Administrator – The Administrator of the Service and Data (hereinafter “Administrator”) is the individual “Ewa Affek,” residing in Warsaw, providing electronic services via the Service
User – a natural person for whom the Administrator provides electronic services via the Service
Device – an electronic device with software, through which the User accesses the Service
Cookies – text data collected in the form of files placed on the User’s Device
GDPR – 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)
Personal Data – information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, identification number, location data, online identifier, or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural, or social identity of that natural person
Processing – an operation or set of operations performed on personal data or on sets of personal data, whether or not by automated means, 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
Restriction of Processing – marking stored personal data to restrict their future processing
Profiling – any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location, or movements
Consent – the data subject’s freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them
Personal Data Breach – a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to personal data transmitted, stored, or otherwise processed
Pseudonymization – processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
Anonymization – an irreversible process of operations on data that destroys/overwrites “personal data,” making identification or association of a given record with a specific user or natural person impossible.

§2 Data Protection Officer

Pursuant to Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

For matters related to data processing, including personal data, please contact the Administrator directly.

§3 Types of Cookies

Internal Cookies – files placed and read from the User’s Device by the Service’s ICT system
External Cookies – files placed and read from the User’s Device by ICT systems of External Services. Scripts of External Services that may place Cookies on Users’ Devices have been deliberately placed in the Service via scripts and services provided and installed in the Service
Session Cookies – files placed and read from the User’s Device by the Service during a single session of that Device. After the session ends, the files are deleted from the User’s Device
Persistent Cookies – files placed and read from the User’s Device by the Service until they are manually deleted. The files are not deleted automatically after the Device session ends unless the User’s Device is configured to delete Cookies after the session ends.

§4 Data Storage Security

Cookie Storage and Reading Mechanisms – The mechanisms for storing, reading, and exchanging data between Cookies saved on the User’s Device and the Service are implemented using built-in web browser mechanisms and do not allow the retrieval of other data from the User’s Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, trojan horses, and other worms to the User’s Device is also practically impossible.
Internal Cookies – Cookies used by the Administrator are safe for Users’ Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the Device used by the User.
External Cookies – The Administrator makes every effort to verify and select service partners regarding User security. The Administrator selects well-known, large partners with global social trust for cooperation. However, the Administrator does not have full control over the content of Cookies originating from external partners. The Administrator is not responsible for the security of Cookies, their content, or their lawful use by installed Scripts from External Services, to the extent permitted by law. A list of partners is provided later in this Privacy Policy.

Cookie Control

The User may, at any time, independently change the settings regarding the saving, deletion, and access to data of saved Cookies for any website.
Information on how to disable Cookies in the most popular desktop browsers is available on the website: how to disable cookies or from one of the indicated providers:
- Managing cookies in Chrome
- Managing cookies in Opera
- Managing cookies in Firefox
- Managing cookies in Edge
- Managing cookies in Safari
- Managing cookies in Internet Explorer 11
The User may, at any time, delete all Cookies saved so far using the tools of the User’s Device through which the User uses the Service.

User Risks

The Administrator uses all possible technical measures to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s actions. The Administrator is not responsible for interception of this data, impersonation of the User’s session, or deletion thereof as a result of conscious or unconscious activity of the User, viruses, trojan horses, and other spyware with which the User’s Device may be or has been infected. Users should follow safe internet usage principles to protect themselves from these risks.

Personal Data Storage

The Administrator ensures that every effort is made so that the personal data voluntarily entered by Users is secure, access is limited and implemented in accordance with their purpose and processing objectives. The Administrator also ensures that every effort is made to secure the data held against loss by using appropriate physical and organizational safeguards.

§5 Purposes for Which Cookies Are Used

Improving and facilitating access to the Service
Personalizing the Service for Users
Compiling statistics (users, number of visits, types of devices, connections, etc.)

§6 Purposes of Personal Data Processing

Personal data voluntarily provided by Users is processed for one of the following purposes:

Provision of electronic services
Communication between the Administrator and Users regarding the Service and data protection
Ensuring the Administrator’s legitimate interest
Booking appointments online via the Calendly tool, including processing the User’s first name, last name, and email address

Data about Users collected anonymously and automatically is processed for one of the following purposes:

Compiling statistics
Ensuring the Administrator’s legitimate interest

§7 Cookies of External Services

The Administrator uses JavaScript scripts and web components from partners in the Service, who may place their own cookies on the User’s Device. Remember, in your browser settings, you can decide which cookies are allowed for each website. Below is a list of partners or their services implemented in the Service that may place cookies:

Compiling statistics:
- Google Analytics
Advertising activities:
- Google Ads
Online appointment booking:
- Calendly LLC – enables online appointment scheduling and may use cookies for the proper functioning of the service

Services provided by third parties are beyond the Administrator’s control. These entities may change their terms of service, privacy policies, data processing purposes, and cookie usage at any time.

§8 Types of Data Collected

The Service collects data about Users. Some data is collected automatically and anonymously, while some data is personal data voluntarily provided by Users when signing up for specific services offered by the Service.

Anonymous data collected automatically:

IP address
Browser type
Screen resolution
Approximate location
Service subpages visited
Time spent on a given subpage
Type of operating system
Previous subpage address
Referrer page address
Browser language
Internet connection speed
Internet service provider

Data collected during registration:

First name / last name / nickname
Username
Email address
IP address (collected automatically)

Data collected when signing up for the Newsletter:

First name / last name / nickname
Email address
IP address (collected automatically)

Data collected when adding a comment:

First name and last name / nickname
Email address
Website address
IP address (collected automatically)

Data collected when booking an appointment online:

First name and last name
Email address
Other data voluntarily provided in the Calendly booking form

Some data (excluding identifying data) may be stored in cookies. Some data (excluding identifying data) may be transferred to the provider of statistical services.

§9 Access to Personal Data by Third Parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the provided services is not transferred or sold to third parties.

Access to data (usually based on a Data Processing Agreement) may be granted to entities responsible for maintaining the infrastructure and services necessary for the operation of the Service, such as:

Hosting companies providing hosting or related services to the Administrator
Companies through which the Newsletter service is provided
**Personal data provided for the purpose of booking an appointment online may be transferred to Calendly LLC, based in the United States (271 17th St NW, Atlanta, GA 30363, USA), which provides the online booking service as a data processor on behalf of the Administrator.
The transfer of data to Calendly LLC may involve the transfer of data outside the European Economic Area (EEA). Calendly ensures an adequate level of data protection by applying standard contractual clauses approved by the European Commission.**

Data Processing Entrustment – Hosting, VPS, or Dedicated Servers… The Administrator uses the services of an external hosting, VPS, or Dedicated Server provider – OVH sp. z o.o. All data collected and processed in the Service is stored and processed in the provider’s infrastructure located in Poland. There is a possibility of access to data as a result of maintenance work carried out by the provider’s personnel. Access to this data is regulated by an agreement between the Administrator and the Provider.

§10 Method of Personal Data Processing

Personal data voluntarily provided by Users:

Personal data will not be transferred outside the European Union, except where it is necessary to book an appointment online via the Calendly tool. In such cases, data may be transferred to the United States, with appropriate legal safeguards in accordance with the GDPR (standard contractual clauses).
Personal data will not be used for automated decision-making (profiling).
Personal data will not be sold to third parties.

Anonymous data (without personal data) collected automatically:

Anonymous data (without personal data) will be transferred outside the European Union.
Anonymous data (without personal data) will not be used for automated decision-making (profiling).
Anonymous data (without personal data) will not be sold to third parties.

§11 Legal Bases for Personal Data Processing

The Service collects and processes Users’ data based on:

Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR)
- Article 6(1)(a): the data subject has given consent to the processing of their personal data for one or more specific purposes
- Article 6(1)(b): processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
  Processing of personal data for the purpose of booking appointments online is carried out on the basis of Article 6(1)(b) GDPR (necessity for the performance of a contract or to take steps at the request of the data subject).
- Article 6(1)(f): processing is necessary for the purposes of the legitimate interests pursued by the administrator or by a third party
The Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws 2018, item 1000)
The Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)
The Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24, item 83)

§12 Period of Personal Data Processing

Personal data voluntarily provided by Users:

As a rule, the indicated personal data is stored only for the period of providing the Service by the Administrator. They are deleted or anonymized within up to 30 days from the termination of the service (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.)

An exception is a situation that requires securing the legitimate purposes of further processing of this data by the Administrator. In such a case, the Administrator will store the indicated data, from the time of the User’s request for deletion, for no longer than 3 years.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, is stored by the Administrator for the purpose of compiling Service statistics for an indefinite period.

§13 Users’ Rights Related to Personal Data Processing