Privacy Policy

PRIVACY POLICY
KANCELARIA RADCY PRAWNEGO
Barbara Szul

www.barbaraszul.com

§ 1 INTRODUCTION

1. KANCELARIA RADCY PRAWNEGO Barbara Szul is incorporated and
   registered under the laws of Poland with the tax identification number
   5170111959 (“the Kancelaria”).
2. The Kancelaria wants to be transparent about how collects, processes, stores,
   uses, protects and discloses personal data. This privacy policy (“the Policy”)
   applies to all users of the Kancelaria website, whether it is a former, existing or
   potential client, or just a visitor.
3. By accessing and using the Kancelaria website, the User acknowledges that
   read, understood and agrees to be bound by the provisions of this Policy. If the
   User does not agree with any part of this Policy, it is necessary to discontinue
   the use of the website.
4. The Kancelaria is a personal data controller and complies with the
   requirements of international data protection law and, where applicable, the
   General Data Protection Regulation (GDPR) of the European Union.

§ 2 TYPES OF PERSONAL DATA AND SOURCES OF IT

1. The Kancelaria only collects the personal data relevant in the context of the
   relation with the User.
2. Preliminary, the Kancelaria collects data directly from the User. When
   necessary, the Kancelaria may collect data from other sources, in particular
   from publicly available sources or third-party service providers.
3. The Kancelaria may collect and process the personal data including but not
   limited to:
   a) IP address and geolocation;
   b) name and contact information, like email address and phone number;
   c) information needed for the Know-Your-Customer procedure (KYC), like
   residential address, ID document details, date and place of birth;
   d) financial information like source of funds, source of wealth,
   employment status;
   e) biometric data for the purpose of verifying the User identity;
   f) records related to the relation with User and provided services;
   g) records of calls and electronic communication with the User.
4. The User is not obligated to provide the personal information. However, in
   case of refusal, the Kancelaria may not be able to provide services, and also
   fulfil legal and regulatory requirements.

§ 3 PURPOSES OF USING PERSONAL DATA

1. The Kancelaria collets and processes personal data for the following
   purposes:
   a) to provide, operate, maintain and improve services;
   b) to communicate with the User;
   c) to send promotional communications about new services, features or
   events;
   d) to comply with the legal and regulatory requirements and with the
   requests of the public authorities or law enforcement;
   e) to detect and prevent of frauds or other potential prohibited or illegal
   activities;
   f) to investigate, evaluate, bring and defend legal claims;
   g) to analyse usage trends and preferences to improve service quality.
2. If the Kancelaria wishes to collect and process personal data in the extent not
   covered by law, the User consent is required. The User may withdraw the
   given consent at any time. The withdrawing of consent does not render the
   prior handling of personal data unlawful, and it might have an impact on the
   ability to continue the providing of services. The Kancelaria relies on the User
   consent for the following purposes:
   a) to verify the identity by using biometric data;
   b) to analyse and personalise marketing content;
   c) to provide marketing content; 
   d) to share personal data, name, email, and phone number with the third-
   party partners for marketing purposes;
   e) to collect behavioural and statistical data (cookies) from using the
   website.

§ 4 SHARING PERSONAL DATA

1. The Kancelaria does not sell, rent or trade personal data to third parties.
2. Where necessary, the Kancelaria may share information about the User with:
   a) third-party service providers performing services for the Kancelaria,
   subject to the confidentiality obligations and agreements regarding data
   processing;
   b) public authorities, including courts, regulatory authorities and tax
   authorities;
   c) law enforcement agencies;
   d) the User explicit consent for purposes not covered herein.
3. The operates globally and may transfer the personal data to the places
   outside of the User country of residence. The Kancelaria implements
   appropriate standards to make sure that the User personal data is protected.
   By using the Kancelaria website, the User consent to transfer its personal data
   outside of the country of residence.
4. The Kancelaria shall only disclose information about the User as permitted
   under the law, contractual terms and confidentiality obligations.

§ 5 KEEPING PERSONAL DATA

1. The Kancelaria retains personal data as long as necessary for the purposes
   for which it has been collected.
2. Personal data collected for the identifying and verifying the User during the
   KYC procedure, and to provide services shall be kept for three years from the
   end of any relation with the User.
3. If the User gave consent to collect and process personal data by the
   Kancelaria, in particular for marketing purposes, the Kancelaria shall kept
   personal data until the withdrawn of given consent by the User.
4. Notwithstanding the above, the Kancelaria may keep certain information for
   longer periods where it is needed by law, regulatory requirements or legitimate
   business purposes.

§ 6 DATA SECURITY

1. The Kancelaria implements comprehensive technical, administrative and
   physical measures to protect the personal data against unauthorized access,
   alternation, disclosure or destruction, like:

a) secure server infrastructure;
b) encryption of data in transfer;
c) access controls;
d) regular security assessment and audits;
e) employee training on data protection and security practices.
2. The Kancelaria cannot guarantee absolute security of the User personal data.
3. The User is obligated to maintain the confidentiality of the account credentials
and login data.

§ 7 DATA PROTECTION RIGHTS

1. Subject to the legal and regulatory requirements, the User has the right to:
   a) access to its personal data held by the Kancelaria (right of access);
   b) correct inaccurate or incomplete personal data (right of correction);
   c) withdraw the consent for processing personal date where the consent is
   a legal basis (right to withdraw consent);
   d) erase the personal data where there is no good reason for continuing to
   process it by the Kancelaria (right to be forgotten);
   e) restrict the processing of personal data under certain circumstances
   (right to restriction);
   f) transfer the personal data in a commonly used electronic format (right
   to data-portability);
   g) object to the processing of personal data by the Kancelaria based on
   legitimate interest (right to object).
2. To execute any of the right, the User has to contact the Kancelaria directly.
   The Kancelaria is obligated to response without undue delay.

§ 8 UPDATES OF THE POLICY

1. The Kancelaria may update this Policy at any time.
2. All updates shall be effective after the posting on the Kancelaria website.
3. The Kancelaria is obligated to notify the User about any substantial updates, in
   particular when it affects how the personal data is processed.
4. The further using of the Kancelaria services constitutes the User acceptance
   of updated Policy.