1. Personal Data Controller
  2. The Controller of your personal data is Enterosoft Sp. z o. o. with its registered office in Gdańsk, ul. Starodworska 1, 80-137 Gdańsk, court registration (KRS): 0000850020, Tax ID (NIP): 5833401725, National Official Business Register (REGON): 386524824 (hereinafter: we). You can contact us in the following way:

    • by letter at the following address: Enterosoft Sp. z o. o., ul. Starodworska 1, 80-137 Gdańsk
    • by e-mail: privacy@enterosoft.com
  3. Data Protection Officer
  4. As we have no duty to do so, we have not appointed the Data Protection Officer. You may obtain a response to any doubts and questions about personal data by sending an e-mail to: privacy@enterosoft.com

  5. Definitions
  6. Application, Service – an electronic service offered by the Controller in compliance with the Rules.

    User – a natural person irrespective of age, or an entrepreneur in the meaning of the Entrepreneurs’ Law Act of 6 March 2018, a person acting on the entrepreneur’s behalf or collaborating with the entrepreneur, who uses the Services made available by the Controller in compliance with the Rules.

    Account – the User account, a set of resources and authorisations allocated to the particular User.

    Password – an encrypted sequence of characters, alphanumeric (consisting of letters and digits) in principle, permitting User authorisation and permitting his or her access to the certain functions of the Service related to the User's activity, which is only possible following User authentication. Entering the Password may be necessary for the service to perform the User’s instructions.

    Cookie files or other similar technologies – Cookie files or other tools used in Applications, intended for similar purposes i.e. collection, recording and storage of information about Users’ activity.

    Rules – the Rules for the provision of electronic services, as made available by the Controller.

    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).

    Mobile Device – a portable electronic device permitting data processing, reception and transmission without the need to maintain a cable connection with the Internet.

  7. Purposes, time and legal basis for data processing
  8. When our Applications are used, we will process the Users’ data for the following purposes:

    • provision of the service and ensuring the option to use the functionalities of Applications. If the Application permits sharing information recorded on the User Account, we will also gather information on other Users. Data are processed in compliance with Article 6(1)(b) of the GDPR, to the extent as the Service is used, and are processed throughout the time of the provision of the Service and for 5 years from the end of the calendar year in which cooperation ended.
    • complaint handling: in the course of complaint handling, we process several data, including the User’s first and last name, e-mail, information on the User’s taking advantage of the Services, Cookie Files or other similar technologies and information about devices. Data are processed in compliance with Article 6(1)(b) of the GDPR for the provision of the Services and over the time necessary to handle complaints, not longer than for 3 months from the end of the complaint procedure, for storage purposes, in case there is a need for defence against claims, if any.
    • conducting explanatory proceedings: if explanatory proceedings are undertaken which concern any breach of the Rules, law, rules of social contract or good manners, or if proceedings are undertaken to pursue claims by the Controller or other Users or entities, for the defence against claims made by Users or other entities, we may process personal data of specific Users until the end of the proceedings and until the expiry of the time for prescription of the Controller’s claims against the User, such time usually being 3 years. If personal data are processed for the pursuance of other Users’ claims, those data may be disclosed for that purpose to another User, entity or public authority entitled under law, e.g. courts, the Police or prosecution service. Those data will then be processed, including disclosure, in compliance with Article 6(1)(c) of the GDPR, i.e. to perform a legal obligation, or in compliance with Article 6(1)(f) of the GDPR, i.e. in the Controller’s legitimate interest consisting in pursuing his claims against the User. The Controller’s legitimate interest will then be overriding in relation to his rights and freedoms.
    • analysing traffic at the website and measuring Application usage (Google Analytics): we process information about Service usage, such as the IP address, information about the Mobile Device on which the Application is installed (the operating system, device model, Application configuration), data about errors from the Application, time and date of Application usage and the advertising ID as well as cookie files or other similar technologies. You can manage your cookie settings from within your web browser or by installing special add-ons that allow you to control your cookies. These data are processed on the basis of Article 6(1)(f) of the GDPR for the Controller’s legitimate interest in facilitating the use of the Service and improving its quality and functionality. The information is processed for 3 months from its acquisition, but no longer than until the data subject has filed an objection.
    • site protection against automatons (Google Recaptha)

    Personal data collection during a visit at our website:

    • When the website is used only to obtain information, i.e. if you do not register or otherwise provide us with information, we only collect personal data that are transmitted to our server by your browser. If you wish to browse our website, we collect the following data, which we need for technical reasons in order to display our website and guarantee its stability and security (the legal basis is Article 6(1)(f) of the GDPR):
      • IP address
      • date and time of the enquiry
      • time difference in relation to Greenwich Mean Time (GMT)
      • request content (a particular site)
      • access status/HTTP response code
      • data volume transfer
      • the website from which the request originates
      • browser
      • operating system and its interface
      • browser language and software version.
    • When you use our website cookie files are saved on your computer. Cookie files are small text files recorded in the memory of your computer and allocated to the browser used by you. Thanks to these files, we receive specified information. Cookie files may not start any programmes or transfer viruses to your computer.
    • Types of cookie files:
      • Transient cookies are temporary cookies that are automatically deleted when you close the browser. These include, in particular, session cookies. They store the so-called session ID, which permits the allocation of various browser requests to a common session. Thanks to that, it is possible to recognise your computer again if you return to our website. Session cookies are deleted when you log out or close your browser.
      • Persistent cookies are permanent files that are deleted automatically after specific time, which may vary depending on the type of the file. Cookie files may be deleted at any time through the use of the security settings of the browser.
      • We use cookie files to be able to identify you during your next visit.
      • The above data are processed on the basis of Article 6(1)(f) of the GDPR for the Controller’s legitimate interest in facilitating the use of the Service and improving its quality and functionality. The information is processed for 3 months from its acquisition, but no longer than until the data subject has filed an objection.
    • You can configure your browser settings as you wish and, for example, refuse to accept third-party or all cookie files. Please note, however, that then you will not be able to use all the functions of this website to the full extent.

    Use of data in the course of our cooperation:

    • Marketing activities: we may send information to Users with regard to our promotional activities. We do not undertake any profiling activities, in particular we do not analyse information we obtain about Users and do not create their behavioural profiles for marketing purposes. Processing takes place on the basis of the Controller's legitimate interest (Article 6(1)(f) of the GDPR) in undertaking marketing activities in order to present marketing information.
    • Other uses: The data will be used for ongoing billing, documenting the performance of the agreement, as well as for contact for the purposes mentioned above. And also for diagnostics, traffic analysis and marketing campaign effectiveness analysis (Google Analytics).

    Account deletion or data change

    • The User may delete his or her account or change his or her personal data by using the options available in the Services. In some Services, the Account is also deleted after 1 month from the definite end of the Service usage.
  9. Data recipients
  10. We will transfer your personal data to:


  11. Your rights in relation to the processing of your personal data and automated decision-making
  12. You have the following rights in relation to the processing of your personal data:

    • the right to withdraw your consent to data processing,
    • right of access to your personal data,
    • pthe right to request the rectification of your personal data,
    • the right to request the erasure of your personal data,
    • the right to request the restriction of processing of your personal data,
    • the right to object the processing of your data due to your particular situation – in cases where we process your data on the basis of our legitimate interest,
    • the right to the portability of your personal data, i.e. the right to receive your personal data from us in a structured, commonly used, machine-readable format. You may transmit these data to another controller or request us to send your data to another controller. However, we will do that only if such transmission is technically possible. You have the right to personal data portability only with respect to the data processed by us on the basis of the agreement with you or your consent,

      Right to withdrawal of consent
      To the extent that your data are processed on the basis of your consent, you have the right to withdraw your consent to data processing at any time. The withdrawal of consent does not affect the lawfulness of processing based on your consent before its withdrawal. You may withdraw your consent by sending a statement of consent withdrawal to our correspondence or e-mail address. To exercise the above rights, please contact us. The right to lodge a complaint with an authority You also have the right to lodge a complaint with the supervisory authority dealing with personal data protection i.e. the President of the Personal Data Protection Office.
  13. Automated data processing and profiling
    • We point out that, with regard to data concerning the way in which the services are provided by us, it is possible to implement IT solutions resulting in the automatic notification of individual categories of events to the Controller, in particular of the balance and frequency of billings or purchase preferences. In each case, such information may only result in the presentation of potential proposals for the purchase of goods or services to you if you have given the relevant consent or voluntarily used the solutions made available by us.
    • Our website uses Google Analytics, a web analytics service provided by Google Inc. (“Google”). Google Analytics uses the so-called “Cookies” i.e. text files saved on your computer and enabling the analysis of website usage by you.
    • We use Google Analytics to analyse the use of our website and improve it on a regular basis. Thanks to the statistics, we can improve our offer and make it more interesting for you as the Users. With regard to the exceptional cases in which personal data are transferred to the USA, Google complies with the EU-US Privacy Shield agreement, www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics is Article 6(1)(f) of the GDPR.
    • Information of the external provider: Google Dublin, Google Ireland Ltd., Gordon House, Barrow Street, Dublin 4, Ireland, fax: +353 (1) 436 1001. Conditions of usage https://policies.google.com/privacy , Information on personal data protection:https://policies.google.com/terms .

  14. Transfer of personal data to third countries
  15. We may transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular the USA. The providers of these tools guarantee an adequate level of protection of personal data through the relevant compliance mechanisms provided by the GDPR, in particular the use of standard contractual clauses.

  16. Security
  17. We ensure the confidentiality of any personal data provided to us. We ensure that appropriate security and data protection measures are taken as required by data protection laws. Personal data are collected with due care and adequately protected from access by unauthorised persons.

  18. Changes in the Privacy Policy
  19. The Privacy Policy may be supplemented or updated as necessary in order to provide current and reliable information to Users with regard to their personal data and information about such data. Any changes to the Privacy Policy will be notified to the Users in the Rules of the Service and, if the Controller deems it appropriate or necessary, at the e-mail address provided to him.