Dear User!
The law requires us to inform you about how we process your personal data. We have included all the information below. We have tried to do this in as accessible and understandable way as possible. Should you still have any questions on this subject, please contact us by sending an email to dobrykontakt@intu.mobi or a letter to Intu sp. z o.o., ul. Grochowska 309/317D, Apt. 113, 03-838 Warsaw (Poland).
Remember that you can delete all your data from the INTU app at any time. You can do this directly in the INTU app in the Profile tab (the “Delete account” option is at the very bottom) or by asking us to do so via email, sending your request to intumeditation@gmail.com.
I. DEFINITIONS
Controller/Us – we are the Controller of your Personal Data, Intu sp. z o.o. with its registered office in Warsaw, ul. Grochowska 309/317D Apt. 113, 03-838 Warsaw, entered into the Register of Entrepreneurs being part of the National Court Register kept by the District Court for the Capital City of Warsaw, under KRS number: 0000687745, NIP: 1132947168, REGON: 367869305, share capital of PLN 10 000;
INTU App – the INTU application available on [AppStore / Google Play], owned and developed by the Controller;
Personal Data or Data – information that identifies you or makes you directly or indirectly identifiable, e.g., your name, phone number, email address;
Newsletter – a service where we send to your email address information on our activities. The information may include promotional or commercial content;
Third Parties – defined in section V of this Privacy Policy;
Policy – this document, the Privacy Policy;
Terms and Conditions – rules for managing our store and services provided via our Website posted on our Website https://intuyourself.com/pl/;
RODO – a piece of legislation establishing uniform rules for the processing of personal data across the European Union, the exact title of which is 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 (General Data Protection Regulation);
Website – the Website we operate at: https://intuyourself.com/pl/ and the INTU Application, which contains the same content as our Website.
II. WHAT KIND OF DATA DO WE COLLECT?
Most of your Personal Data we collect comes directly from you – you give it to us when you subscribe to our meditations, sign up for our Newsletter, browse our Website or write to us.
We process your following Data: name, email address, phone number. In exceptional cases, if you pay for your subscription by traditional bank transfer, we gain access to your account number and home address.
In addition, we may collect the following information: your internet usage, how often and how long you use the INTU App, how you use our social media profiles – including your IP address, location data, an ID of your device with installed INTU App. We may combine such Data with other data we have about you, particularly for our internal purposes such as making analysis and statistics, supporting our customer service, improving our services and marketing purposes.
III. DATA PROCESSING
We process your Personal Data when you interact with us – whether you subscribe to our meditations, visit our Website or write to us. In this section of the Policy, we have compiled information about all situations in which we process your Data. For each case, we indicate our purpose of processing and the legal basis, and we also inform you how long we will hold your Data.
We may undertake the following activities when processing your Personal Data: collect, capture, organise, store, view, display, use, transfer, share, combine, restrict, delete and destroy.
a) When you contact us by email or via the contact tab on our Website
Purposes and legal basis of processing your Personal Data:
When you contact us by email or via the “contact us” tab on our Website, we process your Personal Data that you enter into the form. We do this to respond to your request. The legal basis for the processing is that the processing is necessary to perform a contract – namely provision of services in accordance with the Terms and Conditions (Article 6(1)(b) of the RODO), and the service, in this case, is to enable you to contact us via our Website.
We also process your Personal Data in case we need to use them in defence against claims addressed to us. Our right to collect your Personal Data is based on our legitimate interest (Article 6(1)(f) RODO), namely defending our rights. It may happen in case you put claims against us in connection with our response to you.
Suppose you contact us with a matter not related to the services we provide. In that case, the legal basis for processing your Personal Data is our legitimate interest (Article 6(1)(f) RODO to correspond with you. In such a case, we only process the Personal Data relevant to the matter related to our communication.
Voluntariness of providing Data and consequences of not doing so:
Your provision of Personal Data is voluntary and is not a statutory or contractual requirement or a condition for concluding a contract. However, failure to provide specific Personal Data (e.g., your email address) may prevent or severely hinder us from contacting you and responding to your enquiry.
Retention period of Personal Data:
We will process the Personal Data for a time necessary to provide you with an answer, and after that for a time required by law (i.e., the period specified by the legislation on the limitation of claims is three years).
b) When you are our client – you use our meditations
Purposes and legal basis of processing your Personal Data:
If you are our customer, we process your Personal Data to conclude and perform a contract and communicate with you. The processing of your Personal Data is necessary for the performance of a contract to which you are a party or to take action at your request before concluding a contract (Article 6(1)(b) RODO), among other things, if you write to us to ask something before you decide to subscribe.
In addition, we also process your Personal Data to:
- initiate and maintain contact with you – based on the Article 6(1)(f) RODO (processing is necessary for our legitimate interests, which include building our client portfolio and improving our services);
- comply with our legal obligations (including for our tax and accounting obligations, processing of complaints) – based on the Article 6(1)(c) RODO;
- identify, pursue a claim or defend against potential claims – based on the Article 6(1)(f) RODO (processing is necessary for the purposes arising from our legitimate interests in defending our rights).
Voluntariness of providing Data and consequences of not doing so:
The provision of Personal Data is a contractual requirement and a condition for the conclusion and performance of the contract and is voluntary. The consequence of failing to provide Personal Data is that the contract cannot be concluded.
Retention period of Personal Data:
We process your Personal Data for the duration of the contract (the subscription period) and, after the termination of the agreement, for the period required by law (including the period specified by the regulations on the limitation of claims).
c) When you registered for the Newsletter
Purposes and legal basis of processing your Personal Data:
We process your Personal Data to send you our Newsletter. The legal basis for the processing, in this case, is its necessity for the performance of the contract to which you are a party (article 6(1)(b) RODO) once you signed up for the Newsletter and accepted the Terms and Conditions.
The system that handles the Newsletter remembers your IP address, which you used when signing up for the Newsletter. Furthermore, it determines your approximate location and keeps track of how you interact with the messages sent to you, e.g., which messages you opened, which links you clicked on, etc. To better manage the Newsletter, we may process this Data to tailor the Newsletter to your individual needs related to our meditations. Such profiling does not result in a decision producing legal effects or affect you in a similarly significant manner.
You can unsubscribe from the Newsletter at any time by clicking on the link provided in each email: “here you can reliably unsubscribe”.
Voluntariness of providing Data and consequences of not doing so:
The provision of your Personal Data, in particular your email address, is a condition for the conclusion of the contract. If you do not provide it, this will prevent us from sending you the Newsletter.
Retention period of Personal Data:
We will process your Personal Data until you unsubscribe from the Newsletter or until we stop sending the Newsletter.
d) If you use our profiles on social media (Facebook, Instagram, YouTube)
Purposes and legal basis for processing your Personal Data:
We process your Personal Data that you have disclosed on our Facebook, Instagram or YouTube profiles (e.g., name, nickname, comment content, reactions to the Website or content on the Website – likes, follows and notifications). We process your Personal Data to:
- enable you to be active on our social media profiles;
- actively maintain our profiles, including responding to your comments, providing you with information about our events, products or promotions;
- use it for statistical and analytical purposes;
- use it for possible defence against claims.
The basis for processing your Personal Data is our legitimate interest (the Article 6(1)(f) RODO), which includes maintaining our profiles on Facebook, Instagram or YouTube, presenting our activities and products we offer and defending our rights.
Voluntariness of providing Personal Data and consequences of not doing so:
The provision of Personal Data is voluntary and is not a statutory or contractual requirement.
Retention period of Personal Data:
We will process your Personal Data in compliance with provisions indicated in the privacy policies of a respective social media. You will find all the information under the following links:
– Facebook – https://www.facebook.com/privacy/explanation
– Instagram – https://help.instagram.com/519522125107875
– YouTube – https://www.youtube.com/t/terms_dataprocessing
We use plug-ins and buttons provided by Facebook, Instagram, and YouTube on the Website.
When you open our Website, your browser sends information to these portals that you have visited the Website. Plug-ins and buttons are part of social media, so your entry causes your browser to send information about the request to download the content of the respective social media to the Website.
The controllers of the social media may collect your Data and use that information to tailor your use of the Website. They may also use the information for their own purposes, such as optimising their own operations and tailoring products and services to your needs.
Even if you did not log into a given social media, your browser might send a set of information to the Controller of that social media. The information package is limited compared to what is transmitted when you log into a social media.
Please refer to their rules and privacy policies if you need more details. We have provided above links to them.
IV. The recipients of Personal Data
Since we cooperate with various individuals and companies while conducting our business, these entities may have access to your Personal Data in some cases. For example, a platform we use to send the Newsletter has access to your email address; a company processing your payments has access to your credit card number or account number (depending on which payment option you choose); a third-party IT specialists we use may have access to our communication. Where this is the case, these entities are acting under either our express authorization or based on a contract, ensuring your Data’s protection and are obliged not to disclose it to anyone else.
The following are the possible recipients of your Personal Data: our employees and associates, affiliated companies, our lawyers, tax advisors, accountants, our third-party IT specialists, our cloud service provider (currently Google), entities supporting the maintenance of relationships and business initiatives, entities providing online payment services, FSi sp. z o.o. based in Kraków, which owns the 1koszyk.pl platform through which you may purchase a subscription to the Website, home.pl S.A. based in Szczecin, which holds our domains and email accounts.
V. Transfer of Data to Third Parties
Generally, we do not transfer your Personal Data to countries outside the European Economic Area, i.e., outside the countries of the European Union and Iceland, Norway and Liechtenstein (herein referred to as “Third Countries”), but we do use third party providers of communication tools (e.g., email, servers). Accordingly, there may be transfers of Data to servers located in Third Countries. These third parties provide the appropriate level of protection for Personal Data as required by the RODO (formally known as standard contractual clauses).
VI. Your rights concerning processing of your Data
You have the following rights:
- the right to access your Data including the right to obtain information from us as to whether your Data is processed and, if so, for what purpose, for how long, to whom we disclose it;
- the right to obtain a copy of the processed Data;
- the right to rectification – the right to have inaccurate or incomplete Data corrected;
- the right to erasure – we will only be unable to erase your Personal Data if we are required by law to continue processing it;
- right to restrict processing – we will cease processing your Data till the moment we clarify a matter concerning your Data, e.g., for a time necessary to examine your objection or verify accuracy of your Data;
- the right to data portability – the right to receive your Data in a structured, commonly used readable format or the right to request that your Data is transferred directly to other controllers where this is technically possible;
- the right to object processing of your Data based on legitimate interests (mainly applies to the processing Data for marketing purposes);
- the right to withdraw consent to the processing of your Data, e.g., by changing your browser settings concerning cookies. Withdrawal of consent shall not affect the lawfulness of processing before the withdrawal of your consent;
- the right to lodge a complaint to the President of the Office for Personal Data Protection – in case you believe that we process your Data unlawfully.
You have the right to object processing of your Personal Data if:
- We process your Personal Data based on our legitimate interests and the objection is based on your particular situation, and/or
- We process your Personal Data for direct marketing purposes.
Please contact us, should you wish to exercise your rights mentioned above related to processing of your Data.
VII. Profiling
We automatically evaluate and analyse your activity to present you with advertisements, offers, and promotions best suited to your interests. However, our actions have no legal effect or similar significant impact on you. It means that we do not differentiate between your situation and that of other customers, do not affect the prices we show you and do not vary the terms of contracts.
VIII. Cookies
Suppose your Internet browser automatically accepts the use of cookies and does not block them. In that case, we assume, in compliance with Polish regulations, that you agree to the storage of cookies on your device (computer, tablet or smartphone), storing information on these devices and accessing them. You can withdraw your consent at any time by changing the settings of a browser you use to access our Website.
Cookies files are text files stored on your device when using a web browser, including opening our Website. The main purpose of cookies is to facilitate using the Website to its visitors as much as possible. The information collected by cookies is stored mainly for the following purposes: maintaining your session active on the Website, helping us to improve the Website by verifying its usage statistics, and customizing the appearance of the Website to your individual preferences (e.g., language).
The information stored or accessed will not alter the configuration of your device or software installed.
We use four types of cookies on our Website:
- Session cookies – collect information about your activities and only exist for the duration of a given session, which begins when you access the Website and ends when you leave the Website. When the session of a given browser ends or the device is switched off, the stored information is deleted from its memory. The mechanism of session cookies does not allow the collection of Personal Data or any confidential information from your device;
- Permanent cookies are stored in your device’s memory and remain there until they are deleted or expired. The mechanism of persistent cookies does not allow collecting Personal Data or any confidential information from your device.
- Own cookies – placed by us to ensure the proper functioning of our Website;
- External cookies – are decoded by third parties.
We use external cookies of third parties to collect general and anonymous statistical data via Google Analytics – an analytical tool. The controller of such external cookies is Google Ireland Limited registered and operating under the laws of Ireland, registration number 368047, Gordon House, Barrow Street, Dublin 4, Ireland.
Google Analytics automatically collects information about the use of the Website. Such data is, in principle, transmitted to and stored on Google servers located worldwide. In carrying out these activities, we are relying on our legitimate interest (Article 6(1)(f) RODO) in generating statistics and analysing them to optimise our Website.
We have activated IP anonymisation – your IP address is truncated before transmission and is thus not combined with other Google data. The full IP address is only exceptionally transmitted to Google’s servers and shortened there.
We do not collect personally identifiable information as part of Google Analytics, nor do we combine this information to enable such identification. You may find detailed information on the scope and principles of data collection of this service under a link: https://policies.google.com/privacy?hl=pl.
We use a Google Advertising ID service, which relates to mobile applications where cookies do not work so seamlessly as on a computer web browser. The idea is that each user of a mobile device is assigned with a unique code, based on which application owners learn from Google when an advertisement for their product was displayed in a specific mobile application and when it was “clicked” by the user. This means that when you use the INTU App, you’ll receive ads related to your interests (which we know by having data about how you use the internet). Google Advertising ID does not collect your Personal Data, which can help to identify you. You remain anonymous – we only know what you like, what you’re interested in.
Starting in autumn 2021, Google is giving users of Android-based devices the option to effectively unsubscribe from the Google Advertising ID service (opt-out). You can check this option when you download the INTU App or through your browser settings. Then you’ll also receive ads, but they won’t be linked to the content you’re searching for online.
If you’re using an Apple device, it will ask you during downloading the INTU App whether you want to use the Advertising ID service or not. If you’re using an older version of iOS, you can personally disable Apple ads. To do this, go to Settings >> Privacy >> Apple Ads and turn off “personalised ads”.
IX. Updating of the Policy
The Policy shall be reviewed on an ongoing basis. The current version of the Policy is effective as of 15.11.2021.