Privacy Policy

 

The privacy policy of Lexmotion.eu

 

Your privacy is crucial to us because you give us your data in trust, and the services we offer are based on them. This document explains what information is collected by our website, how we secure it, and how we use it.

The administrator of the data processed by Lexmotion internet service is Małgorzata Nowotyńska conducting business under the name of Lexmotion Kancelaria Radcy Prawnego Małgorzata Nowotyńska, Plac Lasoty 3 / 1B, 30-539 Kraków, Poland.

In case of any doubts related to the privacy policy, you can contact us at any time by sending a message to lawoffice@lexmotion.eu.

 

Short version - the most important information about how we process data in our service

 

We want to take care of your privacy in addition to taking care of your time. That is why we have prepared an abridged version of the most important rules related to privacy protection for you.

  • By filling out the forms on the Lexmotion.eu website, using the contact form or simply by contacting us directly via email, phone, our profiles on social networks facebook.com, www.linkedin.com, www.instagram.com, as well as mobile applications of these websites, you provide us with your data, and we undertake that your data will remain confidential, secure and will not be made available to any third parties without your express consent.
  • We use analytical tools, such as Google Analytics, which collect anonymous information about your visits to the website, such as subpages that you have viewed, the time you spent on the site or transitions between individual subpages. This is related to the use of Google cookies.
  • We use remarketing tools, such as Facebook Pixel and Google Ads. Pixel, to target you. This is related to the use of Facebook and Google cookies.
  • For your safety and convenience, we use the Hiveage invoicing system and the Paypal, payment processor. This is related to the use of cookie policy and the privacy policies of these companies.
  • We use cookies so that you can use the site in a comfortable way.

If this is not enough for you, you can find more details below.

 

1. How and why we process your data

 

CUSTOMERS

We process your data to fulfil the contract with you and to fulfil tax obligations.

The legal basis for the processing of your data is, therefore, art. 6 par. 1 lit. b. GDPR ( processing is necessary for the performance of the contract with the party to which are related the data, or to take action at the request of that party before concluding the agreement), and art. 6. para. 1 lit. c. GDPR ( processing is necessary to fulfil the legal obligation of the administrator ).

During cooperation or after its completion, we can send you a questionnaire measuring your satisfaction with cooperation with us. Our procedures (e.g. immigration and work permits) usually take time, and during that period you may receive reminders and inquiries from us. We may also send you a message if you were our client in the past or if you only expressed interest in our services, but then we did not have the opportunity to cooperate. Maintaining contact with you and your opinion are very important to us, and the legal basis for these activities is art. 6 par. 1 lit. f. of GDPR ( processing is necessary for purposes arising from legitimate interests pursued by the administrator or by a third party ).

Another legitimate interest for the processing of your data is to provide us with the opportunity of proof in the event of a dispute with you the contents of the contract that connects us and that we have executed it properly.

Through the Lexmotion.eu website you can also get preliminary, free legal advice about your opportunities related to Polish citizenship, stay and work in Poland. In order to obtain such information, you should provide us with your personal data necessary for this, i.e. your name and surname, e-mail address, citizenships, country of origin, country of residence, marital status, information about the relationships with your immediate family and your relatives in Poland and information related to the emigration of your ancestors or yours .

The data provided in the forms will be stored in the database and will be stored in it until the claims for the ordered free service are time-barred. Each completed form is recorded as a separate item in the database. In addition to personal data, details regarding the performance of the service are also recorded, such as the date of receipt of the completed form. The data is automatically integrated, but you can always modify it.

 

CUSTOMERS’ NEXT OF KIN

We process your data to fulfil the contract with our client. The legal basis for these activities is art. 6 par. 1 lit. f. of RODO ( processing is necessary for purposes arising from legitimate interests pursued by the administrator or by a third party ).

We assume in good faith that our client has informed you about the disclosure of your data to us and the purpose of their processing. We believe that by processing your data in the manner described here, we do not do it for other purposes than those in which our client has obtained it from you. If it was different - please contact us by sending a message to the address  lawoffice@lexmotion.eu

 

SERVICE USERS

We process data of each service user characterising the way he uses our website (these are so-called operating data). This processing includes an automatic reading of a unique identification identifying the end of the telecommunications network or IT system you use (i.e. your IP address), the date and time of the server, information about the technical parameters of the software and the device you use (e.g. whether you use your laptop or phone for browsing our site and the place from which you connect to our server. We may use this information for market research purposes and for improving the website's performance. The data stored in the server logs is not associated with specific people using the website. The server logs are the only auxiliary material used to administer the site.

 

The legal basis for data processing operations is art. 6 par. 1 lit. f) of GDPR ( processing is necessary for purposes arising from legitimate interests pursued by the administrator ). This legitimate interest is to enable the diagnosis of errors on the site and the improvement of its quality.

 

Lexmotion.eu, like almost all other websites, uses cookies. Cookies are small text information on your device (e.g. computer, tablet, smartphone) that can be read by our ICT system.

 

Cookies allow us to:

  • ensure the proper functioning of the website;
  • improve the speed and security of using the website;
  • use analytical tools;
  • use marketing tools, including tools that perform profiling in the understanding of GDPR

 

Acceptance of cookies. During the first visit to our web service, you are shown information about the use of cookies. Accepting and closing this information means that you agree to the use of cookies by the provisions of this privacy policy. You can always withdraw your consent by deleting cookies and changing cookie settings in your browser. Remember, however, that disabling cookies may cause difficulties in using the service, as well as from many other websites that use cookies.

Own cookies. Cookies can be divided into own and from third parties. As for own cookies, we use them for our service to function properly.

Third party cookies. Lexmotion.eu, like most of today's web services, uses functions provided by third parties, which involves the use of cookies from third parties. The use of these types of cookies is as follows:

Analysis and statistics. We use cookies to track website statistics, such as the number of visitors, the type of operating system and web browser used to browse the site, time spent on the website, visited subpages, etc. We use the following tools in this area:

Google Analytics. The information collected by this tool is completely anonymous and does not allow your identification. For this purpose, Google LLC cookies are used for the Google Analytics service. The use of Google Analytics services involves the implementation of the tracking code in the code of our website (the so-called tracking code). This code is based on cookies, but may also use other tracking technologies. Detailed information about Google Analytics can be found at https://www.google.com/intl/en_us/analytics/.

You can prevent the processing of personal data in this way (block Google Analytics) by making the appropriate choices on the site available here: https://tools.google.com/dlpage/gaoptout

 

Marketing. We use the following marketing tools :

  • we implemented the Facebook's Pixel in our service's code, which remembers your visit. For this purpose, Facebook cookies are used. This results in showing you our ads on Facebook.
  • We have implemented the so-called in the code of our service Google Ads Pixel to target you when you browse the Internet for some time after visiting our site. You can prevent Google's from the use of advertising cookies by visiting the special page with Google ad settings, available at this link.

More information about cookies can be found in our Cookies Policy, available here: https://www.lexmotion.eu/pl/page/cookie-policy/.

 

SUPPLIERS

We process your data to fulfil the contract with you and to fulfil tax obligations.

The legal basis for the processing of your data is, therefore, art. 6 par. 1 lit. b. of GDPR ( processing is necessary for the performance of the contract with the party to which are related the data, or to take action at the request of that party before concluding the contract ), and art. 6. para. 1 lit. c. GDPR ( processing is necessary to fulfil the legal obligation of the administrator ).

 

2. What personal data we process

 

We process the following personal data:

 

CUSTOMERS

  1. name and surname,
  2. email address,
  3. date and place of birth,
  4. possessed citizenships,
  5. country of origin,
  6. country and address of residence,
  7. marital status,
  8. information about the relationships with Poland of your immediate family and yours,
  9. information related to the emigration of your ancestors or yours,
  10. information about the military service of your ancestors or yours,
  11. information about the employment of your ancestors or yours,
  12. information about places of detention, internment and repression of your ancestors or yours

 

CUSTOMERS’ NEXT OF KIN

  1. name and surname,
  2. email address,
  3. date and place of birth,
  4. possessed citizenships,
  5. country of origin,
  6. country and address of residence,
  7. marital status,

 

SERVICE USERS

  1. IP address,
  2. server date and time,
  3. location of the terminal device from which the user connects to the service,
  4. technical parameters of the device and software used by the user,
  5. device interface language,
  6. UTM tags, determining from which network location the user arrived
  7. online identifiers, including cookie IDs, web protocol addresses and device identifiers (for the use of cookies).

 

SUPPLIERS

  1. name and surname,
  2. email address,
  3. telephone number,
  4. fax number,
  5. address of business activity,
  6. company name,
  7. Tax Identification Number (NIP),
  8. Business Registry Number (REGON).
  9. history of transactions with you,
  10. history of correspondence with you (including by email),
  11. contact details of your employees (if they contact us on your behalf).

 

3. Whom we disclose your data to

 

We entrust the processing of personal data to the following entities:

  • H88 S.A. based in Poznań, ul. Franklin Roosevelt 22, 60-829 Poznań - to store data on the server. Our site is on these servers, everything you enter in our forms must appear there. Your data is stored on secure servers in Germany. The connections we use to connect to the server are encrypted.
  • FLG Software Limited, Ribble Court, 1 Mead Way, Padiham BB12 7NG, registered under number 09192721 in the UK - to automate the transfer of data between the website and the CRM sales system. Your data goes through the Flowxo service, which does not store data, only provides communication between the website and the Pipedrive CRM. The connections we use to connect to Flowxo are encrypted.
  • Pipedrive OÜ, a limited liability company, established under the law of the Republic of Estonia, whose main place of business is Paldiski mnt 80, Tallinn, 10617, Estonia and registered in the Estonian trade register under number 11958539 and being a subsidiary of Pipedrive US; - in order to use the online sales system of the Pipedrive CRM type. Thanks to Pipedrive, we can communicate effectively with you, and the data you have provided in the form is given in an organised form.
  • Vesess Inc., Suite 373, 5348 Vegas Dr, Las Vegas NV 89108, USA - to use the Hiveage invoicing system. Hiveage receives your address details and your first and last name so that we can issue you a sales document that you can pay online,
  • Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland to store data on the server and support the mail server. We use Google services to handle our email correspondence, and store data in the cloud (Gsuite), and also for analytical and statistical (Google Analytics) and advertising purposes (Google Ads Pixel).
  • Asana, Inc., 1550 Bryant St., 8th floor, San Francisco, CA 94103 - in connection with the use of Asana software for project management and communication with clients and suppliers.

Some of the operations described above involve the transmission of your data to the so-called third countries (outside the European Economic Area), where the GDPR is not applicable. However, this always happens on the basis of legal instruments provided for in the GDPR, guaranteeing adequate protection of your rights and freedoms. Detailed information in this regard can be found in the privacy policies placed by suppliers on their websites. If you want, we will give you a list of useful links (write to us for this purpose to the address  lawoffice@lexmotion.eu )

Also, we entrust the processing of data to an external accounting office, translation offices, an external IT service provider and courier and forwarding companies. In contracts with these entities, we have ensured that your data will not be transferred to the so-called third countries (outside the European Economic Area), where the GDPR is not applicable.

We also disclose processed data to independent data controllers, such as:

  • state administration bodies authorised to do so by law (e.g. tax authorities, self-government bodies of legal advisers, offices, courts),
  • payment service providers,
  • service providers related to the so-called re-marketing (Google and Facebook).

 

4. How long will we process your data

 

CUSTOMERS; CUSTOMERS’ NEXT OF KIN; SUPPLIERS

We will process your data for as long as it is necessary for tax purposes, that is - by the current provisions of Polish law - even for 6 to 7 years.

If the limitation period for claims related to our service is longer than the retention period for tax purposes - then this longer period applies.

If we work with you on a permanent basis, then, of course, some of your data, necessary for this purpose, we will process throughout the whole period of cooperation.

Above, in our Privacy Policy, we wrote that we could send you messages to keep in touch with you if you were our client in the past, or only expressed interest in our services, and then we did not have the opportunity to cooperate. Your data will be processed for this purpose for a period not exceeding 26 months unless you exercise your right to object.

 

SERVICE USERS

We will process your personal (operational) data for 26 months. The data we collect from you is stored in an anonymous form.

Our ads related to the use of cookies will appear to you for a month from the last visit to our website (unless you delete our cookies from your browser beforehand).

 

5. How we enable you to exercise your rights

 

We strive to make you happy with working with us. Remember, however, that you have many privileges that will allow you to influence the way we process your personal information, and in some cases cause you to stop such processing. These rights are:

  • the right of access by the data subject (regulated in Article 15 of the GDPR)

 

Article 15

The right of access by the data subject

1 The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:

(a) | the purposes of the processing;

(b) | the categories of personal data concerned;

(c) | the recipients or categories of recipient to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;

(d) | where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;

(e) | the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;

(f) | the right to complainwith a supervisory authority;

(g) | where the personal data are not collected from the data subject, any available information as to their source;

(h) | the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.

2 Where personal data are transferred to a third country or an international organisation, the data subject shall have the right to be informed of the appropriate safeguards under Article 46 relating to the transfer.

3 The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject requests by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.

4 The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

 

  • right to rectification of your data (regulated in Article 16 of the GDPR)

 

Article 16

Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

 

  • right to erase your data (regulated in Article 17 of the GDPR)

 

Article 17

Right to erasure (‘right to be forgotten’)

1 The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have an obligation to erase personal data without undue delay where one of the following grounds applies:

(a) | the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;

(b) | the data subject withdraws consent on which the processing is based according to the point (a) of Article 6(1), or point (a) of Article 9(2), and where there is no other legal ground for the processing;

(c) | the data subject objects to the processing under Article 21(1), and there are no overriding legitimate grounds for the processing or the data subjectobjects to the processing pursuant to Article 21(2);

(d) | the personal data have been unlawfully processed;

(e) | the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;

(f) | the personal data have been collectedin relation to the offer of information society services referred to in Article 8(1).

2 Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.

3 Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:

(a) to exercise the right of freedom of expression and information;

(b) | to comply with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller;

(c) | for reasons of public interest in the area of public health according to the points (h) and (i) of Article 9(2) as well as Article 9(3);

(d) | for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes according to Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or

(e) | for the establishment, exercise or defence of legal claims.

 

  • right to restrict of processing of your data (regulated in Article 18 of the GDPR)

 

Article 18

Right to the restriction of processing

1 The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:

(a) | the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;

(b) | the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;

(c) | the controller no longer needs the personal data for the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;

(d) | the data subject has objected to processing under Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

2 Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.

3 A data subject who has obtained a restriction of processing under paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

 

  • Right to object to the processing of your data (regulated in Article 21 of the GDPR)

 

Article 21

Right to object

1 The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to the processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.

2 Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to the processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.

3 Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.

4 At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.

5 In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.

6 Where personal data are processed for scientific,historical research or statistical purposes under Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

 

  • right to data portability of your data (regulated in Article 20 of the GDPR)

 

Article 20

Right to data portability

1 The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:

(a) | the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1), and

(b) | the processing is carried out by automated means.

2 In exercising his or her right to data portability under paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.

3 The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or the exercise of official authority vested in the controller.

4 The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

 

To use any of the rights described, please contact us by e-mail, to the address we contacted you, or at the address  lawoffice@lexmotion.eu .

 

6. Complaint to the supervisory authority

 

According to art. 77 of GDPR you are entitled to submit a complaint to the supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place where the alleged violation is committed, if you believe that the processing of personal data regarding you violates the provisions of the GDPR. In Poland, the supervisory body is the President of the Office for Personal Data Protection - you can make a complaint, among others by traditional mail to the address of ul. Stawki 2, 00-913 Warsaw or by email to the address  kancelaria@uodo.gov.pl , you can also get more detailed information (including current phone numbers) on the website: https://uodo.gov.pl/.

 

7. Is the provision of data necessary to conclude an agreement with us

 

CUSTOMERS; SUPPLIERS

We collect your data primarily to the extent necessary to conclude and execute the contract. A part of the data is also necessary to fulfil our obligations under the law (tax regulations, accounting regulations, obligations arising from professional regulations). Failure to provide your data will, unfortunately, prevent the conclusion and implementation of the contract.

 

SERVICE USERS

Your data is not collected to conclude an agreement with you.

 

8. From where we have your data

 

CUSTOMERS; SUPPLIERS; SERVICE USERS

We obtain your data from you (including in an automated way).

 

CUSTOMERS’ NEXT OF KIN

We obtain your data from the customer.

 

9. Automated processing and profiling

 

 Operational data and the use of cookies are processed in an automated manner (they are not profiled as understood by the GDPR). The remaining personal data are not processed in this way.