Privacy policy
General Provisions
This document explains and describes by what means the data of Users of the Unipla platform are collected, processed and secured. Prior to using the Platform, its websites and mobile applications, the User should read the contents of this document.
Definitions
Whenever the Privacy Policy refers to:
Privacy Policy – it shall mean this document.
Platform – it shall mean the Unipla electronic platform.
Operator – it shall mean CODE&MORE Software House Marek Lewczuk, with its registered office in Warsaw, Aleja KEN 18/3a, 02-797 Warsaw, EU VAT PL5431796118.
Company – it shall mean a client of the Operator who uses the services of the Platform.
Administrator – it shall mean a person who is a representative of the Company, who has the right to access and modify data owned or processed by the Company, which is entered and processed as part of and for the purposes of the services available on the Platform.
User – it shall mean a person who is a client of the Company or an employee of the Company's client, who uses the services of the Platform and resources/data introduced by the Company onto the Platform.
Administrative Panel – it shall mean a website and a web application to which the Administrators of the Company have access, and in which they can manage the Company's data and use additional functionalities.
Application – it shall mean a mobile application (for iOS and Android platforms) and/or a web application (Progressive Web App) and/or a website that was created at the request of the Company by the Operator or that is a generally available application created by the Operator, which allows Users and Administrators of the Company to access data created by the Company.
Project – it shall mean a set of data that can be displayed, made available and processed in Applications and the Administration Panel, which is created by Administrators or Users.
Data collection and data processing by the Operator
The administrator of the personal data is the Operator.
The administrator of the personal data of the Users who are using Applications dedicated to the Company is the Company or the entity specified in the privacy policy of the Project, accessible by the User.
The administrator of the personal data of the Users who are creating an individual access account in the Application not dedicated to a specific Company is the Operator.
If additional Users' personal data is collected as part of the Project (e.g., using forms), the administrator of such data is the Company or the Company's client who entrusted the Company with the processing of the personal data.
In all the above cases, the Operator processes personal data exclusively for the purposes of the Platform's services or purposes commissioned by the Company. The processing of personal data is carried out in accordance with applicable law, including Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR) and the Act of 18 July 2002 on Providing Services by Electronic Means.
Registration of Administrators (creating an individual access account) is necessary to enable access control and data protection. Registration requires the following data: name, surname, email address, mobile phone number (optional) and password. The Administrator's data (name, surname, telephone number and email address) are available to other Administrators of the Companies that have granted the Administrator access to their data. The above Administrator's data may also be available to Users, if the Company decides that such information should be available to its Users.
User registration (creating an individual access account) may be required in order to use the Application. To create an individual access account, it is required to provide the following data: name, surname, e-mail address, telephone number (optional) and password. The Company may specify additional data in the registration form, but they are not saved in an individual access account.
The Operator collects information on the interaction of Administrators and Users. The information collected includes, among others: information regarding the device and logins, the system logs, containing the date and the time of the visit and the IP number of the device from which the connection was made, as well as data on the statistics of accessibility/usage of the Platform. The purpose of collecting such information is to improve the operation of the Platform and to analyze the needs of its Users. In the case of an unregistered User, the data stored in the server logs are anonymous and do not allow for the identification of a specific person.
The Operator also receives information about the Administrator from the payment operator, i.e., entities that enable the Administrator to make online payments for services purchased on the Platform. The information includes the status of payments for services.
In the case of registering and logging in to the Platform via another platform – one that is verifying and authenticating the user – the Operator receives data from entities providing such services, i.e., Facebook, Google or Twitter. The data received are: email address, gender, user ID, date of birth, first name, last name, telephone number.
The personal data of the Administrators are stored only for the duration of having an account on the Platform. After deleting the account, the data is deleted and limited to the name and surname only. The data may be stored for a longer period, if such an obligation results from the provisions of law or it is necessary for the Operator's defense or pursuit of claims against the Administrators.
The personal data of Users who have individual accounts in a non-dedicated Application are stored until the account is deleted on the Platform. The User has the option to delete the account on their own in the Application or by sending a message to privacy@unipla.eu.
The storage time of personal data of Users of dedicated Applications and personal data collected as part of the Projects is determined by the Company that created the Project or for whom the dedicated Application was created.
The Company may collect and process additional User data for purposes related to the functioning of the Application as part of the Project. Additional processing of the User's data by the Company requires separate consents, which the Company may individually obtain from the User in the application (e.g., in the registration form, survey) or outside of it.
Data Sharing
As a rule, the Operator does not disclose personal data of Administrators and Users to third persons or third parties, except for situations where the Operator has a legal basis to do so, at the request of authorized entities, or when it is necessary to perform Platform services (employees, subcontractors, technology providers).
The Operator is responsible for the actions of employees, subcontractors and technology providers in the field of personal data processing. Each of them has signed an applicable agreement, the subject of which is to secure data against access by unauthorized persons, to specify the scope of data processing and to list out the obligations of the data processor.
As part of the provision of services, the Operator transfers data to the following entities:
Google Cloud Poland LLC. with its registered office in Poland, scope of data processing: storage of all data, including personal data
Amazon Web Services EMEA SARL with its registered office in Poland, scope of data processing: name and surname, email address, content of the e-mail message sent from the Platform by the Company
Mixpanel S.L. with its registered office in Spain, only at the request of the Company, scope of data processing: name and surname, email address, telephone number
The company providing the SMS gateway service with its registered office in Poland, the scope of the transferred data: telephone number, content of the SMS message sent from the Platform by the Company
The company providing the SMS gateway service with its registered office in the EU, the scope of the transferred data: telephone number, content of the SMS message sent from the Platform by the Company
Access to the data of the Company's Administrators and Users who are the Company's clients, and are using the Application and Company's data, are available to select Company's Administrators.
Due to the need to prevent Internet robots from performing certain functions on the Platform, the Operator uses the Google reCAPTCHA mechanism to occasionally check whether the behavior of the people using the Platform does not bear the hallmarks of robotic behavior. Because of this, the Operator may disclose the IP address of the User’s compute to Google Inc.
Google Analytics
The websites and Applications functioning within the Platform use the Google Analytics service. It is used to monitor the correct functioning of the Platform and analyze the Users’ behavior. The data transferred to Google Analytics is anonymized, which means the Platform does not provide any information which could help identify a specific person.
Cookies and local memory storage
In order to ensure the proper functioning of the Platform, cookies (and local memory storage) are used on websites and within the Applications. Cookies are used only for technical purposes, i.e., remembering certain information on the browser/application side (e.g., temporary data, session ID) or for collecting statistical data. As for the Application, additional data may be saved on the device, which is related exclusively to the functioning of the Application or the User 's activity within the Application.
Rights of the Platform’s Users
Each Administrator and registered User has the right to inspect their data collected on the Platform. They also have the right to delete all data, which is tantamount to deleting the User's account on the Platform, which in turn means they won’t be able to access the Administration Panel or the Application. In order to obtain information about their data or delete it, or delete their account, the User should send a request via email to privacy@unipla.eu or to the personal data protection officer of the Company whose dedicated Application is used by the user.
Data security
The Operator undertakes to make every effort to secure data about the Administrator and Users. In practice, this means implementing an appropriate data access control system, both at the technical level (software) and at the personal level, by limiting the list of persons (employed by the Operator) with access to such data. The Operator will also inform the Companies about the requirements and rules regarding data security.
Contact and the right to lodge a complaint
Users may contact the Operator via email, by sending a message to the technical support address support@unipla.eu or to the personal data protection at privacy@unipla.eu.