Privacy and personal data protection policy
This PRIVACY AND PERSONAL DATA PROTECTION POLICY (hereinafter referred to as the Policy) is developed in accordance with the requirements of Directive 2002/58/EC of the European Parliament and of the Council of July 12, 2002 on the processing of personal data and the protection of privacy in the electronic communications sector (the „Privacy and Electronic Communications Directive”) and 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 (the „Law”).
This Policy establishes the procedure for the processing of personal data provided by customers who use the website https://www.businesstribe.school/ and its individual services to receive or provide services (hereinafter referred to as the Users and the Website, respectively) by CENTRUM ROZWOJU PROJEKTÓW EDUKACYJNYCH SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ – LLC (hereinafter referred to as the Company). The Policy determines the types of personal data collected, the purpose of using such personal data, the Company’s interaction with third parties, security measures to protect personal data, conditions for access to personal data, as well as contact information for the user to access, amend, block or delete their personal data and handle any questions that may arise regarding personal data protection practices.
The Company has great respect for the confidential (personal) information of all persons, without exception, who have visited the Website https://www.businesstribe.school/, as well as those who use the services provided by the Website; in this regard, the Company strives to protect the confidentiality of personal data (information or a set of information about an individual who is identified or can be specifically identified), thereby creating and ensuring the most comfortable conditions for using the Website services for each user.
The text of the Policy is available to Users on the Internet at https://www.businesstribe.school/. In case of disagreement with the terms of the Policy, the User must immediately stop using the Website.
1. Terminology and abbreviations
The terminology used in this Policy means the following:
1.1. Personal data – Any information relating directly or indirectly to a specific or identifiable individual (personal data subject).
1.2. Company – LLC „CENTRUM ROZWOJU PROJEKTÓW EDUKACYJNYCH”,
Franciszka Klimczaka 5/35
02-797 Warszawa, Polska
NIP 9512569860
REGON 525494381
KRS 0001039991
1.3. Processing of personal data – Any action or set of actions performed with the use of automation tools or without the use of such tools with personal data, including collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction of personal data.
1.4. Automated processing of personal data – Processing of personal data by means of computer technology. Despite this, automated processing of personal data does not contain an automatic processing system, including profiling, which creates legal consequences in relation to the User, or which in a similar way significantly affects the User.
1.5. Dissemination of personal data – Actions aimed at disclosing personal data to an indefinite number of persons.
1.6. Provision of personal data – Actions aimed at disclosing personal data to a specific person or a specific circle of persons.
1.7. Blocking of personal data – Temporary suspension of the processing of personal data (except when processing is necessary to clarify personal data).
1.8. Use of personal data – Actions (operations) with personal data performed by the Company in order to make decisions or perform other actions that give rise to legal consequences in relation to the personal data subject or other persons or otherwise affect the rights and freedoms of the personal data subject or other persons.
1.9. Depersonalization of personal data – actions as a result of which it becomes impossible to determine the ownership of personal data to a specific personal data subject without the use of additional information.
1.10. Destruction of personal data – Actions as a result of which it becomes impossible to restore the content of personal data in the personal data information system and (or) as a result of which material carriers of personal data are destroyed.
1.11. Online Program – An educational program, which is conducted exclusively using distance technologies on the Company’s Online Platform, available at https://www.businesstribe.school/
1.12. Online platform – the Company’s software, which is a set of interconnected web services and modules that make up a single space for providing services to consumers on the Internet
1.13. Free Class – Audiovisual material (webinar), access to which, as well as to all materials thereof, is provided by the Company free of charge to all users who have registered for participation in such webinar. The Company conducts free classes for all interested users. A free class is not an educational program in whole or in part.
1.14. User Agreement means an Agreement concluded by the Company with its Clients.
1.15. Site – A set of information, texts, graphic elements, design, images, photos and videos and other results of intellectual activity, as well as computer programs contained in the information system that ensures the availability of such information on the Internet at the network address https://www.businesstribe.school/
1.16. Personal Account – a section of the Website to which the User gets access after registering on the Website by entering a unique login and password.
1.17. Cookies – Data that is automatically transmitted to the Company in the process of using the Site through the software installed on the User’s device, including IP address, geographic location, information about the browser and type of operating system of the User’s device, technical characteristics of the equipment and software used by the User, date and time of access to the Site. Cookies can be eternal (called persistent cookies) and stored on the computer until the user deletes them, or temporary (such cookies are called session cookies), that is, they are stored only until the browser is closed. In addition, cookies are divided into first-party cookies (they are set directly by the Website visited) and third-party cookies (set by other websites).
1.18. „IP address” is a numerical designation used by computers on a network to identify the computer each time it accesses the Internet.
2. User’s consent to the processing of personal data by the Company
2.1. The User accepts the terms of the Policy and gives the Company an informed and conscious consent to the processing of his/her personal data under the conditions provided for by the Policy and the Law:
2.1.1. During registration on the Website – for personal data provided by the User to the Company:
– by filling out the registration form located on the Internet, it is considered that the User has consented to the processing of his personal data when he ticked the box „I accept the terms of the Offer Agreement and agree to the personal data processing policy” at the moment of clicking the „Register” button;
-by authorization using personal data provided by the User in social networks or electronic services. The User is considered to have consented to the processing of his/her personal data at the moment of clicking the button displaying the social network or electronic service selected for authorization.
- By clicking this button, the User agrees to transfer to the Company all personal data that was made publicly available by indicating in the profile of the relevant social network or electronic service.
2.1.2. When entering or changing personal data in the section „Personal data”, „My interests” in the personal account – for personal data that the User provides when editing information in the section „Personal data”, „My interests” in the personal account. The User is considered to have consented to the processing of his/her newly entered or changed personal data at the moment of clicking the „Save” button.
2.1.3. When filling out the feedback form – for personal data that the User provides to the Company when filling out the feedback form on the Internet on the Website and electronic services (Google, etc.). The User is considered to have given consent to the processing of his/her personal data entered in the fields of the feedback form at the moment of clicking the button confirming the submission of the application (the buttons may be called „Send”, „Leave a request” and other similarly named).
2.1.4. When subscribing to receive information and news materials from the Company – by filling out the form for subscribing to the newsletter located on the Internet. The subscription form becomes available after the registration procedure. The User is considered to have consented to the processing of their personal data when they tick the box „I hereby consent to the processing of personal data” at the time of clicking the „Subscribe” button.
2.1.5. Enrollment in the Online Program by filling in the fields of the application for enrollment located on the Internet. The user is considered to have consented to the processing of his/her personal data when he/she ticks the „Enrollment” form at the moment of clicking the „Enroll” button.
2.1.6. When sending a scanned copy of the completed consent form to the processing of personal data by e-mail – for personal data that the User provides to the Company to receive educational services on the Website under the program of additional professional education. It is considered that the User has given consent to the processing of their personal data at the time of sending a scanned copy of the consent to the e-mail address with the domain name @ laba.ua.
2.1.7. Registration for a Free Lesson – by filling in the fields of the application for registration located on the Internet. It is considered that the user has given consent to the processing of their personal data when they tick the „Enrollment” form at the time of clicking the „Enroll” button.
2.1.8. During any use of the Website – for personal data that is automatically transferred to the Company in the process of using the Website through the software installed on the User’s device. The User is considered to have consented to the processing of his/her personal data when he/she started using the Website.
2.2. The User’s consent to the Company’s processing of his/her personal data is valid from the date of granting consent to their processing (clause 2.1 of the Policy), and for the period necessary to achieve the purposes of processing personal data (section 5 of the Policy).
2.3. The User has the right to withdraw consent to the processing of personal data in the form and manner prescribed in Section 9 of the Policy. - 3. Consent to the provision of personal data by the User
The Company assumes that when providing personal data on the Website, the User:
3.1. Confirms that he/she has all the necessary rights that allow him/her to acquire civil rights for himself/herself and exercise them independently, and is able to create civil obligations for himself/herself, fulfill them independently and bear responsibility in case of their non-fulfillment;
3.2. Provide accurate information about themselves to the extent necessary to use the Website and keep the provided personal data up to date.
3.3. If the User uploads his/her image through the personal account of the Website, he/she agrees to use this image for purposes not related to the identification of the User free of charge. The User undertakes not to provide photographs of third parties as the User’s image.
3.4. Realizes that the information on the Website posted by the User about himself/herself may become available to other Users of the Website, may be copied and distributed by such Users in the cases and under the conditions specified in clause 6.7 of the Policy.
3.5. The User is aware that any telephone conversations held with an employee of the Company are automatically recorded in order to control the quality of customer service, as well as to resolve controversial and conflict situations that may arise in such telephone conversations. At the same time, the User agrees to such automatic recording of telephone conversations and storage of such records in accordance with the terms of this Policy.
3.6. Having read this Policy, the User expresses his/her informed and conscious consent to it. - 4. Personal data processed by the Company
4.1 The User’s personal data processed by the Company includes:
– last name, first name, patronymic;
– mobile phone number;
– e-mail address;
– data of accounts in social networks and electronic services (links to the User’s profiles in VKontakte, Facebook, Linkedin, Skype, Google, Twitter, etc;)
– image
– place of work;
– country, city;
– date of birth
– profession
– work experience and position;
– IP address;
– cookies;
– parameters and settings of Internet browsers (User-agent). - 4.2. The Company protects the Data that is automatically transmitted in the process of viewing ad units and when visiting pages on which the system’s statistical script („pixel”) is installed:
– IP address;
– information from cookies;
– information about the browser (or other program that provides access to the display of advertising);
– time of access;
– address of the page where the ad unit is placed;
– referrer (address of the previous page). - 4.3. When visiting the Website, all logins to the system are recorded. Other information on user traffic is not processed or stored.
4.4. The Company does not collect any information for the processing of which certain requirements are established by law, such as information about racial or ethnic origin, political, religious or ideological beliefs, membership in political parties and trade unions, conviction of a crime or sentence to a criminal penalty, as well as data related to health, sexual life, biometric or genetic data.
4.5. The Company collects data on website traffic statistics. The data may contain information about the connection, traffic, user’s browser, as well as the date, time, duration of work on the Internet and stay on the Site.
4.6. Any other personal information that is not specified above (history of visits, browsers and operating systems used, etc.) is subject to secure storage and non-disclosure. - 5. Use of cookies
5.1. The Company cares about its users and tries to make your stay on the Site as comfortable as possible, and for this purpose the Company needs to analyze the behavior, preferences and interests of the user using cookies. Such analysis will help the Company improve the experience of interaction with the Website, determine the most convenient interface and navigation of the Service.
5.2. According to the classification of the International Chamber of Commerce, the Company uses the following categories of cookies:
Strictly Necessary Cookies – are required for the user to move around the web page and when using certain services, for example, to access secure pages, register and authorize, search the Site. They also memorize the user’s previous actions when going to the previous page in the same session.
Performance cookies – aggregate information about how the Website is used. This data is stored on the user’s device between web browser sessions. Examples of such data may include the following metrics: time spent on the Site, most frequently visited pages, understanding which sections and services of the Site were most interesting to the user, how effective a particular advertising and/or marketing campaign is, etc.
All information collected through performance cookies is intended for statistical and analytical purposes. Some cookie data may be provided to third parties that have permission from the website and solely for the purposes specified above.
Functional cookies – used to save parameters or configurations that are stored on the user’s device between web browser sessions. Examples of such data may include the following metrics: username, profile photo, information on comments left, website language, location, information about whether the user has been provided with any information or selected preferences previously, as well as other Website settings.
These cookies also allow users to watch videos, participate in interactive activities (polls, voting) and interact with social networks.
To make the experience more pleasant after visiting the resource, these cookies remember the information provided by the user, increasing the efficiency of interaction with the Site.
Some cookie data may be provided to third parties that have permission from the website, and solely for the purposes specified above.
Targeting cookies – used to provide content that may be of interest to the user. This data is stored on the user’s device between web browser sessions. Examples of such data may include the following metrics: tracking recommended text, graphics, audio and video material in order to avoid repeated display, managing targeted advertising, evaluating the effectiveness of advertising campaigns, information about the user’s visits to other resources during transitions, as well as other settings of the Site.
The website may share this information with other parties, including media clients, advertisers, agencies and related business partners, in order to provide high-quality targeted advertising.
Cookies of third-party services and analytics services:
For prompt delivery, better display and detailed analysis of the content on the Website, the Company uses services owned by other third-party companies, such as Facebook, Twitter, Instagram, Alphabet Inc.
The companies listed as an example may use cookies on the user’s device while working on the Site.
Please note that the Website cannot influence the operation of cookies used by these services. All the necessary information about their use can be found by visiting the relevant resource.
Terms of use of Google Analytics – http://www.google.com/analytics/terms/ru.html - Managing cookies:
The major web browsers (listed below) are set to automatically accept cookies. To disable them, use the help function in your browser. Help can be accessed through the menu or by pressing F1.
Microsoft Edge – https://privacy.microsoft.com/privacystatement
Mozilla Firefox – https://www.mozilla.org/privacy/websites/#cookies
Google Chrome – https://support.google.com/chrome/answer/95647?hl
Opera – http://help.opera.com/Windows/11.50/cookies.html
Safari for macOS – https://support.apple.com/kb/PH21411?locale=en_US - Important:
the configuration of cookie settings for mobile device web browsers may differ;
it should be recalled that full-fledged work with the Site is available only if cookies are used;
disabling cookies may result in restricted access to the content and inadequate functioning of the Website services. - To contact the Company regarding the use of cookies, send an e-mail to tribe.business.school.pl@gmail.com. If the user does not enable the use of cookies or deliberately deletes all cookies from his/her web browser, the user will be re-offered to enable and use cookies during subsequent visits to the Site.
Information about users obtained through cookies is not sold or distributed in the public domain and is the property of the company that owns the resource. - 6. Purposes of personal data processing
The Company processes personal data of users exclusively for the following purposes:
6.1. Registration of the User by the Company on the Website, providing the User with the opportunity to fully use the Website services.
6.2. Displaying the User’s profile on the Website in the personal account.
6.3. Establishing and maintaining communication between the User and the Company, advising on the provision of services, providing customer and technical support in case of problems related to the use of the Website.
6.4. Fulfillment of the Company’s obligations to the User who has enrolled in the Online Program for a Free Class under the agreements with the Company.
6.5. The Company sends advertising messages to the User’s e-mail address; targeting of advertising materials.
6.6. Improving the quality of user service and modernization of the Company’s Website by processing requests and applications from the User.
6.7. Статистичні та інші дослідження на основі знеособленої інформації, наданої Користувачем.
6.8. Placement on the Company’s Online Platform available at: https://www.businesstribe.school/, in official social media groups and other communities of the Company on the Internet, other advertising and information sources, for purposes not related to the identification of the User:
– video materials obtained in the process of providing services;
– feedback left by the User about the services provided by the Company. - Regarding the social network Facebook: Facebook does not offer a separate data processing agreement for any products. If Facebook processes data on behalf of customers, the terms and conditions of Facebook products are subject to the requirements of the data processing agreement. For more context, Facebook has drafted data processing addendums to clearly track the required provisions set out in Article 28(3) of the GDPR, which governs data processing agreements. Among the key functions where Facebook acts as a data processor for advertisers and processes data from EU users, the data processing addendum (1) limits Facebook’s data processing except as specified by the advertiser (in accordance with the applicable product terms); (2) requires Facebook to adopt appropriate technical and organizational measures to protect personal data; and (3) imposes obligations on Facebook to assist advertisers in fulfilling the advertiser’s own GDPR obligations as a data controller. The relevant terms can be found here:
Facebook Business Tools Terms
Custom Audience Term
Data Processing Terms.
The user has the right to unsubscribe from the newsletter. In this case, their name and email address will be automatically removed from the database. To do this, just one mouse click on the corresponding item in each received email is enough. - 7. Processing of personal data
7.1. The processing and storage of the provided personal data is carried out in data centers where the equipment that ensures the functioning of the Website services is located. The provided personal data is processed and can be stored in the Personal Database or in a separate table of the Website Database. Since the Company’s servers are located in different regions around the world, the information of a particular User may not be considered in the country in which he or she resides. The level of information protection and legal regulations in this area may differ from country to country. Regardless of where the User’s data is processed, the Company uses the same measures to ensure its security as described in this Policy. The Company also adheres to a number of legislative norms in the field of data transfer, including the EU-US Privacy Shield Framework, as well as a similar agreement between the United States and Switzerland, the Swiss-US Privacy Shield Framework.
Personal data is processed using automated systems, except when non-automated processing of personal data is necessary in connection with the fulfillment of legal requirements.
7.3. The processing of the User’s personal data includes the following actions by the Company: collection, recording, systematization, accumulation, storage, clarification (updating, changing), extraction, use, transfer (distribution, provision, access), depersonalization, blocking, deletion, destruction.
7.4. The User’s personal data is collected in the cases specified in clause 2.1 of the Policy.
7.5. Personal data is stored (depending on which event occurs first):
– until they are deleted by the User in the „My Profile and Programs” and „Settings” sections of the personal account;
– until they are destroyed by the Company – in case the User withdraws consent to the processing of personal data or requests the destruction of personal data;
– until the expiration of the consent (clause 2.2 of the Policy) or the achievement of the purposes of personal data processing. - 7.6. The User may update personal data independently in the sections „Personal data”, „My interests” of the Personal Account or by the Company at the User’s request.
7.7. The Company may disseminate personal data only in the following cases:
7.7.1. Subject to the processing of personal data in order to display the User’s profile for other users of the Site to maintain communication, including when providing services remotely. In this case, the User’s personal data may be available to the Users registered on the Website in accordance with clauses 2.1.4, 2.1.8.
7.7.2. For the purpose of posting reviews of the services provided by the Company left by the Users in various information sources.
7.7.3. In order to place video materials obtained in the process of providing services in various sources of information.
7.8. The Company has the right to transfer personal data to third parties (the Company’s Processors) subject to the following conditions:
– The third party ensures the confidentiality of personal data during their processing and use; undertakes not to disclose to other persons, as well as not to distribute personal data of users without their consent.
– The third party guarantees compliance with the following measures to ensure the security of personal data during their processing: use of information security tools; detection and recording of unauthorized access to personal data and taking measures to restore personal data; – restriction of access to personal data; – registration and recording of actions with personal data; – control and evaluation of the effectiveness of the measures taken to ensure the security of personal data. - 7.9. The Company destroys personal data in the following cases:
– deletion of personal data by the User in the „My Profile and Programs” and „Settings” sections of the personal account;
– receipt from the User of a withdrawal of consent to the processing of personal data;
– receipt of a request from the User to destroy personal data;
– expiration of the consent (clause 2.2 of the Policy). - The Company does not transfer personal data to third parties, except when such transfer is required by law, at the request of the personal data subject or in other cases set forth in this Policy. The Company understands that personal information is a value and inalienable content, including personal non-property rights of any individual, and therefore takes all possible measures to protect the personal information of users voluntarily and knowingly transferred to the Company.
7.10. Cross-border transfer of personal data
The Company is obliged to make sure that the foreign state to whose territory it is planned to transfer personal data provides adequate protection of the rights of personal data subjects before such transfer.
Cross-border transfer of personal data on the territory of foreign states that do not provide adequate protection of the rights of personal data subjects may be carried out in the following cases:
– the personal data subject’s written consent to the cross-border transfer of his/her personal data;
– performance of a contract to which the personal data subject is a party. - 8. Protection of personal data
The Company takes the necessary and sufficient legal, organizational and technical measures to protect the information provided by the Users from unauthorized or accidental access, destruction, alteration, blocking, copying, distribution, as well as from other illegal actions of third parties. However, despite its best efforts, the Company cannot guarantee absolute protection against any threats arising outside the Company’s regulation.
The Company uses standard methods of operation: encrypted communication, protected premises, network security systems and password protection systems to ensure the confidentiality of personal data.
The Company provides access to information and personal data only to authorized employees who have agreed to ensure the confidentiality of such information and data in accordance with the requirements of the Company.
The Website may contain links to other websites (for informational purposes only). If you follow a link to other websites, this Policy will not apply to such websites. In this regard, the Company recommends that you familiarize yourself with the privacy and personal data policy of each website before submitting personal data that can be used to identify you. - 9. Rights of the Users
The User has the right to:
9.1. At his/her discretion, provide the Company with personal data for processing under the conditions specified in the Policy. At the same time, some of the personal data provided is necessary for the conclusion of the User Agreement, and in case of failure to provide it, the conclusion of such an Agreement is impossible;
9.2. Independently make changes and corrections to your personal data in the section „Personal data”, „My interests” in your personal account, provided that such changes and corrections contain relevant and reliable information;
9.3. Delete personal data by editing the section „Personal data”, „My interests” in the personal account;
9.4. Require the Company to clarify his/her personal data, block or destroy it if the personal data is incomplete, outdated, inaccurate, illegally obtained or not necessary for the stated purpose of processing, as well as take measures provided for by law to protect his/her rights;
9.5. To receive a response on whether personal data is processed no later than thirty calendar days from the date of receipt of the request, except as provided by law, and to receive the content of such personal data;
9.6. To submit a reasoned request to the personal data controller with an objection to the processing of their personal data;
9.7. To apply legal remedies in case of violation of the legislation on personal data protection, including filing a complaint with a supervisory authority;
9.8. To update, access, amend, block or delete your personal data, revoke the consent to the processing of personal data that you have provided to the Company in accordance with this Policy, or if you have any comments, requests or claims regarding your personal data processed by the Company, please contact the Company by e-mail: tribe.business.school.pl@gmail.com.
9.9. Send the Company your requests and requirements, including those regarding the use of your personal data, as well as withdrawal of consent to the processing of personal data. The Request may be sent in writing to the Company’s address (Section 11 of the Policy); or by e-mail (the Document must be sent from the User’s e-mail address specified by him/her during registration on the Website or in the Agreement as an authorized e-mail address), to the Company’s e-mail address tribe.business.school.pl@gmail.com. The Company shall consider the Users’ Requests, respond to them and/or take the necessary actions within 30 calendar days from the date of receipt of the Request.
9.10. Крім перерахованих в цій Політиці прав Користувач має можливість реалізувати будь-яке передбачене Законом право. - 10. Changes to the Policy
10.1. The Company reserves the right to make changes and additions from time to time and without prior notice to the User, including in case of changes in the requirements of the law.
The User has the obligation to familiarize himself with the text of the Policy every time he uses the Website.
10.2. The new version of the Policy comes into force from the moment it is posted in the relevant section of the Company’s website. Continued use of the Website or its services after the publication of the new version of the Policy means acceptance of the Policy and its terms by the User. In case of disagreement with the terms of the Policy, the User must immediately stop using the Website and its services.
10.3. Please review the Policy from time to time in order to be aware of any changes or additions.