- you visit our website: www.ailleron.com, www.livebank24.com (hereinafter the “Website”),
- you contact us, including by contact forms available at the Website, personally, by traditional mail or using e-mail,
- you are our shareholder, or you perform managerial duties in Ailleron and Ailleron uses the Website: www.ailleron.com to perform its duties resulting from the provisions of law.
1. Data Controller
1.2. In matters regarding your personal data, you can contact us:
- by mail or personally – 43b Jana Pawła II Avenue, 31-864 Kraków, Poland,
- by e-mail: firstname.lastname@example.org
2. Purpose and legal basis of processing of personal data
- to respond to inquiries sent to us via contact forms, or to messages sent to our contact details – based on our legitimate interest as a personal data controller,
- to fulfill legal obligations incumbent on Ailleron as a joint stock company listed on the Warsaw Stock Exchange – based on the provisions of Polish law and European Union law imposing such obligations, including those regulating the functioning of commercial companies and their obligations towards shareholders and reporting obligations,
- to analyze the use of the Website, as well as to improve its functioning and security – based on our legitimate interest as a personal data controller,
- to pursue and defend against claims, before courts and administrative authorities and outside them – based on our legitimate interest as a personal data controller,
- for direct marketing of products or services – based on our legitimate interest if we have an existing business relationship with you, and if we are just going to establish such a relationship based on your consent (from the time the consent is given for no longer than until its withdrawal),
- to send newsletters – based on our legitimate interest in the event that you subscribe to our newsletter,
- for data archiving and backing up – in connection with the obligation imposed on us as a data controller to properly secure data and based on our legitimate interest as a personal data controller.
3. Data processed for contact purposes – scope of processing
In the event that you decide to contact us using the contact form available on our Website, or using our email addresses, phone numbers, or traditionally by mail, or in person, as well as in situations where we have the right to contact you ( e.g. for marketing purposes, or when you are a shareholder of Ailleron), we will process personal data that you provide to us or are necessary to respond to your inquiry (including identification and contact details, as well as the IP address when using the form contact on our Website), or which we have in connection with the relationship that connects us, or we have collected from publicly available sources. We process these data due to the fact that they are necessary to fulfill the obligations arising from the above-mentioned provisions or to pursue the legitimate interests of Ailleron, i.e.:
- in order to reply to a message sent to us and further contact with you,
- for direct marketing of own- and third-party products and services (in a situation where we do not have your consent to the processing of data for marketing purposes),
- for archiving and backing up data in connection with the obligation imposed on us as a data controller to properly protect data).
4. Data processed in connection with the use of our website – scope of processing
If you use the Website, we save data such as: IP address, type and version of the device and browser you use, language, region, Website settings, choices made in the area of cookies, and how you use the Website. We can collect this data both by our Website’s server logs and with the use of additional technologies, such as, e.g., cookies. In most cases, we will not be able to identify you as a user and this data will be anonymous to us – our intent is not to collect your personal data. However, in a situation where we are able to connect information with you, which may occur when we have additional data from another source (e.g., we will save such data when you contact us using the contact form on our Website), they become your personal data for us. We process this data
- due to the fact that they are necessary for purposes resulting from legitimate interests pursued by us, that is in particular:
a. adjusting the way, the Website is displayed and personalizing it,
b. saving data from forms to preserve the session and facilitate the use of the Website,
c. analyzing the Website’s behavior to improve its functioning and protect against abuse,
- based on your consent – if this data is used for marketing purposes and we do not have an existing business relationship, or when it is collected to provide it to third parties.
5. How long do we process personal data
Your personal data will be processed:
- to contact you – from the day they were collected and as long as we are holding the conversation in the matter in which you made contact,
- for marketing purposes – for the duration of our legitimate interest, i.e., the duration of the relationship that connects us or until consent is withdrawn, if it was given to us,
- for the purposes of pursuing and defending against claims – for a period not exceeding the limitation period for claims or for the duration of a proceeding in case such one is started,
- for the purposes of performing obligations imposed by law – for a period not longer than necessary to demonstrate that these obligations were carried out by Ailleron,
- for the purpose of improving the functioning and security of the Website – for the time for which these data are necessary to achieve this purpose, but no longer than until you express an effective objection to their processing,
- for the purpose of sending newsletters – from the date of signing up until you effectively object to the processing (unsubscribing from the newsletter),
- for archiving and backup purposes – for the period determined in accordance with the backup and archiving policy at Ailleron.
6. Data recipients
We will use due diligence in the selection of entities to which we will transfer your data and in the case of such selected entities we will require that they protect your data by appropriate technical and organizational measures. Your personal data may only be disclosed:
- to third parties providing services to us that are needed to achieve the purposes in relation to which we process your data (e.g., IT services, recruitment, electronic communication, hosting),
- to entities from the Ailleron capital group (entities associated with Ailleron), in particular when they provide each other services, or as part of the internal administrative purposes of the Ailleron group (e.g., when this results from the organization of tasks within the group),
- to recipients to whom the disclosure is required by applicable law or order of a court or other authority,
- to other recipients, if you give us your consent to disclose data to them or if the transfer of data to them is necessary to protect your vital interests or vital interests of other individuals or for the common good.
In particular, we are using services of the following third parties:
The data gathered using Google Analytics may then be shared and used by other tools from Google suite that we use (Google Ads, Google Tag Manager and Google Search Console).
We also use reCAPTCHA, which is a service from Google that helps protect Websites from spam and abuse. A “CAPTCHA” is a Turing test to tell human and bots apart. By adding reCAPTCHA to our Website, we can block automated software. In order for reCAPTCHA API to work, it collects hardware and software information (which in some cases may be personal data), such as device and app data, and sends it to Google for analysis.
Meta (formerly Facebook)
More information about Facebook pixel can be found here: https://www.facebook.com/business/help/742478679120153?id=1205376682832142.
Information about how Facebook processes your personal data can be found here: https://www.facebook.com/privacy/explanation.
7. Transfer of data to third countries
Your personal data may be transferred to entities outside the European Economic Area (EEA), including the USA, with whom we cooperate. Whenever your personal data is transferred outside the European Economic Area (EEA) or to countries that do not provide the same or an adequate level of protection for personal data, we will ensure that this is done on the basis of a valid legal basis and using the safeguards required by law.
8. Links to third party-websites
The Website also includes links to third-party websites. When you visit these pages, different rules apply than those described here in the field of personal data processing, as well as someone else is the data controller of data processed there. We recommend that you read the rules applicable to the processing of personal data published by the administrators of these websites.
9. Social media
Social media plug-ins
The Website uses social media plugins. By using the Website, your device’s IP address and an identifier of the browser you use are transmitted to the providers of these social media. Thanks to this integration, service providers receive information that your browser has displayed our website, even if you do not have a profile with a given service provider or are not currently logged into it. Clicking on social media plugins additionally establishes a direct connection to the servers of the media providers who can collect other data from your device. Please note that we have no influence on what data is collected by providers of social media when you click on their plug-in. For more information regarding the purpose and scope of data collected by these entities and how your personal data is processed, used, protected, including your rights and possible options to protect your privacy, please visit:
- Facebook. Information on how Facebook processes personal data is available here: https://pl-pl.facebook.com/privacy/explanation. We point out that together with Facebook Ireland Limited (hereinafter “Facebook”) Ailleron acts as a joint-controller in the field of data processing for the purposes of statistics. Information on the principles of joint-controllership of data by Ailleron and Facebook can be found on this page https://www.facebook.com/legal/terms/page_controller_addendum.
Information on how Facebook processes personal data for the purposes of statistics is available here https://www.facebook.com/legal/terms/information_about_page_insights_data.
- Twitter, Inc., USA. Information on how Twitter processes personal data is available here: https://twitter.com/en/privacy.
We also run our company profiles on social networks:
- LinkedIn (which is operated by LinkedIn Corporation, 2029 Stierlin Court, Mountain View, 94043, USA, or if you are a resident of the EU, LinkedIn Ireland Unlimited Company). You can read about the rules that apply to us and LinkedIn in accordance with the contract concluded with LinkedIn and how it affects your rights here: https://www.linkedin.com/legal/l/dpa?
In connection with having a company profile, we have access to the name and surname of the registered person who uses this profile, public photo, and other publicly specified information. In practice, these are elements that are available to all registered users. You can also provide us with other personal information in your comments or messages, such as customer service requests via the above-mentioned. portals. We talk about how we process such data in point 3.
10. Data subject rights
- The right to obtain information, access to data and to receive a copy of the data. You have the right at any time to request information about your personal data that we store or to which we have access. At your request, a copy of your personal data that is subject to processing will be presented to you free of charge. For sending each subsequent copy of data we have the right to request a fee that will cover the reasonable costs of handling such a request.
- Right to withdraw consent. Each time your data is processed based on your consent given, you have the right to withdraw this consent at any time, whereas withdrawal of consent will not affect the lawfulness of data processing that happened before you withdraw your consent.
- The right to rectify personal data. We take reasonable steps to ensure that your personal data is correct, complete, and up to date. If it is necessary to change these data, please let us know.
- Right to data portability. You have the right to request the transfer of your personal data in a structured, commonly used machine-readable format, as well as to request the transfer of data to another data controller, when your consent is the legal basis for the processing of your personal data.
- The right to delete data and to limit processing. In the cases indicated in the provisions of law on the protection of personal data, you have the right to request the deletion of your personal data. However, this right is not absolute – there may be occasions when we are still entitled to process your personal data. You can also request a restriction on the further processing of your data.
- Right to object to processing. In the cases indicated in the provisions of law, you have the right to object to the further processing of your data when the legal basis for the processing of personal data is our legitimate interest.
- The right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with the supervisory body dealing with the protection of personal data – in principle, it will be the President of the Office for Personal Data Protection (Prezes Urzędu Ochrony Danych Osobowych).
11. Cookies Policy
The Website uses the tools indicated above for various purposes, including:
- to adapt the way the Website is displayed to the devices, software, and users’ preferences as well as the settings selected by them,
- to monitor how users use the Website and to improve its functioning,
- to personalize the content offered,
- to target better tailored content displayed to users via other websites.
We use the following types of cookies:
- analytical cookies that investigate user behavior on the Website;
- functional cookies enabling to remember the settings selected by the user and personalization, i.e., in terms of the selected language or the cookies options you select.;
Ways to disable cookies
- Google Chrome – https://support.google.com/chrome/answer/95647?Every=GENIE.Platform%3DDesktop&hl=en
- Opera – https://help.opera.com/en/latest/web-preferences/#cookies
- Firefox – https://support.mozilla.org/en-US/kb/enable-and-disable-cookies-website-preferences
- Apple Safari – https://support.apple.com/en-us/guide/safari/manage-cookies-and-website-data-sfri11471/mac
- Windows Internet Explorer – https://support.microsoft.com/fil-ph/help/17442/windows-internet-explorer-delete-manage-cookies
Users can also set their browsers in a way so that they have to accept cookies each time. Then, the browser will ask the user for permission to grant access each time before granting access to the cookie. This gives the user control over what is stored on his device; however, it has the disadvantage that it slows down the ability to navigate the Website and other websites.
Any user can opt out of receiving ads targeted to him in the following ways:
- by using the NAI tool (www.networkadvertising.org/choices), which will allow you to opt out of watching targeted advertising from us and from other approved NAI member companies,
- via the Digital Advertising Alliance – DDA website (www.aboutads.info/choices). We follow the Self-Regulatory Principles for Online Behavioral Advertising developed by this organization,
- via the website of the European Interactive Advertising Digital Alliance (www.youronlinechoices.com). We follow the guidelines for online advertising developed by this organization.
When using the opt-out option using the tools described above, please remember that:
- we may still collect certain data about your online activity for purposes other than marketing,
- opt-out options of other advertising companies may function differently than our opt-out options,
- each time you can opt out of tracking your activity for advertising purposes by using the “Do Not Track” option. In such cases we respond to “DNT” signals sent from the user’s browser. If the ‘DNT’ signal is received on the page of one of our advertisers during a user’s visit, we will not combine the collected data with the user’s browser ID during this visit, so new data collected about the user cannot be used by us for the purpose of targeted advertising, but previously collected user data can still be used,
- at any time, it is possible to modify the browser settings in terms of cookies. Restricting the use of cookie files may lead to restrictions on some of the functions available on our Website.
You have the option of disabling the transfer of your data for analytical and statistical purposes using Google Analytics. To do this, you can install the browser extension in accordance with the instructions at this address: https://support.google.com/analytics/answer/181881?hl=en.