Privacy Policy

We are very pleased that you have trusted us and provided us with your personal data. We would like to assure you that we will take all reasonable measures to protect your personal data. Below you will find details about how we process your personal data (hereinafter collectively referred to as the “Privacy Policy”) in the situation when:

• you visit the website www.ailleron.com, www.livebank24.com (including each of their subsites – hereinafter referred to collectively as the “Website”),
• you sign up to the Newsletter,
• you wish to receive our marketing material or commercial information about our products and services,
• you conclude Resource Material Agreement with us,
• we contact you or you contact us because you are our supplier/customer or member of staff/representative of our supplier/customer,
• you contact us, including for example via contact forms on the Website, our social media, in person, by traditional mail, or by email, or provide us with your details so that we can contact you about a specific matter,
• you are a shareholder or perform management duties at Ailleron and Ailleron fulfills its legal obligations to you through the website www.ailleron.com,
• we run pages/channels on social networking sites like Facebook (Meta), Instagram (Meta), X, LinkedIn and Youtube.

1. Data Controller

1.1. The data controller of your personal data processed in accordance with this Privacy Policy is Ailleron Spółka Akcyjna (a Polish joint-stock company), with its main office in Kraków, address: al. Jana Pawła II 43b, 31-864 Kraków, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Kraków Śródmieście in Kraków, XI Commercial Division of the National Court Register under the KRS number 0000385276, TIN number: 9452091626, REGON: 120532280 (hereinafter: “Ailleron”).

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: dane.osobowe@ailleron.com

2. Purpose and Legal Basis of Processing of Personal Data

We will process your personal data that we obtain in situations covered by this Privacy Policy for the following purposes:

• to fulfil legal obligations incumbent on Ailleron as a joint-stock company listed on the Stock Exchange – based on national and European Union laws imposing such obligations, including regulations governing the functioning of commercial companies and their obligations towards shareholders and reporting obligations (article 6 (1) point (c) GDPR),
• to fulfil legal obligations incumbent on Ailleron related to the provision of intermediary services, including content moderation and receiving notifications of illegal content in provided services, in accordance with Article 16(1) of Regulation (EU) 2022/2065 of the European Parliament and of the Council of 19 October 2022 on a single market for digital services and amending Directive 2000/31/EC (Digital Services Act) (“Notification”) or complaints about decisions made as a result of handling the Notification (“Complaint”) – based on the aforementioned European Union laws and national laws imposing such obligations (article 6 (1) point (c) GDPR),
• to analyze the use of the Website, as well as to improve its functioning and security, as well as to analyse how you use our social media accounts – based on our legitimate interest as a personal data controller (article 6 (1) point (f) GDPR),
• to pursue and defend against claims, before courts and administrative bodies, as well as outside of them – based on our legitimate interest as a personal data controller (article 6 (1) point (f) GDPR),
• for direct marketing of products or services – based on our legitimate interest if we have an existing business relationship with you (article 6 (1) point (f) GDPR), 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 – on article 6 (1) point (a) GDPR),
• to research the effectiveness of our marketing activities and improve their quality – based on our legitimate interest as a personal data controller (article 6 (1) point (f) GDPR),
• to respond to inquiries sent to us via contact forms or social media, or messages sent to our contact details, or providing us with requests to get in touch on a given matter – based on our legitimate interest as a personal data controller (article 6 (1) point (f) GDPR),
• to organise online events, on the basis that the processing is necessary for the performance of the agreement under which you are participating in the online event (article 6 (1) point (b) GDPR),
• to make recordings of online events and publish this recordings online – if you are just an element of a larger whole, such as a gathering, landscape, or public event, based on our legitimate interest as a personal data controller (article 6 (1) point (f) GDPR), and in other cases on the basis of your consent (article 6 (1) point (a) GDPR),
• for the performance and settlement of the contract (article 6 (1) point (b) and (f) GDPR – if you are our supplier/customer or member of staff/representative of our supplier/customer),
• for sending by us marketing information about our products and services, including sending commercial information within the meaning of the provisions of the Act of 18 July 2002 on the provision of services by electronic means, including direct marketing – if you have consented to the processing of personal data for these purposes (article 6(1) point (a) GDPR and Article 398(1) of the Act of 12.07.2024. – Electronic Communications Law),
• to dispatch of the Newsletter – based on the necessity of processing for the performance of the agreement on the provision of the Newsletter service by electronic means (pursuant to article 6(1)(b) of the GDPR and Article 398 (1) of the Act of 12.07.2024. – Electronic Communications Law),
• for data archiving and making backups – 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 (article 6 (1) point (c) and (f) GDPR).

3. Data Processed for Contact and Marketing Purposes – Scope of Processing

If you decide to contact us using the contact form available on our websites, or using our email addresses, phone numbers, by traditional mail, or in person, as well as in situations where we have the right to contact you (e.g., for marketing purposes when you give your consent, we have established a business relationship with you or you have made a request to us to contact you about a particular matter, or if you are a shareholder of Ailleron), we will process personal data that you provide to us or that are necessary to respond to your inquiry (including identification and contact details, as well as the IP address when using the contact form on our website), or which we have in connection with our existing relationship or we have collected from publicly available sources. We process these data:

• because they are necessary to fulfil the obligations imposed on us, that is in particular:
  • if a Notification was made or a Complaint was filed regarding the content you submitted/provided – informing you of the decision made regarding such content,
  • for the publication of information resulting from the fulfilment of our obligations towards our shareholders or reporting obligations under applicable legislation;
• due to the fact that they are necessary for purposes resulting from legitimate interests pursued by us, that is in particular:
  • in order to reply to a message sent to us and further contact with you,
  • in order to respond to your request to get in touch with you on a specific issue,
  • for direct marketing of our own products and services, if we have an established business relationship,
  • for archiving and making backups of data in connection with the obligation imposed on us as a personal data controller to properly secure data,
• 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.

The provision of personal data is voluntary, but may be necessary in order to answer a question you have asked and/or to contact you.

4. Data Processed in Connection with Website Use – Scope of Processing

When you use the Website, we record 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 may collect these data both in our Website server log and through additional technologies such as cookies. In most cases, we will not be able to identify you as a user and these data will be anonymous to us – our intention is not to collect your personal data. However, if we are able to link this information to you, which can happen when we have additional data from another source (e.g., we record such data when you contact us via the contact form on our Website), they become your personal data for us. We process these data:

• for the provision of electronic services in terms of making available to users the content collected on the Website, on the basis of necessity to perform the agreement on provision of services electronically,
• because they are necessary for purposes arising from our legitimate interests, particularly:
  • adjusting the way the Website is displayed and personalizing it,
  • saving data from forms to maintain session and facilitate the use of the Website,
  • analyzing the use of the Website 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.

The provision of personal data is voluntary, but may be necessary for the use of the Website and its functionalities.

5. Data Processed in Connection with a Notification or Complaint – Scope of Processing

In case of making a Notification or filing a Complaint, we will process such personal data as the name and email address of the notifier/complainant, data regarding the entity on whose behalf the notifier/complainant is acting and its position (if applicable), other data provided in the Notification or Complaint, as well as the IP address and data contained in the content that is the subject of the Notification or Complaint. Please note that providing personal data is a statutory requirement. The lack of providing data may result in the inability to process the Application or Complaint. We process the data due to the fact that it is necessary for the fulfillment of our obligations, which include:

• receiving and considering the Notification and informing about the decision made regarding the Notification, as well as about the possibility of appealing our decision made regarding the Notification,
• receiving and considering the Complaint and informing about the decision made by us regarding the filed Complaint,
• identifying the notifier/complainant as a person authorized to represent the entity on whose behalf the Notification or Complaint was made (if applicable),
• informing law enforcement or judicial authorities of the interested Member State or interested Member States about the suspicion that a crime threatening the life or safety of a person, or persons has been committed, is being committed, or may be committed, and providing all available information on this matter.

6. Data Processed for Organization of Online Events

6.1 In the event that you registered for online event, including webinar organized by us, we will process the following personal data: your first name, last name, name of company which employs you/cooperates with you, email address, your account name on the platform we use for the transmission of events, the data you voluntarily provide during the event such as other data, your image and voice (e.g. if you participate in a discussion with the tutor or other participants and you decide to provide your image/voice).

6.2 Your personal data will be processed:

• to respond to your inquiries concerning a possibility of participation in webinars,
• to send you an invitation for an event together with a link to the registration form,
• to create an account at a platform we use for the organization of the event,
• to send you a link to the event in order to enable you to participate in the event including giving you an opportunity to take part in a discussion which may take place during the event,
• to make recordings of the events and to publish these recordings online on a paid or unpaid basis.

6.3. If you register for an online event organized by us, we will make your data available to HubSpot, Inc., LinkedIn Ireland Unlimited Corporation, Microsoft Corporation, Zoom Communications, Inc. and ClickMeeting sp. z o.o. – the suppliers of the online platforms HubSpot, LinkedIn, Microsoft Teams, Zoom and ClickMeeting for the organization of online events in order to create an account for you and enable you to participate in the online event organized by us (depending on the online event you choose, the respective supplier and type of platform may vary). In this case, HubSpot, Inc., LinkedIn Ireland Unlimited Corporation, Microsoft Corporation, Zoom Communications, Inc. and ClickMeeting sp. z o.o. may become separate controllers of some of your data, such as login credentials, IP address, data of the network you use or settings of the device you use to connect these platforms. The details of how the above-mentioned entities process the user data can be found on the following pages:

• HubSpot – information on how HubSpot processes personal data is available here: https://legal.hubspot.com/privacy-policy
• LinkedIn – information on how LinkedIn processes personal data is available here: https://linkedin.com/legal/privacy-policy
• Microsoft Teams – information on how Microsoft processes personal data is available here: https://www.microsoft.com/en-us/privacy/data-collection-teams and https://www.microsoft.com/en-us/privacy/privacystatement/
• Zoom – information on how Zoom processes personal data is available here: https://www.zoom.com/en/trust/privacy/privacy-statement/ and https://media.zoom.com/download/assets/privacy-data-sheet.pdf/
• ClickMeeting – information on how ClickMeeting processes personal data is available here: https://legal.clickmeeting.com/privacy-security/privacy-policy/

7. Data Processed in Connection with Cooperation with our Suppliers and Customers

7.1 In the event that we establish a cooperation with our Suppliers and Customers, we will process personal data of their designated representatives and members of staff who conclude contracts on behalf of our Customers and Suppliers, are involved in the execution of such contracts and whom we contact in the course of such cooperation.

7.2 Thus, if you are a representative or a member of staff of our Supplier or Customer (e.g. contact person), we will process your personal data that was provided by your employer or principal: your first name, last name, the company you work for, your position and contact details.

7.3 We process this data: 

• for the performance and settlement of the contract concluded with your employer or principal – based on our legitimate interest in ensuring the proper performance of contractual obligations,
• for establishing and maintaining good business relations with your employer or principal – based on our legitimate interest in maintaining business relations with our Suppliers and Customers,
• for conducting direct marketing of our products or services – based on our legitimate interest in marketing and promotion of our products and services,
• for archiving to the extent necessary to comply with legal obligations, in particular tax regulations, accounting regulations – based on our legitimate interest in storing evidence related to conclusion or performance of the contract with our Customer or Supplier,
• for possible establishment and investigation of claims or defence against claims – based on our legitimate interest in protection and assertation of our rights.

8. Data Processed in Order to Conclude and Execute Resource Material Agreement

8.1 In the event that you conclude with us Resource Material Agreement, we will process personal data that you provide to us in order to conclude and execute Resource Material Agreement (agreement for the supply of digital content such as e-books or digital services such as participation in webinars, training sessions and other events in exchange for your personal data which will be processed for marketing and promotional purposes, such as contact in order to present you our products and services and sending you our newsletter). The scope of data includes name, surname and e-mail address, name of company and your position.

8.2 We will process your personal data that we obtain for the following purpose:

• to deliver you digital content or services: for organization of webinars, trainings and other events, which you signed up or deliver you other digital content or services, such as e-books,
• for archiving to the extent necessary to comply with legal obligations,
• for marketing of our products or services, including sending you our Newsletter.

8.3 We will process your personal data based on a necessity of the data processing for the conclusion and performance of the Resource Material Agreement and our legitimate interest as a personal data controller.

9. Data of Newsletter’s Subscribers

9.1 In the event that you sign to get our Newsletter, we will process personal data that you provide to us in order to receive our Newsletter (in particular information about our products and services).

9.2 The scope of data includes name, surname, e-mail address, the position/function held, the economic sector in which the company provides its services.

9.3 We will process your personal data that we obtain for the following purpose:

• to send you our Newsletter,
• for archiving to the extent necessary to comply with legal obligations.

9.4 We will process your personal data based on a necessity of the data processing for the conclusion and performance of the agreement and our legitimate interest as a personal data controller.

10. Data Processing Period

Your personal data will be processed:

• to contact you – from the day they were collected until we have completed correspondence on the matter on which you have made contact or until such time as we reasonably believe we will need to contact you,
• for marketing purposes – (i) in case of marketing based on our legitimate interest – for the duration of our legitimate interest, that is, the duration of our relationship or until you object, however no longer than you effectively objected it; (ii) in cases that marketing is based on your consent – until the withdrawal of consent, that was given to us,
• for the purpose of the organization of an online event – for the time necessary to execute and settle the contract on the basis of which you participate in the online event, but for a period not exceeding the limitation period for claims,
• for the purposes of pursuing and defending against claims – for a period not exceeding the limitation period for claims or the duration of a specific proceeding, if one is initiated,
• for the purposes of performing legal obligations imposed by law – for a period not longer than necessary to demonstrate that these obligations were fulfilled by Ailleron,
• for the purpose of improving the functionality 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 performance and settlement of contracts concluded with Suppliers and Customers – for the period of performance and settlement of the contract, including the period for claims and keeping records for performance obligations imposed by law,
• for the purpose of establishing and maintaining business relations with Suppliers and Customers – for the duration of such relationship,
• for sending you Newsletter – until the agreement is in force, however no longer than 24 months from the end of the year the agreement was concluded (in particular your data will not be processed for this purpose when you unsubscribed Newsletter or objected the processing),
• for the performance and settlement of the Resource Material Agreement concluded with you – until the agreement is in force, however no longer than 24 months from the end of the year the agreement was concluded (in particular your data will not be processed for this purpose when you unsubscribe from receiving the Newsletter or objected the processing).
• for the purpose of archiving and making backups – for a period determined in accordance with Ailleron’s backup and archiving policy.

11. Data Recipients

We will exercise due diligence in selecting the entities to which we will transfer your data and, in the case of such selected entities, we will require them to protect your data with 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, electronic communications, hosting, supplying a platform for the organization of online events, providing marketing, improvement of sales and customer and legal services),
• entities in the Ailleron Group (entities affiliated with Ailleron), in particular when they provide services to each other, 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),
• recipients to whom disclosure is required by applicable law or order of a court or other authority,
• 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 the vital interests of other individuals or for the public good.

We particularly use the services of the following third parties:

Hubspot

We use HubSpot for inbound marketing, improving sales, and customer service (including through a CRM system). Generally, HubSpot acts as our data processor, but in some limited cases, it may process your data as a separate data controller. This can concern data related to your use of our Website, which has first been anonymized or aggregated and shall not allow to directly identify you. This may happen when you start using our Website and give consent to the cookies that are placed by HubSpot on our Website (based on your consent), or when you engage in further interactaction with us (e.g., by contacting us or becoming our customer) – in such a case, the basis for processing will be our legitimate interest or HubSpot’s legitimate interest. The purpose of data processing by HubSpot (in addition to providing services to us) is to support specific features and functionalities of HubSpot’s products and services (which is HubSpot’s legitimate interest). Further and more detailed information on how HubSpot uses your data and your rights can be obtained by accessing HubSpot’s privacy policy (https://legal.hubspot.com/privacy-policy) or by contacting HubSpot directly (using the contact form available here: https://preferences.hubspot.com/privacy or by mail at the address: HubSpot, Inc., 25 First Street, 2nd Floor, Cambridge, MA 02141, Attention: Privacy and Data Protection Officer).

Google

We use Google Analytics, a web analytics service offered by Google that tracks and reports information about Website traffic. This information is then shared with Google, which may use it to contextualize and personalize ads. You can opt out of sharing information about your activity on our Website with Google by installing the browser add-on to disable Google Analytics (available for download from this page: https://support.google.com/analytics/answer/181881?hl=en&sjid=11447657786918276799-EU). This add-on prevents Google Analytics JavaScript from sharing information about your activity with Google Analytics. You can also disable ad personalization here: https://adssettings.google.com/.

Data collected via Google Analytics may then be shared and used by other tools in the Google suite that we use (Google Ads, Google Tag Manager, and Google Search Console).

We also use reCAPTCHA, a service by Google that helps protect websites from spam and abuse. “CAPTCHA” is a Turing test to distinguish humans from bots. By adding reCAPTCHA to our Website, we can block automated software. For the reCAPTCHA API to work, it collects information about hardware and software (which in some cases may be personal data), such as device and application data, and sends it to Google for analysis.

For more information about Google’s privacy practices, visit Google’s Privacy & Terms website: https://policies.google.com/privacy and https://policies.google.com/terms.

Meta (formerly Facebook)

We use the Meta Pixel provided by the social network Facebook, operated by Meta Platforms, Inc., 1 Hacker Way, Menlo Park, CA 94025, USA, or if you are an EU resident, by Meta Platforms Ireland Ltd., 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (hereafter “Meta”). The Meta Pixel is a mechanism (a piece of JavaScript code) for tracking your activity on our Website to identify you as a target audience for our ads on Facebook. The Meta Pixel also helps us track the effectiveness of our ads for statistical and market research purposes by checking if users visited our Website after seeing our ad on Facebook (conversion tracking). The Meta Pixel stores a cookie on your device – if you log into Facebook or visit Facebook, your visit to our Website will be noted on your Facebook profile. By using the Meta Pixel, we gain access to analytical data (which very rarely may be sufficient to identify you and become your personal data). Meta collects and processes your data, which are associated with your Facebook profile (or sometimes with other data if you do not have a Facebook profile). Thus, we and Meta are considered joint controllers concerning the aforementioned processing. The joint controllership agreement between us and Meta is available here: https://www.facebook.com/legal/controller_addendum.
More information about the Meta Pixel can be found here: https://www.facebook.com/business/help/742478679120153?id=1205376682832142.
Information on how Meta processes your personal data can be found here: https://www.facebook.com/privacy/explanation.

12. Transfer of Personal 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 personal data protection, we will ensure that it is done based on a valid legal basis and with the use of legally required safeguards.

13. Links to Third-Party Websites

The Website contains links to third-party websites. When you visit these websites 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 personal data processing published by the administrators of these websites.

14. Social Media

Social Media Plugins

The Website includes social media plugins. By using the Website, the IP address of your device and the identifier of the browser you are using are transmitted to the providers of these social media platforms. Through this integration, the providers receive information that your browser has accessed our Website, even if you do not have a profile with the respective provider or are not currently logged in. Clicking on social media plugins also establishes a direct connection to the servers of these providers, who may collect other data from your device. Please note that we have no control over what data is collected by social media platforms after clicking on their buttons. 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 privacy protection options, please visit: 

• Facebook (Meta) – Information on how Meta processes personal data is available here: https://www.facebook.com/privacy/explanation. Please note that along with Meta Platforms Ireland Limited (“Meta”), Ailleron acts as joint controller regarding data processing for statistical purposes. Information about the terms of joint data processing by Ailleron and Meta can be found here: https://www.facebook.com/legal/terms/page_controller_addendum. Information on how Meta processes personal data for statistics purposes is available here: https://www.facebook.com/legal/terms/information_about_page_insights_data;
• Instagram (Meta) – information on how Meta processes personal data is available here: https://privacycenter.instagram.com/policy/;
• X (ex-Twitter) – information on how X processes personal data is available here:: https://x.com/en/privacy;
• LinkedIn – information on how LinkedIn processes personal data is available here: https://linkedin.com/legal/privacy-policy;
• Youtube – information on how Google processes personal data is available here: https://policies.google.com/privacy.

Social Media Profiles

14.1 We operate pages/channels/fanpages on social media sites Facebook (Meta), Instagram (Meta), X, LinkedIn and Youtube to promote our business.

14.2 We process personal data of individuals who, on our social media profiles:

• subscribed to a profile by clicking the ‘Like’, ‘Follow’, ‘Share’ or ‘Subscribe’ icon, etc;
• have performed an action/reaction on the profile on social media, e.g. by clicking ‘Like’, ‘Comment’, ‘Share’, ‘Save post’, ‘Retweet’, etc.; and
• sent us a private message via the ‘send message’ function.

14.3 We obtain personal data from the administrators of Meta Platforms Ireland Limited, Twitter International Unlimited Company, LinkedIn Ireland Unlimited Company and Google Ireland Limited from your public profile and posts on the aforementioned social media sites.

14.4 As the founder of pages on the aforementioned social media sites provided by the entities indicated, the controller of your personal data is also:

• Meta Platforms Ireland Limited (Facebook and Instagram) with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland;
• Twitter International Unlimited Company (X) with registered office at One Cumberland Place, Fenian Street, Dublin 2, Ireland;
• LinkedIn Ireland Unlimited Company (LinkedIn) with registered office at Wilton Plaza, Wilton Place, Dublin 2, Ireland;
• Google Ireland Limited (Youtube) with its registered office at Gordon House, Barrow Street, Dublin 4, Dublin, Ireland,

and each of them independently decides on the purposes and means of data processing. Each social media channel has its own policy on how it processes and protects personal data. We are only responsible in respect of the personal data we process. If you have any concerns or questions about the use of personal data by the above-mentioned entities, please read their privacy policy carefully before using the channels they provide.

14.5 Due to the specific nature of the operation of the aforementioned social media, information about the actions taken by users on these sites is public. The data that is available to all users of the aforementioned social media, including us, includes: identification data, such as e.g. the user’s name, nickname, address data and other data available on the profile; data in the form of image captured in published photos and videos; data contained in published comments and posts.

(a) Facebook and Instagram

14.6 The scope of data that may be processed by us as profile provider and social media providers is as follows:

We only have access to the aggregate statistics of the page (number of followers of the fanpage/profile, age and gender of the users with a breakdown of the percentage of followers, names of the cities and countries from which the users are following with a breakdown of the percentage, reach of the fanpage/profile and individual posts, number of likes and reactions, number of comments and shares, number of clicks on the link and aggregate and anonymised reports on campaigns run via the self-service advertising system).

Details of the rules for the joint processing of site statistics with Meta Ireland Limited are available at: https://en-en.facebook.com/legal/terms/page_controller_addendum.

(b) X (ex-Twitter)

We only have access to personal data you share with your public profile.

The rules for the processing of personal data specified by the X (ex-Twitter) service provider can be found at: https://x.com/en/privacy.

(c) LinkedIn

We only have access to numerical data for a given period of time (number of profiles that have visited the profile, number of profile mentions, number of new observers and new contacts, number and type of reactions under the publication, number and content of comments, number of shares of the publication, content of messages sent via website, data contained in the profile – inter alia image, name and surname, education, career history, in the case of profiles run by entrepreneurs: average duration of employment with a given entrepreneur, related persons working for a given entrepreneur, education of some of the employees).

The data processed within the LinkedIn platform is co-managed by the Ailleron and LinkedIn (LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland). The details of the data co-management, including information on your rights, are described on this page: https://legal.linkedin.com/pages-joint-controller-addendum.

(d) Youtube

We only have access to personal data you share with your public profile.

The rules for the processing of personal data specified by the Youtube service provider can be found at: https://policies.google.com/privacy.

14.7 Details of the personal data processing rules set out by the provider of the relevant service and other products and features offered by the service provider can be found in the service’s privacy policy, available at:

• Facebook – https://www.facebook.com/privacy/explanation. If you access our profile from outside the EU/EEA the controller of your data may be Meta Platforms Inc., 1601 Willow Road, Menlo Park, California;
• Instagram – https://privacycenter.instagram.com/policy/. If you access our profile from outside the EU/EEA the controller of your data may be Meta Platforms Inc., 1601 Willow Road, Menlo Park, California;
• X (ex-Twitter) – https://x.com/en/privacy. If you access our profile from outside the EU/EEA the controller of your data may be X Corp., 1355 Market Street, Suite 900, San Francisco, CA 94103;
• LinkedIn – https://linkedin.com/legal/privacy-policy. If you access our profile from outside the EU/EEA the controller of your data may be LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale, CA 94085;
• Youtube – https://policies.google.com/privacy. If you access our profile from outside the EU/EEA the controller of your personal data may be Google LLC, 1600 Amphitheatre Parkway, Mountain View, California 94043, USA.

14.8 Your personal data will be processed in order to:

• maintain our profiles on the social networks Facebook (Meta), Instagram (Meta), X (ex-Twitter), LinkedIn and Youtube in order to inform you through them about our activities, to promote events, to inform you about our offer (to provide information about the products and services provided, to carry out sales activities), employer branding, to carry out marketing and promotional activities and to communicate through the available functionalities of these websites;
• carry out statistical analyses carried out through the tools provided by the applications of the respective social networks regarding the popularity and use of the social media sites belonging to us.

14.9 Personal data will be processed for the aforementioned purposes on the basis of necessity for the purposes arising from the legitimate interests pursued by us as a data controller in the form of running and managing our pages, channels, fanpages on social media sites (based on Article 6(1) point (f) of the GDPR).

14.10 In the event that you choose to provide us with additional personal data through the use of functionality offered by the provider of the relevant social network (such as Sales Navigator within LinkedIn), we will process your personal data on the basis of your consent (on the basis of Article 6(1) point (a) of the GDPR).

14.11 The provision of personal data is voluntary, but may be necessary for the use of our social media profiles.

15. Data Subject Rights

Regarding each of the rights listed below, you can contact us using the contact details provided in section 1 of the Privacy Policy. You have the following rights:

• Right to obtain information, access to data, and to receive a copy of 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. Whenever your data is processed based on your consent given, you have the right to withdraw that consent at any time. However, the withdrawal of consent will not affect the lawfulness of data processing that happened before you withdraw your consent.
• Right to rectify personal data. We take reasonable steps to ensure that your personal data is correct, complete, and up-to-date. If changes to this data are necessary, please notify us accordingly.
• 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, where the legal basis for the processing of your data is your consent or the performance of a contract.
• 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, and there may be situations when we are still entitled to process your personal data. You may also request restriction of 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 further processing of your data where the processing is based on our legitimate interest in carrying out direct marketing, or where the processing is based on our legitimate interest for purposes other than direct marketing, and you raise an objection on grounds justified by your particular situation.
• Right to lodge a complaint with a supervisory authority. You have the right to lodge a complaint with the supervisory authority responsible for data protection. As a rule, this will be the President of the Office for Personal Data Protection (Prezes Urzędu Ochrony Danych Osobowych) (contact details: Stawki 2 Street, 00-193 Warszawa; https://uodo.gov.pl/en).

16. Changes to the Privacy Policy

16.1 The Privacy Policy is continuously reviewed and updated as necessary.

16.2 The current version of the Privacy Policy has been adopted and is effective as of 07.04.2025