Privacy policy & Cookies

This Privacy Policy (hereinafter: „Policy”) includes information related to processing Users’ personal data in connection with using Renderro Platform which website is located at https://renderro.com (hereinafter: „the Platform”) and personal data of those users who are only browsing or scanning the Platform, not using it for all practical purposes as users (hereinafter: „Guest Users”).

All terms written with capital letter, which have been defined differently in Policy acquir etheir meaning given in Regulations providing cloud services within Renderro Platform: https://storage.googleapis.com/renderro-mvp.appspot.com/legal/TermsAndConditions.pdf

Personal data Administrator of all Users and Guest Users is Renderro Limited Liability Company (Sp. Zo.o.) based in Puławy (address: ul. Ignacego Mościckiego 1, 24-100 Puławy), entered into the Register of Entrepreneurs maintainedby the District Court Lublin-Wschód in Lublin based in Świdnik, 6th Commercial Division of the National Court Register, under entry No: 0000782690, NIP: 7162826202, REGON: 383143139 (hereinafter: „Administrator”, „Renderro” or „we”).

In all matters related to data processing including execution of warranties attached below, feel free to contact with us via given email gdpr@renderro.com

Means of personal data protection

Renderro uses modern organisational and technical security system to assure Users and Guest Users the best personal data protection. We guarantee that personal data are processed by us in accordance with the provisions of Regulation of the European Parliament and Council (EU)2016/679 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/WE (General Data Protection Regulation) (hereinafter: “GDPR”) on the protection of people of 10th May 2018 on the protection of personal data with other provisions of protection of personal data.

Purposed and legal basis of processing personal data

Enabling the use of the Platform or only browsing requires processing personal data by Renderro. Purposes of the processing personal data of Users and Guest Users are described (in details) below. Legal basis which was used to support the processing data process. Unless otherwise provided, the indicated purpose and legal basis refer to both Users and Guest Users.

The conclusion and performance of the agreement between Administrator - In purpose of conclusion and performance the agreement Renderro proceeds the following personal data: emailaddress, name, surname, User’s dataregistered on application’s account or website’s account (especially email address) – if the User uses such account for logging in to the Platform, address - if the User makes the method of payment activated, and the company and NIP number (when the User uses Platform as an entrepreneur). Legal basis of processing personal data mentioned above is Article 6.1(b) on Personal Data Protection Regulation (PDPR) according which personal data may be processed by Administrator if it is necessary for the performance of the contract between the person who is the data subject or taking necessary actions to conclude the contract. Personal data submission mentioned above is voluntary, however necessary for the conclusion or performance of acontract of cloud-based services concluded between Administrator (failure to provide data will affect that the conclusion of the mentioned above contract shall be impossible).

Fulfilling the obligations concerning tax regulations – to fulfill obligations concerning tax regulations, we are processing following Users’ personal data: name, surname,residential address, company’s name and NIP number (if the User exploits the Platform as an entrepreneur). Legal basis of processing personal data mentioned above is Article 6.1(b) on Personal Data Protection Regulation (PDPR) according which personal data may be processed by Administrator if it is required to perform incumbent legal obligation. Personal data submission mentioned above is voluntary, however necessary to fulfill legal obligations incumbent on Administrator.

Sending newsletter and contact form – if the User Or Guest User subscribed our newsletter or Has agreed to receive our newsletter we’ll be processing his following personal data: email address, when it comes to sending messageto us via contact form, we’ll be also processing another personal data, which is name. Legal basis of processing personal data mentioned above is Article 6.1(b) on Personal Data Protection Regulation (PDPR) according which personal data may be processed by Administrator in order to execute his legitimate interest. In this case our legitimate interest is as follows: informing about current and planned Renderro’s activity (newsletter) and remaining in contact with Users of our website (contact form). Personal data submission mentioned above is voluntary, however necessary to receive newsletter (failure to provide data will affect that the receiving of the mentioned above newsletter shall be impossible) or using contact form (personal data are necessary that we could answer to the message you’ve sent to us).

Fulfilling obligations related to personal data protection (e.g. creating appropriate registers)– to fulfill all obligations related to regulations regarding personal data processing, we are processing following information: name, surname, email address. Legal basis of processing personal data mentioned above is Article 6.1(b) on Personal Data Protection Regulation (PDPR) according which personal data may be processed by the Administrator in order to execute his legitimate interest, in this case obligations caused by executing PDPR. Personal data submission mentioned above is voluntary, however necessary for the purpose of exercising the rightsattached to PDPR.

Activities related to possible claims (e.g. establishing, investigating and protecting against them) – Indicated activities require processing following personal data: name, surname, email address, company name and NIP number (if the User uses Platform as an entrepreneur). Legal basis of processing personal data mentioned above is Article 6.1(b) on Personal Data Protection Regulation (PDPR) according which personal data may be processed in order to execute his legitimate interest, in this case establishing, investigating and protecting against possible claims which may appear as a result of performance of the contract. Personal data submission mentioned above is voluntary, however necessary for investigating and protecting against possible claims.

Analise of Users’ and Guest Users’ activity - to analyze activity we process the following personal data: date and time of visiting, device’s IP number, type of operating system, approximate location, type of browser used for browsing the Platform, visited subpages and action taken within the Platform. Legal basis of processing personal data mentioned above is Article 6.1(b) on Personal Data Protection Regulation (PDPR) according which personal data may be processed in order to execute his legitimate interest, in this case establishing, investigating and protecting against possible claims which may appear as a result of performance of the contract. Personal data submission mentioned above is voluntary, however necessary to gain information related to Users’ activity on the Platform.

Profiling

Some personal Users and Guest Users are asked to give during profiling. It concerns such data as name, surname, email address, residential address, company name and NIP number (if the User uses Platform as an entrepreneur) and information related to Users’ activity, such as: date, time of visiting the Platform, device’s IP number, type of device’s operating system, estimated location, type of the browser used for browsing the Platform, time spent on the Platform, visited subsites and activities taken within the Platform. Profiling data mentioned above is based on analyzing preferences and behaviors of Users and Guest Users on the Platform to create profiles of mentioned above Users for marketing purposes and to manage direct marketing (advertisements on social media e.g. Facebook) adjusted to their preferences.

Legal basis of processing personal data mentioned above is Article 6.1(b) on Personal Data Protection Regulation (PDPR) according which personal data may be processed in order to execute his legitimate interest, in this case our legitimate interest is conducting marketing and promotional efforts adjusted to our recipients. Personal data submission mentioned above is voluntary, however necessaryfor purposes mentioned above (failure to provide mentioned above data will affect that those purposes shall be impossible to fulfill). Described above activities will not affect any legal consequences or influence significantly on Users’ and Guest Users’ situation.

Planned storage periods for personal data

The storage period for personal data depends on the purpose and legal basis of processing those data. Below we indicate planned storage periods for personal data along with adequate data categories.

For the duration of the contract, we will store personal data processed in order to establish and conclude the contract;
within the period of 5 years we will store personal data processed in order to fulfill Administrator’s tax obligations;
until filing the effective opposition reaching goal of processing, personal data will be stored in order to: send a newsletter, analyzing of activity on the Platform, creating profiles for marketing purposes (profiling), managing direct marketing to Users and Guest Users (advertisements on social media e.g. Facebook);
until the expire of the deadlines of claims, we will be storing data processed in purpose fulfilling obligations related to personal data protection and in order to establishing, investigating and to defend against claims.

Personal data recipients

Personal data recipients will be external partiescollaborating with Renderro:

AWS/Amazon (computing cloud service provider);
Companies providing tools being used for analyzing activity on the Platform and managing direct marketing to the Platform Users and those who browse it (a.o. Goodle, Facebook, Hotjar, Linkedln);
MailChimp (Newsletter service provider);
Genprox limited liability company (company providing accounting services).

Besides, personal data may be further transmitted to public bodies or private parties, if such obligation arises from generally applicable law regulations.

Transferring personal data to third countries

With regard to using by Renderroweb Google Analytics, personal data may be transferred to the following thirdcountries:

The United States of America - under decision adopted on the basis of 2016/1250/EU under Directive 95/46/WE of the European Parliament and of the Council adequacy of the protection provided by the protection law of the EU USA.
Chile, Singapur and Tajwan (Republic of China) – on the basis of a contractual clauses providing adequate level of protection, which shall comply with standard contractual clauses set out in the Commission’s decision of 2 February 2010 on standard contractual clauses for the transfer of personal data to processors established in third countries under Directive 95/46/EC of the European Parliament and of the Council.

There’s a possibility of acquiring copies of personaldata transmitted to third country.

Entitlements

When itcomes to processing personal data by Renderro, Users are grantedthe following rights:

A right to be informed what type of personal data concerning the User will be processed by the Administrator and the right to receive copies of mentioned data (so-called a right of access). First copy of data is free, though User may be charged for next copies.
If processed data become outdated or incomplete(or otherwise incorrect) the User those data concerns has a right of its rectification.
A right of requiring of removal of the personal data, e.g. when they are no longer needed for Controller’s purposes Users were informed; when consent on processing personal data is validly withdrawn (unless Controller has no right to process the data on other legal basis); if the data’s unlawfully processed; or if the necessity of data removal is based on the obligation that Controller holds.
in case when personal data are being processed by the Administrator on the basis of the consent granted for processing, or in order to perform the contract concluded with him, the person who is the data subject has a right to transfer all the personal data to different Controller.
if the User who is the subject of data considers that processed personal data are inaccurate, processing is unlawful, or Controller doesn’t need certain data, the User mayrequest that for a specified, required time (for checking the accuracy of data or investigating claims) Administrator didn’t perform any operations on those data, he was only storing those data.
a right to object to processing personal data, which may be processed on the basis of Administrator’s legitimate interest. In case of raising effective objection, Controller will stop processing personal data in purposes mentioned above.
the right to lodge a complaint to the President of the Data Protection Officewhen a person, who is the data subject considers that processing personal data violates PDPR.

Cookies

Information regarding the usage of cookieson the Platform is here: https://storage.googleapis.com/renderro-mvp.appspot.com/legal/Cookies.pdf.

Final Provisions

Controllerhas a right to make changes in this Policy in the procedure described within given paragraphs, starting with §35.2 up to §35.5 of the Terms of Use.

In matters not regulated by this Policy, applicable provisions of personal data protection shall apply.This Policy is valid from 1 October 2020.

Side to side comparison of English and Polish version available here: https://storage.googleapis.com/renderro-mvp.appspot.com/legal/PL-ENG_PrivacyPolicy.pdf.