Privacy Policy 7bulls.com

The Privacy Policy is informative and fulfills the information obligations imposed on the data controller by RODO, i.e. Regulation 2016/679 of April 27, 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 (General Data Protection Regulation).Anyone who uses the website at www.aleet.co and the 7bulls application should read the Privacy Policy. The Privacy Policy sets forth the rules for the processing of personal data of persons using the aforementioned website or 7bulls application and the use of cookies and other tracking technologies used in connection with the operation of the website.

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1. Administrator of personal data

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The controller of personal data is 7bulls sp. z o.o. with its registered office in Warsaw, 00-609, al. Armii Ludowej 26, entered in the Register of Entrepreneurs of the National Court Register under KRS number: 0000139981, NIP: 521-32-18-694, hereinafter referred to as 7bulls.
Any data subject may contact 7bulls, which is the controller of his/her personal data, by sending a message to the e-mail address: gdpr@aleet.co or by letter sent to the address indicated in paragraph 1.1. above.

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2. Method of data processing

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The purpose and scope of processing of personal data is determined by the scope of consents and data provided by the data subject in an e-mail message, contact form or otherwise. The processing of personal data that 7bulls processes may concern, in particular: first and last name, electronic mail (e-mail) address, telephone number, computer IP address, as well as other data voluntarily provided.
The scope, purposes and legal grounds for processing personal data are presented in the table below*.
7bulls does not process personal data within this website for the purpose of automated decision-making, including profiling.
In order to fulfill some of the processing purposes indicated in the table above, 7bulls may transfer personal data to third countries. In this case, this will always be done on the basis of standard contractual clauses in accordance with the European Commission’s decision, in which both 7bulls and its contractors undertake to ensure an adequate degree of security for the personal data transferred. Before signing the standard contractual clauses, 7bulls verifies each of its contractors that will have access to personal data, as well as assesses whether the country receiving the personal data allows for the enforcement of rights and provides data subjects with effective legal remedies.
If the European Commission issues a decision on whether a third country provides an adequate level of protection for personal data, then transfers of personal data to that country may also proceed on the basis of that decision.
If it is not possible to apply the standard contractual clauses and there is no decision of the European Commission, then the transfer of personal data will only take place in specific situations, by which is meant the need to perform a contract that has been concluded between the data subject and 7bulls, or the implementation of pre-contractual measures. Also in this situation, 7bulls shall thoroughly vet each of its contractors who will have access to the data subject’s personal data to ensure maximum security.
In any case of transfer of personal data to a third country, the data subject is entitled to obtain a copy of the data.

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3. Data recipients

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7bulls may entrust the processing of personal data to third parties to perform certain activities. Then the recipients of individual data may be: a hosting provider for 7bulls, an email service provider, an IT company, a software provider, an email service provider, a law firm, an accounting firm, entities providing cloud solutions, and other solutions used by 7bulls in its day-to-day operations that involve the processing of personal data.
Personal data collected by 7bulls may also be made available: to relevant state authorities upon their request under relevant laws, or to other persons and entities – in cases provided by law.
Each entity to which 7bulls entrusts personal data for processing, based on the entrustment agreement for the processing of personal data (hereinafter “Entrustment Agreement”) guarantees an adequate level in terms of security and confidentiality of personal data processing. An entity that processes personal data of data subjects based on the Entrustment Agreement may process personal data of such data subjects, through another entity, only on the basis of 7bulls’s prior consent.
Sharing of personal data with unauthorized entities according to this Privacy Policy, may only take place with the prior consent of the data subject.

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4. Rights of data subjects

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Every data subject has the right to: (a) to have the personal data collected about him/her erased both from the system belonging to 7bulls and from the databases of entities with which 7bulls cooperates or has cooperated, (b) to have the processing restricted, (c) to have the personal data collected by 7bulls transferred, including to receive it in a structured form, (d) to request from 7bulls access to his/her personal data and to have it rectified, (e) to object to the processing, (f) to revoke 7bulls’s consent at any time without affecting the legality of the processing performed on the basis of consent before its revocation; (g) lodge a complaint against 7bulls to the supervisory authority (President of the Office for Personal Data Protection).
The exercise of the rights of data subjects may be carried out in particular through the communication channels referred to in paragraph 1.2. of this Privacy Policy.

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5. Other data

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7bulls may store http requests, and therefore some information may be stored in the server log files, including the IP address of the computer from which the request came, the station name of the data subject – identification carried out by the http protocol, if possible, the date and system time of registration on the 7bulls site and arrival of the request, the number of bytes sent by the server, the URL of the site previously visited by the data subject if he/she entered the 7bulls site using a link, information about the browser, information about errors that occurred during the execution of the http transaction. Logs may be collected as material for the proper administration of 7bulls. Only persons authorized to administer the computer system have access to the information. Log files may be analyzed to compile statistics of traffic on the 7bulls website and errors that occur. A summary of such information does not identify an individual.
7bulls may use Google Analytics and other analytical tools, whereby it has access to anonymized information about Users, including: information about the operating system and web browser, time spent on the website age range, gender, approximate location, interests, based on its activity on the Internet. The information referred to in the preceding sentence is not combined with personal data and does not allow for its identification and is not personal data within the meaning of the provisions of the RODO.

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6. Security

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7bulls cares about the security of personal data. In particular, 7bulls uses technical and organizational measures to ensure the protection of the processed personal data appropriate to the risks and categories of protected data, including technical and organizational protection of data against their access to unauthorized persons, taking by an unauthorized person, processing in violation of the Act, and change, loss, damage or destruction, among others, SSL certificates are used. The collection of collected personal data is stored on a secure server, and data is also protected by 7bulls’s internal procedures on personal data processing and information security policy.
7bulls has also implemented appropriate technical and organizational measures, such as pseudonymization, designed to effectively implement data protection principles, such as data minimization, and to give the processing the necessary safeguards to meet the requirements of the RODO and protect the rights of data subjects.
Notwithstanding the above, 7bulls points out that the use of the Internet and electronically provided services may be at risk of malicious software (malware) entering the ICT system and device of the user in question, as well as unauthorized access to data, including personal data, by third parties. In order to minimize these risks, the data subject should use appropriate technical safeguards, e.g. using up-to-date anti-virus software or protecting his/her identification on the Internet. In order to obtain detailed and professional information regarding the preservation of security on the Internet, 7bulls recommends seeking it from entities specializing in such IT services.

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7. Cookies

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In order for the website to function properly, 7bulls uses cookie technology. Cookies are text information stored on a given user’s device (computer, tablet, smartphone), via 7bulls, usually containing information consistent with the purpose of the file, by means of which a given user uses the 7bulls website – these are usually: service address, date of posting, expiration date, unique number and additional information consistent with the purpose of the file.
7bulls uses two types of cookies: (a) session cookies, which are deleted permanently when the browser session ends; (b) persistent cookies, which remain after the browser session ends until they are deleted.
Based on Cookies, both session and permanent, it is not possible to determine the identity of a given user. The Cookies mechanism does not allow the collection of any personal data.
7bulls Cookies are safe for the device of a given user, in particular, they do not allow viruses or other software to enter the device.
Cookies generated directly by 7bulls cannot be read by other services. External Cookies (i.e. Cookies placed by entities cooperating with 7bulls) can be read by an external server.
A given user may change his/her own settings regarding Cookies at any time, specifying the conditions for their storage, through the settings of the Internet browser or through the configuration of the service.
First of all, the given user may disable the storage of Cookies on his/her device, according to the instructions of the browser manufacturer, but this may result in the unavailability of some or all of the functions of the 7bulls website.
The given user may also delete the Cookies stored on his/her device at any time on his/her own, according to the instructions of the browser manufacturer.
7bulls uses its own Cookies for the following purposes: to configure the website and adapt the content of the pages to the preferences or behavior of the respective user; to analyze and study the audience, the number of clicks and the path through the website in order to improve the design and organization of the content on the website, the time spent on the website, the number and frequency of visitors to the 7bulls website.
7bulls uses external Cookies to create anonymous statistics to optimize the website, through analytical tools in the form of Google Analytics, referred to in paragraph 5.2. above.
Detailed information on the handling of Cookies is available in the settings of the Internet browser used by the data subject.

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8. Final provisions

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This Privacy Policy is effective as of 01.09.2023.

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*Table

Purpose of processing

Range of data

Legal basis

Data processing time

providing access to the website

IP address

Article 6(1)(b) of the RODO – processing is necessary for the performance of a contract to which the data subject is a party, or to take action at the request of the data subject prior to entering into a contract

Until the expiration of the statute of limitations for claims related to access to the website

conducting correspondence in the form of electronic messages

e-mail address, first name, last name, organization name, other personal data voluntarily provided by the data subject

Until the correspondence is terminated or the data subject objects

telephone contact With data subjects; conducting telephone calls

telephone number, other personal data voluntarily provided by the data subject

Article 6(1)(f) of the RODO – the legitimate interest of the controller in handling inquiries and correspondence addressed directly by data subjects

Until such time as the discussions are concluded or the data subject objects

undertaking marketing activities

email address

Article 6(1)(f) RODO – the administrator’s legitimate interest in providing information about its activities

Until the data is no longer useful or the data subject objects

website traffic survey

IP address, cookies like: _utma, _utmb, _utmc, _utmz , PHPSESSID

Article 6(1)(a) of the RODO – consent of the data subject

Until the data is no longer useful or the data subject withdraws consent

Newsletter mailing

email address

Article 6(1)(b) RODO – performance of a contract or taking action at the request of the data subject prior to entering into a contract

Until the data is no longer useful or the contract the subject of which is the sending of the Newsletter is terminated

protection from claims, referral of claims

e-mail address, first name, last name, other data voluntarily provided by the data subject

Article 6(1)(f) of the RODO – legitimate interest of the administrator to protect against claims and to direct claims

until the expiration of the statute of limitations for claims related to access to the website and users’ activities on the website, calculated from the last time the user in question visited the website

conclusion of the agreement with 7bulls

name, surname, address, e-mail address, billing information, tax ID number

to the expiration of the statute of limitations for claims related to access to the 7bulls application

providing access to the 7bulls application

Article 6(1)(b) RODO – processing is necessary for the performance of the contract

to the expiration of the statute of limitations for claims related to access to the 7bulls application