PRIVACY POLICY
VALID FROM 12/12/2021
1. This Privacy Policy contains information regarding processing by:
Sovo Spółka z ograniczoną odpowiedzialnością with its registered office in Rzeszów ul. Targowa 10, 35-064 Rzeszów, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court in Rzeszów, 12th Commercial Division of the National Court Register under KRS number: 0000903160 KRS, REGON: 389027492, NIP: 8133861225, with a share capital of PLN 5,000.00 0 zloty.
2. The Privacy Policy is made available in order to provide persons whose Personal Data are processed by the Administrator with the widest possible information about the scope of data being processed, the methods and principles of data processing and the rights of these persons. The basic legal regulation regarding the protection of Personal Data is Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016.
on the protection of natural persons with regard to the processing of personal data
and on the free movement of such data and repealing Directive 95/46/EC.
3. Each User using the Application accepts the provisions of the Policy and consents to the manner in which the Administrator collects, stores, uses and protects Personal Data.
I. GLOSSARY OF TERMS
1. The following expressions shall have the following meanings:
1) Administrator – this should be understood as Sovo Spółka z ograniczoną odpowiedzialnością with its registered office in Rzeszów, ul. Targowa 10, 35-064 Rzeszów, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court in Rzeszów, 12th Commercial Division of the National Court Register under KRS number: 0000903160 KRS, REGON: 389027492, NIP: 8133861225, with a share capital of PLN 5,000.00 0 zloty.
2) Application – this should be understood as a mobile application called Sovo for iOS and Android systems allowing the use of the Services provided by the Administrator.
3) Cookies – this should be understood as text files placed by the server on the device on which the Browser operates. Cookies are IT data, in particular text files, which are stored on the User’s end device
and are intended for the use of the Application.
4) Personal Data – this should be understood as any information about an identified or identifiable natural person, in particular based on an identifier such as name and surname, identification number, location data, online identifier or one or more specific factors determining the physical, physiological , genetic, mental, economic, cultural or social identity of a natural person.
5) Browser – this should be understood as an IT program used to display websites (e.g. Mozilla, Firefox, Google Chrome).
6) Third country – this should be understood as a country outside the European Economic Area.
7) Profiling – it should be understood as any form of automated processing of Personal Data, which consists in using Personal Data to evaluate certain personal factors of a natural person, in particular to analyze or forecast aspects regarding the effects of work of this natural person, his or her economic situation, health, personal preferences, interests, credibility, behavior, location or movements.
8) Privacy Policy (hereinafter also referred to as the “Policy”) – this should be understood as a document containing primarily information on the scope of data processing, methods and principles of data processing of Users using the Application and the rights of these persons.
9) Processing – it should be understood as any operation or set of operations performed on Personal Data or sets of Personal Data in an automated or non-automated manner, such as collecting, recording, organizing, structuring, storing, adapting or modifying, downloading, viewing, using, disclosing by transmitting, disseminating or otherwise making available, aligning or combining, restricting, deleting or destroying.
10) Application Regulations – this should be understood as the Application regulations available at https://sovo.pl/regulamin.
11) GDPR – this should be understood as Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/ IN.
2. Expressions not defined above and used in the content of the Privacy Policy have the meaning given to them in the Application Regulations.
II. SCOPE OF APPLICATION
This Privacy Policy describes the principles of processing Personal Data in connection with the use of the Application by Users, the provision of Services by the Administrator available to Users via the Application, or in order to establish contact and provide additional services.
III. TRANSFER OF PERSONAL DATA
The Administrator may obtain Personal Data directly from the Users themselves (i.e. Personal Data is provided by the User when using the Application, completing the forms available in the Application, as well as through any exchange of information with the Administrator by telephone, e-mail or in any other way, as well as when filing a complaint). If you use the solutions offered by Identity Providers, the Administrator may automatically obtain the User’s Personal Data from such external entities. The categories of data processed by the Administrator are specified in point V of this Policy.
IV. LEGAL BASIS, PURPOSES, TIME AND SCOPE OF PROCESSING OF PERSONAL DATA WITHIN THE APPLICATION
1. The User’s Personal Data may be processed for the following purposes and on the following legal bases:
| Purpose of processing |
Legal basis |
Processing time |
|
Taking steps to conclude the Agreement; concluding and exercising rights and obligations arising from the Agreement (including maintaining and running the Account; providing functionalities).
|
art. 6 section 1 letter b) GDPR and art. 6 section 1 letter f) GDPR (i.e. the Administrator’s legitimate interest in running a business).
|
Personal Data is processed for the time necessary to conclude and implement the Agreement. |
|
Sending push notifications in the Application containing, among others: reports on learning progress, plans made, time devoted to learning, completion date of learning in accordance with the established learning schedule. |
art. 6 section 1 letter b) GDPR (in connection with the implementation of functionalities available as part of the Account Service) in connection with voluntarily expressed consent to the communication channel. |
Personal Data are processed for the time necessary to perform the Agreement, but no longer than until the User withdraws consent. Push notifications are sent only after obtaining the User’s prior consent to this type of communication. Consent to receiving push notifications may be revoked at any time by changing the settings of the Mobile Device, browser or from the Application level. |
|
Determining, investigating or defending against possible claims related to the concluded Agreement. |
art. 6 section 1 letter f) GDPR (i.e. the Administrator’s legitimate interest in determining, investigating or defending against claims that may arise in connection with the provision of Services or the use of the Application). |
Personal Data will be processed until the limitation periods for claims that may arise in connection with the concluded Agreement expire.
|
|
Implementation of the complaint procedure or the right to withdraw from the Agreement. |
art. 6 section 1 letter b) and c) GDPR, among others in connection with joke. 8 section 3 point 4) Act on the provision of electronic services, art. 27 Consumer Rights Act. |
Personal Data will be processed for the time necessary to implement the complaint procedure and/or the right to withdraw from the Agreement.
|
|
Fulfillment of tax and accounting obligations (including in order to process a VAT invoice or other document based on which the Administrator makes settlements).
|
art. 6 section 1 letter c) GDPR, among others in connection with joke. 70 of the Tax Ordinance and Art. 74 of the Accounting Act.
|
Personal Data will be processed for the time necessary to fulfill the Administrator’s statutory obligations under the law. |
|
Fulfillment of obligations related to the protection of personal data (including creating registers of data processing activities and records resulting from the GDPR). |
art. 6 section 1 letter c) GDPR.
|
Personal Data will be processed for the time necessary to fulfill the Administrator’s statutory obligations.
|
|
Management and improvement of the Application. |
art. 6 section 1 letter f) GDPR (i.e. the Administrator’s legitimate interest in running a business) |
Personal Data are processed for the time necessary to implement the legitimate interest of the Administrator or until the User submits a justified objection. |
|
Analytical and statistical |
art. 6 section 1 letter f) GDPR (i.e. the legitimate interest of the Administrator consisting in particular in conducting analyzes of Users’ activity, as well as their preferences in order to improve the functionalities used and the Services provided, or to optimize the Application). |
Personal Data are processed for the time necessary to implement the legitimate interest of the Administrator or until the User submits a justified objection. |
|
Enabling the User to provide and exchange information with the Administrator (including for the purpose of concluding the Agreement and/or for the purpose of conducting electronic correspondence and telephone contact) and with other Application Users via Chat. |
art. 6 section 1 letter b) GDPR and/or Art. 6 section 1 letter f) GDPR (i.e. processing is necessary due to the legitimate interest of the Administrator, which is the intention to conclude the Agreement and conduct correspondence with the User, and in the case of correspondence between Users, also to ensure the security of the Services provided). |
The data provided for the purpose of concluding the Agreement is processed for the time necessary to conclude the Agreement; in the case of Personal Data processed on the basis of legitimate legal interest, until the Administrator’s legitimate interest exists or until the User submits a justified objection. |
|
Displaying contextual advertising (conducting direct marketing of the Administrator’s own services or goods or services or goods of third parties). |
Art. 6 section 1 letter f GDPR (i.e. processing is necessary due to the Administrator’s legitimate interest in promoting the products or services of the Administrator or third parties). |
Personal Data is processed until you stop using the Application or until you submit a justified objection by the user. |
|
Displaying behavioral advertising based on previously viewed content, customizing offer categories and content based on activity in the Application |
art. 6 section 1 letter f) GDPR in connection with joke. 173 of the Telecommunications Law (i.e. processing is necessary due to the legitimate interest of the Administrator, which is the promotion of products or services of the Administrator or third parties). |
Personal Data are processed until the consent is withdrawn (granted under the provisions of the Telecommunications Law) or until an effective objection to the processing of Personal Data is expressed. Withdrawal of consent does not affect the legality of previous processing. |
|
Contacting Users for purposes related to permitted marketing activities (including sending the Newsletter) via available electronic communication channels (via e-mail, SMS). |
art. 6 section 1 letter f) GDPR in connection with joke. 10 of the Act on the provision of electronic services or Art. 172 of the Telecommunications Law (i.e. processing is necessary due to the legitimate interest of the Administrator, which is the promotion of products or services of the Administrator or third parties in connection with the voluntarily expressed consent to the communication channel). |
Personal Data are processed until you withdraw your consent to receive communications or marketing information (pursuant to the provisions of the Act on the Provision of Services by Electronic Means or the Telecommunications Law) or until you express an effective objection to the processing of Personal Data.
Withdrawal of consent does not affect the legality of previous processing.
|
After the processing period, Personal Data is immediately deleted or anonymized.
V. DATA PROCESSED BY THE ADMIN
1. Data provided by the User for the purpose of registering an Account and implementing the Account Agreement: (1) User’s name; (2) email address; (3) password; (4) avatar (profile photo) – if shared. Providing the above data is voluntary, but necessary to conclude and implement the Account Management Agreement (except for the avatar, the uploading of which is not necessary to conclude the Account Management Agreement). If the services of Identity Providers are used, the data referred to in this point will be received by the Administrator based on the User’s consent from the Identity Provider used by the User to authenticate the data. When using external entities providing authorization services, the User is obliged to read the regulations and principles of personal data processing of entities offering such services.
After completing the Account registration process, a User with Consumer status may additionally provide the following data: (5) name and surname; (6) residential address; (7) date of birth; (8) education; (9) description; (10) biography. Indication of the data referred to in sentence the previous one is voluntary and is not required to use the Application. (Please verify the data processed in connection with registering and maintaining the Account; in particular, please verify the data provided by the entrepreneur and the consumer, as well as whether the entrepreneur could also complete the data; the scope should be identical to the regulations)
2. In the case of ordering a Subscription Service, the Administrator will process information: about the Subscription number (key) and transaction data (i.e. type of Subscription Service, date of ordering the Subscription Service, and information whether the payment was processed correctly). The data referred to in the first sentence will be obtained by the Administrator from the Store through which the Subscription Service was ordered and paid for. The data referred to in this point are necessary for the conclusion and implementation of the Subscription Agreement, including managing access to paid functionalities of the Application.
3. If the User subscribes to the Newsletter, the Administrator will process: (1) e-mail address; (2) name and surname or username of the User. Providing the above personal data is voluntary, but necessary in order to conclude and implement the Agreement for the provision of Newsletter services.
4. If you exercise the right to withdraw from the Agreement or initiate a complaint procedure, the data provided by the User will be processed, such as: (1) name and surname (or company), (2) e-mail address, (3) residential address (or registered office); (4) Personal Data included in the declaration of withdrawal, and in the case of a complaint, also other information that the Administrator may require from the User in the event of reporting problems regarding the use of the Application. In the case of entities other than natural persons: (5) name and surname of the person authorized to deal with matters related to the submitted complaint. Providing the above personal data is voluntary, but necessary to exercise the right to withdraw from the Agreement or implement the complaint procedure.
5. If the User uses communication channels with the Administrator (including via contact forms), the Administrator processes Personal Data necessary to communicate with the User, respond to the inquiry submitted by the User, or to fulfill the User’s request. This may be data such as: name, e-mail address, Personal Data contained in the content of the message.
6. When using the Chat functionality, the User’s name (nickname) that was set when using the messenger for the first time, as well as the record of the User’s correspondence within the Chat, will be processed. Providing the data referred to in this section is voluntary, but necessary to use the Chat.
7. Personal Data necessary to issue invoices/other settlement documents. The scope of Personal Data processed results from the provisions of tax law. After concluding the Agreement with the Administrator, the processing of these Personal Data by the Administrator is necessary in order for the Administrator to meet its tax obligations.
8. Personal Data necessary to perform the statutory obligations imposed on the Administrator in the scope of the GDPR (including the User’s name, surname). Providing the above personal data is necessary in order for the Administrator to properly perform the obligations arising from the provisions on the protection of personal data (including, among others, the implementation of the rights granted to the User by the GDPR.
9. In the event of exercising the right to withdraw from the Agreement and/or initiating the complaint procedure, the data provided by the User will be processed, such as: name, surname, e-mail address, Personal Data contained in the declaration of withdrawal, and in the case of a complaint, also other information that the Administrator may require from the User if necessary reporting problems regarding the use of the Application.
10. In the scope of marketing activities (based on the legitimate interest of the Administrator or the legitimate interest of entities cooperating with the Administrator or based on the User’s consent), information will be processed to help the Administrator match advertisements and content to the User’s preferences and expectations (including in connection with displaying behavioral advertising). For this purpose, the Administrator may process the following data: (1) information about the User’s IP address, (2) login data, (2) operating system, (3) advertising identifier, (3) information about the visit and its time, (4) ) data download errors, (5) interactions with other third-party sites. In addition, the Administrator may also process (6) the User’s contact details, to the extent indicated by the User (telephone number or e-mail address). Providing the above personal data is voluntary, but necessary to implement the above-mentioned. purpose. The consequence of not providing them will be the Administrator’s inability to conduct marketing activities tailored to the Users’ preferences.
11. For analytical and statistical purposes, as well as to adapt the content and functionality of the Application to a given User, information will be collected on the User’s activity in the Application, including information related to the use of individual services, as well as Personal Data regarding the User’s preferences and expectations. .
12. In accordance with applicable regulations and if required, after obtaining the User’s consent, the Administrator may develop any combination of information regarding the User, including his Personal Data and data obtained using analytical tools, which may also be sent to the Administrator’s business partners or may be obtained from them. The Administrator may use this information and combinations thereof for the purposes set out in this Policy.
13. Each time, the scope of required data is also indicated in the Application Regulations and before the commencement of the provision of a specific Service within the Application.
VI. RECIPIENTS OF PERSONAL DATA
1. The Administrator informs that in connection with the provision of the Services, Personal Data will or may be disclosed to external recipients:
1) the Administrator’s business partners;
2) the Administrator’s service providers, in particular (1) entities providing accounting services; (2) law firms; (3) entities providing IT services; and providing IT support and management; (4) advertising and marketing agencies; (4) suppliers of external technologies (including in particular suppliers of payment systems available in the Application; invoicing systems; external applications – messengers); (5) analytical tools providers;
3) persons cooperating with the Administrator within the Application, based on issued authorizations or concluded contracts for entrusting data processing;
4) state authorities, including the prosecutor’s office and the police (when required by law).
2. The Administrator informs that the transfer of Personal Data to external recipients will take place when:
1) it is necessary to use the services of an external entity;
2) it is necessary for the implementation of contracts concluded with external entities;
3) it is necessary for analytical and statistical purposes, including optimization of the Application;
4) it is necessary to conclude an Agreement between the Administrator and the User in the future;
5) it is necessary for the proper implementation of the Agreement;
6) it is necessary to establish contact and conduct correspondence with the User, in particular to present a commercial offer;
7) it results from the provisions of generally applicable law;
8) it is necessary to defend the claims or rights of the Administrator, including in connection with an ongoing lawsuit;
9) a circumstance has occurred that poses a threat to life, health, property or safety.
VII. DATA PROCESSING IN THIRD COUNTRIES
1. Taking into account the scope of the Administrator’s activities, Users’ Personal Data may be transferred outside the European Economic Area as part of the Administrator’s use of the services of entities providing IT solutions and systems (e.g. hosting services, analytical tools), which entities may store Personal Data on servers located outside this area or as part of the Administrator’s provision of services related to the business activity conducted – to the extent necessary to perform them.
2. The administrator carefully selects the entities with which I cooperate or whose services I use and always ensure adequate data protection. The entities with which the Administrator cooperates guarantee an adequate level of protection of Personal Data, which is required by European law.
3. Entities processing Personal Data applicable outside the European Economic Area are:
1) Google – providing services in the field of Google Cloud services;
2) International Business Machines Corporation (IBM Corp.) – providing the Administrator with network and server services;
3) Microsoft – providing the Administrator with network and server services;
4. The transfer of Personal Data takes place on the basis of appropriate mechanisms guaranteeing the security of data processing. In the case of data transfer outside the European Economic Area, the basis for such data transfer may be a decision of the European Commission stating the appropriate level of protection. In turn, in the event of transfer of Personal Data to a third country for which the European Commission has not issued a decision confirming the appropriate level of protection – the Administrator will apply appropriate legal safeguards, in particular the so-called standard contractual clauses for data protection (adopted by the European Commission or by a supervisory authority and approved by the European Commission in accordance with the examination procedure) and ensuring an appropriate level of security in accordance with applicable regulations. If the European Commission fails to issue a decision confirming the appropriate level of protection or the Administrator fails to provide appropriate legal safeguards, Personal Data may be transferred to a third country on the basis of one of the grounds listed in Art. 49 section 1 GDPR.
5. When transferring Personal Data to an entity located in a third country, the Administrator is obliged to register each case of export of Personal Data in the register of data processing activities.
VIII. AUTOMATED DECISION MAKING AND PROFILING
The Administrator may use Personal Data for automated decision-making, including profiling. Profiling of the User’s Personal Data (such as age, education) is carried out by the Administrator in order to individually adapt the study plan and schedule to the User. Profiling of the above-mentioned scope is necessary to fulfill the obligations arising from the concluded Agreement.
In addition, profiling may be conducted for marketing purposes and direct marketing to the User tailored to the User’s preferences. The legal basis for the processing of personal data for marketing purposes is Art. 6 section 1 letter f) GDPR. The Administrator will process Personal Data for the purpose of profiling until an effective objection is raised or the purpose of processing is achieved.
USER PERMISSIONS
1. Pursuant to the provisions of the GDPR, the User has the following rights related to the control of the processing of Personal Data:
1) the right to access the content of Personal Data (including obtaining information about what type of Personal Data are processed by the Administrator, including receiving a copy of your Personal Data);
2) the right to request correction, update or rectification of Personal Data;
3) the right to request the deletion of Personal Data if it is incomplete, outdated, false or was collected in violation of the law or is unnecessary to achieve the purpose for which it was collected;
4) the right to lodge a complaint with the supervisory authority responsible for the protection of Personal Data – i.e. the President of the Office for Personal Data Protection (e.g. if it is found that the processing of Personal Data violates the provisions of the GDPR or other provisions regarding the protection of Personal Data);
5) the right to request restriction of the processing of Personal Data;
6) the right to object to the processing of Personal Data if the processing is based on the legitimate interest of the Administrator or for direct marketing purposes.
If Personal Data is processed on the basis of consent, the User is entitled to:
1) the right to withdraw consent at any time;
2) the right to transfer Personal Data.
2. In order to exercise their rights, the User may contact the Administrator via the communication channels indicated in point. XIV: “Contact Details”.
COOKIES AND ANALYTICAL TOOLS
1. The Administrator uses cookies on the Application website.
2. The Administrator processes the data contained in Cookies when Users use the Application website for the following purposes:
1) improving the usability of the application;
2) statistics related to the use of the application:
3. The Administrator uses the following Cookies on the Application website:
1) Own cookies – files placed in the Application directly by the Administrator;
2) External cookies – files placed in the Application by entities other than the Administrator;
3) Session cookies – files placed and read from the User’s end device during one session of the User’s device. Cookies are stored until you turn off the browser (after the device session ends);
4) Cookies became e – files uploaded and read from the User’s end device. The files are not deleted automatically after the end of the device session, unless the configuration of the User’s end device is set to the mode of deleting cookies after the end of the device session. Files are stored for a defined period of time, which is determined by the parameter contained in the Cookie file. The user also has the option of manually deleting all or selected cookies;
5) Necessary cookies – cookies absolutely necessary for the proper functioning of the Application or tools that the User wants to use. Cookies are used to store and identify the User’s unique session identifier in order to manage the User’s session in the Application.
6) Functional cookies – Cookies enable remembering the settings selected by the User and personalizing the User’s interface (e.g. in terms of the selected language or region from which the User comes, font size, appearance of the Application, etc.). The User can disable or restore the option of collecting Cookies at any time by changing the settings in the Internet browser.
7) Analytical cookies – Cookies enable the Administrator to collect analytical data, such as information on the number of views and traffic in the Application, which allows the Administrator to evaluate and improve its functioning.
8) Social cookies – cookies of social media, such as Facebook, LinkedIn, whose plugins have been placed in the Application.
9) Advertising cookies – Cookies allow the delivery of advertising content tailored to the User’s interests.
4. The Application website also uses plug-ins of Google Analytics analytical tools. Google Analytics is a service that analyzes Internet services and activities. Google Analytics uses Cookies that enable analysis of the use of the Application and its improvement in accordance with User preferences. Details about this Google service are available by clicking the link: https://analytics.google.com/analytics/web/provision/?hl=pl#/provision
5. The User can check which specific Cookies are used by the Application’s website by clicking on the link: https://sovo.pll/polityka-cookie
6. If Cookies are not necessary for the proper operation of the Application website, the first time you start the Application website, a message about the use of Cookies is displayed, through which the User can consent to the Administrator placing the acceptance of optional Cookies, blocking Cookies or adjusting Cookies. . Moreover, the User can control and manage Cookies using the settings of the Mobile Device and by changing the browser settings.
7. Most browsers allow you to view, manage, delete and block cookies on a website. However, please remember that removing or disabling them may affect the operation of the Application website (e.g. it may be impossible to log in or use it).
8. Detailed information on Cookie settings and their independent removal in the most popular browsers should be available in the “help” or similar section. Below are links to the official websites of the manufacturers of the most frequently used Device Browsers, which provide information on the steps needed to change the settings of a given Browser in the scope described above:
9. Detailed information on Cookie settings and their independent removal in the most popular Internet browsers should be available in the “help” (or other similar) section of the Internet browser and on the following websites:
1) in Google Chrome browser:
http://support.google.com/chrome/bin/answer.py?hl=pl&answer=95647
2) in Mozilla Firefox browser:
http://support.mozilla.org/pl/kb/ciasteczka
3) in Internet Explorer:
https://support.microsoft.com/pl-pl/topic/usuwanie-plik%C3%B3w-cookie-i-zarz%C4%85dzanie-nimi-168dab11-0753-043d-7c16-ede5947fc64d
4) in the Opera browser:
http://help.opera.com/Windows/12.10/pl/cookies.html
5) in Safari browser:
https://support.apple.com/kb/PH5042?locale=en-GB
XI. SECURITY OF PERSONAL DATA
The Administrator ensures appropriate security measures to ensure that Personal Data is processed in a safe manner, ensuring, above all, that only authorized persons have access to the data and only to the extent
to the extent necessary for the tasks they perform. The Administrator takes all steps to ensure that entities cooperating with him guarantee the use of appropriate security measures whenever they process Personal Data on behalf of the Administrator. To secure Personal Data, the Administrator uses in particular: SSL certificate; automatic software updates; making data backups.
REDIRECTS
The application may contain redirects (links) to the websites of business partners. In the event of redirection, the User is obliged to read the regulations and privacy policy of the given business partner. As a result of such redirection, the Administrator does not process the User’s Personal Data, and the processing entity will be the administrator of the website to which the User was redirected, under the terms specified in his privacy policy.
NEWSLETTER
1. The e-mail address provided by the User is used to send the Newsletter. What is required here is the User’s confirmation, which consists in expressing voluntary consent to receive the Newsletter by the owner of the e-mail address.
2. The User may terminate the Newsletter Service Agreement at any time by deactivating the subscription. Deactivation of the Newsletter Service is possible by sending the User a declaration of will to info@sovo.pl or via the appropriate link located in the footer of each message sent as part of the Newsletter.
CONTACT DETAILS
In case of any questions, applications and requests regarding the User’s Personal Data or the desire to exercise a specific right, the User may contact the Administrator in writing to the following address: Targowa 10, Rzeszów, by e-mail to the following address:
info@sovo.pl or with the designated Personal Data Inspector by e-mail to the following address: info@sovo.pl.
CHANGES TO THE PRIVACY POLICY
The Administrator strives to ensure that this Policy is up-to-date and updated.
In the event of changes in legal provisions, court decisions, guidelines of bodies responsible for supervising Personal Data processing processes, introduction of codes of good practice (if the Administrator is bound by such codes), changes in technology, methods, purposes or legal basis for the processing of Personal Data, the Administrator will make appropriate changes this Policy, of which Users will be informed in the following manner at the first attempt to log in to the Application after changing this Policy.