Privacy Policy

The following Privacy Policy sets out the rules for saving and accessing data on Users' Devices using the Service for the purpose of providing services electronically by the Administrator and the rules for collecting and processing Users' personal data that have been provided by them personally and voluntarily through the tools available in the Service.

The following Privacy Policy is an integral part of the Service Terms and Conditions, which set out the rules, rights, and obligations of Users using the Service.

§1 Definitions

• Service - the "MyCFO" website operating at https://mycfo.pl

• External Service - websites of partners, service providers, or service recipients cooperating with the Administrator

• Service Administrator / Data Controller - The Service Administrator and Data Controller (hereinafter Administrator) is the company "MYCFO sp. z o.o.", conducting business at: ul. BOLESŁAWA KRZYWOUSTEGO 7/61-144 POZNAŃ WIELKOPOLSKIE, with tax identification number (NIP): 7851815533, with KRS number: 0001031829, providing services electronically through the Service

• User - a natural person for whom the Administrator provides services electronically through the Service.

• Device - an electronic device together with software through which the User accesses the Service

• Cookies - text data collected in the form of files placed on the User's Device

• GDPR - 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 (General Data Protection Regulation)

• Personal data - means information about an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person

• Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

• Restriction of processing - means the marking of stored personal data with the aim of limiting their processing in the future

• Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements

• Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her

• Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed

• Pseudonymization - means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person

• Anonymization - Data anonymization is an irreversible process of operations on data that destroys / overwrites "personal data" making it impossible to identify or link a given record with a specific user or natural person.

§2 Data Protection Officer

Pursuant to Art. 37 GDPR, the Administrator has not appointed a Data Protection Officer.

For matters concerning the processing of data, including personal data, please contact the Administrator directly.

§3 Types of Cookie Files

• Internal Cookies - files placed and read from the User's Device by the Service's IT system

• External Cookies - files placed and read from the User's Device by IT systems of External Services. Scripts of External Services that may place Cookie files on Users' Devices have been deliberately placed in the Service through scripts and services made available and installed in the Service

• Session Cookies - files placed and read from the User's Device by the Service or External Services during one session of a given Device. After the session ends, the files are deleted from the User's Device.

• Persistent Cookies - files placed and read from the User's Device by the Service or External Services until they are manually deleted. The files are not automatically deleted after the Device session ends unless the User's Device configuration is set to delete Cookie files after the Device session ends.

§4 Data Storage Security

• Mechanisms for storing and reading Cookie files - The mechanisms for storing, reading, and exchanging data between Cookie files saved on the User's Device and the Service are implemented through built-in mechanisms of web browsers and do not allow the retrieval of other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. The transfer of viruses, Trojans, and other malware to the User's Device is also practically impossible.

• Internal Cookies - Cookie files used by the Administrator are safe for Users' Devices and do not contain scripts, content, or information that could threaten the security of personal data or the security of the Device from which the User is using the Service.

• External Cookies - The Administrator takes all possible measures to verify and select service partners in the context of User security. The Administrator selects well-known, large partners with global social trust for cooperation. However, it does not have full control over the content of Cookie files originating from external partners. The Administrator is not responsible for the security of Cookie files, their content, and use in accordance with the license by Scripts installed in the service, originating from External Services, to the extent permitted by law. The list of partners is included later in the Privacy Policy.

• Cookie File Control

  • The User may at any time independently change the settings for saving, deleting, and accessing data stored in Cookie files by each website

  • Information on how to disable Cookie files in the most popular computer browsers is available at: how to disable cookies or from one of the indicated providers:

    • Managing cookies in the Chrome browser
    • Managing cookies in the Opera browser
    • Managing cookies in the Firefox browser
    • Managing cookies in the Edge browser
    • Managing cookies in the Safari browser
    • Managing cookies in the Internet Explorer 11 browser

  • The User may at any time delete all Cookie files saved so far using the tools of the User's Device through which the User uses the Service.

• Threats on the User's side - The Administrator applies all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User's activities. The Administrator is not responsible for the interception of this data, impersonation of the User's session, or their deletion as a result of the User's conscious or unconscious activity, viruses, Trojans, and other spyware with which the User's Device is or was infected. Users should follow internet usage rules to protect themselves against these threats.

• Storage of personal data - The Administrator ensures that it makes every effort to ensure that processed personal data voluntarily entered by Users is secure, access to it is restricted and carried out in accordance with its purpose and processing objectives. The Administrator also ensures that it makes every effort to secure the data it holds against loss by applying appropriate physical and organizational safeguards.

§5 Purposes for Which Cookie Files Are Used

• Improving and facilitating access to the Service
• Personalization of the Service for Users
• Marketing, Remarketing in external services
• Conducting statistics (users, number of visits, types of devices, connection, etc.)
• Serving multimedia services

§6 Purposes of Personal Data Processing

Personal data voluntarily provided by Users is processed for one of the following purposes:

• Provision of electronic services:
  • Services for sharing information about content posted in the Service on social networks or other websites.
• Communication between the Administrator and Users regarding matters related to the Service and data protection
• Ensuring the Administrator's legitimate interest

Data about Users collected anonymously and automatically is processed for one of the following purposes:

• Conducting statistics
• Remarketing
• Ensuring the Administrator's legitimate interest

§7 Cookie Files of External Services

The Administrator uses javascript scripts and web components of partners in the Service, who may place their own cookie files on the User's Device. Please note that in your browser settings you can decide which cookie files may be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookie files:

• Multimedia services:
  • YouTube
  • SoundCloud
  • Spotify
• Conducting statistics:
  • Google Analytics
  • HubSpot
  • WordPress Stats (Automattic Inc.)
• Other services:
  • Google Maps

Services provided by third parties are beyond the Administrator's control. These entities may change their terms of service, privacy policies, data processing purposes, and methods of using cookie files at any time.

§8 Types of Data Collected

The Service collects data about Users. Some data is collected automatically and anonymously, and some data is personal data provided voluntarily by Users during registration for individual services offered by the Service.

Anonymous data collected automatically:

• IP address
• Browser type
• Screen resolution
• Approximate location
• Opened subpages of the service
• Time spent on the respective subpage of the service
• Operating system type
• Previous subpage address
• Referring page address
• Browser language
• Internet connection speed
• Internet service provider

Data collected during registration:

• First name / last name / pseudonym
• Login
• Email address
• Phone number
• IP address (collected automatically)

Data collected during Newsletter subscription

• Email address

Some data (without identifying data) may be stored in cookie files. Some data (without identifying data) may be transferred to the statistics service provider.

§9 Access to Personal Data by Third Parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided is not transferred or sold to third parties.

Access to data (most often based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to operate the service, i.e.:

§10 Method of Processing Personal Data

Personal data voluntarily provided by Users:

• Personal data will not be transferred outside the European Union unless it has been published as a result of an individual User's action (e.g., entering a comment or post), which will make the data available to anyone visiting the service.
• Personal data will not be used for automated decision-making (profiling).
• Personal data will not be sold to third parties.

Anonymous data (without personal data) collected automatically:

• Anonymous data (without personal data) will be transferred outside the European Union.
• Anonymous data (without personal data) will not be used for automated decision-making (profiling).
• Anonymous data (without personal data) will not be sold to third parties.

§11 Legal Basis for Processing Personal Data

The Service collects and processes Users' data on the basis of:

• 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 (General Data Protection Regulation)
  • Art. 6(1)(a)
    the data subject has given consent to the processing of his or her personal data for one or more specific purposes
  • Art. 6(1)(b)
    processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
  • Art. 6(1)(f)
    processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
• Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018 item 1000)
• Act of 16 July 2004 - Telecommunications Law (Journal of Laws 2004 No. 171 item 1800)
• Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No. 24 item 83)

§12 Period of Personal Data Processing

Personal data voluntarily provided by Users:

As a rule, the indicated personal data is stored only for the period of providing the Service within the Service by the Administrator. It is deleted or anonymized within 30 days from the end of the provision of services (e.g., deletion of a registered user account, unsubscription from the Newsletter list, etc.)

An exception is a situation that requires securing the legally justified purposes of further processing of this data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User's request for their deletion, for no longer than 3 years in the case of violation or suspected violation of the service terms and conditions by the User

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, not constituting personal data, is stored by the Administrator for the purpose of conducting service statistics for an indefinite period

§13 Users' Rights Related to the Processing of Personal Data

The Service collects and processes Users' data on the basis of:

• Right of access to personal data
  Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator

• Right to rectification of personal data
  Users have the right to request that the Administrator immediately rectify personal data that is inaccurate or / and supplement incomplete personal data, exercised upon request submitted to the Administrator

• Right to erasure of personal data
  Users have the right to request that the Administrator immediately erase personal data, exercised upon request submitted to the Administrator. In the case of user accounts, data deletion consists of anonymizing data enabling User identification. The Administrator reserves the right to suspend the implementation of the data deletion request in order to protect the Administrator's legitimate interest (e.g., when the User has violated the Terms and Conditions or data was obtained as a result of correspondence).
  In the case of the Newsletter service, the User has the ability to independently delete their personal data using the link included in each email message sent.

• Right to restriction of processing of personal data
  Users have the right to restrict the processing of personal data in cases specified in Art. 18 GDPR, including questioning the accuracy of personal data, exercised upon request submitted to the Administrator

• Right to data portability
  Users have the right to obtain from the Administrator personal data concerning the User in a structured, commonly used, machine-readable format, exercised upon request submitted to the Administrator

• Right to object to the processing of personal data
  Users have the right to object to the processing of their personal data in cases specified in Art. 21 GDPR, exercised upon request submitted to the Administrator

• Right to lodge a complaint
  Users have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data.

§14 Contact with the Administrator

The Administrator can be contacted in one of the following ways

• Postal address - MYCFO sp. z o.o., ul. BOLESŁAWA KRZYWOUSTEGO 7/61-144 POZNAŃ WIELKOPOLSKIE

• Email address - kontakt@mycfo.pl

• Telephone connection - +48 660 781 567

• Contact form - available at: mycfo.pl/kontakt

§15 Service Requirements

• Restricting the saving and access to Cookie files on the User's Device may cause some functions of the Service to malfunction.

• The Administrator is not responsible for malfunctioning Service functions in the event that the User restricts in any way the ability to save and read Cookie files.

§16 External Links

The Service - articles, posts, entries, or User comments may contain links to external websites with which the Service Owner does not cooperate. These links and the pages or files indicated by them may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for content located outside the Service.

§17 Changes to the Privacy Policy

• The Administrator reserves the right to make any changes to this Privacy Policy without the need to inform Users about it with regard to the use and utilization of anonymous data or the use of Cookie files.

• The Administrator reserves the right to make any changes to this Privacy Policy with regard to the processing of Personal Data, which will be communicated to Users with user accounts or subscribed to the newsletter service via email within 7 days of the change in provisions. Continued use of the services means familiarization with and acceptance of the introduced changes to the Privacy Policy. In the event that the User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.

• Changes introduced to the Privacy Policy will be published on this subpage of the Service.

• Changes introduced take effect upon their publication.