Privacy Policy

Effective date: January 11, 2022

This privacy policy describes the rules for the collection and use of personal data by Łukasz Łażewski Informatics SKA, with registered seat in Warsaw, at Jana Kazimierza 12/217 street, NIP: 5272985142, entered into the Central Register and Information on Economic Activity, hereinafter referred to as “LLI”, being the data administrator, and the rights of persons they relate to.

In this privacy policy, “personal data” means any information about a natural person who can be directly or indirectly identified, in particular on the basis of an identifier such as name and surname, identification number, location data or internet identifier. Personal data also relates to one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person. This policy also covers special categories of personal data (data belonging to specific categories) from which we can determine or infer:

  • Racial or ethnic origin.
  • Political views.
  • Religious or philosophical beliefs.
  • Membership in trade unions.
  • Genetic data.
  • Biometric data.
  • Data on physical or mental health.
  • Sexual life or sexual orientation.

as well as personal data on committed crimes and offenses.

LLI processes personal data for the various purposes described in this privacy policy. We collect personal data directly, including from clients who commission us to provide services, from llinformatics.com website visitors (our website), our subcontractors and service providers, from those applying for a job at LLI, as well as those who send us their application using the “contact” tab on the LLI website. In addition, we process personal data in the context of providing professional services to the employer or service provider of the data subject. We also obtain personal data from publicly available sources. By definition, this privacy policy covers all of the scenarios listed above. LLI may, inter alia, process personal data for the following purposes:

  • conclusion, performance and continuation of contracts for the provision of services offered by the administrator.
  • fulfillment of legal obligations incumbent on the administrator (in particular: related to employment, issuing and storing invoices/sales documents and other accounting documents, considering complaints).
  • determination, defense and pursuing claims.
  • direct marketing.
  • production based on an original script and subsequent publication (in particular on messengers and social networking sites such as Slack, Instagram, LinkedIn, Facebook, Twitter) of audio and/or video materials, including podcasts.
  • compilation of analyses and statistics.
  • verification of payment credibility.
  • service support.
  • broadly understood commercial cooperation, based on Article 6 Section 1 letters a, b, c, d, e, f or Article 9 Section 1 and section 2 letter a, b, c, d, h, I, j – General Regulation on the Protection of Personal Data of April 27, 2016.

At the initial stage, LLI may process selected contact details, resulting, for example, from the data provided in the completed contact form, in particular, such as name, surname, e-mail, telephone number, position, company name. After the possible start of cooperation with LLI, it may also process additional data voluntarily sent by you. 

Examples of rights available to data subjects are listed below

  • The right to access your personal data held by LLI.
  • The right to have your personal data corrected, for example if it is incomplete or incorrect.
  • The right to opt out of receiving marketing communications at any time.
  • The right to limit the processing or object to the processing of personal data or request the deletion of personal data (in certain circumstances and in accordance with applicable regulations).
  • The right to receive a copy of the personal data provided to LLI in a structured, commonly used and machine-readable format (also referred to as the right to data portability) (under certain circumstances and in accordance with applicable laws).
  • In the case of voluntary data transfer or consent to their use – the right to withdraw the consent granted.
  • The right to lodge a complaint with the data protection supervisory authority that is President of the Personal Data Protection Office, Stawki 2 street, 00-193 Warsaw.

If you have any questions about data processing, please contact LLI’s data protection team, who will send your inquiry to the appropriate person or team within our organization. If you have any questions or believe that our privacy statement does not cover important issues for you, please contact us by e-mail at contact@llinformatics.com.

Privacy – Detailed Provisions

Website and Social Media

Personal information we collect falls into several different categories.

Information provided voluntarily

We collect personal data provided voluntarily via our website, including in case of the visitor fills in the online form to contact us, subscribes to our newsletter, takes part in surveys or registers for events organized by us. Information collected includes:

  • name, surname and position.
  • job title.
  • name of the company or organization.
  • company’s data.
  • contact details, including email address and phone numbers.
  • demographic information such as postal code, preferences and interests.
  • other information for the purposes of customer surveys or similar surveys.
  • information about registered using forms related to events.
  • information affecting the provision of our services to you.
  • any other personal information that you choose to voluntarily provide to us.

We do not intentionally collect data from sensitive categories, unless you provide us with such data. Although the website may contain free text fields where you can enter any information, we do not intend to process any sensitive information. The user is not obliged to provide and should not disclose sensitive personal data in free text fields. If you choose to provide any sensitive personal information in this way, you confirm your consent to the collection and processing of this sensitive information.

If you register on our website, your personal data will be stored in our CRM system. Data of registered users are deleted in the absence of active cooperation with LLI for a period of 36 months or earlier in cases provided for by law. If you opt out of receiving LLI publications, our unsubscribe list will still contain your basic contact details.

Information Collected Automatically

When you visit our website, we automatically collect certain personal data from the visitor’s device. Automatically collected data includes, in particular, information such as IP address, device type, unique device identification number, browser type, general geographic location (e.g. country or city) and other technical information. We also collect information about the communication between the visitor’s device and our website, including but not limited to go to the website and click on the links. This enables us to get to know our website visitors better, their place of origin and the content on our website that arouses their interest. We use this information for internal analysis and to improve the quality of our website and the relevance of its content to visitors. Information will be collected using cookies and similar tracking technologies as set out in the LLI’s Cookie Policy.

Our website uses Google Analytics (“Google”) to compile reports, visualization and data analysis. Google processes the following types of personal data: the user’s IP address (to complete geosegmentation reports and to identify internal and external users using our website) and user IDs, e-mail addresses, names and passwords to the extent provided directly by website visitors. Your personal data will be processed by Google for the following purposes: (i) to record metrics about user traffic on our website (e.g. pages viewed and links clicked); (ii) to analyze information about website traffic; (iii) to enable Google to make informed decisions about our website; and (iv) to authenticate users and allow them to access our site

Purposes of processing personal data of visitors to our website
  • Administration and management of our website, including confirmation and authentication of the identity of visitors and prevention of unauthorized access to restricted sections of our website.
  • Personalizing and enriching the visitor’s experience while browsing our website by displaying content that is more likely to arouse interest among visitors and that visitors may find relevant.
  • Data analysis of visitors to our website.
  • Analysis of data on the movement of people on the website.
  • Determining in which company, organization, institution or agency the visitor works or with which the visitor is associated other than through employment.
  • Development of our business and service.
  • Provision of marketing communication.
  • Conducting benchmarking and data analysis (including the use of our website and demographic analyzes of visitors to our website).
  • Obtaining information on the use by visitors of the functions available on our website.
  • Monitoring and enforcement of compliance with the applicable website terms and conditions.
  • Conducting quality and risk management reviews.
  • Enabling better management of LLI events.
  • Enabling event management teams to more effectively coordinate email campaigns and event notifications.
  • Enabling you to sign up for an event and a webinar.
  • Allow content to be downloaded.
  • Any other purposes for which visitors have provided LLI information.

Our website also uses various plugins for social networks.

Social Media plugins

On our website, we use the so-called social media plugins. When a user accesses a page with one or more such buttons, his browser establishes a direct connection to the server of the social network and downloads the direct button from that server. At the same time, the social media provider will know that the user has visited the corresponding page on our website. We have no influence on the data collected by the social media providers using these buttons. If you want to prevent collecting this information, please log out of your social media account before visiting our website. In addition, social media providers set cookies, unless the user blocks the acceptance and storage of cookies in the settings of your browser.

Twitter plug

Our website has built-in functions provided by Twitter. When a user uses Twitter and the “retweet” feature, the pages they visit are linked to their Twitter account and disclosed to other users. If the user is not logged in to his Twitter account, after clicking the Twitter button, the Twitter login page will be displayed to enter his login and password. In this way, his data will also be transferred to the Twitter provider. We would like to point out that we do not know the content of the transmitted data and we do not know how it is used by the Twitter provider. For more information, see Twitter’s privacy policy.

Instagram plug

Our website has built-in functions offered by Instagram.

If you are logged into your Instagram account, you can click the Instagram button to link the content on our website to your Instagram profile. This means that Instagram makes it possible to relate visits to our pages with your user account. If the user is not logged in to his Instagram account, after clicking the Instagram button, the Instagram login page will be displayed to enter the login and password. We would like to expressly point out that we do not receive information about the content of the transmitted data or its use by the provider of Instagram.

For more information, see Instagram’s privacy policy.

LinkedIn Lead Gen Forms

LLI uses LinkedIn Lead Gen Forms to promote Sponsored Content and Sponsored LinkedIn InMails for recruitment and marketing campaigns. After clicking on the LLI ad, LinkedIn users will see a form in which there will already be data from the user’s profile on LinkedIn, such as name and surname, contact details, company name, seniority, position and city. After submitting the form, the LinkedIn user will connect to LLI. For more information, see LinkedIn’s privacy policy.

LEGAL BASIS for the processing of personal data of our websites’ visitors, including in social media, and the use of social media plugins and tools:
  • Pursuing the legitimate interest of promoting LLI’s services and brand.
  • Pursuing the legitimate interest of attracting, identifying and recruiting highly qualified employees.
  • Pursuing a legitimate interest in improving the experience of our website’s visitors and optimizing our services .
  • Pursuing a legitimate interest in the effective provision of information and services and the conduct of our business in an effective and lawful manner.
  • Our legitimate interest in developing and improving our website and your user experience.
  • Express consent of the visitor.

Data obtained by providing services

When you engage in professional services, we collect and use personal information when we have legitimate business reasons to do so in connection with the services. In the context of providing professional services to clients, LLI also processes personal data of persons who are not directly our clients (e.g. employees, clients or suppliers of our clients). Most of the personal data that we collect and use to provide our services is data that our clients provide to us voluntarily (or that we collect from external sources at the request of our clients).

For this reason, if you are a customer of LLI, it will generally be clear to you what kind of personal data we collect and use. This information may include:

  • Basic information such as your name and surname, company name, job title and relationship with the person.
  • Contact details such as postal address, e-mail address, and telephone numbers.
  • Financial information, such as payment information.
  • Any other personal data relating to you or third parties that you provide to us in order to receive our services.

We also process special category data for some services. For example, in some countries, the performance of services involves processing details of payments made by our customer, their spouse and their dependents in relation to trade union membership, political party, medical treatment or charity. These data are collected intentionally and will be used only if it is necessary in connection with the provision of the service for which the data was collected.

Most of the personal data we collect and use to provide our services is delivered voluntarily by our customers (or collected by us from external sources upon their request). Accordingly, if you are a customer of LLI it will usually be obvious to you what personal data we collect and use. This information may include:

  • Basic information such as your name and surname, company name, job title and relationship with the person.
  • Contact details such as postal address, e-mail address, and telephone numbers.
  • Financial information, such as payment information.
  • Any other personal data relating to you or third parties that you provide to us in order to receive our services.

We use this information:

  • To provide services to our clients.
  • To manage our relationship and maintain contractual relationships.
  • For accounting and tax purposes.
  • For marketing and business development purposes.
  • To meet our legal and regulatory obligations.
  • To establish, perform and assert legal rights.
  • For documentation and statistical purposes.

Due to the wide variety of services we provide, we process many categories of personal data.

We process personal data of persons listed in our database of contacts (former, current and potential clients and persons employed by or cooperating with such clients and other persons in the database of business contacts, which include alumni, consultants, regulatory authorities and journalists) in our CRM systems . CRM systems support the implementation of marketing operations at LLI. Opinion-making LLI materials, newsletters, marketing materials, information about training courses, surveys and invitations to participate in events can be sent to people from the contact database in our CRM systems.

In our CRM systems, we process the following categories of personal data:

  • Name and surname, position, address, e-mail address, telephone and fax numbers.
  • Name of the employer or organization with which the data subject cooperates.
  • Marketing preferences.
  • Responses to invitations and confirmations of participation in the event.

We do not intentionally collect sensitive data, unless the data subject provides us with such information himself when participating in one of our events.

Data of people in the business contacts database who have not actively cooperated with LLI in the last 36 months will be removed from our CRM systems. If you opt out of receiving future LLI publications, our unsubscribe list will still contain your basic contact details.

LEGAL BASIS for the processing of personal data of persons listed in our contact database:
  • The explicit consent of the person listed in the business contacts database.
  • To pursue our legitimate interest in managing our relationships with people in our business contacts database and providing information about LLI, our services and events we organize.
  • Comply with a legal or regulatory obligation.
  • Pursuing a legitimate interest in developing and improving our website and user experience.

LLI Events

We process personal data of participants in meetings, conferences, events and educational sessions organized by LLI (events). We use various applications to guide the registration process of participants, which contain their own privacy policy statement explaining why and how they collect and process personal data. We encourage participants to read the privacy policy available on these applications.

As part of our event management processes, we process the following personal data (but only to the extent necessary to implement a given event):

  • Name and surname, age or date of birth.
  • Customer personnel data (home address, business address and company details).
  • Credit or debit card number.
  • Customer data (home address, business address and company details).
  • E-mail address.
  • Sex.
  • Home address and other physical address.
  • Employer names.
  • Profession (position).
  • Passport number.
  • URL of own website (if the data subject has his own website that he wishes to make available).
  • Telephone or fax numbers.
  • Event-related data such as: dietary or other special requirements, registration status, participant status / type, media presence in the event, previous event experience, arrival / departure time, hotel check-in / check-out time, flight information (airline, arrival and departure dates).

We do not intentionally collect sensitive data, unless the data subject provides us with such information (for example, information on special dietary requirements, on the basis of which it is possible to determine his religious affiliation or food allergies or other data regarding his health condition necessary to provide support participants if necessary, for example if it is necessary to provide a wheelchair).

Attendees at LLI events taking place at external venues must bring an ID with photo to verify their identity in order to ensure the protection of our employees, property and information, and to prevent unauthorized persons from accessing LLI events taking place off-site.

LLI may take photos and make audio and audiovisual recordings in public places during LLI events. We use such messages in our marketing materials. The image and voice of event participants will be recorded. Recordings will be edited, duplicated, shown, published or disseminated.

LEGAL BASIS for the processing of event participants personal data:
  • The explicit consent of the participant.
  • Pursuing the legitimate interest of organizing events and managing the process of registering participants for such events.
  • Pursuing the legitimate interest of protecting our employees, property and information, and preventing unauthorized persons from gaining access to LLI events taking place outside the company’s premises.
  • Pursuing the legitimate interest in providing information on LLI, our services and the events we organize.

Social Media

LLI uses various social platforms, including for recruitment and marketing purposes. We use social media to provide Internet users with easy access to relevant information about job offers at LLI and the opportunity to participate in events we organize, as well as to promote our services and brand.

LLI is responsible for the content posted via social media platforms, but is not responsible for the management of such platforms (creating user statistics and placing cookies). When using social media platforms, users are required to comply with the legal requirements and privacy protection conditions imposed by the providers of such social media. Providers collect personal data of users, including statistical and analytical data on the use of social media platforms, including information about websites viewed, likes, recent visits and entries that have been published by the user or aroused his interest. If user wish to access such data or to invoke one of your other rights (such as the right to object to the processing of your data), please contact the provider of the relevant social platform. Some social media providers transfer LLI aggregate data about our pages, including information about the number of likes in response to our content or the number of posts, our pages visitors, photos downloaded by users, or clicks on links posted by us.

IT security, including electronic correspondence

LLI uses various tools to maintain the security of our IT infrastructure, including our email. Examples of such tools are:

  • Systems that scan incoming messages to recipients from LLI for suspicious attachments and URLs in order to prevent malware attacks.
  • Endpoint threat detection tools to identify malware attacks.
  • Tools that block certain content or websites.

In the case of e-mail correspondence with the LLI, the messages received from the user will be scanned with the tools used by LLI to secure its IT infrastructure, which may lead to situations in which the content of the message is read by authorized persons from the LLI who are not its intended recipient.

LEGAL BASIS for the processing of personal data of persons corresponding with e-mail correspondence with LLI:
  • Realization of a legitimate interest consisting in securing our IT infrastructure against unauthorized access and data leakage.
  • Pursuing a legitimate interest in analyzing e-mail traffic.

Recruitment

We collect data from candidates and information about them in connection with job offers at LLI. The information we collect and the way we use it and the time we collect it varies depending on the country in which you apply. In general, the data we collect about people applying for a job with our company includes a curriculum vitae or CV, identification documents, proof of education, career information, employment information and references.

We use candidates’ personal data to match their skills, experience and education with specific job offers at LLI. The collected information is passed on to the relevant managers recruiting for a given position and to people involved in the recruitment process, who decide to invite the candidate for an interview. Should the candidate progress to the interview phase (or its equivalent) and the subsequent stages of the recruitment process, the LLI will collect further information. Information collected in this case includes interview notes, evaluation results, feedback and details of the offer.

In connection with carrying out the recruitment activities, including the consideration of applications and the implementation of new employees, we will also collect data from candidates belonging to specific categories of data, if such an obligation is provided for in the labour law. Information has a significant impact on the future working environment at LLI or the provision of future employee benefits, and where the law allows for the collection of such information, the basis for collecting it is the explicit consent of the person concerned. Some employees will also need a criminal background check to assess their eligibility to work for LLI or for LLI’s clients.

LLI may collect personal data about applicants from the following sources:

  • Directly from the candidate – inter alia the information that the candidate provided while applying for the position directly on the LLI website with job offers
  • From recruitment agencies – for example, when a recruitment agency that has contact details for a candidate presents you as a potential candidate for a given position
  • Publicly available sources on the Internet – for example, where your job profile is shared online (e.g. on your current employer’s website or on a job network website such as LinkedIn)
  • References – for example based on references provided by a former employee or employer or obtained from a person designated by the candidate as providing the reference
  • The results of the candidate’s background verification
LEGAL BASIS for the processing of personal data of people applying for a job at LLI:
  • The explicit consent of the candidate.
  • Pursuing the legitimate interest of attracting, identifying and recruiting highly qualified employees.
  • Pursuing the legitimate interest of processing and managing applications for positions at LLI, including verification and selection of candidates.
  • Pursuing the legitimate interest in the management of our websites with job offers (including the performance of statistical analysis).
  • Comply with a legal or regulatory obligation (when screening a candidate’s background to ensure a candidate is eligible for a job).

Suppliers

We process the personal data of our suppliers (including subcontractors and people working with our suppliers and contractors) to manage our relationships and contracts and to receive services from our suppliers.

The personal data we process is generally limited to contact details (name and surname, employer name, telephone number, email address and other contact details) and financial information (payment information).

In addition, we use data about our suppliers to check if there are restrictions that prevent supplier selection due to a conflict of interest. Before starting cooperation with a new supplier, we also assess the independence of the audit and verify the supplier’s past in accordance with the requirements provided for by law, including, inter alia, verification of unfavourable information in the media, bribery and corruption as well as other financial crimes.

Legal basis for the processing of personal data of our suppliers:
  • Performance of the contract.
  • Comply with a legal or regulatory obligation.
  • Pursuing a legitimate interest in managing payments and fees as well as collecting and recovering our receivables.
  • Pursuing the legitimate interest of identifying any conflicts of interest or difficulties related to the independent conduct of business legislation.
  • Pursuing the legitimate interest of protecting the LLI against inadvertent actions using funds derived from criminal activity or providing assistance in carrying out any other activities that are unfair or illegal (such as terrorism).

Suppliers

We process the personal data of our suppliers (including subcontractors and people working with our suppliers and contractors) to manage our relationships and contracts and to receive services from our suppliers.

The personal data we process is generally limited to contact details (name and surname, employer name, telephone number, email address and other contact details) and financial information (payment information).

In addition, we use data about our suppliers to check if there are restrictions that prevent supplier selection due to a conflict of interest. Before starting cooperation with a new supplier, we also assess the independence of the audit and verify the supplier’s past in accordance with the requirements provided for by law, including, inter alia, verification of unfavourable information in the media, bribery and corruption as well as other financial crimes.

Legal basis for the processing of personal data of our suppliers:
  • Performance of the contract.
  • Comply with a legal or regulatory obligation.
  • Pursuing a legitimate interest in managing payments and fees as well as collecting and recovering our receivables.
  • Pursuing the legitimate interest of identifying any conflicts of interest or difficulties related to the independent conduct of business legislation.
  • Pursuing the legitimate interest of protecting the LLI against inadvertent actions using funds derived from criminal activity or providing assistance in carrying out any other activities that are unfair or illegal (such as terrorism).

Reporting data

We transfer or disclose the personal data we collect to third party support providers (and their subsidiaries and affiliates) who are involved in internal support processes. For example, we engage support providers to provide (a) general office support, including printing, document creation and management, archiving, and translation services; (b) support in the field of accounting, finance and billing; (c) IT functions, including system management and security, data storage, business applications, voicemail and system replication for business continuity / disaster recovery; and (d) conflict checking, risk management and quality reviews.

According our policy, we use only support providers who are required to maintain an adequate level of data protection, security and confidentiality, and who comply with all applicable legal requirements regarding the transfer of personal data outside the jurisdiction in which it was originally collected. For data collected within the EEA or about data subjects within the EEA, the LLI requires an appropriate data transfer mechanism if this is necessary to comply with applicable law.

LLI discloses personal data:

  • If it is appropriate in the context of achieving the purposes described for the processing of personal data, including within the LLI organization.
  • If required by applicable law.
  • In connection with the reorganization or merger of our organization with another enterprise.
  • If we believe such disclosure is justified in order to enforce or apply terms of cooperation or other agreements, or to protect and defend the rights, property or safety of LLI.
  • To comply with a court proceeding, court order, or other legal obligation, or inquiries made by a regulatory or government authority, or
  • With the consent of the data subject.

We would like to highlight the fact that in certain jurisdictions, the LLI has a legal obligation to report suspicious transactions and other activities to the relevant regulatory authority under anti-money laundering, terrorist financing, insider dealing or related laws. In addition, the LLI reports suspected criminal activity to the police and other law enforcement agencies. The law does not always allow the data subjects to be informed about this prior to disclosure or at all.

The external recipients of personal data include:

  • Professional advisers (law firms, tax advisers and statutory auditors).
  • Insurers.
  • Bodies supervising the activity of statutory auditors.
  • Tax and customs authorities and authorities collecting excise duty.
  • Regulatory and other professional bodies.
  • Stock exchange and listing authorities.
  • Public records of company directors and shares.
  • Identity verification service providers.
  • Credit reference agencies.
  • Courts, police and law enforcement.
  • Government departments and agencies.
  • Service Providers.
  • Support service providers.

Minor

Our site is not intended for use by minors under the age of sixteen (16). LLI does not knowingly collect, disclose or sell personal data of minors under the age of 16. If you are under the age of 16, please do not provide any personal information, even if prompted. If you believe that you have provided your personal data inadvertently, please ask your parents or legal guardians to notify us and we will delete your personal data.

Behavioural targeting and cookies policy

We may work with third parties to display advertisements for LLI products on our websites and to manage our advertisements on other websites that are not owned by LLI. We and our third party partners may use technologies, such as cookies, to collect information about your activities on this website and other websites in order to provide you with advertising based on your browsing activities and interests. Please also see the technical information of your browser or mobile device for instructions on how to delete and disable cookies and other tracking / recording tools (to learn more about cookies, gifs / beacons and related technologies, please visit allaboutcookies.org and / or the Network Advertising Initiative’s online resources at networkadvertising.org). If you access websites on your mobile device, you may not be able to control the tracking technology through your settings. Some of the cookies we use come from third parties such as Adobe Analytics, Google Analytics, Hubspot, Marketo Munchkin Tracking, AS Remarketing, Xing and Linkedin Analytics to provide us with web analytics and information about our sites. These companies use programming code to collect information about your interaction with our sites, such as the pages you visit, the links you click, and the time you spend on our sites. This code is only active when you use LLI pages. More information on how these companies collect and use information on our behalf can be found in their privacy policies: Adobe on Adobe Privacy Center, Google on Google Privacy & Terms, Hubspot on Hubspot Privacy Policy and Marketo on Marketo Privacy Policy, AS Remarketing w Advanced remarketing services and Linkedin at Linkedin Privacy Policy, Xing at Xing Privacy Policy and Yoptima at Yoptima Privacy Policy.

The only way to completely “opt-out” of any information being collected by cookies or other tracking technology is to actively manage the settings on your browser or mobile device.

Reference

In addition to other recommendations, we may display personal reference of satisfied customers on our website. With your consent, we can publish your reference along with your name. If you want to update or delete your refrence, you can contact us at contact@llinformatics.com.

Privacy policy changes

our practices and services. If we post changes to the content of this privacy policy, we will revise the date of the last update at the top of this document. If we make significant changes to the way we collect, use and share personal data, we will notify you by posting the changes on our website. We recommend that you check the content of this page at regular intervals in order to be aware of any changes to the content of this privacy policy.