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Social media policy

By using our social media accounts, you interact with us, for instance, by subscribing to a fanpage, leaving your reaction (like, comments) or sending a message to us. The information you provide us with about yourself may constitute personal information. Social media policy given describes how we process personal data collected through accounts on the following social media sites (hereinafter referred to as „Social Media Websites”).

We process your personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of the 27th of 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 (hereinafter referred to as „General Data Protection Regulation”).

I. Personal Data Controller

The controller of your personal data is Leon Software sp. z o.o. sp. j. with its registered office in Warszawa, Al. Jerozolimskie 151/5U, 02-326 Warszawa (hereinafter referred to as the „Controller” or „we”). You can contract Controller by email or by post at the above mentioned address of the Controller’s registered office.

 

II. Categories of data subjects whose data are processed and the scope of data processing

FACEBOOK

We process data of data subjects who:

  • subscribed to the account by clicking the „Like” or „Watch” icon,
  • published a comment, shared it or clicked the „Like” icon under any of the posts in the account,

We process the following types of personal information:

  • account identifier (typically including your name or nickname),
  • our profile picture,
  • other photos (which may also present an image),
  • the content of your comments,
  • statistical data about visitors to the fanpage available through the „Facebook Insights” function, collected through cookies.

TWITTER

We process data of data subjects who:

  • subscribed to the account by clicking the "Watch" icon,
  • published a comment under any of the posts on the account or reacted to published photos.

We process the following types of personal information:

  • account identifier (typically including your name or nickname),
  • profile picture,
  • other photos (which may also include an image),
  • the content of your comments,
  • statistical data on account visitors collected through cookies.

LINKEDIN

We process data of data subjects who:

  • visited the Controller’s website,
  • have interacted with the Controller,
  • published or submitted data through the services offered by LinkedIn (e.g. filled in forms, answered surveys),

We process the following types of personal data:

  • first name, last name, image, and other identifying information you have made publicly available on the profile you have created on LinkedIn (including, but not confined to address, contact information e.g. email address, phone number, and information about your education, professional experience, professional eligibility, and history of previous employment),
  • statistical data concerning visitors of your profile, collected through cookies.

YOUTUBE

We process data of data subjects who:

  • subscribed to the account by clicking on the "Subscribe" icon,
  • posted a comment under any of the videos posted in the account, or reacted to videos posted.

We process the following types of personal data:

  • an account ID (typically including your first and last name or nickname),
  • your profile picture,
  • the content of your comments,
  • statistical data about account visitors collected through cookies.

III. Purpose and legal basis of processing

We process your personal data:

  1. on the basis of legitimate interest (Article 6 (1) (f) of the General Data Protection Regulation) consisting of:
    1. maintaining an account on the Social Media Website, under the terms and conditions specified by the operator of the Portal and informing through it about our activities, promoting events and the brand, products and services, building and maintaining a community with us (including supervision of the content published by users) and for the purpose of communication through the available functionalities of the Social Media Website (comments, messages),
    2. keeping statistics (by analysing data on the activity of users of our account),
    3. possible establishment, investigation or defence against claims.
  2. on the basis of separately granted consent in the scope and for the purpose specified in the content of the consent and for the time until its withdrawal (Article 6 (1) (a) or Article 9 (1) (a) of the General Data Protection Regulation),
  3. on the basis of statutory requirements in order to fulfil our legal obligations under the law (Article 6 (1) (c) of the General Data Protection Regulation),

If we organise promotional campaigns via the Social Network Website, the principles of processing your personal data, including the purpose and legal basis of such processing, are described in the regulations of such campaigns. Before participating in such a promotional action, please read its regulations.

IV. Joint control of personal data

With regard to the processing of personal data for statistical purposes, we act as joint controllers within the meaning of Article 26 (1) of the General Data Protection Regulation together with the operator of the Social Media Website, which provides the statistics option. We undertake such activities within the framework of our legitimate interest (Article 6 (1) (f) of the General Data Protection Regulation) as described above.

For more information on the processing of data for statistics purposes, please follow the link:

V. Recipients of the data

Access to your personal data will be available to:

  • our authorised personnel and the entities providing services to us (including but not limited to marketing, IT and support services) who need access to your data to perform their duties,
  • other users of the Social Media Website (due to the fact that information about the people watching the account, likes, as well as the content of comments, posts and other information provided by users are overt),
  • public authorities and entities performing public tasks or acting on behalf of public authorities, to the extent and for the purpose emerging from the provisions of the commonly applicable legal provisions,
  • Social Media Website Administrator on the terms described in the privacy policies provided.

Please note that the operators of Social Media Websites are separate entities responsible for the processing of data of persons using Social Media Websites, including data concerning you. These entities process your personal data for their own purposes based on the legal basis they have established. In particular, they may collect and process the information contained in the cookies of visitors to our account based on their own Social Media Website operating rules. Therefore, we have limited influence over the processing of data by the operators of the Social Media Website. Thus, we ask you to read the regulation of their functioning and the privacy policies provided by them, which you can find here:

 

VI. Transfer of data to third countries or international organizations

We do not transfer your personal data to a third country or international organization.

VII. Data retention period

The duration of data processing is related to the purposes and grounds for processing, whereby:

  • data processed on the basis of consent will be processed until you withdraw your consent,
  • data processed on the basis of statutory requirements shall be processed for the time in which the law prescribes data storage,
  • data processed on the basis of the legitimate interest of the Controller will be processed until an objection is lodged effectively or this interest ceases to exist, i.e:

* by default, we process your data until we terminate your Social Media Wesbite account,

* personal data obtained in the course of correspondence, we store for the time of processing the message sent to us,

* data processed in order to establish, assert or defend against claims will be processed for a period equal to the period of limitation of such claims.

VIII. You are entitled to the following rights:

  • the right to request access to your personal data, rectification, erasure or restriction of processing, as well as the right to data portability,
  • the right to object at any time to the processing of your data for direct marketing purposes,
  • the right to object to the processing of your data, based on your particular situation,
  • where the processing of your data is based on consent – the right to withdraw consent at any time without affecting the legality of processing carried out on the basis of consent before its withdrawal,

To exercise your rights, please contact us at our contact details indicated in the introduction.

You also have the right to lodge a complaint to the supervisory authority – President of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw.

IX. Information about the source of the data and other information

  • we receive your personal data directly from you through your interaction with our account in the Social Media Website and from your public profile,
  • the provision of data is voluntary,
  • personal data will not be subject to automated decision-making, including profiling.

X.Changes to the Social Media Policy

The Privacy policy may change, about which you will be informed 7 days in advance.

Questions related to the Social Media Policy should be directed to: .

 

Data of last modification: 17 June 2021