Privacy Policy

(hereinafter:“Privacy Policy”)

We present information on how Opennet Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw (01-360), at ul. Człuchowska 68A, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division of the National Court Register, under no. KRS: 0000855145, NIP 1182175331 and REGON no. 38045118800000

processes Personal Data provided by Users in connection with the use of the www.Opennet.pl website www.Opennet.pl

§1 DEFINITIONS

1. Personal Data – means the personal data within the meaning of Article 4(1) of the GDPR that Users provide to Opennet in connection with their use of the Website.
2. Opennet – means Opennet Spółka z ogranioczoną odpowiedzialnością with its registered seat in Warsaw.
3. GDPR – means Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 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).
4. Website – means the website Opennet.pl
5. Support Portal – means the ticketing system for Opennet customers available at www.sp.opennet.pl.
6. User– means any person using the Website in any way.

§2 GENERAL INFORMATION

1. The Controller of Users’ Personal Data is Opennet.
2. ​For any matter relating to the protection of Users’ Personal Data, including for the purpose of exercising Users’ rights as data subjects (these rights are described below), Opennet may be contacted by email at: iod@opennet.pl or by post to the address of Opennet registered office, i.e. ul. Człuchowska 68A, 01-360 Warszawa.
3. Opennet has appointed a Data Protection Officer who can be contacted at email address: iod@opennet.pl on any issues relating to the processing of Users’ personal data.

§3 CATEGORIES OF DATA AND PURPOSES OF PROCESSING

1. Opennet will process the following categories of Users’ Personal Data:
   • Basic identification data entered voluntarily into the contact form on the Website and the use of the Support Portal by Users available on the Website, e.g. name, surname, e-mail address, telephone, position, data concerning professional activities,
   • Cookies and other data of diagnostic nature collected by Opennet when using the Website, as well as when Users use the Support Portal available on the Website, e.g. Internet logs and Users’ IP addresses.
2. Personal Data of Users, is processed for the following purposes:
   • to enable logging in and servicing the User, who uses software supplied by Opennet, via the Support Portal – on the basis of Article 6(1)(b) and (f) of the GDPR and no longer than until expiry of claims in connection with the concluded agreement, i.e. no longer than 3 years from the expiry of the agreement in connection with which the data were collected ;
   • to comply with obligations imposed on Opennet by relevant legislation – on the basis of Article 6(1)(c) of the GDPR and for no longer than the period of limitation claims for public-law debts, i.e. no longer than 6 years from the end of the financial year in which the agreement on the basis of which the data was collected expired;
   • to pursue Opennet’s legitimate interests, including the promotion and advertising of Opennet’s business, services and products (no longer than until the time of raising an objection), to respond to communications and queries sent to Opennet, to maintain ongoing cooperation and contacts with our Customers’ representatives in order to provide services under the concluded agreements, to monitor traffic on the Website, to ensure its correct and optimal functioning, to diagnose errors related to the operation of the server, to analyse potential security breaches and to manage the Website, and for statistical purposes, i.e. collecting and analysing demographic data of the Users (from where the connection was made), adjusting the Website to the needs and interests of the Users, asserting and defending against claims, archiving for the purposes of protecting Opennet’s legal interests (e.g. demonstrating compliance with the relevant provisions of law (no longer than until those purposes are realised) – pursuant to Article 6(1)(f) of the DPA),

§4 PROCESSING TIME

1. Opennet only collects and processes Personal Data that is necessary and appropriate to fulfill the purposes set out above. Opennet will retain it for no longer than is necessary for those purposes.
2. Where personal data is processed on the basis of consent, this consent may be withdrawn at any time, but this will not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal.
3. The provision of personal data by Users is voluntary, but necessary for the above-mentioned purposes – it will not be possible in the case of refusal.

§5 DATA SUBJECTS’ RIGHTS

1. Users have the following rights:
   • the right to access their Personal Data, to obtain a copy of it and to be informed, inter alia, of the purposes of its processing, its categories, recipients and duration of storage;
   • the right to require Opennetus to delete their Personal Data (“right to be forgotten”) in certain situations, including where the processing is unlawful, is no longer necessary for the purposes for which the data was collected, or where you object and there are no other legal grounds for processing;
   • the right to request Opennet to restrict the processing of their Personal Data in certain situations, including, but not limited to, during the period Opennet verifies the accuracy of the Personal Data that has been contested or until the objection raised is verified;
   • the right to portability of their Personal Data, i.e. to receive it in a structured, commonly used format and send it to another controller, provided that the data are collected on the basis of your consent or processed in connection with the performance of a contract concluded with Opennet;
   • the right to object to the processing of their Personal Data where it is carried out for the purposes of Opennet’s legitimate interests on grounds relating to your particular situation;
   • the right to object to the processing of Personal Data where it is carried out for direct marketing purposes;
   • the right to withdraw their consent, where the User has given their consent to the processing of data;
   • the right to lodge a complaint to the supervisory authority which is the President of the Office for Personal Data Protection (address: President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw), in case you consider that the processing of your Personal Data is incompatible with the applicable regulations

§6 DATA RECIPIENTS

1. Opennet may share Personal Information with third parties (recipients) who cooperate with Opennet in the operation of the Website and provide services to Opennet in this regard.
2. All entities to which Opennet provides Personal Data will be required to process such data in accordance with applicable laws, including the GDPR.
3. Opennet does not transfer data outside the European Economic Area [“EEA”]. In the event that such a transfer of data becomes necessary, information to that effect will be provided in this Policy. Notwithstanding the foregoing, such transfer will be made taking into account the requirements set out in Chapter V of the GDPR.

§7 EXTERNAL WEBSITES

The Website may contain links to external websites and social networks which do not belong to Opennet. Opennet is not responsible for the way personal data is processed or the use of cookies by entities owning external sites and recommends that you read the privacy policies published there.

§8 FINAL PROVISIONS

All data collected by Opennet is protected using reasonable technical and organisational measures and security procedures to prevent unauthorised access or use. Opennet’s affiliates, trusted partners and third party service providers manage data in accordance with security and privacy requirements. This Privacy Policy is continuously updated by Opennet. Any changes to it due to changes in the law or related to changes in the service offerings available on the Website or development of its functionality will be promptly communicated on the Website.