Due to the provisions 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 (hereafter as GDPR) we wish to inform you on the rules according to which DFLIGHTS is processing your personal data, and on your rights regarding such data processing.
- THE DATA CONTROLLER IS:
DFLIGHTS, a company operating under the laws of Poland, with its registered seat in Warsaw (zip code 00-526), Krucza 24/26, entered into the Registry of Foundations of National Court Registry under the number 369620432.
- YOU CAN CONTACT DFLIGHTS AT:
- e-mail: office@dflights.pl
- traditional mail: Krucza 24/26, 00-526, Warsaw, Poland
Additionally, DFLIGHTS had appointed a Data Protection Officer, with a goal of taking care for the safety of your personal data processed by DFLIGHTS. Our DPO can be contacted at: office@dflights.pl;
III. DFLIGHTS GATHERS AND PROCESSES PERSONAL DATA IN connection with:
- its statutory activities,
- educational materials offered by Foundation,
- marketing activities,
- established business relations;
- THE GOAL OF DATA PROCESSING, LEGAL BASES, AND AN ESTIMATED TIME OF KEEPING THE DATA:
- If you are a Social Partner or Beneficiary of DFLIGHTS within its statutory activities:
| Goal of processing | Legal basis | Duration of data processing/keeping |
| Performance of agreements regarding cooperation for charity or social activities | art. 6 sec. 1 let. b) GDPR | Equal to the duration of the agreement |
| Processing regarding claims and defense against claims regarding statutory activities, which constitutes the legitimate interests pursued by the controller | art. 6 sec. 1 let. f) GDPR | Expiration period according to applicable provisions of the law |
| Keeping accounting books and tax documentation | art. 6 sec. 1 let. c) GDPR in connection with art. 74 sec. 2 of act on accounting and other applicable laws | The period for keeping accounting books and tax documentation is based on applicable laws |
- If you are a Contractor of DFLIGHTS, performing support services for Foundation’s statutory activities:
| Goal of processing | Legal basis | Duration of data processing/keeping |
| Performance of sales/services/supply agreements | art. 6 sec. 1 let. b) GDPR | Equal to the duration of the agreement |
| Processing regarding claims and defense against claims regarding, the agreements, which constitutes the legitimate interests pursued by the controller | art. 6 sec. 1 let. f) GDPR | Expiration period according to applicable provisions of the law |
| Keeping accounting books and tax documentation | art. 6 sec. 1 let. c) GDPR in connection with art. 74 sec. 2 of act on accounting and other applicable laws | The period for keeping accounting books and tax documentation is based on applicable laws |
- If you are a Participant in a Grant Competition organized by DFLIGHTS:
| Goal of processing | Legal basis | Duration of data processing/keeping |
| Execution of Grant Competition and selection of Beneficiaries | art. 6 sec. 1 let. a GDPR | Period necessary for executing the Grant Competition |
| Keeping with a goal of archive purposes, relations management and accountability (proof of fulfilling binding obligations) | art. 6 sec. 1 let. f GDPR | Up to 5 years after the end of calendar year, in which the Competition took place, unless you execute your right to object on a closer date |
| Processing regarding claims and defense against claims regarding Grant Competitions, which constitutes the legitimate interests pursued by the controller | art. 6 sec. 1 let. f) GDPR | Expiration period according to applicable provisions of the law |
- If you are the representative of a Social Partner/Beneficiary/Contractor of DFLIGHTS, nominated contact person, person authorized to act on behalf of a Social Partner/Beneficiary/Contractor of DFLIGHTS:
| Goal of processing | Legal basis | Duration of data processing/keeping |
| Execution of the agreement entered into between DFLIGHTS and the entity you represent, which constitutes the legitimate interests pursued by the controller. | art. 6 sec. 1 let. f GDPR | Equal to the duration of the agreement entered into between DFLIGHTS and the entity you represent. |
| Processing regarding claims and defense against claims regarding, the agreements, which constitutes the legitimate interests pursued by the controller | art. 6 sec. 1 let. f GDPR | Expiration period according to applicable provisions of the law |
| Keeping accounting books and tax documentation, if your data was given in the agreement or other documents related to DFLIGHTS’s obligations resulting from applicable laws, including tax and accounting laws. | art. 6 sec. 1 let. c GDPR in relation with art. 74 sec. 2 of act on accounting and other applicable laws | The period for keeping accounting books and tax documentation is based on applicable laws |
- If you are a potential Social Partner/Beneficiary of DFLIGHTS:
| Goal of processing | Legal basis | Duration of data processing/keeping |
| Actions taken before entering into agreement on your demand. | art. 6 sec. 1 let. b GDPR | Until the decision is made on entering into agreement |
| Processing regarding claims and defense against claims regarding, the negotiations and agreements, which constitutes the legitimate interests pursued by the controller. | art. 6 sec. 1 let. f GDPR | Expiration period according to applicable provisions of the law |
- 6. If you are a person towards whom DFLIGHTS directs its marketing:
| Goal of processing | Legal basis | Duration of data processing/keeping |
| Execution of direct marketing action regarding the DFLIGHTS’s activities, including the mailing of materials and business information, including those send via means of electronic communication, should you express permission to do so | art. 6 sec. 1 let. f GDPR, art. 6 sec. 1 let. a GDPR, art. 10 sec. 2 of Act on the provision of electronic services, art. 172 of Telecommunications Law | For the time necessary to reach the goal, yet no longer than: 1) when you execute your right to object the processing for this purpose, or 2) if you expressed the permission for electronic mailing – until such permission is withdrawn |
| Statistical purposes with a goal of improving DFLIGHTS activities, which constitutes the legitimate interests pursued by the controller | art. 6 sec. 1 let. f GDPR | For the time necessary to reach the goal, yet no longer than when you execute your right to object the processing for this purpose |
- If you represent the media (i.e. you are a journalist, publisher, etc.):
| Goal of processing | Legal basis | Duration of data processing/keeping |
| Informing about DFLIGHTS’s activities and relations management which constitutes the legitimate interests pursued by the controller | art. 6 sec. 1 let. f GDPR | For the time of DFLIGHTS’s existence, yet no longer than when you execute your right to object the processing of your data |
- 8. If you use the contact forms on DFLIGHTS’s websites, you’re contacting DFLIGHTS via traditional mail, e-mail, social media for purposes other than those mentioned above:
| Goal of processing | Legal basis | Duration of data processing/keeping the data |
| Managing the correspondence, answering questions/applications/petitions for the purposes relating from the correspondence, in a goal of establishing future contact, as well as with a goal of archive purposes and relations management, which constitutes the legitimate interests pursued by the controller | art. 6 sec. 1 let. f) GDPR | Until the end of DFLIGHTS activity, unless the data in question is a sensitive one, in which case DFLIGHTS removes or anonymizes those data as soon as possible. |
- CATEGORIES OF DATA GATHERED BY DFLIGHTS
| Social Partner/Beneficiary/Contractor |
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| Participant in a Grant Competition |
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| Representative of a Social Partner/ Beneficiary/Contractor, person designated for contact, person authorized to act on behalf of a Social Partner/Contractor, project coordinator |
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| Potential Partner/Contractor |
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| Person placing order for educational materials via www.wiemczujepomagam.pl Internet platform: |
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| Person participating in events organized by DFLIGHTS, including events organized within the scope of Domino’s Effect Workshop |
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| Person towards whom DFLIGHTS directs its marketing |
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| Receiver of DFLIGHTS’s newsletter |
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| Representative of the media (journalist, publisher): |
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| Person making a donation |
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| Person donating 1% of income tax |
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| Person using the contact forms on DFLIGHTS’s websites, or person contacting DFLIGHTS via traditional mail, e-mail, social media for purposes other than those mentioned above | Data can include: name, surname, address, e-mail address, other data included in your message |
- DFLIGHTS GATHERS YOUR DATE FROM THE FOLLOWING SOURCES:
| Social Partner/Beneficiary/Contractor | Directly from data subject before or during the execution of the agreement |
| Participant in a Grant Competition | Directly from the data subject via your registration in Grant Competition by filling in the registration form at www.dflights.pl and sending it to the controller |
| Representative of a Social Partner/ Beneficiary/Contractor, person designated for contact, person authorized to act on behalf of a Social Partner/Contractor, project coordinator | Via the represented entity; |
| Potential Partner/Contractor | Directly from data subject or from public sources |
| Person participating in events organized by DFLIGHTS, including events organized within the scope of Domino’s Effect Workshop | Directly from data subject or from his/her legal guardian/supervising person by filling the participation form |
| Person towards whom DFLIGHTS directs its marketing | Directly from data subject, via represented entity or from public sources |
| Receiver of DFLIGHTS’s newsletter | Directly from data subject via the permission to process the data |
| Representative of the media (journalist, publisher) | Directly from data subject, via represented entity or from public sources |
| Person making a donation | Directly from data subject by filling the “support our activities” form at http://kulczykfoundation.org.pl (name, surname, e-mail address, phone number), or via bank (name, surname, account number, the amount of money, address) |
| Person donating 1% of income tax | Via Tax Office |
| Person using the contact forms on DFLIGHTS’s websites, or person contacting DFLIGHTS via traditional mail, e-mail, social media for purposes other than those mentioned above | Directly from data subject |
VII. NECESSITY OR VOLUNTARILITY OF DATA SUBMISSION:
| Social Partner/Beneficiary/Contractor | Your decision to submit your data is voluntary, yet necessary to enter into and execute the agreement. The refusal to submit your data will result in inability to enter into and execute the agreement |
| Participant in a Grant Competition | Your decision to submit data is voluntary, yet necessary to participate in Grant competition. The refusal to submit data will result in inability to participate in the competition |
| Representative of a Social Partner/ Beneficiary/Contractor, person designated for contact, person authorized to act on behalf of a Social Partner/Contractor, project coordinator | If you to submit your data, you do it is voluntary, yet it might be necessary to enter into and execute the agreement between DFLIGHTS and the entity you represent. The refusal to submit your data may result in inability to enter into and execute the agreement |
| Potential Partner/Contractor | Your decision to submit your data is voluntary, yet necessary to enter into cooperation, place offer and subsequently to enter into and execute the agreement. The refusal to submit your data will result in inability to enter into cooperation; |
| Person placing order for educational materials via www.wiemczujepomagam.pl Internet platform: | Your decision to submit your data is voluntary, yet necessary to place your order. The refusal to submit your data asked in the order form will result in inability place and execute the order. Submission of data not necessary for the order is voluntary. |
| Person participating in events organized by DFLIGHTS, including events organized within the scope of Domino’s Effect Workshop | Your decision to submit your data is voluntary, yet necessary to participate in the event. The refusal to submit your data will result in inability to participate. |
| Person towards whom DFLIGHTS directs its marketing | Your decision to submit your data is voluntary, yet necessary if you want to receive information on DFLIGHTS’s activities, projects and events. |
| Receiver of DFLIGHTS’s newsletter | Your decision to submit your data is voluntary, yet necessary to receive e-mails. |
| Representative of the media (journalist, publisher) | Your decision to submit your data is voluntary, yet necessary if you want to receive information on DFLIGHTS’s activities, projects and events |
| Person making a donation | Your decision to submit your data is voluntary, yet necessary to make the donation |
| Person donating 1% of income tax | Your decision to submit your data is voluntary |
| Person using the contact forms on DFLIGHTS’s websites, or person contacting DFLIGHTS via traditional mail, e-mail, social media for purposes other than those mentioned above | Your decision to submit your data is voluntary, yet necessary if you want to receive a response. The lack of submission of your data will result in inability to answer |
VIII. ENTITIES TO WHICH DFLIGHTS MAY TRANSFER YOUR DATA:
DFLIGHTS only entrusts your data to trusted entities with which it permanently cooperates, such as:
- Providers of technical and organizational services
- Entities providing postal and courier services
- Legal consultants and advisors
- Partners and Contractors of DFLIGHTS, in a scope necessary to perform DFLIGHTS’s statutory activities
- Other entities, persons or groups – in the scope determined by applicable laws
with the proviso that when entrusting data to external entities, DFLIGHTS uses the due diligence to ensure that external entities apply the appropriate level of security required by the relevant laws and concludes agreements for this purpose.
- RIGHTS OF SUBJECTS OF DATA PROCESSED BY DFLIGHTS
You have the following rights resulting from processing of your data by DFLIGHTS:
- Right to access your data (art. 15 GDPR);
- Right to rectification (art. 16 GDPR);
- Right to erasure the data in cases described in art. 17 sec. 1 GDPR, notwithstanding the exclusions set out in art. 17 sec. 3 GDPR;
- Right to restriction of processing the data in cases described in art. 18 GDPR;
- Right to transfer the data in cases described in art. 20 GDPR.
If Your data is processed based on your consent, you also have the right to withdraw such consent at any time, yet such withdrawal does not affect the lawfulness of processing before withdrawal.
DFLIGHTS informs, that due to your special position, you also have the right to object the processing of your data in case when the basis for processing is DFLIGHTS’s legitimate interest.
You can file your objection against processing for the purpose of direct marketing (inc. profiling) at any time without giving any reasons. Your objections constitute a ban for DFLIGHTS on processing your data for this purpose.
In order to exercise any of Your rights please contact DFLIGHTS via:
- e-mail: office@dflights.pl;
- traditional mail at: Krucza 24/26, 00-526 Warsaw
- the withdrawal of consent for receiving the Newsletter can be made each time you receive one by using a “sign off” button
You also have a right to fila a complaint to the supervisory authority, i.e. Prezes Urzędu Ochrony Danych Osobowych, should the processing of your data violate applicable data protection laws.
- AUTOMATED INDIVIDUAL DECISION-MAKING BASED ON YOUR DATA
DFLIGHTS will not conduct automated individual decision-making based on your data (i.e. decisions made without human factor), specifically your data will not be profiled.
The above does not apply to electronic processing (inc. profiling) of your data for marketing purposes, which allow DFLIGHTS to present you with individualized and personalized information DFLIGHTS’s activities.
- SECURITY OF PERSONAL DATA
In order to ensure the security of your personal data, DFLIGHTS has implemented appropriate technical and organizational measures. In particular, DFLIGHTS protects your data from unauthorized access, loss or destruction. With this goal, DFLIGHTS has implemented adequate measures of personal, organizational and technical nature.
Data sent electronically is secured against its acquisition and modification by unauthorized persons through the use of, among others the following protections: access control, use of server security devices and firewalls software.
XII. COOKIES
Website locate under the domain https://www.dflights.pl/ (hereafter referred to as the Site) uses cookies.
Cookies are digital data, including text files, stored at the end device of Site User and are used in order to browse the website. Cookies contain the name of the website from where they originate, time of storage on end device and unique number.
The entity storing the cookies and getting access to it is DFLIGHTS as Site’s admin.
Information on some of Users’ activities are gathered and stored on the server. Those data are used exclusively for managing the Site.
The data is identified by URL addresses. The following data can also be stored:
- time of inquiry,
- time of answer,
- cilent’s station name – via http protocol,
- error logs,
- referer link,
- information on user’s browser,
- information on user’s IP address.
Gathered information is not linked to specific Site’s users. The user can browse the Site maintaining its anonymity. DFLIGHTS does not pursue the identification of the user, unless it’s necessary as a result of user-taken action, such as donating or messaging via message form.
Cookies are used for:
- statistics, in order to determine how the users use the Site, leading to its changes in regards of content, functionality and accessibility
- keeping the user’s session – preventing from the need of re-submitting username and password
- defining User’s preferences profile, thanks to which it is possible to provide him with tailored, personalized advertising messages by advertising networks cooperating with the Site, in particular the Google network.
Within the Site two type of cookies occur: session cookies and persistent cookies. Session cookies are temporary files stored at user’s end device until logoff, exit from the site or closing the browser. Persistent cookies are stored at user’s end device until the time set in files properties or until the user deletes them.
The browsers allow for cookie storage by default. The user can change its browser settings. In order to do so the user should consult its browser’s manual or contact the producer.
Disabling cookies storage may result in limiting access to some functionalities of the Site or its incorrect operation
Cookies stored in user’s end device can also be used by marketing companies cooperating with the Admin, including Google network, with a goal of displaying ads personalized toward specific user.