Welcome to the website (the “Site”) of Betegy. We believe that protecting our customers’ and business partners’ privacy is crucial to our business and values.
Operator of this website is BETEGY Spółka z ograniczoną odpowiedzialnością seated in Warsaw, Poland (“Betegy”, “we”, “us,” and/or “our”). This Site been created to provide information about our company and advertising automation services and related services (together with the Site, the “Services”) to our Service visitors (“you”, “your”). This Privacy Policy sets forth Betegy’s policy with respect to information, including personally identifiable data (“Personal Data”) and other information that is collected from visitors to the Site and Services.
Unless otherwise expressly stated herein, the terms used in this Privacy Policy shall have the meaning set forth in the General Data Protection Regulation (EU) 2016/679 (the “GDPR”).
[1] Information We Collect:
When you interact with us through the Services or visit our Site, we may collect Personal Data and other information from you, including when you voluntarily provide such information, such as when you contact us with inquiries, respond to one of our surveys, register for access to the Services, or use certain Services. You may use various functionalities of the Site and various Services.
Betegy uses the Personal Data you provide in a manner that is consistent with this Privacy Policy. If you provide Personal Data for a certain reason, we may use the Personal Data in connection with the reason for which it was provided. For instance, if you contact us by email, we will use the Personal Data you provide to answer your question or resolve your problem. Also, if you provide Personal Data in order to obtain access to the Services, we will use your Personal Data to provide you with access to such services and to monitor your use of such services. If at any time you wish not to receive any marketing communications or you wish to have your name deleted from our mailing lists, please contact us.
If Betegy intends on using any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time at which the Personal Data is collected.
In this part of the Policy, we describe how we may use Personal Data we collect. Wherever Betegy collects Personal Data, we will inform you about the conditions and details of their processing.
[1.1.] Personal Data of Site’s visitors and Service users:
Cookies and Non-Identifiable Data. When you visit our Site or interact with Betegy through the Services of the Site, we receive and store certain personally non-identifiable information. Such information, which is collected passively using various technologies, cannot presently be used to specifically identify you. Betegy may store such information itself. The Services may use such information and pool it with other information to track, for example, the total number of visitors to our Site, the number of visitors to each page of our Site, and the domain names of our visitors’ Internet service providers. It is important to note that no Personal Data is available or used in this process. While simply visiting the Site or using our Services, you can stay anonymous until you decide otherwise.
In operating the Services, we may use cookie technologies and similar technologies – collectively hereinafter referred to as Cookies. A cookie is a piece of information that the computer that hosts our Services and the Site gives to your browser when you access the Services or the Site. Our cookies help provide essential functionality to the Services and our Site. For instance, our Site may set a cookie on your browser that allows you to access the Services without needing to remember and then enter a password more than once during a visit to the Site. In all cases where we use Cookies, we will not collect Personal Data except when it is essential for provision of Services or with your permission.
If it is necessary to process Personal Data in relation to Cookies technologies, providing such Personal Data is voluntary, however, failure to provide them may result in the inability to use certain elements or functionalities of the Site.
Legal basis for collecting Personal Data stored in Cookies is Article 6(1)(f) of GDPR, which enables processing of Personal Data for pursuing our legitimate interests. Depending on which Cookies are accepted, the abovementioned legitimate purposes, for which data stored in Cookies are used, include:
- ensuring proper and safe operation of the Site for you and your device;
- assistance for effective navigation on the Site – adapting the Site to the your individual settings and remembering the data you entered, related to the use of the Site, i.a. the choice of storing Cookies;
- performing various functions, including traffic analysis – conducting statistical analyses of the Site, i.a. website visit statistics, which will be used to improve the effectiveness of our marketing activities and build a business strategy.
Data, including Personal Data, are being processed until the purposes of their collection (indicated above) are achieved or until an effective objection to such processing is reported, or until the Cookies are removed from the end device you use when connecting to the Site – depending on which event occurs as first.
Some Cookies enable the compilation of your Personal Data and the creation of statistics and summaries from them, which we can later use to properly match the content we publish on our Site. In connection with performance of analyses and preparation of statistics, you may be profiled, so: we can create a profile containing information about your interests or specific characteristics. At the same time, we would like to inform you that decisions based on the created profiles will not be made in an automated manner.
Agreement conclusion and execution. Our Services are available for users, with whom we have concluded an agreement or a contract for provision of Services.
Personal Data of individuals who are a party of concluded agreements (clients) or were appointed as our clients’ representatives are being processed for execution of concluded agreements, including for invoicing and to send important information to the Data Subject, e.g., regarding changes of applicable fees, price list, and conditions, or to contact the Data Subject and provide information customized Services according to the interests of the Data Subject.
- If you concluded the agreement with us as a natural person (individual running business activities in your own name), we process your Personal Data:
- for the performance of the contract you concluded with us (Article 6(1)(b) of GDPR) – until such contract is terminated or ends,
- for the purposes of our legitimate interests (Article 6(1)(f) of GDPR), including for securing claims (until limitation of such claims) and maintaining contact with you in relation to execution of concluded contract (until such contract is terminated or ends),
- to comply with legal obligations applicable to us, such as corporate and accounting (Article 6(1)(c) of GDPR in relation to i.e. Polish Accounting Act) – for the time stated in applicable law provisions, including Article 74 of Accounting Act (5 years after the end of calendar year, in which the agreement/contract was terminated);
- If you were appointed as our clients’ representative (person authorized to represent our client, indicated as contact person or actually performing the agreement on behalf of our client), we process your Personal Data to pursue our legitimate interests (Article 6(1)(f) of GDPR). Our legitimate interests are:
- execution of agreement concluded with the client which you represent or who indicated you as a contract person for the performance of the contract, including for maintaining contact with our client in relation to execution of concluded contract – until such contract is terminated or ends or until our client states, that you no longer represent it, whichever occurs first,
- securing claims – until limitation of such claims.
[1.2.] Personal Data in our marketing activities:
We conduct marketing and promotion activities, aimed at providing information about our offer and services, in form of distribution of marketing materials and information. If such marketing activities take place using electronic communication channels, in accordance with e-privacy regulations, we need additional consent to use electronic communication channels to conduct marketing activities.
- Personal Data of our clients and their representatives are being processed for our marketing purpose on the basis of Article 6(1)(f) of GDPR (pursuing our legitimate interests in form of marketing of products and services in our offer) – until consents for communication via electronic channels are withdrawn or until successful objection for processing Personal Data is reported, depending on which event occurs first.
- If you are neither our client nor a representative of our client or if you subscribe our newsletter, your Personal Data are being processed for the above-stated purpose on the basis of your consent (Article 6(1)(a) of GDPR), and such consent may be expressed by a clear affirmative action – until any of the consents is withdrawn (for the processing of Personal Data or for receiving marketing and information materials electronically).
Additionally, we create analysis and statistics that help us improve the effectiveness of our marketing activities and build a business strategy. In the vast majority, such statistics are created based on non-personal or anonymized data. In some cases, Personal Data may be used. If so, their processing will be based on the need to pursue our legitimate interest in the form of analytical and statistical activities aimed at our development (pursuing our legitimate interests in the form of analytical and statistical activities), until the above purpose is achieved (an analysis or statistics is developed) or until an effective objection to such processing is made, depending on which event occurs first.
[1.3.] Personal Data collected while handling inquiries, including by Betegy’s support centre:
We collect Personal Data when you contact us, including via our support centre. When responding to an inquiry, we process your Personal Data in order to provide an answer, pursuant to Article 6(1)(f) of GDPR (pursuing our legitimate interests in form of establishing and maintaining contact with you, responding to the received inquiry, considering complaints) – until the inquiry is answered or until an effective objection to such processing is reported, depending on which event will occur first.
We care about the quality of the services we provide. We analyse each problem reported to us. We may process information obtained while handling inquiries to improve the overall quality of our services, apply corrective actions and implement system solutions. For this purpose, we use in principle anonymized notifications, while the anonymization process itself is processing of Personal Data. As a consequence, in order to ensure the best quality of services, we may process your Personal Data (for the time necessary to anonymise the quality-related report).
If we process your Personal Data in connection with quality processes, the legal basis for processing is Article 6(1)(f) of GDPR (pursuing our legitimate interests in form of ensuring the highest quality of services).
[1.4.] Betegy’s social media profiles (LinkedIn):
We cooperate with social media providers, i.e. by running profiles in social media (LinkedIn).
We cooperate with LinkedIn Ireland Unlimited Company („LinkedIn”). The purpose and scope of data collection and further processing and use by LinkedIn, as well as your privacy rights and settings, can be found in LinkedIn’s privacy policy: https://pl.linkedin.com/legal/privacy-policy.
Because LinkedIn and Betegy are joint controllers of Personal Data of persons who use technologies of LinkedIn implemented on this Site and users of our profiles on LinkedIn, such person has the right to obtain an extract from the arrangements made by LinkedIn and Betegy in the field of joint control. An extract of the most important information is available at: https://legal.linkedin.com/pages-joint-controller-addendum.
We may obtain Personal Data in relation to our cooperation with LinkedIn via Cookies or while handling inquiries, responding to your comments etc.
- We process Personal Data collected via Cookies as described above, in section 1.1. (“Personal Data of Site’s visitors and Service users”);
- We process Personal Data collected while handling inquiries, responding to your comments etc. as described above, in section 1.3. (“Personal Data collected while handling inquiries”).
As part of cooperation with LinkedIn, we partially obtain Personal Data directly from you, and partially you’re your LinkedIn profile.
- To the extent that we obtain data directly from you, providing personal data is completely voluntary, and failure to provide it does not have any negative consequences for you. You may use the Site and our LinkedIn profiles in social media without providing any personal data and may remain anonymous at all times (when only browsing the Site or any of our LinkedIn profiles, without interacting with these profiles).
- To the extent that we obtain data from the your profile in social media (due to interaction with i.e. our LinkedIn profile), we may acquire all data included in the your profile, marked as “Public” or those which you will clearly make available to us through your profile, marking the privacy settings in such a way that we will be able to read them. We may also obtain anonymous statistical summaries from LinkedIn, which are also prepared taking into account your data (including Personal Data).
[2] Your rights:
You are entitled to access your Personal Data, their rectification, and under specific conditions also to demand their erasure, restriction of their processing, to object to their processing and to data portability. You are also entitled to withdraw provided consent for processing Personal Data and for receiving marketing information via e-mail or phone number, without affecting the lawfulness of processing based on consent before its withdrawal. To execute your rights, please contact us.
You are also entitled to lodge a complaint if you perceive processing your Personal Data as incompliant with GDPR. The complaint shall be lodged with appropriate supervisory authority, which in Poland, since May 25th, 2018 is the President of the Personal Data Protection Office.
In relation to our use of Cookies, you can specify Cookies settings on your device (including: opt out of collecting Cookies and delete already collected Cookies) by adjusting your browser settings. For more information, visit support centre of your browser’s provider. Please note that blocking all Cookies may make some functionalities unavailable or may adversely affect the performance, effectiveness or customization of Services or the Site.
[3] Other Information:
We may ask for certain Facebook permissions allowing us to perform actions with the Data Subject’s Facebook account and to retrieve information, including Personal Data, from it. This allows our Services to connect with the User’s account on the Facebook social network provided by Facebook Inc. In this context, the following permissions may be asked: About Me, Access Rights (including but not limited to Ad Account Access, Business Manager Access), App Notifications, Contact Email, Manage Advertisements, and Manage Pages. For more information about Facebook permissions, refer to the Facebook permissions documentation and to the Facebook Data Policy.
[3.1.] Our Disclosure Of Your Personal Data And Other Information:
Betegy is not in the business of selling your information. We consider this information to be a vital part of our relationship with you. There are, however, certain circumstances in which we may share your Personal Data with certain third parties without further notice to you, as set forth below:
Business Transfers: As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, Personal Data may be part of the transferred assets.
Legal Requirements: Betegy may disclose your Personal Data if required to do so by law or in the good faith belief that such action is necessary to (i) comply with a legal obligation, (ii) protect and defend the rights or property of Betegy, (iii) act in urgent circumstances to protect the personal safety of users of the Services or the public, or (iv) protect against legal liability.
Partners and service providers: Entities cooperating with us, such as technology and IT suppliers or service providers (i.e. entities providing website hosting, Cookie technology, audit and accounting services, advisory, consultative and legal services) may have access Personal Data you share with us while using the Site or Services. We conclude agreements with our partners, ensuring safety and lawful use of your Personal Data.
Betegy Group: We may share your personal data also within Betegy Group, with companies affiliated in Betegy Group. Some of our affiliates provide us with certain services. They act like our Partners, while also being are bound by our Group standards, including standards applicable to Personal Data protection.
Some of our service providers may store or process Personal Data outside the European Economic Area (i.a. in US). In such cases, Personal Data may be stored in countries that ensure an adequate level of personal data protection, or in countries that do not provide such a level. In the latter case, we secure your Personal Data by concluding agreements with our service providers containing the so-called Standard Contractual Clauses approved by the European Commission, which guarantee adequate protection of Personal Data in third countries, or uses other grounds for the transfer of personal data. For more information in this regard, please contact us.
[3.2.] Exclusions:
This Privacy Policy does not apply to any Personal Data collected by Betegy other than Personal Data collected through the Services and the Site or in relation to provision of Services via the Site. This Privacy Policy shall not apply to any unsolicited information you provide to Betegy through the Services or through any other means. This includes but is not limited to, information posted to any public areas of the Services, such as forums, any ideas for new products or modifications to existing products, and other unsolicited submissions (collectively, “Unsolicited Information”). All Unsolicited Information shall be deemed to be non-confidential, and Betegy shall be free to reproduce, use, disclose, and distribute such Unsolicited Information to others without limitation or attribution.
[3.3.] Children:
Betegy does not knowingly collect Personal Data from children under the age of 13. If you are under the age of 13, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a child under the age of 13 has provided Personal Data to Betegy through the Services, please contact us, and we will endeavor to delete that information from our databases.
[3.4.] Links To Other Websites:
This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated or controlled by Betegy (the “Third Party Sites”). The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Betegy endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
[3.5.] Integrating Third-Party Services:
One of the features of the Service is that it integrates information from various third-party services like Facebook (“Third Party Service(s)”). To take advantage of the Services, you will need to provide your login credentials for each Service that you connect to. When you add a Third Party Services account to the Service, we will collect relevant information necessary to enable the Service to access that Third Party Service and your data contained within that Third Party Service. As part of such integration, the Third Party Service will provide us with access to certain information that you have provided to the Third Party Service, and we will use, store, and disclose such information in accordance with this Privacy Policy. However, please remember that the manner in which Third Party Services use, store, and disclose the policies of such third parties govern your information, and Betegy shall have no liability or responsibility for the privacy practices or other actions of any Third Party Services that may be enabled within the Service.
[3.6.] Security:
Betegy takes reasonable steps to protect the Personal Data provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error-free. In particular, emails sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Data to Betegy via the Internet.
[4] Changes To Betegy’s Privacy Policy:
The Services and our business may change from time to time. As a result, at times, it may be necessary for Betegy to make changes to this Privacy Policy. Betegy reserves the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
Betegy is committed to protecting and respecting your privacy, and we’ll only use your personal information to administer your account and to provide the products and services you requested from us. From time to time, we would like to contact you about our products and services, as well as other content that may be of interest to you.
[5] Access To Information; Contacting Betegy:
Please feel free to contact us if you have any questions about Betegy’s Privacy Policy or the information practices of the Services.
Topiel 23
00-342 Warszawa, Poland
