Privacy Policy

Information Obligation under Art. 13 of the GDPR

Information obligation pursuant to Article 13 of Regulation (EU) 2016/679 of the European Parliament and of the Council 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) of 27 April 2016 (OJ EU L 119, p. 1), hereinafter referred to as the “GDPR”.

This Policy describes the principles of personal data processing regarding processes carried out via the website www.migramate.pl, ensuring the security and diligent use of such data.

1. Who is the controller of your personal data?

The Controller, i.e., the entity deciding on the purposes and means of processing personal data, is MigraMate spółka z ograniczoną odpowiedzialnością with its registered office in Lublin at the address: ul. Jasna 6/13, 20-077 Lublin, entered into the Register of Entrepreneurs of the National Court Register kept by the District Court Lublin-Wschód in Lublin with its seat in Świdnik, VI Commercial Division of the National Court Register under KRS number: 0001163710, NIP: 7123490726, REGON: 541257579 (hereinafter as: “Controller”).

The Controller is not required to appoint a Data Protection Officer.

In matters related to the processing of your personal data by the Controller, you may contact us via:

2. Where do we get your personal data from?

We received it from you during your visit to the website www.migramate.pl, in particular while sending a message through the contact form, subscribing to the newsletter, as well as while expressing and sharing your opinions about the services provided by the Controller.

3. What is the purpose, scope, legal basis, and period of processing your personal data?

Purpose Scope of data Legal basis Processing period
Ensuring access to the website www.migramate.pl and its proper functioning (cookies); website management
  • IP address
  • technical data of the device
  • data regarding activity in the Service
 Art. 6(1)(f) GDPR – legitimate interest of the controller consisting in maintaining the website Until a successful objection to the data processing is submitted; this period may be extended if the processing is necessary to establish and pursue potential claims or defend against them; data from cookies in accordance with the settings of the browser or consent management tool.
Preparation of an offer, conclusion of a contract, provision of legal consultation and advisory services
  • first name and surname
  • PESEL number
  • number of ID card / passport / other identity document
  • address
  • e-mail address, telephone number
  • any other personal data provided in connection with the provision of services based on a contract
 Art. 6(1)(b) GDPR – processing is necessary to take steps at the request of the data subject prior to entering into a Contract and Art. 6(1)(f) GDPR – legitimate interest of the controller For the duration of the contract or its individual provisions and obligations, and after the end of this cooperation for a maximum period until the expiry of the limitation periods for potential claims, i.e., for a maximum of 3 or 6 years from the end of the calendar year in which the data was provided based on Art. 118 of the Civil Code.
Contact – providing an answer to an inquiry / submission from the contact form
  • first name
  • e-mail address, telephone number
  • possibly other personal data provided (voluntarily) in the message content
 Art. 6(1)(b) GDPR – processing is necessary to take steps at the request of the data subject prior to entering into a Contract – if the contact leads to the conclusion of a contract; Art. 6(1)(f) GDPR – legally justified interest of the Controller consisting in maintaining communication with Users and handling inquiries For the time necessary to carry out the contact and provide an answer to the inquiry contained in the contact form; after this time, the data may be stored by us until the establishment and pursuit of potential claims.
Marketing – sending the newsletter
  • first name and surname
  • e-mail address
 Art. 6(1)(a) GDPR and Art. 398 of the Act of July 12, 2024 – Electronic Communications Law – consent of the data subject expressed within the Service or in another way; Art. 6(1)(f) GDPR – legitimate interest of the controller consisting in sending materials to former and current clients Until the withdrawal of previously granted consent (provided that personal data processing takes place on the basis of Art. 6(1)(a) GDPR); until the data loses its usefulness in terms of sending the Newsletter; until an objection is submitted by the data subject (provided that personal data processing takes place on the basis of Art. 6(1)(f) GDPR).
Posting opinions / testimonials / references about services provided by the Controller
  • first name
  • country of origin
  • image (photo)
 Art. 6(1)(a) GDPR – consent of the data subject Until the withdrawal of previously granted consent.

Processing based on a “legitimate interest” includes:

  • monitoring your activity including e.g., searching for keywords;
  • analysis of data collected automatically when using the website;
  • conducting marketing activities towards you, including direct marketing in accordance with applicable law;
  • contacting you, including for purposes related to permitted marketing activities, through available communication channels, in particular by e-mail or telephone;
  • ensuring the security of the services we provide to you electronically, including enforcing internal rules and preventing fraud and abuse;
  • pursuing claims or defending against potential claims, including conducting court, arbitration, mediation, and enforcement proceedings;
  • storing data for archiving purposes, and ensuring accountability (demonstrating fulfillment of our legal obligations).

If your data is processed by us based on our legally justified interest – you have the right to object to the use of the data – i.e., the right to object at any time to our use of your personal data.

If you give your consent, we process your personal data for the purpose of:

  • saving data in cookies, collecting data from websites and mobile applications,
  • sending the newsletter and other marketing content,
  • placing opinions / testimonials / references on the website.

If the legal basis for processing your data is consent, you have the right to withdraw this consent at any time. This right can be exercised by sending an appropriate request to the Controller to the details provided above.

Withdrawal of consent does not affect the lawfulness of processing that took place before its withdrawal.

4. Data Recipients

We may share your personal data with the following categories of entities:

  • entities that support us in providing services as part of current activities, including employees, associates, contractors;
  • entities that provide us with accounting (financial – book-keeping – tax), administrative, advisory, and consultation services;
  • entities that provide us with IT services, e.g., hosting providers, providers of software needed to run the website;
  • as well as other entities to which the Controller shares data based on a legal obligation or based on a concluded personal data processing agreement (so-called processing entities).

We transfer your data in particular to:

We ensure that in a situation of further transfer of your personal data, it takes place only within legally permitted limits, based on data processing agreements concluded by the Controller with third parties or under an authorization to process data.

5. Your Rights

If the relevant legal conditions are met, in addition to the right to withdraw the consents granted to us, you are also entitled to the following rights:

  • right to access data – i.e., the right to obtain confirmation from us whether data is being processed by us.
  • right to rectify data – i.e., the right to obtain access to personal data and obtain information, among others, about the source of its origin, the purposes for which it is processed by us, about the categories of processed data, about its recipients, the planned period of processing and storage of data by us or about the criteria for determining this period, and about the entitled rights.
  • right to erase data (“right to be forgotten”) – i.e., the right to request the deletion of all or some data; please remember, however, that despite this, we may keep certain personal data to the extent necessary to establish, pursue or defend against potential claims.
  • right to restrict data processing – i.e., the right as a result of which, until the request is considered, you will not have the possibility to use certain functionalities or services, the use of which involves the processing of personal data. In this case, no communications will be sent to you, including marketing communications.
  • right to data portability – i.e., the right to receive from us personal data that has been provided to us, in a commonly used IT format.
  • right to object to the use of data – i.e., the right to object at any time to our use of personal data, if the data is processed by us based on our legally justified interest.
  • right to withdraw consent for the processing of personal data – i.e., the right to withdraw each consent submitted for the processing of personal data by us. Withdrawal of consent will have an immediate effect from the moment of its withdrawal. At the same time, we indicate that although withdrawal of consent does not entail any negative consequences, it may nevertheless prevent the use of full services or functionalities that we can provide only with consent.
  • right to lodge a complaint with a supervisory authority (in Poland – to the President of the Personal Data Protection Office, address: ul. Stanisława Moniuszki 1A, 00-014 Warsaw).

6. International Transfers

The Controller does not intend to transfer your personal data to Third Countries (countries outside the European Economic Area) or international organizations (organizations and bodies subordinate to it acting on the basis of public international law or other bodies established by an agreement between at least two countries or on the basis of such an agreement).

However, some types of personal data processing result in the transfer of data to servers working on behalf of IT technology providers. Some of these servers are located in the USA, e.g., Google, Facebook, Instagram.

In the event that the Controller entrusts the processing of personal data to an entity outside the European Economic Area or concludes an agreement with an entity transferring personal data outside the European Economic Area, the Controller will ensure that the transfer of personal data will take place with the use of appropriate safeguards, in particular: the agreement will contain standard data protection clauses adopted by the European Commission or the transfer of personal data will take place on the basis of a decision of the European Commission stating an adequate level of protection.

More information on how the entities use your data can be found in their privacy and cookie policies, for example:

7. Automated Processing

Your personal data will not be processed in an automated manner, including through profiling.

8. Plugin

The website www.migramate.pl contains plugins to the following services:

  • Facebook
  • Instagram
  • LinkedIn
  • YouTube

The Facebook, Instagram, LinkedIn, YouTube plugin on the website is marked with the Facebook, Instagram, LinkedIn, YouTube logo. This plugin will directly connect you with the service. The services may then obtain information that you are visiting the website from your IP address. If you visit our website while being logged in to your social media profiles, then information about your visit will be registered in these social media services.

9. Facebook and Instagram

In the event of your visit to the MIGRAMATE profile on Facebook or Instagram and the initiation of contact (communication) using the tools available on the indicated profiles, personal data obtained in connection with this communication will be processed as part of co-administration of personal data respectively by the Controller and the Facebook portal or the Instagram portal.

The Controller will process your personal data in order to conduct communication with you and conduct marketing activities – the legal basis for processing is Art. 6(1)(f) GDPR.

The data will be processed until an objection to the processing of personal data is submitted.

10. Cookies

If you visit our website, collected information called cookies is: “cookies” files. Apart from necessary cookies (which contribute to the usability of the website by enabling basic functions such as site navigation, session maintenance – the website cannot function properly without these cookies), the Controller allows the user to choose cookies such as: cookies for statistics and analytics (which allow analyzing traffic on the site, optimize site performance, study user behavior) and marketing cookies (used to track users on websites to personalize ads).

The Controller collects necessary cookies in order to enable the use of basic functionalities of the website. The legal basis for the processing of personal data is Art. 6(1)(f) GDPR, i.e., the legally justified interest of the Controller.

The data will be processed until an objection to the processing of personal data is submitted.

Statistical, analytical and marketing cookies will be processed only if you express your consent by clicking permission for a choice and then making a choice of cookies or permission for all.

At any time, you can resign from selected cookies by going to the internet browser settings and deleting given cookies and website data.