PRIVACY POLICY

Caring for the personal data of users of the Press Glass website / Press Glass Mobile application and respecting their right to privacy, Press Glass Holding S.A. (hereinafter referred to as: the “Controller” and/or „Press Glass”) with its registered office at ul. Golfowa 19, 42-274 Konopiska, Konopiska commune, entered into the National Court Register by the District Court in Częstochowa, 17th Commercial Division of the National Court Register under number 0000131477, using Tax Identification Number NIP 574-000-74-96 and Business Statistical Number REGON 150021158, share capital of PLN 502 000 (in words: five hundred two thousand zlotys 00/100), paid in full, represented by the Management Board – in accordance with a valid legal authorisation – is the Controller of personal data collected via www.pressglass.com website / the Press Glass Mobile application.

§ 1 Privacy Policy Standards

1. Press Glass attaches importance to whether users using the www.pressglass.com website / Press Glass Mobile application – hereinafter referred to as the “mobile application” are confident that their personal data is protected in a reliable and lawful manner, therefore, Press Glass is taking steps to properly secure information about people coming to this place. Not only does it guarantee the standards adopted by law, but also systematically works on raising them.

2. The adopted Privacy Policy is fully reflected in the applicable law, because it includes regulations resulting, inter alia:

  • from 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 (General Data Protection Regulation – OJEU L of 2016, No. 119, item 1) – hereinafter referred to as the GDPR,
  • from the Personal Data Protection Act of 10 May 2018 (Journal of Laws 2018, item 1000),
  • from the Act of 18 July 2002 on rendering electronic services (Journal of Laws 2018, item 650),
  • from the Act of 16 July 2004 – Telecommunications Law (consolidated text, Journal of Laws 2014, item 243, as amended),
  • from Article 22 1 of the Act of 26 June 1974, Labour Code (Journal of Laws 2018.0.917),

thus, fulfilling the principle of legality of actions undertaken within the framework and limits set out by applicable provisions of law at the time of their application.

3. This Privacy Policy is intended to inform all users of the website / Press Glass Mobile application how Press Glass processes personal data through the above-mentioned website and mobile application (to what extent and for what purpose, and what is the legal basis for the processing of personal data), when it can pass it on to third parties, what means of protection of this data against falling into unauthorised hands it applies and what can a user do if it is not fully satisfied with the methods of protection applied.

§ 2 Scope of the Privacy Policy

1. The Privacy Policy applies to the website located at the Internet address www.pressglass.com in language versions (i.e. English international version, German, French, Croatian, Italian, Polish, Swedish, British English and American English), as well as the above-mentioned language versions in the Press Glass Mobile application, available on the Google Play store (https://play.google.com/store/apps/details?id=eu.pressglass&hl=pl) and the App Store (https://itunes.apple.com/pl/app/press-glass-mobile/id773201326?mt=8&ls=1).

2. Press Glass publishes on the aforementioned website links to other websites that include, among others, projects with the company’s participation. While Press Glass is committed to achieving the highest standards in the field of personal data protection and the right to privacy, it cannot guarantee that the owners (controllers) of linked websites are guided by the same rules, since Press Glass has no influence on their privacy policies and policies regarding cookies. Therefore, the company recommends that users should each time read the rules applicable on the websites to which links are provided on this website.

3. As a rule, Press Glass does not provide space on its website / mobile application to other entities, e.g. for advertising or announcement purposes. However, if such situation arises, Press Glass, as in the case referred to in sec. 2, shall not be able to ensure that the owners (controllers) of the indicated websites comply with applicable provisions of law and duly care about the safety of users’ data. In this case, you also need to read the privacy policy and Cookies policy presented on these websites and their mobile applications.

§ 3 Personal Data

Personal data is all information that can identify the user of the www.pressglass.com website / Press Glass Mobile application for example, first name and surname, telephone number, e-mail address. The words “to process” or “processing” used by Press Glass shall mean all activities and operations performed on the user’s personal data (e.g., storage of data) in the scope of the above-mentioned website / mobile application.

§ 4 Principle of Voluntariness and Accountability

1. The use of the www.pressglass.com website / Press Glass Mobile application is voluntary. It is the user who decides himself or herself whether he or she wants to use the Press Glass website / mobile application and the services provided through it. Providing by the user his or her personal data to Press Glass using forms and other technical methods developed in the scope of the above-mentioned website / mobile application is voluntary, however, in order to use some services, e.g. registration in the process of recruitment organized by Press Glass, it is necessary to provide personal data, about which the user is always informed by Press Glass in advance.

2. Any person who has provided his or her personal data to Press Glass as the Controller may request to obtain access to it, to correct, update or rectify it, to limit its processing, suspend temporarily or permanently its processing, delete it or transfer it, that is, indicate the entity to which Press Glass, on behalf of the user, shall send its personal data. Everyone has the right to object against the processing of his or her personal data by Press Glass free of charge. Everyone has the right to submit a complaint to the supervisory body against actions taken by the Controller of the www.pressglass.com website / Press Glass Mobile application Assistance can also be found at https://uodo.gov.pl/en/p/data-protection-authorities or https://edpb.europa.eu/edpb_en

In Poland, the supervisory body is the President of the Office for Personal Data Protection in accordance with the Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000).

§ 5 Purpose and Duration of Personal Data Processing

1. As the Controller, Press Glass may process the following personal data of users:

  • first name and surname,
  • address (mailing address (residence address), postal code, city, province, region, country),
  • phone number,
  • e-mail address,
  • information about the connection parameters (websites from which the user enters the Controller’s website, IP address, date and time of access, the amount of data transferred, information about the browser used and the operating system).

2. Information listed in § 5 sec. 1 shall be used to undertake activities within the administration of the website, mobile application, to analyse traffic statistics, detect and solve problems of the website / mobile application, analyse the safety of the website / mobile application, analyse abuse reports. Information on the users’ IP can be transferred to authorized state authorities at their request, for the needs of proceedings conducted by them, on the basis of applicable laws, or to third parties on the basis of decisions of state authorities, and for the purpose of profiling users – any form of automated processing of personal data for the assessment of certain personal factors (e.g. preferences, interests, locations).

3. In the case of the recruitment of employees, Press Glass Holding S.A. has the right to process the following type of personal data during the recruitment process – legal basis: Article 6 sec. 1(a) and sec. 1(b) of the GDPR:

  • first name and surname,
  • address (street and house / flat number / mailing address, postal code, city, province, region, country),
  • phone number,
  • e-mail address,
  • date of birth,
  • information regarding education,
  • information about the course of employment,
  • image of the user – the candidate – with his or her consent – legal basis: Article 6 sec. 1(a) of the GDPR

Optionally: (depending on the requirements for a given job) the following data may also be processed:

  • additional rights/qualifications (e.g. knowledge of foreign languages, operation of machinery/equipment, driving license etc.) – legal basis: Article 6 sec. 1(a) of the GDPR,
  • experience in a similar position – legal basis: Article 6 sec. 1(a) of the GDPR.

4. Personal data of the users of the www.pressglass.com website/ Press Glass Mobile application shall be processed for the purposes of:

  • publication of contents posted via the above-mentioned website / Press Glass Mobile application – legal basis: Article 6 sec. 1(f) of the GDPR,
  • contacting the user: these data are necessary for purposes directly related to the functioning of the above-mentioned website / Press Glass Mobile application, for example, in order to submit commercial, promotional information presented to the user in the form of advertisement and other marketing activities via www.pressglass.com / mobile application (personal data being processed: first name and surname, e-mail address) – legal basis: Article 6 sec. 1(a) and sec. 1(b) of the GDPR,
  • sending to the user appropriate technical documentation in the scope of products and services presented by Press Glass via the www.pressglass.com website/ Press Glass Mobile application (personal data being processed: first name and surname, e-mail address) – legal basis: Article 6 sec. 1(b) of the GDPR,
  • contacting the user to enable him or her to participate in the recruitment process conducted by and for Press Glass in the scope of the recruitment for a vacant post, including via www.pressglass.com – legal basis: Article 6 sec. 1(a) in conjunction with Article 22 1 of the Labour Code.

5. Press Glass also processes personal data for the purposes set out below, based on a legitimate interest, i.e.:

  • to ensure the security of services that it provides electronically, including enforcement of the rules provided for by law and the prevention of fraud and abuse, as well as to ensure traffic safety on the aforementioned website / mobile application (personal data being processed: e-mail address) – legal basis: Article 6 sec. 1(c) and sec. 1(d) of the GDPR,
  • to conduct research and analyses of the website / Press Glass mobile application, among other things, in terms of functionality, improvement of the operation of services, or estimation of the main interests and needs of visitors – legal basis: Article 6 sec. 1(f) in conjunction with Article 22 of the GDPR,
  • analysis of received abuse reports and establishing contact with the user in order to identify and remove violations – legal basis – Art. 6 sec. 1(f) of the GDPR
  • to handle requests from users submitted via the contact form in a situation where they are not directly related to the performance of the agreement – legal basis: Article 6 sec. 1(f) of the GDPR,
  • to conduct statistical analyses – legal basis: Article 6 sec. 1(f) of the GDPR in conjunction with Article 22 of the above Regulation,
  • to perform legal obligations imposed on the Controller – legal basis: Article 6 sec. 1(c) of the GDPR,
  • to establish, defend and pursue claims – legal basis – legally justified interest pursued by the Controller consisting in conducting business activity – Article 6 sec. 1(f) of the GDPR,
  • to collect personal data for archival purposes and ensure compliance with the accountability principle (showing that Press Glass meets its obligations under the law) – legal basis: Article 6 sec. 1(f) and Article 6 sec. 1(f) in conjunction with Article 22 of the GDPR.

6. On the basis of the consent of the user and only if the user provides the consent (including after obtaining the consent of legal representatives in the case of a person who is under 16 years of age), Press Glass shall process personal data for the purposes of:

  • saving data in Cookies and collecting data from the pages of the www.pressglass.com website / Press Glass Mobile application related to user profiling – legal basis: Article 6 sec. 1(a) of the GDPR in conjunction with Article 22 of the above Regulation,
  • maintenance and improvement of the functioning of the www.pressglass.com website / Press Glass Mobile application, including data collected automatically in the course of user visits, e.g. IP address, domain name, browser type, operating system type – Article 6 sec. 1(a) of the GDPR in conjunction with Article 22 of the above Regulation,
  • sending notifications (so-called push push) – short messages displayed to the user of the www.pressglass.com website / the Press Glass Mobile application in the corner of the computer screen or in the notifications of the phone/mobile device, to which the user has previously consented within the selected web browser when staying on the www.pressglass.com website or the Press Glass Mobile application – legal basis – Article 6 sec. 1(a) in conjunction with Article 22 of the GDPR,

7. If the user is under 16 years of age, Press Glass may not process his or her personal data in accordance with the law (Article 8 of the GDPR) in the scope of marketing consents granted – for example, in order for the user to receive to his or her e-mail address information about competitions, promotional campaigns organised by Press Glass, unless the consent previously expressed by the user is confirmed by a person having legal custody over him or her or consent is granted to Press Glass by legal representatives on behalf of and for the user who has not completed the above-mentioned age at the time of granting the consent for the processing of this data.

8. If the legal representatives do not confirm the consent to the processing of personal data of the user referred to in § 5 sec. 7 of this Policy to the e-mail address: gdpr@pressglass.com, Press Glass shall refrain from marketing activities with respect to such user.

§ 6 Access to and Security of Personal Data

1. Press Glass as the controller of personal data processed via the www.pressglass.com website or the Press Glass Mobile application, informs that it takes and applies technical and organizational measures that ensure protection of personal data processing appropriate to the threats and categories of data subject to protection, and in particular, protects data from being made available to unauthorised persons, being taken away by an unauthorized person, its processing in violation of applicable laws and its change, loss, damage or destruction. Due to the cooperation of the Controller with its affiliates and service providers established outside the EEA, personal data of users may be transferred outside the European Economic Area.

2. Personal data of the users of the www.pressglass.com website / Press Glass Mobile application may be transferred to the USA in the scope of support of the above-mentioned website / application. Based on appropriate legal safeguards, which are standard contractual clauses for the protection of personal data approved by the European Commission, including actions in accordance with Article 28 of the GDPR, as well as due to the fact that, in relation to the above-mentioned Country, the European Commission on 12 July 2016 adopted a decision on the appropriate protection of personal data (EU-US Privacy Shield Program), which allows the transfer of personal data of EU citizens, while ensuring an adequate security standard of the above-mentioned procedures, personal data of users of the Press Glass website / Press Glass Mobile application are properly protected.

3. At any time, Press Glass may provide the user with additional explanations regarding the transfer of personal data, in particular, when the issue raises his or her concern.

4. Press Glass, as the controller of personal data, may entrust another entity with the processing of personal data, but it may do so only for the purpose and to the extent specified in the agreement.

5. Press Glass, in order to conduct promotional activities, adapt the website / mobile application to the expectations of users, as well as position the www.pressglass.com website in available search engines, shall use tools and technologies offered by external suppliers, such as Google and Facebook, Lead Forensics Limited, using Google Analytics in the field of remarketing, reports on displays on the Google Display Network, integration with the DoubleClick platform, reports on interest and demographic data of users of the aforementioned website / Press Glass Mobile application, as well as conducting via Facebook, Instagram, Pinterest, Linkedin advertising campaigns that are based on the interests and location of its users.

6. When conducting marketing activities, Press Glass does not collect data allowing the identification of people. On the basis of the marketing tools used, it creates and analyses recipient groups, which, however, do not constitute data allowing the identification of personal data. Press Glass can address – target advertisement to target groups, profile recipients and analyse marketing metrics using the Cookies technology.

7. Press Glass informs that, when conducting promotional campaigns, it does not use the so-called sensitive data that could identify: sexual orientation and/or sexual preferences, ethnic and racial information, political and trade union affiliation, ideological and/or religious affiliation, property status, health of the user of the www.pressglass.com website / Press Glass Mobile application.

8. Press Glass informs that it may conduct surveys among users of the above-mentioned website / mobile application to get profile data (e.g. age, education, profession, earnings information). Filling out the survey and disclosing data indicated in it is always voluntary. In each case, the surveys are processed anonymously and serve to create a collective image of users using the website / mobile application.

§ 7 Duration of Personal Data Processing

1. In accordance with applicable law, Press Glass Holding S.A. does not process users’ personal data “indefinitely”, but for the time that is needed to achieve the designated purpose of personal data processing. After this period, personal data shall be permanently removed or destroyed.

2. In the situation where there is no need to perform operations on users’ personal data other than storing them until they are permanently deleted or destroyed, personal data shall be additionally secured – through pseudonymisation. Pseudonymisation consists in such encryption of personal data or a personal data set that it is impossible to read them without an additional key, and thus, such information becomes completely useless to an unauthorized person.

3. Regarding individual periods of personal data processing, we kindly inform that we process personal data:

  • until the personal data become obsolete or lose validity, however, no longer than for one year with regard to the personal data: in the form of an IP address, domain name, browser type, operating system type, processed for the purpose of maintenance and operation of the www.pressglass.com website / Press Glass Mobile application, including data collected automatically in the course of users’ visits on the aforementioned website / mobile application,
  • until the consent is withdrawn or the purpose of the processing is achieved, however, no longer than until claims under the law of the relevant EU country have expired (the period of limitation on the validity of claims can be checked at: https://beta.e-justice.europa.eu/home?init=true&action=home&plang=en) in relation to personal data obtained in the scope of the user’s consent to the processing of his or her personal data, including data obtained in the profiling process,
  • until the consent is withdrawn or the purpose of the processing is achieved, however, no longer than until claims under the law of the relevant EU country have expired (the period of limitation on the validity of claims can be checked at: https://beta.e-justice.europa.eu/home?init=true&action=home&plang=en) in relation to the user’s consent granted in the recruitment processes organized by and for Press Glass,
  • in connection with the prevention of abuse and fraud, for statistical and archiving purposes, from the date of termination of the agreement or event necessitating such processing until claims under the law of the relevant EU country have expired (the period of limitation on the validity of claims can be checked at: https://beta.e-justice.europa.eu/home?init=true&action=home&plang=en).

4. At the same time, in order to implement the accountability principle, Press Glass stores personal data for the period in which the Company is obliged to maintain data or documents containing them for the purpose of documenting the fulfilment of legal requirements, including enabling control of their fulfilment by public authorities.

5. Periods in years are counted from the end of the year in which Press Glass began processing personal data. Separate term counting for each event would entail significant organizational and technical difficulties, as well as significant financial effort, so setting one date for removing or destroying personal data allows for more efficient management of these processes by Press Glass. Of course, if the user uses the right to be forgotten, such situations are considered individually.

§ 8 Users’ Rights in the Scope of Personal Data Protection

1. Press Glass guarantees users to respect all of their rights under the General Data Protection Regulation, commonly referred to as the GDPR, and the provisions of Polish law concerning the processing of personal data:

  • access to personal data,
  • information about the processing of personal data,
  • rectifying personal data,
  • deletion of personal data,
  • restriction of the processing of personal data,
  • objection to the processing of personal data,
  • transfer of personal data (at the user’s request, within a month the user shall receive from Press Glass a file with data in a structured, commonly used, machine-readable format. Under this right, the user can also indicate an entity to which Press Glass should send his or her data,
  • the right to object to the profiling of personal data – not being subject to automated decision-making.

2. Press Glass indicates that these rights are not absolute and, therefore, may be legally refused in certain situations. However, a decision of refusal shall be taken by Press Glass only if the refusal to meet the request is necessary.

3. As regards the right to object, Press Glass explains that the user has the right to object to the processing of his or her personal data on the basis of a legitimate interest of the Controller of personal data, due to a special situation of the user. In accordance with regulations, Press Glass may refuse to take into account the objection if it proves that:

  • there are legitimate grounds for processing that override users’ interests, rights and freedoms or,
  • there are grounds for establishing, pursuing or defending claims.

4. Furthermore, at any time, the user may object to the processing of his or her personal data for marketing purposes. In this situation, after receiving objection, Press Glass shall cease processing data for this purpose.

The user can exercise his or her rights by:

  • sending a written message directly to the address of Press Glass Holding SA headquarters at ul. Golfowa 19 in Konopiska, 42-274 Konopiska, Konopiska commune, Poland or to e-mail address: gdpr@pressglass.com,

§ 9
Cookies

1. Cookies are files that are saved and stored on the user’s computer, tablet or smartphone, or another device used to access the Internet during the visit to the www.pressglass.com website. Information on Cookies also applies to other similar technologies used within the above-mentioned website or mobile application.

2. The entity placing Cookies on the user’s device and having access to them is the Controller, Press Glass Holding S.A., with its registered office at ul. Golfowa 19, 42-274 Konopiska, Konopiska commune, entered into the National Court Register by the District Court in Częstochowa, 17th Commercial Division of the National Court Register under number 0000131477, using Tax Identification Number NIP 574-000-74-96 and Business Statistical Number REGON 150021158, share capital of PLN 502 000 (in words: five hundred two thousand zlotys 00/100), paid in full, represented by the Management Board – in accordance with a valid legal authorisation.

3. Cookies shall be used by Press Glass to adapt the content of the pages of the website to the preferences of users and the best possible method of use of the pages of the aforementioned website by the users. Cookies allow to recognise the user’s device and display pages tailored to his or her individual needs. As the controller, Press Glass can also create statistics based on them, which help to understand how website users use the pages of the www.pressglass.com website. This allows Press Glass to improve their structure and content. These files also provide the ability to provide users of the above-mentioned website with advertising content that takes into account their needs and interests.

The controller uses the following Cookies via the website / mobile application:

  • session cookies – are data necessary to maintain the session under the current activities of the website’s users. This information is stored only in the user’s end device’s operating memory and remains there until the session is terminated – the website is closed or the web browser is turned off.
  • permanent cookies – are information that is stored between the user’s visits on the website. These files can be collected in order for Press Glass to recognize how the user uses the website, types of his or her preferences, number of visits and duration of visits. This information does not record specific personal data of the user, but it is used to analyse the statistics of the website use.

In the case of the Press Glass Mobile application with tools that are located on the www.pressglass.com, website, the mobile application can also remember the above-mentioned Cookies within the offered tools.

4. The Controller uses in particular the following Cookies:

5. Users of the www.pressglass.com website can make changes to the Cookies settings at any time. These settings can be changed, in particular in such a way as to block the automatic handling of Cookies, in the web browser settings (e.g. Safari, Firefox, Internet Explorer, Chrome, Opera), or inform them about each placement on the device of the website’s user. Details on the possibilities and methods of managing Cookies are available in the software settings (of a specific web browser). Users can also change the settings related to the automated profiling activities directly on the website on the GDPR Friendly Settings tab located at the bottom of the website, next to this Privacy Policy.

6. Failure to change the settings in the scope of Cookies means that they will be placed in the user’s end device, and thus, Press Glass, as the Controller, will have the right to store information about the user’s end device and access this information.

7. Disabling the use of Cookies may cause difficulties in using certain services on the aforementioned website, in particular requiring, for example, logging in or sending messages to Press Glass. On the other hand, disabling the option of accepting Cookies does not mean that you cannot read or view the contents posted on the www.pressglass.com website, except for those for which login access is required.

8. Personal data collected by Press Glass as the Controller via www.pressglass.com or using the Press Glass Mobile application is protected by means of security procedures as well as technical and organisational tools and measures.

§ 10
Change of Policy

1. Over time, circumstances may arise that will make it necessary to change this Privacy Policy. Most often they will be linked to:

  • technological progress,
  • change in the way of using the website,
  • change of applicable regulations,
  • introduction of new legal regulations,
  • decisions of public authorities, e.g. court decisions etc.

2. Bearing in mind the above circumstances, this Privacy Policy is updated on an ongoing basis, in accordance with regulations applicable in the Republic of Poland and the European Union. Users will be informed about any changes to the Privacy Policy on the www.pressglass.com website / Press Glass Mobile application.

3. In the scope not covered by this Privacy Policy, the regulations on the protection of personal data provided for by Polish and EU legislation shall apply.

4. This Privacy Policy shall apply from 25 May 2018.

§ 11 Contact with the Website Controller

1. The User may, at any time, contact the Controller of the www.pressglass.com website / Press Glass Mobile application to obtain information on whether and how Press Glass uses or intends to use his or her personal data.

2. The User may also contact the Controller of the website / mobile application to exercise his or her rights referred to in § 8.

3. E-mail address at which the Controller can be contacted is: gdpr@pressglass.com, and telephone number: +48 34 327 50 69.

4. The Controller has appointed a Data Protection Officer.
The Data Protection Officer can be contacted directly by electronic means at the following e-mail address: iod@pressglass.com or by phone at: +48 602 638 231.