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Privacy policy

effective as of May 25, 2018

I. Basic goals of the privacy policy

  1. This Privacy Policy applies to the processing and protection of Users' personal data in connection with the use of the www.wsb-nlu.edu.pl website and www.wsb-nlu.clouda.edu.pl website (hereinafter referred to as "Website"), in including all their subpages administered by the Wyższa Szkoła Biznesu/ Business School/- National Louis University with registered office in Nowy Sącz, ul. Zielona 27, 33- 300 Nowy Sącz, NIP/ TAX IDENTIFICATION NUMBER/: 734-10-03-635, REGON National Business Registry Number: 490028409 (hereinafter referred to as "Administrator" or "WSB-NLU").
  2. The privacy policy contains the rules on the collection and use of data of its users (hereinafter referred to as "Users") in the Website, collected during the use of the Website.
  3. The overriding objective is to provide the Website Users with privacy protection at least at the level defined in the applicable legal regulations, in particular in compliance with the provisions of Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data; and the repeal of Directive 95/46 / EC (the General Data Protection Regulation/ Personal Data Protection Act, hereinafter referred to as "the RODO").

II. Objectives, purposes and basis for data processing on the Website

II.I. Using the Website - general rules

  1. Personal data of persons using the Website are processed by the Administrator, in particular for the purposes of:
    • providing the service of running and servicing the User's account in the CloudA system - the legal basis for data processing is the necessity of processing to perform the contract (Article 6 paragraph 1 letter b) of the RODO), and in the field of data provided optional - the legal basis for processing is consent (art. 6 (1) (a) of the RODO),
    • conducting the recruitment process within the CloudA system for a chosen field of study - the legal basis for data processing is the necessity of processing to perform the contract (Article 6 (1) (b) of the RODO) and the legal obligation (Article 6 paragraph 1 lit. c) RODO) in the form of the need to implement the requirements resulting from special laws, in particular the Act of 27 July 2005 Law on Higher Education (Journal of Laws 2005 No. 164 item 1365, as amended), and in the scope of optional data - the legal basis for processing is consent (Article 6 (1) (a) of the RODO),
    • implementation of educational services and data archiving after the completion of the service - the legal basis for data processing is the necessity of processing to perform the contract (Article 6 paragraph 1 letter b) of the RODO) and the legal obligation (Article 6 paragraph 1 c) RODO) in the form of the need to implement the requirements resulting from special laws, in particular the Act of 27 July 2005 Law on Higher Education (Journal of Laws 2005 No. 164 item 1365 with later amendments),
    • examination of the graduate's fate - the legal basis for processing is consent (Article 6 (1) (a) of the RODO),
    • providing electronic services in the scope of presenting WSB-NLU offer and enabling Users to use the Website's functionality, including to the extent necessary to establish, shape, change, solve and correctly provide services provided electronically - the legal basis for data processing is the performance of the contract ( Article 6 (1) (b) of the RODO),
    • consideration of complaints / remarks, investigations and advocacy of rights in the event of mutual claims - the legal basis for data processing is the legitimate interest of WSB-NLU as the Data Administrator (Article 6 paragraph 1 letter f) of the RODO),
    • marketing and sending commercial information by electronic means - only in the event of consent by the User - the legal basis for data processing is consent (Article 6 paragraph 1 point a) of the RODO),
    • participation in the Newsletter service - only in the event of consent by the User - the legal basis for data processing is consent (Article 6 paragraph 1 letter a) RODO), further processing of data as part of the Newsletter service is based on the necessity of processing to perform the contract ( Article 6 (1) (b) of the RODO) and the legitimate interest of WSB-NLU as an Administrator (Article 6 (1) letter f) OF THE RODO), in connection with the expressed consent to receive the Newsletter,
    • contact with Users and reply to previously sent messages and queries, both directly in the form of e-mail, and by using an active chat and / or electronic contact forms - the legal basis for processing is the necessity of processing to perform the contract for the provision of services (art 6 (1) (b) of the RODO),
    • maintaining the content posted by Users (eg entries, comments) - the legal basis for processing is the necessity of processing to perform the contract (Article 6 (1) (b) of the RODO).
  2. The Administrator processes, in particular, the following Users' personal data:
    • name, possibly a middle name and surname, possibly maiden name,
    • company name,
    • NIP/ tax identification number,
    • address (street and house or apartment number),
    • zip code,
    • city,
    • country,
    • province,
    • date and place of birth - for recruitment purposes,
    • name of father and mother - for recruitment purposes,
    • PESEL/ personal ID number - for recruitment purposes,
    • series and number of the ID document - for recruitment purposes,
    • phone number,
    • e-mail address.
  3. The detailed rules for the processing of personal data for specific purposes are described in the relevant paragraphs below.
  4. The User's activity on the Website, including his personal data, is recorded in system logs (a special computer program used for storing a chronological record containing information on events and activities regarding the IT system used to provide services by the Administrator). Information collected in logs is processed primarily for purposes related to the provision of services. The administrator also processes these data for technical and administrative purposes, to ensure the security and management of the IT system, as well as for analytical and statistical purposes - in this respect the legal basis for processing is the legitimate interest of the administrator (Article 6 paragraph 1 point f) ) RODO).

II.II. Registration in the CloudA system and use of the created account

  1. Persons who register the User's account in the CloudA system are asked to provide the data necessary for its creation. Subsequently, they log in to the created account using a login and password.
  2. In order to register an account voluntary, but necessary to provide is the following personal information:
    • First name, possibly a middle name and surname, possibly maiden name,
    • Gender,
    • Date and place of birth,
    • Social Security,
    • Father's name,
    • Mother's name,
    • A contact phone,
    • E-mail address.
    • series and number of the identity document,
  3. Personal data is processed for the purposes of:
    • providing the service of running and servicing the User's account in the CloudA system - the legal basis for data processing is the necessity of processing to perform the contract (Article 6 paragraph 1 letter b) of the RODO), and in the field of data provided optional - the legal basis for processing is consent (art. 6 (1) (a) of the RODO),
    • implementation of educational services and data archiving after the completion of the service - the legal basis for data processing is the necessity of processing to perform the contract (Article 6 paragraph 1 letter b) of the RODO) and the legal obligation (Article 6 paragraph 1 c) RODO) in the form of the need to implement the requirements resulting from special laws, in particular the Act of 27 July 2005 Law on Higher Education (Journal of Laws 2005 No. 164 item 1365 with later amendments),
    • reviewing complaints / remarks, investigating and defending rights in the event of mutual claims - the legal basis for data processing is the legitimate interest of WSB-NLU as the Data Administrator (Article 6 paragraph 1 letter f) of the RODO), consisting in the protection of its rights,
    • analytical and statistical - the legal basis for processing is the legitimate interest of the Administrator (Article 6 paragraph 1 letter f) of the RODO), consisting in analyzing Users' activity on the Website and how to use the account, as well as their preferences, to improve the functionalities,
    • marketing and sending commercial information by electronic means - only if the User agrees - the rules for the processing of personal data for marketing purposes are described in the Marketing section.
  4. If the User places any personal data of other people on the Website (including their name, address, telephone number or e-mail address), they may do so only on condition that they do not violate applicable law and personal rights of such persons.

II.III. The recruitment process within the CloudA system

  1. As part of the CloudA system, it is possible to electronically recruit a candidate for a selected field of study offered by WSB-NLU.
  2. In order to make an electronic recruitment, the candidate, after selecting the course of study that interests him, provides in particular the following personal data:
    • First name, possibly a middle name and surname, possibly maiden name,
    • Date and place of birth,
    • Social Security,
    • Father and mother's name,
    • phone number,
    • address of residence,
    • address of permanent residence,
    • correspondence/ mailing address,
    • series and number of the identity document,
    • details of the completed school.
  3. Providing the above data is voluntary, but necessary to effectively enroll in the chosen field of study.
  4. Personal data is processed for the purposes of:
    • conducting the recruitment process within the CloudA system for a chosen field of study - the legal basis for data processing is the necessity of processing to perform the contract (Article 6 (1) (b) of the RODO) and the legal obligation (Article 6 paragraph 1 c) RODO) in the form of the need to implement the requirements resulting from special laws, in particular the Act of 27 July 2005 Law on Higher Education (Journal of Laws 2005 No. 164 item 1365, as amended), and in the scope of optional data - the legal basis for processing is consent (Article 6 (1) (a) of the RODO),
    • implementation of educational services and data archiving after the completion of the service - the legal basis for data processing is the necessity of processing to perform the contract (Article 6 paragraph 1 letter b) of the REDO) and the legal obligation (Article 6 paragraph 1 c) RODO) in the form of the need to implement the requirements resulting from special laws, in particular the Act of 27 July 2005 Law on Higher Education (Journal of Laws 2005 No. 164 item 1365 with later amendments),
    • consideration of complaints / remarks, investigations and defense of rights in the event of mutual claims - the legal basis for data processing is the legitimate interest of WSB-NLU as the Data Administrator (Article 6 paragraph 1 letter f) of the RODO),
    • analytical and statistical - the legal basis for processing is the legitimate interest of the Administrator (Article 6 paragraph 1 letter f) of the RODO), consisting in analyzing Users' activity on the Website and how to use the account, as well as their preferences, to improve the functionalities,
    • marketing and sending commercial information by electronic means - only if the User agrees - the rules for the processing of personal data for marketing purposes are described in the Marketing section.

II.IV. Contact by sending a query

  1. The administrator provides the opportunity to contact him by sending a request in a traditional letter, or by e-mail, as well as by using an active chat and / or electronic contact forms.
  2. Initiation of contact with WSB-NLU requires providing personal data necessary to contact the User and reply to the request. Failure to do so results in the inability to obtain an answer.
  3. Personal data is processed:
    • in order to identify the sender and handle his inquiry and reply to previously sent messages and queries - the legal basis of processing is the necessity of processing to perform the contract for the provision of services (Article 6 paragraph 1 letter b) of the RODO),
    • for analytical and statistical purposes - the legal basis of the processing is the legitimate interest of the Administrator (Article 6 (1) (f) of the RODO), consisting in keeping statistics on queries submitted by Users via the Website in order to improve its functionality.
  4. In case of using the possibility of contact using the active chat, personal data of Users are transferred for processing by Smartsupp.com, s.r.o. - details in point VI.

II.V. Marketing and advertising

  1. The administrator processes Users' personal data in order to carry out marketing activities, which may actually be:
    • displaying to the User marketing content that is not adapted to their preferences (including contextual advertising),
    • displaying to the User marketing content corresponding to his interests (behavioral advertising),
    • directing e-mail notifications about interesting content, which in some cases contain commercial information (Newsletter service),
    • conducting other types of activities related to direct marketing (sending commercial information by electronic means).
  2. In order to implement marketing activities, the Administrator in some cases uses automated activities, including profiling. This means that thanks to the automatic processing of data, the Administrator evaluates preferences in order to best match the content and offers targeted at the future.
  3. The Administrator processes Users' personal data for marketing purposes in connection with sending advertisements to Users, including contextual advertising (ie advertising that is not suited to the User's preferences). The processing of personal data for this purpose takes place in connection with the pursuit of the legally justified interest of the Administrator (Article 6 paragraph 1 letter f) of the RODO).
  4. The Administrator processes Users' personal data, including personal data collected via cookies and other similar technologies for marketing purposes, in connection with the targeting of behavioral advertising to Users (ie advertising that is tailored to the User's preferences). The processing of personal data for this purpose also includes profiling of Users.
  5. The User's personal data may also be used by the Administrator to direct marketing content to him via e-mail, SMS and other electronic communication means. Such actions are taken by the Administrator only if the User has expressed his consent in this respect, which may be withdrawn at any time. Withdrawal of consent does not affect the legality of the processing, which was made on the basis of consent before its withdrawal.

II.VI. Newsletter

  1. The Administrator provides the Newsletter service to persons who for this purpose have provided their e-mail address and / or telephone number. Providing the data is required in order to provide the Newsletter service, and failing to submit or requesting the deletion of data results in the inability to send it.
  2. Personal data is processed:
    • in order to participate in the Newsletter service - only if the User agrees - the legal basis for data processing is consent (Article 6 (1) (a) of the RODO), further processing of data as part of the Newsletter service is based on the necessity of processing to perform agreements (Article 6 (1) (b) of the RODO) and legitimate interest of the Company as an Administrator (Article 6 (1) (f) of the RODO), in connection with the expressed consent to receive the Newsletter,
    • in the case of marketing content to the User as part of the Newsletter - the legal basis for processing, including profiling, is the Administrator's interest (Article 6 (1) (f) of the RODO), in connection with the consent to receive the Newsletter,
    • for analytical and statistical purposes - the legal basis for processing is the legitimate interest of the Administrator (Article 6 (1) letter f) OF THE RODO), consisting in analyzing the Users' activity on the Website in order to improve the functionalities used,
    • to establish, investigate or defend against claims - the legal basis of the processing is the legitimate interest of the Administrator (Article 6 (1) (f) of the RODO).
  3. Details of the rules for using the Newsletter service are set out in the Regulations.

II.VII. Social networks and others

  1. The administrator processes the personal data of Users visiting the WSB-NLU profile maintained on the Social Media website. These data are processed only in connection with running a profile, including to inform Users about the activity of the Administrator, to promote the Website, as well as to provide answers to short queries sent via Facebook. The legal basis for the processing of personal data by the Administrator for this purpose is its legitimate interest (Article 6 (1) (f) of the RODO), which consists in promoting its own brand and necessity of processing to fulfill its obligations (Article 6 (1) b) RODO) to the extent that inquiries are directed through the messenger or Facebook.
  2. Notwithstanding the activities described in paragraph 1 above, WSB-NLU places "Like" and "Share" buttons linked to Facebook on the pages of its website. For this purpose, a code referring to Facebook is placed in the relevant sections and pages. By using the "Like" button or recommending an image or a page section, the User logs in to Facebook, in which the Facebook privacy policy applies. This policy can be found under neighboring links.
  3. In addition, WSB-NLU processes personal data of Users visiting profiles WSB-NLU conducted in social media such as YouTube, Instagram, Twitter, Google +, Linkedin. These data are processed only in connection with running the profile, including to inform Users about the activity of the Administrator and to promote various types of events, services and products, as well as to communicate with Users via the functionality available in social media. The legal basis for the processing of personal data by the Administrator for this purpose is its legitimate interest (Article 6 (1) (f) of the RODO), which consists in promoting its own brand and building and maintaining a brand-related community.
  4. WSB-NLU places video clips from YouTube on the website of its Website. For this purpose, the code referring to YouTube is placed in the relevant sections and pages. YouTube keeps track of video clips, and this tracking follows YouTube's privacy policy, which is available under the next link.
  5. WSB-NLU places on the pages of its website buttons for adding entries and photos on Instagram, which are linked to the Instagram website. For this purpose, the code referring to the Instagram website is placed in the relevant sections and pages. By adding an entry, the User logs in to the Instagram website, where the Instagram privacy policy applies. You can read the privacy policy under the next link.

III. Cookies and similar technology - information about Cookies

  1. WSB-NLU, using content on the Website, uses the so-called cookies, i.e. information stored in the browser, which servers can read every time you connect to this terminal device, may also use other technologies with functions similar or identical to cookies. Information on cookies also applies to other similar technologies used within our websites. Cookies usually contain the domain name of the website they come from, the time they are stored on the end device and a unique number.
  2. Cookies are used for:
    • adjusting the content of web pages to User's preferences and optimizing the use of websites,
    • creating statistics on the use of websites,
    • maintaining the user session of the website (after logging in).
  3. WSB-NLU may use the following types of cookies on its Website:
    • Essential, "necessary" cookies, enabling the use of services available on the website (including authorization),
    • cookies used to ensure security,
    • cookies, enabling the collection of information on how to use the websites of the website.
  4. The web browser may by default allow storage of cookies. Website Users can change their cookie settings at any time. Detailed information about the possibilities and ways of handling cookies are available in the web browser settings. Lack of change in settings in the field of cookies means that they will be saved in the browser's memory, and thus available to the web server.
  5. Disabling the use of cookies in the case of sites that require logging in will prevent the use of their content. In the case of public services, disabling the option of accepting cookies does not make it impossible to read or view the content posted on WSB-NLU websites.

IV. The period of personal data processing

  1. Personal data are processed and stored by the Administrator for the period necessary for the performance of the contract, and after this period for purposes and for the time and to the extent required by law or to secure any claims, until the consent is withdrawn.
  2. The data processing period may be extended if the processing is necessary to establish, investigate or defend against possible claims, as well as at the request of competent public authorities, and after that period only if and to the extent that they will require it law.
  3. After the processing period, the data is irreversibly deleted or irretrievably anonymized.

V. User's rights

  1. In particular, the User has the right to access the data and demand their rectification, deletion, processing restrictions, the right to transfer data and the right to object to the processing of data, and the extent to which User's data are processed on the basis of consent, including the right of withdrawal granted consent at any time. Withdrawal of consent does not affect the legality of the processing, which was made on the basis of consent before its withdrawal.
  2. The rights listed in paragraph 1 above, and other accrued to the User rely on:
    • The right to information about the processing of personal data - on the basis of the person submitting such a request, the Administrator provides information about the processing of personal data, primarily about the purposes and legal grounds of processing, the scope of data held, entities to which personal data are disclosed and the date of their removal;
    • The right to obtain a copy of data - on this basis, the Administrator provides a copy of the data processed concerning the person making the request;
    • The right to rectify - on this basis, the Administrator removes any non-conformities or errors regarding the personal data being processed, completes them or updates them if they are incomplete or have been changed;
    • The right to delete data - on this basis you can request deletion of data, the processing of which is no longer necessary to carry out any of the purposes for which they were collected;
    • The right to limit the processing - on this basis, the Administrator ceases to conduct operations on personal data, except for operations agreed to by the data subject and their storage, in accordance with accepted retention rules or until the reasons for limiting data processing cease to exist (e.g. a supervisory decision will be issued allowing the further processing of data);
    • The right to data transfer - on this basis, to the extent that the data is processed in connection with the concluded agreement or consent, the Administrator issues data provided by the person concerned in a format that allows their reading by the computer. It is also possible to request that data to be sent to another entity - provided, however, that there are technical possibilities in this respect both on the part of the Administrator and that other entity;
    • The right to object to the processing of data for marketing purposes - the data subject may at any time object to the processing of personal data for marketing purposes, without the need to justify such objection;
    • The right to object to other purposes of data processing - the data subject may at any time object to the processing of personal data on the basis of a justified interest of the Administrator (eg for analytical or statistical purposes or for reasons related to property protection). An objection in this respect should include justification and is subject to the Administrator's assessment;
    • The right to withdraw consent - if the data are processed on the basis of consent, the data subject has the right to withdraw it at any time, but this does not affect the lawfulness of the processing carried out prior to the withdrawal of the consent.
  3. In case of any doubts related to the processing of personal data, each person may ask WSB-NLU for information. Notwithstanding the foregoing, if it is found that the processing of personal data violates the provisions of the RODO or other provisions on the protection of personal data, the data subject has the right to lodge a complaint with the supervisory body - the President of the Office for Personal Data Protection.

VI. Recipients of data

  1. In connection with the implementation of services available on the Website, the Administrator will transfer the collected personal data to external entities, including in particular suppliers responsible for IT systems, entities such as banks and payment operators, entities providing accounting, legal, auditing, consulting, agencies marketing (in the scope of marketing services) and entities affiliated with the Administrator - under relevant agreements entrusting the processing of personal data. In this situation, the transfer of data does not entitle other entities to any processing, but only to use them for explicitly indicated purposes. In no case does the transfer of data release the WSB-NLU as the Administrator from the responsibility for their processing.
  2. In the event of consent, the data may also be made available to other entities for their own purposes, including for marketing purposes.
  3. The Administrator reserves the right to disclose information about the User to the competent authorities or third parties who submit a request for such information, based on an appropriate legal basis and in accordance with the applicable law.

VII. Transmission of data outside the European Economic Area

  1. The level of protection of personal data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, Users' personal data will be transferred outside the EEA only when it is necessary and with an adequate level of protection, primarily through:
    • cooperation with entities processing personal data in countries for which an appropriate decision of the European Commission has been issued,
    • use of standard contractual clauses issued by the European Commission,
    • applying binding corporate rules, approved by the competent supervisory authority,
    • in the event of data transfer to the USA - cooperation with entities participating in the Privacy Shield program (PrivacyShield), approved by the European Commission.
  2. The administrator always informs about the intention to transfer personal data outside the EEA at the stage of collection.

VIII. Security and safety of personal data

  1. The personal data administrator takes special care to protect the interests of the data subjects, and in particular ensures that the data is:
    • correct and processed in accordance with the law,
    • collected for marked, legitimate purposes and not subject to further processing incompatible with those purposes,
    • appropriate and not excessive,
    • accurate and current,
    • factually correct and adequate in relation to the purposes for which they are processed,
    • stored securely in a form allowing identification of persons whom they concern, no longer than it is necessary to achieve the purpose of processing,
    • processed in accordance with the rights of the persons to whom they relate, including the right to reserve access,
    • not transferred without proper protection.
  2. The personal data administrator uses technical and organizational measures to ensure the protection of personal data being processed appropriate to threats and categories of data protected, in particular, protects data from unauthorized access, unauthorized removal, processing in violation of applicable laws and change, loss, damage or destruction.
  3. The administrator conducts risk analysis on an ongoing basis to ensure that personal data is processed in a secure manner, ensuring primarily that access to data is only authorized persons and only to the extent that it is necessary due to the no tasks. The administrator makes sure that all operations on personal data are recorded and made only by authorized employees and associates.
  4. The Administrator shall take all necessary actions to ensure that its subcontractors and other cooperating entities guarantee that appropriate security measures are applied whenever they process personal data at the request of the Administrator.

IX. Contact

All questions related to the processing and protection of personal data of Website Users and the use of cookies, including those regarding this Privacy Policy, please contact:

Wyższa Szkoła Biznesu/ Business School – National Louis University
ul. Zielona 27, 33- 300 Nowy Sącz

Mail: rektorat@wsb-nlu.edu.pl

The User may also contact us in order to obtain information about whether and to what extent WSB-NLU processes User's data, about the purposes and methods of personal data processing of the Website User, and to access their personal data, correct or delete them.

X. Final provisions

  1. This version of the Privacy Policy becomes effective on May 25, 2018.
  2. The Administrator has the right to change this Privacy Policy, including due to the change in the existing provisions on the protection of personal data, the act on the provision of electronic services, telecommunications law and consumer rights, and in the situation of implementing or changing technical or technological solutions used by the Administrator, including those caused by advances in the field of internet technology. The administrator will inform about the changes by posting in the website an amended version of the Policy, preceded by sending out an appropriate message informing about the changes and the date of their entry into force.
  3. In matters not covered by this Privacy Policy, the relevant provisions of Polish law shall apply.
  4. The invalidity of any of the provisions of this Privacy Policy shall not affect the validity of the remaining provisions and this document as a whole. In such a situation, the Company undertakes to replace the invalid provision with a valid provision, in particular regarding the purpose of this document.
  5. This Policy is for information only and applies only to the Administrator's Website. If you use another site, it is recommended to read the effective privacy policy.
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