This document has been prepared to fulfill our information obligation under Article 13(1) and (2) of the GDPR in a clear and accessible manner.
The administrator of this website and your personal data is EFFECTIVITY Sp. z o.o., ul. Esperantystów 17, 58-100 Świdnica, registered in the National Court Register under KRS: 0000511111, NIP: 8842750852, REGON: 02242063000000.
The iCompose.it brand website is owned by Effectivity Sp. z o.o.
If you have any questions or concerns regarding personal data protection, please feel free to contact us:
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via email: info@effectivity.pl
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by phone: +48 790 212 276
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in writing: to the address of our headquarters.
By using the website features, subscribing to our Newsletter, or contacting us directly, you provide us with your personal data. We guarantee that your data remains confidential and secure. Within our organization, access to personal data is granted only to authorized employees bound by confidentiality obligations. We share your personal data with third parties (as defined in Article 4(9) of the GDPR) only when necessary for the proper provision of our services or functionality of the website.
Your email address may be shared with the provider of our mailing system (for the Newsletter). Data is also stored on servers operated by our hosting provider. For accounting obligations, we cooperate with a professional accounting firm. Personal data may also be shared with legal or debt collection service providers. Furthermore, your data may be disclosed to entities legally authorized to receive them.
We use analytics tools such as Google Analytics, which collect anonymized information about website visits (e.g., visited subpages, time spent). This involves the use of cookies by Google.
We also offer social media features, such as content sharing and subscribing to our profiles. These involve the use of cookies by services like Facebook, Instagram, YouTube, and LinkedIn.
We use cookies to improve your experience on our website.
Personal Data
The controller of your personal data is EFFECTIVITY Sp. z o.o., ul. Esperantystów 17, 58-100 Świdnica, Poland.
We have not appointed a Data Protection Officer. All data protection duties are handled directly by the data controller.
The purposes, legal basis, and retention periods for personal data processing are defined individually for each use case (see below).
Under the GDPR, you have the following rights:
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the right to access, rectify, delete (right to be forgotten), or restrict processing;
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the right to object to processing;
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the right to data portability;
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the right to withdraw consent at any time (if given);
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the right to lodge a complaint with a supervisory authority.
Providing your personal data is voluntary but necessary to use our services, subscribe to the newsletter, or contact us.
We ensure the confidentiality and security of your personal data, processed solely within the European Union.
Use of Services
When using the services we provide, you are required to provide personal data necessary to conclude and perform the contract, such as your full name, email address, phone number, and mailing address. You may also provide additional information, such as details about your business activity.
The legal basis for processing your personal data in this context is the performance of pre-contractual activities at your request and the subsequent execution of the contract (Article 6(1)(b) of the GDPR).
After the contract is completed, personal data will be processed until the limitation period for claims arising from the contract expires (our legitimate interest in the defense and pursuit of legal claims – Article 6(1)(f) of the GDPR).
In the case of accounting documents, the data will be stored until the end of the retention period specified by tax law regulations (Article 6(1)(c) of the GDPR – Article 86 § 1 of the Tax Ordinance Act).
Newsletter
You can subscribe to our newsletter via the website to receive updates about news, promotions, products, and services related to our online activities. To send the newsletter, we require your email address and first name.
The legal basis for processing your personal data for newsletter purposes is Article 6(1)(b) of the GDPR—that is, the processing is necessary for the performance of a contract for the provision of the newsletter service, to which you are a party.
An additional legal basis is our legitimate interest in marketing our own products and services (Article 6(1)(f) of the GDPR).
You may unsubscribe from the newsletter at any time. Your data will be processed for as long as the newsletter is in operation, unless you opt out earlier—in which case your data will be immediately removed from the mailing list.
Complaints and Withdrawal from a Contract
When submitting a complaint or withdrawing from a concluded contract, you provide us with personal data included in the content of the complaint or the withdrawal notice, such as your name, address, phone number, and email address.
The data provided in connection with submitting a complaint or withdrawing from a contract is used solely for the purpose of carrying out the complaint or withdrawal procedure (Article 6(1)(c) of the GDPR).
The data will be processed for as long as necessary to complete the complaint or withdrawal procedure.
Email Contact
When contacting us via email, you naturally provide us with your email address as the sender of the message. Additionally, the content of your message may include other personal data.
The data provided for the purpose of contacting us is processed based on your voluntarily given consent (Article 6(1)(a) of the GDPR), as well as our legitimate interest in maintaining business continuity (Article 6(1)(f) of the GDPR).
Your personal data shared with us in the course of email communication is processed solely for the purpose of handling your inquiry and maintaining further correspondence.
The data will be processed until the correspondence is concluded, and then retained for up to 3 calendar years from the date you sent your last message.
Contact Form and Chat
To make it easier for you to get in touch with us, we have provided a contact form and chat feature on our website. Using the form requires you to provide your name, phone number, company name, and email address.
The legal basis for processing your personal data in this case is Article 6(1)(a) of the GDPR—that is, the processing is based on your consent, which is given by completing the contact form or by submitting your data while using the chat feature (a clear affirmative action confirming consent).
An additional legal basis is our legitimate interest in maintaining business continuity (Article 6(1)(f) of the GDPR).
Once you send us a message via the contact form, it is delivered to our email inbox. The data will be processed until the correspondence is concluded, and then retained for up to 3 calendar years from the date you sent your last message.
Cookies and Other Tracking Technologies
Like almost all modern websites, our website uses cookies to provide you with the best possible experience while browsing.
Cookies are small text files stored on your end device (e.g., computer, tablet, smartphone), which can be read by our IT system. Cookies allow us to:
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ensure the website functions properly as expected;
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improve the speed and security of the site;
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enhance the features available to you on our site;
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use analytical tools;
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use marketing tools;
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enable comment functionality;
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provide social media features.
The legal basis for processing personal data in this context is our legitimate interest (Article 6(1)(f) of the GDPR), which consists of analyzing user activity on the website and their preferences in order to improve the functionalities we offer.
More details are provided below.
Cookie Consent
When you visit our website for the first time, you will see a notification regarding the use of cookies. By accepting and closing this message, you consent to the use of cookies in accordance with the provisions of this Privacy Policy.
You may withdraw your consent at any time by deleting cookies and changing your browser’s cookie settings.
Please note, however, that disabling cookies may result in difficulties when using our website, as well as many other websites that rely on cookies.
First-Party Cookies
Cookies can be categorized as first-party or third-party. First-party cookies are used by us to ensure the proper functioning of our website.
Third-Party Cookies
Like most modern websites, our website uses functionalities provided by third parties. This involves the use of third-party cookies. The use of such cookies is described in more detail below.
How to Disable Cookies
You can disable cookies at any time by adjusting the settings in your web browser. Below are links to information on cookie settings in the most commonly used browsers:
Please note that disabling or limiting the use of cookies may prevent you from using certain features available on our website and may cause difficulties when navigating our website and others that rely on cookies. For example, if you block cookies related to social media plugins, buttons, widgets, and social features implemented on our site may no longer be available to you.
Analytics and Statistics
We use cookies to track website statistics such as the number of visitors, the type of operating system and web browser used to access the site, time spent on the site, visited subpages, and more. For this purpose, we use Google Analytics. The information collected is completely anonymous and does not allow us to identify you. This functionality relies on cookies provided by Google LLC in connection with the Google Analytics service.
The use of Google Analytics involves the implementation of a tracking code provided by Google in our website’s code. This tracking code is based on cookies but may also use other tracking technologies.
Google provides a browser add-on that blocks the operation of Google Analytics, available at:
https://tools.google.com/dlpage/gaoptout
If you do not want your data to be processed by this tool, we recommend using the solution provided by Google.
We also encourage you to review Google’s general privacy principles at:
https://www.google.com/analytics/learn/privacy.html
Marketing
We use Facebook marketing tools to deliver ads to you on that platform. To do so, we have implemented the Facebook Pixel in the code of our website, which tracks your visits. This functionality relies on cookies provided by Facebook.
The information collected via the Facebook Pixel is anonymous—meaning it does not allow us to identify you personally. Depending on your activity on our website, you may be assigned to a specific audience group, but we do not in any way identify individual users within those groups.
Please note that Facebook may combine the data collected through the Pixel with other information gathered from your use of the Facebook platform and use it for its own purposes, including marketing. These activities are carried out independently by Facebook and are beyond our control. You can learn more by reviewing Facebook’s Privacy Policy:
https://www.facebook.com/privacy/explanation
You can also manage your privacy settings directly from your Facebook account. For more information, visit:
https://www.facebook.com/ads/settings
Facebook Lead Ads / LinkedIn / LinkedIn Insight Tag
We use the Facebook Lead Ads marketing tool. If you complete a Facebook Lead Ads form on the Facebook platform, you provide us with the personal data specified in the form, including your name, phone number, email address, and company information. We process the data you submit for the purpose of initiating contact and for marketing purposes. The legal basis for this processing is your explicit consent expressed by submitting the form (Article 6(1)(a) of the GDPR), as well as the legitimate interest of the data controller in conducting marketing activities (Article 6(1)(f) of the GDPR). Providing data in the Facebook Lead Ad form is voluntary, and you may withdraw your consent at any time.
We also use LinkedIn Ads. By consenting to submit a lead generation form via LinkedIn, including personal data such as your name, phone number, email address, and company details, you provide us with this information voluntarily. We process this data to initiate contact and for marketing purposes. The legal basis for processing is your explicit consent expressed by submitting the form (Article 6(1)(a) of the GDPR), as well as the legitimate interest of the data controller in carrying out marketing activities (Article 6(1)(f) of the GDPR). Submitting a LinkedIn Ads form is voluntary, and consent to data processing can be withdrawn at any time.
We have also implemented the LinkedIn Insight Tag in our website’s code. This tool helps us better understand and optimize the effectiveness of our marketing activities. The LinkedIn Insight Tag, provided by LinkedIn Ireland – Wilton Plaza, Wilton Place, Dublin 2, Ireland, enables us to collect data on visits to our website, including URL, referrer URL, IP address, device and browser characteristics, timestamps, and page views.
The data collected through the LinkedIn Insight Tag is anonymous and does not allow us to identify you personally. The data is encrypted, anonymized within seven days, and the anonymized data is deleted within 90 days.
This data may be used in particular for ad profiling on the LinkedIn platform, analyzing the effectiveness of ad campaigns, measuring conversions, personalizing advertising content, and retargeting. It allows us to display targeted ads on websites other than our own without identifying you as a visitor to our website.
If you are a LinkedIn user, you can manage your privacy settings and opt out of such analytics.
For more information on how LinkedIn handles your data, please refer to LinkedIn’s Privacy Policy:
https://pl.linkedin.com/legal/privacy-policy
Profiling
Profiling is primarily used by applications such as Google Ads, LinkedIn Insight Tag, and Facebook Pixel. If you do not wish to be subject to profiling, you can adjust the settings in your web browser accordingly. You also have the right to object to profiling—if you choose to do so, please contact us directly.
Remarketing and the Similar Audiences feature in Google Ads allow us to reach users who have previously visited our website and display relevant messaging to them.
Please note that you can opt out of Google cookies by adjusting your ad settings at:
https://adssettings.google.pl/authenticated
Social Media Features
We provide the option to use social media features, such as subscribing to our official business profile (fanpage) on selected social platforms. Please note that we act as the data controller of personal data (such as name, surname, and image) of users who follow our official business profiles (fanpages) on popular social networks, including Facebook, Instagram, and LinkedIn.
These personal data are not processed within databases under our control, as they are handled solely within the databases owned by the respective social media platform providers. These providers are independent data controllers. While we use these platforms as regular users, our access to the list of followers means that we also act as an independent data controller.
You may revoke our access to your personal data on a given platform at any time by using the appropriate functionality offered by that platform (e.g., by “unliking” our page on Facebook).
Please note that using social media features involves the use of cookies set by the administrators of these platforms.
For example, when visiting Facebook—on a computer or other device used to browse the site, including visits to our fanpage—Facebook stores cookies on your browser each time you access the site, regardless of whether you have an account on the platform. These cookies are intended to store information in web browsers and remain active for up to two years unless deleted earlier.
Through these cookies, our company receives from Facebook anonymized statistics based on the number of visits to our fanpage. While these statistics do not allow us to identify individual users, they help us understand the audience of our fanpage. Using filters provided by Facebook, we can define criteria for generating such statistics (e.g., demographic or geographic data), and determine categories of users whose data Facebook processes. Based on these aggregated insights, we can better tailor our content to match the interests of Facebook users, including our page subscribers.
For more information on how social media platform administrators process data collected via plugins—including the purpose, scope, further processing, and usage of the data, as well as your rights and privacy settings—we encourage you to review their respective privacy policies:
Hotjar
We would like to inform you that we use the Hotjar marketing tool. Heatmaps, forms, funnels, and video recordings track user behavior on desktop, mobile, and tablet devices. These tools provide us with insights on how to optimize our website to better meet your needs as a visitor. When using Hotjar on our website, we do not have access to any data that would allow us to identify you as an individual user.
Through Hotjar, we are able to see:
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page scrolls, cursor movement and pauses, time spent on the website, the source of your visit, on-page clicks, navigation between subpages within our site, and form interactions (without access to the actual form data).
To enable this functionality, we have implemented the Hotjar tracking code on our website, which uses cookies provided by Hotjar Ltd.
Please note that you can block Hotjar from storing and processing your data by visiting: https://www.hotjar.com/privacy/do-not-track/
We also encourage you to read Hotjar’s Privacy Policy: https://www.hotjar.com/legal/policies/privacy/
Server Logs
Using the website involves sending requests to the server on which the site is hosted. Each request sent to the server is recorded in server logs.
The logs include, among other things, your IP address, the server date and time, and information about the web browser and operating system you are using. These logs are stored and maintained on the server.
The data recorded in the server logs is not associated with specific individuals using the website and is not used by us to identify users.
Server logs are used solely for administrative purposes related to website management, and their contents are not disclosed to anyone except persons authorized to administer the server.
Thank you for taking the time to read about how we protect your personal data!
