Legal & Security Privacy Policy

Privacy Policy

Last updated: August 10th, 2021

1. What do the terms used in the Privacy Policy mean?

  1. Kyotu Technology / Controller / “we”, “us” or “our” – Kyotu Technology Sp. z o.o. (Limited Liability Company) a company incorporated in Poland, Warsaw, registered by District Court of Warsaw, XII Commercial Department of National Court Register under number 0000879500 (KRS) whose registered office is at Warsaw (00-008), ul. Marszałkowska 126/134, Poland, tax identification number: PL5252849401 (VAT EU / NIP);
  2. User – any natural person visiting the Website or using one or more services or functionalities made available on the Website;
  3. Newsletter – an electronic report containing news concerning the activities of Kyotu which is sent to subscribers on a regular basis;
  4. Cookies – IT data, in particular text files, which are stored on the Website User’s end device which are intended for using the Website’s pages;
  5. Policy – this Privacy Policy;
  6. Website – www.kyotutechnology.com;

2. Who is the data controller?

The Controller of your personal data is Kyotu Technology Sp. z o.o. (Limited Liability Company) a company incorporated in Poland, Warsaw, registered by District Court of Warsaw, XII Commercial Department of National Court Register under number 0000879500 (KRS) whose registered office is at Warsaw (00-008), ul. Marszałkowska 126/134, Poland, tax identification number: PL5252849401 (VAT EU / NIP). Contact with us is possible in writing to the address indicated above or via the email address: [email protected].

3. What type of data do we collect?

lf you decide to provide us with your personal data, Kyotu Technology will process the following data:

  1. your email address provided in order to subscribe to the Newsletter;
  2. any other personal data which you may provide directly to us via Website;
  3. cookies applicable to the Website;

4. What are the purposes and the legal grounds for processing your data?

Kyotu Technology processes the data of:

  1. Website Users:
    1. to provide a newsletter to Users. The legal basis for the processing of personal data is Article 6(1)(b) of the GDPR, i.e. processing is necessary to perform the contract to which the data subject is party, or to take action at the request of the data subject, before concluding the contract.
    2. for analytical and statistical purposes. The legal basis is Article 6(1)(f) of the GDPR, i.e. our interest in measuring the effectiveness of the Website and improving its overall functionality;
    3. to diagnose problems related to the operation of the Website, ensuring its correct configuration and IT security. The legal basis is Article 6(1)(f) of the GDPR, i.e. the legitimate interest of the Controller consisting in ensuring the proper functioning of the Website. For these purposes, the Controller processes data on the activity on the Website, i.e. the content viewed on the Website, session data, device, operating system, browser, location and the User’s IP address;
    4. to establish and pursue claims or defend against claims which may arise. The legal basis is Article 6(1)(f) of the GDPR, i.e. the legitimate interest of the Controller consisting in the protection of its rights.

    Providing your personal data is necessary to use our Website and answer your inquiry.

  2. People who follow Kyotu Technology fanpage on Facebook, LinkedIn and Instagram:
    1. promotion of our products and services and building a positive image of Kyotu Technology (Article 6 (1) (f) of the GDPR);
    2. responding to received inquiries and questions (Article 6 (1) (f) of the GDPR).

    Providing your personal data is necessary to observe our social media profiles and answer your inquiry.

    In case of:

    1. persons visiting and using the Kyotu Technology Website who decide to contact us, we process: e-mail address, information related to your industry and project and the content of the message you send us
    2. people who follow the Kyotu Technology fanpage on Facebook, LinkedIn and Instagram, we process: name, surname, image (profile photo), ID associated with the social network and email address;

5. When and how do we collect your personal data?

We collect your personal data directly from you when you:

  • browse through our Website;
  • follow us on Facebook, LinkedIn or Instagram;
  • provide your email address in order to subscribe to our newsletter;
  • reach out to us using any contact method available on our website;

6. How long do we keep your personal data?

The period of data processing depends on the type of service provided, the purpose of processing and the legal basis:

  1. if we process personal data on the basis of consent, the processing period lasts until the consent is withdrawn;
  2. if we process personal data on the basis of the legal interest of the data controller, the processing period lasts until the end of the above-mentioned interest (e.g. the statute of limitations for civil law claims, obligations imposed by Polish tax and accounting laws) or until the data subject effectively objects to further processing – in situations where such objection is permitted under the law;
  3. in the case of processing cookies, we will process your personal data for the period in which cookies will be stored on your device.

7. Newsletter

We process personal data that you provide when you sign up for our Newsletter. The processing of your personal data in this context is based on your voluntary consent.

To receive no further information by the Newsletter, you need only to withdraw your consent by unsubscribing from them.
Subscribing to our Newsletter is completely voluntary, however, you may not be able to receive the requested content if you refuse to provide or give incorrect personal data.

We will process your personal data until you unsubscribe from our Newsletter.

The purpose of the Newsletter is to provide you with information about our services or important industry updates..

8. Disclosure of your personal data

Depending on the context in which we obtained your personal data the following categories of entities may gain access to your personal data:

  • providers of services that help us run our business (e.g. payment processors, external accounting, headhunters, legal and business advisors);
  • providers of cloud computing, productivity, and collaboration tools and software which we use to run our business (e.g. Slack);
  • hosting services providers (e.g. Tytani24 Sp. z o.o.);
  • providers of tools that help us run marketing campaigns (e.g. tools such as HubSpot, Zapier, etc.) as well as external sales and marketing consultants.

Where required or permitted by law, we may also provide your personal data to regulators and law enforcement agencies.

9. What are your rights?

You have a right to:

  • access your data: you have the right to access the information that we have on you. If you choose to exercise this right, upon your request, we will also make sure to provide you with a copy of the data we process about you and information about how we process them. We will fulfill your request by sending your copy electronically unless the request expressly specifies a different method. For any subsequent access request, we may charge you an administrative fee.
  • rectification of data, erasure, and restriction of processing: if you believe that the information we have about you is incorrect, you are welcome to contact us, so we can update it and keep your data accurate. We will automatically delete information about you after it is no longer needed for the purposes it was collected for. Nonetheless, if at any point you wish for us to delete information about you, you have the right to do so. You also have the right to obtain restrictions on the processing of your data.
  • data portability: in case the processing of your personal data is based on a contract or your consent, you have the right to receive the personal data that you have provided to us in a structured, commonly used, and machine-readable format. You can also request us to transmit such data to another controller if it is technically feasible.
  • withdrawal of consent and the right to object to processing: If the processing of your data is based on consent, you have the right to withdraw your consent at any time. Remember that withdrawal of consent will not affect the lawfulness of processing based on this consent before its withdrawal. In case the processing of your data is based on our legitimate interest you have the right to object to such processing.
  • The right not to be subject to a decision based solely on the automated processing of their personal data.

To comply with requests concerning your rights, if the information that you provide is insufficient to identify you, we will ask you to give us some additional information that we will use to verify your identity. If you fail to provide such information we may refuse to fulfill your request

10. Profiling and automated decision making

We do not use any information provided by you for automated decision-making, including profiling.

11. International data transfers

Whenever possible, we will try to use processors that process personal data within the European Economic Area (“EEA”). In case there is a need for us to use processors located outside of the EEA, we will only disclose personal data to them provided that appropriate international data transfer safeguards described in the GDPR are in place.

As of the date of this Privacy Policy, we may transfer information that you provided us with to the United States of America. Such transfer relies either on Binding Corporate Rules implemented by our processors or standard data protection clauses approved by the European Commission.

12. Changes to this Privacy Policy

We constantly review our Privacy Policy and strive towards making it better. That is why we reserve the right to amend this Privacy Policy from time to time. We will not reduce any of your rights stated in this Privacy Policy without asking for explicit prior consent to the changes. Each amendment to the Privacy Policy will be signed with the date of publishing and will be effective from that date.

13. How to contact us and seek additional help?

If you have any questions or doubts related to this Privacy Policy or want to know more about how we protect your personal data or your rights, you can contact us by sending an email at [email protected].
We hope that we will be able to answer all your questions and settle all disputes amicably. Nonetheless, if you think that your rights were not observed or that your privacy was harmed, you can always lodge a complaint with a data protection authority.

14. Cookies and similar technologies

Our websites use cookies, which are tiny files that are downloaded to your device (e.g. computer, tablet, or smartphone). This section describes our use of cookies in detail.

Please note that we make use of plugins and tools from external providers, such as Google Analytics. This means that – depending on your device settings and your consent – the information about your use of our website may be combined with other information that you’ve shared with the providers or that they’ve collected from your use of their service. These parties collect data directly from your web browser, processing the data under their privacy policies (see below for relevant link).

15. What do we use cookies for?

Cookies that we use can be divided into the following categories:

  • statistics & analytics cookies which make it possible for us to understand how you interact with our website by collecting and reporting anonymous and aggregated statistical data;
  • marketing & remarketing cookies which make it possible for us to track visitors across our website and advertise our services online.

16. What types of information do we gather through cookies?

By using cookies, we gather the following information:

  • your web request, IP address, browser type, and settings, referring/exit pages and URLs, number of clicks, date and time stamp information, language preferences;
  • information about the device that you use to connect with our website (e.g. the type of device that you are using, the system under which it operates, your network information, and unique device identifiers such as your MAC address);
  • information about your approximate geographic location inferred from your IP address;
  • metadata about your interactions with our website – whenever you use it, some metadata that provides high-level information about the way you use our website is generated (e.g. the way you navigate the website, the features and functionalities that you interact with, third-party services, and integrations that you use).

17. What cookies do we use?

We use two types of cookies:

  • session cookies, which remain on your device until a web browser session is completed or the web browser is closed;
  • persistent cookies, which remain on your device until their expiry date or until you delete them, but no longer than 2 years.

18. Accepting/ disabling cookies

Unless you accept our use of cookies we will not save them on your device. You may also manage your cookie preference through your browser’s preferences even if you have consented to the use of cookies in the past. You can also delete cookies stored on your computer at any given time. Please note that disabling cookies may negatively impact your online experience on our Website.