I Introduction

The protection of personal data and information security are always prioritized in the operations of Sales Insiders Sp. z o.o. As a responsible and aware organization, we are committed to properly informing you about matters related to the processing of personal data, especially in light of new data protection regulations, including 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, repealing Directive 95/46/EC (“GDPR”). We recognize that information holds a certain value and must be appropriately protected. With your data security in mind, this document presents key information regarding the legal bases for personal data processing, its use, and collection.

 II Sales Insiders Sp. z o.o. 

Sales Insiders Sp. z o.o., headquartered at ul. Szyperska 14, 61-754 Poznań, hereinafter referred to as the “Company.”

 III WHEN DOES THIS PRIVACY POLICY APPLY?   

This privacy policy applies to all instances where Sales Insiders Sp. z o.o. acts as the data controller and processes personal data. This includes personal data obtained directly from the data subject as well as data acquired from other sources. Sales Insiders Sp. z o.o. fulfills its information obligations in both cases, as specified in Articles 13 and 14 of the GDPR in accordance with these regulations.

Sales Insiders Sp. z o.o. is the controller of marketing processes (including managing social media accounts), IT systems (including information systems where personal data of, among others, contractors is stored), security incidents, and coordinates employee recruitment processes. The Company also manages the website www.salesinsiders.eu and coordinates the processing of personal data submitted through forms on the site (e.g., via the contact form).

 IV SCOPE, METHODS, AND PURPOSES OF DATA PROCESSING

 IV.1. PROCESSING OF PERSONAL DATA OF INDIVIDUALS VISITING WEBSITES OPERATED BY SALES INSIDERS SP. Z O.O. OR USING SERVICES PROVIDED ELECTRONICALLY

1. General Information

Every individual using our electronic services or visiting our website has control over the personal data they provide to us. We hereby inform you that the data collected in this way is limited to the minimum necessary to deliver services at the expected level.

2. Cookies  

To a limited extent, we may automatically collect personal data through cookies on our websites. Cookies are data, particularly text files, stored on the User’s device. They are intended for use on the website. Cookies typically contain the name of the website they originate from, the duration of storage on the end device, and a unique key-value pair.

Cookies are used for the purpose of:

a) customizing the content of the website to the User’s preferences; in particular, these files allow recognition of the User’s device and proper display of the website;

b) creating statistics, which helps improve the structure and content.

The website uses two types of cookies: “session” cookies and “persistent” cookies. Session cookies are temporary files stored on the User’s device until logout, leaving the website, or closing the browser. Persistent cookies are stored on the User’s device for the duration specified in the cookie parameters or until deleted by the User.

The following types of cookies are used on the website:

a) „necessary” cookies, enabling the use of services available on the website;

b) cookies used to ensure security;

c) „performance” cookies, allowing the collection of information about how the website is used;

d) „functional” cookies, allowing the User’s selected settings to be remembered and personalization of the User interface.

In many cases, web browsing software (web browser) by default allows the storage of cookies on the User’s device. Users of the website can change their cookie settings at any time. These settings can be adjusted, in particular, to block automatic cookie handling in the browser settings or to notify about each cookie placement on the User’s device. Detailed information about managing cookies is available in the software (web browser) settings. Please note that restricting the use of cookies may affect some functionalities available on the website.

Cookies placed on the User’s device may also be used by advertisers and partners cooperating with us. Content from external providers may contain cookies from other entities; therefore, it is recommended that Users familiarize themselves with the cookie policies of these external providers.

3. Online Submissions and Forms

Visitors to the Sales Insiders Sp. z o.o. website have the option to contact the company by filling out a contact form. When using these forms, it is necessary to provide your personal data. This data is processed solely for the purpose for which it was provided and with your explicit consent. Consent regarding contact forms is given through your deliberate action (so-called implied consent), meaning by submitting the form and providing personal data.

4.

Profiling

Personal data processed for marketing purposes may involve:

– displaying marketing content independent of your preferences (including standard advertising;

– displaying marketing content tailored to your interests (behavioral advertising);

– sending email notifications about interesting offers or content, which in some cases include commercial information (newsletter service);

– conducting other types of direct marketing activities related to goods and services (sending commercial information electronically and telemarketing activities).

For marketing purposes, the Company may use profiling in some cases. This involves displaying personalized advertisements or automatically assessing which services you might be interested in and presenting offers tailored accordingly. This means that through automated data processing, the Company evaluates certain behaviors you exhibit or predicts your future behaviors.

Such profiling carried out by the Company does not result in decisions producing legal effects against you or similarly significant impacts.

5. Use of Social Plugins

On the website www.salesinsiders.eu, we currently use so-called Social Plugins (“Plugins”) from Facebook, Google+, LinkedIn, Instagram, TikTok, X, and YouTube. We employ a two-click solution. This means that when visiting our website, no personal user data is automatically transmitted to the plugin providers. The plugin provider can be identified by its logo. We provide the option to communicate directly with the plugin provider via a button. Only after the user clicks and activates the designated field does the plugin provider receive information about the user’s access to the page with our online service offer. After activation, the user’s personal data is transmitted to the respective plugin provider and stored on their servers (for US providers, in the USA). Since the plugin provider collects this data mainly through cookies, we recommend deleting all cookies via your browser’s security settings before clicking the grey frame.

We have no influence over the data collected and processing procedures, nor do we have knowledge about the full scope of data collection, processing purposes, or retention periods. We also lack information about the deletion of data collected by the plugin providers.

The plugin provider stores collected user data in the form of a user profile and uses it for advertising purposes, market research, and/or designing its website based on user preferences. Such analysis is conducted (even for users not logged in) primarily to display ads tailored to individual preferences and inform other users of the social network about the user’s activity on our website. Users have the right to object to the creation of these user profiles by contacting the plugin provider directly. The plugin mechanism allows users to integrate with social networks and other users, which helps us improve our offerings and make them closer to user preferences. The legal basis for using plugins is defined in Article 6(1)(f) of the GDPR.

Data sharing occurs regardless of whether the user has an account with the plugin provider and is logged in there. If the user is logged into their account with the plugin provider, the data collected on our site is directly linked to their account with the provider. When the activated button is pressed, for example, to share a page, the plugin provider also saves this information on the user’s account and shares it publicly with the user’s friends. We recommend logging out regularly after leaving the social network portal, especially before activating the button, to avoid data being linked to the plugin provider’s profile.

Further information on the purpose and scope of data collection and processing by the plugin provider can be found in the plugin provider’s privacy policy. It also includes information about user rights and settings to protect privacy.

6. Images

The photos and icons displayed on the website are the property of Sales Insiders Sp. z o.o., sourced from image and icon banks, or purchased from agencies as website materials

 IV.2. PROCESSING OF PERSONAL DATA OF INDIVIDUALS CONTACTING SALES INSIDERS SP. Z O.O. TO REQUEST INFORMATION ABOUT THE OFFER OR PROVIDE FEEDBACK REGARDING SERVICES, AS WELL AS THOSE CONTACTING TO CONCLUDE A CONTRACT 

From individuals contacting Sales Insiders Sp. z o.o. to request information about the offer, express opinions or comments, or to initiate contract discussions, we collect the following personal data: first and last name, email address, and phone number.

We kindly ask that you do not provide, via the website, any special categories of personal data listed in Article 9(1) of the GDPR (such as information about race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, physical or mental health, genetic data, biometric data, sexual life or sexual orientation, or criminal history). If such information is provided for any reason, it will be considered explicit consent to collect and use this information as specified in this document or where the information was disclosed.

 IV.3. PROCESSING OF PERSONAL DATA OF CUSTOMERS AND POTENTIAL CUSTOMERS 

Sales Insiders Sp. z o.o. processes personal data of its customers and potential customers. This may include contact details of individuals on the customers’ and potential customers’ sides (their employees). Such personal data is processed in the IT systems used by Sales Insiders Sp. z o.o., including the CRM system. The personal data processed for these purposes includes, among others: first and last name, employer’s name, contact person’s position, phone number, email address, or other business contact details.

 IV.4 PROCESSING OF PERSONAL DATA OF INDIVIDUALS VISITING THE BUSINESS PROFILE OF SALES INSIDERS SP. Z O.O.

Data of Users who liked the business profile of Sales Insiders Sp. z o.o., available on social media platforms such as Facebook, Instagram, X, LinkedIn, YouTube, and TikTok, will be processed for the purpose of administering and managing the Sales Insiders Sp. z o.o. business profile, communicating with Users (including responding to inquiries), engaging in interactions, and informing about organized events, interesting information, services, and products offered by the Controller, as well as creating a community on Facebook.

Accordingly, Sales Insiders Sp. z o.o., as the Controller of the mentioned business profiles, may generate anonymous statistical data about visitors using functions provided by Facebook, LinkedIn, X, Instagram, TikTok, or YouTube. The legal basis for data processing is consent. Users voluntarily choose to like/follow/interact with the profile/page/group on the given social media platform.

The rules governing the Sales Insiders Sp. z o.o. business profile on Facebook/LinkedIn/X/Instagram/TikTok/YouTube are set by the Controller; however, the rules of participation in the chosen social media platform are governed by that platform’s terms of use. You may stop following or even block the Controller’s profile on Facebook/LinkedIn/X/Instagram/TikTok/YouTube at any time. Due to the nature of the platforms used by the Controller, only using the “block user” option will prevent you from seeing any content created by the Controller. Other content available on the platform remains public.

Withdrawal of consent does not affect the lawfulness of processing carried out based on consent before its withdrawal.

The Controller processes publicly available personal data such as names, surnames, or general information posted on User profiles and available publicly. Processing of other personal data is conducted by the social media platforms Facebook/LinkedIn/X/Instagram/TikTok/YouTube under their respective terms and conditions. Under no circumstances will data of persons who liked the Sales Insiders Sp. z o.o. business profile on Facebook/LinkedIn/X/Instagram/TikTok/YouTube be used for purposes other than those for which it was provided. Personal data may be transferred outside Poland, the European Union, and the European Economic Area within the operation of these social media platforms.

Additional information regarding electronic correspondence:

If you wish to send us an email message, please note that unencrypted emails sent over the Internet are not sufficiently protected against unauthorized access by third parties.

 IV.5 PROCESSING OF PERSONAL DATA OF JOB APPLICANTS

Personal data of job applicants is collected for the purposes of ongoing recruitment processes and actions prior to contract conclusion. The Company may also process data if the applicant has consented to its use, including for future recruitment needs.

Applicant data will be processed during the recruitment period and for up to three years after its conclusion—that is, for the duration in which any potential claims may be made.

If processing is based on consent for participation in future recruitment processes, personal data will be processed until the consent is withdrawn.

 V LEGAL BASES FOR PROCESSING   

The processing of personal data of individuals visiting the website operated by Sales Insiders Sp. z o.o., using electronically provided services, or interacting on Sales Insiders Sp. z o.o.’s business profiles on social media platforms is based on different legal grounds depending on the category of personal data processed and the purpose of processing.

Personal data of visitors to our websites are processed based on the legitimate interest of the data controller (Article 6(1)(f) GDPR) or on consent if such consent has been obtained from the data subject (Article 6(1)(a) GDPR).

Data of individuals filling out online/contact forms are processed because it is necessary for the performance of a contract or to take steps at the request of the data subject prior to entering into a contract (Article 6(1)(b) GDPR), based on consent (Article 6(1)(a) GDPR), or based on the legitimate interest of the controller to respond to inquiries (Article 6(1)(f) GDPR).

Data of individuals visiting our fan page are processed in accordance with Facebook’s terms and conditions, based on the user’s consent (Article 6(1)(a) GDPR).

The processing of personal data of individuals contacting Sales Insiders Sp. z o.o. to request information about offers, provide feedback regarding services, or to conclude a contract is based on consent given by the user making such request (Article 6(1)(a) GDPR) or for the purpose of contract execution (Article 6(1)(b) GDPR). The data may also be processed on the basis of the legitimate interest of the data controller (Article 6(1)(f) GDPR).

Processing of personal data of individuals who are potential customers is based on:

• the legitimate interest of Sales Insiders Sp. z o.o. as the data controller (especially regarding database creation and direct marketing of its own products) (Article 6(1)(f) GDPR);

• consent (particularly consent for email marketing or telemarketing) (Article 6(1)(a) GDPR).

 VI DATA RETENTION PERIOD   

Sales Insiders Sp. z o.o. processes and stores personal data for a period dependent on the legal basis constituting the lawful ground for data processing. We inform you that Sales Insiders Sp. z o.o. processes personal data based on:

• consent, where the processing period lasts until the consent is withdrawn by the data subject or the purpose of processing ends;

• the legitimate interest of the data controller, where the processing period lasts until the cessation of the said interest (e.g., limitation period for civil claims) or until the data subject objects to further processing—when such objection is permitted by law;

• applicable legal regulations, where data processing periods are determined by those laws.

In the absence of specific legal or contractual requirements, the basic data retention period for records and other evidentiary documentation created during contract execution is a maximum of 6 years.

 VII DATA RECIPIENTS   

Personal data is shared with other entities based on legal requirements or in connection with the purpose for which the data was provided to us. At the same time, we declare that we only use services from verified, locally recognized entities that guarantee data security. Agreements under which we entrust personal data processing include provisions on the protective measures we require to ensure the confidentiality, integrity, and availability of the transferred data.

We may share personal data with companies or other trusted business partners who provide services on behalf of the Company, as well as with entities we cooperate with. Additionally, data may be transferred to providers of services such as debt collection, tax, legal, and accounting services. Personal data is shared with these entities and other third parties only when necessary to perform services requested or authorized by the data subject, to protect rights, property, or safety, or if the Company is obligated to do so under applicable laws, court orders, or regulations of other authorities, or if disclosure is otherwise necessary to support legal or criminal investigations or court proceedings.

Furthermore, access to personal data is granted to authorized employees of the Company.

 VIII RIGHTS RELATED TO PERSONAL DATA PROCESSING

The rights of individuals regarding the processing of personal data include:

a) The right to access the content of their personal data;

b) The right to rectify data;

c) The right to restrict data processing;

d) The right to request data deletion;

e) The right to data portability to another data controller.

You can exercise the rights mentioned above by contacting us via email at info@salesinsiders.eu or by mail at: Sales Insiders Sp. z o.o., ul. Szyperska 14, 61-754 Poznań.

Individuals have specific rights regarding their personal data, and Sales Insiders Sp. z o.o., as the data controller, is responsible for ensuring these rights are upheld in accordance with applicable laws.

We also wish to inform you that every individual has the right to object to the processing of their personal data. In cases where data processing is based on the legitimate interest legal basis, an individual has the right to object for reasons related to their particular situation. If you exercise this right, the Company will cease processing the data for that purpose unless it demonstrates compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the individual, or grounds related to the establishment, exercise, or defense of legal claims.

Objections can be submitted via email to info@salesinsiders.eu or by mail to: Sales Insiders Sp. z o.o., ul. Szyperska 14, 61-754 Poznań.

 IX CONTACT POINT   

The Controller has appointed a Data Protection Officer, who can be contacted via email at info@salesinsiders.eu or by mail at the Controller’s registered address.

 X CHANGES TO THIS PRIVACY POLICY  

We commit to regularly reviewing this Privacy Policy and making changes when necessary or desirable due to: new legal regulations, new guidelines from data protection supervisory authorities, or best practices in the field of personal data protection.