Effective date: 28.05.2020.
|Identification data||First name and surname, platform, user name on that platform and profession (source of generated traffic). In the case of contact through social media – also the user name in these media.|
|Contact data||First name and surname, user name. In the case of contact through social media – also the user name in these media. If you subscribe to the newsletter, Contact data refers only to the provided name and email address.|
|Data related to image||Image of a person who has concluded a contract with inSTREAMLY (lease of advertising space).|
|Financial data||Bank account number.|
|Technical data||Internet protocol address (IP), browser type and version, settings and location of the time zone, types and versions of browser plug-ins, operating system and platform, other technologies applied in devices employed by the user in order to access this website.|
|User data||Information about the manner of use of the website or services (tracking of behaviour).|
|Tracking data||Information that is collected about the user by inSTREAMLY or other entities using cookies and similar tracking technologies, such as web beacons, pixels and mobile device identifiers.|
|Direct interactions||The user provides data directly to inSTREAMLY. The provision is performed upon registration (conclusion of a contract), contact by mail or by phone and contact through social media, or upon performance of the contract (lease of advertising space). In this manner, we collect Identification data, Contact data, Data related to image and Financial data.|
|Automated activities||Data are collected automatically during interactions with inSTREAMLY (also through the website) by cookies and analytic tools. In this manner, we collect Technical data, User data and Tracking data. We may also collect Aggregated data. In automated activities, we only use Google Analytics and Hotjar.|
|From third parties||Data are provided by entities which are external in relation to inSTREAMLY (including entities providing tracking services, statistical services, etc. as well as entities providing solutions related to logging-in, e.g. Google Sign-In), if these entities have a legal basis for such provision. This basis usually consists in the user’s consent. In this manner, we collect Technical data, User data and Tracking data. We may also obtain Financial data (payments operators) and, upon authentication, Identification data and Contact data (social portals, streaming portals). Necessary personal data may be obtained by inSTREAMLY also through API placed in portals of business partners of inSTREAMLY and entities providing services for inSTREAMLY.
The manner of use of data by inSTREAMLY is contingent upon the purpose for which these data have been provided or obtained:
|If we perform a contract which has already been concluded or if we want to conclude a contract.||For example, if the user logs in to lease advertising space.|
|If it is justified by the interests of inSTREAMLY or by the interests of third parties, and the interests of the user do not override them.||For example, if we have a reasonable suspicion of fraud; if inSTREAMLY wants to inform the user about new services.|
|If inSTREAMLY must perform a legal obligation imposed on it.||For example, for the purpose of tax settlement.|
However, as a rule, inSTREAMLY uses data for the purpose of:
a. performance of services provided by electronic means, and in the case of users with whom a contract has been concluded – also for the purpose of performance of that contract; b. performance of other services; c. handling of inquiries, requests and orders; d. marketing activities (marketing of own products); e. analysis and improvement of the functioning of websites and services provided by inSTREAMLY; f. development, repair or tests of various functionalities;
inSTREAMLY may process personal data on the following legal bases:
|Performance of a contract or action prior to its conclusion||Article 6(1)(b) of the GDPR. Data are retained for a period that is necessary for the contract to be performed, terminated or otherwise dissolved.||Identification data, Contact data, Data related to image and Financial data|
|Direct marketing||Article 6(1)(f) of the GDPR. Data are stored for the period of existence of a legitimate interest pursued by inSTREAMLY, however, if you exercise your right to object or you withdraw your consent to receive our newsletter, no longer than for the period of limitation of claims after such action. The limitation period is defined by the law, in particular, by the provisions of the Civil Code (the basic limitation period for claims related to conducting business activity is three years, and in the case of a sales contract - two years). inSTREAMLY cannot process data for the purpose of direct marketing if the data subject effectively objects to it.||Contact data|
|Keeping accounts||Article 6(1)(c) of the GDPR in conjunction with Article 74 paragraph 2 of the Accounting Act. Data are stored for a period required by the legal provisions obliging inSTREAMLY to maintain accounts (five years calculated from the beginning of the year following the financial year concerned by the data).||Identification data, Contact data and Financial data, NIP [Tax No.]|
|Responding to an inquiry||Article 6(1)(f) of the GDPR. Data are stored for the period of existence of a legitimate interest pursued by inSTREAMLY, however, no longer than for a period necessary to respond to inquiries sent.||Identification data, Contact data|
|Determining, pursuing or defending against claims||Article 6(1)(f) of the GDPR. Data are stored for the period of existence of a legitimate interest pursued by inSTREAMLY, however, no longer than for the period of limitation of claims in relation to the data subject. The limitation period is defined by the law, in particular, by the provisions of the Civil Code (the basic limitation period for claims related to conducting business activity is three years, and in the case of a sales contract – two years).||Identification data, Contact data and Financial data, NIP [Tax No.]|
|Ensuring security, data protection and protection against fraud||Article 6(1)(f) of the GDPR. Data are stored for the period of existence of a legitimate interest pursued by inSTREAMLY, however, no longer than for the period of limitation of claims in relation to the data subject. The limitation period is defined by the law, in particular, by the provisions of the Civil Code (the basic limitation period for claims related to conducting business activity is three years, and in the case of a sales contract – two years).||Identification data, Contact data, Data related to image and Financial data|
The data subject (the user) has the following rights:
|The right of access, rectification, limitation, erasure or portability||The data subject has the right to request the following from inSTREAMLY: access to their personal data, their rectification, erasure (“the right to be forgotten”) or limitation of their processing, the right to object to their processing and the right to data portability. The detailed conditions of exercising the aforementioned rights are indicated in Article 15-21 of the GDPR.|
|The right to withdraw the consent at any time||The person whose data are processed by inSTREAMLY based on the consent given (pursuant to Article 6(1)(a) or Article 9(2)(a) of the GDPR) has the right to withdraw the consent at any time without affecting the legitimacy of the processing performed based on the consent prior to its withdrawal.|
|The right to lodge a complaint with the supervisory body||The person whose data are processed by inSTREAMLY has the right to lodge a complaint with the supervisory body in the manner and mode defined in the provisions of the GDPR and the Polish law, in particular, the Act on Personal Data Protection. The President of Personal Data Protection Office is the supervisory body in Poland.|
|The right to object||At any time, the data subject has the right to object – for reasons related to their specific situation – to the processing pertaining to their personal data based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interest), including profiling based on these provisions. In such an event, inSTREAMLY will no longer be able to process such personal data, unless it proves the existence of important, legitimate grounds for the processing, overriding the interests, rights and freedoms of the data subject, or any grounds for determining, pursuing or defending claims.|
|The right to object to direct marketing||If personal data are processed for the purpose of direct marketing, the data subject has the right to object, at any time, to the processing pertaining to their personal data for the purposes of such marketing, within the scope in which the processing is related to such direct marketing.|
As a rule, data collected by inSTREAMLY are not shared with third parties. However, inSTREAMLY may:
a. share data of persons who have concluded a contract with inSTREAMLY (lease of advertising space) with advertisers at the stage of their deciding about cooperation with inSTREAMLY, as well as information about the implemented campaigns;
b. share data of persons who have used the services of inSTREAMLY with entities supporting inSTREAMLY in the provision of services, such as payment processors or providers of analytic tools (e.g. Google Analitycs);
c. provide data to law enforcement authorities, supervisory bodies, entities performing public tasks or other entities, if the obligation to provide data results from the legal provisions.
The provision of data must always be performed based on the legal provision or the relevant contract (outsourcing of personal data processing).
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