PRIVACY POLICY

1. DEFINITIONS:
   • Administrator – Princeton Language Academy Iwona Święcka sp.k. (hereinafter referred to as „Princeton” or „Administrator”);
   • Personal Data – all information about a natural person identified or identifiable by one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, internet identifier and information collected using via cookies and name and surname, telephone number or e-mail address;
   • Processing of Personal Data – means an operation or a set of operations performed on personal data or sets of personal data in an automated or non-automated manner, in particular collecting, recording, organising, storing, downloading, browsing, using, disclosing by sending or otherwise sharing, matching or combining, limiting, removing or destroying;
   • Policy – this Privacy Policy;
   • GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council 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 repealing Directive 95/46/EC;
   • Website – Website – a website run by the Administrator at the following address: businessenglish.princeton.pl/en/;
   • User – any natural person visiting the Website or using the functionalities described in the Policy;
2. POLICY INFORMATION
   • The Policy contains basic information on the processing of User’s personal data. The Policy applies to all Princeton services offered through the Site.
   • The purpose of the Policy is to fulfill the information obligation imposed on the Administrator pursuant to art. 13 GDPR by explaining how Princeton uses the Personal Data the User provide, in particular which Personal Data is being collected and for what purpose.
3. PROCESSING INFORMATION RELATED TO THE USE OF THE WEBSITE
   • In connection with the User’s use of the Website, the Administrator collects data to the extent necessary to provide individual services offered, as well as information about the User’s activity on the Website.
   • In particular, the data collected by the Administrator may include name, surname, telephone number, e-mail address and date of birth.
4. PURPOSES NAD LEGAL BASIS FOR PROCESSING OF PERSONAL DATA ON THE WEBSITE 
   • Personal data of people who use the Website (including IP address or other identifiers and information collected via cookies) are processed by the Administrator for the following purposes:
     • to provide electronic services in the field of providing Users with content collected on the Website, pursuant to art. 6 sec. 1 lit. b GDPR, covering the necessity of processing to perform the contract, and in the scope of optional data – the legal basis for processing is consent (Article 6 (1) (a) of the GDPR);
     • for statistical and administrative purposes, pursuant to art. 6 sec. 1 lit. f GDPR, covering the legitimate interest of the Administrator, consisting in conducting analyses of Users’ activity and preferences, in order to constantly improve the functionalities and services provided;
     • for purposes of evidence and defense of claims, pursuant to art. 6 sec. 1 lit. f GDPR, covering the Administrator’s legitimate interest, consisting in considering potential complaints and protecting their rights;
     • for the Administrator’s marketing purposes – detailed rules for the processing of personal data for marketing purposes are described below in point 6 – “MARKETING AND SOCIAL MEDIA WEBSITES”.

5. CONTACT FORM AND ONLINE APPLICATION
   • The Administrator provides the possibility of contacting them using the electronic contact form. Using the form requires providing personal data necessary to contact the User and answer the inquiry. The User may also provide other data to facilitate contact or service the inquiry. Providing data marked as mandatory (including name and surname, telephone number and e-mail address) is required in order to accept and handle the inquiry, and failure to do so results in the inability to service. Providing other data (e.g. in the content of the inquiry) is voluntary.
   • In the case of the contact form, Personal Data is processed for the following purposes:
     
     • to handle the inquiry submitted via the contact form – the legal basis for processing is the necessity of processing to perform the contract for the provision of the service (Article 6 (1) (b) of the GDPR); in the scope of optional data processing, the legal basis for processing is the consent (Article 6 (1) (a) of the GDPR).
     • to assert or defend against claims – the legal basis for processing is the legitimate interest of the Administrator (Article 6 (1) (f) of the GDPR), consisting in the protection of their rights.
   • The Administrator also provides the option of submitting an Online Application via the Website. The use of the Online Application form requires the provision of Personal Data necessary to contact the User (contact details) and process the Application (financial data). Providing financial and contact details is required in order to accept and handle the Application, and failure to provide them results in the inability to handle the Application.
   • In the case of an Online Application, Personal Data is processed for the following purposes:
     
     • To handle the application submitted via the Online Application form – the legal basis for processing is the necessity of processing to perform the contract for the provision of the service (Article 6 (1) (b) of the GDPR);
     • In order to assert or defend against claims – the legal basis for processing is the legitimate interest of the Administrator (Article 6 (1) (f) of the GDPR), consisting in the protection of their rights.

6. MARKETING AND SOCIAL MEDIA WEBSITES
   • The Administrator processes Users’ Personal Data for marketing purposes, which in particular include:
     
     • sending e-mail notifications about offers or content, which in some cases contains commercial information;
     • offering products and services as part of direct marketing, including by phone.
   • The Administrator sends e-mail notifications about offers or content to those Users who have provided their e-mail address for this purpose. Providing data is necessary to send e-mail notifications, and failure to do so results in the inability to send such notifications.
   • Personal data in the field of marketing are processed for the following purposes:
     
     • to send marketing content to the User as part of e-mail notifications about offers or content and direct marketing, including telephone marketing, pursuant to art. 6 sec. 1 lit. f  GDPR, covering the legitimate interest of the Administrator, in connection with the consent expressed by the User;
     • to possibly establish and pursue claims or defend against them, pursuant to art. 6 sec. 1 lit. f GDPR, covering the legitimate interest of the Administrator, consisting in the possibility of defending their rights.
   • The Administrator also processes the Personal Data of Users visiting the Administrator’s profiles in social media (Facebook, Instagram). These data are processed in connection with the keeping of these profiles, in order to inform Users about the Administrator’s activity, including promotion of services. The legal basis for the processing of the Administrator’s personal data for this purpose is their legitimate interest, consisting in promoting their own brand, in accordance with art. 6 sec. 1 f GDPR.
   • The User may at any time opt out of receiving information from the Administrator via direct marketing. For this purpose, an e-mail should be sent to the following address: biuro@princeton.pl
   • The User’s Personal Data will not be subject to automated decisions, including profiling.
7. COOKIES AND ANALYTICAL AND MARKETING TOOLS
   • Cookies are small text files installed on the device of the User browsing the Website. They collect information that facilitates the use of the website – e.g. by remembering the User’s visits to the Website and the activities performed by the User.
   • The consent to the use of cookies is completely voluntary. The Website User may refuse to accept the use of cookies or use the web browser settings regulating their use.
     Blocking cookies  in whole or in part may limit the functionality of the Website (more about cookies can be found in the Cookies tab).
8. PERSONAL DATA STORAGE PERIOD
   • The periods of personal data processing by the Administrator and the related periods of personal data storage depend on the type of services provided and the purposes of processing. After the expiry of the processing period, the data is irreversibly deleted or anonymized.
   • As a rule, data is processed for the duration of the provision of services or the handling of Contact Forms, until:
     
     • the consent granted on the basis of which the processing takes place is withdrawn;
     • effective objection to data processing is reported in situations where the legal basis for data processing is the legitimate interest of the Administrator;
   • The data processing period may be extended when processing is necessary to establish and assert any claims or defend against them. In this case, they will be deleted or made anonymous after the expiry of the limitation period.
9. USERS’ RIGHTS
   • The User is in particular entitled to:
     
     • the right to access the content of the data and receive a copy thereof;
     • the right to request rectification or deletion of data;
     • the right to request restriction of data processing;
     • the right to object to data processing;
     • the right to transfer data;
     • the right to lodge a complaint to the supervisory body (the President of the Personal Data Office, ul. Stawki 2, 00-193 Warsaw).
   • Within the scope of the right specified in point 1.4, the User has the right to object to the processing of data that is processed on the basis of the legitimate interests of the Administrator. In the event of an objection, the Administrator will cease to process the data, unless they are able to demonstrate the existence of valid, legitimate grounds for processing, overriding the interests, rights and freedoms of the data subject, or grounds for establishing, investigating or defending claims, in accordance with art. 21 paragraph 1 GDPR.
   • To the extent that the User’s data is processed on the basis of the consent expressed by them, it can be withdrawn at any time by contacting the Administrator. Withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal.
   • Any requests submitted by the User in the exercise of the rights set out in points 1.1– 9.1.5 and others resulting from the GDPR, the Administrator will consider immediately, but not later than within one month of receiving the request. If it is necessary to extend this period, the Administrator informs the applicant about the reasons for this action.
   • In the event that the request was sent to the Administrator electronically, the response is provided in the same form, unless the applicant has requested a response in a different form. In other cases, replies are provided in writing. In the event that the deadline for fulfilling the request makes it impossible to respond in writing, and the scope of the applicant’s data processed by the Administrator allows for electronic contact, the answer should be provided electronically.
   • The Administrator stores information about the request and its author, in order to ensure compliance and to establish, defend or pursue any claims of data subjects. The request register is kept in a manner that ensures the integrity and confidentiality of the data contained therein.
10. DATA RECIPIENTS
    • In connection with the provision of services, the User’s personal data may be disclosed to external entities, including in particular subcontractors to whom activities requiring data processing have been commissioned, e.g. IT service providers, analytical and consulting companies, marketing agencies (in the field of marketing services), as well as Administrator’s employees.
    • The Administrator reserves the right to disclose selected 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 provisions of applicable law.
    • The Users’ personal data will not be transferred outside the European Union (to third countries or international organisations).
11. PERSONAL DATA SECURITY
    • The Administrator conducts a risk analysis to ensure that the processing of Personal Data is carried out in a safe manner – which means that only authorised persons have access to the data and only to the extent that it is necessary for the proper performance of their tasks. The Administrator makes every effort to ensure that all operations on Personal Data are recorded and performed only by authorised employees and associates.
    • In each case of data processing at the request of the Administrator by subcontractors or other entities cooperating with him, the Administrator will take all necessary steps to ensure that these entities guarantee the application of appropriate security measures.
12. ADMINISTRATOR’S CONTACT DETAILS
    • The Administrator has not appointed a Personal Data Inspector.
    • Contact with the Administrator in any matters regarding Personal Data (including this Privacy Policy and Cookies Policy) is possible by e-mail or post:

• e-mail address: biuro@princeton.pl or
• mailing address: ul. Kopernika 34, 00-336 Warszawa, Polska

13. FINAL PROVISIONS
    • The Policy is verified on an ongoing basis and updated if necessary. In this case, the User will be informed about it by displaying appropriate information on the Website or by sending an e-mail. In the event of prior notification of the User about changes to the Policy, the fact of using the Website’s services by them means acceptance of the changes.
    • Any User who does not accept the terms of the new version of the Policy may stop using the Website.
    • The current version of the Policy is effective from 13 December 2021.