1.3 We may process your personal information in different scenarios based on different legal reasons, such as performing contracts and providing products and/or services to you, based on legitimate business interests or with your prior consent.
2．Personal Information may collected by Polski Plus
In any scenario in which you interact with us, we are likely to ask you to provide personal information. If you do not provide the relevant information, you may not be able to achieve the specific purpose for a particular scenario. For example, you cannot purchase an Polski Plus course / service; our teachers/admin team cannot reach you and provide you with pre-sales and after-sales service; or you cannot access to our online test, online payments solutions, you cannot receive special offers.
Polski Plus offers language courses online at competitive prices. To take one of these courses, enjoy a free trial or become a user of our community services, you need to become a member of our website. During registration we collect information such as your name and email address.
Here are some of the scenarios where we may collect your personal information:
2.1 When you register for a language course, you may provide relevant personal information, such as user first name, last name, gender, phone number, email, mailing address, zip code, method of payment and bank account information, etc.
2.2 Where permitted by law, Polski Plus may also obtain data about you from third-party sources. For example, when you use a third-party network account or via an agent / partner to register at Polski Plus, we may obtain your personal details from a third-party network service company. Depending on your choice of third-party network account, we may collect your WhatsApp, Facebook or Google account information. In such case, only the account information will be obtained.
2.3 When you study with us, we may also collect information about your courses, feedbacks, language level, expectations, nationality, age etc.
2.4 When you call our teachers/admin team for assistance, we may ask for your name, phone number, booking details and record your number of calls, date of call, problem encountered and the solution we give to you.
2.5 If you participate in one of Polski Plus events, we may also ask for information such as your name, gender, email address, and phone number, target language, previous knowledge, etc.
2.6 Your information shared through Polski Plus Community, such as your personal photos uploaded on our website or social media groups, your thoughts and experiences shared through forums and friends, etc.
2.7 If you fill out a form on our website, the information will be stored in our offline internal records and database. We do not give out any personal details to third parties, unless this is a stated part of the admissions process.
3. How Polski Plus may use Personal information
Polski Plus will use your personal information based on the following legitimate purposes. One or more purposes may be applied at the same time. If we use your personal information beyond the following purposes or the scope allowed by the law, we will obtain your consent again on the basis of special purpose needs.
3.1 Used for authentication, security, fraud monitoring, archiving purposes to ensure the security at our school and services provided to you by Polski Plus.
3.2 Provide you with services such as course confirmation, quotes, invoices, receipt and delivery of goodies; refund of payment for goods; after-sales support; accommodation booking / upgrade information, and other similar purposes.
3.3 Help Polski Plus to improve products and services. For example, Polski Plus will analyse and study the collected data to make user-friendly adjustments to its website and interface design in accordance with user characteristics. When you choose to share your feedback, Polski Plus can modify offers, improve services according to your reviews, which helps to ensure that quality is the best.
3.4 With your consent, Polski Plus may send you our latest offers and service information, and may also send you holiday greetings. You may choose to unsubscribe at any time if you do not wish to receive such information.
3.5 Description of services based on location information: some pre-loaded web-section in Polski Plus website provide services based on the user’s precise or unique geographic location, such as maps, navigation and price lists, special packages. These services are provided by third parties independent of Polski Plus. Therefore, your personal information, including your location, will be collected and processed by third parties and not controlled and processed by Polski Plus. You can choose to turn off location-based services and refuse to share location information.
3.7 Privacy of Children: Kids under 13, do not send any information about yourself to us–including information such as your name, address, or e-mail address. We do not knowingly collect personally identifiable information from children under 13. In the event that we learn we have collected any personal information from a child under the age of 13 we will delete that information from our database as quickly as possible.
4.3 In addition to cookies, Polski Plus also uses other similar technologies such as local storage, web beacons, and pixel tags on its website. Like local storage of HTML5, this can cache frequently-used data related to you so that such data can be rendered to you quickly when you switch between different web pages of the Polski Plus website. For another example, an email sent to you may contain a click URL linked to the content of the website. If you click on the link, this click will be tracked to help Polski Plus better understand your product and service preferences and improve customer service. Web beacons are usually transparent images embedded in websites or emails. With the help of the pixel tags in emails, Polski Plus can know whether the email content is effectively served to the user.
4.4 Opting out of personalized website ads You can opt-out of receiving personalized website ads from advertisers and ad networks that are members of the Network Advertising Initiative (“NAI”) or who follow the DAA Self-Regulatory Principles for Online Behavioral Advertising using their respective opt-out tools. The NAI’s opt-out tool can be found here NAI opt-out http://www.networkadvertising.org/choices/ and the DAA’s opt out tool can be found here Choices. http://www.aboutads.info/choices/ Learn more about privacy at Google and to opt-out of this feature by installing the Google Analytics Opt-out Browser Add-on. http://www.google.com/analytics/learn/privacy.html You may opt out of such display advertising at any time by visiting your Google Ads Settings page https://www.google.com/settings/ads
5. How Polski Plus may share personal information
5.1 We may disclose your personal information between affiliates or subsidiaries and ensure that the same level of protection is provided for your personal information between affiliates and subsidiaries.
5.2 Polski Plus may disclose your personal information to its partners under certain circumstances. For example, when you book Polski Plus services through Polski Plus’s online store, Polski Plus will disclose your services purchase and personal information to our authorized administration team.
5.3 In addition, Polski Plus may disclose your information to public authorities with jurisdiction over the territories in which we operate to provide personal information of our users in compliance with the law or in the performance of legal procedure.
5.4 In any case of sharing your personal information with third parties, we endeavor to disclose it to such third parties only to the extent permitted by law and we require data recipients to process and protect your personal information in compliance with applicable laws and regulations.
5.5 Polski Plus promises not to sell personal data to any third party and guarantees the legitimate and fair use of user information only to the extent permitted by law.
6. How you access and control your personal information
6.1 Polski Plus will do its utmost to take the appropriate technical measures to ensure that you can access, update, correct and delete your own registration information or other personal information provided when using Polski Plus services. When you access, update, correct and delete the aforementioned information, you may be asked for authentication to protect the information security.
6.2 You can control your own personal information. For example, you can turn off the location sharing button to stop sharing your device’s location information, or you can revoke prior consent for data collection and processing. However, please understand that once you make above choice, you may not be able to enjoy the related services.
6.4 This site contains links to other sites. Please be aware that PolskiPlus is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any website that collects personally identifiable information.
7. How Polski Plus protect Personal information
7.2 Polski Plus uses various management policies (such as establishing information security system; signing a confidentiality agreements with information management employees; allowing only work-related employees to access the information collected; and other similar policies) and security techniques and procedures (such as entering passwords before access, access control isolation, monitoring for computer use, etc.) to prevent the loss of information, improper use, and unauthorized reading or disclosure. For example, in some services, Polski Plus uses encryption technology (such as SSL) to protect the personal information you provide. However, please understand that due to technical limitations and possible malicious means, it is impossible for any company providing Internet-related services to guarantee 100% security of information, even if all efforts are made to strengthen security measures. You need to understand that the systems and communication networks you use to access Polski Plus services may be subject to problems that are beyond Polski Plus’s control.
7.3 If Polski Plus is informed that the security of the data it has acquired and stored is compromised or the user’s nonpublic information is disclosed to an unrelated third party due to external acts (such as hacker attack), Polski Plus will take reasonable actions (including but not limited to internal investigations, reporting and notification to law enforcement agencies, and cooperation with the law enforcement agencies) as it may consider appropriate, notwithstanding any disclaimer in this Policy. In parallel, Polski Plus will take legal and reasonable steps as it deems appropriate to notify the relevant users, informing them of the information disclosed and the extent to which we are aware of such situations.
7.4 Data cross-border transfer: your personal information may be transmitted and transferred across borders, and stored and processed in the target country. Depending on the laws in your country, the receiving country and region of these data may not meet the requirements. We promise that we will have the right security measures to ensure that the protection level of data can meet the full requirements of the laws and regulations of your country and region.
8. Third-party service
8.2 We are not responsible for how third parties collect, use, share, transfer and protect user’s personal information, and cannot control how it is processed.
9. What is our justification for handling your personal data?
Under European data protection laws, we have to ensure that we process your personal information fairly and lawfully. This means that we must have a “legal basis” for each of our processing activities where they relate to the personal data of an individual within the EEA. These bases include:
- Consent – we may decide to obtain your specific, freely given consent to one or more processing activities;
- Legal obligation – we may need to process your data where it is necessary to comply with applicable laws that we are subject to;
- Performance of a contract – we may process your data if we are entering into a contract with you, or taking preparatory steps to do so;
- Legitimate interests – we may process your personal data where we believe that we have a legitimate interest in doing so, and we have analyzed this and determined that our interests are not overridden by the impact on your rights and freedoms under data protection law.
We rely on these legal bases in different ways, and in relation to different types of processing of your personal data.
We believe that our use of your other personal information described herein is necessary for our legitimate interests, which are as follows:
- To run, grow and develop our business;
- To operate our Website;
- For marketing, market research and business development;
- For internal administrative purposes.
If we rely on our, or another person’s, legitimate interests for using your personal information, we will undertake a balancing test to ensure that our (or the other person’s) legitimate interests are not outweighed by your interests or fundamental rights and freedoms which require protection.
9.1 Rights of EEA Residents
Residents in the EEA have the following rights:
- The right to ask us to provide you with copies of personal information that we hold about you at any time free of charge, although we may charge a reasonable fee if your request is manifestly unfounded or excessive, or repetitive.
- The right to ask us to update or correct any out-of-date or incorrect personal information that we hold about you (in accordance with applicable data protection laws).
- The rights to request that we stop using or delete your personal information (in certain circumstances we may not be able to stop using your personal information but if that is the case, we will let you know why).
- The right to opt out of any marketing communications that we (or any third party to whom we have disclosed your personal information with your consent) may send you.
9.2 Rights of the data subject
a) Right of confirmation: Each data subject shall have the right granted by the European legislator to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact any employee of the controller.
b) Right of access: Each data subject shall have the right granted by the European legislator to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing;
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organisation. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer. If a data subject wishes to avail himself of this right of access, he or she may, at any time, contact any employee of the controller.
c) Right to rectification: Each data subject shall have the right granted by the European legislator to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement. If a data subject wishes to exercise this right to rectification, he or she may, at any time, contact any employee of the controller.
d) Right to erasure (Right to be forgotten): Each data subject shall have the right granted by the European legislator to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by the PolskiPlus, he or she may, at any time, contact any employee of the controller. An employee of PolskiPlus shall promptly ensure that the erasure request is complied with immediately.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required. An employees of the PolskiPlus will arrange the necessary measures in individual cases.
e) Right of restriction of processing: Each data subject shall have the right granted by the European legislator to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the PolskiPlus, he or she may at any time contact any employee of the controller. The employee of the PolskiPlus will arrange the restriction of the processing.
f) Right to data portability: Each data subject shall have the right granted by the European legislator, to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others. In order to assert the right to data portability, the data subject may at any time contact any employee of the PolskiPlus.
g) Right to object: Each data subject shall have the right granted by the European legislator to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
The PolskiPlus shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defence of legal claims.
If the PolskiPlus processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the PolskiPlus to the processing for direct marketing purposes, the PolskiPlus will no longer process the personal data for these purposes. In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the PolskiPlus for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
In order to exercise the right to object, the data subject may contact any employee of the PolskiPlus. In addition, the data subject is free in the context of the use of information society services, and notwithstanding Directive 2002/58/EC, to use his or her right to object by automated means using technical specifications.
h) Automated individual decision-making, including profiling: Each data subject shall have the right granted by the European legislator not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorised by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the PolskiPlus shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision. If the data subject wishes to exercise the rights concerning automated individual decision-making, he or she may, at any time, contact any employee of the PolskiPlus.
i) Right to withdraw data protection consent: Each data subject shall have the right granted by the European legislator to withdraw his or her consent to processing of his or her personal data at any time. If you wish to exercise any of the above rights, please use the forms indicated where applicable and email us at firstname.lastname@example.org
We will consider all such requests and provide our response within a reasonable period (and in any event within any time period required by law). Please note, however, that certain personal information may be exempt from such requests in certain circumstances.
If an exception applies, we will tell you this when responding to your request. We may request you provide us with information necessary to confirm your identity before responding to any request you make.
Please also note for security and fraud investigation and prevention purposes, we will retain the full IP address for users located in the EEA for up to 12 months.
In addition, we keep a copy of requests submitted to us to comply with our own legal obligation to maintain data processing records.
10. Change and modification
11. Notification and delivery
11.1 Any notice from Polski Plus will be sent to the email address, phone number, and/or mailing address left when you register for an account or purchase of Polski Plus product, or pushed directly through mobile phone system. If sent via electronic methods, notice shall be deemed served when your device or the used electronic system receives the message; if sent by courier, it shall be deemed served on the third day after sending out.
E-mail address: email@example.com
Tel.: +48 695 410 741
This Agreement is updated on May, 2018.