PRIVACY POLICY („Policy”)


Data protection is particularly important to us, so as part of the following Policy, we want to inform you (as our website / resource user) about how we process your personal data that you may provide to us by using dev-academy.com, websecurity-academy.com, fullstack-testing.com and its resources (hereinafter: the "Website"), provided also through teachable.com. 


Please note that we have adopted a data protection practice that is compliant with EU Regulation no. 2016/679 ("GDPR").


Accordingly, this Policy constitutes fulfillment of our information obligation under Article 13 – 14 GDPR.

1) Information About The Personal Data Controller

The personal data controller of the Website is Bartosz Pietrucha conducting a sole proprietorship under the name: “Premium Software Consulting Bartosz Pietrucha” with its seat at ul. Tadeusza Zielińskiego, 36/36, 53-534 Wroclaw, hereinafter “PDC“ or “we“.

You can contact the PDC by regular post - by writing to the address above, or by e-mail -by writing to the following address:[email protected].

2) Aims and Legal Grounds for Processing Personal Data
The purposes of personal data processing and legal grounds are mentioned below. 

CONTACTING YOU / RESPONDING TO QUERIES


Purposes. If you ask us a question/request a certain action via email, we may process your personal data in order to fulfill your request / contact you.
Providing contact information, in this case, is voluntary, however, it may be necessary to enable us to process your request.

Legal basis. In the above cases, your personal data is processed on the basis of:

  1. Article 6(1)(f) GDPR, i.e. on the basis of our legitimate interests of seeking to provide the most comprehensive response to your question/request, or 
  2. Article 6(1)(b) GDPR, i.e. the necessity of the processing for the performance of the contract, if the request is directly related to your use of our services within the scope of the access granted to you and the proper performance of our obligations / possibly to take action at your request before entering into a contract with us;
  3. Article 6(1)(c) GDPR, i.e. on the basis of a provision of law, if the request is related to your personal data or other legal obligation incumbent on us under the relevant legislation.



Data type. In this case, we process any personal data that you include in the content of the messages you send to us (for e.g. identification data such as name, surname and e-mail address / selected messenger ID number).


CONCLUSION OF THE CONTRACT AND/OR USE OF WEBSITE RESOURCES 


Purposes. We may process the personal data that you provide in connection with the conclusion of a contract with us as well as in connection with services that we render for you, particularly on Teachable.com - your personal data is then processed primarily for the purpose of (i) verifying your eligibility to enter into a contract (ii) verifying your eligibility to use the services we render (iii) providing you with such services (for this reason, we may exchange some of your data with Teachable.com) (iv) investigating and defending against claims. 

Provision of data is voluntary but necessary to enter into a contract with us and use the services we render. 


Legal basis. The legal basis for processing your personal data for the above purposes is:

  1. to the extent related to the conclusion and execution of the contract:
  2. if you represent a legal person or an unincorporated entity, or you are a proxy of a sole proprietor - our legitimate interest, i.e. Article 6(1)(f) GDPR,
  3. if you are an individual, including a person conducting a sole proprietorship and acting on your own behalf - the necessity to enter into a contract and execute it, i.e. Article 6(1)(b) GDPR;
  4. to the extent necessary to settle the contract, in particular in accordance with tax and accounting regulations and to fulfill other legal obligations that are incumbent on us as the PDC - Article 6(1)(c) GDPR; 
  5. to the extent relating to the investigation and protection against claims - our legitimate interest, i.e. Article 6(1)(f) GDPR.


Data type. The types of data we process in this way may include, in particular: 

  1. identification data, e.g. first name, last name, ID card number, PESEL number, NIP, REGON;
  2. address data, e.g. e-mail address, telephone number, address of residence/registration/business;
  3. any other personal data posted by you or your employees and associates.


OUR MARKETING, STATISTICAL AND ANALYTICAL PURPOSES


Purposes. We may process your personal data for the purposes of: (i) promoting our own products and services, including informing you of updates to the services or products you use, and (ii) analyzing how you use our services and the Website to provide you with the highest quality service. For this purpose, we may process data about your activity on the Website, such as the subpages you visit on the Website, your use of particular services offered through the Website, and the time you visit the Website. This data may be linked to your email address and account.


Legal basis. The legal basis for the processing of your personal data for the above purposes is our legitimate interest or the legitimate interest of a third party - Article 6 (1) (f) GDPR or Article 6 (1)(b) GDPR – performance of the contract, if you accepted our newsletter terms and conditions.


Data type. Data processed for the above purposes may include, in particular:

  1. identification data, e.g. IP address;
  2. address data, e.g. email address, telephone number;
  3. data about your behavior on the Website, for instance: date and time of visiting the page, kind of operating system, estimated location, kind of browser used to view the page, time passed on the website, viewed subpages, watched videos embedded on the subpages.


Consent to our commercial information. In addition, if you have provided us with your email address and you have consented to be contacted through this channel, we may send our commercial information (e.g., our offer or advertisement of our services) to a such email address for these purposes. 


You have the right to withdraw the consent given in this regard at any time by sending an email to: [email protected] or by clicking on the relevant link provided in the email sent by us to you - however, this does not affect the legality of operations (sending commercial information) performed by us until the consent is withdrawn. If you withdraw your consent, we will not send you commercial information by email or telephone, but we may still process your personal data for our marketing purposes (based on Article 6(1)(f) GDPR. 


Facebook Conversion API

Purposes: After you sign up for our newsletter and give consent to the processing of your data, we may process data regarding your newsletter sign-up and any subsequent purchases using Facebook Conversion API. This data is sent to Facebook to analyze the effectiveness of our advertising campaigns and personalize ads.

Legal basis: The legal basis for processing your personal data in this context is your consent (Article 6(1)(a) GDPR) obtained when you submit the newsletter signup form.

Data type: Data processed for this purpose may include, in particular:

• Identification data: SHA256 hash of email address (we do not send the actual email address);

• Transaction data: details of purchases made.

You have the right to withdraw your consent at any time by contacting us at [email protected]. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.


WEBSITE MANAGEMENT PURPOSES


Purposes. We may process your personal data for the purposes of managing your access to our resources and administrating the Website. 


Legal basis. The legal basis for the processing of your personal data for the above purposes is our legitimate interest or the legitimate interest of a third party - Article 6 (1) (f) GDPR.


Types of data. Data processed for the above purposes may include, in particular:

  1. identification data: IP address,
  2. server or computer system data: information concerning the request sent to our server, your browser, or operational system.
    — the above data is stored automatically in so-called server log files every time the Website is used. Administrating the Website without using the server and its automatic data storage would not be possible. 


3) Cookie Files

We use only essential cookies required for the operation of the Website and displaying our newsletter signup form (ConvertKit). These cookies do not require user consent as they are necessary for the proper functioning of the Website. For more detailed information about the specific cookies used by ConvertKit and their purposes, please refer to ConvertKit’s Privacy Policy.


Legal basis. The legal basis for processing personal data that may be collected by cookie files is:

  1. Article 6 (1)(f) GDPR– our legitimate interest or Article 6 (1)(b) GDPR – performance of the contract, when it is necessary for the operation of the Website or rendering the services we offer for you.  
  2. Article 6 (1)(a) GDPR – your freely given consent that can be granted as you enter the Website for the first time.


You are informed about the details concerning cookies during your first visit to the Website through the cookie banner - then you learn when we need your consent to process personal data collected by cookies, and you have the option to consent or reject the use of selected or all cookies (except for the essential ones).


Whenever we base the processing of your personal data on your consent, you can withdraw that consent. You have the right to withdraw your previously given consent at any time by sending an email to: [email protected] or by changing your browser settings - however, this does not affect the legality of the processing operations we have carried out up to the time of withdrawal of consent.  


Data type. Data collected by cookie files may include, in particular:

  1. identification data: IP address, first name, last name;
  2. contact data: e-mail address, telephone number;
  3. behavioral data about how you use the Website.


BLOCKING COOKIES
Your browser allows storing cookies on your end devices by default. You may object to using all cookies while accessing the Website by changing the settings in your browser. The settings may be changed in every time. Please note that blocking or limiting all cookies may cause serious problems in Website usage, such as the long time of loading the Website, limitation on the use of its functions, etc.


4) Automated Decision-Making And Profiling

We do not make automated decision-making and profiling. 


5) Recipients of personal data

Like other entrepreneurs, we are supported by different entities which usually involves the transfer of personal data. Due to the above, we may provide your personal data to the hosting companies, software providers (for e.g. Hotmart B.V., ConverKit LLC, Hello Bar LLC, Deadline Funnel, SparkTech Enterprises Ltd), marketing agencies or our tax, business and legal advisors if there is such a need.

Moreover, we may be asked to disclose your personal data to other entities, public or private, if the competent state authority or the law requires such disclosure. 

We assure you that every request to disclose your personal data is analyzed carefully and profoundly, in order to prevent inadvertent informing the unauthorized person.


Data Processing Agreement (DPA) with ConvertKit

We have entered into a Data Processing Agreement (DPA) with ConvertKit to ensure that they process personal data in compliance with applicable data protection laws. ConvertKit acts as a data processor on our behalf, processing email addresses and other personal data collected through our newsletter signup forms.


Transfers of personal data to third countries

We kindly inform you that we may rely on tools, whose providers are based outside EEA (European Economic Area) – in such cases, we transfer your personal data on the basis of the decisions made by the European Commission stating the appropriate level of data protection in the given countries (so-called adequacy decisions), standard contractual clauses or other legal instruments mentioned under Chapter V GDPR. 


6) Time of Processing
In accordance with the law, we do not process your personal data ‘’endlessly” but for the time that is needed to achieve the desired purposes. After such time, your personal data will be irreversibly deleted or erased, unless there is other legal ground to process it. 


Your personal data is processed until:

  • the time of effective objection to processing or achieving the desired objective of processing — if the basis for processing is our legitimate interest;
  • the time prescribed by law – if the basis for processing is our legal obligation;
  • the consent is effectively withdrawn if the processing was based on the consent.


7) Your Rights

You have the right to:

  • access your personal data;
  • correct your personal data;
  • delete your personal data;
  • limit the processing of your personal data;
  • object to the processing of your personal data (please note that the objection has to be justified and will only be considered as blocking our right to process your data if your personal interest overrides ours. Also, please note that objection does not influence the processing undertaken by us before it was deemed justified and effective);
  • receive your data that you have provided to us in a structured, common and machine-readable format or to request that it be transferred to another controller ("data portability"), provided that (1) the processing is based on consent or on a contract premises, and 2) the processing is carried out by automated means.


We respect your rights arising from law regulations and we try to facilitate their realization to the greatest extent possible. Please note however that the aforementioned rights are not of the absolute character, therefore, we may refuse to fulfill them in accordance with the law in some cases. 


You may exercise your rights by sending an e-mail directly to the PDC to the e-mail address: [email protected].


If you consider that your personal data are processed unlawfully, you may file a complaint to the President of Personal Data Protection Office.


8) Final Provisions


In the absence of specific provisions of this Privacy Policy, the regulations concerning personal data protection shall apply.


Please note that as we may occasionally and reasonably modify the Policy, thus you may receive some notifications on your e-mail address from us about such updates.