Privacy Policy

General Information

This Privacy Policy sets out the rules for data processing, including Personal Data, and the protection of the privacy of Website Users and Users.

  1. Definitions Personal Data (Data) – information about an identified or identifiable natural person (“data subject”). The Personal Data processed as part of the Website’s operation is the data referred to in point II. 1 of this Privacy Policy.

Cookie files (so-called cookies) – small information files, created by a web browser at the entrance to each website, saved on the Website User’s or User’s Device, which the Website User or the User uses while browsing the websites. During the next visit from the same Device, the browser can check if the appropriate Cookie File is saved on the Device and send the data contained therein to the page that saved the cookie. Thanks to this, it is possible to recognize whether the Website User or the User of a given Device has already visited a previously specified website and how he used it.

Advertiser – an entity interested in presenting advertisements for its products or services to Users.

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 (general regulation on the protection of data).

Website – website located at: www.pragmaticad.com

Service – a service provided by the Website Owner consisting in presenting to Users, at the request of Advertisers, advertising content on the websites of Media Partners.

Device – the end device from which the Website User or the User connects to the Website or websites of Media Partners, such as e.g. a telephone, tablet, computer.

User – a natural person or other entity using websites, whose data, including Personal Data, are saved in Cookies placed on the websites of Media Partners by the Media Partners themselves or by the Website Owner.

Website User – a natural person or other entity using the Website, in particular an Advertiser or Media Partner.

Owner of the Website – PRAGMATICAD limited liability company with its seat in Warsaw, address: ul. Czapli 57, 02-781 Warsaw.

Media Partner – a natural person who is not a consumer with full legal capacity, a legal person, or an organizational unit without legal personality interested in placing advertisements on their own or third-party resources. A Media Partner may, in particular, be: a) the owner or the person managing the mobile application, b) influencer, i.e. a person with a channel or profile in social media, c) the owner or the person managing the mailing base; The Media Partner may place their own Cookies on the website or allow the Website Owner to place the Website Owner’s Cookies on this website.

Who we are and what we do

PRAGMATICAD SP. Z O. O. is an entity from the technology industry, the subject of which is the provision of digital tools enabling the presentation of advertising content to Users at the request of Advertisers on the websites of Media Partners. As part of the Service, we provide Advertisers with tools that provide advertising space on the websites of Media Partners. Our Website also provides tools to present certain advertising content only to those Users who may potentially be interested in the product or service presented in the advertising message.

Our Data

PRAGMATICAD SP. Z O. O. ul. Czapli 57, 02-781 Warsaw, KRS 0000694503, NIP 5272820694, REGON 368298879

Contact

Traditional mail: PRAGMATICAD SP. Z O. O. ul. Czapli 57, 02-781 Warsaw. E-mail: kontakt@pragmaticad.com Data Protection Officer: iod@pragmaticad.com

Personal Data

  1. What data of the Website Users do we collect, for what purpose, on what basis and for how long we will store them.

In connection with the use of the Website, we may use Personal Data (in particular in the case of Website Users logged in to the Website), as well as other data that may, but not always, enable the identification of a specific Website User, contained e.g. in Cookies. If, in connection with the use of our Website by Website Users, we come into possession of their Personal Data, we are the administrator of this Data. At the time of connecting to our Website, information about numbers, including IP address or MSISDN number, type of Device and type of software on the Device from which the connection with the Website was made, appears in the Website’s system logs. If you want to use our Service, please fill out the registration form, in which it is necessary to provide other data necessary to register and create an account on the Website. Providing such data is voluntary and does not constitute a statutory obligation, but failure to do so makes it impossible to register and create an account on the Website. We process the data referred to above in order to:

enabling the use of the Website, in particular registration and creation of an account on the Website, as well as logging in and servicing the account on the Website – for the duration of the Website User’s use of the Website (the legal basis for data processing for this purpose is art.6 par.1 b) GDPR, called in short “Performance of the contract”);
performance of our legal obligations – for the duration of the performance of these obligations (the legal basis for data processing is Article 6 (1c) of the GDPR, shortly referred to as “legal obligation”), or for the period in which the provisions require the storage of Data (the legal basis for data processing is a legal obligation), or for the time during which we may suffer the legal consequences of non-performance of our legal obligation, e.g. receive a financial penalty (the legal basis for data processing is Article 6 (1) f) of the GDPR, shortly referred to as “our legitimate interest”) ;
establishing, defending and pursuing claims, including between us and entities cooperating with us (e.g. Advertisers, Media Partners) – for the period after which the claims expire (the legal basis for data processing for this purpose is our legitimate interest);
detecting and combating abuses when using the Website and ensuring the security of the Website – for the duration of using the Website, and then for the period after which the claims resulting from such use expire, and in the case of our pursuing claims or notifying the competent authorities – for the duration of the proceedings in the matter (the legal basis for data processing for this purpose is our legitimate interest);
improving the operation of the Website – for the duration of the use of the Website (the legal basis for data processing for this purpose is our legitimate interest);
creating statistical summaries and analyzes for our internal needs – for the period during which we store Data for other purposes indicated above (the legal basis for data processing for this purpose is our legitimate interest);
direct marketing, including profiling (i.e. automated data analysis and the development of predictions about the preferences or future behaviors of Website Users) – until an objection to the processing of Data for this purpose (the legal basis for Data processing is our legitimate interest).

  1. Who we will provide the Website Users’ Data to

The data may be transferred to: a. Entities processing them on our behalf, including:

intermediaries in the sale of our Services,
operators of our ICT systems or providing us with ICT tools,
providing us with advisory, audit, legal, tax and accounting services, b.other data administrators, processing them on their own behalf, including:
law firms. We do not anticipate the transfer of Data outside the European Economic Area.

  1. What are the rights of the Website Users

The Website User may submit an application (regarding Personal Data) for:

access to his Personal Data processed by us, i.e. to receive information about the Personal Data processed by us or to receive a copy of the Data,
rectification (correction) of Personal Data,
deletion of Personal Data or limitation of their processing,
transfer of Personal Data to another data administrator or to the Website User. The implementation of these rights by us depends on the possibility of identifying the person submitting the application to be sure that it has been submitted by an authorized person. The scope of each of the above-mentioned rights and the situations in which they can be exercised result from the provisions of law. The rights that the Website User may exercise will depend, for example, on the legal basis and the purpose of processing Personal Data.

Objection to the processing of Personal Data

Regardless of the rights mentioned above, the Website User may object at any time to the processing of Personal Data (including profiling) for the purposes of direct marketing. After accepting the request in this matter, we are obliged to stop processing the Data for this purpose. In special situations, the Website User may at any time object to the processing of his Personal Data (including profiling) by us, if the basis for using the Data is our legitimate interest or public interest. In such a situation, after considering the application, we will no longer be able to process the Personal Data covered by the objection, unless we prove that there are:

valid and legitimate grounds for the processing of data which are deemed by law to override the interests, rights, and freedoms of the Website User, or
grounds for establishing, investigating or defending claims.

Consent to the processing of Personal Data

If the legal basis for the processing of Personal Data of the Website Users is the consent granted, such consent may be withdrawn at any time. Withdrawal of consent will not affect the lawfulness of the processing of Personal Data on the basis of consent, prior to its withdrawal. Application for the exercise of the rights indicated in point II. 3-5 can be submitted to our address indicated above in “Contact us”.

Right to lodge a complaint

A Website User who considers that his Personal Data is being processed unlawfully may lodge a complaint with the President of the Personal Data Protection Office.

Cookies

As part of the Website, we also use Cookies, which may or may not be related to the Personal Data of Website Users. Cookies may contain information about which parts of the Website or other websites were used by Website Users in the past.

  1. For what purpose and on what basis we use Cookies

We use cookies for the following purposes:

creating anonymous statistics of visits to the Website and individual subpages of the Website,
adjusting the Website to the needs of Website Users and potential Website Users,
ensuring the security of the session,
maintaining the continuity of the session,
remembering the settings on the Website,
marketing, both for the presentation of tailored advertisements or content on the Website, as well as on the websites of Media Partners. The legal basis for our use of the information contained in Cookies is the consent of the Website User.

  1. How you can withdraw your consent to Cookies

The Website User may independently and at any time, through the settings of the web browser used on the Device, withdraw consent to the storage and access to Cookies on this Device, thus blocking the acceptance of new Cookies. Most web browsers offer the option of:

accepting and rejecting all Cookies,
accepting only some Cookies and rejecting others,
sending notifications about each posting of a Cookie File on the Device. By using the functions available in the web browser used by the Website User on the Device, it is also possible to delete Cookies previously placed on the Device. The method of managing Cookies may differ depending on the type of web browser used by the Website User. Detailed information on the possibilities and methods of handling Cookies is available in the web browser settings. Please note that blocking or limiting the use of Cookies, as well as deleting previously saved Cookies from the Device may cause difficulties in using the Website or completely prevent the use of some of its functionalities.

  1. Acquiring and using Cookies

In connection with the provision of the Service to Advertisers and Media Partners, we may use information stored in Cookies placed on Users’ Devices. We obtain this information:

as a result of placing own Cookies on the website of the Media Partner,
as a result of placing own Cookies on the Advertiser’s website,
from external partners providing such data, This information does not identify a specific User. We use them to:
implementation of marketing campaigns for Advertisers aimed at Users who may potentially be interested in a given product or service offered by the Advertiser,
creating marketing profiles to adjust the advertisements displayed on the websites of Media Partners to the interests and expectations of Users visiting these websites. The legal basis for using the information contained in Cookies is the User’s consent, granted through the settings of the web browser used by the User. The consent to Cookies may be withdrawn in the manner described above in point III.2.

Data Safety

Ensuring the security of your data is our top priority. Therefore, in addition to complying with legal provisions regulating issues related to the protection of privacy and personal data, we use high-quality security measures and best practices to protect the data we collect and use. We make sure that only authorized persons have access to them, and thanks to the use of appropriate technical and organizational measures, they do not fall into the possession of unauthorized persons in an uncontrolled manner.

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