Zinisoft is committed to protecting your privacy and personal data. This privacy policy (“Privacy Policy”) explains how Zinisoft Sp. z o. o. and its authorized partners and affiliates (“Zinisoft”) process personal data in connection with zinisoft.net.

As used in this Privacy Policy, the term “personal data” means any information about you which is personally identifiable like your name, address, telephone number, e mail address or any other personal information that may be supplied by you.

Please read this Privacy Policy carefully prior to accessing the Website. If you do not agree with this Privacy Policy, we expect you to leave this Website.

Personal data

Zinisoft may collect personal data that you voluntarily provide when using the Website. By using this Website or submitting your personal data, you consent to Zinisoft’s processing of your personal data as further described herein.

Zinisoft always notifies the user of the collection of personal data through the Website.

The personal data collected through the Website includes general contact and personal information such as name, address, email, phone, subscriber organization, information about people’s contact requests, information required from job applicants used for recruitment and staffing purposes (the candidate management system provided by softgarden eRecruiting GmbH), as well as other information required to manage the Website and provide the services contained therein.

Purpose of personal data processing

The personal data collected through the Website is processed for the purposes of managing customer, investor and media relations and communications, handling contact requests and course subscriptions, providing marketing information, conducting recruitment and HR purposes, and dealing with other matters relating to the management and development of the Website and the services provided on it.

We will not keep them for longer than is legally permissible and necessary for these purposes.

Legal basis for data processing

As part of his activities, Zinisoft collects and processes personal data:

1. for the purpose of concluding and performing contracts concluded with the users of the Website, as well as for the purpose of correct and complete provision of services and fulfilling legal obligations incumbent on Zinisoft — legal basis: Art. 6 (1) (b) GDPR, Art. 6 (1) © GDPR;

2. for the purposes arising from the legitimate interests pursued by Zinisoft, i.e. for analytical and statistical purposes and to ensure IT security related to the Website — legal basis: Art. 6 (1) (d) GDPR.

Your rights

You have the right to know what personal data we hold about you. You may contact Zinisoft in order to review the accuracy of the personal data related to you. Upon your request Zinisoft will rectify or erase any incomplete, inaccurate or outdated personal data.

You may withdraw you consent for processing of your personal data. As processing of your personal data is necessary for us to be able to provide you with our services, revoking your consent may lead to a situation where we cannot provide you with some or all of the services.

You have the right of access to your personal data, the right to rectification, erasure or restriction of processing, the right to data portability, the right to object if the processing is based on Article 6 (1) (f) GDPR.

Right to lodge a complaint

You have the right to lodge a complaint related to the processing of your personal data by the Administrator to the President of the Personal Data Protection Office.

IP addresses, cookies and other tools

Zinisoft may collect information about your computer, including where available your IP address, operating system and browser type and for system administration. This is statistical data about Zinisoft’s users’ browsing actions and patterns, and does not identify any individual.

For the same reason, Zinisoft may obtain information about your website usage by using a cookies file which is stored on the hard drive of your computer. Cookies contain information that is transferred to your computer’s hard drive. They help us to improve our site and to deliver a better and more personalized service. They enable us:

• To estimate our audience size and usage pattern.

• To store information about your preferences, and so allow us to customize our site according to your individual interests.

• To speed up your searches.

• To recognize you when you return to our site.

You may refuse to accept cookies by activating the setting on your browser which allows you to refuse the setting of cookies. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, Zinisoft’s system will issue cookies when you log on to our site.

Social media

Zinisoft also processes your personal data within our accounts on portals such as: Facebook, Instagram and LinkedIn. The personal data processed includes data identifying the user’s profile of the portal (usually including first and last name), his/her profile picture, the content of comments posted by the user’s portal.

In the case of social media, your personal data is processed on the basis of Article 6 (1) (f) GDPR, i.e. on the basis of Zinisoft’s legitimate interest.

The purpose of the processing of the personal data of the users of the portal is to run Zinisoft’s profile on the social networking site Facebook and LinkedIn, under the terms and conditions specified by Facebook Inc., Facebook Ireland ltd. and LinkedIn Corporation and to inform by means of it about Zinisoft’s activity, and for the purpose of communication via available Facebook functionalities (comments, chat, messages).

Personal data collected through communication with the user is only processed for the purpose of responding, if necessary.

The personal data, which we hold in private messages, is stored until the user of the portal objects to further processing of such data. In the case of information that we have in our possession as part of your comments, they are available on our profile until they are deleted by the author or, in justified cases, by Zinisoft, e.g. in the case of posting comments on our profile inciting violence, propagating hatred, or being spam or a form of recommending the services of another entity.

Transfer of personal data to other entities

The recipients of your personal data may be Zinisoft’s authorised employees, external service providers, e.g. IT service providers, marketing service providers, web hosting providers, online payment service providers, carriers, insurers, subcontractors, entities managing the Facebook social network (Facebook Ireland Ltd. and Meta Platforms Inc.) and the LinkedIn portal (LinkedIn Corporation) and other entities processing data on behalf of Zinisoft on the basis of a contract for entrustment of personal data processing, as well as accountants, lawyers, administrative authorities, state services and courts.

Transfers of data to third countries (outside the European Economic Area)

Your personal data may be transferred to third countries, such as the USA, in connection with Zinisoft’s use of the services of entities based outside the European Economic Area (Google Inc., Facebook Ireland Ltd., Meta Platforms Inc., LinkedIn Corporation), in order to ensure the correctness, effectiveness and efficiency of the services provided. In this case, Zinisoft, in accordance with the requirements of the GDPR, implements security measures to ensure correct processing and adequate protection of your personal data.

Google Suite

More information on the processing of personal data by this entity can be found at: https://support.google.com/a/answer/60762?hl=pl.

Facebook

More information on the processing of personal data by this entity can be found at: https://pl-pl.facebook.com/business/gdpr/ and https://www.facebook.com/about/privacy and https://pl-pl.facebook.com/legal/terms.

Instagram

More information on the processing of personal data by this entity can be found at: https://www.facebook.com/help/instagram/519522125107875.

HubSpot

More information on the processing of personal data by this entity can be found at: https://legal.hubspot.com/privacy-policy.

Google Analytics

This Website uses Google Analytics, a web analytics service provided by Google Inc. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google Inc. on servers in the United States.

Google Inc. will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for Website operators and providing other services relating to Website activity and internet usage. Google Inc. may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google Inc.’s behalf.

Google Inc. will not associate your IP address with any other data held by Google Inc. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Website. By using this Website, you consent to the processing of data about you by Google Inc. in the manner and for the purposes set out above.

Google Analytics

This Website uses Google Analytics, a web analytics service provided by Google Inc. The information generated by the cookie about your use of the Website (including your IP address) will be transmitted to and stored by Google Inc. on servers in the United States.

Google Inc. will use this information for the purpose of evaluating your use of the Website, compiling reports on website activity for Website operators and providing other services relating to Website activity and internet usage. Google Inc. may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google Inc.’s behalf.

Google Inc. will not associate your IP address with any other data held by Google Inc. You may refuse the use of cookies by selecting the appropriate settings on your browser, however please note that if you do this you may not be able to use the full functionality of this Website. By using this Website, you consent to the processing of data about you by Google Inc. in the manner and for the purposes set out above.

Introduction

Our Website uses HubSpot for various marketing and analytics purposes. HubSpot helps us improve your experience on our Website and understand our audience better. This section of our privacy policy explains how we use HubSpot, what data we collect, and how that data is used.

Cookies and Tracking Pixels

We use HubSpot’s tracking pixel and cookies to collect data about your interactions with our Website. A cookie is a small piece of data that our Website asks your browser to store on your device. The tracking pixel is a transparent image file, used to monitor your journey around a single Website or collection of sites.

These technologies enable us to:

Understand user behavior (e.g., which pages you visit and how long you stay on them).

• Improve site performance and user experience.
• Serve more relevant content and offers to our users.

Data Collected

Through HubSpot, we may collect:

• Details of your visits to our website and the resources you access.
• Information about your device, including where available, your IP address, operating system, and browser type.
• Other data relevant to customer surveys and/or offers.

Use of Data

The data we collect via HubSpot is used to:

• Understand and analyze our website traffic and user behavior.
• Personalize your experience on our site.
• Improve our products, services, and marketing efforts.
• Carry out retargeting and ad-related activities.
• Data Sharing and Transfers

HubSpot is a trusted partner and ensures data protection compliance in line with EU regulations. However, as part of the services offered to our users, the information you provide to us may be transferred to and stored in countries outside the European Economic Area (EEA). By submitting your personal data, you agree to this transfer, storing, or processing.

Your Choices and Rights

You can opt-out of HubSpot’s tracking cookies and tracking pixels at any time by adjusting your browser’s cookie settings or using our cookie management tool.

File descriptions and contacting Zinisoft

If you have any questions regarding this Privacy Policy or if you are concerned about how your personal data is processed by Zinisoft, please contact Zinisoft hi@zinisoft.net.

Files description related to the processing of personal data under this Website for marketing and communication purposes is attached as a file.

File description related to processing of personal data under this Website for recruitment and HR purposes is attached as file.

Changes to the Privacy Policy

Zinisoft reserves the right to amend this Privacy Policy at any time and the linked File Description. You must review this Privacy Policy from time to time for any amendments.

Information clause

The following information clause is dedicated to the visitors of the Website, the profiles of Zinisoft sp. z o. o. in social media on portals such as: Facebook, Instagram and LinkedIn, as well as persons participating in the recruitment process using the candidate management system provided by softgarden eRecruiting GmbH.

1. The controller can be contacted via email: hi@zinisoft.net.

2. The Data Protection Officer, appointed by Zinisoft, can be contacted by email: hi@zinisoft.net.

3. We process your personal data collected through the Website, which includes general contact and personal information such as name, address, email, telephone, subscriber organisation, information about people’s contact requests, information required from job applicants used for recruitment and staffing purposes (candidate management system provided by softgarden eRecruiting GmbH), as well as other information required to manage the Website and provide the services contained therein. In the case of Zinisoft’s official profile on the social networks Facebook, LinkedIn and Instagram, the personal data processed includes data identifying the profile of the portal user (usually including name), his profile picture, the content of the comments posted by the portal user.

4. Your personal data is processed on the basis:

Article 6 (1) (a) GDPR, i.e. on the basis of your consent given when you access the Website, as well as on the basis of your consent given on a separate form (the candidate management system provided by softgarden eRecruiting GmbH);

Article 6 (1) (b) GDPR, i.e. for the purpose of concluding and performing contracts concluded with users of the Website;

Article 6 (1) ©© GDPR, i.e. for the correct and complete provision of services and to fulfil Zinisoft’s legal obligations, in particular to carry out the employee recruitment process pursuant to Article 221 § 1,2, 4 and Article 221a LC;

Article 6 (1) (df) GDPR, i.e. for the purposes arising from the legally justified interests pursued by Zinisoft, i.e. for analytical and statistical purposes as well as for ensuring information and communication security related to the Website and for exercising rights or claims before any state authorities.

5. The purpose of the processing of your data is to manage customer, investor and media relations and communications, to handle contact requests and course subscriptions, to provide marketing information, to carry out employee recruitment, and to handle other matters relating to the management of the Website and the services provided therein and their development. In the case of maintaining an official profile of Zinisoft on social networking sites Facebook, LinkedIn and Instagram, the purpose of the processing of personal data of users of such sites is to maintain an official profile of Zinisoft on these sites, under the terms and conditions laid down by Meta Platforms Inc., Facebook Ireland ltd. and LinkedIn Corporation and to inform through it about Zinisoft’s activities, and to communicate via the available Facebook functionalities (comments, chat, messages).

6. Recipients of your personal data may be authorized employees of Zinisoft, external service providers, e.g. IT service providers, marketing service providers, web hosting providers, online payment service providers, carriers, insurers, subcontractors, entities managing the social networking site Facebook (Facebook Ireland Ltd. and Meta Platforms Inc.) and the LinkedIn portal (LinkedIn Corporation) and other entities processing data on behalf of Zinisoft on the basis of an agreement on entrustment of personal data processing, as well as accountants, lawyers, administrative bodies, state services and courts.

7. Personal data collected through communication with you via Facebook (comments, chat, messages) are processed only for the purpose of responding, if necessary.

8. Your personal data will not be kept longer than legally permitted and necessary for the purposes of the processing — in the case of the recruitment process for a period of three years. As for the personal data we hold in private messages on Facebook, this will be kept until you object to further processing of such data. As for the information we hold in the context of comments you have provided, it is available on our portal until deleted by the author or, in justified cases, by the Administrator, e.g. in the case of posting comments on the portal inciting violence, promoting hatred, or being spam or a form of recommendation of the services of another entity.

9. Your rights are:

the right of access to your personal data, including obtaining back-up copies;

the right to rectification of personal data;

the right to erasure or restriction of processing;

the right to portability of your data;

the right to withdraw consent at any time without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal.

10. Furthermore, you may lodge a complaint with the supervisory authority, which is the President of the Personal Data Protection Office, if you consider that the processing of your personal data by the controller violates the provisions on personal data protection.

11. Your personal data shall not be subject to profiling.

12. Providing data is voluntary, however, the consequence of failing to provide data will be the inability to participate in the recruitment process and inability to view Zinisoft’s official profile on social networking sites Facebook, LinkedIn and Instagram or leave comments (Facebook service).