PRIVACY POLICY

Definitions

Controller – the personal data controller within the meaning of Article 4(7) of the GDPR, that is Fool’s Theory Sp. z o. o. with its registered office in Bielsko-Biała, ul. 1 Maja 15, 43-300 Bielsko-Biała, NIP7010803359.

Cookies – text data collected in the form of files placed on the Device.

Personal data – information about an identified or identifiable natural person (“data subject”); an identifiable natural person is one who can be identified, directly or indirectly, in particular, by reference to an identifier such as a name, an identification number, location data, an online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the individual.

Processing – an operation or a set of operations performed on Personal Data or sets of Personal Data, whether or not by automated means, such as collecting, recording, organising, structuring, storing, adapting or modifying, retrieving, viewing, using, disclosing by transmission, dissemination or otherwise sharing, aligning or combining, restricting, erasing or destroying.

Privacy Policy – this document.

GDPR – Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

Website – a website where the Controller provides its Services, that is: https://www.foolstheory.com/

Device – a device with software through which the User gains access to the Website.

User – an adult natural person using the Services offered by the Controller as part of the Website. In the case of a minor or completely incapacitated person, the legal representative of that person is considered to be the User.

§ 1 General provisions

This Privacy Policy sets out the rules for the processing and protection of personal data provided by Users in connection with their use of the services offered through the Website.
The Privacy Policy applies to all Users using the Website and services provided on the Website at: https://xxxxxxxxxxxxxxxxxx [A1]
The principles regarding the protection of personal data are set out inter alia in Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as the GDPR), the Personal Data Protection Act in the national law, and in special laws – also in the national law.

§2. Data Controller

The Controller of personal data contained on the website is Fool’s Theory Sp. z o. o. with its registered office in Bielsko-Biała, ul. 1 Maja 15, 43-300 Bielsko-Biała, NIP 7010803359.
Contact in matters related to the processing of personal data and the exercise of rights related to the processing of personal data is possible at the e-mail address: xxxxxxxxxxxxxxx [A2]

§3. Purposes and legal bases for the personal data processing

Personal Data obtained as part of the operation of the Website are processed on the basis of the consent expressed by the User, for the purpose of the contract concluded between the parties or on the basis of the legitimate interest of the Controller.
The data are processed for the following purposes:
1. in connection with the provision of services offered by the Website. The legal basis for the processing of personal data is a contract, i.e. processing is necessary to perform a contract to which the data subject is a party, or to take action at the request of the data subject before concluding a contract (Article 6(1)(b) of the GDPR),
1. sending commercial information, including marketing information, by electronic means or telephone in relation to own products and services. The legal basis for the processing of personal data is the consent of the data subject (Article 6(1)(a) of the GDPR) or the processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except for situations where the interests or fundamental rights and freedoms of the data subject requiring protection of personal data override these interests, in particular, when the data subject is a child (Article 6(1)(f) of the GDPR),[A3]
1. for contact purposes, i.e. receiving and handling reports and inquiries sent via the contact form, e-mail, telephone or other means of distance communication, pursuant to Article 6(1)(f) of the GDPR, where the legitimate interest of the Controller is to respond to submitted notifications and inquiries.

§4. Obtaining personal data

The Website performs the functions of obtaining information about the users and their behaviour in the following manner:

through the information voluntarily entered in the forms,
by collecting cookies – see the Cookie Policy.

§5. Scope of personal data processing

The scope of personal data being processed has been limited to the minimum necessary to provide services, and depends on the purpose for which the data are processed. Providing data which are not necessary for the provision of the service is voluntary and requires explicit action by the Website User for their further processing.
When contacting us via the contact form, e-mail, telephone or otherwise, the following data may be collected: first name, surname, e-mail address, telephone number, and other data, if provided in the content of the correspondence.
The Website also uses Cookies, which may also process personal data, such as data regarding the User’s activity on the Website, in particular, data on how much time the User spent on the Website, what options they used and what actions they performed, as well as their IP address, location, device ID. More details on the functioning of Cookies can be found in the Cookie Policy.

§6 Period of storage of personal data

If you use the services offered by the Website, personal data are processed for the duration of the service contract.
In the case of the consent to receive commercial information, including marketing information, electronically or by telephone in relation to own products and services, for an indefinite period until an objection is raised. Withdrawal of the consent in the case of receiving commercial information, including marketing information in relation to own products and services, is possible at any time without affecting the lawfulness of the processing carried out on the basis of the consent before its withdrawal.[A4]
In the case of personal data left for contact purposes, until comprehensive information is provided in response to the inquiries received and then until the defense or pursuit of any claims related to the answer provided.
In the case of information collected using Cookies, in accordance with the information specified in relation to individual files. More details in the Cookie Policy.

§7. Sharing and entrusting personal data

Personal data collected on the Website may be transferred to data recipients, public authorities or entities under the currently applicable legal provisions and may be entrusted for processing pursuant to Article 28 of the GDPR (the Controller has entrusted the processing of personal data to onther entity – the processor). The data Controller cooperates only with entities that meet the requirements of the GDPR and have implemented appropriate technical and organisational measures to secure the entrusted personal data.

§8. Transfer of personal data to a third country

Personal data collected on the Website are not transferred to a third country or an international organisation. However, the website uses various services, tools and technologies offered by companies based outside the European Union (e.g. Facebook, Google). As part of the use of tools provided by these entities, which may collect anonymous data about Users, data may be stored on servers located in third countries outside the EEA. However, the providers of these services guarantee an adequate level of personal data protection through the compliance mechanisms provided for in the GDPR.

§9. Rights in connection with the processing of your personal data

If you want to exercise your rights, you can submit a request via the contact form. In addition, you can also use the Account settings regarding privacy (applies to people who have an Account).

Request fulfilment time

If you exercise the above-mentioned rights and contact us with a certain request, we will fulfill this request (or refuse to fulfill it, if necessary) immediately, but no later than within one month from the date of receipt of the request. If the request is complicated or there are many such requests and we are unable to fulfill it within a month, we undertake to fulfill it within the next two months, having previously informed you about the extension of this deadline.

The right to withdraw the consent

You have the right to withdraw your consent to the processing of your Personal Data, which you granted when using our Services and functionalities. Withdrawal of the consent takes effect from the moment of withdrawal and does not affect the processing carried out by us before its withdrawal.

Basis: Article 7(3) of the GDPR

The right to object to the use of your data

You have the right to object to the use of your Personal Data, including profiling, if we process your Personal Data based on our legitimate interest specified in Article 6(1)(f) of the GDPR.

Basis: Article 21 of the GDPR

The right to limit the processing of your data

You have the right to request restriction of the processing of your Personal Data, including: questioning the accuracy of Personal Data. After submitting this request to us, until it is considered, it may become impossible for you to use some functionalities or Services – this applies to Personal Data covered by the request.

Basis: Article 18 of the GDPR

The right to the erasure of your data (“the right to be forgotten”)

You have the right to request the erasure of your Personal Data. Below, we indicate when you have the right to request us to erase your Personal Data:

the processing of your Personal Data is unlawful;
after withdrawing the consent to the processing of your Personal Data, to the extent that the processing was based on this legal basis;
after you object to the processing of your Personal Data in connection with our marketing activities;
if the purpose of the processing was based on our legitimate interest and the objection was considered justified by us;
the processing of your Personal Data is no longer necessary to achieve the purposes
for which they were collected or processed.

Despite your request, we would like to point out that some of your Personal Data may still be retained by us to the extent necessary for:

determining, investigating or defending against claims, within the scope of the first name and surname, e-mail address, history of activity on the Website and billing data.

Basis: Article 17 of the GDPR

The right to access data and obtain a copy thereof

You have the right to confirm whether we process your Personal Data, and if such processing takes place, you have the right to obtain:

access to your Personal Data;
information about the purposes of the processing, categories of Personal Data processed;
information about the recipients or categories of recipients of these Personal Data;
information about the planned period of storage of Personal Data or about the criteria for determining this period;
information about your rights under the GDPR and the right to lodge a complaint with the supervisory authority;
information about the source of Personal Data;
information about automated decision-making, including profiling;
information about the safeguards used when transferring Personal Data outside the EEA;
a copy of your Personal Data.

Basis: Article 15 of the GDPR

The right to rectification of your data

You have the right to rectify and supplement your Personal Data. You can do this yourself through your Account settings. In the case of other Personal Data, you can submit a request to us to rectify the incorrect data or to supplement them, if the Personal Data are incomplete.

Basis: Article 16 of the GDPR

The right to data portability

In connection with your right to transfer Data, you have the right to:

receive from us a file with your Personal Data, which you can send to the Personal Data controller of your choice, or
request that we transfer your personal data directly to the controller indicated by you, provided that it is technically possible.

Your Personal Data will be provided to you in a commonly used file format that is machine-readable and allows the transfer of Personal Data to another Personal Data controller.

Basis: Article 20 of the GDPR

Complaints, questions and requests

If you have any complaints, questions or requests regarding our processing of your Personal Data and the exercise of your rights, please contact us.

You can also lodge a complaint with the President of the Office for Personal Data Protection (address: ul. Stawki 2, 00-193 Warsaw www.uodo.gov.pl) if you believe that your rights granted to you under the GDPR have been violated.

§13. Automated data processing

We would like to inform you that when using the website, your data may be subject to automated processing by Google Analytics [A5] . More details about our use of Google Analytics can be found in the Cookie Policy.

§14. Personal data security

In order to ensure the security of the data entrusted to us, we have developed internal procedures and recommendations to prevent data from being made available to unauthorised persons. We control their implementation and constantly check their compliance with relevant legal acts.

§15. Links to external websites

The Website may contain links to other websites. Such websites operate independently of the Website and are not supervised in any way by https://www.foolstheory.com/. These websites may have their own privacy policies and regulations, which we recommend that you read.

§17. Changes in the Privacy Policy

We reserve the right to make changes in the website privacy policy, which may be affected by the development of the Internet technology, possible amendments to the law on the protection of personal data and development of our website. We will inform you about any changes in a visible and understandable way.
If you have any doubts regarding any of the provisions of this Privacy Policy, we are at your disposal – our details can be found in the CONTACT tab.

COOKIE POLICY

1. Application of the Cookie Policy

We always apply this Cookie Policy whenever we refer to the website https://www.foolstheory.com/

2. Content of the Cookie Policy

We always apply this Cookie Policy whenever we refer to the website https://www.foolstheory.com/

This document contains the following information regarding Cookies:

use of Cookies;
purposes of using Cookies;
selection and preferences regarding Cookies.

Other information regarding the processing of Personal Data is specified in the Privacy Policy.

3. What are Cookies?

A cookie is a small text file that a website saves on the User’s computer or mobile device while browsing it. Administrator cookies are files belonging to the website you are visiting. Only this website can read them.

4. Use of Cookies

Cookies can be divided according to their life cycle and the domain from which they come.

Life cycle criterion:

Session cookies – deleted when the web browser used to visit the website is closed;

Persistent cookies – they are deleted after a specified period of time, regardless of whether the web browser used to visit the website has been closed;

Criterion of origin:

Own cookies – set by our website;

Third party (partner) cookies – set by the servers of partners we cooperate with.

5. Purposes of using Cookies

No.	Type/Category of Cookies	Does it require consent?	Purpose
1.	Necessary cookies	These files are always active.	Files necessary for the proper operation of the Website’s functionality, including ensuring IT security. These files are always active and it is impossible to disable them.
2.	Analytical cookies	The consent is required.	Files that enable us to check performance and improve the website’s fit to visitors’ preferences.
3.	Functional cookies	The consent is required.	Files enabling remembering settings or preferences, e.g. language, font.
4.	Marketing cookies	The consent is required.	Files enabling better matching of advertisements to the needs and interests or measurement of effectiveness. This information may be collected by us or our partners.
5.	Information from other websites	The consent is required.	Files that enable observing the activity of visitors to our website on other websites, in order to best match our advertisements and offers to their needs and interests.
6.	Social media and plugins	The consent is required.	Files that enable sharing our content, e.g. on Facebook, using the “Like” button on the website. Thanks to these files, it is also possible to register an account using Facebook.

6. Information collected using Cookies

Information about the device you are using (e.g. ID, IP address, operating system, language preferences, web browser, screen resolution)
Information about visits to the website (time, length of visit, date, phrases searched on the website, subpages visited)
Location information (if you have consented to the transfer of such information)
Information about viewed advertisements, including clicks on links
Information about activity on other websites (if consent has been given to transfer such information, e.g. information about the website visited and frequency of visits)

7. Consents and cookie management

Consents and management of cookie preferences can be easily adjusted via the Cookie management centre. In order to change your preferences, select the Cookie management centre tab in the footer of the website and update your consents.

Please be advised that modifying your Cookie preferences may make it more difficult to use some of the services offered by our website.

With regard to the Cookies of our partners, please read their cookie policies.