Privacy Policy

• Service - the online service "Whitegard" operating at https://www.whitegard.com

• External Service - the websites of partners, service providers, or contractors cooperating with the Administrator

• Service / Data Administrator - The Service Administrator and Data Administrator (hereinafter Administrator) is the company "Whitegard sp. z o.o.", conducting business at: Księcia Janusza 66, 01-452 Warsaw, Poland, with the assigned tax identification number (TID): PL5223192737, providing electronic services through the Service

• User - a natural person for whom the Administrator provides electronic services via the Service.

• Device - an electronic device with software through which the User gains access to the Service.

• Cookies - text data collected in the form of files placed on the User's Device.

• GDPR - 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).

• Personal Data - means 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, identification number, location data, online identifier, or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

• Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.

• Restriction of processing - means the marking of stored personal data with the aim of limiting their processing in the future.

• Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person's performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

• Consent - the consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject's wishes by which they, by a statement or by a clear affirmative action, signify agreement to the processing of personal data relating to them.

• Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, personal data transmitted, stored or otherwise processed.

• Pseudonymization - means the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.

• Anonymization - Anonymization of data is an irreversible process of data operations that destroys / overwrites "personal data" making it impossible to identify, or associate a given record with a specific user or natural person.

Based on Article 37 of the GDPR, the Administrator has not appointed a Data Protection Officer.

For matters concerning data processing, including personal data, please contact the Administrator directly.

• Internal Cookies - files placed and read from the User's Device by the Service's telecommunication system.

• External Cookies - files placed and read from the User's Device by the telecommunication systems of External Services. Scripts of External Services that may place Cookies on the User's Devices were intentionally placed in the Service through scripts and services made available and installed in the Service.

• Session Cookies - files placed and read from the User's Device by the Service during one session of a given Device. After the session ends, the files are deleted from the User's Device.

• Persistent Cookies - files placed and read from the User's Device by the Service until they are manually deleted. The files are not deleted automatically after the Device session ends unless the User's Device configuration is set to delete Cookies after the Device session ends.

• Mechanisms for storing and reading Cookies - The mechanisms for storing, reading, and exchanging data between Cookies stored on the User's Device and the Service are carried out through built-in browser mechanisms and do not allow for downloading other data from the User's Device or data from other websites visited by the User, including personal data or confidential information. Transferring viruses, Trojan horses, and other worms to the User's Device is also practically impossible.

• Internal Cookies - Cookies used by the Administrator are safe for the Users' Devices and do not contain scripts, content, or information that may threaten the security of personal data or the security of the Device used by the User.

• External Cookies - The Administrator makes every effort to verify and select service partners in the context of User security. The Administrator selects known, large partners with global social trust. However, the Administrator does not have full control over the content of Cookies from external partners. The Administrator is not responsible for the security of Cookies, their content, and their use in accordance with the license by Scripts installed in the service, from External Services, to the extent permitted by law. A list of partners is included in the further part of the Privacy Policy.

• Control of Cookies

  • The User may, at any time, independently change the settings regarding the saving, deletion, and access to data of saved Cookies by any website.

  • Information on how to disable Cookies in the most popular computer browsers is available at: how to disable cookies or from one of the listed providers:

    • Managing cookies in Chrome browser
    • Managing cookies in Opera browser
    • Managing cookies in FireFox browser
    • Managing cookies in Edge browser
    • Managing cookies in Safari browser
    • Managing cookies in Internet Explorer 11 browser

  • The User may delete all Cookies saved so far at any time using the tools of the User's Device, through which the User uses the services of the Service.

• User-side threats - The Administrator applies all possible technical measures to ensure the security of data placed in Cookies. However, it should be noted that ensuring the security of these data depends on both parties, including the User's activities. The Administrator is not responsible for the interception of these data, impersonation of the User's session, or their removal as a result of conscious or unconscious activity of the User, viruses, Trojan horses, and other spyware that may or have been infected with the User's Device. Users should take measures to protect themselves from these threats. should follow the principles of internet use.

• Storage of personal data - The Administrator ensures that every effort is made to keep the personal data voluntarily provided by Users secure, with access to them being limited and performed in accordance with their intended purpose and processing objectives. The Administrator also ensures that every effort is made to secure the data held against loss by using appropriate physical and organizational safeguards.

• Improvement and facilitation of access to the Service
• Personalization of the Service for Users
• Marketing, Remarketing in external services
• Conducting statistics (users, number of visits, types of devices, connection, etc.)
• Serving multimedia services

Personal data voluntarily provided by Users are processed for one of the following purposes:

• Providing electronic services:
  • Newsletter services (including sending advertising content with consent)
  • Services for sharing information about content posted on the Service on social media or other websites.
• Communication between the Administrator and Users regarding the Service and data protection
• Ensuring the legitimate interest of the Administrator

Data about Users collected anonymously and automatically are processed for one of the following purposes:

• Conducting statistics
• Remarketing
• Ensuring the legitimate interest of the Administrator

The Administrator uses JavaScript scripts and web components from partners who may place their own cookies on the User's Device. Remember that you can decide on the allowed cookies used by individual websites in your browser settings. Below is a list of partners or their services implemented in the Service that may place cookies:

• Multimedia services:
  • YouTube
• Newsletter services:
  • Mailerlite
• Conducting statistics:
  • Google Analytics

Services provided by third parties are beyond the control of the Administrator. These entities may change their terms of service, privacy policies, data processing purposes, and methods of using cookies at any time.

The Service collects data about Users. Some of the data is collected automatically and anonymously, while some are personal data voluntarily provided by Users when signing up for various services offered by the Service.

Anonymous data collected automatically:

• IP Address
• Browser Type
• Screen Resolution
• Approximate Location
• Visited Subpages
• Time Spent on the Relevant Subpage
• Operating System Type
• Previous Subpage Address
• Referrer Page Address
• Browser Language
• Internet Connection Speed
• Internet Service Provider
• Demographic Data (age, gender)

Data collected during registration:

• First Name / Last Name / Nickname
• Login
• Email Address
• IP Address (collected automatically)

Data collected during subscription to the Newsletter service

• First Name / Last Name / Nickname
• Email Address
• IP Address (collected automatically)

Some data (without identifying information) may be stored in cookies. Some data (without identifying information) may be transmitted to the statistical services provider.

As a rule, the only recipient of personal data provided by Users is the Administrator. The data collected as part of the services provided are not transferred or resold to third parties.

Access to the data (usually based on a Data Processing Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the service, such as:

• Hosting companies providing hosting or related services for the Administrator
• Companies through which the Newsletter service is provided

Entrusting personal data processing - Newsletter

In order to provide the Newsletter service, the Administrator uses the services of a third party - the service Mailerlite, . Data entered in the newsletter subscription form is transferred, stored, and processed in the external service of this provider.

We inform you that the indicated partner may modify the indicated privacy policy without the Administrator's consent.

Entrusting personal data processing - Hosting, VPS, or Dedicated Server Services

In order to run the service, the Administrator uses the services of an external hosting, VPS, or Dedicated Server provider - Vercel Inc.. All data collected and processed in the service are stored and processed in the infrastructure of the provider located in Poland. Access to the data may occur as a result of maintenance work carried out by the provider's personnel. Access to this data is regulated by an agreement between the Administrator and the Service Provider.

We inform you that the indicated partner may modify the indicated privacy policy without the Administrator's consent.

Personal data voluntarily provided by Users:

• Personal data will not be transferred outside the European Union unless published as a result of an individual User action (e.g., posting a comment or entry), which will make the data available to any visitor to the service.
• Personal data will not be used for automated decision-making (profiling).
• Personal data will not be resold to third parties.

Anonymous data (without personal data) collected automatically:

• Anonymous data (without personal data) will be transferred outside the European Union.
• Anonymous data (without personal data) will not be used for automated decision-making (profiling).
• Anonymous data (without personal data) will not be resold to third parties.

The Service collects and processes Users' data based on:

• 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)
  • art. 6(1)(a)
    the data subject has given consent to the processing of their personal data for one or more specific purposes
  • art. 6(1)(b)
    processing is necessary for the performance of a contract to which the data subject is a party or in order to take steps at the request of the data subject prior to entering into a contract
  • art. 6(1)(f)
    processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
• Act of 10 May 2018 on the protection of personal data (Journal of Laws 2018, item 1000)
• Act of 16 July 2004 Telecommunications Law (Journal of Laws 2004 No. 171, item 1800)
• Act of 4 February 1994 on copyright and related rights (Journal of Laws 1994 No. 24, item 83)

Personal data provided voluntarily by Users:

As a rule, the indicated personal data is stored only for the period of providing the Service within the Service by the Administrator. They are deleted or anonymized within 30 days from the end of the provision of services (e.g., deletion of a registered user account, unsubscribing from the Newsletter, etc.)

An exception is a situation that requires securing the legitimate purposes of further processing of this data by the Administrator. In such a case, the Administrator will store the indicated data, from the time of the User's request for their deletion, for no longer than 3 years in the case of a breach or suspicion of a breach of the Service regulations by the User.

Anonymous data (without personal data) collected automatically:

Anonymous statistical data, which does not constitute personal data, is stored by the Administrator for an indefinite period to conduct service statistics.

The Service collects and processes Users' data based on:

• Right of access to personal data
  Users have the right to obtain access to their personal data, carried out on request submitted to the Administrator

• Right to rectify personal data
  Users have the right to request the Administrator to rectify personal data that is inaccurate or to complete incomplete personal data, carried out on request submitted to the Administrator

• Right to erasure of personal data
  Users have the right to request the Administrator to delete personal data immediately, carried out on request submitted to the AdministratorIn the case of user accounts, data deletion involves anonymizing data that allows User identification. The Administrator reserves the right to suspend the implementation of the data deletion request to protect the legitimate interest of the Administrator (e.g., if the User has violated the Regulations or the data was obtained as a result of correspondence).
  In the case of the Newsletter service, the User has the option to delete their personal data independently using the link provided in each sent email message.

• Right to restrict the processing of personal data
  Users have the right to restrict the processing of personal data in cases indicated in Article 18 of the GDPR, including questioning the accuracy of personal data, carried out on request submitted to the Administrator

• Right to data portability
  Users have the right to receive from the Administrator their personal data in a structured, commonly used, and machine-readable format, carried out on request submitted to the Administrator

• Right to object to the processing of personal data
  Users have the right to object to the processing of their personal data in the cases specified in Article 21 of the GDPR, carried out on request submitted to the Administrator

• Right to lodge a complaint
  Users have the right to lodge a complaint with a supervisory authority dealing with personal data protection.

You can contact the Administrator in one of the following ways:

• Postal Address - Whitegard sp. z o.o., Księcia Janusza 66, 01-452 Warsaw, Poland

• Email Address - [email protected]

• Phone Call - +48 888 883 043

• Contact Form - available at: /contact

• Limiting the storage and access to Cookies on the User's Device may cause some Service functions to malfunction.

• The Administrator bears no responsibility for improperly functioning Service functions if the User in any way restricts the ability to save and read Cookie files.

In the Service - articles, posts, entries, or User comments may contain links to external websites with which the Service Owner does not cooperate. These links and the sites or files indicated under them may be dangerous for your Device or pose a threat to the security of your data. The Administrator is not responsible for the content found outside the Service.

• The Administrator reserves the right to change this Privacy Policy at any time without informing Users in the scope of using and utilizing anonymous data or using Cookie files.

• The Administrator reserves the right to change this Privacy Policy in the scope of processing Personal Data, about which Users with user accounts or subscribed to the newsletter service will be informed via email within 7 days from the change. Continued use of the services indicates familiarity with and acceptance of the changes made to the Privacy Policy. If the User does not agree with the changes, they must delete their account from the Service or unsubscribe from the Newsletter service.

• The changes made to the Privacy Policy will be published on this subpage of the Service.

• The changes come into effect upon publication.