Privacy Policy
By reviewing this Privacy Policy, the User of the Website learns in particular: who the controller of personal data is, what personal data is collected in connection with the use of the Website and newsletter subscriptions, for what purposes such data is processed, on what legal basis, as well as what measures are applied to protect personal data.
This Privacy Policy constitutes the basic information on the purposes, principles, and methods of processing personal data, as well as on the rights of data subjects, in connection with the use of the website available at: www.thesmartsplit.com (hereinafter referred to as the “Website”).
§1. General information
The controller of your personal data is Joanna Kubica, operating the website available at www.thesmartsplit.com.
The Controller processes users’ personal data in connection with:
the use of the Website,
subscription to the newsletter,
contact via electronic mail,
the implementation of informational, educational, and marketing purposes related to the Controller’s business activity.
You may contact the Controller:
via electronic mail at: joanna@thesmartsplit.com
§2. Principles of personal data processing
The Controller processes personal data in accordance with applicable laws, in particular:
Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR),
the Act of 10 May 2018 on the protection of personal data.
Personal data is processed by the Controller in accordance with the following principles:
lawfulness, fairness and transparency – data is processed in accordance with applicable law and in a clear manner for the data subject;
purpose limitation – data is collected for specified, explicit and legitimate purposes and is not further processed in a manner incompatible with those purposes;
data minimisation – only data necessary to achieve a given purpose is processed;
accuracy – data is accurate and, where necessary, kept up to date;
storage limitation – data is stored no longer than is necessary for the purposes for which it is processed;
integrity and confidentiality – data is processed in a manner ensuring appropriate security, including protection against unauthorised access, loss or destruction.
§3. Purposes, legal bases and scope of personal data processing
Your personal data is processed by the Controller for the following purposes:
contact purposes – in order to respond to messages sent by you, regardless of the form of contact (e-mail, contact form, social media, telephone contact), based on the Controller’s legitimate interest consisting in conducting correspondence and providing responses;
marketing purposes – in particular for sending marketing content, information about products, services, updates or special offers (e.g. newsletter), exclusively on the basis of your consent. Personal data processed in connection with newsletter subscriptions is processed on the basis of your consent, and you may unsubscribe from the newsletter at any time, in particular via the unsubscribe link included in each e-mail message;
informational purposes – in order to provide important information regarding services or content you use via the Website, based on the Controller’s legitimate interest;
purposes related to operating social media profiles (such as Facebook, Instagram, TikTok, YouTube) – in order to inform about activities, products, promotions, and to communicate with users, in accordance with the rules established by the operators of the respective social media platforms, which constitutes the Controller’s legitimate interest;
technical purposes – in order to ensure the proper functioning of the Website, using necessary cookies (so-called technical cookies), based on the Controller’s legitimate interest;
statistical and analytical purposes – if you have given consent to the use of cookies for analytical purposes (so-called analytical cookies);
marketing purposes using cookies – if you have given consent to the use of cookies for marketing purposes (so-called marketing cookies);
archival and evidentiary purposes – in order to store correspondence, telephone numbers and messages, based on the Controller’s legitimate interest consisting in securing potential claims;
analysis of anonymised data – for statistical and marketing analysis of the Website. This data includes in particular information about the browser, operating system, type of device, time spent on the Website, navigation between subpages, link clicks, approximate location, age range or gender. This data is anonymised, collected via advertising and analytical systems of the Controller’s partners, and does not allow identification of a specific user.
The Controller processes personal data within the following scope:
in the case of contact via e-mail, contact form, social media or telephone – data contained in the content of the message sent by you. Providing this data is voluntary. You may request its deletion at any time;
in the case of interaction with the Controller’s social media profiles (e.g. liking a profile, commenting, reacting, sending a private message) – data made available by you within a given social media service, in accordance with the rules applicable in that service. Processing ends when you unfollow the profile or delete the interaction;
other technical data, including IP address and data stored in cookies. The scope of data processing depends on your browser settings or cookie consent preferences. You may change your cookie preferences at any time;
data processed via APIs (Application Programming Interfaces) provided by external partners, for the purpose of integrating functionalities such as analytical tools, advertising tools or social media services. External partners may process data in accordance with their own privacy policies, over which the Controller has no control.
§4. No automated profiling
The Controller does not use automated profiling of users within the meaning of Article 22 of the GDPR on the Website, consisting of making decisions that produce legal effects concerning the user or similarly significantly affect them.
The Controller may use advertising and analytical systems of external partners (such as Google or Meta/Facebook). Data collected by these systems is aggregated and statistical in nature and does not allow the Controller to identify a specific user or make individual decisions concerning them.
Marketing campaigns conducted by the Controller may be targeted at general audience groups created on the basis of anonymous statistical data, without the possibility of assigning advertisements to a specific individual.
Detailed information on profiling principles and data processing by external partners can be found in their privacy policies, links to which are provided later in this Privacy Policy.
§5. Recipients of personal data and transfer of data outside the EEA
Depending on the purpose of personal data processing, recipients of your data may include in particular:
public authorities and other public entities – to the extent that the obligation to provide data results from applicable laws, in particular in connection with the performance of the Controller’s legal obligations;
entities providing technical and organisational services to the Controller, including:
hosting, server and domain providers,
entities providing technical or programming support for the Website,
providers of cloud-based data and document storage tools;
entities providing marketing services and managing the Controller’s social media channels;
providers of tools for managing cookies and user consent;
advertising and analytical partners, such as Google or Meta (Facebook, Instagram), exclusively if you have given the relevant consent for analytical or marketing cookies.
Users’ personal data may be transferred to countries outside the European Economic Area, in particular to the United States of America, solely in connection with the use of tools provided by external suppliers, such as:
Google LLC (including Google Analytics, Google Ads, Google Search Console, Google Drive, YouTube),
Meta Platforms, Inc. (Facebook, Instagram, including advertising and analytical tools).
Transfers of data outside the EEA are carried out exclusively with the application of appropriate safeguards required by the GDPR, in particular on the basis of:
standard contractual clauses approved by the European Commission, or
other mechanisms compliant with applicable law.
Detailed information regarding data processing principles applied by the above-mentioned entities can be found in their respective privacy policies.
§6. Personal data retention period
Personal data is stored for no longer than is necessary to achieve the purposes for which it was collected, taking into account applicable legal provisions and the principles arising from the GDPR.
In particular:
data processed for contact purposes is stored for the duration of the correspondence and, after its completion, for the period necessary to secure potential claims;
data processed on the basis of consent (e.g. newsletter) is stored until such consent is withdrawn;
data processed on the basis of the Controller’s legitimate interest is stored until an effective objection is raised or until such interest ceases to exist;
data processed on the basis of legal obligations is stored for the period resulting from applicable laws.
§7. Users’ rights
In connection with the processing of your personal data, you are entitled to the following rights:
the right to access your personal data and the right to rectify, erase or restrict the processing of such data;
the right to data portability;
the right to object to the processing of personal data;
the right to withdraw consent to the processing of personal data at any time – where processing is based on consent. Withdrawal of consent does not affect the lawfulness of processing carried out prior to its withdrawal.
To the extent that personal data is processed on the basis of applicable laws, for the performance of a contract or on the basis of the Controller’s legitimate interest, some of the above rights may be subject to limitation in accordance with the GDPR.
You also have the right to lodge a complaint with the President of the Personal Data Protection Office
(ul. Stawki 2, 00-193 Warsaw, Poland) if you consider that the processing of your personal data violates applicable law.
More information on personal data protection is available on the website of the Personal Data Protection Office: www.uodo.gov.pl.
§8. Information on cookies
The Website uses cookies (so-called “cookies”).
The Website uses a tool that allows users to independently manage consent for the use of cookies and the scope of data processing, including within the Consent Mode v2 mechanism.
Cookies are small text files stored on the user’s device while using the Website. They are used to ensure the proper functioning of the Website, improve the quality of services, and conduct statistical and marketing analyses – in accordance with the user’s expressed consents.
Cookies may be:
session cookies – deleted when the browser is closed;
persistent cookies – stored on the user’s device for a specified period or until deleted.
The Website uses:
first-party cookies – necessary for the proper functioning of the Website;
third-party cookies – in particular for analytical and marketing purposes and for integration with social media services.
Users may independently manage cookies, including limiting or deleting them, via browser settings or the consent management tool available on the Website.
Restricting or disabling cookies may affect certain functionalities of the Website.
The following types of cookies are used on the Website:
technical cookies – necessary for the proper functioning of the Website, ensuring security and handling forms;
analytical cookies – used to collect anonymous statistical information about the use of the Website;
marketing cookies – used for marketing activities and measuring the effectiveness of advertising campaigns, solely after obtaining appropriate consent.
§9. Why do we use cookies?
Comfort of using the Website: cookies enable proper and convenient use of the Website, including smooth navigation between its subpages.
Content personalisation: cookies allow displayed content to be adjusted to the user’s preferences, to the extent resulting from granted consents.
Saving settings: cookies enable the Website to remember selected user settings, such as language or other technical preferences, facilitating future visits.
Login: cookies may allow recognition of a logged-in user and the use of features requiring authentication without the need to log in again each time.
Session maintenance: cookies allow the maintenance of a user session and continuation of actions initiated on the Website, such as filling out forms.
Optimisation of Website performance: cookies may be used to analyse how the Website is used, enabling its development, performance improvement and adaptation of functionalities to users’ needs.
Advertising: subject to appropriate consent, cookies may be used for marketing activities and measuring the effectiveness of advertising campaigns.
Integration with social media: cookies may enable integration of the Website with social media services, allowing the use of functions such as content sharing or interactions with embedded social media elements.
§10. Functions of technical cookies
Maintaining user sessions: technical cookies enable the maintenance of the user’s session while using the Website, allowing smooth navigation between sections without re-entering the same information.
Saving user preferences: technical cookies allow storing basic user settings, such as language preferences or other technical settings affecting how the Website is displayed.
Form handling: technical cookies support the proper functioning of forms available on the Website, including contact forms, ensuring correct processing of submitted data.
Ensuring proper Website operation: technical cookies are used to ensure the stability, performance and correct operation of the Website and its individual elements.
Security: technical cookies may be used to enhance Website security and protect users, including detecting irregular activities and preventing abuse.
§11. Functions of analytical cookies
Measuring Website traffic: analytical cookies enable the collection of information on the number of visits to the Website, the number of users and page views, allowing an overall assessment of Website performance.
Analysis of user behaviour: analytical cookies make it possible to collect data on how the Website is used, such as time spent on individual pages, navigation paths or the moment the Website is exited.
Analysis of Website goal effectiveness: analytical cookies may be used to assess the extent to which the Website achieves its objectives, such as newsletter subscriptions, contact form submissions or other user interactions.
Segmentation of statistical data: the use of analytical cookies allows grouping statistical data according to specific criteria, enabling better understanding of how different user groups use the Website.
Testing technical and functional solutions: analytical cookies may be used to test different versions of the Website or its elements in order to assess their impact on Website performance and user behaviour.
§12. Functions of marketing cookies
Displaying marketing content: marketing cookies enable the display of advertising content tailored to the user’s general interests, based on prior interactions with the Website, solely after appropriate consent has been granted.
Remarketing activities: marketing cookies make it possible to target marketing content to users who have previously visited the Website, in order to remind them of available offers or content.
Measuring advertising campaign effectiveness: marketing cookies allow analysis of the effectiveness of marketing activities, in particular by collecting data on impressions, clicks or other interactions with advertisements.
Integration of marketing activities across channels: marketing cookies enable marketing activities to be carried out across various external channels, such as search engines or social media platforms, to the extent resulting from granted consents.
Optimisation of marketing content: marketing cookies may be used to analyse the effectiveness of different forms and types of marketing content, enabling their adjustment and improvement.