Privacy Policy
The following Privacy Policy specifies the rules for saving and accessing data on the Devices of Users using the Service for the purposes of providing services electronically by the Administrator and the rules for collecting and processing personal data of Users, which were provided by them personally and voluntarily through the tools available on the Service.
The following Privacy Policy is an integral part of the Service Regulations, which specify the rules, rights and obligations of Users using the Service.
§1 Definitions
Service – the “Sunbirds” website operating at https://e-sunbirds.com
External website – websites of partners, service providers or service recipients cooperating with the Administrator
Service / Data Administrator – the Service Administrator and Data Administrator (hereinafter referred to as the Administrator) is the company “Centrum Psychoterapii Sunbirds Anna Skrzypiec-Żurek”, operating at the following address: ul. Stefana Batorego 18/108, 02-591 Warsaw, Poland, European Union, with the assigned tax identification number (NIP): 8252111393, providing services electronically via the Website
User – a natural person for whom the Administrator provides services electronically via the Website.
Device – an electronic device with software through which the User gains access to the Website
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, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person
Processing – means an operation or set of operations performed on personal data or sets of personal data by automated or non-automated means, such as collection, recording, organization, structuring, storage, adaptation or modification, retrieval, consultation, use, disclosure by transmission, dissemination or other type of making available, matching or combining, restriction, erasure or destruction; Processing restriction – means marking stored personal data in order to limit their future processing
Profiling – means any form of automated processing of personal data that involves the use of personal data to assess certain personal factors of a natural person, in particular to analyse or forecast aspects concerning the performance of that natural person’s work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements
Consent – the consent of the data subject means the voluntary, specific, conscious and unambiguous expression of will by which the data subject, in the form of a declaration or a clear confirming action, consents to the processing of personal data concerning him/her
Data protection breach – means a breach of security leading to the accidental or unlawful destruction, loss, modification, unauthorized disclosure or unauthorized access to personal data transmitted, stored or otherwise processed
Pseudonymisation – means the processing of personal data in such a way that it 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 covered by technical measures and organizational, making it impossible to assign them to an identified or identifiable natural person
Anonymization – Data anonymization is an irreversible process of data operations that destroys / overwrites “personal data” making it impossible to identify or link a given record to a specific user or natural person.
§2 Data Protection Inspector
Based on Art. 37 of the GDPR, the Administrator has not appointed a Data Protection Inspector.
In matters concerning the processing of data, including personal data, contact the Administrator directly.
§3 Types of Cookies
Internal Cookies – files placed and read from the User’s Device by the Service’s IT system
External Cookies – files placed and read from the User’s Device by the Service’s IT system
and read from the User’s Device by the IT systems of external Services. Scripts of external Services that can place Cookies on the User’s Devices have been consciously placed on the Service through scripts and services made available and installed on 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 the mode of deleting Cookies after the Device session ends.
§4 Data storage security
Cookie storage and reading mechanisms – The mechanisms for storing, reading and exchanging data between Cookie files saved on the User’s Device and the Service are implemented through built-in mechanisms of web browsers and do not allow downloading other data from the User’s Device or data from other websites that the User has visited, including personal data or confidential information. Transferring viruses, Trojan horses and other worms to the User’s Device is also practically impossible.
Internal Cookies – the Cookie files used by the Administrator are safe for 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 takes all possible actions to verify and select service partners in the context of Users’ security. The Administrator selects well-known, large partners with global social trust for cooperation. However, he does not have full control over the content of Cookie files from external partners. The Administrator is not responsible for the security of Cookie files, their content and use in accordance with the license by Scripts installed on the website, originating from external Services, to the extent permitted by law. The list of partners is included in the further part of the Privacy Policy.
Cookie control
The User may at any time independently change the settings for saving, deleting and accessing the data saved in Cookie files by each website
Information on how to disable Cookie files in the most popular computer browsers is available on the website: how to disable cookies or from one of the indicated providers:
Cookie management in Chrome
Cookie management in Opera
Cookie management in FireFox
Cookie management in Edge
Cookie management in Safari
Cookie management in Internet Explorer 11
The User may at any time delete any previously saved Cookie files using the tools of the User’s Device through which the User uses the services of the Service. User-side threats – the Administrator uses all possible technical measures to ensure the security of data placed in Cookie files. However, it should be noted that ensuring the security of this data depends on both parties, including the User’s activity. The Administrator is not responsible for intercepting this data, impersonating the User’s session or deleting it, as a result of the User’s conscious or unconscious activity, viruses, Trojan horses and other spyware that may have infected or infected the User’s Device. In order to protect themselves against these threats, Users should follow the recommendations for using the network.
Storing personal data – the Administrator ensures that it makes every effort to ensure that the processed personal data entered voluntarily by Users is safe, access to it is limited and implemented in accordance with its intended use and processing purposes. The Administrator also ensures that it makes every effort to protect the data it holds against loss, by using appropriate physical and organizational security measures.
Storing passwords – the Administrator declares that passwords are stored in encrypted form, using the latest standards and guidelines in this area. Decrypting the account access passwords provided on the Website is practically impossible.
§5 Purposes for which Cookies are used
Improving and facilitating access to the Website
Personalization of the Website for Users
Enabling Login to the Website
Maintaining statistics (users, number of visits, types of devices, connections, etc.)
Providing multimedia services
§6 Purposes of personal data processing
Data personal data voluntarily provided by Users are processed for one of the following purposes:
Implementation of electronic services:
Services of registration and maintenance of the User’s account on the Service and functionalities related to it
Communication between the Administrator and Users on matters related to 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:
Maintaining statistics
Ensuring the legitimate interest of the Administrator
§7 Cookies of external Services
The Administrator uses JavaScript scripts and web components of partners on the Service, which can place their own cookies on the User’s Device. Remember that in the settings of your browser you can decide on the permitted cookies that can be used by individual websites. Below is a list of partners or their services implemented in the Service that may place cookies:
Multimedia services:
YouTube
Statistics:
Google Analytics
Hotjar
Other services:
Google Maps
Services provided by third parties are beyond the Administrator’s control. These entities may change their terms of service, privacy policies, the purpose of data processing and the methods of using cookies at any time.
§8 Types of collected data
The Service collects data about Users. Some data is collected automatically and anonymously, and some data is personal data provided voluntarily by Users when signing up for individual services offered by the Service.
Anonymous data collected automatically:
IP address
Browser type
Screen resolution
Approximate location
Subpages of the service opened
Time spent on the relevant subpage of the service
Operating system type
Address of the previous subpage
Address of the referring page
Browser language
Internet connection speed
Internet service provider
Demographic data (age, gender)
Data collected during registration:
Name / surname / nickname
Login
E-mail address
Phone number
IP address (collected automatically)
Data collected during subscription to the Newsletter service
E-mail address
Some data (without identifying data) may be stored in cookies. Some data (without identifying data) may be transferred to the statistical services provider.
§9 Access to personal data by third parties
As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided is not transferred or resold to third parties.
Access to data (most often based on the Data Processing Entrustment Agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to run the service, i.e.:
Hosting companies providing hosting services or related services for the Administrator
IT service and support companies performing maintenance or responsible for maintaining the IT infrastructure
Companies intermediating in online payments for goods or services offered as part of the Service (in the case of making a purchase transaction on the Service)
Entrusting the processing of personal data – Hosting Services, VPS or Dedicated Servers
In order to run the service, the Administrator uses the services of an external hosting provider, VPS or Dedicated Servers – HITME.pl – MAREK BAJERSKI. All data collected and processed on the service are stored and processed in the service provider’s infrastructure located in Poland. It is possible to access the data as a result of service work carried out by the service provider’s staff. Access to this data is regulated by an agreement concluded between the Administrator and the Service Provider.
Entrustment of personal data processing – Website maintenance services
In order to maintain the website, the Administrator uses the services of an external service provider – Marketing Agency Agnieszka Gajewska. The staff of the indicated entity has access to the data entered by users during registration and editing of the user account and/or data concerning the Newsletter service. Access to this data is regulated by an agreement concluded between the Administrator and the Service Provider.
Data processing in the case of online payments
In the case of online payments, all payment data is transferred directly by the User to the entities executing the payment – PayPro S.A. and Stripe, Inc. Selected data necessary for the execution of the transaction is then transferred by this entity to the Administrator. The transfer of data is regulated by an agreement concluded between the Administrator and the Service Provider.
§10 Method of processing personal data
Personal data provided voluntarily by Users:
Personal data will not be transferred outside the European Union, unless they have been published as a result of an individual action by the User (e.g. entering a comment or entry), which will make the data available to anyone visiting
ej 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.
§11 Legal basis for personal data processing
The Service collects and processes User data on the basis of:
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)
Article 6 paragraph 1 letter b. a
the data subject has consented to the processing of his or her personal data for one or more specific purposes
Article 6(1)(b)
processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract
Article 6(1)(b) f
processing is necessary for the purposes of legitimate interests pursued by the administrator or 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)
§12 Period of personal data processing
Personal data provided voluntarily by Users:
As a rule, the indicated personal data are stored only for the period of provision of the Service within the Service by the Administrator. They are deleted or anonymized within 30 days of the end of the provision of services (e.g. deletion of a registered user account, unsubscription from the Newsletter list, etc.)
An exception is a situation that requires securing legally justified purposes of further processing of such data by the Administrator. In such a situation, the Administrator will store the indicated data, from the time of the User’s request to delete them, for no longer than 3 years in the event of a violation or suspicion of a violation of the provisions of the service regulations by the User
Anonymous data (without personal data) collected automatically:
Anonymous statistical data, not constituting personal data, are stored by the Administrator for the purpose of maintaining service statistics for an indefinite period
§13 User rights related to the processing of personal data
The Service collects and processes User data on the basis of:
Right to access personal data
Users have the right to obtain access to their personal data, implemented upon request submitted to the Administrator
Right to rectify personal data
Users have the right to request the Administrator to immediately correct personal data that is incorrect or/and to supplement incomplete personal data, implemented upon request submitted to the Administrator
Right to delete personal data
Users have the right to request the Administrator to immediately delete personal data, implemented upon request submitted to the Administrator In the case of user accounts, deletion of data consists of anonymization of data enabling the identification of the User. The Administrator reserves the right to suspend the execution of the request to delete data in order to protect the legitimate interest of the Administrator (e.g. when 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 of deleting their personal data themselves using the link placed in each sent e-mail message.
The right to limit the processing of personal data
Users have the right to limit the processing of personal data in the cases indicated in art. 18 of the GDPR, including questioning the accuracy of personal data, implemented upon request submitted to the Administrator
The right to transfer personal data
Users have the right to obtain from the Administrator, personal data concerning the User in a structured, commonly used machine-readable format, implemented upon request submitted to the Administrator
The 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 art. 21 GDPR, implemented upon request submitted to the Administrator
Right to file a complaint
Users have the right to file a complaint with the supervisory authority responsible for the protection of personal data.
§14 Contact the Administrator
With the Administrator you can contact us in one of the following ways
Postal address – Sunbirds Psychotherapy Center Anna Skrzypiec-Żurek ul. Stefana Batorego 18/108, 02-591 Warsaw
E-mail address – hello@e-sunbirds.com
Telephone call – +48 501 639 633
Contact form – available at: https://e-sunbirds.com/kontakt
§15 Service Requirements
Restricting the recording and access to Cookie files on the User’s Device may cause some functions of the Service to function incorrectly.
The Administrator shall not be liable for incorrectly functioning functions of the Service in the event that the User restricts in any way the ability to save and read Cookie files.
§16 External links
The Service – articles, posts, entries or comments of Users may contain links to external websites with which the Owner of the Service does not cooperate. These links and the pages or files indicated under them may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for the content located outside the Service.
§17 Changes to the Privacy Policy
The Administrator reserves the right to change this Privacy Policy at any time without having to inform Users about the use and exploitation of anonymous data or the use of Cookies.
The Administrator reserves the right to change this Privacy Policy at any time regarding the processing of Personal Data, about which it will inform Users who have user accounts or have subscribed to the newsletter service, via e-mail within 7 days of the change in the entries. Further use of the services means familiarization with and acceptance of the introduced changes to the Privacy Policy. In the event that the User does not agree with the introduced changes, they are obliged to delete their account from the Service or unsubscribe from the Newsletter service.
The changes introduced to the Privacy Policy will be published on this subpage of the Service.
The introduced changes come into effect upon their publication.