SITE PRIVACY POLICY «DE.RAZEM.WORK»

Effective date: July 29, 2020
Last Modified Date: July 29, 2020

1. Terms and conditions

1.1 Before using the Site, read this Privacy Policy (hereinafter referred to as "the Policy") as it affects your rights and duties. This Policy is an integral part of the Terms of use (Agreement) on the website "de.razem.work" available under the link https://de.razem.work/pages/default/view?page=terms-and-conditions.

If the Employer does not agree with the Policy, he should immediately stop using the Website.

1.2 Concepts and terms in this Policy are understood of meaning the concepts defined in Section 1 of the Terms of Use, unless otherwise provided in this Policy.

1.3 This Privacy Policy is aimed at informing Employers about the procedures for collecting, using and processing information, namely Personal Data provided to Razem and to Users using the website de.razem.work.

1.4 The administrator of personal data processing (controller) is RAZEM:
Razem Sp. z. o. o.
KRS 0000720974
NIP 5252742175
Region 369588770
WARSAW, str. Twarda, 18, 00-105

The Website Administrator is responsible for collecting, storing and processing Personal Data. If you have any questions, suggestions or requests regarding Personal Data, please contact the Website Administrator at admin@razem.work or by phone on +48 22 307 41 48.

1.5 After providing your e-mail address, after clicking the button on the Website that confirms your consent and when registering an Account on the Website, the user agrees to the transfer or processing and storage of Personal Data Razem, received from the Account, also other data that may be additional received when using the Website.

1.6 The processing of Personal Data includes all activities or all activities related to the collection, registration, storage, adaptation, modification, renewal, use and dissemination (implementation, transfer), deletion (liquidation) of Employer Personal Data to ensure the functioning of the Website.

1.7 Razem reserves the right to change this Policy at any time. Razem will post the latest changes made to the Privacy Policy in the "Last Modified Date" field and notify Employers of such changes within a reasonable period (within 48 hours) by means of an information message to the Account, sending a message to the Employer's email address. By continuing to use the Website after making such changes, the Employer agrees and accepts them as part of the Privacy Policy.

2. Data collected by Razem

2.1 Razem may collect and process the following Employer Information provided voluntarily by the Employer:

• e-mail address required during registration to receive Services on the Website (in the case of Account registration, and when subscribing to RAZEM);
• information that is necessary to start using the Website and provide in Account Settings (name, phone number, e-mail address, company name, address and other data about the legal entity representing the Employer (including KRS number and tax identification number);
• photo, video;
• trademark (logo and text) and trade name.

Payment information is not stored and used by the company Razem, but is stored and processed by the online acquiring service specified in point 3.1 of the Terms of use, which is the Administrator (controller) of Personal Data. In addition to payment information, online acquiring services can also collect information: name, surname, place of residence and e-mail address. The cooperation of such a website and Razem, in particular in the scope of transfer and processing of Personal Data, is specified in the contract and is carried out in accordance with the requirements of applicable legislation.

2.2. Razem may collect and process the following Employer Information collected automatically:

• to the extent permitted by applicable law, information on devices that are used by Employers and used by the Employer when using the Website. This may include information such as: IP address, login information, browser type and version, browser plug-in type and type, operating system and platform, visit information, including displacement by URL to, through or from the Website, searched or viewed by the Employer Users 'personal surveys, the number of invitations sent by the Employer, messages, the number of Users' responses to the Employer's invitations, the number of paid services purchased, details of using paid access (number of days of use, time of interaction with paid services), download errors, length of browsing certain pages , page interaction or any number that has been used to contact the number of our technical support center; such information is collected using various technologies, including cookies;
• statistical information, which includes the systematization of data from Accounts to examine the employers' database, development trends, marketing purposes, as well as the publication of such information in the public domain in a generalized form.

Such information has the status of Personal Data only if it allows directly identifying the Employer.

3. Use of Personal Data

3.1 Razem processes Employer's Personal Data solely for the purpose of:

• providing Services via the Website in accordance with the Regulations;
• processing of payments for the use of the selected tariff, other paid services of the Website and transfer of these data to third parties responsible for making payments (acquiring service referred to in point 3.1 of the Terms of use, which is the Personal Data Administrator);
• assessment, analysis and improvement of Services;
• facilitating the use of the site for employers (and increasing its speed);
• effective administration of the Website;
• informing other Employers and potential clients about provided services and updates.

4. Personal Data Processing

4.1 Razem does not disclose Personal Data to third parties, except for cases expressly agreed by the Employer on the terms and conditions specified in this Policy.

4.2 We take into account the features of the website, some third parties may have access to some or all of your personal data:

Category 1

• users registering personal Questionnaires on the Website (https://de.razem.work) in order to search for information messages from Employers and for further communication and cooperation;
• websites with which Razem (partner websites) cooperates to post materials about the Website and Services (including, but not limited to, advertising, market research, publication of journalistic materials). Razem sends to these entities only aggregate information that does not allow the Employer to be identified, but which can be identified only with the consent of the Employer.

These entities gain access to Personal Data in a manner consistent with the purpose of the Website. Access to Personal Data takes place to the extent specified by the Website Administrator and in accordance with the terms of use by Users and relevant websites with which he cooperates. Razem is not responsible for the protection of Personal Data that has been disclosed by the User outside the Website or has been voluntarily disclosed to the functional units of the Employer as part of the Website (for example, via e-mail address). The procedure for collecting, processing and securing Personal Data entities outside the Website must comply with the conditions set out in the relevant Privacy Policy or other regulatory documents of such entities.

Category 2

• Google Inc., through the Google Analytics service, analyzing the statistics of the use of the Website;
• Facebook Inc., via the Facebook Pixel service, which analyzes information from a particular Website in order to create targeted advertisements;
• Hotjar Ltd., through the Hotjar service, which analyzes information from a particular Website in order to improve its appearance and increase attendance;
• Jivosite Inc., through the Jivosite (Jivochat) service integrating online chat with a specific Website;
• The Internet service, specified in point 3.1 of the Regulations, to support Employer payments for monthly subscription and other paid Website Services;
• Fakturownia.pl (Fakturownia sp.z o.o.) - a website that allows the Employer to issue a pro-forma invoice and invoice to pay Website Services through his own account.

Although these services receive general information that cannot be considered Personal Data within the meaning of applicable law, taking into account the technical feasibility of testing and analyzing such data, Razem is not responsible for the collection, processing and storage of Personal Data obtained by third parties. To find out how third parties use data, please refer to the relevant Third Party Privacy Policy.

4.3 Razem is required to comply with and comply with legal requirements so that in some cases it may disclose Personal Data without notice if:

• Razem considers that such disclosure is necessary and justified to ensure compliance with laws, litigation, investigations or at the request of public authorities;
• Personal data is disclosed in response to a complaint to protect against abuse, misuse, improper or illegal use of the Website.

In this case, Personal Data will be disclosed only to the extent necessary to achieve the required legitimate purpose.

5. Modifying and Deleting Personal Data

5.1 The Employer can change Personal Data at any time through Account Settings.

5.2 The employer may send the Website Administrator a request to modify, correct or remove any incorrect or false information about him posted on the Website, the Website Administrator is obliged to consider and make a decision of such request within 72 hours from the date of receipt.

5.3 At the request of the Employer, the Website Administrator is obliged to delete all Employer's Personal Data to which he obtained access in connection with the provision of Employer's Services, as well as to completely and irrevocably delete the Employer's Account on the Website.

5.4 The employer may exercise the right to be forgotten by sending the Website Administrator a request for irreversible destruction of all information (including Personal Data) available for Razem. The Website Administrator is obliged to delete all available information about the Employer, who owns the Account, within 72 hours of receiving the request.

6. Protection and storage of personal data

6.1 Razem guarantees that all Employer's Personal Data will be used, stored and processed in the Razem and third parties database in accordance with the applicable legislation of the Republic of Poland (including the Constitution of the Republic of Poland, the Act of August 29, 1997 on the protection of personal data and the Regulation (EU) 2016/679 of the European Parliament and of the Council). Additionally, Razem uses physical protection resources for Personal Data media against unauthorized access, detailed reporting of access to Personal Data and uses software to protect Personal Data, such as password, codes and security protocol for connecting to the SSL service.

6.2 Razem will also endeavor to use, store and process Personal Data in accordance with other applicable laws.

6.3 By default, Personal Data will be stored for the period necessary to achieve the purposes of processing such data specified in point 3.1 of this Policy, but not longer than 10 (ten) years. Personal data is destroyed after the expiry of the storage period or in cases provided for by applicable law.