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Privacy policy

Since 25.05.2018, 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 (hereinafter: GDPR), has applied. Its provisions concern the privacy of processed data, aim to strengthen the security and protection of personal data in the EU, and replace the European privacy directive and national legislation accordingly.

The GDPR gives all residents and customers in the EU greater control over how their data is used, how it is obtained and how the data subject is contacted. These changes will also allow better protection of personal data.

We are committed to protecting privacy effectively

We process all data in compliance with data protection law and with appropriate safeguards. Transparency about how we collect, process and use the data provided by our customers is extremely important to us. Our website uses essential cookies to make the site work and to remember your consent choices. Optional analytics and marketing tools launched via Google Tag Manager are enabled once you consent to the relevant category.

Data controller

The controller of personal data is iTrust sp. z o.o. (hereinafter: the Company), with its registered office in Warsaw (00-689) at ul. Poznańska 37, entered in the Register of Entrepreneurs of the National Court Register by the District Court in Warsaw, XII Commercial Division, under no. 0000691931 on 25 August 2017, tax ID (NIP) 7010712208.

Data Protection Officer

At iTrust sp. z o.o., the Data Protection Officer is Mr Dariusz Mikołajczyk, who can be contacted by email at iod@itrust.pl or in writing at the Company’s registered office address.

From which sources do we obtain personal data?

We process personal data that comes from customer correspondence, including the contact form. In that case we state which data is necessary and mandatory for us to provide the service in question. The second source is information we obtain from public sources, such as public address registers, or from business partners we work with.

For what purposes do we process personal data?

We process personal data solely for the following purposes:

  • Managing relationships with customers and business partners
  • Managing and monitoring contracts and services
  • Financial settlements
  • Disclosing data to public authorities under applicable law

Legal bases

We process personal data on the basis of:

  • consent given, which constitutes the legal basis for processing the data;
  • a relevant contract concluded with iTrust sp. z o.o., which obliges the Company to comply with its provisions;
  • legal provisions (e.g. the obligation to retain certain data for a specified period);
  • the pursuit of our legitimate interests, including the purposes listed above.

Automated decision-making

The Company does not make decisions by means of automated decision-making systems.

How long do we keep personal data?

We keep personal data in a form that permits identification for no longer than is necessary for the purposes for which it is processed. As a rule, personal data is kept for the duration of the relationship with customers and for a maximum of 6 years after the relationship ends. Retention periods may vary depending on the category of data. The Company defines and regularly reviews retention periods for specific types of data. When personal data is no longer necessary, it is deleted or anonymised as soon as possible.

Who processes personal data?

Your data is processed by our employees and associates who need access to it to perform their duties, and by trusted entities working with us where necessary to provide our services, e.g. couriers, banks, insurers, law firms, mail handling providers, IT service providers and sales partners. These entities process personal data in accordance with applicable privacy laws.

Where an entity processes data on our behalf, this always takes place under a contract which guarantees that the data is processed securely, in accordance with privacy laws and in line with data processing best practice.

We may also disclose personal data to public administration authorities or judicial authorities if we are required to do so by law.

Does the Company transfer personal data to other countries?

iTrust sp. z o.o. does not transfer personal data outside the European Union or the European Economic Area (EEA).

How is personal data protected?

iTrust sp. z o.o. implements the technical and organisational measures necessary to ensure an adequate level of data protection. These measures include: monitoring access rights so that only authorised persons process personal data, pseudonymisation of data, detailed instructions and procedures, training for those responsible for personal data protection to raise data security awareness, restricted access to premises, appropriate documentation of data processing operations, updating contracts to comply with data protection law, and careful selection of our service providers who process personal data on our behalf.

How do we obtain personal data through IP addresses, cookies and similar technologies?

The Company may collect data on website visitors by means of cookies and other similar techniques which:

  • make it possible to remember visits to the website and preferences relating to it (e.g. content layout);
  • allow us to compile anonymous statistics on visits to our websites.

You can block the use of cookies by changing your web browser settings; however, this may prevent our website content from displaying correctly.

What rights do you have in connection with the processing of your data?

  • Right of access – the right to obtain confirmation as to whether the Company processes your personal data and, if so, to receive a copy of that data and information about the processing.
  • Right to data portability – for the purpose of transfer, personal data may be provided in a structured, commonly used and machine-readable format, or transmitted in that format directly to another controller.
  • Right to rectification – the right to correct and complete your data if it is inaccurate or out of date.
  • Right to be forgotten – the right to request erasure of personal data if: 
    • the data is no longer needed for the purposes for which it was processed;
    • consent to processing has been withdrawn, thereby depriving the Company of a legal basis for processing the data,
    • the data is processed unlawfully, or
    • processing the data is not necessary to comply with applicable legal requirements, to establish, pursue or defend legal claims, or for statistical or archiving purposes.
  • Right to withdraw consent – the right to withdraw consent given to processing for a specific purpose.
  • Right to object to the processing of personal data – you may object to the processing of your data if it is based on the legitimate interests of the Company or a third party. Unless iTrust sp. z o. o. demonstrates legitimate grounds for processing the data, further processing will not be possible.
  • Right to object to direct marketing – you may object at any time to the processing of personal data for direct marketing.
  • Right to restriction of processing – you may request iTrust sp. z o. o. to restrict the processing of personal data, among other things where the accuracy of the personal data is contested or where an objection to processing has been raised – until it is determined whether the legitimate grounds of the Controller override the grounds for the objection.
  • Right not to be subject to automated decision-making – if a decision were made solely by automated means and had legal effects, you may request a review of that decision based on a new, individual assessment. This applies if the Company cannot demonstrate that the automated decision is necessary to enter into or perform a contract.

To exercise the above rights, please send a request to the contact address given at the end of this Privacy Policy.

  • Right to lodge a complaint with a supervisory authority – you may lodge a complaint with the supervisory authority, the President of the Personal Data Protection Office (UODO), if your personal data is processed in breach of applicable law.

Register of consents and form submissions

In the submissions register we record the email address, the date the form was sent, consent decisions together with the version and a copy of their wording, and the status of delivery of the message to the mail server. The register does not contain the content of the enquiry, the subject, full name, organisation, phone number or IP address. Data entered in the form is sent by email to handle the enquiry.

To withdraw consent to contact, the newsletter or offers, write to iod@itrust.pl.

If you consent to analytics, we also run our own measurement of page views and traffic sources. The fc_analytics cookie stores a random browser identifier for 90 days. We record the page visited, the time, the source, the medium and the campaign name. We do not record the IP address, the full referring page address or form content. The measurement is not linked to contact details or the consent register. Detailed data is deleted after 90 days, at the next statistics write. Withdrawing consent removes the identifier from the browser and stops further measurement.

Changes to the Privacy Policy

iTrust sp. z o. o. reserves the right to make changes to this Privacy Policy. Updates may be necessary due to, for example, the development of our services or changes in legislation.

Please send any questions, comments and requests concerning this Privacy Policy by email to: iod@itrust.pl.