As we for the wording “Grupa Wydawnicza WSiP” we explain, as follows, that the Group shall comprise the following entities:
- Wydawnictwa Szkolne i Pedagogiczne Spółka Akcyjna (WSiP PLLC), including our Profi-Lingua language schools,
- Wydawnictwo Zielona Sowa LLC
- ALFA LOGIS LLC.
Personal Data Protection Inspector
According to article 37 (1) of the GDPR, the data administrator has appointed Maciej Byczkowski for the Personal Data Protection Inspector. The data subjects shall contact the Personal Data Protection Inspector on all matters relating to the processing of their data and the exercise of the data subject’s rights under the GDPR.
In case of any doubt relating to your personal data processing do not hesitate to contact the Inspector:
- By writing at: Al. Jerozolimskie 96, 00-807 Warszawa
- By sending an email at: iod@wsip.pl
The Personal Data Protection Inspector shall ensure full confidentiality of the data subjects’ enquiries. According to article 38 (5) of the GDPR Regulation, Personal Data Inspector is subject to an obligation of secrecy and confidentiality concerning the performance of their tasks - by Union or Member State law.
Purposes and the legal basis for the personal data processing:
Your data will be processed for the following purposes:
- The conclusion and performance of the contract (e.g. as a result of the performance of contracts or performance of the electronically supplied service, the use of online portals and the acceptance of the terms and conditions). The legal basis for processing personal data is the necessity of processing the key data for the conclusion and performance of the contract.
- The direct marketing of the Administrator’s products and services, as well as for analytical and profiling purposes. The legal basis for processing the personal data is the necessity of the data processing for attaining the legitimate Administrator’s interest thus the possibility of carrying out the direct marketing of their services.
- Marketing purposes, as well as analytical and profiling purposes for products and services of the subjects of WSiP Grupa Wydawnicza (Publishing Group) and the entities cooperating with WSiP, operating on the education and publishing markets. The legal basis for the data processing is the voluntary consent.
- A one-time telephone or email contact from a WSiP representative concerning an information previously request, levelling test feedback, course enrolment, depending on the nature of activity carried out by the person concerned. The legal basis for the data processing is formed by the legitimate interest of the Data Administrator, which is reliable customer service for the website visitors and the willingness to provide help in obtaining necessary information.
- The communication of personal data to the third parties cooperating with WSiP for marketing purposes. The legal basis for the processing is formed by the voluntary consent provided that the consent has been given. If no consent has been given the personal data shall not be processed for this purpose.
- Alternatively to pursue the claims relating to the contract concluded (including the electronically supplied services within the online portals), which forms the legitimate Administrator’s interest; for the complaints’ handling. The legal basis for the data processing is the obligation deriving from the statutory provision.
- As for some language schools operate as independent bodies and cooperate with our company upon franchise agreement, in case you leave your data on our website to participate in a course of a given language school, we will share with the school your data (name, surname, email address, telephone number) to allow the contact. The legal basis for the data processing is formed by our legitimate interest, which is to provide help in carrying out a language course.
Profiling - related information
Based on your data our company carries out profiling activities i.e. an automatic evaluation of some of your features. The purpose of profiling is to choose in the best possible way the information materials and offers to promote our products, services and events. Thanks to profiling you shall receive possibly less information, allowing us to better meet your preferences.
To carry out the profiling activities we shall use the following information: age, sex, region, place of living, size of the locality, family status, interests, profession, work post, device type (device model in case of mobile devices), Internet provider, screen resolution, version of the operating system and the browser, language preferences settings as well as the information relating to your activities carried out on our website and the products/services ordered.
The data recipients
The following data recipients shall be granted the access to the personal data:
- The entitled employees of the Data Administrator,
- The entities performing services assigned with data processing tasks by contractual agreement to provide services for the data administrator, such as call-centre, IT services providers, in particular Primeon LLC, ClickMeeting LLC or HUbSpot Inc., with its registered headquarters in the United States, marketing agencies, mailing services companies, legal offices, and the external auditors and their entitled employees to the extent which is necessary for the provision of such services,
- The entities cooperating with the data administrator, with whom the personal data is shared upon a voluntary consent of the data subject for the purposes indicated in the consent.
- The language schools operating as independent bodies and cooperating with our company upon a franchise agreement.
Transferring the data to the third countries (i.e. outside the European Economic Area)
As for the use of an external provider’s IT system it may thus be necessary to transfer the data to the third countries recipients, we assure however that the data is adequately protected. In this regard, we collaborate exclusively with the entities holding a valid Privacy Shield Certificate (inside the United States) or bound by the contractual agreement based upon the Standard Contractual Clause approved by the European Commission. Both solutions ensure the safety of the data processed at least at the level applicable to the European Union Standards.
Data retention period
- Your data shall be retained for the relevant limitation period under agreement/order or until the expiry of the data retention period under the legislation, in particular the obligation to store the accounting documents prescribed in the accountancy law.
- In the event of leaving the data in the contact form, your data shall be retained until your request shall be completed and in some cases for the relevant limitation period.
- Shall you object to the data processing for direct marketing, including profiling and analytical purposes, or shall you withdraw your consent in this regard, we are bound to stop processing your data for these purposes.
- If you have given us your consent to share your data with different entities from WSiP Grupa Wydawnicza or the entities included in the consent form to further process your data by these entities for the marketing purposes, your data will be made available until the consent has been withdrawn.
Data collection principles
Providing personal data by a data subject is voluntary, however, as for an order of goods or services, as well as for the online registration, contact form and placement tests forms, it is necessary to provide the data to carry out the agreement/order/enquiry.
Sharing your data for marketing purposes is voluntary.
The laws and regulations relating to the processing of your data
As for your personal data processing, there is a set of data protection regulations guaranteeing several rights:
- The right to access your data and to demand to correct it.
- As for the scope in which the premise of the legitimate interest of your administrator constitutes the basis of your personal data processing you have the right to object to the personal data processing due to the particular circumstances. In particular, you have the right to object to the processing for direct marketing purposes, including profiling.
- The right to withdraw your consent to the extent that such processing is based upon the voluntary consent. The withdrawal of your consent does not affect the legality of the processing law carried out under the consent before it has been withdrawn.
- The right to the personal data transfer, i.e. to receive the data from the personal data administrator in a structured and commonly used and machine-readable format in the event of your data being processed for the conclusion and implementation of the contract/order or being processed under the consent. You can share the data you have received with another data administrator.
- The right to claim to limit your personal data processing.
- The right to erase your data (i.e. “a right to be forgotten”), however, we are bound to comply with your right only if we are not obliged by law for the further processing.
To claim one’s data protection rights please contact us or reach out to the Data Protection Inspector. You shall find the contact data at the beginning of this communication.
You are also entitled to complain about the personal data processing to the supervisory authority responsible for the data protection, i.e. the President of the Office of the Data Protection, in case you find that the processing may infringe the GDPR provisions.
