§ 1

Information for the User in accordance with the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. on the protection of individuals 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; hereinafter: GDPR)

Who is the administrator of your personal data?

The administrator, i.e. the entity deciding how your personal data will be used, is Smart Concept Spółka z ograniczoną odpowiedzialnością with its registered office in Piaseczno (05-502) at ul. Zalesiej 1J; with a share capital of PLN 5,000 paid up in full, entered into the National Court Register kept by the District Court for the Capital City of Warsaw Warszawa in Warsaw, 14th Department of the National Court Register under the number 0000419584; NIP: 9522117786; REGON: 145956275.

How to contact us for more information about the processing of personal data?

Representatives of Smart Concept Sp. z o. o. are at your disposal under the following contact details:

correspondence address: ul. Zaleśna 1J, 05-502 Piaseczno

e-mail address: biuro@qulla.pl

How and for what purpose were your personal data obtained and processed?

You provide your data voluntarily for the purpose of proper performance of the contract concluded with us.

The processing of your personal data is necessary to perform the contract concluded with you. Moreover, the applicable provisions related to tax law and accounting require the administrator to process this data. Another basis for processing is the legitimate interest of Smart Concept, which is:

• contacting for purposes related to the performance of the contract;
• providing payment services;
• proper administration of the e-learning platform;
• debt collection; conducting court, arbitration and mediation proceedings;
• conducting marketing activities and advertising;
• conducting statistical analyses;
• storing data for archiving purposes, and ensuring accountability (showing the fulfillment of obligations under the law).

What data is necessary for the performance of the contract?

The data we collect is limited to the requirements of the proper performance of the contract in order to ensure the highest quality of services. To conclude the contract, we only require your name and e-mail address. Other data that you provide in your user account are voluntary, they will help you better and more fully use the service, and help us improve its quality and adapt it to your needs.

If required by law, we may require you to provide other data necessary, e.g. for accounting or tax reasons.

In connection with the proper administration of our e-learning platform, we process such data as your IP address, server date and time, information about the web browser, information about the operating system, as well as the so-called cookies. cookies, about which you can read in § 2.

What are your rights regarding the processing of personal data?

We guarantee the right to access, rectify and delete data, limit their processing, the right to transfer them, not to be subject to automated decision-making, including profiling, as well as the right to object to the processing of personal data.

These rights can be exercised when:

• regarding the request to rectify the data: you notice that the data is incorrect or incomplete;
• regarding the request to delete data: the data will no longer be necessary for the purposes for which they were collected by Smart Concept; withdrawal of consent to data processing; objecting to data processing; the data will be processed unlawfully; the data should be deleted in order to fulfill the obligation resulting from the law;
• regarding the request to limit data processing: the data is incorrect – you can request the restriction of data processing for a period allowing to determine the correctness of this data; the data will be processed unlawfully, but you will not request that they be deleted; the data will no longer be needed, but you may need it to defend or pursue claims; an objection to data processing is raised – until it is determined whether the legitimate grounds on our part override the grounds for objection;
• regarding the request to transfer data: data processing takes place on the basis of your consent or a contract concluded with you and when this processing would take place automatically.

You have the right to lodge a complaint regarding the processing of personal data by us to the supervisory body, which is the Inspector General for Personal Data Protection (address: General Inspector for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw).

In what situations can you object to data processing?

The right to object to the processing of personal data arises when:

• the processing of personal data is based on a legitimate interest or for statistical purposes, and the objection is justified by a particular situation,
• personal data is processed for the purposes of direct marketing, including profiling for this purpose.

Who is your personal data shared with?

The data is made available to entities cooperating in the execution of the transaction as well as entities dealing with financial transaction support, accounting and bookkeeping, and in the event of a dispute, to entities professionally providing legal assistance. In special cases, personal data may be transferred to public authorities fighting fraud and abuse.

How long is your personal data stored?

We store personal data for the duration of the contract concluded with you, throughout the period in which you have an active User account, as well as after the end of the contract for the purposes of:

• pursuing claims in connection with the performance of the contract,
• performance of obligations arising from legal provisions, in particular tax and accounting (5 years),
• preventing abuse and fraud,
• statistical and archiving,
• for a maximum period of 6 years from the date of completion of the contract (limitation of civil law claims).

For accountability, to prove compliance with the provisions on the processing of personal data, we will store data for the period in which we are obliged to retain data or documents containing them to document the fulfillment of legal requirements and enable public authorities to control their fulfillment.

Do we transfer data to countries outside the European Economic Area?

NO.

Do we process personal data automatically (including through profiling) in a way that affects your rights?

NO. We do not make automated decision-making, including based on profiling. Your user account is not evaluated by the IT system.

§2 Cookie Policy

Smart Concept on its e-learning platform (www.qulla.pl), similarly to other entities, uses the so-called cookies, i.e. short text information saved on a computer, telephone, tablet or other user device. They can be read by our system, as well as by systems belonging to other entities whose services we use (e.g. Facebook, Google).

Cookies perform many useful functions, without which the use of our services would not be complete or efficient. We have tried to describe them below, but if this information turns out to be insufficient, write to us and we will answer all your doubts.

• ensuring security – cookies are used to authenticate users and prevent unauthorized use of the user’s account.
• impact on the processes and efficiency of using the website – cookies are used to ensure that the platform works efficiently and that you can use the functions available on it, which is possible, among others, by remembering settings between subsequent visits to the platform.
• session state – cookies often store information about how visitors use the platform, e.g. which trainings they view most often. They also enable the identification of errors displayed in some functionalities. Cookies used to save the so-called “session state” and help to improve services and enhance the platform experience.
• maintaining the state of the session – if the user logs into his account, cookies allow the session to be maintained. This means that you do not have to re-enter your login and password every time, which is conducive to the comfort of using the service.
• creating statistics – cookies are used to analyze how users use the platform (how many enter it, how long they stay on it, what content is most popular, etc.). Thanks to this, we can constantly improve our platform and adapt its operation to the preferences of users. In order to track activity and create statistics, we use Google tools, such as Google Analytics; in addition to reporting website usage statistics, the Google Analytics pixel may also be used, together with some of the cookies described above, to help display more relevant content to the user on Google services (e.g. in Google search engine)
• using social functions – the platform uses Facebook Pixel, a tool that allows us to direct personalized advertisements to you. For this to be possible, we must use cookies provided by Facebook.

Your web browser by default allows the use of cookies on your device, therefore, upon your first visit, please accept our Privacy Policy, an integral part of which is the Cookie Policy described here. Such acceptance means consent to the use of cookies in the manner and for the purposes described above. If you do not wish to use cookies and do not express such consent, but still want to use our services, change the settings in your web browser. You can completely block the automatic handling of cookies or request notification each time cookies are placed on your device. You can change the settings at any time. However, you must remember that disabling or limiting the use of cookies may cause quite serious difficulties in using our services and affect some of the functionalities of our platform.

The platform uses two basic types of cookies: “session” (session cookies) and “permanent” (persistent cookies). Session cookies are temporary files that are stored on the user’s end device until logging out, leaving the platform or turning off the software (web browser). “Permanent” cookies are stored on the user’s end device for the time specified in the cookie file parameters or until they are deleted by the user.