Privacy Policy

This Privacy Policy sets out the rules for storing and accessing data on the Devices of Users using the Site for the purpose of the provision of services by electronic means by the Controller, as well as the rules for collecting and processing the personal data of Users which they have provided personally and voluntarily through the tools available on the Site.

§1 Definitions

• Site - the “Puławska” website operating at https://magdalena-pulawska.pl
• External site - the websites of partners, service providers or service recipients cooperating with the Controller
• Site / Data Controller - the Site Controller and the Data Controller (hereinafter the Controller) is the firm “Magdalena Puławska Kancelaria Radcy Prawnego”, operating at the following address: ul. Diamentowa 8 lok. 14, 80-028 Gdańsk, Pomeranian Voivodeship, with the assigned tax identification number (NIP): PL7221619977, providing services by electronic means through the Site
• User - a natural person to whom the Controller provides services by electronic means through the Site.
• Device - an electronic device together with its software through which the User accesses the Site
• Cookie files (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 any information relating to 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 to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person
• Processing - means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
• Restriction of processing - means the marking of stored personal data with the aim of limiting their processing in the future
• Profiling - means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyse or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behaviour, location or movements
• Consent - consent of the data subject means any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which the data subject, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her
• Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to, personal data transmitted, stored or otherwise processed
• Pseudonymisation - means the processing of personal data in such a manner that the personal data 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 subject to technical and organisational measures to ensure that the personal data are not attributed to an identified or identifiable natural person
• Anonymisation - Data anonymisation is an irreversible process of operations on data which destroys / overwrites “personal data”, making it impossible to identify, or to link a given record with, a specific user or natural person.

§2 Data Protection Officer

Pursuant to Article 37 of the GDPR, the Controller has not appointed a Data Protection Officer.

In matters concerning the processing of data, including personal data, please contact the Controller directly.

§3 Types of Cookies

• Internal cookies - files placed on and read from the User’s Device by the Site’s ICT system
• External cookies - files placed on and read from the User’s Device by the ICT systems of External Sites. The scripts of External Sites which may place cookies on the User’s Devices have been deliberately included in the Site through scripts and services made available and installed in the Site
• Session cookies - files placed on and read from the User’s Device by the Site during a single session of a given Device. Once the session ends, the files are deleted from the User’s Device.
• Persistent cookies - files placed on and read from the User’s Device by the Site until they are deleted manually. The files are not deleted automatically once the Device session ends, unless the configuration of the User’s Device is set to delete cookies when the Device session ends.

§3a List of cookies used on the Site

Analytics cookies are stored only after consent has been given. Until then, the Google Analytics script neither writes nor reads any cookie. You give consent in the banner displayed on your first visit, and you may withdraw it at any time using the Cookie settings link in the footer of the Site - it opens the same banner and allows you to change your decision. The withdrawal of consent does not affect the lawfulness of processing carried out before the consent was withdrawn.

Advertising cookies are stored only after separate consent to advertising cookies has been given. Consent to analytics cookies does not cover them - these are two independent decisions in the consent banner and you may take each of them separately. Until advertising consent is given, Google scripts neither write nor read any advertising cookie, and the Site passes no information about advertising effectiveness to Google. These cookies are used solely to measure the effectiveness of advertising - they are not used to display ads to you on other websites. You may withdraw your consent at any time using the Cookie settings link in the footer of the Site.

Cloudflare Turnstile. The contact form is secured by the Cloudflare Turnstile mechanism, which protects it against automated abuse. Turnstile does not store any cookies on this Site, but it processes your IP address and basic information about your browser. The basis is the Controller’s legitimate interest in protecting the Site against abuse (Article 6(1)(f) of the GDPR). As this mechanism is necessary for the secure operation of the form, it cannot be switched off in the consent banner. You will find information on transfers of data outside the European Economic Area in §10a.

§4 Security of data storage

• Mechanisms for storing and reading cookies - The mechanisms for storing, reading and exchanging data between the cookies saved on the User’s Device and the Site are implemented by means of the built-in mechanisms of web browsers and do not allow other data to be retrieved from the User’s Device or data of other websites visited by the User, 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 cookies used by the Controller are safe for Users’ Devices and do not contain scripts, content or information that could threaten the security of personal data or the security of the Device used by the User.
• External cookies - The Controller takes all possible action to verify and select the Site’s partners in terms of Users’ security. For cooperation, the Controller selects well-known, large partners enjoying global public trust. However, it does not have full control over the content of cookies originating from external partners. To the extent permitted by law, the Controller is not liable for the security of cookies originating from External Sites, for their content or for their licence-compliant use by the Scripts installed on the Site. The list of partners is provided later in this Privacy Policy.
• Control of cookies
  • The User may at any time independently change the settings concerning the saving and deletion of, and access to, the data of cookies saved by each website
  • Information on how to disable cookies in the most popular desktop browsers is available on the pages of the providers indicated below:
    • Managing cookies in the Chrome browser
    • Managing cookies in the Opera browser
    • Managing cookies in the FireFox browser
    • Managing cookies in the Edge browser
    • Managing cookies in the Safari browser
  • The User may at any time delete all cookies saved so far by using the tools of the User’s Device through which the User uses the services of the Site.
• Threats on the User’s side - The Controller applies all possible technical measures to ensure the security of the data placed in cookies. It should be noted, however, that ensuring the security of this data depends on both parties, including on the User’s own conduct. The Controller is not liable for the interception of this data, for impersonation of the User’s session or for its deletion, resulting from the deliberate or unintentional conduct of the User, from viruses, Trojan horses and other spyware with which the User’s Device is or has been infected.
• Storage of personal data - The Controller declares that it makes every effort to ensure that the personal data voluntarily entered by Users and processed are secure, that access to them is limited and exercised in accordance with their intended use and the purposes of the processing. The Controller also declares that it makes every effort to protect the data it holds against loss, by applying appropriate physical and organisational safeguards.

§5 Purposes for which cookies are used

• Improving and facilitating access to the Site
• Keeping statistics (users, number of visits, types of devices, connection, etc.)
• Measuring the effectiveness of advertising (checking which ad click led to contact through the form) - only with your consent

§6 Purposes of personal data processing

Personal data provided voluntarily by Users are processed for one of the following purposes:

• Provision of electronic services:
• Communication by the Controller with Users on matters relating to the Site and to data protection
• Securing the legitimate interest of the Controller

Data on Users collected anonymously and automatically are processed for one of the following purposes:

• Keeping statistics
• Securing the legitimate interest of the Controller

§7 Cookies of External Sites

On the Site, the Controller uses JavaScript scripts and web components of partners who may place their own cookies on the User’s Device. Please remember that in your browser settings you can decide for yourself which cookies may be used by particular websites. Below is a list of partners or of their services implemented on the Site which may place cookies:

• Keeping statistics:
  • Google Analytics
• Measuring advertising effectiveness:
  • Google Ads (through Google Tag Manager)

Services provided by third parties are beyond the Controller’s control. Those entities may at any time change their terms of service, their privacy policies, the purpose of data processing and the ways in which they use cookies.

§8 Types of data collected

The Site collects data on Users. Part of the data is collected automatically and anonymously, and part of the data is personal data provided voluntarily by Users when signing up for the individual services offered by the Site.

Anonymous data collected automatically:

• IP address
• Browser type
• Screen resolution
• Approximate location
• Opened subpages of the Site
• Time spent on a given subpage of the Site
• Type of operating system
• Address of the previous subpage
• Address of the referring page
• Browser language
• Internet connection speed
• Internet service provider
• Demographic data (age, gender)

Part of the data (without identifying data) may be stored in cookies. Part of the data (without identifying data) may be transferred to the statistics service provider.

§9 Access to personal data by third parties

As a rule, the only recipient of the personal data provided by Users is the Controller. Data collected as part of the services provided is neither transferred nor resold to third parties.

Access to the data (most often on the basis of a data processing agreement) may be held by entities responsible for maintaining the infrastructure and services necessary to operate the Site, i.e.:

• Hosting companies providing hosting services or related services to the Controller
• Google Ireland Limited - as regards data on advertising effectiveness, only after consent to advertising cookies has been given. The details of transfers outside the European Economic Area are described in §10a.

Entrusting the processing of personal data - Hosting, VPS or Dedicated Server services

In order to operate the Site, the Controller uses the services of an external provider of hosting, VPS or Dedicated Servers - Kru.pl Sp. z o.o. (ul. E. Radzikowskiego 3, 31-305 Kraków, NIP PL9512360611, KRS 0000434320), services available at www.kru.pl. All data collected and processed on the Site is stored and processed in the service provider’s infrastructure located in Poland. Access to the data is possible in the course of maintenance work carried out by the service provider’s personnel. Access to that data is governed by the agreement concluded between the Controller and the Service Provider.

§10 Manner of processing personal data

Personal data provided voluntarily by Users:

• Personal data may be transferred outside the European Economic Area to the extent described in §10a. Data published as a result of an individual action of the User becomes available to every person visiting the Site.
• 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.

§10a Transfers of data outside the European Economic Area

Three services used on the Site involve transferring data to the United States. Each case works differently, which is why I describe them separately.

Google Analytics 4 - visit statistics

• Data from the European Economic Area is collected by domains and servers located in the European Union, and Google truncates the IP address while still on the European side - it neither records nor stores it.
• The processing and storage themselves, however, take place in Google’s global infrastructure, and therefore also in the United States. Standard Google Analytics 4 does not offer the option of storing data exclusively in the European Union - it is not a product with a data residency guarantee.
• Recipient: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), which transfers the data to Google LLC.
• This data is collected only after you have given your consent to analytical cookies. Without consent, the Google Analytics script neither writes nor reads any cookie.

Google Ads - measuring advertising effectiveness

• Data on ad clicks and on form submissions is processed in Google’s global infrastructure, and therefore also in the United States.
• Recipient: Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland), which transfers the data to Google LLC.
• This data is collected only after you have given separate consent to advertising cookies. Without that consent, Google scripts neither write nor read any advertising cookie.
• The basis for the transfer is the same as for Google Analytics 4 - see the Basis for the transfer paragraph below.

Cloudflare Turnstile - protection of the contact form

• By default, the user’s traffic terminates at the nearest Cloudflare point of presence - for a person connecting from the Tricity area, most often in Warsaw. The content of the traffic therefore usually does not leave Europe, but this results from the way traffic is routed and not from a contractual guarantee.
• Logs and metadata go by default to Cloudflare’s main data centre. Restricting them exclusively to the European Union is ensured only by the Customer Metadata Boundary feature, available as part of the Data Localization Suite and solely to customers on the Enterprise plan. The related features are Regional Services, which determines where HTTPS traffic is decrypted, and Geo Key Manager, which determines where TLS keys are stored.
• Regardless of the configuration, Cloudflare, Inc. remains a US company and is subject to the provisions of the CLOUD Act. The location of the servers does not change this.
• Recipient: Cloudflare, Inc. (101 Townsend St., San Francisco, CA 94107, United States).

Basis for the transfer. Google LLC and Cloudflare, Inc. participate in the EU-U.S. Data Privacy Framework programme, covered by European Commission Implementing Decision (EU) 2023/1795 of 10 July 2023 finding an adequate level of data protection. In addition, the standard contractual clauses adopted by Commission Decision (EU) 2021/914 apply, as included in the data processing agreements. The current list of participants in the programme can be checked at www.dataprivacyframework.gov, and I will provide a copy of the safeguards applied on request sent to the Controller’s address.

§11 Legal bases for the processing of personal data

The Site collects and processes Users’ 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(1)(a)
    the data subject has given consent 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)(f)
    processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party
• Act of 10 May 2018 on the Protection of Personal Data (Journal of Laws / Dz.U. 2018, item 1000)
• Act of 12 July 2024 - Electronic Communications Law (Journal of Laws / Dz.U. 2024, item 1221), in particular Article 361 on the storing of information in telecommunications terminal equipment
• Act of 4 February 1994 on Copyright and Related Rights (Journal of Laws / Dz.U. 1994, No. 24, item 83)

§12 Period of personal data processing

Personal data provided voluntarily by Users:

As a rule, the personal data indicated above is stored only for the period during which the Controller provides the service within the Site. It is deleted or anonymised within 30 days from the moment the provision of services ends (e.g. deletion of a registered user account, unsubscribing from the Newsletter list, etc.)

An exception is a situation that requires securing the legitimate purposes of further processing of this data by the Controller. In such a situation the Controller will store the data indicated above, from the time the User requests its deletion, for no longer than 3 years in the event of a breach or suspected breach of the provisions of the Site’s terms and conditions by the User

Anonymous data (without personal data) collected automatically:

Anonymous statistical data that does not constitute personal data is stored by the Controller for the purpose of keeping Site statistics for an indefinite period

§13 Users’ rights related to the processing of personal data

The Site collects and processes Users’ data on the basis of:

• Right of access to personal data
  Users have the right to obtain access to their personal data, exercised upon a request submitted to the Controller
• Right to rectification of personal data
  Users have the right to request the Controller to rectify without undue delay personal data which is inaccurate and / or to complete incomplete personal data, exercised upon a request submitted to the Controller
• Right to erasure of personal data
  Users have the right to request the Controller to erase personal data without undue delay, exercised upon a request submitted to the Controller In the case of user accounts, erasure of data consists in the anonymisation of data enabling identification of the User. The Controller reserves the right to withhold performance of a request for erasure of data in order to protect the legitimate interest of the Controller (e.g. where the User has breached the Terms and Conditions or where the data was obtained in the course of correspondence).
  In the case of the Newsletter service, the User may delete their personal data themselves using the link included in every e-mail message sent.
• Right to restriction of processing of personal data
  Users have the right to restrict the processing of personal data in the cases indicated in Article 18 GDPR, including where the accuracy of the personal data is contested, exercised upon a request submitted to the Controller
• Right to personal data portability
  Users have the right to obtain from the Controller the personal data concerning the User in a structured, commonly used, machine-readable format, exercised upon a request submitted to the Controller
• 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 Article 21 GDPR, exercised upon a request submitted to the Controller
• Right to lodge a complaint
  Users have the right to lodge a complaint with the supervisory authority responsible for the protection of personal data.

§14 Contacting the Controller

The Controller can be contacted in one of the following ways

• E-mail address - kancelaria@magdalena-pulawska.pl
• Telephone call - +48 512 278 244
• Contact form - available at magdalena-pulawska.pl

§15 Site Requirements

• Restricting the storage of and access to cookies on the User’s Device may cause some functions of the Site to work incorrectly.
• The Controller bears no liability whatsoever for functions of the Site that do not work correctly where the User restricts in any way the ability to store and read cookies.

§16 External Links

The Site may contain links to external websites with which the Site Owner does not cooperate. These links, as well as the pages or files they point to, may be dangerous for your Device or may pose a threat to the security of your data. The Controller bears no liability for content located outside the Site.

§17 Changes to the Privacy Policy

• The Controller reserves the right to change this Privacy Policy at its discretion, without having to inform Users, as regards the application and use of anonymous data or the use of cookies.
• The Controller reserves the right to change this Privacy Policy at its discretion as regards the processing of Personal Data, of which it will inform Users who hold a user account or who are subscribed to the newsletter service, by electronic mail within 7 days of the change to the provisions. Further use of the services means that the changes made to the Privacy Policy have been read and accepted. Where the User does not agree with the changes made, the User is obliged to delete their account from the Site or to unsubscribe from the Newsletter service.
• Changes made to the Privacy Policy will be published on this subpage of the Site.
• The changes made take effect upon their publication.