Privacy Policy
I. INTRODUCTION
The Independence March Association with its registered office in Warsaw, at ul. Stawki 4B/U1, 00-193 Warsaw (hereinafter referred to as the Association or the Administrator), fulfilling the obligations arising from the applicable legal provisions concerning the protection of personal data, including 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 referred to as the GDPR), wishes to provide you with information concerning the processing and protection of your personal data.
The information contained in this Privacy Policy will help you understand what personal data the Association collects and processes, for what purpose they are used, and what rights you have in connection with the protection of personal data.
II. PROCESSES OF PROCESSING PERSONAL DATA IN THE ASSOCIATION
The Association collects and processes personal data in connection with:
- maintaining permanent contact with the Association in connection with the realisation of its statutory aims, in particular by informing about organised social actions (campaigns, debates, seminars, scientific and press conferences), as well as possibilities of supporting the Association’s activity;
- conducted social actions, including the collection of declarations of support for actions, petitions, protests, civic legislative initiatives etc.;
- establishing contact via contact forms available on the websites;
- organisation of public events, debates, seminars, scientific or press conferences;
- making available publications, analyses, brochures, positions of the Association;
- support of the Association’s activity by donors;
- use by users of the Association’s websites (use of cookies);
- involving supporters in volunteering in connection with the organisation of the Independence March.
III. CATEGORIES OF DATA PROCESSED BY THE ASSOCIATION
The Association collects and processes personal data to the extent necessary to achieve the purpose for which they were collected.
Depending on the purpose and legal basis for the processing of personal data, the Association may collect and process, among others, the following data:
- identifying data, including: first name, surname, date of birth;
- contact data, including: residential address or correspondence address, telephone number, e-mail address;
- data collected and processed in connection with the statutory aims of the Association, including among others: data necessary for the organisation of public events, social actions, a civic legislative initiative, data about donors in connection with support granted to the Association;
- data about persons involved in volunteering for the Independence March, including among others: age, education or specialist knowledge.
IV. PURPOSES, LEGAL BASES AND PERIODS OF PROCESSING OF PERSONAL DATA IN THE ASSOCIATION
1. If you receive from the Association invitations or information about the realisation of the Association’s statutory aims, including about organised social actions.
This concerns persons who have subscribed to the mailing list, persons communicating with the Association via social media (Facebook, Twitter, YouTube), as well as persons whose data have been obtained by the Association from publicly available sources.
| Purpose of processing personal data | Legal basis for processing personal data | Period of processing personal data |
|---|---|---|
| Informing about the realisation of the Association’s statutory aims, including informing about organised social actions (campaigns, actions, protests, petitions, debates, seminars, scientific or press conferences), as well as possibilities of supporting the Association’s activity | Art. 6(1)(f) GDPR – realisation of the Administrator’s legitimate interest consisting in maintaining permanent contact with the Association in connection with its statutory aims | Period necessary to achieve the purpose, however no longer than until you lodge an objection to the processing of personal data |
| Establishment, pursuit of claims and defence against claims, including documentation of lodged objections to the processing of personal data | Art. 6(1)(f) GDPR, Art. 17(3)(e) GDPR – legitimate interest of the Administrator in processing the data | Limitation period of possible claims arising from legal provisions |
If you support social actions, in particular protests, petitions, campaigns, including civic legislative initiatives, organised by the Association.
This concerns natural persons who have filled in paper forms and sent them to the Association’s address or persons who have filled in forms on websites run by the Association in order to support actions, petitions, protests or campaigns organised by the Association.
| Purpose of processing personal data | Legal basis for processing personal data | Period of processing personal data |
|---|---|---|
| Informing persons who have granted support for a given social action about its further course | Art. 6(1)(f) GDPR – realisation of the Administrator’s legitimate interests in the form of communication with persons granting support for a given social action | Period necessary for informing about the course of the social action, however no longer than until you lodge an objection to the processing of personal data |
| Informing about the realisation of the Association’s statutory aims, including informing about organised social actions (campaigns, actions, protests, events, meetings, competitions, debates, seminars, scientific and press conferences), as well as possibilities of supporting the Association’s activity | Art. 6(1)(f) GDPR – realisation of the Administrator’s legitimate interest consisting in maintaining permanent contact with the Association in connection with its statutory aims | Period necessary to achieve the purpose, however no longer than until an objection to the processing of personal data is lodged |
| Establishment, pursuit of claims and defence against claims, including documentation of lodged objections to the processing of personal data | Art. 6(1)(f) GDPR, Art. 17(3)(e) GDPR – legitimate interest of the Administrator in processing the data | Limitation period of possible claims arising from legal provisions |
If you use contact forms available on websites run by the Association.
This concerns natural persons who have asked questions or submitted applications via a contact form on websites administered by the Association.
| Purpose of processing personal data | Legal basis for processing personal data | Period of processing personal data |
|---|---|---|
| Contact in connection with a question or application submitted via a contact form on the website | Art. 6(1)(f) GDPR – realisation of the Administrator’s legitimate interests in the form of communication with website users | Period necessary to reply to questions or the application, however no longer than until an objection to the processing of personal data is lodged |
| Informing about the realisation of the Association’s statutory aims, including informing about organised social actions, as well as possibilities of supporting the Association’s activity | Art. 6(1)(f) GDPR – the Administrator’s legitimate interest consisting in maintaining permanent contact with the Association in connection with its statutory aims | Period necessary to achieve the purpose, however no longer than until you lodge an objection to the processing of personal data for this purpose, and after that time they may be processed for the limitation period of possible claims (Art. 17(3)(e) GDPR) |
| Establishment, pursuit of claims and defence against claims, including documentation of lodged objections to the processing of personal data | Art. 6(1)(f) GDPR, Art. 17(3)(e) GDPR – legitimate interest of the Administrator in processing the data | Limitation period of possible claims arising from legal provisions |
4. If you participate in public events organised by the Association.
This concerns natural persons who have expressed a wish to participate in a given event, meeting, debate, seminar, scientific or press conference organised by the Association, e.g. to deliver a paper or take part as a listener in a conference by filling in a form on the website informing about the given conference or filling in a form at the reception desk immediately before the event.
| Purpose of processing personal data | Legal basis for processing personal data | Period of processing personal data |
|---|---|---|
| Informing about the organised event, meeting, debate, seminar, scientific or press conference | Art. 6(1)(f) GDPR – realisation of the Administrator’s legitimate interests in the form of communication with persons who have expressed a wish to participate in a given public event | Period necessary for informing about the organised event, however no longer than until you lodge an objection to the processing of personal data |
| Informing about the realisation of the Association’s statutory aims, including informing about organised social actions, as well as possibilities of supporting the Association’s activity | Art. 6(1)(f) GDPR – the Administrator’s legitimate interest consisting in maintaining permanent contact with the Association in connection with its statutory aims | Period necessary to achieve the purpose, however no longer than until you lodge an objection to the processing of personal data for this purpose, and after that time they may be processed for the limitation period of possible claims (Art. 17(3)(e) GDPR) |
| Establishment, pursuit of claims and defence against claims, including documentation of lodged objections to the processing of personal data | Art. 6(1)(f) GDPR, Art. 17(3)(e) GDPR – legitimate interest of the Administrator in processing the data | Limitation period of possible claims arising from legal provisions |
5. If you receive free publications issued by the Association.
This concerns natural persons to whom the Institute makes available free scientific publications, books, reports, bulletins, brochures, analyses, positions issued by the Association.
| Purpose of processing personal data | Legal basis for processing personal data | Period of processing personal data |
|---|---|---|
| Realisation of an order for a publication, including delivery of it to the ordering party, contact in connection with the realisation of the order | Art. 6(1)(b) GDPR | Period necessary to achieve the purpose of processing personal data |
| Informing about the realisation of statutory aims, including informing about organised social actions, as well as possibilities of supporting the Association’s activity | Art. 6(1)(f) GDPR – the Administrator’s legitimate interest consisting in maintaining permanent contact with our Institute in connection with its statutory aims | Period necessary to achieve the purpose, however no longer than until you lodge an objection to the processing of personal data for this purpose, and after that time they may be processed for the limitation period of possible claims (Art. 17(3)(e) GDPR) |
| Pursuit of claims and defence against possible claims, which constitutes a legitimate interest of the Administrator in processing the data | Art. 6(1)(f) GDPR, Art. 17(3)(e) GDPR | Limitation period of possible claims arising from legal provisions |
6. If you support the Association’s activity with donations
This concerns natural persons making donation payments directly to the Association’s bank account indicated on the websites www.marszniepodleglosci.pl, via online fundraising portals (such as zrzutka.pl) or via and with the use of the payment system: tpay.pl.
| Purpose of processing personal data | Legal basis for processing personal data | Period of processing personal data |
|---|---|---|
| Management of payments from donors, including issuing certificates for tax purposes | Art. 6(1)(b) GDPR | Period of realisation of the donation, including issuance of a certificate allowing deduction of the amount of the transferred donation in the PIT settlement |
| Contacting donors by traditional or electronic mail in order to reply to their enquiries or applications, as well as in order to send thanks for the support | Art. 6(1)(f) GDPR | Period necessary to reply to the donor’s enquiries or application or to send him thanks for the support |
| Keeping accounting books and tax documentation | Art. 6(1)(c) GDPR in connection with Art. 74(2) of the Accounting Act and other specific provisions | Period of storage of accounting and tax documentation arising from legal provisions |
| Informing about the realisation of the Association’s statutory aims, including informing about organised social actions and the possibility of further support for the Association | Art. 6(1)(f) GDPR, which constitutes the Administrator’s legitimate interest consisting in maintaining permanent contact with the Association in connection with its statutory aims | Period necessary to achieve the purpose, however no longer than until an objection to the processing of personal data for this purpose is lodged, and after that time your personal data may be processed for the limitation period of possible claims (Art. 17(3)(e) GDPR) |
| Pursuit of claims and defence against claims arising from a concluded agreement, which constitutes a legitimate interest of the Administrator in processing the data | Art. 6(1)(f) GDPR, Art. 17(3)(e) GDPR | Limitation period of possible claims arising from legal provisions |
If you use the Association’s websites.
For your convenience the websites run by the Association use cookies for the following purposes:
- to adapt the service to the needs of users such as e.g. remembering the preferred language or font size,
- for statistical purposes through anonymous analysis of the behaviour of website users,
- to understand the actions, behaviour and interests of visitors to our websites,
- to recognise new or former users,
- to improve our website and better recognise your visits on our platforms,
- to integrate with social media services,
- to facilitate the use of the basic functions of the website,
- for the handling of targeted advertising.
The website sometimes uses internet services of third parties to display certain content, for example images or videos. The Association is not able to prevent these sites or domains from collecting information concerning the manner of use of the content placed there by our users. In order to become acquainted with the manner of use by them of the obtained information about users and the possibilities of opting out of the relevant cookies or deleting such data, the terms of use of those sites in the scope of the privacy policy and cookies conducted should be read.
If you have become involved in volunteer activity connected with the organisation of the Independence March.
This concerns natural persons who have expressed a wish to become involved as volunteers in connection with the organisation of the Independence March. These data have been collected via a form on the website marszniepodleglosci.pl or other channels directly to the Association. In this scope information about age, skills or specialist knowledge is also processed, which makes it possible to use your involvement in the appropriate areas.
| Purpose of processing personal data | Legal basis for processing personal data | Period of processing personal data |
|---|---|---|
| Management of payments from donors, including issuing certificates for tax purposes | Art. 6(1)(b) GDPR | Period of realisation of the donation, including issuance of a certificate allowing deduction of the amount of the transferred donation in the PIT settlement |
| Contacting donors by traditional or electronic mail in order to reply to their enquiries or applications, as well as in order to send thanks for the support | Art. 6(1)(f) GDPR | Period necessary to reply to the donor’s enquiries or application or to send him thanks for the support |
| Keeping accounting books and tax documentation | Art. 6(1)(c) GDPR in connection with Art. 74(2) of the Accounting Act and other specific provisions | Period of storage of accounting and tax documentation arising from legal provisions |
| Informing about the realisation of the Association’s statutory aims, including informing about organised social actions and the possibility of further support for the Association | Art. 6(1)(f) GDPR, which constitutes the Administrator’s legitimate interest consisting in maintaining permanent contact with the Association in connection with its statutory aims | Period necessary to achieve the purpose, however no longer than until an objection to the processing of personal data for this purpose is lodged, and after that time your personal data may be processed for the limitation period of possible claims (Art. 17(3)(e) GDPR) |
| Pursuit of claims and defence against claims arising from a concluded agreement, which constitutes a legitimate interest of the Administrator in processing the data | Art. 6(1)(f) GDPR, Art. 17(3)(e) GDPR | Limitation period of possible claims arising from legal provisions |
V. RIGHTS ACCRUING TO YOU IN CONNECTION WITH THE PROCESSING OF DATA BY THE ASSOCIATION
In connection with the processing by the Association of your personal data you are entitled to:
1. the right of access to your personal data on the basis of Art. 15 GDPR;
2. the right to rectification of your personal data on the basis of Art. 16 GDPR;
3. the right to request erasure of data in the cases specified in Art. 17(1) GDPR (subject to the exceptions specified in the provision of Art. 17(3) GDPR), in particular in the case of your exercise of the following rights:
- The right to withdraw consent – in the case of processing of personal data by the Association on the basis of consent – natural persons have the right at any time to withdraw their consent, without affecting the lawfulness of processing based on consent before its withdrawal. It should however be remembered that the Association does not process personal data on the basis of consent, since it usually acts on the basis of other legal bases contained in Art. 6 GDPR and specified in point IV of this Policy. Fulfilment of any of the legal bases specified in Art. 6 GDPR is sufficient for the Association to be able to process your data;
- The right to lodge an objection – in the case of processing of your personal data on the basis of a legitimate interest realised by the Association (e.g. in the case of informing about the realisation of the Association’s statutory aims, sending invitations to public events organised by the Association, sending thanks to donors for support). In such a case the Association will no longer process the personal data or will restrict the processing, unless it demonstrates the existence of compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or grounds for the establishment, exercise or defence of the Association’s claims;
4. the right to request restriction of processing of data in the cases specified in Art. 18 GDPR;
5. the right to data portability in the cases specified in the provisions of Art. 20 GDPR.
If you wish to exercise any of these rights, the Association enables contact via the e-mail address: [email protected] or by post: Independence March Association, ul. Stawki 4B/U1, 00-193 Warsaw.
In the event that you consider that the processing of your personal data violates the provisions on the protection of personal data, you also have the right to lodge a complaint with the President of the Personal Data Protection Office.
VI. TAKING AUTOMATED DECISIONS CONCERNING YOUR PERSONAL DATA
Your data may be processed by the Association in an automated manner, including also in the form of profiling. However, decisions concerning an individual person connected with this processing will not be automated.
VII. MAKING YOUR PERSONAL DATA AVAILABLE TO THIRD PARTIES
The Association applies appropriate technical and organisational measures so that your personal data are secure, including securing personal data against unauthorised access, their loss or destruction. In order to ensure the security of your personal data, appropriate personnel, organisational, technical (IT) and physical safeguards have been implemented in the Association.
We transfer personal data to other entities only when the provisions allow us to do so. In such a case, in the agreement we provide for provisions and security mechanisms in order to protect the data and to maintain our standards in the scope of data protection, their confidentiality and security.
Access to your personal data may be held by:
- employees and co-workers of the Association authorised to process your personal data on the instruction of the Administrator;
- entities to which the Association has entrusted the processing of your personal data, including entities providing hosting, IT, printing, mailing, payment, legal, accounting and HR services for the Association.
The Association may transfer your personal data to countries outside the European Economic Area and to international organisations, which is connected with the scope of the activity conducted by the Association and the cooperation undertaken with various entities. The Association ensures that the data will be transferred to countries in respect of which the European Commission has issued decisions on the fulfilment by them of an adequate level of protection of personal data or with observance of all legal requirements, including on the basis of an appropriate agreement containing data protection clauses adopted by the European Commission, ensuring an appropriate manner of securing the transferred personal data.
VIII. CHANGES TO THIS PRIVACY POLICY
Having regard to the principle of transparency, the Association will regularly review and update the above Privacy Policy by publishing its new version on its website.
IX. GDPR
We inform you that your personal data are processed by the Independence March Association with its registered office in Warsaw at ul. Stawki 4B/U1, postal code 00-193 (data administrator) within the framework of maintaining permanent contact with the Association in connection with its statutory aims, in particular by informing about organised social actions. The legal basis for the processing of personal data is Art. 6(1)(f) 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 (GDPR). Provision of the data is voluntary; nevertheless without indicating them realisation of the newsletter service is not possible. We inform you that you have the right of access to the content of your personal data, their rectification, erasure or restriction of processing, the right to data portability, the right to lodge an objection to their processing, as well as the right to lodge a complaint with the supervisory authority. Use of the newsletter is for an indefinite period. At any time you have the right to lodge an objection to the processing of personal data. In such a case the data entered by you in the registration process will be erased immediately after the expiry of the limitation period of possible claims and rights provided for in the Civil Code. Access to your personal data may also be held by entities providing services for us, in particular hosting, IT, printing, mailing, payment, legal, accounting and HR services. The personal data provided may be processed in an automated manner, including also in the form of profiling. However, decisions concerning an individual person connected with this processing will not be automated. In the event of any requests, questions or doubts as to the processing of your personal data, please contact us via the e-mail address: [email protected] or by post: Independence March Association, ul. Stawki 4B/U1, 00-193 Warsaw.