*The sending of commercial information by electronic means (e.g. newsletter) is carried out only on the basis of the User’s prior consent.

4. COOKIES
   
   

   1. We use cookies to run our website. They may be read by our system and by the systems of our Trusted Partners whose services we use listed in point 4.2 below.

   2. Our Trusted Partners are: Facebook, Google, Stripe, Hubspot

   3. The Website may include links to external websites or websites of the Trusted Partners listed in point 4.2. above. When visiting an external website or a third-party website, the Users are subject to a separate privacy and data protection policy for a given website. The User should review the privacy and data protection policies of particular external and third-party websites.

   4. The Controller informs that they use cookies and similar technologies on the website to store information or gain access to the information stored on the telecommunications terminal device of the User through which they use the Website.

   5. There are two types of cookies used:

      1. session cookies which are deleted from the hard disk when a given browser session ends or when the computer is shut down

      2. persistent cookies which are stored in the memory of a computer or a mobile device until the User deletes them manually with appropriate tools available in the web browser or until they expire.

   6. We use cookies on our website to:

      1. provide services;

      2. ensure security, i.e. User authentication;

      3. adjust the presented website content to User preferences and optimise website use;

      4. carry out surveys;

      5. create statistics which help to understand how the Users use the Website, which enables us to co improve its structure and content;

      6. present personalised advertisements, among other things taking into account the interests or place of residence of the User;

      7. influence processes and effectiveness of website use;

      8. use the social media function.

   7. Storage of cookies or access to them by the Controller does not cause configuration changes to the telecommunications terminal device of the User and the software installed on it.

   8. The entities which place information in the form of cookies and other similar technologies on the User’s terminal device (e.g. on a computer, laptop, smartphone, Smart TV) and gain access to them are the Controller and the Trusted Partners listed in point 4.2.

   9. The Website may place cookies in the browser, if cookies are enabled in the browser. What is important, the browser gives the Website access only to the cookies placed by that website rather than to cookie files placed by other websites.

   10. Detailed information on the use of cookies can be found in a separate Cookie Policy available on the rsqholo.com website.
       
       

5. MANAGEMENT OF BROWSER SETTINGS
   
   

   1. Your web browser enables cookies on your device by default, so when first visiting our Website please give your consent to the use of cookies. If you consent to your software settings allowing for cookies, this will mean your consent to the Website using cookies, in the meaning of Article 173 clause 2 of the Act of 16 July 2004 Telecommunications Law. In such an event the Controller will have the right to use cookies and similar technologies to store information or gain access to the information stored on the telecommunications terminal device of the User. The above consent enables the Controller, as well as the advertising companies, research companies or suppliers of multimedia applications cooperating with the Controller to use cookies. However, if you do not want cookies to be used when you are browsing through the website, you may change the browser settings — completely block the automatic handling of cookies or request notification each time cookies are placed on the device. The settings may be changed any time.

   2. Disabling or limiting cookies may result in difficulties in using the website, e.g. in the form of the need to login on each subpage, the website taking longer to load, limitations in the use of functionalities, limitations in the website being liked on Facebook, etc.
      
      

6. RIGHT TO WITHDRAW THE CONSENT
   
   

   1. If personal data is processed on the basis of a consent, you may withdraw such a consent any time.

   2. In order to withdraw your consent, you should:

      1. send an e-mail directly to the Controller or to iod@rsqholo.com or

      2. delete a comment published under an article, or - delete a published opinion about the services.

   3. If your personal data was processed on the basis of a consent, we have the right to process your personal data by the time of its withdrawal. Withdrawal of the consent does not affect legal compliance of the processing carried out so far.
      
      

7. REQUIREMENT OF PROVISION OF PERSONAL DATA
   
   

   1. Provision of any personal data is voluntary and depends on your decision. However, in some cases providing specific personal data is necessary in order for us to meet your expectations in respect of service use.

   2. To order a service on the Website you need to provide your name and email address — without this we are not able to conclude and perform a contract.

   3. In order for us to be able to contact you by phone in matters related to service performance, you need to provide your telephone number — without this we are not able to call you.

   4. To be able to receive discounts for future services, you need to provide your name and e-mail address — without this we are not able to send you discount codes.
      
      

8. AUTOMATED DECISION-MAKING OR PROFILING

The Controller will not process your personal data in a manner which would involve taking only automated decisions with regard to you. Your data may be subject to profiling for statistical and marketing purposes.

9. RECIPIENTS OF PERSONAL DATA
   
   

   1. Your data may be provided to entities processing personal data at the request of the Controller, among other things IT service providers, marketing agencies and other entities with which the Controller concluded a data processing agreement – such data is processed solely in accordance with the Controller’s instructions.

   2. Your data may also be provided to entities entitled to receive it under applicable law, e.g. law enforcement agencies in case of a request from the agency on appropriate grounds.

   3. Regarding the processing of health-related data (e.g. in connection with diagnostic or preventive services), the legal basis for processing is Article 9(2)(h) of the GDPR – processing necessary for the purposes of preventive healthcare and medical diagnosis.

   4. In the case of transferring personal data outside the European Economic Area, the Controller applies appropriate legal safeguards, including standard contractual clauses approved by the European Commission or adequacy decisions confirming an adequate level of protection.
      
      

10. TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES
    
    

    1. In some cases your data may be transferred to recipients from outside of the European Economic Area, e.g. if this is required for provision of services to you or if this has other important legal grounds. Information about this is available as part of individual services.

    2. We will provide you with additional explanations with regard to provision of personal data any time, especially if this issue raises your concerns.

    3. You may receive a copy of personal data transferred to a third country any time.
       
       

11. PERIOD OF PROCESSING OF PERSONAL DATA
    
    

    1. According to applicable legal regulations, we are processing your personal data only for a period necessary to achieve the specified purpose. After this period your personal data will be irretrievably deleted or destroyed.

    2. By the time your data is permanently deleted or destroyed, if we do not need to carry out any operations on your personal data other than its storage, we will protect it by way of pseudonymisation. Pseudonymisation consists in encoding personal data or a personal data set in such a way that it cannot be read without an additional key, thus such information becomes completely useless to an unauthorised person.

    3. As far as particular personal data retention periods are concerned, please be informed that we process personal data for the period of:

       1. contract duration — in relation to personal data processed for the purpose of contract conclusion and performance;

       2. 20 years from the end of the calendar year during which the last entry was made with regard to personal data processed for the purpose of preventive medicine and medical diagnosis;

       3. 3 years or 10 years — in relation to personal data processed in order to establish, pursue or defend claims (the length of the period depends on whether or not both parties are entrepreneurs);

       4. 5 years — in relation to personal data related to the fulfillment of the obligations under tax law;

       5. by the time of withdrawal of the consent or achievement of the purpose of processing, but not longer than for 5 years – in relation to personal data processed on the basis of a consent;

       6. by the time of effective filing of an objection or achievement of the purpose of processing, but not longer than for 5 years — in relation to personal data processed on the basis of legitimate interests of the Personal Data Controller or for marketing purposes;

       7. by the time the data becomes outdated or is no longer needed, but not longer than for 3 years — in relation to personal data processed mainly for analytical purposes, use of cookies and website administration.

    4. The periods in years are calculated from the end of the year in which we started personal data processing to enhance the process of personal data deletion or destruction. Requests will be examined individually in the case of exercising the right to be forgotten.
       
       

12. RIGHTS OF THE DATA SUBJECT
    
    

    1. In relation to the Controller’s processing of your data you have the right to:

       1. request from the Controller access to your personal data,

       2. request from the Controller rectification and correction of your personal data,

       3. withdrawal of your consent at any time by sending an e-mail to the indicated address. The withdrawal of consent is binding on the Controller with respect to the data processed on the basis of that consent. The withdrawal does not affect the lawfulness of the processing carried out on the basis of the consent before its withdrawal;

       4. request from the Controller erasure of your personal data,

       5. request from the Controller restriction of processing of your personal data in the case and on the terms set out in Article 18 of the GDPR or data erasure pursuant to Article 17 of the GDPR,

       6. object to the processing of your personal data pursuant to Article 21 clause 1 of the GDPR,

       7. personal data portability pursuant to Article 20 of the GDPR,

       8. file a complaint with the supervisory authority (President of the Personal Data Protection Office).

    2. A complaint may be lodged with the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw, www.uodo.gov.pl).

    3. The rights listed in point 12.1. are not absolute, so in some cases we may refuse to observe them. A refusal to comply with a request will be preceded by a thorough analysis and will be made if necessary only.

    4. You may exercise your rights by sending an e-mail directly to the Controller or to iod@rsqholo.com
       
       

13. FINAL PROVISIONS
    
    

    1. Any matters not regulated by this Privacy Policy are governed by personal data protection regulations.

    2. We will inform you about any changes made to this Privacy Policy by email.

    3. The current version of the Privacy Policy is always available on the rsqholo.com website.

    4. This Privacy Policy comes into effect as of January 18, 2025.