Privacy Policy

§1 | General Provisions

1. This Privacy Policy (hereinafter referred to as the “Policy”) provides information
   on personal data processing by eDev Studio Sp. z o.o. with its
   registered office in Olsztyn, including personal data of our Clients and
   Clients’ representatives. In particular, the Policy provides information on:
   • the entity that is the controller of your data;
   • the purpose and grounds for the processing of your data;
   • who we share your data with;
   • the retention period for which your data are stored;
   • the rights that can be exercised by the data subjects.
2. We make every effort to ensure full security of personal data processing and meet
   all other obligations resulting from the provisions on personal data protection,
   including in particular the 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 – GDPR).
3. In the Policy, the term “Personal Data” shall mean information about a
   natural person who can be identified, directly or indirectly, in particular by
   reference to an identifier such as a name and surname, an
   identification number, location data or an
   online identifier. Personal data also refer to one or more factors specific to the
   physical, physiological, genetic, mental, economic, cultural or social identity
   of that natural person.

§2 | Personal Data Controller

1. The Controller of your personal data is
   eDev Studio Sp. z o.o. with its registered office in
   Olsztyn, ul. Władysława Trylińskiego 2, 10-683 Olsztyn, Poland, entered
   in the register of entrepreneurs of the National Court Register
   maintained by the District Court in Olsztyn, 8th Commercial Division
   of the National Court Register under the number
   KRS: 0000722653, hereinafter referred to as the
   “Personal Data Controller”, the
   “Company” or “we”.
   In its communications, the Company uses the trade marks
   EDS CONTROLLERS and Ambity Line, as
   well as the communication channels associated with them (including
   the website and electronic mail), through which the Company may also
   collect personal data.
2. In all matters relating to personal data protection, you may contact
   our Data Protection Officer at:
   admin@edev-studio.com.
   You may of course choose to contact us otherwise; however, then it
   may take us longer to respond or take appropriate steps. If you use
   other forms of communicating with us in matters relating to personal
   data management, you should ensure that the message is properly
   identified so that we can forward it to a competent person dealing
   with such matters.

§3 | The purpose of grounds for and period of personal data processing

1. Your personal data are only processed for specific, explicit and legitimate purposes.
2. The purpose of data processing is the reason for which we process your personal data.
   If we intend to process your personal data for other purposes that are not indicated below, you will be
   informed separately.
3. The purposes for which we process your personal data include:
   1. Preparation of an offer:
      • we will process the personal data in order to handle your inquiry concerning our offer and potentially
        agree detailed terms of cooperation, prepare and submit the offer,
      • replying to your inquiries as a potential Client and engaging in talks or correspondence relating to
        future cooperation is our legitimate interest that justifies the processing of data
        under Article 6.1(f) of the GDPR (such grounds will be hereinafter referred to as: our legitimate interest).
        Your personal data may be also processed in order to conclude an agreement between us; in this case the
        processing will take place on the grounds provided for in Article 6.1(b) of the GDPR,
      • data processing duration: personal data will be stored for 12 months
        of sending an inquiry, unless steps are taken to conclude an agreement. In this case the data will
        processed in accordance with the rules of processing personal data of the Company Clients or the
        processing of personal data of representatives of the Company Clients,
      • Personal data in your Customer Account (an individual account you can create for
        placing orders via the website) is stored for as long as the account is active. You can update or
        delete this data at any time.
   2. Conclusion, proper performance, termination of agreements or execution of orders
      (in the case of Company Clients):
      • personal data will be processed in order to conclude an agreement, prepare for its conclusion,
        perform an agreement/execution of an order, provide service support, handle complaints, terminate
        an agreement, archive and perform other legal acts relating to an agreement,
      • legal grounds:
        • Article 6.1(b) of the GDPR – data necessary for performance of an agreement or taking steps
          leading to its conclusion,
        • Article 6.1(a) of the GDPR – consent granted on a voluntary basis,
        • Article 6.1(f) of the GDPR – for establishment, exercise and defence of civil law claims
          and protection against inspections by fiscal authorities (our legitimate interest),
      • data processing duration: for the period of Agreement performance and after its
        termination – until expiry of legal archiving obligations, limitation periods of mutual claims
        or tax liabilities (whichever occurs later).
   3. Meeting legal obligations (accounting and tax):
      • we process personal data to fulfill obligations under applicable law, in particular accounting
        and tax regulations,
      • legal grounds: Article 6.1(c) of the GDPR,
      • data processing duration: until the Company fulfills its legal obligations.
   4. Establishment, exercise or defence of claims:
      • personal data will be processed to establish, exercise and defend the Company and third-party claims,
      • legal grounds: Article 6.1(f) of the GDPR,
      • data processing duration: up to 10 years or until an objection
        is submitted; in case of disputes – from final completion of proceedings.
   5. Use of Company websites:
      • personal data is processed to enable communication and provision of services,
      • legal grounds: Article 6.1(b) or 6.1(f) of the GDPR,
      • data processing duration: during communication/service provision or until objection,
        or after agreement termination for up to 10 years to secure claims.
   6. Marketing of Company products and services:
      • personal data is processed for marketing and sending commercial information (post, electronic or
        telephone),
      • legal grounds: Article 6.1(f) of the GDPR,
      • data processing duration: until an objection is submitted or expiry of agreements.
   7. Processing based on consent:
      • personal data is processed within the scope specified in granted consent (e.g. partner marketing),
      • legal grounds: Article 6.1(a) of the GDPR,
      • data processing duration: until consent is withdrawn.
   8. Other legitimate interests:
      • processing necessary for evidence, protection of claims and other legitimate interests,
      • legal grounds: Article 6.1(f) of the GDPR,
      • data processing duration: up to 10 years or until objection;
        extended in case of court proceedings.
4. We obtain personal data:
   • directly from you (orders, contact forms, e-mail, phone),
   • indirectly from systems and tools during website use,
   • from public sources (KRS, CEIDG, your website).
5. Depending on relations, we may process:
   • personal identity data,
   • contact details,
   • identification data (e.g. PESEL, IP),
   • contract details,
   • transaction data,
   • publicly available data,
   • audio-visual data,
   • website activity data.

§4 | The requirement of personal data provision

1. The provision of personal data is voluntary and you do it at your
   own discretion, but it is a condition of the conclusion or performance of the Agreement.
2. If you do not provide us with your personal data, we will not be able to conduct the activities that we
   are expected to conduct, such as contact you in order to prepare and present an offer,
   carry out a commercial transaction, undertake activities relating to
   order execution, after-sales support, including the provision of
   service and warranty support.

§5 | Automated decision making and profiling

We do not use your personal data for any decisions made
automatically or on the basis of profiling.

§6 | Recipients of personal data

1. We need your personal data both for activities carried out by us and for activities
   performed in cooperation with or by other entities.
2. Within the Company’s organizational structure, access to your personal data is granted
   only to authorized employees and only to the necessary extent.
3. In certain situations, your personal data may be disclosed to recipients outside the Company.
   In such cases, we always carefully verify the legal grounds for data disclosure.
4. The recipients of your personal data may include:
   • Banks and financial institutions – e.g. entities acting as agents in the execution of transfers,
   • Economic information offices – e.g. National Debt Register (KRD), ERiF Biuro Informacji
     Gospodarczej S.A.,
   • Service providers entrusted with data processing – e.g. courier service providers,
   • Authorized distributors of the Company’s products,
   • Telecommunications and postal service providers,
   • Accounting and HR service providers – e.g. accounting firms,
   • Advisory and audit firms,
   • Legal and debt collection entities – e.g. law firms,
   • Entities to whom we have obtained your consent to share your data,
   • Public authorities and entities authorized by law to receive personal data.

§7 | Transfer of personal data to third countries or international organizations

The Company does not transfer personal data to third countries
or international organizations, nor does it use any
external technical data storage resources located outside the
European Union or the European Economic Area.

§8 | Your rights

1. You have the right of access to your personal data, including the right to obtain a
   copy, rectification and erasure of your data and
   restriction of processing.
2. If you are entitled to additional rights (e.g. the right to data portability or the
   right to object to processing), you will find information on this in the relevant
   information clause above.
3. You have the right to object to processing of your personal data if they are processed
   to fulfil the legitimate interests of the Company. At the same time we wish to inform you
   that in accordance with the law we can refuse to accept the objection if we prove that
   there are legal grounds for processing that prevail over your interests, rights and freedoms or there are
   grounds to establish, exercise or defend claims. The above right of refusal shall not apply
   to objections submitted when your personal data are processed for marketing purposes.
   In this case, after receipt of an objection, we will cease to process your personal data for this purpose.
   In addition, objection to data processing for marketing purposes does not have to be justified.
4. You have the right to receive your personal data from the Company in a structured format
   and to have your personal data transmitted to another controller. If the data are
   transferred, on the basis of other legal regulations, the need may arise to obtain your consent
   or the consent of another person or to meet other conditions resulting from such regulations.
5. If the processing takes place on the basis of the consent granted, you have the right to
   withdraw at any time the consent for individual purposes of processing. The withdrawal of
   consent shall not affect the lawfulness of processing based on consent before its withdrawal.
6. The above-mentioned rights may be limited or conditional by law, therefore in certain
   situations, we may lawfully refuse to comply with them. Each refusal is preceded by
   a careful analysis and assessment of the given case.

§9 | The right to lodge a complaint

If you believe that the processing of your personal data is inconsistent with
applicable law, you can lodge a complaint with the
President of the Office for Personal Data Protection
(website where you can find contact details: https://uodo.gov.pl/p/kontakt).