PRIVACY POLICY

 

Dear User!

 

This Privacy Policy sets out the rules for the collection, processing and use of personal data obtained from you on the website www.caps-group.com, (hereinafter referred to as the ” Website “) by CAPS S. A. with its registered office in Poznań with taking into account the legislation in force, in particular the provisions 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).

 

  1. WHO PROCESSES YOUR DATA?

Administrator of your data is CAPS S. A. with its registered office in Poznań, Bułgarska 69/73, postal code 60-320 Poznan, entered into the register of entrepreneurs of the National Court Register kept by the District Court Poznań – Nowe Miasto and Wilda in Poznań, VIII Commercial Division of the National Court Register under the number 0000390799, tax ID: 7831676465, CRO certificate number: 301720017 (hereinafter referred to as ” We“).

Contact:

You can contact us by correspondence at the following address: CAPS SA, Bulgarska 69/73,

60-320 Poznan or by e-mail: info@caps-group.com .

  1. WHAT DATA DO WE COLLECT?

As part of the Website, we may ask you to provide us with data, including personal data. This is related, among other things, to your request to contact us and for our marketing activities. The data we collect include, where applicable, in particular:

  • contact details, including name and surname, e-mail address / telephone number,
  • data on your activity on the website, including click analysis,
  • device ID,
  • browser type, domain and language of communication, operating system and settings
    assigned to it,
  • country,
  • time zone,
  • visited websites,
  • personal and marketing preferences,
  • cookies and pixel tags,
  • IP addresses.

 

Other data may also be collected via the Website, including personal data in connection with the provision of forms on the Website (eg a contact form, a recruitment form related to providing the possibility of submitting application documents in the “Work” tab). Each time, we provide a dedicated separate information on the processing of personal data in the link under the form. We recommend that you read their content when using the forms.

 

 

  • SERVER LOGS

Using the Website is associated with each time sending a query to our server. Individual queries are saved in the server logs and stored there. The data contained in the logs include: your IP address, the time of the inquiry, the time of sending the answer, information about the browser and the User’s operating system. These data are not associated with specific people using our Website, they are also not used to identify Users in any way, they are used only for server administration purposes and, as a rule, the storage period is 30 days.

 

  • COOKIES

Our website collects data contained in cookies. Cookies are small text files sent by the Website and stored on your end device, containing certain information related to your use of the Website.

Cookies are used, among other things, to provide you with the opportunity to visit our Site, to display it correctly and to enable you to use all of its features.

In compliance with the consents you have given us, we may use cookies to personalize content and advertising on our Site (and other sites) and to analyze traffic on our Site. If applicable, we may also share information about your use of our Site with our advertising partners, who may combine it with other information that you have provided to them or that they have collected as a result of your use of their services.

By agreeing to marketing cookies, you consent to the sharing of your data with our advertising partners and you consent to the automated processing of your data to personalize content and ads on and off our Site.

In connection with the use of statistical and marketing tools on the Website provided by companies such as Google and LinkedIn, your consent to statistical and / or marketing cookies is tantamount to consent to the transfer of data to the United States, which is not subject to the decision of the European Commission stating the appropriate level of protection in line with European data protection legislation.

More detailed information on the individual tools used on our Website can be found further in the Privacy Policy.

Our Site may contain links to other websites or applications, including those of our business partners. Please note that third party websites may also use cookies. We have no influence on the websites of third parties and are not responsible for the cookies they collect or access. When clicking on a link or an application, please remember that each has its own cookie policy. For this reason, we ask that you read their privacy policies before using other websites or applications.

 

  • TYPES OF COOKIES

Depending on the time of storage on the end device, the cookies we use can be divided into:

 

  1. a) session cookies : stored on the User’s device and remain there until the end of the browser session. The saved information is then permanently deleted from the device’s memory;
  2. b) permanent cookies : they are stored on the User’s end device for the time specified in the cookie parameters or until they are deleted by the User.

 

We use the following types of cookies:

  1. necessary cookies , enabling the use of services available on our Website, e.g. security cookies, used to detect fraud in the field of authentication on our Website. Files of this category ensure the basic functionality of our Website, and their download depends on the use of services available on our Website, which means that their support is constantly enabled;
  2. functional cookies allow the website to remember information that changes the appearance or functioning of the website, e.g. the preferred language or the region in which the User is located;
  3. performance cookies are used to understand and analyze the Site’s KPIs, which helps to provide a better User experience for visitors.
  4. statistical cookies – used to analyze how Users use the Website;
  5. marketing cookies and third-party cookies – related to our use of marketing and remarketing tools , are used to provide visitors with relevant advertising and marketing campaigns. These cookies track Users across Sites and collect information to deliver tailored advertising.

 

  • MANAGING COOKIES IN THE BROWSER

In many cases, the software used for browsing websites allows cookies to be stored on the User’s device by default, giving the User the ability to manage the settings and delete cookies according to their preferences.

You can check and change your settings for our Website at any time – the tool that allows you to manage your preferences regarding the installation of cookies can be found in the footer of our Website under the heading “Cookie settings”.

In order to delete cookies stored on your computer, follow the instructions provided by the manufacturer of your browser in the help tab for managing cookies in their products.

 

  1. PURPOSES FOR WHICH WE COLLECT YOUR PERSONAL DATA AND LEGAL BASIS

As part of our Website, we process your data (depending on the service / circumstances) for the following purposes:

  • analyzing and managing your activity on the Website in order to adapt the services and content to your individual preferences – as appropriate, based on your consent [art. 6 par. 1 (a)] or on the basis of our legitimate interest [Art. 6 par. 1 (f) GDPR], taking into account the consents expressed for the use of individual types of cookies;
  • handling inquiries and notifications that you address to us, including sending via e-mail relevant information regarding our products and services in accordance with the content of the inquiry – based on our legitimate interest [art. 6 par. 1 (f) GDPR];
  • contacting you, in particular for purposes related to the provision of services and handling your inquiry – based on our legitimate interest [art. 6 par. 1 (f) GDPR];
  • analyzing website traffic for the purpose of conducting research and analysis in order to improve the operation of available services – based on our legitimate interest [art. 6 par. 1 (f) GDPR], taking into account the consents expressed for the use of individual types of cookies;
  • monitoring traffic on the Website in terms of information regarding the interest in our Website, including which companies and organizations visit our Pages – based on our legitimate interest [art. 6 par. 1 (f) GDPR], taking into account the consents expressed for the use of individual types of cookies;
  • compiling general statistics on the use of the Website by you and other Users, including the collection of general demographic information (e.g. about the region from which the connection is made) – based on our legitimate interest [art. 6 par. 1 (f) GDPR], taking into account the consents expressed for the use of individual types of cookies;
  • performing technical activities and solving technical problems related to the administration of the Website – based on our legitimate interest [art. 6 par. 1 (f) GDPR];
  • ensuring the security and integrity of the services that we provide you electronically, including counteracting fraud and abuse and ensuring traffic safety – based on our legitimate interest [art. 6 par. 1 (f) GDPR];
  • storing data to ensure accountability (including demonstrating compliance with our obligations under the law) – based on our legitimate interest [art. 6 par. 1 (f) GDPR];
  • establishing, protecting and pursuing possible claims – based on our legitimate interest [art. 6 par. 1 (f) GDPR];
  • data storage for archival purposes – based on our legitimate interest [art. 6 par. 1 (f) GDPR];
  • conducting court, arbitration and mediation proceedings – based on our legitimate interest [art. 6 par. 1 (f) GDPR].

 

If you use the contact form and forms related to the provision of application documents in the “Work” tab, available on our Website – detailed information on the purposes and legal basics for processing personal data can be found in the dedicated information provided under each form.

 

  1. TOOLS WE USE

In order to optimally use the information contained, among others, in cookies, we use analytical tools and tools that enable us to manage advertising and marketing of our products, including by displaying targeted advertising based on the recognition of the User’s device.

These tools also allow us to process the collected information in such a way that supports our research and development works and supports our marketing activities.

According to the consents you have given us, your personal data (collected, among others, by means of cookies) may be processed in an automated manner (including in the form of profiling), and based on the collected information (e.g. data on your preferences), we can customize the content presented on our Website and beyond it, including advertising content.

Within the limits of the consents you have given us, with the help of the tools used, we may also share information about the use of our Website with our advertising partners, who may combine it with other information that you have provided to them or that they have collected as a result of your use of their services.

 

  • GOOGLE ANALYTICS, GOOGLE ADS, GOOGLE TAG MANAGER

Using GoogleAds marketing tools and Google Analytics analytical tools in conjunction with additional Google services, such as Google Tag Manager, we process data related to your activity on our Website, including online identifiers, in order to provide you with personalized ads based on profiling or to monitor your choices using statistical and marketing cookies. We only undertake our activities with the use of these tools within the limits of your consent to the use of individual types of cookies, including consents regarding automated decision-making and the transfer of data to advertising partners . You can check / change your consent settings at any time – the tool that allows you to manage your preferences regarding the installation of cookies can be found in the footer of our Website under the heading “manage consent”.

 

  • GOOGLE ANALYTICS : Google Analytics allows us to generate detailed statistics on how Users use our Website. Thanks to the tools provided by Google, your IP address is anonymized.

In accordance with the terms of the Google Analytics service, Google declares that it will not associate the IP address of the data subject with other data held by Google.

To opt out of Google Analytics cookies, you can also download and install the opt-out browser add-on for Google Analytics. Add-on :  https://support.google.com/analytics/answer/181881?hl=pl .

  • GOOGLE ADS: is an advertising system from Google that enables, where appropriate, advertising to be displayed on the Google advertising network. More information on data processing by Google can be found in the privacy policy:

https://www.google.com/policies/privacy/ .

 

In connection with our use of tools provided by Google, your personal data may be transferred to the United States. The USA is not subject to an adequacy decision by the European Commission under European data protection legislation. The transfer of data to the USA involves the risk of possible access to the entrusted data in connection with programs enabling American public authorities to access personal data transferred from the European Union to the United States for national security purposes, resulting in restrictions on the protection of personal data that are not limited to a way that meets the requirements substantially equivalent to the requirements of EU law. These laws do not grant data subjects rights that may be enforceable against US authorities in the courts. The legal basis for the transfer of personal data to the USA is in this case the consent given by you when entering our Website. You can withdraw your consent at any time – the tool that allows you to manage your preferences regarding the installation of cookies can be found in the footer of our Website under the heading “manage consent”.

 

  • YOUTUBE VIDEOS ON OUR SITE

We place YouTube videos on our Website in an extended privacy mode – without the use of cookies that track User behavior data. This means that activity information will not be collected by YouTube in order to personalize the way you view it, and the content that will be displayed with the extended privacy mode enabled will not affect your browsing on YouTube.

 

In connection with our use of tools provided by Google (YouTube API Services), your personal data may be transferred to the United States. The USA is not subject to an adequacy decision by the European Commission under European data protection legislation. The transfer of data to the USA involves the risk of possible access to the entrusted data in connection with programs enabling American public authorities to access personal data transferred from the European Union to the United States for national security purposes, resulting in restrictions on the protection of personal data that are not limited to a way that meets the requirements substantially equivalent to the requirements of EU law. These laws do not grant data subjects rights that may be enforceable against US authorities in the courts. The legal basis for the transfer of personal data to the USA is in this case your consent to the appropriate cookies when entering our Website. You can withdraw your consent at any time – the tool that allows you to manage your preferences regarding the installation of cookies can be found in the footer of our Website under the heading “manage consent”.

More information on data processing by Google can be found in the privacy policy: https://www.google.com/policies/privacy/ .

 

  • LINKEDIN ADS

We use advertising tools provided by LinkedIn both within and outside the LinkedIn environment, including those enabling us to run our advertising and remarketing campaigns . We use tools to match the recipients of our marketing activities ( Matched Audiences ) and Lead Gen Forms . We also collect information regarding conversion tracking and demographic data about the use of our Site. That tools enable us to track and retargeting on various Users’ devices with the use of automated decision-making based on profiling. All our activities take place only within the limits of the consent given by the User to the use of individual types of cookies, taking into account the consents, preferences and settings of the User’s account on LinkedIn (LinkedIn Members can control the use of their personal data for advertising purposes in their account settings).

 

We carry out the above-mentioned activities in order to conduct marketing and analytical activities based on data such as: IP address anonymized by LinkedIn; device identifiers, browser type, domain and language of communication, operating system and settings assigned to it, URL, country, time zone, pseudonyms, names and surnames, e-mail addresses, other contact details, company details, position data, any other data provided to us by the User in the forms (eg Lead Gen Form).

 

The legal basis for the processing of personal data in connection with the activities in question is the consent expressed by the User through the settings for consents to the use of individual cookies. You can withdraw your consent at any time – the tool that allows you to manage your preferences regarding the installation of cookies can be found in the footer of our Website under the heading “manage consent”. The processing of personal data sent to us by users as part of LinkedIn forms will be based on the legal grounds indicated in the information clauses dedicated to individual forms.

 

As part of the activities in question, depending on the service used, we provide LinkedIn personal data or entrust it for processing on the basis of a data processing agreement.

 

LinkedIn Ireland also provides us with statistics that help us to better understand the types of actions Users are taking on our profile and our Site (” Site Statistics “). LinkedIn Ireland compiles aggregated Site Stats without revealing your details (please note that, as a site administrator, we may be able to associate your profile picture with page likes in the statistics if you like our profile and set the profile to be publicly visible). CAPS Group together with LinkedIn Ireland Unlimited Company acts as joint controllers in the field of data processing for the purposes of statistics. More on data processing for the purposes of website statistics can be found at the link:

https://legal.linkedin.com/pages-joint-controller-addendum .

 

In connection with our use of the tools provided by LinkedIn, your personal data may be transferred to the United States. The USA is not subject to an adequacy decision by the European Commission under European data protection legislation. The transfer of data to the USA involves the risk of possible access to the entrusted data in connection with programs enabling American public authorities to access personal data transferred from the European Union to the United States for national security purposes, resulting in restrictions on the protection of personal data that are not limited to a way that meets the requirements substantially equivalent to the requirements of EU law. These laws do not grant data subjects rights that may be enforceable against US authorities in the courts. The legal basis for the transfer of personal data to the USA is in this case the consent expressed by you when entering our Website in the consent settings for the use of individual types of cookies. You can withdraw your consent at any time – the tool that allows you to manage your preferences regarding the installation of cookies can be found in the footer of our Website under the heading “manage consent”.

 

  • BAZO AND LEAD FORENSIC TOOLS

Thanks to the use of this type of tools, only within the limits of your consent and settings regarding the use of cookies, we can monitor the traffic on our Website in terms of information regarding the interest in our Website, including which companies and organizations visit our Pages. These technologies work by tracking the IP address and combining it with relevant databases. The data that we receive thanks to this are, among others: company name, registered office address, website address, other organization data as well as information related to the use of our Website. These data are generally limited to data on business entities and allow us to obtain knowledge about potential customers and measure the level of interest in our Website and our offer, on the basis of which we can adjust both our activities and our services.

 

In connection with the use of tools provided by LEAD FORENSIC based in Great Britain – data in the form of the IP address of the Users of our Website, depending on the consent granted regarding the installation of cookies, may be transferred to the United Kingdom, the legal basis for the transfer of data will be an executive decision stating an adequate level of personal data protection in Great Britain, i.e. decision no. C (2021) 4800 final , issued on the basis of Regulation (EU) 2016/679 (GDPR).

 

  1. TECHNICAL MEASURES

We make every effort to secure your data and protect it against the actions of third parties. We use all necessary security measures for servers, connections and the Website. In particular, communication between your computer and our server when we collect your personal data is encrypted using the SSL protocol (Secure Socket Layer

). In addition, our databases are protected against access by third parties.

 

In the case of using the services of subcontractors – we carefully verify their credibility and the security measures they apply in order to protect the data of the Users of our Website.

 

  1. RECIPIENTS OF YOUR DATA

Where applicable, we will provide data:

  • persons authorized by us, our employees and associates who must have access to the data in order to perform their duties,
  • processing entities to whom we commission this task, e.g. companies dealing with the operation of our ICT systems or providing us with ICT tools and server space, companies providing consulting and marketing services to us, suppliers of analytical tools,
  • other entities that will process personal data as an independent data administrator: e.g. business partners as part of the marketing and remarketing tools used on the Website ,
  • public entities, if it results from an obligation imposed by law.

 

  1. STORAGE PERIOD OF YOUR DATA

We are entitled to process the personal data that we process based on your consent until your consent is revoked or until the processing of your personal data is no longer necessary to achieve the purpose for which the data is processed, and when the given purpose of processing will be achieved and completed.

In the case of answering your inquiries, your personal data will be processed by us until the answer to your question is provided. After answering the question, your data may be stored by us, but only for a period of time corresponding to the period of limitation of claims that may be raised against us and which we may be entitled to against you.

We will process the data that we process on the basis of our legitimate interest until you make a possible objection, or until the processing of your personal data is no longer necessary to achieve the purpose for which the data is processed, and when the given purpose of processing is achieved and finished.

 

Data from the Website server logs are stored, as a rule, for a period of 30 days and after that time they are deleted.

 

  1. YOUR RIGHTS

In connection with the processing of your personal data, you have the following rights, within the limits specified by law and where applicable:

  1. access to the content of your data and rectification, deletion or limitation of processing and transfer of your data,
  2. in situations where we process your data on the basis of your consent, you have the right to withdraw it at any time, but this will not affect the lawfulness of processing based on your consent before its withdrawal,
  3. object at any time to the processing of personal data based on our legitimate interest for reasons related to your particular situation,
  4. to lodge a complaint with the President of the Data Protection Office, if you believe that the processing of your personal data violates the provisions of the GDPR.

Profiling of personal data in order to present them tailored to your preferences takes place only on the basis of your express consent. Providing your data is voluntary, but failure to do so may result in the inability to use some of the services of our Website, including contacting us via the forms available on the Website.

 

  1. CHANGES TO OUR PRIVACY POLICY

Our goal is to ensure the highest possible protection of your data. Due to the development of technology and our Website, the Privacy Policy may be changed.