Date of the last revision: 16th of November 2024 r.
TABLE OF CONTENTS
5. PROCESSING PERSONAL DATA BY DBC1
6. WHO WE MAY TRANSFER YOUR PERSONAL DATA
7. RIGHTS OF PERSONS WHOSE DATA IS PROCESSED BY DBC1
APPENDIX NO. 1 - data processing agreement
The Policy has been developed based on the provisions of the GDPR. The Controller of the Personal Data collected through the Website and the Tool, other DBC1 service or when you contact us directly or we contact with you is:
Mok Yok Group sp. z o.o. registered in Wroclaw, postal code no. 50-125, Św. Mikołaja 8-11, entered into the Register of Entrepreneurs managed by the District Court for Wroclaw-Fabryczna in Wroclaw, VI Commercial Division of the National Court Register, under Registry no. 0000503224, with share capital of 5.200,00 PLN, State Register of Entities of National Economy (REGON): 022383863, Tax Identification Number (NIP): 8971797577
(hereinafter: DBC1).
DBC1 is a company that is committed to providing an appropriate level of privacy protection for users of the Website and the Tool. We believe that this Policy will fully explain to you how the processing and protection of Personal Data works in our company. The data processing policy applicable at DBC1 has been established on the legal basis of GDPR and best practices. By familiarizing yourself with the Policy, you will know what actions we take in respect of Personal Data. These actions are intended to ensure security and fulfillment of obligations incumbent on DBC1 as a data Controller.
You should read this Policy before contacting us, using the Website, the Tool or our other services. Please be advised that if you use our Website, the Tool or other services, this means that you accept the Policy. However, if after reviewing the Policy, you find it to be unacceptable, you may not continue to use our Website the Tool or other services.
If you have any questions or concerns regarding this Policy, you may contact us. Contact information is located in the Contact DBC1 section.
If you are using the Tool, you acknowledge that personal data is processed along with Privacy Policy and Data Processing Agreement as established in Appendix no. 1 to this Privacy Policy.
Personal Data – information about an identified or identifiable natural person, defined in accordance with the GDPR and Polish regulations on the protection of personal data, e.g. name, surname, identification number, factor determining mental or physiological identity, IP address.
Policy – this document.
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.
Website – a website available at https://www.DBC1.com/, with an SSL certificate installed, which, by encrypting data, secures your Personal Data and their transmission.
the Tool - a service that manages Google Workspace Gmail Signatures (terms are available under the link https://DBC1.com/terms-of-service)
User – a person who uses the Website, the Tool or the other DBC1 services, depending on the context in which the word “User” was used.
The Website uses cookies or similar technologies in order to provide you with services of the highest quality.
Files of cookies (so-called "cookies") are IT data, in particular text files, which are stored in the end device of the Website User and are intended for use on websites. Cookies usually contain the name of the website they come from, the time they are stored on the end device and a unique number.
When you visit the Website, cookies and similar technologies can be used for the following purposes:
The Website uses two basic types of cookies:
The web browsers usually allow the storage of cookies on the User's end device by default. Website Users can change their settings in this regard. The web browser allows deleting cookies. It is also possible to block cookies automatically. Detailed information on this subject can be found in help or documentation of the web browser used. For your convenience we present below sample information on managing cookies for the most popular web browsers:
However, changes in the settings of cookies can affect the operation of the website you are viewing. Cookies do not change the configuration of the device you are using. They make it easier to adapt the browsed content to your expectations and preferences, e.g. language version, proper display of a page on a device, interests or individual needs. Cookies used for authentication enable e.g. easy form filling or logging in.
DBC1 is the provider who places and accesses cookies on the Website User's end device. Cookies placed on the User's end device or other similar technologies can also be used by partners cooperating with us.
Please be informed that information about certain User behaviour is subject to logging in the server layer of our hosting operator. This data is used by us solely for the purpose of administering the Website and to ensure the most efficient operation of the hosting services provided. Viewed resources are identified by URLs. In addition , the following can be recorded:
Information about our hosting provider's privacy policy can be found HERE.
Importantly, the above data is not associated with specific visitors and is only used for server administration purposes.
The Website collects information voluntarily provided by the User through forms available on the Website. Please note that the Website may also record information about your connection parameters (time stamp, IP address). The data provided on the form may constitute a collection of potential clients of DBC1. The data provided on the form is processed for a purpose stemming from the function of the specific form, e.g., to process a request or to conduct a business contact.
Social media
Social media are one of the main channels of contact with our customers and potential customers. Through them we provide up-to-date information about our activities, services, promotions, news about our services and create a place for common exchange of ideas.
Therefore, on the basis of legitimate interests, we process Personal Data of people who use our websites on social networking sites (e.g., to respond to comments and inquiries) and data that we access if you use the social networking plug-in available on our Website (in terms of statistics purposes our Website).
The processing of Personal Data on social networking is subject to the privacy rules of the respective social media provider. Therefore, we encourage you to read the rules of the social media providers we use to maintain our social media profiles:
If you use our profiles on social media, DBC1 also acts as a Controller of Personal Data. This data is processed by us on the terms of the Policy.
Please be advised that, in terms of the processing of Personal Data in connection with your use of the social plugins available on our Website, i.e. for the purpose of so-called web tracking (if applicable), DBC1 and the social media provider act as joint controllers of the Personal Data in accordance with Article 26 of the GDPR. Web tracking also takes place if you use the plugin as a not logged in social media user.
Web tracking consists in creating aggregate statistics based on events recorded by social media providers while users use the website. You must know that these events are logged by the social network providers without the participation of DBC1. Information regarding the processing of Personal Data by the social network provider, contact data and information regarding the right to object can be found in social media providers privacy documents indicated above.
Plugins
On our Website we also use:
Using Google Analytics software, our Website places a counting code on your computer to collect data about you. Please be advised that we are party to an agreement with service provider and we use a mechanism to anonymize the User's IP number. The user may at any time object to the collection of data by the Google Analytics software by changing the web browser settings.
Provider: Provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA, United States) and for users in the European Union, European Economic Area and Switzerland - Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (the provider for your location should be mentioned in Privacy policy)
Privacy Policy: https://policies.google.com/privacy
The website uses Google Web Fonts. This means that your browser loads the appropriate Google font into its cache in order to display texts and fonts correctly. For this purpose, it is necessary to establish a connection through the browser to Google servers. As a result of this connection, Google obtains information that access to the Website was obtained from your IP address.
We use Google Web Fonts to maintain the visual uniformity of the Website, which makes it more readable for the recipient. The legal basis for sharing the IP address is our legitimate interest (Article 6(1)(f) of the GDPR).
You can find more information about Google Web Fonts at https://developers.google.com/fonts/faq and in Google's privacy policy:
https://www.google.com/policies/privacy/
Provider: Provided by Google LLC (1600 Amphitheatre Parkway, Mountain View, CA, United States) and for users in the European Union, European Economic Area and Switzerland - Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland (the provider for your location should be mentioned in Privacy policy)
Privacy Policy: https://policies.google.com/privacy
Within our site, we use a tool called Clearbit to enrich data about customers and potential customers by identifying (via IP or cookies) visitors to our site and filling in missing information to better tailor marketing and sales activities.
Provider: API Hub, Inc.,
Privacy Policy: https://clearbit.com/privacy-policy ((privacy policy contains information about opt-out from profiling)
As part of the Application, we use the Cloudflare service provided by Cloudflare, Inc. This service optimizes the website and improves the speed of loading content, as well as increases security (eliminates bots), and its operation is to enable the transfer of larger multimedia files via distributed servers connected over the Internet.
Provider: Cloudflare, Inc
Privacy policy: More information on data processing as part of the service can be found at https://www.cloudflare.com/pl-pl/privacypolicy/
When you provide us with your Personal Data, we become their controller.
DBC1's basis for processing your Personal Data may be:
We may process your Personal Data, depending on the basis of our contact, for the purposes of:
More details are provided in the section Information clause.
The maximum scope of Personal Data we process depends on the basis of our relationship and includes:
Please be advised that we do not process specific categories of your Personal Data referred to in Article 9 - 10 of the GDPR such as: ethnic origin, political views or biometric data.
If we ask you to provide Personal Data on our Website (e.g. for the use of the contact form), you must know that providing it is a condition for concluding an agreement to access the functionalities available on our Website. If you do not provide this data, you will be, unfortunately, unable to use them.
The period for which Personal Data may be stored depends on the legal basis for processing your Personal Data and the purpose for which they are processed. More details are provided in the section Information clause.
Please also be informed that from time to time we may transfer or share your Personal Data with entities that cooperate with us e.g. accounting companies, legal advisors, courier companies, advertising and marketing companies, hosting providers, payment providers, CRM System provider. The transfer may take place only when we have concluded appropriate agreements with these entities in order to ensure that they will protect your Personal Data at least as responsibly as we do.
You need to know that the Tool is distributed by our trusted partners - resellers of our services and we could share data provided to us by you (e.g. information about the data characterizing the company - size of the company, number of employees, contact details of persons responsible for cooperation) with one of our resellers. The base of such a transfer is the legitimate interest of the data controller (article 6, para. 1, section f) GDPR). Our legitimate interest is the possibility of transferring your data to a reseller in order for the reseller to enter into a contract with you regarding our services. You should also notice, that if you decide to start using the Tool on the basis of agreement with one of our resellers, that reseller and DBC1 will process data related to Google Workspace accounts administered by you - processing that data is necessary for the proper operation of the Tool. Additional scope of data that reseller may process if you use DBC1 is: data of the Tool user’s employees/partners whose email signature could be modified by the Tool: names and surnames, email address, phone numbers, profile photos and optionally, the email address of the users's managers.The basis for such processing will be the data processing agreement concluded with the reseller. We will inform you when we share your data with our reseller.
Personal Information may also be shared by DBC1 with government authorities or other entities authorized to access the data and according to the law.
Transfer to such entities may only take place after we have obtained your consent (where required) or where such admissibility is provided for by law, e.g. where DBC1 processes data on the basis of a legitimate interest.
As we use tools for our daily operations whose providers may process Personal Data outside the European Economic Area and we work with advisors in various locations around the world your Personal Data may also be transferred for processing outside the European Economic Area. In this case, we shall make every effort to ensure that the processing is carried out on a lawful basis, such as standard contractual clauses. Please also note that such transfer may only take place if the third country or international organization meets the conditions set out in the GDPR.
If you consent to the processing of Personal Data, remember that the consent is given by you voluntarily. You have the right to withdraw your consent at any time. However, remember that the withdrawal of consent does not affect the processing carried out by us prior to the withdrawal.
You have the right to access your Personal Data at any time. You can always ask us, as the controller of your Personal Data, for informing you whether your Personal Data is being processed by us, to provide you with an access to your Personal Data, and to receive other information such as, but not limited to, the duration of the processing, the purposes of the processing, information on to whom we provide the data, information on automated decision-making or profiling.
Remember that you also have the right to lodge a complaint with the supervisory body (the President of the Personal Data Protection Office).
You have the right to rectify your Personal Data by changing or supplementing it.
You have the right to delete your Personal Data, known as the “right to be forgotten”. You can request us to delete your data without undue delay in the following situations:
More details about the right to be forgotten can be found in Article 17 of the GDPR.
You also have the right to restrict processing by the controller. You can request a restriction when:
If the processing is performed based on consent or in an automated manner, you also have the right to transfer data that we should provide to you at your request in a commonly used format. You can also request that the data be transferred by us directly to another controller.
If the processing is based on Article 6 (1) (e) or (f) of the GDPR, you have the right to object to the processing. In this case, we can no longer process your Personal Data unless we demonstrate the grounds required by the GDPR.
You also have the right not to be subject to a decision based on automatic processing, including profiling, if such a decision has legal effects on you or otherwise significantly affects you. Please be advised that this right does not apply if: such a decision is necessary for the performance/conclusion of the contract, is permitted by law or is based on your express consent.
Controller’s data
The Controller of the personal data is Mok Yok Group sp. z o.o. registered in Wroclaw, postal code no. 50-125, Św. Mikołaja 8-11, entered into the Register of Entrepreneurs managed by the District Court for Wroclaw-Fabryczna in Wroclaw, VI Commercial Division of the National Court Register, under Registry no. 0000503224, with share capital of 5.200,00 PLN, State Register of Entities of National Economy (REGON): 022383863, Tax Identification Number (NIP): 8971797577
Purpose of processing
Depending on the circumstances, the provided personal data may be processed for the purposes of:
Please be advised that providing us with the data is voluntary, but necessary to use the data for above mentioned purposes.
Legal basis and time of the processing
Personal Data recipients
The recipients of your data may be relevant state authorities operating on the basis of generally applicable law. Your data may also be transferred to entities, as defined within Who we may transfer your Personal Data to part, processing data at the request of the controller - remember, however, that such entities process data on the basis of a contract with the controller and only in accordance with his/her instructions.
Processing data outside the EEA
Due to the fact that for our business we use tools whose suppliers may process Personal Data outside the European Economic Area, your Personal Data may also be transferred for processing outside the European Economic Area. In this case, we make sure that the processing takes place on a legal basis, which are, for example, standard contractual clauses.
Rights of data subject
You have the right to request the controller to access your personal data, rectify it, delete it or restrict the processing of, as well as the right to withdraw consent if it is expressed and a complaint is lodged with the supervisory body (for Poland: President of Personal Data Protection Office, Stawki 2, 00-193 Warsaw). In matters related to data protection, you can contact us at: contact@DBC1.com
All inquiries and requests related to the processing of Personal Data can be directed to:
We may change our Policy from time to time to take account of the changing legal and technological environment. However, the most up-to-date version will always be available on our Website.
APPENDIX NO. 1 - data processing agreement
DATA PROTECTION AGREEMENT
(hereinafter referred to as Agreement)
concluded as of the date of its acceptance
MOK YOK GROUP SP. Z O.O. established in Poland, Św. Mikołaja 8-11 St., 50-125 Wrocław, entered in the Register of Entrepreneurs managed by the District Court for Wrocław - Fabryczna in Wrocław, VI Commercial Division of the National Court Register under Registry no. 0000503224, with share capital of 5.200,00 PLN, Tax Identification Number (NIP): 8971797577, State Register of Entities of National Economy (REGON) no. 022383863:
hereinafter referred to as Processor
and
Customer as Controller
hereinafter called the Parties and individually called the Party.
The Parties hereby enter into the following Agreement:
§1. GENERAL PROVISIONS
§2. RULES OF PERSONAL DATA PROCESSING
§3. PERSONAL DATA PROCESSING CONTROL
§4. SUBCONTRACTORS
§5. LIABILITY AND DECLARATIONS
§6. TERM
§7. FINAL PROVISIONS