Privacy policy

This Privacy Policy defines the rules for the collection and use of Personal Data of Clients and Visitors of the Service at the address migrateto.pl, regardless of the channel through which the data was obtained (i.e., whether the data was collected as a result of visits to our Service, activities on social media, or direct contact initiated by you). In this Privacy Policy, you will find all the information about how we use your personal data. The rules described below apply to all channels, media, or ways of contacting us. Therefore, whenever we refer to the Service below, we mean all channels for processing personal data.

 

I. The terms used in the Policy shall have the following meaning in case of doubt:

  1. Admin – N.W.U.P. sp. z o.o., with its registered office in Poznań, entered into the National Court Register (KRS) by the District Court Poznań – Nowe Miasto in Poznań under number 0001005173, REGON: 523796936, NIP: 7831869388; ul. Plac Wielkopolski 10/11B/9, 61-746 Poznań.;
  2. Personal data – information about an identified or identifiable natural person. An identifiable person is one who can be directly or indirectly identified, in particular based on an identifier such as name and surname, identification number, location data, online identifier (such as an IP address, cookie identifiers generated by their End Devices, applications, tools, and protocols, or other identifiers such as those generated by RFID tags), or one or more specific factors that determine the physical, physiological, genetic, mental, economic, cultural, or social identity of a person.;
  3. Contact Form – an interactive form available on one of the pages of the Service, allowing Users to contact the Administrator;
  4. Customer – a natural person, legal person, or other organizational unit without legal personality, acting through a representative, having at least partial legal capacity, intending to enter into any agreement with the Seller/Service Provider as provided in the General Terms and Conditions (OWU). The term “Client” also refers to Consumers;
  5. Privacy Policy / Policy – this document, which constitutes the regulations for the processing of personal data by the Administrator.
  6. OWU – General Terms and Conditions posted on the Service, forming an integral part of every agreement concluded between the Service Recipient and the Service Provider;
  7. Service – a group of related websites and other documents owned by the Service Provider, made available under the address migrateto.pl via the WWW service to increase functionality;
  8. Seller, Service Provider – N.W.U.P. sp. z o.o., with its registered office in Poznań, entered into the National Court Register (KRS) by the District Court Poznań – Nowe Miasto in Poznań.
  9. Terminal device – an electronic device that allows the user to access the service;
  10. Electronic service – a service as defined by the Act of July 18, 2002, on providing electronic services (Journal of Laws of 2002, No. 144, item 1204, as amended), provided electronically by the Service Provider to the Service Recipient through the Store;
  11. Client – a natural person, legal entity, or organizational unit without legal personality, to whom the law grants legal capacity to use the Electronic Service;
  12. User – any individual who uses the Service;
  13. Request for quotation – a user’s statement indicating their desire to receive a personalized offer from the seller based on the data provided by the user;
  14. Trustful Partners – defined according to section VI of the Privacy Policy.

 

II. Who is responsible for processing personal data?

  1. The entity responsible for processing your personal data (the “Administrator”) is N.W.U.P. sp. z o.o., located in Poznań, registered in the National Court Register under number 0001005173, REGON: 523796936, NIP: 7831869388, at ul. Plac Wielkopolski 10/11B/9, 61-746 Poznań.

 

III. Privacy Protection Principles

  1. We process your personal data in accordance with applicable laws, especially in line with Regulation (EU) 2016/679 of the European Parliament and Council from April 27, 2016, on the protection of natural persons regarding the processing of personal data and the free movement of such data, and the repeal of Directive 95/46/EC (commonly known as the “GDPR”).

 

IV. What Personal Data We Collect, For What Purpose, and On What Basis

  1. This Privacy Policy applies to current, potential, and former Clients and Users of the Service (as required by applicable law, we are obligated to retain certain personal data even after our relationship with you has ended) and individuals who use the Service but are not Clients (i.e., visitors whose activities we monitor -Users). The type of personal data collected and processed depends on how you use the Service and the services you choose.
  2. Additionally, the Administrator protects not only visitors to the Service but also Clients who have shared their personal data through other communication channels, such as the website https://www.facebook.com and other websites associated with or marked by the Facebook/Meta brand (including subdomains, international versions, widgets, and mobile versions), which operate under the terms provided, for example, at https://www.facebook.com/legal/terms, and are managed by Facebook Inc. or Facebook Ireland Limited (“Facebook Service”). These terms, including the use of Facebook Lead Ads for direct marketing of the Administrator’s products or services, are explained at https://www.facebook.com/policy.php. The Administrator does not have control over the legal regulations of the Facebook Service, including how personal data is processed by Facebook;
  • submission of a Request for Offer through the Form / Execution of the Agreement
  1. Your Personal Data provided in connection with the submission of an offer inquiry or Order, as well as other data collected in connection with your activity on the Service and use of our services, including Electronic Services (in particular: first and last name/company name; email address, website address, type of business activity, contact phone number; address [street, house number, apartment number, postal code, city, country], residential/business address/headquarters [if different from the delivery address], bank account number, and for non-consumer Clients, additionally the company name and tax identification number [NIP]) are or may be processed for the following purposes:
  2. execution of the Sales Agreement or actions taken by the person whose data is processed to conclude the agreement – in particular, confirming the submission of the offer inquiry, confirming the conclusion of the agreement, as well as maintaining contact on these matters- legal basis: Article 6(1)(b) GDPR, i.e. necessity for the performance of the Sales Agreement,
  3. marketing, analytical, and statistical activities by the Administrator or its partners (third parties mentioned in point VIII “Cookie Policy”) or other so-called Trusted Partners we cooperate with, such as displaying advertisements and offers, also tailored to your interests based on profiling (we analyze your activity [e.g., purchase history and behavior within the Service] in a simplified manner, which allows us to better adapt not only to specific, general groups of our Clients but also to your preferences). However, our actions do not significantly influence your decisions, such as purchase decisions – legal basis: Article 6(1)(f) GDPR, i.e. legitimate interest of the Administrator or a third party;
  4. establishing, defending, and pursuing claims that may arise in the context of the relationship between you and the Administrator, and other purposes necessary for the realization of the legally justified interests of the Administrator or a third party – legal basis: Article 6(1)(f) GDPR, i.e. legitimate interest pursued by the Administrator or a third party;
  5. issuing and storing invoices and accounting documents and handling complaints and returns within the time and form specified by law – legal basis: Article 6(1)(c) GDPR, i.e. necessity for the fulfillment of a legal obligation incumbent on the Administrator.
  6. providing Personal Data is voluntary but necessary to conclude the Sales Agreement.
  7. for the purpose of executing the Sales Agreement, your Personal Data will be processed for the duration of the Sales Agreement, as well as for the time required by law (e.g., tax, accounting regulations). In the case of marketing activities, data will be processed until you object, unless a longer period is required for storing data for potential claims, in accordance with the statute of limitations defined by law, particularly the Civil Code, or for other purposes related to the realization of our legally justified interests. In each case, the longer data retention period will apply.
  • complaints Procedure
  1. Your Personal Data provided in connection with filing a complaint and collected in any further communication may be processed for the following purposes:
    • considering your complaint, keeping accounting records, and settling accounts for processed complaints – legal basis: Article 6(1)(c) GDPR, i.e. necessity for the fulfillment of a legal obligation incumbent on the Administrator ;
    •  establishing, defending, and pursuing claims that may arise in the context of the relationship between you and the Administrator, and other purposes necessary for the realization of the legally justified interests of the Administrator or a third party – legal basis: Article 6(1)(f) GDPR, i.e., legitimate interest pursued by the Administrator or a third party.
  2. Your Personal Data will be processed during the handling of your complaint and, later, until the expiration of the statute of limitations for warranty claims, as well as for the time required by law (e.g., tax, accounting regulations). In the case of marketing activities, data will be processed until you object, unless a longer retention period is required for storing data in case of potential claims, for the duration of the statute of limitations set by law, particularly the Civil Code, or for other purposes related to the realization of our legally justified interests. In each case, the longer retention period for Personal Data will apply.
  • contact and Contact Form
  1. Your Personal Data provided in connection with contact initiated (e.g., in an email or through the Contact Form) and collected during any further communication, is or may be processed for the following purposes:
    • communication with you and providing a response to your message – legal basis: Article 6(1)(f) GDPR, i.e., legitimate interest pursued by the Administrator;
    • depending on the content of the communication, taking actions at your request before entering into the relevant Sales Agreement or Electronic Service Agreement – legal basis: Article 6(1)(b) GDPR, i.e., necessity to take actions before concluding the Sales Agreement or Electronic Service Agreement;
    • depending on the content of your message, marketing, analytical, and statistical activities by the Administrator or its partners (third parties mentioned in point VIII “Cookie Policy”) or other so-called Trusted Partners we cooperate with – legal basis: Article 6(1)(f) GDPR, i.e., legitimate interest pursued by the Administrator or a third party;
    • establishing, defending, and pursuing claims that may arise in the context of the relationship between you and the Administrator, and other purposes necessary for the realization of the legally justified interests of the Administrator or a third party – legal basis: Article 6(1)(f) GDPR, i.e., legitimate interest pursued by the Administrator or a third party.
  2. Providing Personal Data is voluntary, but necessary to effectively communicate with us.
  3. Your Personal Data will generally be processed until the communication with you is concluded, and in the case of marketing activities – until you object, unless the law obliges us to process this data for a longer period or we store it for a longer time for potential claims, for the period of their statute of limitations as defined by law, particularly the Civil Code, or for other purposes related to the realization of our legally justified interests. In each case, the longer retention period for Personal Data will apply.
  • Social Media Profiles
  1. Your Personal Data, including the data you leave when visiting our social media profiles (e.g., comments, likes, online identifiers), is or may be processed for the following purposes:
    • marketing, analytical, and statistical activities in the form of enabling you to engage with our profile, effectively managing our profile, by presenting you with information about our initiatives and other activities, as well as promoting various events, services, and products (including those of partners or other third parties we cooperate with) – legal basis: Article 6(1)(f) GDPR, i.e., legitimate interest pursued by the Administrator;
    • establishing, defending, and pursuing claims that may arise in the context of the relationship between you and the Administrator, and other purposes necessary for the realization of the legally justified interests of the Administrator or a third party – legal basis: Article 6(1)(f) GDPR, i.e., legitimate interest pursued by the Administrator or a third party.
  2. Providing Personal Data is voluntary, but necessary to fully use the functionalities of our social media profiles.
  3. Your Personal Data will be processed for the period necessary to achieve the above-mentioned purposes or until you effectively object, as well as for the time required by law (e.g., tax, accounting regulations), unless a longer period is required for storing them in case of potential claims, for the period of statute of limitations defined by law, particularly the Civil Code, or for other purposes related to the realization of our legally justified interests. In each case, the longer retention period for Personal Data will apply.
  • data Collected through Lead Ads Campaigns
  1. As part of advertising campaigns conducted on the Meta platform (Facebook, Instagram), we use Lead Ads forms. By completing such a form directly on the Meta platform, the user provides us with their contact details (e.g., name, email address, phone number). These data are then shared with us by Meta in the advertising panel or – in the case of integration – transferred to external tools, such as our CRM system (Notion).
  2. The data provided by the User in the Lead Ads form is transferred to the Administrator by Meta and processed solely for the purposes specified in this Policy. Meta is not the data controller for these data with regard to their further use by the Administrator.
  3. c. The data collected in this way is used for marketing and sales purposes, particularly to contact the User, present an offer, and take actions at their request before entering into an agreement (Article 6(1)(b) GDPR), as well as for purposes related to the legitimate interests of the Administrator (Article 6(1)(f) GDPR).

 

V. Your Rights

  1. You have the right to:
    • access your data and obtain a copy of it.,
    • correct any incomplete or inaccurate data,
    • request the deletion of your data or restrict its processing,
    • transfer your data to another administrator,
    • if processing is based on consent, withdraw that consent at any time without affecting the legality of processing based on consent before its withdrawal,
    • object to the processing of Personal Data carried out for the purposes of the legitimate interests of the Administrator or a third party (if there are no overriding legitimate grounds for processing). If Personal Data is processed for direct marketing purposes, you have the right to object to the processing of your Personal Data for such marketing, including profiling, insofar as it is related to direct marketing – in which case the data must no longer be processed for such purposes.
  1. You also have the right to object to further processing of your data.
  2. You can exercise all the rights mentioned above by contacting us via the Customer Service Office or the dedicated email address for handling such requests: contact@migrateto.pl. Just let us know which right you would like to exercise.
  3. In order to exercise your right, particularly for identification purposes, we may ask you to provide additional information.
  4. You also have the right to lodge a complaint with the supervisory authority (President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw), if you believe that the processing of personal data violates the provisions of the GDPR.

 

VI. Recipients of Your Data

  1. Your data may be shared with entities authorized to receive it under applicable law, including the relevant judicial authorities.
  2. In addition, for the purposes described in this Policy, your data may be shared with our trusted partners, i.e., entities that assist us in providing our services, such as:
    • providers of technological service,
    • postal services (Poczta Polska S.A.),
    • providers of marketing services (Google Inc, Meta), and
    • services related to promotion and advertising,

in the course of providing our services, we use the support of trusted providers and partners to whom personal data of Users may be entrusted, such as:

    • Meta Platforms, Inc. (Facebook, Instagram) – for conducting advertising campaigns, including Lead Ads campaigns and analytics (Meta Pixel)
    • Google Ireland Limited – for web analytics (Google Analytics)
    • Notion Labs, Inc. -for storing and organizing data in the CRM system,
    • LH.pl Sp. z o.o. – for hosting services and data storage. A data processing agreement has been concluded with this entity.

(Also referred to as “Trusted Partners” both earlier and later.)

  1. If any of our providers is located in a country outside the EEA, we always ensure that they provide adequate data security guarantees, such as signing the Standard Contractual Clauses approved by the European Commission.
  2. In cooperation with Trusted Partners, such as Google Ireland Limited and Meta Platforms, Inc., data can only be processed for the purposes of providing analytical and marketing services. These partners are not considered recipients of data in terms of sharing customer data for legal services, and they do not have access to personal data provided as part of legal assistance.
  3. Upon your request, the Administrator will provide information about all recipients of your personal data to whom it has been disclosed during processing, in accordance with Article 15 of the GDPR.
  4. The Administrator does not transfer personal data to any state authorities or institutions without the appropriate legal basis. In particular, data of individuals seeking legal assistance will not be disclosed to authorities such as border or immigration services without an explicit legal requirement.

 

VII. Other information

  1. Providing your personal data is completely voluntary, but it may be necessary for the provision of services or enabling certain features of the Service. Consequently, failure to provide such data may, in some cases, prevent the conclusion of a Sales Agreement or the response to any queries or requests you send to us.
  2. Certain features of the Service or the services we offer may require us to process third-party personal data provided by users. By providing us with third-party personal data, the user confirms that they have informed the third party about the purposes and methods of processing, and that the third party has consented to this, where required by law.
  3. The Service may periodically contain links to external websites. These websites operate independently of our Service and are not under our control. They may have their own privacy policies, which we encourage you to review before using such websites. The Service is not responsible for the data handling practices of the operators of those sites.
  4. We make every effort to secure your data and protect it from unauthorized actions by third parties. We use necessary server, connection, and Service security measures to protect your data, including an SSL protocol certificate. All connections related to electronic payments you make, if this option is chosen, will be processed via a secure encrypted connection. However, the measures we take may not be sufficient if you do not also follow security best practices.
  5. The provisions of this Privacy Policy may change, for example, in the event of changes to the functioning of the Service, the introduction of new services, or new features. We will inform you of any changes to the Privacy Policy promptly through various means used in the Service (informational banner, pop-up windows, email).

 

VIII. Cookies Policy

  1. When using the Service, data such as IP address, domain name, and browser type are automatically collected for each user. These data may be collected by cookies or other similar mechanisms such as the Google Analytics system, and may also be recorded in server logs. These mechanisms are used to facilitate visitors’ use of the Service, as well as to learn about their preferences regarding how they use it, displaying ads, and providing information tailored to the user’s preferences. Cookies are small text files sent by the Service to your end devices (e.g., computer, phone, tablet, etc.) when using the Service. These files typically contain the name of the website they come from, the time they are stored on the device, and a unique identifier.
  2. Depending on the current solutions implemented and technical capabilities, the Visitor may have the option to define the scope of cookies usage (e.g., for marketing purposes) and give the relevant consent. Depending on the consent given for the scope of cookies use, cookies may automatically collect various data regarding the Visitor’s online activity, as well as information about the location of the device used (if the chosen cookie settings allow and consent is given). If it is not possible to define the scope of cookie use from the website, the browser settings used by the Visitor will remain valid.
  3. Since the Administrator may use solutions with functionalities similar to cookies, the following provisions of the Policy apply accordingly to these technologies.
  4. Cookies are used for:
    • customizing the content of the Service’s pages to the User’s preferences and optimizing their use of the Service, particularly allowing the recognition of the User’s end device and appropriately displaying the Service’s page tailored to their individual needs;
    • creating statistics to understand how users use the Service’s websites, helping to improve their structure and content;
    • maintaining the user session (after logging into the Account), so that the user does not need to re-enter their login and password on every page of the Service;
  1. The cookies used by us may be temporary or permanent. Temporary cookies are deleted when the browser is closed, while permanent cookies remain stored after the user finishes using the Service and are used to store information such as the User’s password or login, which speeds up and facilitates the use of the Service.
  2. The Service uses:
    • essential cookies, which enable the use of services available within the Service, e.g., authentication cookies used for services requiring authentication within the Service;
    • security cookies, e.g., used to detect misuse during registration within the Service;
    • performance cookies, enabling the collection of information about how the Service is used;
    • functional cookies, allowing the “remembering” of settings selected by the user and customizing the user interface;
    • advertising cookies, allowing the delivery of personalized advertising content to Users.
  1. The collection and storage of information using cookies, except when necessary for the proper functioning of the Online Store and the performance of its basic functions (providing you with the service electronically, based on the law – Article 173(3)(2) of the Telecommunications Law), is only possible based on the consent of the Visitor. Depending on the currently implemented and available solutions, defining the scope of cookie technology usage and expressing relevant consent may primarily be possible during the first visit to the Online Store via the cookie banner, which will appear in a visible and accessible location. In such a case, the Visitor may change the selected scope of cookies use at any time in the Service’s Settings (however, some parts of the Service may not function correctly). As a standard, specific types of cookies can also be blocked from the browser settings (this is described in detail later in the document). Withdrawing consent for cookies does not affect the legality of the actions performed based on the consent before it was withdrawn..
  2. To the extent that cookies contain your personal data, the basis for their processing is the legitimate interest of the Administrator or a third party (Article 6(1)(f) GDPR), which is the identification of ad fraud, the need to ensure the highest quality content presented by the Administrator by tailoring it to the Visitor’s preferences, and marketing – including direct marketing – of products and services of the Administrator, Trusted Partners, or other third parties with whom we cooperate. In such cases, these entities do not participate in processing the Customer’s Personal Data. On the other hand, if these entities also have direct access to this information, the legal basis for such processing will be the legitimate interest pursued by these entities or the voluntary consent given by the Visitor.
  3. Sometimes cookies may enable us to communicate with you for marketing purposes (e.g., through the browser). In this case, the basis for such communication is additional, voluntary consent for this communication, which you can always withdraw without affecting the legality of our previous actions.
  4. The Visitor may object to actions by the Administrator based on personal data from cookies for the purposes described above, to the extent that the basis for the Administrator’s actions is a legitimate interest (such situations are specified above). Additionally, the Visitor can at any time change the scope of cookies technology usage and withdraw previously given consent – this will not affect the legality of actions done based on consent before its withdrawal and the communication we conducted based on additional consent.
  5. Cookies placed on the User’s device may also be used by advertisers working with us and Trusted Partners. As part of analytical and marketing activities, we use tools such as Google Analytics and Meta Pixel, which allow us to analyze traffic on the website and conduct remarketing activities. These tools may collect information about the User’s activity on the website and on the internet. Detailed information about how these entities process data can be found at: https://policies.google.com/privacy and https://www.facebook.com/privacy/policy.
  6. In any case, you can block the installation of cookies or delete permanent cookies using the appropriate options of your web browser. If you encounter problems, we recommend using the browser’s help file or contacting the browser’s producer. More useful information about cookies can be found at:wszystkoociasteczkach.pl

 

COOKIES USED IN ONLINE STORE

Cookie Type/Name Description (purpose and scope of data collected) Expiration Time
None None None

 

COOKIES FROM TRUSTED PARTNERS

Cookie Type/Name Description (purpose and scope of data collected) Expiration Time Trusted Partner Link to the Trusted Partner’s Privacy Policy
_dc_gtm_UA-257100301-1 Used by Google Tag Manager to control the loading of a Google Analytics script tag. 1 day Google Ireland Limited
(numer rejestracyjny: 368047 / VAT: IE6388047V), Gordon House, Barrow Street, Dublin 4, Irlandia		 https://policies.google.com/privacy?hl=pl
_ga Registers a unique ID that is used to generate statistical data on how the visitor uses the website. 399 days Google Ireland Limited
(numer rejestracyjny: 368047 / VAT: IE6388047V), Gordon House, Barrow Street, Dublin 4, Irlandia		 https://policies.google.com/privacy?hl=pl
_ga_# Used by Google Analytics to collect data on the number of times a user has visited the website as well as dates for the first and most recent visit. 399 days Google Ireland Limited
(numer rejestracyjny: 368047 / VAT: IE6388047V), Gordon House, Barrow Street, Dublin 4, Irlandia		 https://policies.google.com/privacy?hl=pl
ads/ga-audiences Used by Google AdWords to re-engage visitors that are likely to convert to customers based on the visitor’s online behaviour across websites. session Google

Pixel Tracker

 https://policies.google.com/privacy?hl=pl

 

  1. In addition to cookies, the Service may also collect data through so-called log files or journal files.
  2. Information contained in logs may include, among other things, your IP address, platform and browser type, Internet service provider, and the address of the page you visited before accessing the Service’s website. Some subpages of the Service and other communication tools may contain Web Beacons, which allow the collection of information such as the computer’s IP address, URL number of the page, page load time, and browser type.
  3. The Service uses Google Analytics, an internet analytics service provided by Google Inc. (“Google”). Google Analytics collects cookies that contain information about website traffic and the user’s system profile (including their IP address). This information is transferred to Google and stored on its servers in the United States. Google uses this data to evaluate user interaction with the website, create traffic reports for website operators, and provide other services related to website traffic and internet usage. User IP addresses are not combined with any other data held by Google. Google may also transfer this information to third parties if required by law or if third parties process this information on Google’s behalf. Google will not combine the user’s IP address with other data stored by Google. You can block the use of cookies by selecting the appropriate settings in your browser; however, in such cases, some features of the Service may become unavailable..
  4. In cases where the source of a user’s visit is an advertisement created by partners cooperating with the Service under the CPA (“Cost Per Action”), CPC (“Cost Per Click”), or CPS (“Cost Per Sale”) payment models, cookies are created containing session identification. After the final step of placing an Order, the data regarding the order number and amount are transferred to these companies for billing purposes.
  5. The site uses Usability Tools, an internet analytics service, which uses cookies to store information about how randomly selected anonymous users navigate from page to page (including tracking mouse movements). You can block the use of cookies by selecting the appropriate settings in your browser. Please note that deleting or disabling cookies may affect the functionality of the Service.