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PRIVACY POLICY OF THE POLISH HUMANITARIAN ACTION

The Polish Humanitarian Action was created thanks to the engagement and generosity of thousands of people who have been helping us help others for more than 26 years. Transparency is one of the most important rules for us. That is why we want to inform you why we need your personal data, how we process them and what rights you have in respect of your data.

Rest assured that the technical and organisational solutions we implemented provide a high standard of protection for your personal data. In this Privacy Policy, we explain our approach and practices relating to personal data protection. We undertake to comply with this Policy and the applicable personal data processing laws in our business.

Thank you for being with us.

Who is the personal data controller and data protection officer?

Your personal data are controlled by the Polish Humanitarian Action with its registered office in Warsaw, at Aleja Solidarności 78A, 00-145 Warsaw, with the tax identification number (NIP): 525-14-41-253, business statistical identification number (REGON): 010849302, National Court Register number (KRS): 0000136833.

The Data Protection Officer is Zontek i Wspólnicy Sp.k., a limited partnership with its registered office in Warsaw, at ul. F. Płaskowickiej 46/129, 02-778 Warsaw (e-mail: iod0001@zontekiwspolnicy.pl, phone 22 4068292), which supports PHA as the data controller and takes action to ensure data processing is in compliance with data protection regulations.

What personal data do we process?

We process various categories of personal data, depending on how you get in touch with us and how you make your donations.

Types of interaction Type of data being processed Source of data
If you only visit and browse our website When visiting the websites of: pah.org.pl, www.pajacyk.pl and www.pomagamy.pl, the technical details concerning the User’s visit, such as the IP address, the domain name, the browser type that you use and the operating system type, etc. are collected automatically. We process the personal data collected by the cookies. For more information on the cookies and data collected by the cookies please go below to the final section of our Privacy Policy.
If you make a donation We process: your first and middle names, your last name, pseudonym, sex, e-mail address, postal address (street name, postal code, city/town, country), phone number, date of birth, bank account number, amount, purpose and currency of your donation.
We consider our donors to be our friends. Therefore, in order to ensure as personalised contact as possible, we also process data concerning whether or not you have children (if you decide to share this information with us) because we want to send you gifts. We do not, however, process the data of your children.
We gather personal data when you make a donation by entering your data on the payment form at: www.pah.org.pl www.pajacyk.pl and www.pomagamy.pl or on the postal money transfer form. We gather personal data on the basis of data from the bank transfers, via the PayU payment operators, and also via Facebook, if you took part in a fundraiser organised on www.facebook.com and via Polish Post if you sent donations via a postal money transfer.
If you give us 1% of your income tax and you consented to transferring your data to us on the PIT tax return We process: your first and middle names, last name, sex, residence address (street name, postal code, city/town, country), bank account number, amount, purpose, currency of the 1% of income tax amount transferred, as well as: the first and middle names, last name, sex, residence address (street name, postal code, city/town, country) of your spouse if you settle your taxes with him/her, as well as well as: the name and the address of the Tax Office where you settle your personal income tax. We gather personal data when you transfer the 1% of your personal income tax amount and give your data in the PIT form. We obtain the data on the basis of information provided to us by the Ministry of Finance.
If you enrolled to receive our newsletter We process your e-mail address if you enrolled for the newsletter at pah.org.pl, as well as your e-mail address and your first name if you enrolled at pajacyk.pl. We also check the open rate of the e-mails sent to you and gather information on messages that you click so that we customise the e-mails to your interests as much as possible. We get the data from you directly – from the window where you enter your e-mail address and by means of the cookies..
If you set up a profile and a fundraiser on the platform pomagamy.pl We process the following data as part of pomagamy.pl: your first and middle names, last name, pseudonym, city where you live, language, address (street name, postal code, city/town, country), e-mail address and contact phone number, tax identification number, login name and password to the account, as well as the title and description of the fundraiser you set up, its purpose and closing date. When you act on behalf of a group or a company, we also process its name.
When you give us a donation as part of pomagamy.pl, we will also process your data, as specified in the line concerning donations above.
We get the data from you directly or from Facebook if you use the option “Log in with Facebook”.
If you create a fundraiser on FB We process your first and last name or your pseudonym and your e-mail address as part of the fundraiser. We get the data from Facebook.
If you set up a fundraiser on the website of Fundacja Maraton Warszawski [Warsaw Marathon Foundation] as part of the campaign #BiegamDobrze We process: your first and middle name, last name, pseudonym, sex, e-mail address, password to the marathon portal account, phone number, country, nationality, city/town, date of birth, purpose of fundraiser, amount, T-shirt size, subscriber card number and club affiliation. We get the data from Fundacja Maraton Warszawski [Warsaw Marathon Foundation].
We also get the information that you share with us during meetings, phone calls, in the e-mails you sent to us, via our website and via traditional means.

Why do we process your personal data?
We process personal data in order to:

  • handle the process of the financial donations you make to PHA via the websites: pah.org.pl, www.pajacyk.pl, www.pomagamy.pl, traditional bank transfers, as well as 1% of your income tax, fundraisers via Facebook.com or postal money transfer,
  • handle the process of in-kind donations and services you provide,
  • handle the accounting and fiscal process,
  • thank you for your support,
  • notify you of actions that we take thanks to your support (via the newsletter, paper correspondence, phone calls),
  • notify you of day-to-day needs of people PHA wants to help and encourage you to take part by providing financial support, services or taking an action (via the newsletter, paper correspondence, phone calls),
  • contact you in a manner of your choice,
  • create correspondence for you customised to your interests and preferences,
  • send you birthday wishes,
  • send you invitations to events organised by PHA,
  • analyse whether or not our mailing is of interest to you,
  • comply with legal obligations, including obligations under agreements with individual and business donors,
  • perform the agreement on provision of services electronically in that we maintain your account on the portal pomagamy.pl,
  • market our own activities, to perform market research and demographic research as well as examine the behaviours and preferences of persons using our website, and to maintain the viewing statistics for our website or customise its content,
  • ensure efficient functioning of our websites: pah.org.pl, pajacyk.pl, pomagamy.pl.

On what basis do we process your personal data?

  • We process your data on the basis of your consent given pursuant to Article 6 (1) (a) of the General Data Protection Regulation of 27 April 2016 (“GDPR”) – when we process your data to contact you, send you informational or educational materials (e.g. consent to receive correspondence electronically on the website pah.org.pl, including the newsletter), and also when you donate us 1% of your income tax (you gave such consent on the PIT tax return form).
  • We process your data if it is necessary to perform a contract to which you are a party (e.g. a contract on in-kind or financial donation, and also a contract on providing services electronically by maintaining an account on pomagamy.pl) or to take steps at your request prior to entering into a contract, in keeping with Article 6(1)(b) of GDPR.
  • We process your data if it is necessary for compliance with a legal obligation to which PHA as the controller is subject, in keeping with Article 6(1)(c) of GDPR – in terms of our obligations towards the Minister of Health who oversees us, or in order to comply with our obligations under the Accounting Act, Public Benefit Activity and Volunteering Activity Act, tax regulations and others.
  • We process your data for the purposes of the legitimate interest pursued by the controller, in keeping with Article 6(1)(f) of GDPR, which is to raise funds for public benefit activity – we process your data to contact you, send you informational materials (e.g. sending paper communication to donors) and to ensure efficient operation of the PHA websites.

Giving your personal data is voluntary in each case; however, it is necessary if you want to make a donation via our websites or to enroll for our newsletter. You can always opt out of the newsletter by e-mailing us at: compliance@pah.org.pl or by clicking the link in the newsletter.

If you make a donation to us via Facebook.com, giving your personal data is voluntary; however, you will not be able to make a donation that way if you do not give us your data. If you use the account on the portal pomagamy.pl, giving your data is voluntary; however, you will not be able to create or maintain an account if you do not give your data.

How long do we process your personal data?

If you gave us a donation (by yourself, via PayU or by donating 1% of your income tax) but you did not agree that we send you any correspondence, we will process your personal data for a period corresponding to the periods arising from the applicable law, including the Tax Ordinance, Accounting Act and Civil Code (the statute of limitation on claims). We process the data you gave us while setting up an account on pomagamy.pl for the same period of time.

If you gave us your consent to send you our mailing and to process your personal data for that purpose, we will process your data until you revoke your consent or until you make an objection to our processing of your data.

For information on the time of cookies retention please go to the final section of this Privacy Policy.

Do we entrust and make your personal data available to other entities?

Making donations on the websites: www.pah.org.pl, www.pajacyk.pl, www.pomagamy.pl is possible because we cooperate with the payment operator PayU. Thanks to that cooperation you can make your donation in a quick, easy and safe manner. To make a donation through the intermediation of that payment operator, PHA transmits your personal data to PayU S.A. with its registered office in Poznań. PayU is an independent data controller.

Direct Channel, a company based in Katowice (Direct Channel Sp. z o.o., ul. Wandy 16 B, 40-322 Katowice) helps us prepare printed correspondence.

Sare, a company based in Rybnik (SARE SA, ul. Raciborska 35a, 44-200 Rybnik) and Click Dimensions LLC, a US-based company (5901 Peachtree Dunwoody Road, NE, Suite B500, Atlanta, GA 30328) help us prepare our electronic correspondence. Click Dimensions complies with the agreement between the European Union and the United States on personal data processing, the so-called Privacy Shield.

Furthermore, we store the personal data of our Donors in dedicated systems of Microsoft Dynamics (Navision and CRM) that guarantee safety. Those systems are implemented and maintained for us by ITBoom, a company based in Warsaw (ITBoom Sp. z o.o., ul. Bonifraterska 17, 00-203 Warsaw) and Acrebit, also based in Warsaw (Acrebit ul. Stanisława Augusta 73/4, 03-846 Warsaw). We also cooperate with developers. That way we are sure that your data are protected at every stage of the processing.

Aid Builder Social Fundraising with its registered office at Adelgade 12, 1st Floor, 1304 Copenhagen, Denmark helps us maintain the platform pomagamy.pl. In case of cooperation with that service provider, data are entrusted pursuant to an existing contract and your personal data are not used for purposes other than maintaining your account and serving your activity on the platform. Aid Builder has access to all data on the platform pomagamy.pl; however, it has no access to data acquired in relation to the donation you made.

We may also transfer your personal data to our legal- and tax advisers.

What are your rights in respect of personal data?

  • Right to access data – you have the right to obtain from us confirmation as to whether or not personal data concerning you are being processed and, where that is the case, access to the personal data and to information, such as the purposes of the data processing, in keeping with Article 15 of GDPR.
  • Right to rectification – you have the right to ask us to provide you without undue delay the rectification of inaccurate data concerning you or to have incomplete data completed, in keeping with Article 16 of GDPR.
  • Right to erasure (“right to be forgotten”) – you have the right to obtain from us the erasure of personal data concerning you without undue delay and we have the obligation to erase your personal data without undue delay, unless we are required to continue the data processing, in keeping with Article 17 of GDPR.

If you receive electronic correspondence from us via the Sare or Click Dimensions systems, your e-mail address will be removed from the recipients list automatically once you click on the link in the message.

  • Right to restriction of processing – you have the right to ask us not to process your data in a manner other than only to keep them until your other request concerning your personal data, pursuant to Article 18 of GDPR.
  • Right to data portability – you have the right to receive the personal data concerning you in a structured, commonly used and machine-readable format or in any other form of your preference and to have the personal data transmitted directly to another controller, pursuant to Article 20 of GDPR.
  • Right to object – you have the right to object to our processing of your data if we process them for our legitimate interest or in the public interest, and also if we process them for marketing purposes, pursuant to Article 21 of GDPR.
  • Right to withdraw your consent – you have the right to withdraw, at any time, your consent based on which we process your data. Such withdrawal shall be without prejudice to the lawfulness of processing conducted on the basis of such consent prior to its withdrawal, pursuant to Article 7(3) of GDPR.

Where you receive electronic correspondence from us, you can also revoke your consent for us to use your phone number or e-mail address to send you our materials and process your data. Your data will be removed automatically once you click on the link in the message. You need to keep in mind, however, that withdrawal of consent in that respect only means that we will remove your data that we process for that purpose; however, because you made a donation for us, we may have certain legal obligations, whereunder we must process your data even after you have withdrawn your consent. It is so because the donation agreement between us and the legal obligations on us are the legal basis for the processing of your data if you had made a donation to us.

In order to exercise those rights or receive additional information on the processing of your data, please contact us by using the e-mail address: compliance@pah.org.pl, calling us at 22 828 88 82 or sending us a letter at: Polska Akcja Humanitarna, Aleja Solidarności 78A, 00-145 Warszawa.

Who can you report objections regarding data protection to?

If you have objections as to the manner in which we process your data, please first contact us using the e-mail address: compliance@pah.org.pl, the phone number 22 828 88 82 or the address: Polska Akcja Humanitarna, ul. Aleja Solidarności 78A, 00-145 Warszawa. In addition, you may report your objections to our Data Protection Officer – the firm of Zontek i Wspólnicy with its registered office in Warsaw, at ul. F. Płaskowickiej 46/129, 02-778 Warsaw (email: iod0001@zontekiwspolnicy.pl, phone 22 406 82 92).

Furthermore, please be informed that you also have the right to lodge a complaint with the supervisory authority for personal data protection, i.e. President of the Personal Data Protection Office, pursuant to Article 77 of the GDPR.

Cookies

Cookies are small text files sent by the PHA server and saved on the user’s side which may be read only by the system that had saved them. Cookies are only used to facilitate identification. They are used for storing information that is necessary for the proper display of the PHA website.

If you do not want the cookies to be saved on your computer, please adapt the settings of your browser accordingly. To find out how you can manage the cookie files, and also how to disable them in the browser, you can use the help file of your browser. You can find that information by pressing F1 key in your browser.

The cookies are neither harmful for the computer or for the data of its user, that is why it is recommended not to disable them in the browser. If those files are disabled, some functions of the websites: www.pah.org.pl, www.pajacyk.pl, www.pomagamy.pl may no longer be available.

Cookies are used to:

  1. a) customise the content of website pages, depending on your preferences, and to optimise the use of the website; in particular, cookies enable the identification of your terminal device, which allows the displayed page to be tailored to the your individual needs;
  2. b) gather statistics to help understand how the websites are used, so as to improve their structure and content.

As part of our platform service www.pah.org.pl, and the websites: www.pajacyk.pl i www.pomagamy.pl, we use two basic types of cookies: session cookies and persistent cookies. Session cookies are temporary files stored on your terminal device until you log out, leave the website or exit the browser. Persistent cookies are stored on your terminal device for a period specified as a cookie parameter or until you remove the cookie.

We use the following cookie types on our service platform www.pah.org.pl:

  1. a) “essential” cookies, required to enable the services provided by the website, e.g. authentication cookies, used to provide services that require authentication on the website;
  2. b) “performance” cookies for collecting information about the use of the website;
  3. c) “functional” cookies for “saving” your preferences and your interface customisation, e.g. language and regional settings, font size, appearance, etc.

In many cases, software used to view web pages (Web browser) allows by default the storage of cookies on the user’s terminal device. You may change the cookie settings at any time. In particular, the settings may be changed to prevent automatic acceptance of cookies or ensure that the user is notified each time cookies are to be added to the your device. Detailed information about the possibilities and ways of handling cookies are available in the software settings (Web browser). Unfortunately, if the use of cookies is restricted, it may affect some functionalities available on web pages of our service platform.

Conclusion

This Privacy Policy may be updated from time to time. We encourage you to review the Privacy Policy whenever you visit the website of www.pah.org.pl and the websites: www.pajacyk.pl and www.pomagamy.pl, to ensure that the information contained in this document provides material and relevant details on the gathering and processing of your personal data.

 

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