PRIVACY POLICY OF THE POLISH HUMANITARIAN ACTION
The Polish Humanitarian Action was created due to the commitment and dedication of thousands of people thanks to whom it has been providing help for over 26 years. Transparency is one of the most essential values for us, and that is why we want to inform you why we need your personal data, how we process it, and what rights regarding your data you have.
We assure you that the technical and organizational solutions implemented by us provide a high standard of protection for your personal data. The following Privacy Policy explains our approach and methods regarding personal data protection. As part of the activity we conduct, we oblige ourselves to comply with said policy, as well as the current law in terms of data processing.
Thank you for your support.
Who is the Data Controller and the Data Protection Officer?
The Polish Humanitarian Action with the headquarters in Warsaw, Aleja „Solidarności” 78A, 00-145 Warsaw, Tax Identification Number: 525-14-41-253, National Business Registry Number: 010849302, National Court Register: 0000136833 (hereafter “PAH”) is your Data Controller.
The Data Protection Officer is Michał Kluska of the Domański Zakrzewski Palinka LP law firm which supports PAH in its actions as the Data Controller and works towards providing data processing that complies with all the regulations. The Officer can be contacted via email: iod@pah.org.pl.
What kind of personal data do we process?
We process various categories of personal data, depending on the way you contact us or the way you make the 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 data collected by the cookie files. More information about the cookie files and the data they collect can be found in the last segment of our Privacy Policy. |
If you make a donation | We process, among others, the following type of data: your name, middle name, last name, nick, gender, email, address (street, postcode, city, country), phone number, date of birth, bank account number, donation amount and donation information. We treat donors like our friends, and that is why – in order to provide the most personalized contact – we also process the data regarding the fact if you have children (if you voluntarily share such information with us) because we want to send you occasional gifts. We do not, however, process the personal data of your children. |
We collect the data when you donate to us by inserting your data in the payment form on websites: www.pah.org.pl www.pajacyk.pl and www.pomagamy.pl or in the postal order form. The personal data is collected based on the data from the bank transfers, through the Payment Operator PayU, as well as through Facebook if you participated in the fundraising on www.facebook.com, and Polish Post if you made the donation using the postal order. |
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, among others, the following type of data: your name, middle name, last name, gender, address (street, postcode, city, country), bank account number, amount and other information regarding the donated 1% of tax, as well as the name, middle name, last name, gender and address (street, postcode, city, country) of your spouse, if you pay the tax with them, and the data of the tax office you pay the tax at. | We collect the personal data when you donate 1% of your tax to us by sharing your data in the PIT-OP form. We acquire said data based on the information provided to us by the Ministry of Finance. |
If you enrolled to receive our newsletter | We process your email address if you have enlisted for our newsletter on pah.org.pl, as well as: your email address and name if you have enlisted on pajacyk.pl. We also check how often you open the correspondence we send you, and we collect information regarding the prompts you click on to adjust future mailing accordingly to your interests. | We acquire the data directly from you – using the input field you type your email into and using the cookie files. |
If you set up a profile and a fundraiser on the platform pomagamy.pl | As part of pomagamy.pl, we process the following type of personal data: your name, middle name, last name, nick, city you live in, language, address (street, postcode, city, country), email address and phone number, Tax Identification Number, login and password to the account, as well as the information regarding your fundraising. If you work on behalf of a group or a company, we also process their name. If you donate to us as part of pomagamy.pl, we will also process the data the same way as described above, in the field regarding donations. | 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 | As part of the fundraising, we process your name, last name or nick, and email address. | We acquire 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 name, middle name, last name, nick, gender, email address, password to the marathon account, phone number, country, nationality, city, date of birth, the goal of the fundraising, amount, shirt’s size, subscriber’s card number, club affiliation. | We acquire 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?
Personal data may be processed to:
On what basis do we process your personal data?
Giving consent to sharing your personal data that can be found on the PIT-OP form with PAH, as part of donating 1% of your tax, is voluntary and is not required to donate 1% of your tax.
In other cases, sharing your personal data is also voluntary, however, it is required to finalize the donation through our websites, as well as through other portals. Sharing your personal data is also required to enlist for the newsletter.
You have the right to object to having your data processed at any time, based on a legitimate interest, according to Article 6(1)(f) of the GDPR. You also have the right to object if your personal data is being processed for the purposes of direct marketing.
You can always unsubscribe from the newsletter by informing us about it through email: compliance@pah.org.pl or by clicking the link in the newsletter.
How long do we process your personal data?
If you have donated to us (independently, using PayU or as the 1% of your tax), but you have not agreed to receive correspondence from us, we process your data accordingly and in a necessary scope for the period specified by the date limits dictated by the law, including the Tax Ordinance, the Accounting Act, and the Civil Code (claims limitation period). During that period, we also process the data shared with us while creating an account on pomagamy.pl.
If you have agreed to receive correspondence from us, your data will be processed until you withdraw your consent or object to having your data processed.
Specific information regarding the retention period of the cookie files can be found in the final part of the following Privacy Policy.
Who is the Data Recipient of your personal data?
Your personal data, as well as Donors’ personal data, is shared only with subjects providing services related to maintaining PAH websites, as well as finalizing and handling donations or other types of support for PAH.
One of the Data Recipients might be PayU Inc, with whom personal data is shared while making donations on www.pah.org.pl, www.pajacyk.pl, www.pomagamy.pl. Thanks to the cooperation with PayU Inc, you can make the donation in a quick, easy, and safe way. That is why PAH shares your personal data with PayU Inc with the headquarters in Poznań. PayU is an independent data controller (PayU Inc, Grunwaldzka 186, 60-166 Poznań).
To prepare and distribute the printed correspondence, we get support from companies SPEEDMAIL LLC and EDC Expert Direct Communication LLC, which might be the data recipients of your personal data (SPEEDMAIL LLC with the headquarters in Piotrków Trybunalski, Belzacka 176/178, EDC Expert Direct Communication LLC with the headquarters at Belzacka 176/178, 97-300 Piotrków Trybunalski)
The following subjects that help PAH with preparing electronic correspondence might also be the data recipients of your personal data:
● Digitree Group Inc (formerly Sare Inc) (Digitree Group Inc, Raciborska 35a, 44-200 Rybnik),
● Click Dimensions LLC with the headquarters in the United States (5901 Peachtree Dunwoody Road, NE, Suite B500, Atlanta, GA 30328). Click Dimensions complies with the agreement between the European Union and the United States in terms of data processing, also known as the Privacy Shield.
Moreover, the Donors’ personal data is stored in specially designed, safety-ensuring Microsoft Dynamics systems (Navision and CRM) which are implemented and serviced for us by the following companies:
● ITBoom LLC (ITBoom LLC, Bonifraterska 17, 00-203 Warszawa),
● Acrebit Inc (Acrebit Inc, Stanisława Augusta 73/4, 03-846 Warszawa). We also cooperate with programmers. Because of that, we can be sure that your data is protected during every stage of its processing.
The company Aid Builder Social Fundraising with the headquarters in Adelgade 12, 1st Floor, 1304 Copenhagen, Denmark helps us in maintaining the pomagamy.pl platform. In the case of cooperating with this service provider, your data is not used for any purposes other than keeping your account and servicing your activity on the platform. Aid Builder does not have access to the data acquired through the donations you made.
Your personal data might also be shared with our legal and tax advisers.
Our Donors’ email addresses might also be shared with Facebook, due to the usage of the Facebook Audience Insights tool for statistical and marketing purposes or for acquiring information about our audience. Said process does not identify specific people and is only a statistical action which might be undertaken in the following way:
1) import of chosen email addresses of people who have made a payment using a form on the website www.pah.org.pl into the Facebook Audience Insights tool,
2) pooled analysis of the data regarding Facebook accounts related to the imported email addresses. Said data does not identify specific people – only certain regularities, e.g. gender ratio,
3) commissioning Facebook to display advertisements for the accounts related to the imported email addresses,
4) commissioning Facebook to find accounts similar to those related to the imported email addresses in order to display the advertisements for them.
What are your rights regarding your personal data?
● The right to access your data – you have the right to acquire confirmation from us about whether or not we process your personal data, and if we do, you have the right to gain access to it, which includes receiving its copy and acquiring specific information, e.g. regarding the purposes the data is processed for, according to Article 15 of the GDPR.
● The right to demand the correction of your data – you have the right to demand immediate correction or completion of your personal data that is incorrect, according to Article 16 of the GDPR.
● The right to demand the deletion of your data (“the right to be forgotten”) – you have the right to demand the immediate deletion of your personal data, and we are obligated to do so, unless the law requires us to process it further, or unless other reasons are preventing us from completing the request, according to Article 17 of the GDPR.
● The right to limit the processing of your data – you have the right to demand that we do not process your data in any way other than storing it for the period during which we look into your other request in terms of personal data, according to Article 18 of the GDPR.
● The right to transfer your data – you have the right to receive your personal data from us in a structured, commonly used format that is machine-readable or can be accessed in another, preferable by you, way, as well as the right to send that data to another controller, with no problems caused by the controller who had received your data first, according to Article 20 of the GDPR.
● The right to object – you have the right to object towards processing your data if we process it based on our justified interest or for the public interest, as well as if we process it for marketing purposes, according to Article 21 of the GDPR.
● The right to withdraw consent – at any time, you have the right to withdraw your consent, based on which we process your data. Withdrawing the consent does not influence the legal compliance of the processing done based on said consent before the withdrawal, according to Article 7(3) of the GDPR.
If you receive electronic correspondence from us, you can also withdraw the consent to have your phone number or email address used to send you our materials and process your data. After doing so, the data will be deleted automatically after clicking on the link in the message. However, you must keep in mind that withdrawing your consent in this regard means only the data we process for that purpose will be deleted. Because you have donated to us, we might be bound with legal obligations to keep processing your data even after your withdrawal of consent. The reason for that is the fact that the legal basis for processing your data after making a donation is a contract of donation, as well as legal obligations we are bound with.
In order to make use of the above rights or to acquire additional information regarding processing your data, contact us through email: compliance@pah.org.pl, phone number: 22 828 88 82 or traditional correspondence: Polish Humanitarian Action, Aleja „Solidarności” 78A, 00-145 Warsaw.
Who should you notify about your reservations regarding data protection?
If you have reservations about the way we process your data, we ask that you first contact us using email: compliance@pah.org.pl, phone number: 22 828 88 82, or address: Polish Humanitarian Action, Aleja Solidarności 78A, 00-145 Warsaw. You can also contact our Data Protection Officer, Michał Kluska of the Domański Zakrzewski Palinka LP law firm: iod@pah.org.pl.
At the same time, we inform you that you have the right to make a complaint to the supervisory authority responsible for the data protection, i.e. the President of the Office of Personal Data Protection, Stawki 2, 00-193 Warsaw.
Cookie files
Cookies are small text files, sent by the PAH server and saved on the user’s end, which can be only read by the system that saved them. Cookies are only used to facilitate identification. They store information necessary to properly display a PAH website.
If you do not wish to have the cookie files saved on your computer, adjust your browser settings accordingly. To find out how to manage the cookie files, including how to disable them in your browser, you can use the browser’s “help” option. You can learn more about it, by pressing F1 while in an open browser.
The cookie files are not harmful to the computer, nor to its user’s data, hence it is recommended not to disable them in a browser. Otherwise certain functions of www.pah.org.pl, www.pajacyk.pl, www.pomagamy.pl might become unavailable.
Cookies are used to:
a) adjust the websites’ content to your preferences, and to optimize the websites’ performance; those files are used specifically to recognize your device and properly display the website so that it fits your individual needs;
b) create statistics that help us understand how people use our websites, which enables us to improve their structure and content.
As part of our websites: www.pah.org.pl, www.pajacyk.pl, and www.pomagamy.pl, we use two essential types of cookie files: session cookies and persistent cookies. The session cookies are temporary files stored on your device until you logout, leave the website, or turn off the software (browser). The persistent cookies are stored on your device for the period specified in the cookies’ parameters or until you delete them.
As part of our www.pah.org.pl website, we use the following types of cookie files:
a) strictly necessary cookies that enable using the services our website provides, e.g. the authenticating cookies used for services that require authentication on the website;
b) performance cookies that enable collecting information regarding the ways our websites are used in;
c) functionality cookies that enable “remembering” the settings you choose, and the personalization of your interface, e.g. in terms of the language or region you come from, font size, website’s appearance, etc.
In many cases, the software used to browse websites (browser) allows for cookies to be stored on the user’s device by default. You can change the settings regarding the cookie files at any time. Said settings can be changed especially to block the automatic use of cookies by the browser or to notify you whenever they are stored on your device. Specific information about handling the cookie files can be found in the software’s (browser) settings. Unfortunately, limiting the use of cookies can cause certain functions of our websites to become unavailable.