Privacy Policy

This Privacy Policy sets forth the rules for saving and accessing data on the Devices of Users using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing the personal data of Users provided by them personally and voluntarily through the tools available on the Service.

§1 Definitions

  • Service – the website of the "Sapiens UP Foundation" operating at https://sapiensfoundation.pl/ External service - websites of partners, service providers or service recipients cooperating with the Administrator

  • Administrator of the Service / Data - The Administrator of the Service and the Administrator of the Data (hereinafter referred to as the Administrator) is "SAPIENS UP FOUNDATION ", conducting business at the address: Bitwy Warszawskiej 1920 r. 7, 02-366 Warsaw, with assigned tax identification number (NIP): 7011176404, with assigned KRS number: 0001065045, providing services electronically through the Service

  • User – a natural person for whom the Administrator provides electronic services through the Service.

  • Device - an electronic device with software through which the User accesses the Site

  • Cookies - text data collected in the form of files placed on the User's Device.

  • RODO - Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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)

  • Personal data - means information about an identified or identifiable natural person ("data subject"); an identifiable natural person is one who can be identified, directly or indirectly, in particular on the basis of an identifier such as a name, an identification number, location data, an online identifier or one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person

  • Processing - means an operation or set of operations performed on personal data or sets of personal data in an automated or non-automated manner, such as collecting, recording, organizing, structuring, storing, adapting or modifying, retrieving, viewing, using, disclosing by transmission, dissemination or otherwise making available, matching or linking, limiting, erasing or destroying;

  • Restriction of processing - means the marking of stored personal data in order to limit its future processing

  • Profiling - means any form of automated processing of personal data that involves the use of personal data to evaluate certain personal factors of an individual, in particular to analyze or forecast aspects of that individual's performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movement

  • Consent - consent of the data subject means a voluntary, specific, informed and unequivocal demonstration of will by which the data subject, in the form of a statement or explicit affirmative action, consents to the processing of personal data concerning him or her

  • Personal data breach - means a breach of security leading to the accidental or unlawful destruction, loss, modification, unauthorized disclosure of or unauthorized access to personal data transmitted, stored or otherwise processed

  • Pseudonymization - means the processing of personal data in such a way that they can no longer be attributed to a specific data subject, without the use of additional information, provided that such additional information is stored separately and is covered by technical and organizational measures preventing its attribution to an identified or identifiable natural person

  • Anonymization - Data anonymization is an irreversible process of data operations that destroys / overwrites "personal data" making it impossible to identify, or link, a particular record to a specific user or individual.

§2 Personal Data Administrator

The administrator of the personal data is the SAPIENS UP FOUNDATION based in Warsaw (02-366), at Bitwy Warszawskiej 1920. 7, mailing address: Bitwy Warszawskiej 1920 r. 7, 02-366 Warsaw (hereinafter: "Administrator").

§3 Types of Cookies.

  • Internal cookies - files placed and read from the User's Device by the Service's data communications system

  • External Cookies - files placed and read from the User's Device by the ICT systems of External Services. The scripts of External Services that can place Cookies on User Devices have been knowingly placed on the Site through scripts and services made available and installed on the Site

  • Session cookies - files placed and read from the User Device by the Website during a single session of a given Device. When the session ends, the files are deleted from the User Device.

  • Persistent Cookies - files placed and read from the User Device by the Website until they are manually deleted. The files are not deleted automatically after the end of the Device session unless the configuration of the User Device is set to delete cookies after the end of the Device session.


§4 Data storage security

  • Mechanisms for storing and reading Cookies - The mechanisms for storing, reading and exchanging data between Cookies stored on the User's Device and the Website are implemented through the built-in mechanisms of Internet browsers and do not allow the downloading of other data from the User's Device or data of other websites visited by the User, including personal data or confidential information. Transfer of viruses, Trojan horses and other worms to the User Device is also practically impossible.

  • Internal cookies - the cookies used by the Administrator are safe for the Users' Devices and do not contain scripts, content or information that may compromise the security of personal data or the security of the Device used by the User.

  • External cookies - The Administrator makes all possible efforts to verify and select service partners in the context of Users' security. The Administrator selects well-known, large partners with global public trust for cooperation. However, it does not have full control over the content of cookies from external partners. The Administrator is not responsible for the security of Cookie files, their content and their use in accordance with the license by the Scripts installed in the service, coming from external Services, as far as the law allows. The list of partners is provided later in the Privacy Policy.

  • Cookie control - You can at any time, independently change the settings for storing, deleting and accessing the data of stored cookies by each website.

  • Threats on the side of the User - The Administrator uses all possible technical measures to ensure the security of the data placed in cookies. However, it should be noted that ensuring the security of this data depends on both parties including the activities of the User. The Administrator is not responsible for the interception of this data, impersonation of the User's session or its deletion, as a result of the User's conscious or unconscious activity, viruses, Trojan horses and other spyware with which the User's Device may be or has been infected.

  • Storage of personal data - The Administrator ensures that it makes every effort to ensure that the processed personal data entered voluntarily by Users are secure, access to them is limited and carried out in accordance with their purpose and the purposes of processing. The Administrator also ensures that it makes every effort to secure the data it holds against loss, through the use of appropriate physical as well as organizational safeguards.

§5 Purposes for which cookies are used

  • Streamline and facilitate access to the Service

  • Personalization of the Service for Users

  • Keeping statistics (users, number of visits, types of devices, link, etc.).

  • Providing community services

§6 Purposes of personal data processing

Personal data voluntarily provided by Users are processed for one of the following purposes:

  • Realization of electronic services:

    • Services for sharing information about the content posted on the Site on social networks or other sites.

  • Administrator's communication with Users on matters related to the Service and data protection

  • To ensure the legitimate interest of the Administrator

Data about Users collected anonymously and automatically is processed for one of the following purposes:

  • Keeping statistics

  • To ensure the legitimate interest of the Administrator

§7 Types of data collected

The Service collects data on Users. Part of the data is collected automatically and anonymously, and part of the data is personal data provided voluntarily by Users when signing up for particular services offered by the Service.

Anonymous data collected automatically:

  • IP address

  • Browser type

  • Screen resolution

  • Approximate location

  • Openable subpages of the website

  • Time spent on the relevant subpage of the website

  • Type of operating system

  • Previous subpage address

  • Address of the referring page

  • Browser language

  • Internet connection speed

  • Internet service provider

Data collected during registration:

  • Name,

  • Email address,

  • Phone number,

  • IP address (collected automatically)

Part of the data (without identifying information) may be stored in cookies. Part of the data (without identifying data) may be transferred to a statistical service provider.

§8 Access to personal data by third parties

As a rule, the only recipient of personal data provided by Users is the Administrator. Data collected as part of the services provided are not transferred or resold to third parties.

§9 Method of processing personal data

Personal data provided voluntarily by Users:

  • Personal data will not be transferred outside the European Union, unless published as a result of an individual action by the User (e.g., entering a comment or entry), which will make the data available to any visitor to the site.

  • Personal data will not be used for automated decision-making (profiling).

  • Personal data will not be resold to third parties.

Anonymous data (no personal information) collected automatically:

  • Anonymous data (without personal information) will be transferred outside the European Union.

  • Anonymous data (without personal data) will not be used for automated decision-making (profiling).

  • Anonymous data will not be resold to third parties.

§10 Legal grounds for processing personal data

The Service collects and processes Users' data on the basis of:

  • Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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)

    • Article 6(1)(a)

      the data subject has consented to the processing of his/her personal data for one or more specified purposes

    • Article 6(1)(b)

      processing is necessary for the performance of a contract to which the data subject is party, or to take steps at the request of the data subject prior to entering into a contract

    • Article 6(1)(f)

      processing is necessary for the purposes of legitimate interests pursued by the controller or by a third party

  • Law of July 16, 2004. Telecommunications law (Dz.U. 2004 No. 171 item 1800)

  • Act of February 4, 1994 on Copyright and Related Rights (Journal of Laws 1994 No. 24 item 83)

§11 Period of personal data processing

Personal data provided voluntarily by Users:

As a rule, the personal data indicated are kept only for the period of the provision of the Service within the Service by the Administrator. They are deleted or anonymized within a period of up to 30 days after the termination of the Service.

The exception is a situation that requires securing the legitimate purposes of further processing of such data by the Administrator. In such a situation, the Administrator will keep the indicated data, from the time of the User's request to remove them, no longer than for a period of 3 years in case of violation or suspected violation of the provisions of the regulations of the service by the User

Anonymous data (no personal information) collected automatically:

Anonymous statistical data, which do not constitute personal data, are stored by the Administrator for the purpose of service statistics for an indefinite period of time

§12 Rights related to the processing of personal data

  • Right of access to personal data

    Users have the right to obtain access to their personal data, exercised upon request submitted to the Administrator

  • Right to rectification of personal data

    Users have the right to request the Administrator to promptly rectify personal data that is incorrect and/or to complete incomplete personal data, exercised upon request submitted to the Administrator

  • The right to delete personal data

    Users have the right to demand from the Administrator immediate deletion of their personal data, realized upon a request submitted to the Administrator In the case of user accounts, deletion of data consists in anonymization of data enabling identification of the User. The Administrator reserves the right to withhold the execution of a request for data deletion in order to protect the legitimate interest of the Administrator (e.g. when the User has violated the Terms of Use or the data was obtained as a result of conducted correspondence). In the case of the Newsletter service, the User has the possibility to delete his/her personal data by himself/herself, using a link placed in each e-mail message sent.

  • Right to restrict processing of personal data

    Users have the right to restrict the processing of personal data in cases indicated in Article 18 of RODO, including but not limited to questioning the correctness of personal data, exercised upon request submitted to the Administrator

  • The right to transfer personal data

    Users have the right to obtain from the Administrator, personal data concerning the User in a structured, commonly used machine-readable format, executed upon request submitted to the Administrator

  • Right to object to the processing of personal data

    Users have the right to object to the processing of their personal data in the cases specified in Article 21 of the RODO, exercised upon request submitted to the Administrator

  • Right to lodgea complaint

    Users have the right to lodge a complaint with the data protection supervisory authority.

§13 Contact to the Administrator

The Administrator can be contacted in one of the following ways

§14 Service Requirements

  • Restricting the storage of and access to Cookies on the User's Device may result in the malfunction of some features of the Website.

  • The Administrator shall not be held responsible for malfunctioning functions of the Website in case the User restricts in any way the ability to save and read Cookie files.

§15 Social Networks

Sapiens UP Foundation floods pages on the following social networks (hereinafter: "Portals"):

The Sapiens UP Foundation hereby informs you that it has limited influence over the processing of data by the operators of the Social Networking Sites and, in principle, however, the operators of the Social Networking Sites decide how they process your data.

We would like to inform you in this regard that the purpose of data processing on our pages on the Portals is to inform potential partners and customers of the Sapiens UP Foundation about services related to the educational activities carried out, thematic and promotional actions, news at the Sapiens UP Foundation, as well as to interact with visitors to the social networks in search of this information and to answer questions, to allow them to express their opinion about the Sapiens UP Foundation.

The legal basis for data processing on the Portals is Article 6(1)(f) of the RODO. Data processing is carried out in the interest of promotional activities and due service of visitors to the Sapiens UP Foundation websites. In connection with the processing of data on the Portal, you have the rights set forth in §12 of this Policy.

§16 External links

The Service - articles, posts, entries or comments of Users may contain links to external sites with which the Owner of the Service does not cooperate. These links and the sites or files indicated under them may be dangerous to your Device or pose a threat to the security of your data. The Administrator is not responsible for the content outside the Service.

§17 Changes to the Privacy Policy

  • The Administrator reserves the right to change this Privacy Policy at any time without notifying Users regarding the use and application of anonymized data or the use of cookies.

  • The Administrator reserves the right to change this Privacy Policy at any time with regard to the processing of Personal Data, of which it will inform Users with user accounts or subscribed to the newsletter service, via e-mail within 7 days of the change of records. Continued use of the services implies familiarization with and acceptance of the introduced changes to the Privacy Policy. In case the User does not agree with the introduced changes, he/she is obliged to delete his/her account from the Service or unsubscribe from the Newsletter service.

  • Changes made to the Privacy Policy will be published on this subpage of the Website.

  • The changes made shall take effect upon publication.