(1) This Privacy Policy sets out the rules for the processing of personal data obtained through the Online Platform www.studiaanglia.pl (hereinafter referred to as the “Online Platform”).
(2) The owner of the Online Platform and at the same time the data controller is PL RECRUITMENT LTD with its registered office at Aw House, 6-8 Stuart St, Luton, Bedfordshire, England, LU1 2SJ, Company number 11533940.
(3) Personal data collected by PL RECRUITMENT LTD through the Online Platform is processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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), also referred to as the DPA.
4 PL RECRUITMENT LTD takes special care to respect the privacy of Customers visiting the Online Platform.
§ 1 Type of data processed, purposes and legal basis
(1) PL RECRUITMENT LTD collects information concerning natural persons performing a legal action not directly related to their activity, natural persons conducting a business or professional activity on their own behalf, and natural persons representing legal persons, or organisational entities which are not legal persons, to which the law grants legal capacity, hereinafter collectively referred to as Customers.
(2) Personal data of the Clients is collected in the case of:
a. applying to study abroad via the Online Platform. Legal basis: necessary for the performance of the contract for the provision of the Account service (Art. 6(1)(b) RODO)
b. to use the contact form service on the Online Platform for the performance of the contract provided electronically. Legal basis: necessary for the performance of the contract for the provision of the contact form service (Article 6(1)(b) RODO)
c. use of the service of notification of availability of the Service for the performance of the contract provided electronically. Legal basis – necessary for the performance of the contract for the provision of the service of notification of the availability of the Goods (Article 6(1)(b) RODO).
d. the use of the opinion posting service for the performance of a contract for a service provided electronically. Legal basis – necessary for the performance of the contract for the service of posting an opinion (Article 6(1)(b) RODO).
e. Customer satisfaction surveys. Legal basis: the necessity of the processing for the fulfilment of the legitimate interest of PL RECRUITMENT LTD to provide and maintain a high quality of service and the level of Customer satisfaction with products and services (Article 6(1)(f) RODO).
f. to arrange an Online Consultation via the Online Platform (Article 6(1)(b) of the DPA).
(3) When using the option of applying online or arranging an Online Consultation on the Online Platform, the Customer shall provide:
a. e-mail address
b. first and last name
c. telephone number
4. when using the contact form service, the Customer shall provide the following data:
a. e-mail address
b. first name and surname
c. phone number
(5) In the case of using the service to post a review, the Customer shall provide his/her first and last name.
6. in the case of a Customer satisfaction survey, PL RECRUITMENT LTD processes the following data:
a. e-mail address
b. first name and surname
(7) When using the Online Platform, additional information may be collected, in particular: the IP address assigned to the Customer’s computer or the external IP address of the Internet provider, domain name, browser type, access time, operating system type.
(8) Navigation data may also be collected from Customers, including information about the links they choose to click on or other actions they take on our Online Platform. Legal basis – legitimate interest (Article 6(1)(f) RODO) to facilitate the use of electronically provided services and to improve the functionality of such services.
(9) For the purposes of establishing, investigating and enforcing claims, certain personal data provided by the Customer as part of the use of the functionality on the Online Platform may be processed, such as name, surname, data on the use of the services, if the claims arise from the way in which the Customer uses the services, other data necessary to prove the existence of the claim, including the extent of the damage suffered. Legal basis – legitimate interest (Article 6(1)(f) RODO) to establish, assert and enforce claims and to defend against claims in proceedings before courts and other state authorities.
(10) The provision of personal data to PL RECRUITMENT LTD is voluntary, in connection with the conclusion of sales contracts or the provision of services via the Online Platform, with the proviso, however, that the failure to provide the data specified in the forms in the process of Application or arranging a Consultation, as well as the attempt to Contact via the Contact form, prevents the service from being provided.
§ 2 To whom is the data made available or entrusted and how long is it stored?
(1) The Customer’s personal data are transferred to the service providers used by PL RECRUITMENT LTD in the operation of the Online Platform. The service providers to whom personal data is transferred, depending on the contractual arrangements and circumstances, are either subject to PL RECRUITMENT LTD’s instructions as to the purposes and means of processing such data (processors) or determine the purposes and means of processing themselves (controllers).
a. Processors. PL RECRUITMENT LTD uses suppliers who process personal data exclusively on the instructions of PL RECRUITMENT LTD. These include, but are not limited to, providers of hosting services, accounting services, providers of marketing systems, systems for Customer satisfaction surveys, systems for analysing traffic on the Online Platform, systems for analysing the effectiveness of marketing campaigns, systems for booking online consultations, systems for enabling the Customer’s anchor with the service provider.
2 Location. The service providers are based in the United Kingdom.
3. personal information of Customers is stored:
a. Where the basis for the processing of personal data is consent, then the Customer’s personal data shall be processed by PL RECRUITMENT LTD for as long as the consent is not revoked, and after revocation of consent for a period of time corresponding to the period of limitation of claims that PL RECRUITMENT LTD may raise and that may be raised against it. Unless a special provision provides otherwise, the period of limitation is six years, and three years for claims for periodic performance and claims relating to the conduct of business.
b. Where the basis for processing is the performance of a contract, then the Customer’s personal data shall be processed by PL RECRUITMENT LTD for as long as is necessary for the performance of the contract, and thereafter for a period corresponding to the period of limitation of claims. Unless a special provision provides otherwise, the period of limitation is six years, and for claims for periodic performance and claims relating to the conduct of business, three years.
(4) Navigation data may be used to provide Customers with a better service, to analyse statistical data and to adapt the Online Platform to Customers’ preferences, as well as to administer the Online Platform.
(5) If a request is made, PL RECRUITMENT LTD shall make personal data available to authorised state authorities, in particular to organisational units of the Prosecutor’s Office, the Police, the President of the Office for Personal Data Protection, the President of the Office for Competition and Consumer Protection or the President of the Office of Electronic Communications.
§ 3 Cookie mechanism, IP address
(1) The Internet Platform uses small files, called cookies. These are stored by PL RECRUITMENT LTD on the terminal device of the person visiting the Online Platform, if the Internet browser allows it. A cookie typically contains the name of the domain from which it originates, its “expiry time” and an individual random number identifying the cookie. The information collected through cookies of this type helps to adapt the services offered by PL RECRUITMENT LTD to the individual preferences and real needs of visitors to the Online Platform. They also provide the opportunity to compile general statistics of visits to the products presented on the Online Platform.
(2) PL RECRUITMENT LTD uses two types of cookies:
a. Session cookies: when the session of a particular browser ends or the computer is switched off, the stored information is deleted from the memory of the device.
b. Persistent cookies: they are stored in the memory of the Customer’s terminal device and remain there until they are deleted or expire. The mechanism of session and persistent cookies does not allow any personal data or any confidential information to be retrieved from the Customers’ computers.
(3) PL RECRUITMENT LTD uses proprietary cookies for:
a. Authenticating the Customer on the Online Platform and ensuring the Customer’s session on the Online Platform.
b. analysis and research, as well as audience auditing and, in particular, to create anonymous statistics that help to understand how Customers use the Web Platform, which enables the improvement of its structure and content.
(4) The mechanism of cookies is safe for the computers of the Clients of the Web Platform. Nevertheless, Customers have the option in their browsers to limit or disable access of cookies to their computers. If this option is used, the use of the Online Platform will be possible, except for functions that by their nature require cookies.
(5) Please see below how you can change the settings of popular web browsers regarding the use of cookies:
a. Internet Explorer browser
b. Microsoft EDGE browser
c. Mozilla Firefox browser
d. Chrome and Chrome Mobile web browsers
e. the Safari and Safari Mobile browser
f. the Opera browser
6 PL RECRUITMENT LTD may collect IP addresses of Customers. An IP address is a number assigned to the computer of a person visiting the Online Platform by an Internet Service Provider. The IP number allows access to the Internet. In most cases, it is assigned to the computer dynamically, i.e. it changes each time you connect to the Internet. The IP address is used by PL RECRUITMENT LTD to diagnose technical problems with the server, to create statistical analyses (e.g. to determine from which regions we record the highest number of visits), as information useful for the administration and improvement of the Web Platform, as well as for security purposes and the possible identification of undesirable automatic programmes that load the server and browse the content of the Web Platform.
7 The Web Platform contains links to other websites. PL RECRUITMENT LTD is not responsible for the privacy practices of such other websites.
§ 4 Rights of the data subject
1. right to withdraw consent – legal basis: article 7(3) RODO.
a. The customer has the right to revoke any consent that PL RECRUITMENT LTD has given.
b. The withdrawal of consent has effect from the moment of withdrawal.
c. The withdrawal of consent does not affect the processing lawfully carried out by PL RECRUITMENT LTD prior to its withdrawal.
d. The withdrawal of consent does not entail any negative consequences for the Customer, but it may prevent further use of services or functionalities that PL RECRUITMENT LTD can lawfully provide only with consent.
2 The right to object to the processing of data – legal basis: article 21 RODO.
a. The Customer has the right to object at any time – on grounds related to his/her particular situation – to the processing of his/her personal data, including profiling, if PL RECRUITMENT LTD processes his/her data based on a legitimate interest, e.g. marketing of PL RECRUITMENT LTD products and services, keeping statistics on the use of particular functionalities of the Online Platform and facilitating the use of the Online Platform, as well as satisfaction surveys.
b. Opting out, in the form of an email, from receiving marketing communications regarding products or services, will imply the Customer’s objection to the processing of his/her personal data, including profiling for these purposes.
c. If the Customer’s objection proves to be valid and PL RECRUITMENT LTD has no other legal basis for processing the personal data, the Customer’s personal data will be deleted, against the processing of which, the Customer has objected
3. the right to erasure (“right to be forgotten”) – legal basis: article 17 RODO.
a. The Customer has the right to request the erasure of all or some personal data.
b. The Customer has the right to request the erasure of personal data if:
i. the personal data are no longer necessary for the purposes for which they were collected or for which they were processed
ii. he/she has withdrawn specific consent on which the processing is based
iii. he/she has objected to the use of his/her data for marketing purposes
iv. the personal data is unlawfully processed
v. the personal data must be erased in order to comply with a legal obligation under Union law or the law of a Member State to which PL RECRUITMENT LTD is subject
vi. the personal data was collected in connection with the offering of information society services
c. Despite a request for erasure of personal data, in connection with the lodging of an objection or withdrawal of consent, PL RECRUITMENT LTD may retain certain personal data insofar as the processing is necessary for the establishment, investigation or defence of claims, as well as for complying with a legal obligation requiring processing under Union law or the law of a Member State to which PL RECRUITMENT LTD is subject.
4. the right to restrict processing – legal basis: article 18 of the RODO.
a. The customer has the right to request the restriction of the processing of his personal data. The submission of a request, pending its consideration, prevents the use of certain functionalities or services, the use of which will involve the processing of the data covered by the request.
b. The Customer has the right to request the restriction of the use of his/her personal data in the following cases:
i. when he or she questions the correctness of his or her personal data, in which case PL RECRUITMENT LTD shall restrict the use of his or her personal data for the time needed to verify the correctness of the data, but for no longer than 7 days
ii. when the processing of the data is unlawful, and instead of deleting the data, the Customer requests the restriction of its use
iii. when the personal data is no longer necessary for the purposes for which it was collected or used but is needed by the Customer to establish, assert or defend claims
iv. when he/she has objected to the use of his/her data, in which case the restriction shall be for the time necessary to consider whether, due to the particular situation, the protection of the Client’s interests, rights and freedoms outweighs the interest pursued by the Administrator in processing the Client’s personal data
5. right of access to data – legal basis: article 15 RODO.
a. The Customer has the right to obtain confirmation from the Controller as to whether it is processing personal data, and if this is the case, the Customer has the right:
i. gain access to his/her personal data
ii. obtain information about the purposes of processing, the categories of personal data processed, the recipients or categories of recipients of such data, the intended period of storage of the Customer’s data or the criteria for determining this period (where it is not possible to determine the intended period of processing), the Customer’s rights under the RODO and the right to lodge a complaint with a supervisory authority, the source of such data, automated decision-making, including profiling, and the safeguards applied in connection with the transfer of such data outside the European Union
iii. obtain a copy of your personal data
6. the right to rectification of your data – legal basis: article 16 RODO.
a. The Customer has the right to request from the Administrator the immediate rectification of personal data concerning him/her that is inaccurate. Taking into account the purposes of the processing, the Data Subject Customer has the right to request the completion of incomplete personal data, including by providing an additional statement, by addressing the request to the email address in accordance with §7 of the Privacy Policy.
7 Right to data portability – legal basis: article 20 RODO.
a. The Customer has the right to receive his/her personal data that he/she has provided to the Administrator and then send it to another personal data controller of his/her choice. The Customer also has the right to request that the personal data be sent by the Administrator directly to such controller, insofar as this is technically possible. In this case, the Administrator will send the Customer’s personal data in the form of a file in csv format, which is a commonly used, machine-readable format that allows for the transmission of the received data to another personal data controller.
(8) In the event that the Customer asserts an entitlement arising from the above rights, PL RECRUITMENT LTD shall either comply with the request or refuse to comply with the request immediately, but no later than within one month after receipt. However, if – due to the complexity of the request or the number of requests – PL RECRUITMENT LTD is not able to comply with the request within one month, it shall comply with the request within another two months informing the Customer in advance – within one month of receipt of the request – of the intended extension of the deadline and the reasons for it.
(9) The Customer may submit complaints, queries and requests to the Administrator regarding the processing of his/her personal data and the exercise of his/her rights.
(10) The Customer has the right to request PL RECRUITMENT LTD to provide a copy of the standard contractual clauses by addressing the request in the manner indicated in §7 of the Privacy Policy.
(11) The Customer has the right to lodge a complaint with the President of the Data Protection Authority in respect of a breach of its data protection rights or other rights granted under the RODO.
§ 5 Services tailored to preferences and interests (profiling)
(1) Profiling means any form of automated Processing of Personal Data which involves the use of Personal Data to evaluate certain personal factors of an Individual, in particular to analyse or forecast aspects relating to that Individual’s performance, economic situation, health, personal preferences, interests, reliability, behaviour, location or movement.
(2) Customers’ personal data may be processed in an automated manner (profiling), but this will not have any legal effect on them or similarly significantly affect the situation of the Customers.
(3) Profiling of personal data by PL RECRUITMENT LTD consists of the processing of Customers’ data in an automated and manual manner, by using them to evaluate certain information about the Customer, in particular to analyse or forecast the Customer’s personal preferences and interests.
(4) In order to reach the Customer with marketing messages outside the Website of the Online Platform, PL RECRUITMENT LTD uses the services of external providers. These services consist of displaying marketing messages on sites other than the Web Platform Site. For this purpose, the third-party providers install, for example, an appropriate code or pixel to retrieve information about the Customer’s activity on the Web Platform Site. For details of the cookies used, please refer to §3. Legal basis – Legitimate interest (Art. 6(1)(f) RODO) to tailor marketing messages to preferences and interests.
(5) In order to reach the Customer with marketing messages via the Online Platform Site, PL RECRUITMENT LTD uses the services of third-party providers. These services consist of displaying marketing messages on the Web Platform Pages. For this purpose, the third-party providers install, for example, an appropriate code or pixel to retrieve information about the Customer’s activity on the Web Platform Site. For details on the cookies used, please refer to §3. Legal basis – Legitimate interest (Art. 6(1)(f) RODO) to tailor marketing messages to preferences and interests.
§ 6 Security management – password
(1) PL RECRUITMENT LTD shall provide Customers with a secure and encrypted connection when transmitting personal data on the Online Platform. PL RECRUITMENT LTD uses an SSL certificate.
(2) PL RECRUITMENT LTD never sends any correspondence, including electronic correspondence, requesting login details, in particular the password to access the Customer’s account.
§ 7 Changes to the Privacy Policy
(1) The Privacy Policy is subject to change, of which PL RECRUITMENT LTD will inform the Customers 7 days in advance.
(2) Questions related to the Privacy Policy should be addressed to our Data Protection Officer: info@plagency.co.uk.
