Date of publication: 24.05.2021
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What we write about in our Privacy Policy:
Introduction
Useful definitions
Information about cookies
Processing of personal data by Refolks
Newsletter
Who we may transfer your Personal Data to
Plugins and social media
What are your rights
Information clause


1. Introduction
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Refolks Privacy Policy has been developed on the basis of the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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 (hereinafter the GDPR).
The personal data controller of the refolks.com website is Fly On The Cloud sp. z o.o. (hereinafter Fly On The Cloud) seated in Wrocław (50-130), ul. Rzeźnicza 32/33, entered into the register of entrepreneurs kept by the District Court for Wrocław Fabryczna, VI Division of the National Court Register, under the KRS number 0000500884, NIP number 8971797086.
Refolks makes every effort to ensure an adequate level of protection of the website users’ privacy and our business partners. In order for our users to be properly informed, with you and your Personal Data in mind, we have prepared a Privacy Policy (hereinafter the Policy), which takes into account the principles required by law, including the provisions of the GDPR. By reading its content, you will learn what actions we take with regard to your Personal Data. These activities are aimed at ensuring security and fulfilling our obligations as the data controller.
In case of any questions or doubts regarding matters regulated by the Policy, you can always contact us. Contact details are provided in the section Who can you contact.


2. Useful definitions
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Personal Data – information about an identified or identifiable natural person, defined in accordance with the GDPR and Polish regulations on the protection of personal data, e.g. name, surname, identification number, factor determining mental or physiological identity, IP address.
Website – a website available at http://refolks.com, with an SSL certificate installed, which, by encrypting data, secures your Personal Data and their transmission.

Information about cookies

‍Our website uses cookies in order to improve its operation. We also use data collected through cookies for statistical purposes. It is important that you know that cookies do not identify your Personal Data.
Remember that you can adjust cookie settings to your needs at any time. You can do this in the settings of your web browser. For your convenience, we present below information on cookie management for the most popular browsers:
●  Chrome
‍●  Firefox
‍●  Safari.

Changes in cookie settings may affect the operation of the page you are viewing. Please remember, information on cookie management may be found in your browser provider document.
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Cookies do not change the configuration of the device you are using. They make it easier to adjust the content you view to your expectations and preferences, e.g. the language version, proper display of the page on your device, interests or individual needs. Cookies used for authentication allow e.g. easy filling in of forms or logging in.
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The Website uses two basic types of cookies:
- session cookies - temporary files stored on the user's end device until logging out, leaving the website or turning off the software (web browser)
- persistent cookies - files stored in user's end device for the time specified in the cookie file parameters or until they are deleted by the user.
Refolks enables entities offering social plugins to use the cookie mechanism on the Website. These entities are: Facebook, Google, LinkedIn, Instagram. Remember that when using these plugins and logging into the websites of these entities, you should read their privacy policies. More details are provided in the section Plugins and social media.
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We may use cookies for advertising purposes. The idea is to be able to show our users advertisements tailored to their needs. Based on cookies, we also determine whether users have seen a given advertisement and visited the advertiser's website.
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Using the Google Analytics software, the website places a counting code on the user's computer that allows the collection of user data. Please be advised that we are a party to the contract with Google Inc. and we use the mechanism of anonymising the user's IP number. You can object to the collection of data by the Google Analytics software at any time by changing your web browser settings.
In terms of information about user preferences collected by the Google advertising network, the user can view and edit information derived from cookies using the following tool.

3. Processing of personal data by Refolks
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When you provide us with your Personal Data, we become their Controller.
We process your Personal Data on the basis of: 
- Your consent (if applicable), 
- the relevant legal provision (e.g. the grounds indicated by Article 6 of the GDPR) or
- the fact that the processing is necessary for the performance of a contract or taking steps prior to entering into a contract.
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We may process your Personal Data, depending on the basis of our contact, for the purposes of:
- providing services related to our business, e.g. by providing your Personal Data, you enable us to contact you in order to present our offer
- marketing, so that we can inform you about the best and latest offers and functionalities provided by our partners, e.g. in the form of a newsletter
- statistics related to the operation of the website.
More details are provided in the section Information clause.

The maximum scope of Personal Data we process depends on the basis of our relationship and includes:
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The maximum scope of Personal Data we process includes:
- if you use services related to our business or we talk about our possible cooperation: name, surname, company name, e-mail address, telephone number, company name, position, tax identification number, information about your services, information about your company data ( company size, number of employees, contact details of people responsible for cooperation with Refolks)
- if you take part in our webinar / event: name, surname, e-mail address, telephone number, company name, tax identification number
- if you provided data in the contact form / messengers / when downloading an ebook: name, surname, e-mail address, telephone number, company name, tax identification number
- if you give us a consent for processing data for marketing purposes: name, surname, e-mail address, telephone number
- if you use our Website: IP address, device information, cookies, other data that you provide e.g. by filling in the contact form on our Website.
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Please be advised that we do not process specific categories of your Personal Data referred to in Art. 9-10 of the GDPR, such as: ethnic origin, political views or biometric data.
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By using our contact forms or the messengers available on the Website, contacting us via our social media profiles, you consent to the processing of Personal Data by us.
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If we ask you to provide Personal Data on our Website (e.g. for the use of the contact form), you must know that providing it is a condition for concluding an agreement to access the functionalities available on our Website. If you do not provide this data, you will be, unfortunately, unable to use them.
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The period for which Personal Data may be stored depends on the legal basis for processing your Personal Data and the purpose for which they are processed. More details are provided in the section Information clause.

Please be advised that as part of our webinars we use the Meet tool provided by Google Ireland Limited. By joining the webinar via the Meet tool, you agree to the terms of use of this tool and confirm that you have read its privacy policy. If you take part in a webinar organized by us, remember that users who use the webinar as logged-in Google service users will be identified on the webinar user list by the aliases of their Google accounts. If you do not want your Data to be visible on the list during the webinar, please use the option to join the meeting as a not logged user. The Meet tool's privacy policy is available at: https://policies.google.com/privacy


4. Newsletter
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User, on our Website, you can subscribe to the newsletter service (which is a service provided electronically), consisting in sending to the e-mail address provided by you information about: products, promotions, discounts, contests and events related to our business.You will receive newsletter messages no more than twice a month.
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How can you subscribe to our newsletter:

- fill in the form, indicating your e-mail address
- on the form, mark the consent to receive commercial information by electronic means
- confirm the newsletter subscription by clicking the "I confirm subscription" button in the e-mail message we sent to the e-mail address provided by you.
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To unsubscribe from the newsletter service, use the "Unsubscribe" link present in every newsletter message or send an e-mail from the address provided during registration to the following address: info@refolks.com If you have any problems with unsubscribing, please contact us!
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Remember that due to technical reasons, removing your address from the newsletter database may take several days (up to 7).


5. Who we may transfer your Personal Data to
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Please also be informed that from time to time we may transfer or share your Personal Data with entities that cooperate with us e.g. accounting companies, legal advisors, courier companies, advertising companies, hosting providers. The transfer may take place only when we have concluded appropriate agreements with these entities in order to ensure that they will protect your Personal Data at least as responsibly as we do.
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However, the transfer of data to such entities may need to be based under your consent or legal provision e.g. when Refolks processes data on the basis of a legitimate interest.
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If you use services related to our business or we talk about our possible cooperation in terms of services provided by Facebook Ireland Limited, Google Ireland Limited czy Zendesk Inc., information about your services, information about your company data (company size, number of employees, contact details of people responsible for cooperation with Refolks) is transferred to the indicated service provider. The transfer is connected with the performance of our obligations as authorized partners of Facebook, Google and Zendesk.
Due to the fact that for our daily operations we use tools provided by suppliers who may process Personal Data outside the European Economic Area, your Personal Data may also be transferred for processing outside the European Economic Area. In this case, we make sure that the data processing takes place on a legal basis as for example standard contractual clauses. Also remember that such transfer can only take place if the third country or international organization meets the conditions set out in the GDPR.

5. Plugins and social media
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Social media is one of the main ways of contact with our customers and possible customers. Through them, we provide up-to-date information about our activities, services, promotions, news regarding cloud services, and we create a platform for exchange views on cloud services. Therefore, on the basis of Refolks legitimate interest, Personal Data of people using our social media profiles (e.g. in reaching our customers, responding to comments) and the data that we access if you use a social media plugin within our Website (in terms of statistics purposes of our Website).
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Please remember that the processing of Personal Data on social media is subject to the privacy rules of the respective social media provider. Therefore, we encourage you to read the rules of the social media providers we use to maintain our social media profiles:

- Facebook, provided by Facebook Inc. (1601 S. California Ave, Palo Alto, CA 94304, United States of America), and for users within European Union Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) Privacy Policy 
Information on statistics 
- You Tube, provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland) for users within European Economic Area and Switzerland  Privacy Policy 
- LinkedIn, provided by LinkedIn Corporation (1000 W. Maude Avenue, Sunnyvale, CA 94085, United States of America), and for users within European Union, European Economic Area and Switzerland LinkedIn Ireland Unlimited Company (Wilton Plaza, Wilton Place, Dublin 2, Ireland) Privacy Policy
- Instagram, provided by Facebook Inc. (1601 S. California Ave, Palo Alto, CA 94304, United States of America), and for users within European Union Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) Privacy Policy  

If you use our profiles on social media, Refolks also acts as the controller of Personal Data. These data are processed by us on the terms set out in this Policy.
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Additionally, we would like to inform you that in terms of the processing Personal Data in connection with your use of social media plugins available within our Website i.e. for the purposes of so-called web tracking (if applicable), Refolks and the social media provider act as joint controllers of Personal Data in accordance with art. 26 of the GDPR. Remember that web tracking also takes place when you use the plugin as a not logged in social media user.
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Web tracking consists in creating aggregate statistics based on events recorded by social media providers while users use the website. You must know that these events are logged by social media providers without the participation of Refolks. Information regarding Personal Data processing by the social media provider, contact data and information regarding the right to object can be found in social media providers privacy documents indicated above.

6. What are your rights

If you consent to the processing of Personal Data, remember that the consent is given by you voluntarily. You have the right to withdraw your consent at any time. Remember, however, that the withdrawal of consent does not affect the processing carried out by us prior to the withdrawal.
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You have the right to access your Personal Data at any time. You can always ask us, as the Personal Data controller, whether your Personal Data is processed by us, to provide the Data and other information such as: the time of data processing, the purposes of processing, information on who we provide the data to, information on automated decision-making or profiling.

Remember that you also have the right to lodge a complaint with the supervisory body (the President of the Personal Data Protection Office).
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You have the right to rectify your Personal Data by changing or supplementing it.
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You have the right to delete your Personal Data, known as the "right to be forgotten". You can request us to delete your data without undue delay in the following situations:

- the data is not necessary for the purpose of processing or is processed in a different way consent to processing has been withdrawn previously and we have no basis for processing
- you have objected to data processing
- the data was processed unlawfully
- the controller is obliged to delete data resulting from legal provisions
- the data was collected in relation to the offering of Information Society services.

More details about the right to be forgotten can be found in art. 17 of the GDPR.
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You also have the right to restrict processing by the controller. You can request a restriction when:

- you question the accuracy of the data
- the processing is unlawful, but you are opposed to deletion by only requesting a restriction
- the controller no longer needs the data for processing purposes, but you need them to establish, assert or defend claims
- you object to processing, but only until its grounds are resolved.
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If the processing is performed based on consent or in an automated manner, you also have the right to transfer data that we should provide to you at your request in a commonly used format. You can also request that the data be transferred by us directly to another controller.
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If Personal Data is based under art.  6 sec. 1 letter e) or f) of the GDPR You have the right to object to the processing. In this case, we can no longer process your Personal Data, unless we demonstrate the grounds required by the GDPR.
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You also have the right not to be subject to a decision based on automatic processing, including profiling, if such a decision has legal effects on you or otherwise significantly affects you. Please be advised that this right does not apply if: such a decision is necessary for the performance/conclusion of the contract, is permitted by law or is based on your express consent.

7. Information clause

Controller’s data
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The controller of the personal data is Fly On The Cloud sp. z o.o. seated in Wrocław (50-130), ul. Rzeźnicza 32/33, entered into the register of entrepreneurs kept by the District Court for Wrocław Fabryczna, VI Division of the National Court Register, under the KRS number 0000500884, NIP number 8971797086.
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Purpose of processing
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Depending on the circumstances, the provided personal data may be processed for the purposes of:
- answering questions asked in the forms/via messengers available on the website
- receiving marketing e-mails (newsletters), if you consent to it
- signing up for events/webinars/training organised by us
- establishing cooperation as part of the Fly On The Cloud Affiliate Program
- conducting sales talks via emails, social media or phone calls. 

Please be advised that providing data in the contact forms is voluntary, but necessary to use the forms available on the Website.

Legal basis and time of the processing
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- We process the data provided in the contact form/via messengers/when downloading the e-book based on the legitimate interest of the controller, which is communication with users of our website or social media. We will process your data for the time necessary to provide an answer to your question. After this time, the data may be processed by us during the limitation period for any claims.
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- We process the data used for the purpose of sending the newsletter until consent to the processing of this data is revoked.
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- We process the data provided in the event/webinar registration/trainings form on the basis of the legitimate interest of the controller, which is enabling Users to participate in the events/webinars/trainings until the end of the event and after that time for the use of materials from events/webinars/trainings in our social media (Facebook, LinkedIn, YouTube). If you give additional consent to receive information about planned events/webinars/training, you will also receive information on this subject from us.

- We process the data provided in the form regarding the willingness to cooperate in the Fly On The Cloud Partner Program on the basis of the legitimate interest of the controller, which is communication in order to establish this cooperation. We will process your data for the time necessary to establish and implement the cooperation. After this time, the data may be processed by us during the limitation period for any claims.
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- We process the data obtained during sales talks via email, social media or phone calls after obtaining your consent or on the basis of Refolks legitimate interest (e.g. when we answer your questions about services or carry out our activities aimed at acquiring customers). We process the data for the time necessary to examine the needs of our customers and determine the willingness to start the cooperation with us. After this time, the data may be processed by us during the limitation period for any claims.

Personal Data recipients
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The recipients of your data may be relevant state authorities operating on the basis of generally applicable law. Your data may also be transferred to entities, as defined within Who we may transfer your Personal Data to part, processing data at the request of the controller - remember, however, that such entities process data on the basis of a contract with the controller and only in accordance with his/her instructions.
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If you use services related to our business or we talk about our possible cooperation in terms of services provided by Facebook Ireland Limited, Google Ireland Limited czy Zendesk Inc., information about your services, information about your company data (company size, number of employees, contact details of people responsible for cooperation with Refolks) is transferred to the indicated service provider. The transfer is connected with the performance of our obligations as authorized partners of Facebook, Google and Zendesk.

Processing data outside the EEA
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Due to the fact that for our business we use tools whose suppliers may process Personal Data outside the European Economic Area, your Personal Data may also be transferred for processing outside the European Economic Area. In this case, we make sure that the processing takes place on a legal basis, which are, for example, standard contractual clauses.
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Rights of data subject
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You have the right to request the controller to access your personal data, rectify it, delete it or restrict the processing of, as well as the right to withdraw consent if it is expressed and a complaint is lodged with the supervisory body (for Poland: President of Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw). In matters related to data protection, you can contact us at: info@refolks.com

7. Who can you contact

If you have any questions, you can contact us:

- by e-mail: info@refolks.com
- by phone: 71 382 20 00
- by post to the following address: Fly On The Cloud ul. Rzeźnicza 32/33, 50-130 Wrocław

Please be advised that our Policy is subject to change due to new legal and technological developments.However, its latest content will always be available on our Website.

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