Privacy Policy of the website SpearDevs.com

We inform you that if you access our Website, available under the address speardevs.com/ we may process your personal data.

We assure you that we care about a security of your data and we make every possible effort to respect your rights. If you are a citizen of one of the countries within European Economic Area, we process personal data according to the provisions of Regulation 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 (General Data Protection Regulation; hereinafter: GDPR).

Who is the controller of your personal data?

SpearDevs Sp. z o.o. with its registered office in Poznań, Poland, address: Karpia 27/14, 61-619 Poznań, entered into the Registry of Entrepreneurs by the District Court Poznań - Nowe Miasto i Wilda in Poznań, IXth Commercial Divison of National Court Registry, under KRS no.: 0000902631, NIP 7861724766, REGON No: 389006828, share capital: 5.000 zl, is the Data Controller of your personal data.

How can you contact a Data Controller?

A contact with a Data Controller is possible via:

mail, by sending a letter to the Data Controller’s address mentioned above,
b. an e-mail by sending a message to the address: admin@speardevs.com

Have we appointed the Data Protection Officer?

We have not appointed a data protection officer as we are not required to do so. Data Controller is solely responsible for all issues related to the processing of personal data.

What are legal basis for processing your personal data?

The specific legal basis and purposes for processing of your personal data are as follows:processing of your personal data are as follows:

Visiting our website	If you visit our website, we may process your personal data in connection with our use of cookie files on our website and with storing personal data concerning entering and using a website (logs). Therefore, we may process your personal data, such as your IP address, data about a device that you use, data about your operating system and your Internet service provider as well as statistical data regarding your activity on a website. In such a case, the legal basis for processing of your personal data is the provision of article 6.1.f) of the GDPR, stating that processing personal data is allowed when it is necessary for the purposes of the legitimate interests pursued by the controller. Our legitimate interest is connected with the need to control the traffic on our website, prevent technical errors and bugs, ensure site security, collect statistical data or prevent abuse and violations of law within the application. When you will enter our website for the first time, we will inform you about our usage of cookie files and ask you for your explicit consent concerning storing these files.
Contacting us via e-mail, contact form or phone	If you use a contact form published on our website and you send us a message via this form or you contact us by a phone or via an e-mail, by using contact details presented on our website, we process your personal data (especially data indicated in a contact form, e-mail message or given during a phone conversation) in order to answer your question and contact you back. The necessity to process your personal data in order to answer your question and contact you constitutes our legitimate interest, and the legal basis for data processing in this regard is the provision of article 6.1.f) of the GDPR.
Subscribing to our mailing list	If you subscribe to our mailing list, the legal basis for processing personal data in this regard is our legitimate interest, that is, providing you with marketing messages. Consequently, we process your personal data on the basis of article 6.1.f) of the GDPR, which states that the processing of personal data is lawful if the processing is necessary for the purposes of the legitimate interests pursued by the controller. However, if a specific legal provisions require us to obtain a prior consent before sending marketing messages, we do not send any e-mails if such a consent has not been given by You.
Being our customer or its representative	We process your personal data if:we provide services for you (you are our client) ,we use your services or support we have any other kind of business cooperation. In such case, the processing is conducted to conclude and perform an agreement between us and you, and the legal basis for processing of personal data is the article 6(1)(b) of the GDPR.However, if you act as our client’s or contractor’s representative, e.g. as a employee or a contact person, we may process your personal data in order to conclude and perform an agreement between us and the organization that you represent. Such situation consists our legitimate interests and the processing of personal data is based on the article 6(1)(f) of the GDPR, which states that processing of personal data is allowed when it is necessary for the purposes of the legitimate interests pursued by the controller. We may also process your personal data in order to comply with obligations imposed on the data controller by legal provisions, including in particular tax law or administrative law - the legal basis for personal data processing in this regard is the need for processing the data to fulfil the legal obligation to which data controller is subject, in accordance with the provisions of article 6.1.c) of the GDPR.
Visiting our social media profiles	We have fan pages within social media such as Facebook, Instagram, Youtube or LinkedIn. If you visit these profiles, we may also process your personal data. This also occurs in connection with, for example, leaving likes or comments on our posts or writing private messages to us. We may also use paid adverts on these social media platforms, which may be displayed to you. In this regard, we process your personal data as a controller, and the legal basis for data processing is our legitimate interest, i.e. the need to process your data in connection with our social media profiles. Thus, the basis for data processing is the provision of article 6(1)f of the GDPR. Notwithstanding the above, personal data that is processed within Facebook, Instagram, Youtube or LinkedIn is also processed by Facebook Ireland Limited and Meta Platforms Inc, registered in Menlo Park, California, USA (in relation both to Facebook or Instagram), Google Ireland Limited (in relation to Youtube) and LinkedIn Corp. They act as a separate controller of your personal data in this respect. If you wish to exercise your rights under the provisions of the Regulation, you can contact us in this regard or directly Facebook, Instagram, Youtube or LinkedIn- if you contact us, we will inform you of this information to which we have access, and we can additionally support you in forwarding your question directly to Facebook, Instagram, Youtube or LinkedIn.
Contacting us to participate in a recruitment process, complete our recruitment form or send us your resume	We process your personal data to conduct the recruitment process. Additionally, if you give us your consent, we process your personal data for the purpose of contacting you for future recruitment. The legal basis for processing your personal data as part of the ongoing recruitment process is article 6(1)(b) of the GDPR, which allows for the processing of personal data when it is necessary to conclude a contract with the data subject. The scope of the processed data is based on the provisions of the Polish Labor Code, which indicates the basic data that an employer may obtain during the recruitment process. In the situation where you provide other data not covered by the Labor Code, the legal basis for the processing of personal data is Article 6(1)(a) of the GDPR, which allows for the processing of personal data on the basis of the data subject’s consent. If you express a wish to participate in future recruitments, the legal basis for processing personal data is also your consent

Who we share your personal data with?

In order to provide you with the ability to use our services, we use support of some external companies. Therefore, personal data that we process may be transferred to:

a provider of cloud services: OVH sp. z o.o. with its registered office in Wrocław
an entity who provides accounting services to us: Biuro Rachunkowe Ewa Szulc with its registered office in Poznań

Within our website we also use Google Analytics to monitor and analyse traffic. This means that we transfer some of users’ personal data to Google Ireland Ltd. and Google LLC – a company based in Mountain View, California. Therefore, we may save Google Analytics’ cookies on your device in accordance with the cookie provisions set out above. The legal basis for transferring data to the USA are Standard Contractual Clauses – special version of an agreement, accepted by the European Commission.

Additionally, in connection with visiting our fanpages on social media platforms, we may provide your personal information to:

Facebook Ireland Limited - this entity processes personal data in connection with visiting our fanpage on Facebook, Instagram or contacting us via Messenger. This entity is a subsidiary of Facebook Inc with headquarters in California, USA. Any transfer of personal data to the USA may take place on the basis of Standard Contractual Clauses, a special agreement, the model of which has been approved by the European Commission,
Google Ireland Limited - this entity processes personal data in connection with visiting our fanpage on Youtube. This entity is a subsidiary of Google LLC with headquarters in California, USA. Any transfer of personal data to the USA may take place on the basis of Standard Contractual Clauses, a special agreement, the model of which has been approved by the European Commission,
LinkedIn Corp. based in San Francisco, California, USA - this entity processes personal data in connection with visiting our fanpage on LinkedIn. Any transfer of personal data to the USA may take place on the basis of Standard Contractual Clauses, a special agreement, the model of which has been approved by the European Commission.

Duration of personal data processing

We store your personal data only as long as we actually need it, and after that we delete it. Therefore, we can inform you that:

if you are a visitor to our website, we process your personal data for as long as you use the website and for up to fourteen months after your last visit,
if you are our client, contractor, or representative of an organization that we cooperate with (we have concluded an agreement), we process your personal data as long as we conduct business cooperation with our client or contractor and up to five years after end of such cooperation,
if you are a person who has written to us using the contact form on our website, contacted us by telephone or by e-mail - we process your personal data for as long as the contact between you and us lasts. After it ends and 3 months have passed, we delete the personal data we have collected in this way,
if you are a person who has visited our social media profile, liked or commented on a social media post or written to us via the Messenger application, we will process your data for as long as our profile exists on such a social media site, however, no longer than for the time that you are a user of such site,
if you are a person who subscribed to our mailing list - we process your personal data until you unsubscribe our mailing list or after termination of marketing activities, basing on a mailing list.
if you are participating in the recruitment process, in the case of processing as part of the ongoing recruitment – we process your personal data until the recruitment process is completed. However, if you have agreed to participate in future recruitment – we process your personal data for a period of up to 1 year from the moment of submission of recruitment documents.

What rights do I have regarding the processing of my personal data?

In connection with processing your personal data, you have the right to:

request access to your personal data,
request rectification of your personal data,
request erasure of your personal data,
request restriction of processing your personal data,
request transferring your personal data, if a data processing is based on your explicit consent or an agreement,
object to the processing of your personal data, if a data processing is based on the legitimate interest of the data controller.

What is more, if you believe that your personal data protection rights were infringed, you have the right to lodge a complaint to the applicable supervisory authority.

We do not process your personal data for the purpose of automated decision-making based on profiling. Presenting advertisements via social media platforms is based solely on general criteria and is not linked to automatic decision making.

Providing personal data is voluntary, but in the case of participation in recruitment, failure to provide the personal data indicated in the contents of Labor Code may result in the inability to consider the candidate as part of the recruitment process.

Cookie files

Due to the fact that you visit our website, we use cookies that may be stored on your device. Cookies are small files that enable or facilitate the use of certain functions of our website. They can be saved on your device directly by us or by third parties with whom we cooperate. In connection with using cookies by us, we may process your personal data, such as your IP address, history of your use of the website, or information about the device or software you use. On our website, we also use other technologies similar to cookies that optimize its functioning, and personal data may also be processed in connection with them. If we refer to cookies in this policy, we also mean technologies similar to cookies. Cookies are used to control the traffic on our website, create statistics concerning the use of our website by its users, undertake marketing activities, prevent errors and technical defects, ensure site security or prevent abuse and violations of law.

We may use two types of cookies:

Session cookies: cookies that are stored on your device during the time you use our website (they are deleted when you close your web browser). Session cookies enable the correct use of our website. Blocking them may result in encountering errors or prevent you from using our website.
Persistent cookies: they are stored on your device until they are deleted. They are used to analyse the traffic on our website. We strive to use only the services of such entities that guarantee the security of your device, software and your data. This also applies to cookies used by these entities.

You have the option of limiting or disabling cookies on your device. Settings regarding the use of cookies can be found in the settings of your web browser. Web browsers allow you to disable all cookies or certain groups of cookies (e.g. from third parties). If you disable cookies just partly, cookies used within our website may be saved on your device, enabling the website to function properly. In this case, however, the cookies of the entities with whom we cooperate will not be saved.

Please be aware that if you will block storing cookies on your device, the use of specific services provided by us may be limited, and in some cases may not be possible.

Cookie	Duration	Description
_ga	1 year 1 month 4 days	The _ga cookie, installed by Google Analytics, calculates visitor, session and campaign data and also keeps track of site usage for the site's analytics report. The cookie stores information anonymously and assigns a randomly generated number to recognize unique visitors.
_ga_*	1 year 1 month 4 days	Google Analytics sets this cookie to store and count page views.
_gat_gtag_UA_*	1 minute	Google Analytics sets this cookie to store a unique user ID.
_gid	1 day	Installed by Google Analytics, _gid cookie stores information on how visitors use a website, while also creating an analytics report of the website's performance. Some of the data that are collected include the number of visitors, their source, and the pages they visit anonymously.