[GDPR] Privacy Policy

PRIVACY POLICY

This Privacy Policy determines the terms and conditions regulating the processing of personal data of persons who subscribe to our Newsletter or who write to us. The Policy is for information purposes and serves satisfaction of information obligations imposed on the data controller under GDPR.

1. DATA CONTROLLER AND SCOPE OF DATA PROCESSING

1. The controller of your personal data (hereinafter referred to as LEOCODE) collected by the website www.leocode.com (hereinafter referred to as Website) is Euvic limited with its registered office in Peterborough at 10 Low Cross, Low Cottage, Registered in England and Wales no. 07042716, VAT UE number: GB987856043. LEOCODE is a trading name of Euvic Limited.
2. You may contact LEOCODE via: admin@leocode.com
3. The scope of the processing of your personal data is determined by the scope of data completed by you and sent to LEOCODE by means of a relevant form available on Website pages. The processing of personal data within the frames of Newsletter may concern the following personal data: your first and last name, as well as e-mail and IP address.
4. LEOCODE does not transfer personal data to countries outside the European Union.
5. Your personal data will be processed by LEOCODE until you unsubscribe from the Newsletter or you receive a comprehensive answer to your questions from us.
6. Upon the lapse of the abovementioned time, your data will be deleted, unless their processing is necessary under another legal basis.

2. PURPOSE AND LEGAL BASIS OF DATA PROCESSING

1. Your personal data will be processed by LEOCODE for the following purposes: (a) execution of legal provisions, (b) provision of the Newsletter service, (c) promotional or marketing actions, (d) answering your questions.
2. The legal basis for processing personal data:
   1. in the case referred to in paragraph 2.1(a) is the statutory authorization to process data which are essential to act in accordance with the law;
   2. in the case referred to in paragraph 2.1(b) it is the statutory authorization to process data which is necessary to perform an agreement if the data subject is a party to such agreement, or if it is essential for undertaking certain actions prior to conclusion of an agreement upon request of the data subject;
   3. in the case referred to in paragraph 2.1(c) it is your voluntary consent;
   4. in the case referred to in paragraph 2.1(d) it is the legitimate interests pursued by the controller.
3. Providing personal data is voluntary, but the failure to provide your data and lack of your consent to process personal data marked as obligatory will prevent provision of the Newsletter service for you.

3. RECIPIENTS OF PERSONAL DATA

1. Your personal data may be transferred for processing to entities which enable LEOCODE to run the Newsletter. Such recipients of personal data include: a hosting provider, a company providing maintenance and development services for the Website. 
2. Personal data may also be disclosed to competent state authorities upon their request on the basis of relevant provisions of law or other persons on the basis of your prior consent.
3. Each entity to which LEOCODE transfers your personal data for processing on the basis of a personal data transfer agreement (Transfer Agreement) guarantees an adequate level of security and confidentiality of the processing of personal data. Moreover, the entity processing personal data on the basis of the Transfer Agreement may process your personal data through another entity only upon prior written consent of LEOCODE.
4. Disclosing personal data to unauthorized entities under this Privacy Policy may take place only upon your prior consent.

4. RIGHTS OF DATA SUBJECT

1. Please remember that in the case of the processing of your personal data, you are entitled to:
   1. request LEOCODE to provide you with access to your personal data, to rectify or delete them, to restrict their processing, and the right to object to the processing, as well as the right to data portability;
   2. withdraw the consent towards LEOCODE at any time, without affecting legality of the processing which had been carried out on the basis of the consent before it was withdrawn;
   3. lodge a complaint about LEOCODE with the supervisory authority.
2. In order to exercise the rights indicated in clauses 4.1.1. and 4.1.2., please contact LEOCODE by writing at the e-mail address admin@leocode.com

5. OTHER DATA

The Website may also store https enquiries, therefore the files containing web server logs may store certain data, including the IP address of the computer sending the enquiry, the name of user’s station, if possible, the date and system time of registration on the Website and receipt of the enquiry, the number of bytes sent by the server, the URL address of the page visited by the user before (if the user has entered the System through a link), information concerning user’s browser and the language used, the country from which the user gained access to the Website, information concerning errors occurred by execution of the http transaction, information concerning the number and time of failed attempts to log in to the profile. Web server logs are collected for the purposes of proper administration of the Website. Information is accessible only to persons authorized to administer the Website on the basis of granted authorisations including confidentiality statements in the scope of processing data and relevant safeguards. Files containing web server logs may be analyzed for the purposes of preparing statistics concerning traffic on the Website and occurring errors. Summary of such details does not identify the user.

6. INFORMATION SECURITY

1. LEOCODE guarantees implementation of appropriate technical and organizational means, such as pseudonymisation, which have been designed for the purpose of effective enforcement of the data protection principles, such as data minimisation, and for the purpose of providing the processing with necessary safeguards, so as to meet the GDPR requirements and protect the rights of data subjects. The set of collected personal data referring to you and other persons is stored on a secured server, moreover, the data are also secured by internal procedures of LEOCODE related to the processing of personal data and information security policy.
2. At the same time, LEOCODE states that using the Internet and services provided by electronic means, in particular using publicly available Wi-Fi networks, may pose specific teleinformatic threats, such as: presence and operation of worms, spyware or malware software, including computer viruses, as well as possibility of being exposed to cracking or phishing (fishing passwords) and other. In order to obtain detailed and professional information related to security in the Internet, LEOCODE recommends taking advice from entities specializing in such IT services.

7. COOKIES

1. For the purposes of correct operation of the Website, LEOCODE uses the cookie support technology. Cookies are packages of information stored on a user’s device through the Website, usually containing information corresponding to the intended use of a particular file, by means of which the user uses the Website—these are usually: address of the website, date of publishing, lifetime of a cookie, unique number, and additional information corresponding to the intended use of a particular file.
2. The Website uses two types of cookies: (a) session cookies, which are permanently deleted upon closing the session of the user’s browser; (b) permanent cookies, which remain on the user’s device after closing the session until they are deleted.
3. It is not possible to identify the user on the basis of cookie files, whether session or permanent. The cookie mechanism prevents collection of any personal data.
4. Cookies used on the Website are safe for a user’s device, in particular they prevent viruses or other software from breaking into the device.
5. Files generated directly by LEOCODE may not be read by other websites. Third-Party Cookies (i.e. cookies provided by entities co-operating with LEOCODE) may be read by an external server.
6. The user may individually change the cookies settings at any time, stating the conditions of their storage, through the Internet browser settings or configuration of the service. The user may also individually delete cookies stored on his/her device at any time in accordance with the instructions of the browser producer. The user may also disable storing cookies on his/her device in accordance with the instructions of the browser producer, but this may disable certain parts of or the entire operation of the Website.
7. LEOCODE uses own Cookies for the following purposes: authentication of the user on the Website and preserving user’s session; configuration of the Website and adjustment of content of pages to user’s preferences or conduct; analyses and researches of views, number of clicks and paths of moving on the site for the purpose of improving the appearance and layout of the content on the site, time spent on the site, number and frequency of Website visitors.
8. LEOCODE uses Third-Party Cookies for the following purposes:

1. Details concerning cookie support are available in the settings of the browser used by the user.

8. FINAL PROVISIONS

This Privacy Policy comes into effect as of 28th November 2023r.