Data Processing Clause (GDPR)

Who is the Controller of your personal data?

The Controller of your personal data is Prowly.com Sp. z o.o. with registered office in Warsaw (02-549), ul. Madalińskiego 71/1; tax identification number (NIP): 521-364-92-18, hereinafter referred to as “We”, “Us”, or “Prowly.com”.

You can read more about us at prowly.com.

How to contact the data protection officer?

If you’d like to learn more about how we process your personal data, please contact the designated data protection officer within Prowly.com Sp. z o. o.

Select a method of contact that is most convenient for you:

  1. by email at inspektor@prowly.com
  2. by post to the address of Prowly.com Sp. z o. o., that is ul. Madalińskiego 71/1, Warsaw, with a note: “To data protection officer”.

For what purposes do we process your data?

Prowly.com will process your personal data to deliver services provided under the Agreement on the provision of services by electronic means, which provides a basis for processing of your personal data by us.

If you have also voluntarily consented to receiving marketing and commercial information from Prowly.com, we will be processing your personal data also for this purpose.

What are the grounds for the processing of Your data?

We are processing your personal data under Article 6(1)(b) of the GDPR in connection with the Agreement on the provision of services by electronic means. The provision of personal data is voluntary, yet necessary for the performance of the Agreement concluded with Prowly.com.

If you have additionally given consent to the processing of your personal data for other marketing purposes, including for the purpose of distributing commercial information, we will also be processing your data in accordance with Article 6(1)(a) of the GDPR.

Who is the recipient of your personal data?

There are two categories of the recipients of your personal data processed by Prowly.com: you and entities processing Your personal data on behalf of Prowly.com, in order for Prowly.com to be able to realize the processing purposes described in paragraph 3.

Do we transfer your personal data to third countries?

Yes. We transfer the personal data you provide us with to entities located in the United States of America. These entities process your personal data on Prowly.com’s behalf. The companies we work with are holders of the Privacy Shield Program certificates. 
The Privacy Shield Program was designed to ensure a high level of security with regard to the processing of personal data. The Program operates based on Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequacy of the protection provided by the EU-U.S. Privacy Shield (notified under document C(2016) 4176).

For how long are we going to process your data?

We will continue to process your personal data until cooperation has been concluded, that is, upon termination of the Agreement and once Prowly.com determines that a client has no payment claims towards Prowly.com (until Prowly.com’s entitlements are collected through a recovery procedure and completed legal proceedings resulting in a final and legally valid court decision).

As regards the data we process based on the legitimate interests pursued by Prowly.com and based on the consent you have expressed – until the moment you notify objection.

What are your rights in relation to the fact that we process your personal data?

Because Prowly.com processes your personal data, you have the right to request access to your personal data and order their rectification, erasure or restriction of processing. You also have the right to object to the processing of your personal data by Prowly.com, as well as the right to transfer your personal data.

If we are also processing your data under Article 6(1)(a) of the GDPR, that is, if you have given your consent to receiving marketing and commercial information, you have the right to withdraw this consent at any time. The processing of personal data by Prowly.com is lawful from the moment consent has been expressed until it is withdrawn, which shall be the moment when such information has reached Prowly.com. After the completion of the processing for the original purpose, data will not be processed for any other purpose.

If you would like to exercise your rights referred to above, please contact us via email at: inspektor@prowly.com. You can also contact us by postal mail addressed to Prowly. com, ul. Madalińskiego 71/1, Warszawa (02-549).

The right to lodge a complaint

Please be advised that because Prowly.com is processing your personal data, you have the right to lodge a complaint with a supervisory authority.

At present, all complaints may be addressed to the Inspector General for the Protection of Personal Data. However, we would like to inform you that soon the supervisory authority competent in this area may be the President of the Office for the Protection of Personal Data.

The right to object

In the case we process your personal data under Article 6(1)(f), including for the purpose of profiling, you have the right to object, on grounds relating to your particular situation, at any time to the processing of your personal data with regard to the processing of your data by Prowly.com.

With regard to the processing of your personal data by Prowly.com for direct marketing purposes, including profiling, you have the right to object at any time to the processing of your personal data by Prowly.com, to the extent that the processing of your data is related to such direct marketing.

If you would like to exercise the right to object, please contact us via email at: inspektor@prowly.com. You can also contact us by postal mail addressed to Prowly. com, ul. Madalińskiego 71/1, Warszawa (02-549).

The conditions relating to the provision of personal data

Please be advised that under the Agreement concluded with Prowly.com, you are contractually obliged to provide the following personal data (this also being a prerequisite for providing our services):

  1. email address, password, name
  2. company data and address

The provision of data for the purpose of pursuing legitimate interests of Prowly.com is voluntary, yet necessary for the performance of the Agreement.