Privacy policy
This Privacy Policy (“Policy”) sets out the principles and rules of personal data protection by Flyps Spółka z ograniczoną odpowiedzialnością, registered office in Poznań (ul. Bydgoska 2/8, 61-127 Poznań, Poland), entered in the commercial register under number (KRS): 0000638297, kept by the District Court Poznań – Nowe Miasto i Wilda in Poznań, 8th Commercial Division of the National Court Register, share capital: PLN 10,500.00, tax number (NIP): 9591977339, statistical number (REGON): 365449272 (hereinafter: Flyps).
The principles and rules apply to personal data processed by Flyps in connection with services which it provides, including through www.flyps.io, and personal data processed in connection with the online contact form.
This Policy complies with the personal data protection policy defined in GDPR – 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 (OJ L 119, p. 1), hereinafter “GDPR”, which Flyps has adopted.
We encourage you to read the Policy and, should you have any questions or concerns, please contact us directly.
Personal data controller
The personal data controller is: Flyps (“Controller”), e-mail: [email protected].
General rules of protection
- Legitimacy - Flyps is committed to protecting your privacy and processes data in a legitimate manner.
- Security - Flyps ensures an appropriate level of data security by taking continuous efforts to this end.
- Data subject rights - Flyps enables the data subject to exercise his/her rights and implements them.
Data processed by Flyps
Personal data means any and all information about an identified or identifiable individual. Personal data is not information on the basis of which a specific individual cannot be identified.
The data that can be processed by Flyps (“Data”):
- Identifying information - first name and surname;
- Contact details - telephone number, e-mail address;
- Usage data - describes the use of electronic services, such as ID of the telecommunication network endpoint or user's IT system, or information about the start and end or the scope of each use of Flyps services.
Data collected by Flyps and purposes
The Data is provided to Flyps directly by the data subject when establishing a business contact or other cooperation. The Data is provided on voluntary basis, however without it a contract, contact or cooperation cannot be performed.
| Purpose of processing | Legal basis | Data retention |
|---|---|---|
| Conclusion and performance of a contract, including contacts in performance of the contract | GDPR Article 6(1)(b) (necessary to conclude and perform a contract) | Until the end of the services |
| Complaint processing, including technical issues | GDPR Article 6(1)(f) (legitimate interest of Flyps) | Until the end of the complaint processing or solution of the technical issue |
| Exercise and defence of claims under a contract or connected with the provided services | GDPR Article 6(1)(f) (legitimate interest of Flyps) | Until the end of the statutory time bar |
| Compliance with statutory obligations under tax and accounting regulations | GDPR Article 6(1)(c) (necessary for regulatory compliance) | Until the end of the statutory time bar or the statutory archiving period in accounting |
| Customer contact, including Flyps service marketing | GDPR Article 6(1)(f) (legitimate interest of Flyps) | Until cancellation of the user’s consent to receive communication or information (based on the Electronic Supply of Services Act or the Telecommunications Law) or effective objection to the personal data processing |
| Replying to an enquiry sent through the contact form on the website | GDPR Article 6(1)(a) (consent given in the contact form) | Until cancellation of the user’s consent or the end of the business contact |
| Website usage statistics, improvement of the website and marketing support (PostHog, Google Analytics 4, Hotjar, Snitcher) | GDPR Article 6(1)(a) (consent given in the cookie banner) | Until cancellation of the user’s consent; cookie lifetimes are listed in the cookies policy |
| Customer contact for the purpose of Flyps service marketing | GDPR Article 6(1)(a) (consent) | Until cancellation of the user’s consent or effective objection to the personal data processing |
Data recipients
Flyps may disclose the Data to its contractors and entities entrusted by it with technical processes, such as:
- authorised staff and collaborators;
- external providers of accounting, HR and archiving services;
- external vendors of office software;
- external providers of other services, including IT, programming, website maintenance, as well as website services, tools and scripts used on the website;
- external providers of IT infrastructure, hosting services, mailing tools;
- Pipedrive OÜ, the provider of the customer relationship management (CRM) system to which enquiries sent through the contact form on the website are delivered;
- Usercentrics A/S (Cookiebot), the provider of the cookie banner that records the user’s cookie consent;
- PostHog Inc. (PostHog Cloud EU, data stored in Frankfurt, Germany), Google Ireland Limited (Google Analytics 4) and Hotjar Ltd, the providers of website analytics tools, and Snitcher B.V., the provider of a marketing support tool, only if the user has given consent in the cookie banner.
Rights of data subject
The data subject has the right to:
- request access to the Data, to edit and delete it, to restrict its processing, and to move the data;
- object against the processing of the Data;
- lodge a complaint with the President of the Polish Personal Data Protection Office (UODO) whenever the processing of the Data appears to violate the applicable regulations;
- to cancel the consent to the data processing for marketing purposes, however such cancellation will not affect the legitimacy of any data processing already performed prior to such cancellation.
The scope of the above rights is defined by GDPR.
Marketing activity
Flyps may send marketing information about Flyps via email, with the data subject's express consent. The data subject may opt out of such marketing communication at any time by clicking a link available in the marketing communication, or by contacting Flyps directly at: [email protected].
Cookies policy
Our cookies policy is available at flyps.io/cookies.
Automated decision making
Flyps does not process personal data by automated means, including profiling.
Third country recipients
The user’s personal data may be transmitted to a third country, such as USA, in particular in connection with the Controller's cooperation with its IT infrastructure and hosting providers, its CRM provider (Pipedrive) and website analytics and marketing support providers (PostHog, Google, Hotjar, Snitcher).
The personal data will be transmitted based on standard data protection clauses adopted by the European Commission and, therefore, is covered by adequate safeguards to protect the privacy, rights and freedoms of the data subject. A copy of the standard contract clauses can be obtained from the Controller.
Data retention
The Data is stored in a secure and encrypted form for a period necessary to achieve the purposes for which the Data is processed. In particular, the Data obtained in connection with marketing activities will be processed until the data subject cancels his/her consent.