PRIVACY POLICY

Good morning!

If you've found yourself here, it's an unmistakable sign that you value your privacy. We understand this perfectly, which is why we're presenting you with a document where you'll find, in one place, the principles of processing personal data and the use of cookies and other tracking technologies in connection with the operation of the website https://cloudteam.pl/.

First, some formal information—the administrator of the site is CloudTeam spółka z ograniczoną odpowiedzialnością, Plac Konesera 9, 03-736 Warsaw, registered in the Register of Entrepreneurs of the National Court Register under number 0000276018, whose registration files are kept by the District Court for the Capital City of Warsaw in Warsaw, XIV Commercial Division of the National Court Register, NIP: 5252388265, with a share capital of PLN 854,000.00.

This privacy policy has been constructed in a question-and-answer format. The choice of this form was dictated by our concern for transparency and clarity of the information presented to you. Below you'll find the table of contents of this policy corresponding to the questions we answer sequentially.

1. Who is the administrator of your personal data?

The administrator of your personal data is CloudTeam spółka z ograniczoną odpowiedzialnością, Plac Konesera 9, 03-736 Warsaw, registered in the Register of Entrepreneurs of the National Court Register under number 0000276018, whose registration files are kept by the District Court for the Capital City of Warsaw in Warsaw, XIV Commercial Division of the National Court Register, NIP: 5252388265, with a share capital of PLN 854,000.00.

2. Who can you contact regarding the processing of your personal data?

As part of implementing data protection in our organization, we've decided not to appoint a Data Protection Officer since it's not mandatory in our situation. For matters related to data protection and broadly understood privacy, you can contact us at prywatnosc@cloudteam.pl.

3. What information do we have about you?

Depending on the purpose, we may process the following information about you:

• Name and surname,
• Email address,
• Phone number,
• Data contained in correspondence addressed to us.

We've precisely described the scope of processed data in relation to each processing purpose. Information in this regard can be found in the further part of this policy.

4. Where do we get your personal data from?

In most cases, you provide them to us yourself. This happens when you:

• Submit a request for an offer,
• Register for training,
• Submit complaints or withdraw from a contract,
• Subscribe to the newsletter,
• Contact us.

5. Are your data safe?

We care about the security of your personal data. We've analyzed the risks associated with individual data processing processes and implemented appropriate security measures and data protection. We continuously monitor our technical infrastructure, train our staff, review the procedures used, and introduce necessary improvements. If you have any questions regarding your personal data, we're at your disposal at prywatnosc@cloudteam.pl.

6. For what purposes do we process your personal data?

There are multiple purposes. Below is a list, followed by a more detailed discussion. We've also assigned appropriate legal bases for processing to each purpose.

• Handling a request for an offer – Art. 6(1)(b) GDPR,
• Handling complaints or withdrawal from a contract – Art. 6(1)(f) GDPR,
• Sending the newsletter – Art. 6(1)(a) GDPR,
• Handling correspondence – Art. 6(1)(f) GDPR,
• Fulfilling tax and accounting obligations – Art. 6(1)(c) GDPR,
• Creating an archive for potential defense, establishment, or pursuit of claims, and identifying returning customers – Art. 6(1)(f) GDPR.

Request for an Offer and Contract Conclusion – Details

When submitting a request, you must provide data necessary to prepare an offer and contact you. Providing data is voluntary but necessary to prepare the offer.

Each inquiry is saved in our database, meaning your personal data assigned to the inquiry is accompanied by information regarding the inquiry, such as selected training courses.

Data collected in connection with the inquiry are processed for the purpose of concluding a contract (Art. 6(1)(b) GDPR), issuing an invoice (Art. 6(1)(c) GDPR in conjunction with invoicing regulations), including the invoice in accounting documentation, fulfilling tax and accounting obligations (Art. 6(1)(c) GDPR in conjunction with tax and accounting regulations), and for archival purposes for potential defense, establishment, or pursuit of claims, as well as identifying returning customers, which is our legitimate interest (Art. 6(1)(f) GDPR).

Collected data will be processed for the time necessary to handle the inquiry and then until the expiration of claims arising from the concluded contract. After this period, data may still be processed for archival purposes in case of potential defense, establishment, or pursuit of claims, and identifying returning customers. Remember that we're also obliged to store accounting documentation, which may contain your personal data, for the period required by law.

Complaints and Contract Withdrawals – Details

If you file a complaint or withdraw from a contract, you provide personal data contained in the complaint or withdrawal statement, including name, address, phone number, email, and bank account number. Providing data is voluntary but necessary to file a complaint or withdraw.

Data provided in connection with filing a complaint or withdrawing are used to implement the complaint or withdrawal procedure and then for archival purposes, which is our legitimate interest (Art. 6(1)(f) GDPR).

Data will be processed for the time necessary to carry out the procedure. Complaint documents will be stored until the expiration of warranty rights. Withdrawal statements will be stored with accounting documentation for the period required by law.

Newsletter – Details

By subscribing to the newsletter, you provide us with your name and email address. Providing data is voluntary but necessary to subscribe.

Data provided are used to send you the newsletter, based on your consent (Art. 6(1)(a) GDPR) given during subscription. For processing information not provided by you but collected automatically by our mailing system, we rely on our legitimate interest (Art. 6(1)(f) GDPR) in analyzing subscriber behavior to optimize mailing activities.

You can unsubscribe at any time by clicking the link in each newsletter message or contacting us. Despite unsubscribing, your data will still be stored to identify returning subscribers and for potential defense of claims related to sending you the newsletter, which is our legitimate interest (Art. 6(1)(f) GDPR).

You can modify your data for receiving the newsletter at any time by clicking the appropriate link in each message or contacting us.

Handling Correspondence – Details

When you contact us, you naturally provide your personal data contained in the correspondence, especially your email address and name. Providing data is voluntary but necessary to establish contact.

Your data is processed to contact you, based on our legitimate interest (Art. 6(1)(f) GDPR). After contact ends, the legal basis is also our legitimate interest in archiving correspondence for future evidence (Art. 6(1)(f) GDPR).

Correspondence content may be archived, and we cannot determine when it will be deleted. You have the right to request correspondence history or its deletion unless archiving is justified by our overriding interests, e.g., defense against potential claims.

Tax and Accounting Obligations – Details

If we issue an invoice to you, it becomes part of accounting documentation, stored as required by law. Your personal data is processed to fulfill our tax and accounting obligations (Art. 6(1)(c) GDPR in conjunction with relevant regulations).

Archiving – Details

We've indicated data storage periods for each processing purpose above. These periods often involve archiving data to ensure the possibility of demonstrating certain facts in the future, recreating cooperation history, correspondence, defense, establishment, or pursuit of claims. We rely on our legitimate interest (Art. 6(1)(f) GDPR).

7. How long will we store your personal data?

Data retention periods are specified separately for each processing purpose. You'll find this information within the details dedicated to each purpose.

8. Who are the recipients of your personal data?

Modern business relies on third-party services. We also use such services, some involving your data processing. External service providers participating in processing your data are:

• Hosting providers,
• Cloud computing service providers for backups,
• Mailing system providers for newsletter subscribers,
• CRM system providers for customer service and archival purposes,
• Invoicing system providers,
• Accounting offices processing data on invoices,
• Courier companies for order delivery,
• Law firms accessing data if necessary,
• Other subcontractors requiring data access.

Your data may also be transferred to tax offices to fulfill tax and accounting obligations. Additionally, if necessary, your data may be disclosed to authorized entities like police, courts, or prosecutor's offices.

We also use tools collecting information about your site usage, such as:

• Operating system and browser information,
• Pages viewed,
• Time spent on the site,
• Page transitions,
• Link clicks,
• Referral source,
• Age range,
• Gender,
• Approximate location,
• Interests based on online activity.

This information doesn't, in our opinion, constitute personal data. As it's collected by external tools, it's processed under their policies. Generally, it's used to provide and improve services, measure ad effectiveness, protect against fraud, and personalize content and ads.

9. Do we transfer your data to third countries or international organizations?

Yes, some data processing operations may involve transferring your data to third countries.

We transfer data when using tools storing data on servers in third countries, especially the USA. Providers guarantee adequate data protection through GDPR-compliant mechanisms, like Privacy Shield participation or standard contractual clauses.

Data storage on servers in third countries occurs with tools like:

• Pipedrive (Pipedrive OÜ, Estonia) – for your name, email, phone number, and other data related to training,
• Microsoft Office 365 (Microsoft Corporation, USA) – for all data processed within Office 365, including synchronized files with OneDrive,
• OpenAI (OpenAI Ireland Limited) – for your name, email, and other data related to recruitment and training.

Both Microsoft Office and Pipedrive ensure adequate data protection through GDPR mechanisms, including Privacy Shield participation. Below are links to their Privacy Shield certifications:

• Pipedrive: https://www.privacyshield.gov/participant?id=a2zt0000000TSfxAAG&,
• Office 365: https://www.privacyshield.gov/participant?id=a2zt0000000KzNaAAK&.

We also remind you that we use external tools that may collect anonymous information about you, with providers often using servers worldwide, including the USA.

10. Do we use profiling? Do we make automated decisions based on your personal data?

We do not make decisions based solely on automated processing, including profiling, that would produce legal effects or similarly affect you.

We use tools that may take certain actions based on tracking information, but we believe these don't significantly affect you, as they don't differentiate your customer status or affect contract terms.

Using certain tools, we may direct personalized ads to you based on previous actions on our site or suggest products of interest. This is called behavioral advertising. We encourage you to learn more about it, especially regarding privacy. Detailed information and settings management can be found here: https://www.youronlinechoices.com.

We emphasize that we don't have access to information that would identify you. The information includes:

• Operating system and browser information,
• Pages viewed,
• Time spent on the site,
• Page transitions,
• Referral source,
• Age range,
• Gender,
• Approximate location,
• Interests based on online activity.

We don't combine this information with your personal data in our databases. It's anonymous and doesn't allow us to identify you. This information is stored on providers' servers, often located worldwide.

11. What rights do you have regarding your personal data?

GDPR grants you the following rights:

• Right to access your data and receive a copy,
• Right to rectify your data,
• Right to erase data (if you believe there's no basis for processing),
• Right to restrict processing (e.g., if data is incorrect or processed unjustifiably),
• Right to object to processing based on legitimate interest,
• Right to data portability,
• Right to withdraw consent if processing is based on consent,
• Right to lodge a complaint with a supervisory authority.

These rights are detailed in Articles 16–21 of GDPR. They aren't absolute and may not apply to all processing activities.

You always have the right to lodge a complaint if you believe we've violated data protection laws. You can request information about your data by emailing prywatnosc@cloudteam.pl. We've made efforts to present comprehensive information in this privacy policy.

12. Do we use cookies and what are they?

Our website, like most others, uses cookies.

Cookies are small text files stored on your device (e.g., computer, tablet, smartphone) that can be read by our system (first-party cookies) or third-party systems. Certain information can be stored and accessed for specific purposes.

Some cookies are deleted after closing your browser (session cookies). Others remain to recognize your browser on the next visit (persistent cookies).

For more about cookies, you can read: https://en.wikipedia.org/wiki/HTTP_cookie.

13. On what basis do we use cookies?

We use cookies based on your consent, except when necessary for electronic service delivery.

We assume your consent through browser settings or additional cookie management software. We assume you agree to all cookies not blocked by your browser or software.

Remember, disabling or limiting cookies may prevent some website functions and cause difficulties. For example, blocking social media plugin cookies may make buttons, widgets, and social features unavailable.

14. Can you disable cookies?

Yes, you can manage cookie settings in your browser. You can block all or selected cookies, block cookies from specific sites, and delete previously saved cookies.

Browsers offer incognito mode, which doesn't save visited sites and downloads in history. Cookies created in incognito mode are deleted when all windows are closed.

Plugins like Ghostery (https://www.ghostery.com) allow cookie control. Additional software, like antivirus packages, may offer cookie management.

Online tools allow control over certain cookies, especially for behavioral advertising settings (e.g., https://www.youronlinechoices.com, https://optout.networkadvertising.org/).

Remember, disabling or limiting cookies may prevent some website functions and cause difficulties.

15. For what purposes do we use our own cookies?

Our own cookies ensure proper functioning of site mechanisms, like maintaining sessions after logging in, remembering recently viewed products, and items added to the cart.

Information about your cookie settings is also stored in our own cookies.

16. What third-party cookies are used?

Our website uses the following third-party cookies:

• Google Analytics,
• Google Tag Manager,
• Google AdWords,
• Facebook Custom Audiences,
• CallPage,
• YouTube.

Details are described below.

Google Analytics – Details

We use Google Analytics provided by Google LLC. We carry out activities based on our legitimate interest in creating statistics and analyzing them to optimize our websites.

We've implemented a special tracking code in our site, which uses Google Analytics cookies. You can block this code by installing a browser add-on: https://tools.google.com/dlpage/gaoptout.

Google Analytics collects information about your site usage automatically. This information is usually transmitted to Google's servers worldwide.

Due to IP anonymization, your IP address is shortened before transmission. Only in exceptional cases is the full IP transmitted and shortened by Google. The anonymized IP is generally not combined with other Google data.

We don't collect data that would identify you. The information includes:

• Operating system and browser information,
• Pages viewed,
• Time spent on the site,
• Page transitions,
• Referral source.

We also use Advertising Features like demographic and interest reports, remarketing, advertising reporting features, and user-ID. We still don't collect personal data but access information like age range, gender, approximate location, and interests.

Google Analytics services are ISO 27001 certified. For more about how Google uses data, visit: https://policies.google.com/technologies/partner-sites.

Google Tag Manager – Details

We use Google Tag Manager to manage tags (small code fragments) for controlling traffic, user behavior, ad effectiveness, and site improvement. It doesn't collect information that identifies you but may activate other tags that do collect data.

Google AdWords – Details

We use Google AdWords remarketing features based on our legitimate interest in marketing our products or services.

When you visit our site, a Google remarketing cookie is placed on your device, collecting activity information. This allows us to display ads within the Google network based on your site behavior.

We don't collect data that identifies you. Google may process such data under its agreement with you.

If you don't want personalized ads, manage settings here: https://adssettings.google.com/.

For more about how Google uses data, visit: https://policies.google.com/technologies/partner-sites.

Facebook Custom Audiences – Details

We use Facebook Ads' Custom Audiences feature based on our legitimate interest in marketing.

We've implemented Facebook Pixel, which collects information about your site usage. This information is anonymous to us but may be combined by Facebook with other data.

For Facebook's privacy policy, visit: https://www.facebook.com/privacy/explanation. Manage your ad settings here: https://www.facebook.com/ads/settings.

CallPage – Details

We use CallPage, administered by CallPage sp. z o.o. It allows instant contact by providing your phone number in a widget on our site.

The script uses cookies, but we don't have access to identifying information.

For CallPage's privacy policy, visit: https://www.callpage.pl/polityka-prywatnosci-2018.

YouTube – Details

We embed YouTube widgets to play videos directly from our site. Videos are embedded in privacy-enhanced mode, meaning no cookies are stored until you play the video.

When you play a video, YouTube may store cookies and receive information about your activity. If logged into Google, they may associate data with your account.

For YouTube's terms and privacy policy, visit:

• Terms: https://www.youtube.com/t/terms,
• Privacy: https://policies.google.com/privacy.

17. Do we track your behaviors on our site?

Yes, we use Google Analytics, Google AdWords, and Facebook Custom Audiences, which collect information about your activities. These tools are detailed in the third-party cookies section.

18. Do we direct targeted ads to you?

Yes, we use Facebook Ads and Google Ads to direct ads to specific target groups based on criteria like age, gender, interests, profession, or prior site actions. These tools are detailed in the third-party cookies section.

19. How can you manage your privacy?

As mentioned throughout this policy, you can manage your privacy through:

• Browser cookie settings,
• Browser plugins like Ghostery,
• Additional cookie management software,
• Browser incognito mode,
• Behavioral advertising settings: https://www.youronlinechoices.com,
• Google Analytics Opt-out: https://tools.google.com/dlpage/gaoptout,
• Google Ads Settings: https://adssettings.google.com,
• Facebook Ads Settings: https://www.facebook.com/ads/settings.

20. What are server logs?

Using the site involves sending requests to the server. Each request is saved in server logs, including your IP address, server date and time, browser and operating system information. Logs are stored on the server and aren't associated with specific users or used to identify you. They help administer the site and aren't disclosed except to authorized personnel.

21. Is there anything else you should know?

As you can see, the topics of data processing, cookies, and privacy management are quite complex. We've made every effort to provide you with comprehensive information. If anything is unclear, you want to learn more, or simply discuss your privacy, write to us at prywatnosc@cloudteam.pl.