PRIVACY POLICY

Defines what data we process and under what terms.

TABLE OF CONTENTS:

1. GENERAL PROVISIONS
2. LEGAL BASIS FOR DATA PROCESSING
3. PURPOSE, LEGAL BASIS, AND RETENTION PERIOD FOR DATA PROCESSING ON THE WEBSITE
4. DATA RECIPIENTS ON THE WEBSITE
5. PROFILING ON THE WEBSITE
6. RIGHTS OF THE DATA SUBJECT
7. COOKIES ON THE WEBSITE AND ANALYTICS
8. FINAL PROVISIONS

1. GENERAL PROVISIONS

1. This Privacy Policy of the Website is for informational purposes, which means it is not a source of obligations for Users or Clients of the Website. The Privacy Policy primarily contains rules regarding the processing of personal data by the Administrator on the Website, including the legal basis, purposes, and retention period for personal data processing, as well as the rights of data subjects, and information about the use of cookies and analytical tools on the Website.
2. The administrator of personal data collected through the Website is Patryk Paziewski operating a business under the name WIDEBRAND Patryk Paziewski, registered in the Central Register and Information on Economic Activity of the Republic of Poland maintained by the minister responsible for economy, with: business address: Tarnowska 36/8, 43-300 Bielsko-Biala, and mailing address: Tarnowska 36/8, 43-300 Bielsko-Biala, email address: contact@specodit.com, phone number: +1 (940) 560-3329 — hereinafter referred to as the "Administrator."
3. Personal data on the Website is processed by the Administrator in accordance with applicable law, in particular with 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 (General Data Protection Regulation) — hereinafter referred to as "GDPR" or "GDPR Regulation." The official text of the GDPR Regulation: http://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679
4. Use of the Website is voluntary. Similarly, providing personal data by the User of the Website is voluntary.
5. The Administrator takes special care to protect the interests of persons whose personal data is processed, and in particular is responsible for and ensures that the data collected is: (1) processed lawfully; (2) collected for specified, legitimate purposes and not further processed in a manner incompatible with those purposes; (3) substantively correct and adequate in relation to the purposes for which it is processed; (4) stored in a form that permits identification of data subjects for no longer than is necessary to achieve the purpose of processing; and (5) processed in a manner that ensures appropriate security of personal data, including protection against unauthorized or unlawful processing and against accidental loss, destruction, or damage, using appropriate technical or organizational measures.
6. Taking into account the nature, scope, context, and purposes of processing, as well as the risks of varying likelihood and severity for the rights and freedoms of natural persons, the Administrator implements appropriate technical and organizational measures to ensure that processing is carried out in accordance with this Regulation and to be able to demonstrate this. These measures are reviewed and updated as necessary. The Administrator applies technical measures to prevent unauthorized persons from obtaining and modifying personal data transmitted electronically.

2. LEGAL BASIS FOR DATA PROCESSING

1. The Administrator is entitled to process personal data in cases where — and to the extent that — at least one of the following conditions is met: (1) the data subject has given consent to the processing of their personal data for one or more specified purposes; (2) processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract; (3) processing is necessary for compliance with a legal obligation to which the Administrator is subject; or (4) processing is necessary for the purposes of the legitimate interests pursued by the Administrator or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child.
2. Processing of personal data by the Administrator requires the existence of at least one of the grounds indicated in Section 2.1 of the Privacy Policy. The specific grounds for processing personal data of Users by the Administrator are indicated in the next section of the Privacy Policy — in relation to the given purpose of personal data processing by the Administrator.

3. PURPOSE, LEGAL BASIS, AND RETENTION PERIOD FOR DATA PROCESSING ON THE WEBSITE

1. In each case, the purpose, legal basis, retention period, and recipients of personal data processed by the Administrator result from the actions taken by the given User or by the Administrator.
2. The Administrator may process personal data on the Website for the following purposes, on the following legal bases, and for the periods indicated in the table below:

   Purpose of data processing	Legal basis for data processing	Data retention period
   Use of the Website and ensuring its proper functioning	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) — processing is necessary for the purposes of the legitimate interests pursued by the Administrator	Data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of claims of the Administrator against the data subject arising from the Administrator's business activities. The limitation period is determined by law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for a Sales Agreement two years).
   Maintaining statistics and analyzing traffic on the Website	Article 6(1)(f) of the GDPR Regulation (legitimate interest of the administrator) — processing is necessary for the purposes of the legitimate interests pursued by the Administrator	Data is stored for the duration of the legitimate interest pursued by the Administrator, but no longer than for the period of limitation of claims of the Administrator against the data subject arising from the Administrator's business activities. The limitation period is determined by law, in particular the Civil Code (the basic limitation period for claims related to business activities is three years, and for a Sales Agreement two years).

4. DATA RECIPIENTS ON THE WEBSITE

1. For the proper functioning of the Website, it is necessary for the Administrator to use the services of external entities. The Administrator uses only the services of processors who provide sufficient guarantees of implementing appropriate technical and organizational measures so that processing meets the requirements of the GDPR Regulation and protects the rights of data subjects.
2. The transfer of data by the Administrator does not occur in every case and not to all recipients or categories of recipients indicated in the Privacy Policy — the Administrator transfers data only when it is necessary for the realization of the given purpose of personal data processing and only to the extent necessary for its realization.
3. Personal data of Website Users may be transferred to the following recipients or categories of recipients:
   1. providers of accounting, legal, and advisory services providing the Administrator with accounting, legal, or advisory support (in particular accounting offices, law firms, or debt collection companies) — the Administrator shares collected personal data of the Client with the selected provider acting on their behalf only in the case and to the extent necessary to realize the given purpose of data processing in accordance with this Privacy Policy.
   2. providers of social media plugins, scripts, and other similar tools placed on the Website that enable the browser of the person visiting the Website to download content from the providers of said plugins (e.g., logging in with social media credentials) and to transmit personal data of the visitor to those providers for this purpose, including:
   3. Facebook Ireland Ltd. — the Administrator uses social media plugins of the Facebook service on the Website (e.g., Like button, Share button, or logging in with Facebook credentials), and in connection therewith collects and shares personal data of the User using the Website with Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) to the extent and in accordance with the privacy rules available here: https://www.facebook.com/about/privacy/ (this data includes information about activities on the Website — including information about the device, websites visited, purchases, advertisements displayed, and how services are used — regardless of whether the User has a Facebook account or is logged in to Facebook).

5. PROFILING ON THE WEBSITE

1. The GDPR Regulation imposes on the Administrator the obligation to inform about automated decision-making, including profiling, as referred to in Article 22(1) and (4) of the GDPR Regulation, and — at least in those cases — meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject. With this in mind, the Administrator provides in this section of the Privacy Policy information regarding possible profiling.
2. The Administrator may use profiling on the Website for the purposes of direct marketing, but the decisions made on its basis by the Administrator do not affect the ability to use Electronic Services on the Website.
3. The data subject has the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning them or similarly significantly affects them.

6. RIGHTS OF THE DATA SUBJECT

1. Right of access, rectification, restriction, erasure, or portability — the data subject has the right to request from the Administrator access to their personal data, their rectification, erasure ("right to be forgotten"), or restriction of processing, and has the right to object to processing, as well as the right to data portability. Detailed conditions for exercising the above-mentioned rights are set out in Articles 15-21 of the GDPR Regulation.
2. Right to withdraw consent at any time — a person whose data is processed by the Administrator on the basis of expressed consent (under Article 6(1)(a) or Article 9(2)(a) of the GDPR Regulation) has the right to withdraw consent at any time without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal.
3. Right to lodge a complaint with a supervisory authority — the person whose data is processed by the Administrator has the right to lodge a complaint with a supervisory authority in the manner and mode specified in the provisions of the GDPR Regulation and Polish law, in particular the Personal Data Protection Act. The supervisory authority in Poland is the President of the Personal Data Protection Office.
4. Right to object — the data subject has the right at any time to object — on grounds relating to their particular situation — to the processing of personal data concerning them based on Article 6(1)(e) (public interest or tasks) or (f) (legitimate interest of the administrator), including profiling based on those provisions. In such a case, the Administrator may no longer process this personal data unless it demonstrates compelling legitimate grounds for processing which override the interests, rights, and freedoms of the data subject, or grounds for the establishment, exercise, or defense of legal claims.
5. Right to object to direct marketing — where personal data is processed for direct marketing purposes, the data subject has the right at any time to object to the processing of personal data concerning them for such marketing, including profiling, to the extent that processing is related to such direct marketing.
6. To exercise the rights referred to in this section of the Privacy Policy, you may contact the Administrator by sending an appropriate message in writing or by email to the Administrator's address indicated at the beginning of the Privacy Policy, or by using the contact form available on the Website.

7. COOKIES ON THE WEBSITE AND ANALYTICS

1. Cookies are small pieces of text information in the form of text files sent by the server and stored on the side of the person visiting the Website (e.g., on the hard drive of a computer, laptop, or on the memory card of a smartphone — depending on which device the visitor uses to access our Website). Detailed information about cookies, as well as their history, can be found, among other places, here: https://en.wikipedia.org/wiki/HTTP_cookie.
2. Cookies that may be sent by the Website can be divided into different types according to the following criteria:

   By their provider: 1) own (created by the Administrator's Website) and 2) belonging to third parties (other than the Administrator)	By their retention period on the device of the person visiting the Website: 1) session cookies (stored until logging out of the Website or closing the web browser) and 2) persistent cookies (stored for a specified period defined by the parameters of each file or until manually deleted)	By their purpose: 1) essential (enabling the proper functioning of the Website), 2) functional/preference (enabling the Website to be adapted to the preferences of the visitor), 3) analytical and performance (collecting information about how the Website is used), 4) marketing, advertising, and social (collecting information about the visitor to the Website in order to display personalized advertisements and conduct other marketing activities, including on websites other than the Website, such as social media portals)

3. The Administrator may process data contained in cookies when visitors use the Website for the following specific purposes:

   Purposes of using cookies on the Administrator's Website	identifying Users as logged in on the Website and showing that they are logged in (essential cookies)
   	maintaining anonymous statistics showing how the Website is used (statistical cookies)

4. Checking which cookies (including the lifespan and provider of the cookies) are currently being sent by the Website in the most popular web browsers is possible in the following way:

   In Chrome: (1) click the padlock icon in the address bar on the left, (2) go to the "Cookies" tab.	In Firefox: (1) click the shield icon in the address bar on the left, (2) go to the "Allowed" or "Blocked" tab, (3) click on "Cross-site tracking cookies," "Social media trackers," or "Tracking content"	In Internet Explorer: (1) click the "Tools" menu, (2) go to "Internet Options," (3) go to the "General" tab, (4) go to "Settings," (5) click "View files"
   In Opera: (1) click the padlock icon in the address bar on the left, (2) go to the "Cookies" tab.	In Safari: (1) click the "Preferences" menu, (2) go to the "Privacy" tab, (3) click "Manage Website Data"	Regardless of browser, using tools available, for example, at: https://www.cookiemetrix.com/ or: https://www.cookie-checker.com/

5. By default, most web browsers available on the market accept the storage of cookies. Everyone has the option to define the conditions for using cookies through the settings of their own web browser. This means that you can, for example, partially restrict (e.g., temporarily) or completely disable the storage of cookies — in the latter case, however, this may affect some functionalities of the Website.
6. Web browser settings regarding cookies are important from the perspective of consent to the use of cookies by our Website — in accordance with the law, such consent may also be expressed through web browser settings. Detailed information on changing cookie settings and their manual deletion in the most popular web browsers is available in the browser help section and on the following pages:
   1. in Chrome
   2. in Firefox
   3. in Internet Explorer
   4. in Opera
   5. in Safari
   6. in Microsoft Edge
7. The Administrator may use Google Analytics and Universal Analytics services on the Website, provided by Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland). These services help the Administrator maintain statistics and analyze traffic on the Website. The collected data is processed within the above services to generate statistics helpful in administering the Website and analyzing Website traffic. This data is aggregated in nature. When using the above services on the Website, the Administrator collects data such as the sources and medium of acquiring Website visitors and their behavior on the Website, information about devices and browsers from which they visit the site, IP and domain, geographic data, and demographic data (age, gender) and interests.
8. It is possible to easily block the sharing of information about your activity on the Website with Google Analytics — for this purpose, you can, for example, install a browser add-on provided by Google Ireland Ltd., available here: https://tools.google.com/dlpage/gaoptout?hl=en.

8. FINAL PROVISIONS

1. The Website may contain links to other websites. The Administrator encourages you to review the privacy policy established on those other sites after navigating to them. This Privacy Policy applies only to the Administrator's Website.