Privacy policy

Privacy policy for personal data protection on websites


By visiting our website, you entrust us with your data, which we process for specific purposes, but always with care to protect your privacy. This privacy policy serves as an aid in understanding what data we collect and for what purpose and for what we use it.

The information set out in this document is very important to you, because we have discussed issues related to the processing of personal data, especially regarding the content of new provisions on the protection of personal data, including Regulation of the European Parliament and of the Council (EU) 2016/679 of 27/04/2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data; and the repeal of Directive 95/46 / EC (General Regulation on the Protection of Personal Data), hereinafter referred to as "the GDPR". For this reason, in this document, we inform you about the legal grounds for processing personal data by website’s methods of such data collection and use, as well as the rights of data subjects associated with it.

We recommend you to read this document with care.


What is personal data and how is it processed?

Personal data consists of information about an identified or identifiable individual. The processing of personal data is considered to be every action taken on personal data, irrespective of whether it is done in an automated manner or not, e.g. collecting, storing, fixing, ordering, modifying, browsing, using, sharing, limiting, deleting or destroying. We process your personal data set out in this document for various purposes and during this process various collection methods may be used. the grounds for the legality of processing, use, disclosure and retention periods that are always determined in relation to the purpose for which data is provided by us.

When is this privacy policy applicable?

This privacy policy applies to all cases when we are the Administrator of Personal Data and we process personal data. This applies to both cases when we process personal data obtained directly from the data subject, as well as when we have collected personal data from other sources.

How, based on what legal basis and what type of personal data do we process?

In order to be transparent regarding the methods and legal grounds for processing personal data, as well as the purposes for which this is done, we always provide the necessary information in this regard to every person whose personal data we process. Following the principle set out above, i n this document we present a summary of personal data processing operations based on different legal grounds of the processing process, whenever we indicate the basis for the legality of the data processing based on the legitimate interest of the controller, we try to analyze and balance our interest and the potential impact of the process on the individual whose data is affected (both positive and negative consequences of the process) and the rights of the individual under the provisions.

o Our legitimate interest having the impact on the data subject would prevail over our interests (then we may process personal data if, for example, we have the appropriate consent or require it or allow the law to do so).


Data Administrator

Fulfilling our legal obligation, we inform that Personal Data collected via the website are Co-controlled by Kontomatik sp.z o.o. whose head office is located in Warsaw at 51 Prosta Street and Kontomatik UAB whose head office is located Vilnius, at ul. Upes 23, LT-08128, Lithuania.

You have the right to contact us by sending us a message to the following e-mail address: [email protected]

We protect your privacy, which is why we have appointed a person dealing with the protection of personal data - Data Protection Inspector, with whom you have the right to contact via e-mail ([email protected]) in case of any confusion regarding the processing of your personal data by us.

Categories of individuals whose data may be collected:

The personal data processing on this site applies to:

  • individuals (clients or potential clients) contacting (using contact form) in order to obtain information about the offer or share comments about services or products, as well as contacting them in order to conclude a contract;

  • individuals (website users) using information about the company, services / products made available on the website;

  • individuals (potential employees) who submit their applicagion applications using the form in relation to current recruitment process.


Individuals visiting the website or using the services provided via the website electronically, always have control over the personal data which they provide to us. In other words, our site restricts the collection and use of information about the users to the necessary minimum, required to provide the services at the desired level, pursuant to art. 18 of the Act of 18 July 2002 on the provision of electronic services.

Each time the purpose and scope of data processed by the Data Administrator results

from the necessary minimum associated with the performance of services for the user

in cases:

  • adapting the content of the web page to the user's expectations;

  • analyzing server work problems, preventing possible violations;

  • ensuring security of the website;

  • analyzing website visits statistics, including analyzing demographic data of users visiting the website (information about the region and device from which the connection was made);

  • actions taken by us for you (eg if you want to ask us a question, you may be asked to provide a specific range of personal data).

  1. The purpose of collecting personal data

We collect your personal data in the following instances:

  • in order to tailor the content of the website to your needs and interests, and to manage your website properly. For this purpose, cookies are used on our site (cookies policy) that allow us to recognize the user's device to properly display the page depending on the device or browser used to view it, create statistics that help to understand how users use the website and to identify infringements and ensure the security of the website.

  • in order to enable you to contact us (via the contact form) and to give you a reliable answer depending on the content of the message. To achieve this, we ask you to provide different categories of data. We have tried to ensure that the scope of collected data is adequate (appropriate) and above all, minimal in relation to the goal we want to achieve, understood as:

  • presenting you with a commercial offer in the event of a request for an offer,

  • consideration of a complaint if it is submitted,

  • other, depending on the content of the message sent.

  • in order to request contact from a sales representative;

  • in order to apply for a job in an ongoing recruitment process.

2. The scope of data processed by the website, depending on the purpose for which the data is processed, concern:

  • contact form in the scope of:

  • Personal data (e.g. Name and Surname);

  • Contact details (eg telephone number, e-mail address);

  • Application data (eg education, experience, address of residence, expected remuneration);

  • Data resulting from the content being submitted.

  • website management, in the field of:

  • IP address;

  • Data of the device and type of browser used;

  • Demographic data.

  1. We can also process anonymous data related to visiting our website (so-called logs - IP address, domain). This data is used to generate statistics that help in the administration of the site. This data is aggregate and anonymous, i.e. it does not contain any features identifying individual - the user of the site, and the Logs are not disclosed to third parties, subject to the possibility of sharing information about the IP number, user data of the site at the request of the right holder based on applicable law, state authorities in connection with their proceedings.

  2. Automatic processing of personal data

The information that we collect in connection with the use of our online services / products available on the website may be processed in an automated manner (including

in the form of profiling), however, it will not cause any legal effects to an individual or have any other significant effect. We attach particular importance to profiling and indicate that:

  • we do not process any sensitive data for profiling purposes,

  • for the purpose of profiling, we usually process data that was previously subject to pseudonymisation or such data that we aggregated,

  • if we can not achieve the goal in a different way than by profiling personal data that is not hyper-positively or non-aggregated, we use typical data for this purpose: e-mail and IP address or Cookies,

  • we profile to analyze or forecast personal preferences and interests of people using our site or products or services and matching content found on our site,

  • we profile for marketing purposes, i.e. matching the marketing offer to www. preferences.

  1. Recipients of data

We do not share your personal data with companies, organizations or individuals outside of Kontomatik Sp. z o. o., unless:

  • The user has consented to such an action - in this case, we provide personal data to companies, organizations and individuals outside the Capital Group, if the user agrees.

  • There are legal reasons - in this case we provide personal data to companies, organizations and third parties if we believe in good faith that disclosure, use, preservation or disclosure of data is justified in connection with:

  • striving to meet the requirements of applicable law, regulations, legal processes or legitimate demands of state institutions.

  • enforcing the current Terms of Use (website rules), including the investigation of potential violations;

  • traffic monitoring, time spent, etc.

  • detecting and preventing fraud, as well as solving other problems related to fraud, security and technical issues;

  • protection of property rights or security of the Data Administrator, users of the website and other persons in a manner required or permitted by law.

Change of the processing purpose

We do not anticipate, but we can not rule it out. We know for certain that if the purpose of processing your data changes, we will inform you about this situation so that you are aware and able to exercise your rights accordingly.


The premise of the legal basis for the processing of personal data:

  • processing is necessary for the execution of an agreement in which the data subject is a party of, or to take action at the request of the data subject before concluding the contract (Article 6 (1) (b) OF THE GDPR). This basis refers to data collected through the contact form that has been made available on our website. In this case, providing personal data is necessary to carry out your request for a specific action in accordance with the purpose of processing, e.g., if you do not provide us with an email address, we will not be able to give you an answer to the query in accordance with the message.

We ask you not to provide information from specific categories of personal information via the contact form (such as information on race or ethnicity, political views, religious or philosophical beliefs, trade union membership, information about physical or mental health, genetic data, data biometrics, information about sexual life or sexual orientation and the criminal past). If you provide such information for any reason, we declare that as the Data Administrator in order to ensure the transparency of data processing for a specific purpose, we will delete such content of the message, about which we will inform you to the sentenced email address.

  • Your consent for us to provide you with services and products and to provide you with commercial information services and products via electronic means of communication,

  • in particular, electronic mail in relation to the inquiry sent (Article 6 paragraph 1 point a) of the GDPR),

  • Your consent to process certain categories of data (always for a specific purpose), for which we ask you to give us (Article 6 (1) (a) of the GDPR), for example, consent for data processing in the recruitment process in which you applied for.

  • the need to fulfill the legitimate purposes of the Data Administrator (Article 6 (1) (f) of the GDPR), which is indicated by:

  • website management,

  • exchange of information about the user between entities within the Capital Groupm

  • adapting its content to your needs and expectations, and

  • ensuring the security of your data in cyberspace.


Our goal is to protect you against the negative consequences of processing your personal data. Therefore, optimize storage time of your data collected via the website. We concluded that:

  1. if the Data Administrator processes personal data on the basis of consent, the processing period lasts until the user withdraws the consent or completes the purpose for which they were collected;

  2. if the Data Administrator processes personal data on the basis of a justified interest of the data controller, the processing period lasts until the above mentioned interest (e.g. the period of prescription for civil claims) or the moment of opposition of the data subject, further such processing - in situations where such an objection is in accordance with the law;

  3. if the Data Administrator processes personal data because it is necessary due to the applicable law, the periods of data processing for this purpose are defined by these provisions (for example, it is bound under the law to store User Personal Data for a longer period or if the Data the User's personal data is needed to bring legal charges or to defend against legal charges, the company will keep the User's Personal Data until the end of the relevant storage period or until the relevant charges have been resolved;

  4. in the absence of specific legal or contractual requirements, the basic storage period for records and other documentary evidence drawn up during the performance of the contract for a maximum of 10 years.


Cookies are small text information in the form of text files, sent by the server and saved on the side of the person visiting the website (eg on the hard drive of the computer, laptop or on the smartphone's memory card - depending on which device the visitor uses Our site www).

Detailed information about cookies as well as the circumstances of its’ creation can be found, among others here: ........................... ..


It is important to let you know your rights in relation to the processing of your personal data:

  • At any time you have the right to withdraw your consent, which will stop processing personal data from being processed on the basis of granted consent. The withdrawal of consent does not affect the compliance of the processing of personal data that we have made on the basis of the consent granted prior to its withdrawal. This right can be exercised by sending an e-mail to the following address: [email protected],

  • You have the right to request for removal (right to be forgotten) of your personal data from information systems and files. This right will be implemented by the Administrator, unless the Administrator has the legal obligation to maintain and, at the same time, process the data, despite the right to be forgotten. This right can be exercised by sending an e-mail to the following address: [email protected],

  • You have the right to access your data (requests for a copy of the data). This right can be exercised by sending an e-mail to the following address: [email protected],

  • You have the right to rectify (update data). Please be advised that updating the data will not delete the data before the update, which is related to the obligation of data integrity, processed by the Administrator,

  • You have the right for your data to be processed for a specific purpose. This right can be exercised by sending an e-mail to the following address: [email protected],

  • You have the right to limit processing, including the right to object to the processing of data by reference to a specific situation. Please be advised that the indicated right will only be implemented by the Administrator if the performance of a particular activity does not contradict the applicable law, which obliges the Administrator to process data. This right can be exercised by sending an e-mail to the following address: [email protected],

  • In addition, you have the right to transfer your data from IT systems to a designated entity and to submit a complaint to the Supervisory Office on the activities of the Data Administrator in the processing of personal data.


We do our best to protect users from unauthorized access, unauthorized modification, disclosure and destruction of information held by Kontomatik Sp. z o. o. in particular:

  • we use SSL encryption;

  • We control our methods of collecting, storing and processing information, including physical security measures, to protect against unauthorized access to the system;

  • We provide access to personal data only to employees, contractors and representatives who must have access to them in order to process them for us. In addition, they are contractually required to maintain strict confidentiality,

  • and in the event of failure to fulfill these obligations, they may suffer consequences, including termination of cooperation.


Any questions, concerns or questions regarding the content of this Privacy Policy or the way in which we process your personal data, as well as complaints about these matters (though we hope there will be no need to file such complaints), please email us with details of your complaint address: [email protected]

Any complaints received will be processed and responded to accordingly.

We do not limit contact with us and enable direct contact at the head office of Kontomatik Sp. z o. o. as well as letter contact (by post) or telephone contact and for this purpose we provide the following contact details:

Kontomatik Sp. z o.o.

Prosta 51, 00-838 Warszawa


This privacy policy may be subject to change. User rights resulting from this Privacy Policy will not be restricted without the explicit consent of the user. Any changes to the Privacy Policy will be published on this page, and we will inform you about significant changes (for certain service users this may include sending an appropriate e-mail notification). We also retain previous versions of this Privacy Policy in the archive to allow users to become familiar with them.

The document was last updated on 15/03/2019.

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