Privacy Policy

1. General Information

The following Privacy Policy sets forth the rules for storing and accessing data on the Devices of Users using the Service for the purpose of providing electronic services by the Administrator, as well as the rules for collecting and processing the personal data of Users that have been provided by them personally and voluntarily through the tools available on the Service.

2 Definitions
  1. Administrator - SAGES Sp. z o.o. based in Warsaw, 62c Nowogrodzka Street.
  2. Personal Data - information about a natural person identified or identifiable by one or more specific factors determining physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, Internet identifier and information collected through cookies and other similar technology.
  3. Policy - this Privacy Policy.
  4. RODO - Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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.
  5. Website - the Administrator's website located at www.sages.pl.
  6. User - any natural person visiting the Service.
3. Administrator and data protection contact

The Administrator of the Users' personal data is Sages Sp. z o.o., based in Warsaw, 62c Nowogrodzka Street. The Administrator has appointed a Data Protection Officer, who can be contacted at the Administrator's address indicated above or via e-mail, at: iod@sages.pl.

4. Purposes and legal basis for processing personal data on the site

In connection with the User's use of the Website, the Administrator collects Personal Data to the extent necessary to provide the various services offered. The detailed rules and purposes of processing the Personal Data collected during the User's use of the Service are described below.

Use of the Service

  1. Personal Data of Users using the Service (including IP address or other identifiers and information collected through cookies or other similar technologies), is processed by the Administrator:1. in order to provide services electronically in the scope of providing Users with access to content collected on the Website - in which case the legal basis for processing is the necessity of processing to perform the contract (Article 6(1)(b) RODO); 2. for the purpose of possible establishment and investigation of claims or defense against claims - the legal basis of processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO), consisting in the protection of his/her rights.

  2. The User's activity on the Website, including his/her Personal Data, is recorded in system logs (a special computer program used to store a chronological record containing information about events and activities that relate to the computer system used to provide services by the Administrator). The information collected in the logs is processed for purposes related to the provision of services. The Administrator also processes them for technical, administrative purposes, for the purposes of ensuring the security of the IT system and the management of this system, as well as for analytical and statistical purposes - in this regard, the legal basis for processing is the Administrator's legitimate interest (Article 6(1)(f) RODO).

Provision of services within the service

  1. Personal data is processed:1. in order to provide the services available within the service - the legal basis for processing is the necessity of processing for the performance of the contract (Article 6(1)(b) RODO); 2. to fulfill public law obligations incumbent on the Administrator, primarily under accounting and tax regulations - the legal basis for processing will be the necessity of processing to fulfill the legal obligations incumbent on the Administrator (Article 6(1)(c) RODO); 3. for analytical and statistical purposes - the legal basis of processing will be the legitimate interest of the Administrator (Article 6(1)(f) RODO), consisting of conducting analysis of Users' activity on the Website and the way they use their account, as well as Users' preferences in order to improve the functionalities used; 4. to survey satisfaction with cooperation with the Administrator or our partners and satisfaction with products or services - the legal basis for the processing of personal data is Article 6(1)(f) RODO, i.e. the realization of the Administrator's legitimate interest in assessing the quality of our service and the level of satisfaction of our customers with products and services 5. for the purpose of possible establishment and investigation of claims or defense against claims - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO), consisting in the protection of its rights; 6. for the Administrator's marketing purposes - the principles of processing Personal Data for marketing purposes are described in the Marketing section.

  2. If a User posts any Personal Data of other persons (including their name, address, telephone number or e-mail address) on the Website, he/she may do so only under the condition that he/she does not violate the law and personal rights of such persons.

  3. Provision of data is voluntary, but necessary for the purposes described above.

Contact forms

  1. The Administrator provides the possibility to contact him using electronic contact forms. Using the form requires providing Personal Data necessary to contact the User and respond to the inquiry. The User may also provide other Personal Data to facilitate the contact or handling of the inquiry. Provision of Personal Data marked as mandatory is required in order to accept and service the inquiry, and failure to provide such Data will result in the impossibility of service. Provision of other Personal Data is voluntary.

  2. Personal Data is processed:1. for the purpose of handling his/her inquiry sent through the form provided - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO); 2. for analytical and statistical purposes - the legal basis for processing is the legitimate interest of the Administrator (Article 6(1)(f) RODO), consisting of keeping statistics on queries submitted by Users via the Service in order to improve its functionality. 3. Providing data is voluntary, but necessary to respond to the inquiry.

Candidates for work or cooperation

  1. The Administrator provides the possibility of submitting applications for the offered positions via forms available through the Website.

  2. Personal data are processed:1. In order to take actions necessary to conclude a contract, at your request (Article 6(1)(b) RODO), 2. To the extent required by law, in particular the Labor Code - on the basis of Article 6(1)(c) RODO, in order to carry out the recruitment process, 3. if the Candidate provides data other than that required by law - on the basis of his/her consent, in order to implement the recruitment process (Article 6(1)(a) RODO, and if special category data is provided, also Article 9(2)(a) RODO), 4. in order to realize the legitimate interest of the Administrator to establish, assert or defend against claims (Article 6(1)(f) RODO and, if special category data is provided, also Article 9(2)(f) RODO), 5. if additional consent is given - for consideration for future recruitment (Article 6(1)(a) RODO).

  3. Provision of data is voluntary, but - to the extent indicated in Article 221 of the Labor Code - necessary for participation in recruitment.

Marketing

The Administrator processes Users' Personal Data in order to carry out marketing activities, which consist of direct marketing of goods and services (including sending commercial information by e-mail and telemarketing activities). The Administrator sends commercial information by e-mail and/or conducts telemarketing activities only if the User has given his/her consent, which can be withdrawn at any time. The transfer of data is based on a legitimate legal interest, which is the possibility of direct marketing (Article 6(1)(f) RODO).

5 Rules for the use of cookies
  1. Your personal data will be processed to provide the basic functions of our website. If you have given the appropriate (voluntary) consent, your data will also be processed to provide you with services, offers and communications tailored to your preferences, and to analyze site traffic and provide social features (depending on the preferences you have indicated).
  2. When you sign up for promotional events or download materials from the site, your personal data is processed by EventLabs Sp. z o.o., which is the owner of Evenea.pl, whose forms we use. EventLabs Sp. z o.o. acts as an intermediary in the transfer of personal data between you and us, as the controller of such data. For additional information regarding the protection of your personal data by EventLabs Sp. z o.o., please refer to their privacy policy.
  3. We use MailChimp, owned by Rocket Science Group LLC, to manage our newsletter subscriber list and to send emails to subscribers. MailChimp, as a third-party provider, may collect and process your personal data using industry standard technologies. This allows us to monitor and improve the newsletter. Additional information on data use policies is available in their privacy policy.
  4. YouTube widgets may be embedded on the site allowing you to play recordings available on YouTube directly from our site. Cookies from Google are used in this process. Cookies are only activated during video playback in accordance with their cookie usage policy.
  5. We may include videos from Vimeo on our pages. The cookies used in this are only activated during video playback in accordance with their cookie usage policy.

Types of cookies

Essential cookies

  1. Essential cookies ensure the proper functioning of our website and its basic functions. Without them, you will not be able to use our online services properly. These cookies are exempt from the requirement to obtain your consent (Article 173, paragraph 3 of the Telecommunications Law).
  2. We use our own cookies to ensure the proper operation of the site, in particular the training order process.
  3. Our site offers the possibility to contact us immediately through our online chat company ALEASYSTENT SP. Z O.O. in accordance with their privacy policy. Thanks to the messenger application, the user can use the chat function without installing software on his device, just by clicking the contact button. During the chat, the agent uses the application equipped with a set of tools that provide him with information about the caller (for example, the sites visited), facilitate communication and allow him to provide the best possible assistance.

Analytical cookies

  1. Our website uses analytical cookies. Analytical cookies allow us to track the number and sources of visits so that we can measure and improve the performance of our website. This type of cookie helps us understand which subpages are most or least visited and how visitors navigate our site. If you refuse to save analytical cookies on your computer or smartphone, your visit will not be included in our statistics, but at the same time it will not limit any functionality on our website for you.
  2. Google Analytics - We use Google Analytics to track our website statistics. Information collected through cookies, such as location, browser, operating system, URLs, etc., is transmitted to and stored by Google Ireland Limited. The cookies contain anonymous data that does not identify you. Google may share this information with third parties in accordance with the law or when processing on behalf of Google. For more details about Google Analytics, cookies, data security and privacy policy, please see their cookie usage policy.
  3. Hotjar - Hotjar helps analyze the behavior of site users using tools such as heat maps, session recordings and surveys to obtain their feedback. This tool complements traditional web analytics methods such as Google Analytics. When you visit our site, Hotjar collects information such as your ISP, the site from which you are coming, the areas of the site you visit, the date and duration of your visit, and device data such as device type, system, screen resolution, language, country and browser type. Your IP address is processed during the session, but is truncated and deleted before being stored on Hotjar's servers. For more on this tool's cookie, see their cookie usage policy.

Marketing and advertising cookies

  1. We use these cookies to personalize the content that is displayed to you. Marketing cookies may be used in our advertising campaigns that are run on third-party websites. If you consent to the use of marketing cookies, you may receive information about the websites of our trusted partners where you have responded to our advertisements. If you opt out of marketing cookies, you will be shown generic and non-personalized ads. As with analytical cookies, if you refuse to save marketing cookies on your computer or smartphone, this will not limit any functionality on our website for you.
  2. Google - This website uses Google Ads, an advertising platform from Google that enables the presentation of sponsored links in Google's search results and ads on Google's collaborative sites, such as remarketing sites in accordance with its cookie use policy. To measure the effectiveness of advertising efforts and optimize them, the site uses a conversion tracking feature. This feature adds cookies to a user's computer when they click on an ad, allowing it to track interest in the site and other conversions from the ad. In addition, the Google Analytics advertising function, when activated, allows you to configure audiences, that is, to create lists of users who have performed a certain action on the site, and then makes these lists available for ad targeting.
  3. Facebook - Our site uses the Facebook pixel to evaluate the effectiveness of advertising the site through Facebook's advertising tools and to optimize the ads presented in accordance with their cookie use policy. The Facebook pixel is a tool that makes it possible to measure the effectiveness of ads by analyzing users' actions on the site. This process involves the use of cookies provided by Facebook. Data from the pixel is used to display ads in front of the appropriate audience, create ad audiences, including so-called look-alikes, analyze the results of ad clicks both using Facebook's advertising tools and on the site itself, and use other Facebook advertising tools such as custom audiences.
  4. Linkedin - LinkedIn Insight Tag is a short JavaScript code added to a website to provide detailed reports on a marketing campaign and visitor information such as URL, referring page, IP address, device information, browser, timestamp and page views. LinkedIn provides aggregate reports without revealing personal information about the site owner. Data is encrypted, identifying information is deleted after 7 days, and data is finally deleted after 90 days. The tag also allows re-targeting of ads, allowing personalized ads to be displayed off the site, with members' information kept confidential in accordance with its cookie use policy.

Consent to the installation of cookies

  1. When you visit our website, a banner will be displayed informing you that it uses cookies. If you select the "Accept all" option, this will mean that you accept all cookies that are placed on our website and confirm that you have read the information about cookies and the purposes of their use, as well as when data collected with the help of cookies is transferred to our partners.
  2. Please note that in the case of essential cookies, your consent is not required, as these types of cookies ensure the full and uninterrupted functioning of our website. These cookies are exempt from the requirement to obtain your consent in accordance with Article 173 (3) of the Telecommunications Law.

No consent to the installation of cookies

If you do not want our cookies to be stored on your device, you can select the "Reject all" option.

Modifying your cookie settings

You can manage your cookie preferences in detail by selecting the "Customize all" box on the cookie banner displayed to you, or by clicking "Change cookie preferences" in the footer at the bottom of the page.

Withdrawing consent

  1. You can disable data tracking, among other things, at a link prepared by Google: https://tools.google.com/dlpage/gaoptout/
  2. Most browsers allow users to manage cookies in their preference settings. However, limiting the ability of sites to set cookies may negatively affect the overall user experience.
  3. Click "Change cookie preferences" at the bottom of the page.

Changes to the cookie policy

We reserve the right to change this cookie policy at any time. Any changes to the cookie policy will be posted on https://www.sages.pl/polityka-prywatnosci.

6 Period of processing of personal data
  1. The period of processing of Personal Data by the Administrator depends on the type of service provided and the purpose of the processing:1. use of the service - for the period of service provision, and otherwise no longer than until an effective objection is raised; 2. provision of services - for the period of service provision, for the time required by law, until an effective objection is raised (in the case of processing on the basis of legitimate legal interest), and in any case no longer than until the statute of limitations for claims; 3. contact forms - for no longer than until you raise an effective objection to the processing; 4. Candidates for employment and cooperation - for a period of 6 months after the end of recruitment, and in the case of consent to participate in future recruitment - not longer than 12 months, and in any case not longer than the statute of limitations for claims; 5. marketing - for as long as necessary to fulfill the purpose, but no longer than until you object (or withdraw your consent to sending commercial information or direct marketing using telephone terminal equipment).

  2. The period for processing Personal Data may be extended if the processing is necessary for the establishment and investigation of possible claims or defense against claims, and thereafter only if and to the extent required by law.

7. User privileges
  1. The User has the right to access the content of Personal Data and to request rectification, deletion, restriction of processing, the right to portability of Personal Data and the right to object to the processing of Personal Data, as well as the right to lodge a complaint with the supervisory authority dealing with the protection of Personal Data.
  2. To the extent that your Personal Data is processed on the basis of your consent, you may withdraw this consent at any time by contacting the Administrator at the Administrator's registered office address and by writing to iod@sages.pl. Withdrawal of consent does not affect the lawfulness of processing performed before its withdrawal.
  3. The User has the right to object to the processing of Personal Data for marketing purposes, if the processing is carried out in connection with the Administrator's legitimate interests, as well as - for reasons related to the User's particular situation - in other cases where the legal basis for the processing of Personal Data is the Administrator's legitimate interest (e.g. in connection with the implementation of analytical and statistical purposes).
8 Data recipients
  1. In connection with the performance of services, Personal Data will be disclosed to external entities, including, in particular, suppliers responsible for the operation of IT systems, entities such as banks and payment operators, entities providing accounting, legal, consulting services, marketing agencies (to the extent of marketing services) and subcontractors engaged by the Administrator to provide services, trainers and lecturers, persons cooperating with the Administrator on the basis of civil law contracts, entities providing services to the Administrator, in the field of delivery of correspondence and parcels, in the field of training service, printing and archiving, payment services,
  2. The Administrator reserves the right to disclose selected information concerning the User to competent authorities or third parties who make a request for such information, based on the relevant legal basis and in accordance with the provisions of the applicable law.
9. Information about automated processing

The controller does not process personal data by automated means or profile data subjects.

10. Transfer of data outside the EEA

The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, the Administrator transfers Personal Data outside the EEA only when necessary and with an adequate level of protection, primarily by:

  1. cooperating with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the determination of an adequate degree of protection for Personal Data;
  2. conducting aTransfer Impact Assessment;
  3. applying standard contractual clauses issued by the European Commission.
10. Privacy policy changes

The Policy is reviewed on an ongoing basis and updated as necessary. The current version of the Policy was adopted and is effective as of July 30, 2024.