Privacy & Cookies Policy

Digital TPA sp. z o.o. sp. k. (the "Service Provider") exercises due diligence to respect the privacy of the Service users.

You can contact the Service Provider at office@digital-tpa.com regarding both personal data protection matters and organisational or technical matters.

The Cookies Policy sets out the rules for storing and accessing data on users' devices using the Service for the purpose of providing electronic services by the Service Administrator. It also specifies the duration of such files and whether third parties may gain access to them.

Users using services provided electronically via the Service are requested to voluntarily provide personal data. The Data Controller processes the obtained data pursuant to Article 6(1)(a) of 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. Consent may be withdrawn at any time.

The purpose and scope of personal data processed by the Data Controller depend on the actions taken by the user in the Service.

Users may provide their personal data to the Data Controller via the contact form available on the Service. Personal data provided via the contact form are processed for the purpose of responding to the submitted message, which constitutes our legitimate interest — communication with website users (Article 6(1)(f) GDPR). The scope of processed data includes: first name, last name, company name, e-mail address, phone number.

With the overriding goal of respecting users' privacy, we exercise due diligence. To achieve this goal, we comply with the norms and rules arising from generally applicable laws. In particular, we make every effort to ensure that users' personal data are:

• processed lawfully, fairly, and transparently for the data subject,
• collected for specific, explicit, and legitimate purposes indicated in this document,
• not further processed in a way incompatible with these purposes,
• factually correct and adequate in relation to the purposes for which they are processed,
• stored in a form that permits identification of the data subject for no longer than necessary to achieve the processing purpose,
• processed in a manner ensuring appropriate security of personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction, or damage.

The Data Controller reserves the right, in accordance with applicable data protection laws, to entrust the processing of users' personal data to other entities in order to properly perform activities related to hosting, administration, maintenance, and management of the Service, as well as to pursue claims or investigate unauthorised use of services provided electronically.

The Data Controller informs the user that personal data are entrusted to entities such as IT companies. Entrustment is always based on a written data processing agreement.

In connection with the processing of personal data, users have the following rights:

• the right to request access to their data, rectification, deletion, or restriction of processing,
• the right to object to the processing of personal data when based on legitimate interest or consent for promotional activities,
• the right to data portability,
• the right to withdraw consent for the processing of personal data for a specific purpose if previously given. Withdrawal does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal,
• the right to lodge a complaint with the supervisory authority in connection with the processing of personal data by the Data Controller.

We or third parties, through cookies they administer, may use pixel tag functionality. These are elements embedded in digital content that allow recording of information, e.g., about the user's activity on the website.

While providing services to users, we use professional technologies to collect and store information, such as cookies. These are small, commonly used files containing a string of characters, sent and stored on the end device (e.g., computer, laptop, tablet, smartphone) used by the user when visiting the Service. This information is sent to the browser's storage, which sends it back upon the next visit to the website. Cookies contain information necessary for proper use of the Service. They usually contain the name of the website they come from, their storage time on the end device, and a unique number.

Users using services provided electronically via the Service are requested to voluntarily consent to the processing of cookies by storing information or accessing information already stored on their telecommunications end devices.

Consent is given in particular by using a button containing a statement of consent to the processing of cookies or confirming awareness of its terms. This consent may be withdrawn at any time, free of charge, as described in the section on cookie management.

We process cookies pursuant to Article 399 of the Act of 12 July 2024 on Electronic Communications Law (Journal of Laws of 2024, item 1221).

The Data Controller uses the following types of cookies:

• Necessary cookies — enable the proper functioning of the Service and the functionalities the user wishes to use, e.g., authentication cookies. Without them, using the Service is impossible.
• Functional cookies — enable remembering settings selected by the user and adapting them to their needs and preferences, e.g., selected language, font size, website appearance. They allow the Data Controller to improve the website's functionality and performance. Without them, some functionalities of the Service may be limited.

By validity period

• Session cookies — with memory lasting up to several days.

By administrator

• Data Controller's cookies
• Third-party cookies

These cookies allow the recognition of the user's device and display of the Service's website adapted to their individual expectations, making the use of functionalities easier and more pleasant. By storing these cookies, it is possible to remember login details, maintain a session after logging in, remember selected products or services, or adapt content layout, language, and colours to user preferences.

The Service Provider may use cookies provided by Google Inc., 1600 Amphitheatre Pkwy, Mountain View, CA 94043, USA, under the following services:

• Google Ads — for conducting and evaluating advertising campaigns using Google Ads,
• Google Analytics — for evaluating advertising campaigns using Google Adwords, as well as studying user behaviour and traffic, and generating traffic statistics,
• Google Tag Manager.

The Data Controller may also use cookies from Facebook Inc., 1 Hacker Way, Menlo Park, CA 94025, USA. These may be used to link a user's account on the external social network Facebook with the Service account, or to process activities performed in Facebook using "Share" or "Like" buttons. Such processing may be public.

Use of third-party cookies is subject to the privacy and cookie policies of these entities. We encourage reviewing their rules for processing personal data and privacy protection.

Most browsers allow cookies and other information to be stored on the end device by default. If the user does not agree, the browser settings must be changed accordingly. It is possible to disable cookies for all connections from a given browser or for a specific site, as well as delete them.

The method of managing cookies depends on the software used, so detailed information on the possibilities and methods of handling cookies can be found in the settings of the browser used to connect to the Service.

The Service may contain links to other websites. We are not responsible for the privacy and cookie policies applied on those sites. We recommend reviewing their privacy and cookie policies.

We reserve the right to amend this Privacy and Cookies Policy. If changes are made, we will publish the updated version in this location.

Regarding the processing of personal data in connection with the use of the helpdesk service of the software www.indexfrog.de.

In fulfilling the information obligation resulting from Regulation (EU) No 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), we inform you that:

• The Controller of your personal data is Digital TPA Sp. z o.o. Sp.k. | pl. Władysława Andersa 5 | 61-894 Poznań | NIP 7831867001 | REGON 523492113 | KRS 0000997190 (the "Controller").
• You can contact Digital TPA Sp. z o.o. Sp.k. via the e-mail address office@digital-tpa.com or in writing at the Controller's registered office address.
• Digital TPA Sp. z o.o. Sp.k. processes personal data (including categories of data such as: first names, surnames, company name, identification numbers and logins, contact details, and information concerning the use of telecommunications tools):
  • for the purpose of concluding and performing the agreement and providing the IndexFrog software support service (helpdesk) — Art. 6(1)(b) GDPR;
  • for archival (evidentiary) purposes, safeguarding information in case of a legal need to demonstrate facts, and for the possible establishment, exercise, or defence of claims, which constitutes our legitimate interest — Art. 6(1)(f) GDPR;
  • in other cases, personal data are processed solely on the basis of prior consent, within the scope and for the purpose specified in the content of the consent — Art. 6(1)(a) GDPR.
• The provision of data is voluntary; however, failure to provide such data makes it impossible to use the IndexFrog software support service (helpdesk).
• Personal data will be stored for the period necessary to perform the Agreement for the use of IndexFrog software, and also for the limitation period of claims arising from the Agreement.
• Personal data may be disclosed to other entities — our partners, i.e. companies with which we cooperate by combining products or services. Our subcontractors (processors), e.g. accounting, legal, or IT service providers, may also have access to the data.
• You have the right to request access to your personal data, as well as their rectification (correction). You also have the right to request their erasure or restriction of processing, as well as the right to object to the processing, provided that this right exists only if further processing is not necessary for the Controller to fulfil a legal obligation and there are no other overriding legal grounds for processing.
• You have the right to lodge a complaint regarding the processing carried out by the Controller with the President of the Personal Data Protection Office (uodo.gov.pl).
• The Controller will not use automated decision-making, including profiling.
• Your personal data may be transferred outside the European Economic Area when the Controller uses services of entities providing IT solutions and systems, which may store personal data on servers located outside this area (including in the United States). Such transfer may take place to a third country for which the European Commission has determined an adequate level of protection, or through the application of appropriate legal safeguards, in particular the standard contractual clauses for data protection approved by the European Commission. You have the right to obtain a copy of the safeguards for personal data transferred to a third country, which may be exercised by contacting the Controller in writing.

Regarding the processing of personal data in connection with the use of the contact form on the website www.indexfrog.de.

In fulfilling the information obligation resulting from Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 (GDPR), we inform you that:

• The controller of your personal data is Digital TPA Sp. z o.o. Sp.k. | pl. Władysława Andersa 5 | 61-894 Poznań | NIP 7831867001 | REGON 523492113 | KRS 0000997190 (the Controller).
• You can contact Digital TPA Sp. z o.o. Sp.k. via e-mail office@digital-tpa.com or in writing at the address of the Controller's registered office.
• Digital TPA Sp. z o.o. Sp.k. processes personal data for the purposes of pursuing our legitimate interests (Art. 6(1)(f) GDPR), namely:
  • responding to questions submitted via the contact form (until a reply has been provided to the question asked or until an effective objection to processing is lodged),
  • safeguarding potential claims (until their limitation period under applicable law).
• Providing data is voluntary, but failure to do so makes it impossible to obtain a response to the question submitted through the form.
• Personal data may be disclosed to other entities — our partners, i.e. companies with whom we cooperate by combining products or services. Our subcontractors (processors), e.g. accounting, legal, or IT firms, may also have access to the data.
• You have the right to request access to your personal data, as well as their rectification (correction). You also have the right to request deletion or restriction of processing, as well as to object to processing, provided that further processing is not necessary for the Controller to comply with a legal obligation and there are no overriding legitimate grounds for processing.
• You have the right to lodge a complaint regarding the Controller's data processing with the President of the Personal Data Protection Office (uodo.gov.pl).
• The Controller will not use automated decision-making, including profiling.
• Your personal data may be transferred outside the European Economic Area when the Controller uses the services of entities providing IT solutions and systems, which may store personal data on servers located outside this area (including in the United States). Such transfer may take place to a third country for which the European Commission has determined an adequate level of protection or through the use of appropriate legal safeguards, in particular standard contractual clauses for the protection of personal data approved by the European Commission. You have the right to obtain a copy of the safeguards for personal data transferred to a third country, which may be exercised by contacting the Controller in writing.

We constantly strive to process users' personal data and cookies to the highest standards. Therefore, we have implemented a system for immediate response to threats to these standards. If such a threat or breach is identified, please contact us immediately at office@digital-tpa.com.

We welcome any feedback. If you have any questions, requests, or concerns regarding the processing of personal data or cookies, please contact us.