Privacy Policy of Redegate.com

1. GAP Group Sp. z o.o., the operator of the website available at www.redegate.com, based at Inżynierska 39 / 206, 53-228 Wrocław, with NIP: 8943158670 (hereinafter referred to as: “Redegate”), is a controller as defined by the 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 (hereinafter referred to as: “the GDPR”), in reference to the personal data of Users who are natural persons.
2. Theabove means that Redegate determines the purposes and means of processing Users’ personal data and is responsible for ensuring compliance with the GDPR and all applicable national data protection laws. The Users’ personal data are all information that can identify them directly or indirectly, for instance, their first name and last name, telephone number, PESEL number, email address, place of residence, IP address. The processing of personal data is understood as all activities and operations performed on these personal data, including collection, use, disclosure, deletion, etc.
3. The purpose of this Privacy Policy is to inform website visitors and Users about the activities undertaken by Redegate to protect personal data processed, including those collected via the Redegate website and related services and tools used by Users to perform activities such as Registration, posting or viewing Announcements, accepting and executing Orders and performing a number of other activities related to the above in connection with the use of Redegate services by the Users. All actions by Redegate are subject to the applicable data protection laws.
4. Using the Redegate website is possible only after reading the provisions of this Privacy Policy. Without accepting the Privacy Policy during registration at www.redegate.com, obtaining the status of a User of the Redegate website is impossible.

Categories of Personal Data Collection

In connection with the use of the Redegate website, the following Users’ personal data may be collected and processed:

1. Account data and profile data: creating an Account by the User may require providing information identifying the User, including, for instance, the User’s first name and last name, PESEL number, email address, place and address of residence, telephone number, and data on the education and previous professional career of the User. All Users are required to register and provide the information indicated as mandatory in order to use the Redegate services. By accepting the Privacy Policy, Users agree to share information from their user accounts with other registered Users. This is to enable the Redegate service to provide the service to both groups of Users (Experts and Corporate Clients). 
2. Transactions: Redegate may process information constituting the User’s personal data, enabling the Users to settle Orders, including making payments for services provided by Redegate. The sharing of these transaction data depends entirely on how the User uses the Redegate services.
3. User service:Redegate as part of the Redegate service may collect and otherwise process personal data of Users contacting the user service department. These data may be necessary to communicate with the User (e.g. to answer the questions asked by them), but also to fulfil their request or reply to a complaint. Contact will also be possible through the use of data stored for this purpose on the User’s Account.
4. Data collected by the website and mobile devices: When it is necessary to provide the service to Users or if it constitutes a legitimate interest of Redegate or third parties (which is, for instance, ensuring the security of IT resources or the security of other Users), Redegate is entitled to automatically obtain and recording data transferred to the server by web browsers or Users’ devices. Such data may include, for instance, the IP address (i.e. the address used by the User’s device used to access the Redegate platform), parameters of the software and hardware used by the User, pages viewed, identification number of the mobile device, information on the use of the application and other device and system usage data. Automatically collected data using cookies are based on the User’s consent in accordance with the Redegate cookies policy.

The Legal Basis and Purposes of Processing

1. On the basis of the legitimate interests of Redegate to maintain the functioning and security of the website and to provide high-quality services, Redegate may process the Users’ personal data for the following purposes:
   1. Enabling the Users to fully and safely use the Redegate website
   2. Ensuring the security of electronic services, including enforcement of the Redegate Terms and Conditions and counteracting fraud and abuse
   3. Conducting research and analyses of the Redegate website, among others, in terms of the functioning of the website, improving the operation of available services or estimating the needs of visitors
   4. Conducting court, arbitration and mediation proceedings
   5. Using the collected information for statistical and archival purposes.
2. In order to conclude and perform the agreement concluded between Redegate and the User, Redegate may process the Users’ personal data for the following purposes:
   1. Creating and managing the Users’ Accounts
   2. Performing contracts and orders concluded as part of the Redegate service
   3. Handling complaints, requests and appeals of the Users
   4. Providing payment services, making payments, debt collection
   5. Contacting the Users, including for purposes related to the provision of services, user service, permitted marketing activities, through available communication channels
3. In order to fulfil its obligations under the law, Redegate may process the Users’ personal data for the following purposes:
   a. Performing obligations resulting from legal regulations, including tax or accounting regulations.
   b. Ensuring liability under the GDPR, i.e. the ability to demonstrate that
   • Personal data are processed lawfully, fairly and in a manner that is transparent to the data subject.
   • The purpose of data processing is clearly defined.
   • The processed data are adequate, relevant and limited only with regard to the purposes of their processing.
   • Personal data are correct and, if necessary, updated.
   • Personal data are processed in a manner that ensures adequate security.
   • Data storage is limited to the strict minimum necessary to achieve the purposes for which they are processed.
   • The rights of the data subjects are respected, e.g. the right of access, correction, etc.
4. Redegate is entitled to store the data collected and tracked on the Redegate platform only for the above-mentioned purposes and not to use personal data for other incompatible purposes, unless the User has consented to further use after Redegate has informed them accordingly. Only automated decision-making, including profiling.
5. Redegate respects the privacy of the Users and does not use their data for automated decision-making, including profiling, which may have any legal effects as a result of adversely affecting your rights or contracts or other similar significant effects.
6. Redegate may cooperate with third parties in order to provide services to Redegate Users by these entities. In this case, these entities are not authorised to use Users’ personal data for their own purposes (the data will always be processed on behalf of and for the needs of Redegate), and their actions are subject to the provisions of applicable law and this Privacy Policy. The third parties are required to keep information confidential and process it only under the supervision of Redegate. Providers of services that may process the Users’ personal data are trusted partners of the Redegate website, who provide server, hosting and ICT services, mailing, marketing and customer service services, accounting and debt collection. The personal data will be processed only on servers located within the European Union in order to ensure the highest standards of data protection.
7. The Users’ data may also be made available to the tax office to ensure compliance with tax obligations under national law. Other public authorities may also be recipients of personal data (e.g. law enforcement authorities, courts) if the User does not comply with the terms of use or if the rights and legitimate interests of Redegate or the third parties may be threatened (e.g. property, security, reputation, etc.).
8. Due to the need to prevent certain functions on the Redegate platform by internet robots, Redegate uses the Google reCAPTCHA mechanism to sporadically test whether the behaviour of the platform users does not resemble that of robots. Therefore, Redegate may disclose the User’s IP address to Google Inc.
9. Experts and Corporate Clients, to whom the GDPR applies, after obtaining the personal data of the other party of the Order from Redegate, are obliged to fulfil all obligations under the GDPR and other legal provisions towards the Expert / Corporate Client, including ensuring that they exercise their GDPR rights. They may process personal data obtained solely for the purpose of using the Redegate services and may not further process it for other incompatible purposes, unless the User expressly agrees.

Storage and Security

1. The Users’ personal data are stored for the period of their registration on the Redegate platform.
2. All the data collected by Redegate are stored in secure servers and is protected using reasonable and risk-based technical and organisational measures and security procedures in order to protect them against unauthorised access or their unauthorised use. Redegate affiliates, trusted partners and external service providers manage data in accordance with security and privacy requirements.

The Data Protection Regulation

1. On the basis of the provisions of the GDPR, users are entitled to:
   1. The right to access their data and receive a copy of them.
   2. The right to rectify (correct) their data.
   3. The right to delete the data if such deletion is permitted by law, e.g. if Redegate has no legal basis to process personal data or the data are excessive, irrelevant or out of date.
   4. Data processing restriction. The User may request that Redegate restrict the processing of the User’s personal data only to their storage or performance of activities agreed with the User, if, in the opinion of the User, Redegate has incorrect data about the User or processes them unreasonably.
   5. The right to object to data processing, including:
      a. “Marketing” objection. The User has the right to object to the processing of their data for the purpose of direct marketing, including profiling.
      b. The User has the right to object to the processing of their data on the basis of a legitimate interest for purposes other than direct marketing, as well as when Redegate processes data for statistical and research purposes. In this case, the User should indicate the specific situation which, in their opinion, justifies Redegate’s cessation of the processing covered by the objection.
   6. The right to data portability. The User has the right to receive their data from Redegate in a structured, commonly used and machine-readable format when the processing is based on the User’s consent or for the conclusion and performance of the agreement with Redegate.
   7. The right to withdraw consent to the processing of their personal data. At any time, the User has the right to withdraw consent to the processing of the personal data that are processed by Redegate on the basis of the User’s consent. The withdrawal of consent will not affect the lawfulness of the processing which was carried out on the basis of the User’s consent before the withdrawal.
   8. The right to file a complaint with a supervisory authority. If the User believes that we are processing their data unlawfully, they may submit a complaint to the President of the Office for Personal Data Protection or another competent supervisory authority.

Cookies Policy of Redegate.com, effective from 20.02.2021 

1. This Cookies Policy defines the rules for using small files called “cookies”, used by the Redegate website www.redegate.com
2. The owner of the Redegate website is GAP Group Sp. z o.o. with NIP: 8943158670 
3. Redegate takes special care to respect the privacy of Users visiting the online platform at www.redegate.com
4. Cookies are IT data, particularly text files, which are stored on the end devices of Users visiting the Redegate website (e.g. on a computer, phone or other device of the User from which the website was connected) and are intended for using the website if the web browser allows it. A cookie file usually contains the name of the domain it comes from, the storage time on the User’s end device and an individual, randomly selected number identifying this file. Information collected using this type of file will be stored for the purpose of maintaining the User’s session within the website, and they help adjust the services offered by Redegate. It also enables the development of general statistics of visits to the website. Stored information or access to it does not cause any configuration changes in the end User’s telecommunications end device and the software installed on this device. 
5. Redegate uses two types of cookies:
   a. Session cookies: after ending a web browser session or turning off the computer, the saved information is deleted from the memory of the User’s end device. The mechanism of session cookies does not allow for the collection of any personal data or any confidential information from the Users’ computers.
   b. Permanent cookies: they are stored in the memory of the User’s end device and remain there until they are deleted or expired. The mechanism of permanent cookies does not allow for the collection of any personal data or any confidential information from the Users’ computers.
6. Own cookies: placed by Redegate.
7. External cookies: posted by third parties, approved by Redegate, including Google Analytics cookies, used to analyse the website Users’ activities for statistical purposes.
8. Redegate uses its own cookies for the purpose of:
   a. Authenticating the User on the website and ensuring the User’s session on the website (after logging in), thanks to which the User does not have to re-enter the login and password on each subpage of the website.
   b. Analysis and research, as well as audience audit, particularly to create anonymous statistics that help understand how Users use the website, which allows for improving its structure and content.
9. Redegate uses external cookies for the purpose of:
   a. Collecting general and anonymous static data via Google Analytics analytical tools (external cookie administrator: Google Inc. based in the USA).
   b. Enabling the assessment of the correctness and effectiveness of the advertising activities carried out, using the AdWords network (Google AdWords external cookie administrator: Google Inc. based in the USA), for the purpose of services such as: remarketing, interest categories, similar recipients, other types of interest-based, demographic and location-based advertising.
10. The cookie mechanism is safe for the computers of the Users of the website. In particular, it is not possible for viruses or other unwanted software or malware to enter the Users’ computers in this way. In their web browsers, the Users have the option to limit or disable the access of cookies to their computers. If this option is used, the use of the website will be possible, except for functions which, by their nature, require cookies. If the User does not consent to the use of cookies, they may change the settings for these files at any time by blocking the automatic handling of cookies in the browser settings. Detailed information on the possibilities and methods of handling cookies is available in the software (web browser) settings. Please be advised that restricting the use of cookies may affect some of the functionalities available on the website and prevent the correct functioning of the website.
11. The cookies do not store information constituting personal data of the Users of the website. The cookies are not used to determine the User’s identity.
12. The Redegate website may contain links and references to other websites. Redegate is not liable for the privacy policies of those websites.
13. This Cookies Policy may be changed, and Redegate shall inform its Users about it each time.
14. Questions related to the Cookies Policy should be sent to the following address: kontakt@redegate.com