1. GAP Group Sp. z o.o.., which is the operator of the website available at www.redegate.com, with its registered office at Inżynierska 39/206, 53-228 Wrocław, appearing under the NIP number: 8943158670 (hereinafter referred to as: “Redegate”) is the controller within the meaning of Regulation (EU) of the European Parliament and of the Council (EU) 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: “GDPR”) in relation to the personal data of Users who are natural persons.
2. This means that Redegate determines the purposes and means of processing your personal data and is responsible for ensuring compliance with the GDPR and any applicable national data protection laws. Personal data of users is considered to be any information that can directly or indirectly identify them, for example, name and surname, telephone number, PESEL number, e-mail address, place of residence, IP address. The processing of personal data is considered to be all actions and operations performed on such personal data, including collection, use, disclosure, deletion, etc.
3. The purpose of this Privacy Policy is to inform website visitors and Users about the actions taken by Redegate in the field of protection of personal data processed, including those collected through the Redegate website and related services and tools used by Users to perform activities such as Registration, posting or viewing Advertisements, accepting and executing Orders and performing a number of others, related activities in connection with the use of Redegate services by Users. All of Redegate’s activities are subject to the laws that apply to data protection.
4. You may use the Redegate website only after you have read the provisions of this Privacy Policy. Without accepting the Privacy Policy during registration on the redegate.com, it is impossible to obtain the status of a Redegate User.

Categories of Personal Information Collection

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

1. Account and profile data: creating an Account by the User may require the provision of information identifying the User, including, for example, the User’s name and surname, PESEL number, e-mail address, place and address of residence, telephone number and data concerning the User’s education and previous professional career. All Users are required to register and provide the information indicated as mandatory in order to use Redegate’s services. By accepting the Privacy Policy, Users consent to the sharing of information from their user account with other registered Users. This is to enable Redegate to provide services to both groups of Users (Experts and Corporate Clients).
2. Transactions: Redegate may process information constituting the User’s personal data, enabling Users to settle Orders, including making payments for services provided by Redegate. The sharing of this transaction data depends entirely on how you use Redegate’s services.
3. User service:Redegate, as part of the Redegate website, may collect and otherwise process personal data of Users contacting the User service department. This data may be necessary to communicate with the User (e.g. to answer the questions asked by the User), but also to fulfill their request or respond to a complaint. Contact will also be possible through the use of data placed for this purpose in the User Account.
4. Data collected by the website and mobile devices: When it is necessary to provide a service to Users, or it is in the legitimate interest of Redegate or third parties (such as ensuring the security of IT resources or the security of other Users), Redegate is entitled to automatically collect and record data transmitted to the server by web browsers or Users’ devices. Such data may include, for example, your IP address (i.e. the address used by your device to access the Redegate platform), the software and hardware you use, the pages you view, the identification number of your mobile device, information about your use of the application, and other data about your devices and system usage. The automatically collected data through cookies is based on the User’s consent in accordance with Redegate’s cookie policy.

Legal basis and purposes of processing

1. Based on Redegate’s legitimate interests to maintain the operation and security of the website and to provide high quality services, Redegate may process Users’ personal data for the following purposes:
   1. enable Users to fully and safely use the Redegate website,
   2. ensuring the security of services provided by electronic means, including enforcing compliance with the Redegate Terms and Conditions and counteracting fraud and abuse,
   3. conducting research and analysis 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 Users’ personal data for the following purposes:
   1. creating and managing User Accounts,
   2. execution of contracts and orders concluded as part of the Redegate website,
   3. handling complaints, requests and appeals of Users,
   4. providing payment services, making payments, debt collection,
   5. contacting Users, including for purposes related to the provision of services, User service, permitted marketing activities, through available communication channels
3. In order to comply with obligations arising from the provisions of law, Redegate may process Users’ personal data for the following purposes:a. Fulfilment of obligations resulting from the provisions of law, including tax or accounting regulations,b. To ensure accountability under the GDPR, i.e. the ability to demonstrate that• the personal data are processed lawfully, fairly and in a transparent manner for the data subject,• the purpose of the data processing is clearly stated;• the data processed is adequate, relevant and limited only as to the purposes of the processing;• the personal data are accurate and updated where necessary;•  personal data are processed in a manner that ensures appropriate security;• the storage of the data is limited to the strict minimum necessary to fulfil the purposes for which it is processed;• the rights of the data subjects are respected, e.g. the right of access, rectification, etc.
4. Redegate is entitled to retain the data collected and tracked on Redegate only for the purposes set out above and not to use your personal data for other incompatible purposes, unless you have consented to further use after Redegate has duly informed you. Automated decision-making only, including profiling.
5. Redegate respects the privacy of Users and does not use their data for automated decision-making, including profiling, which may produce any legal effects as a result of an adverse impact on your rights or contracts or other similar significant effects.
6. Redegate may partner with third parties to provide services to Redegate Users. In this case, these entities are not authorized to use the Users’ personal data for their own purposes (the data will always be processed on behalf of and for the needs of Redegate), and their activities are subject to the provisions of applicable law and this Privacy Policy. Third parties are required to keep information confidential and to process it only under the supervision of Redegate. The service providers that may process Users’ personal data are Redegate’s trusted partners, providing server, hosting and ICT services, mailing, marketing and customer service services, accounting and debt collection. Personal data will be processed only on servers located within the European Union in order to ensure the highest standards of data protection.
7. Your data may also be shared with the tax office to comply with tax obligations under national law. Other public authorities may also be recipients of personal data (e.g. law enforcement agencies, courts) in the event that the User does not comply with the terms of use or if the rights and legitimate interests of Redegate or third parties may be threatened (e.g. property, security, reputation, etc.).
8. Due to the need to prevent web robots from performing certain functions on the Redegate platform, Redegate uses the Google reCAPTCHA mechanism to occasionally check whether the behavior of the platform’s users does not bear the hallmarks of robot behavior. For this reason, Redegate may disclose your IP address to Google Inc.
9. Experts and Corporate Clients to whom the GDPR applies, after obtaining the personal data of the other party to the Order from Redegate, are obliged to comply with all obligations towards the Expert/Corporate Client under the GDPR and other legal provisions, including ensuring that they exercise their rights under the GDPR. They may only process personal data obtained for the purpose of using Redegate’s services and may not further process it for other incompatible purposes unless the User has given their explicit consent.

Storage and security

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

General Data Protection Regulation

1. Under the GDPR, users are entitled to:
   1. the right to access your data and receive a copy of it;
   2. the right to rectify (correct) your data;
   3. the right to erasure, where such erasure is permitted by law, e.g. if Redegate has no legal basis to process your personal data or the data is excessive, irrelevant or out of date;
   4. restriction of data processing. You may request that we restrict the processing of your personal data to only storing it or performing the activities agreed with you if, in your opinion, Redegate has inaccurate data about you or is processing it unjustifiably;
   5. the right to object to the processing of your data, including:a. “marketing” objection. You have the right to object to the processing of your data for the purpose of direct marketing, including profiling. You have the right to object to the processing of your 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, you should indicate the specific situation that you believe justifies Redegate ceasing the processing covered by the objection.
   6. the right to data portability. You have the right to receive your data to Redegate in a structured, commonly used and machine-readable format when the processing is based on your consent or for the purpose of entering into and performing a contract with Redegate.
   7. the right to withdraw consent to the processing of personal data. You have the right to withdraw your consent to the processing of your personal data that Redegate processes on the basis of your consent at any time. Withdrawal of consent will not affect the lawfulness of processing based on the User’s consent before its withdrawal.
   8. the right to lodge a complaint with the supervisory authority. If you believe that we are processing your data unlawfully, you may lodge a complaint with the President of the Office for Personal Data Protection or another competent supervisory authority

Cookie policy of the Redegate.com website effective from 20.02.2021

1. This Cookie Policy sets out the rules for the use of small files, called “cookies”, used by the Redegate www.redegate.com
2. The owner of the Redegate website is GAP Group Sp. z o.o. With NIP number: 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, in particular text files, which are stored on the end device of Users visiting the Redegate website (e.g. on the User’s computer, phone or other device from which the connection to the website was made) and are intended for the use of the website, if the web browser allows it. A cookie file usually contains the name of the domain from which it originates, the time of their storage on the User’s end device and an individual, randomly selected number identifying this file. Information collected by means of files of this type will be stored for the purpose of maintaining the user’s session within the website, they help to adapt the services offered by Redegate. It also gives the possibility of developing general statistics of website visits. The stored information or accessing it does not cause any configuration changes in the telecommunications end user’s end device and the software installed on this device.
5. Redegate uses two types of cookies: a. Session cookies: after the end of the session of a given browser 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’ computer. b. Persistent cookies: they are stored in the memory of the User’s end device and remain there until they are deleted or expire. The mechanism of persistent cookies does not allow for the collection of any personal data or any confidential information from the Users’ computer.
6. First party cookies: placed by Redegate.
7. External cookies: placed by third parties, approved by Redegate, including Google Analytics cookies, used to analyse the activities of Website Users for statistical purposes.
8. Redegate uses its own cookies to: a. authenticate the User on the website and ensure 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. analyses and research as well as audience audits, and in particular to create anonymous statistics that help to understand how Users use the website, which allows us to improve its structure and content.
9. Redegate uses external cookies to: a. collect general and anonymous statistical data via Google Analytics analytical tools (external cookies administrator: Google Inc. based in the USA). b. enabling the assessment of the correctness and effectiveness of the advertising activity carried out with the use of the AdWords network (administrator of external Google AdWords cookies: Google Inc. with its registered office in the USA), for the purpose of services such as: remarketing, interest categories, similar recipients, other types of interest-based advertising, demographic and location targeting.
10. The cookie mechanism is safe for the computers of the website Users. In particular, it is not possible for viruses or other unwanted software or malicious software to enter the Users’ computers in this way. In their browsers, Users have the option of limiting or disabling the access of cookies to computers. If you use this option, you will be able to use the Website, except for the functions that by their nature require cookies. If the User does not agree to the use of cookies, they can 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 proper operation of the website.
11. Cookies do not store information constituting personal data of the Website Users. Cookies are not used to determine the identity of the User.
12. The Redegate website may contain links and references to other websites. Redegate is not responsible for the privacy practices applicable to them.
13. The coookies policy is subject to change, and Redegate will inform Users of this policy from time to time.
14. If you have any questions about the Cookie Policy, please contact: kontakt@redegate.com