Privacy Policy

Smart Prospects Ltd., Private Limited Company, registered by the Registrar of Companies for England and Wales under number 084223213, with its registered office in Orchard House, 15 Market Street, TF2 6EL, Telford, United Kingdom (hereinafter referred to as Smart Prospects) being the owner of Smart Prospects web portal located at the website https://www.sp.edu.pl/ and its subpages (hereinafter referred to as the Web Portal) makes every effort to ensure the most comprehensive protection of personal data of users of the Web Portal.

To explain the principles of protection of privacy, we prepared this Privacy Policy. 

Basic definitions

Controller – an individual or a legal person, public authority, unit or other entity which independently or together with others sets purposes and methods of processing of personal data,

Personal data – information on an identified or identifiable individual; an identifiable individual is a person who can be directly or indirectly identified, in particular on the basis of an identifier such as name, identification number, location data, online identifier or one or several special factors specifying physical, physiological, genetic, mental, economic, cultural or social identity of an individual,

Processing ‒ an operation or a set of operations carried out with respect to personal data or sets of personal data in an automated or non-automated way; such as gathering, recording, organising, putting in order, storage, adaptation or modification, downloading, viewing, using, disclosing by sending, dissemination or other type of provision, adjustment or combining, limiting, deletion or destroying,

User – Guest, Registered Guest, Applicant referred to in the Regulations of provision of services by electronic means by web portal https://www.sp.edu.pl, being an individual who by using the Web Portal or otherwise provides Smart Prospects with personal data concerning him or her.

Personal data

§1

Smart Prospects processes personal data of Users in compliance with the law, in particular with the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 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 (the General Data Protection Regulation) of 27 April 2016 (Official Journal of the EU No. 119, page 1), i.e. the GDPR.

§2

1. The data controller is Smart Prospects Ltd., Private Limited Company, registered in the Registrar of Companies for England and Wales under number 084223213, with its registered office in Orchard House, 15 Market Street, TF2 6EL, Telford, United Kingdom, which may be contacted in writing at the aforementioned address or by email at [email protected]
2. The controller may provide other entities with personal data of Users, ensuring sufficient guarantees of the implementation of proper technical and organisational means so the processing of data is lawful and protects Users’ rights. Personal data of Users may be provided only to authorised employees of the Controller, external entities rendering services to Smart Prospects (including with respect of handling payments, courier, accounting, IT, hosting and marketing services) and public administration bodies.
3. Users’ personal data is provided to higher education institutions located in the area of the United Kingdom and to partner organisations cooperating with the Service Provider (for the purpose of provision of services and performance of an agreement entered into with a User). Personal data of Users is not provided to other third country (with the exception of Google Analytics referred to in Clause 11 and Zoho) or to any international organisation.

§3

Smart Prospects processes personal data provided by Users:

1. 1. within the scope arising out of a consent given by a User ‒ as set out in Art. 6(1)(a) of the GDPR,
   2. within the scope necessary for the conclusion, performance and termination of the legal relationship arising out of a service agreement entered into with a User and ensuring on-going communication with a User ‒ as set out in Art. 6(1)(b) of the GDPR,
   3. within the scope necessary for fulfilment of the controller’s legal obligations, in particular tax and accounting obligations ‒ as set out in Art. 6(1)(c) of the GDPR,
   4. within the scope necessary for pursuing a justified interest of the controller in the form of possibly determining, pursuing or protecting against claims, considering submitted complaints, and within the scope necessary for sending up-to-date information on changes and improvement of functionalities of the Web Portal website by using cookies and Internet analytics tools (to gather information on the methods of use of the Web Portal by Users, service of logging on, protection against repeatedly displaying the same contents, compiling anonymous statistics of the contents of the web portal) ‒ as set out in Art. 6(1)(f) of the GDPR.

§4

Commercial information is sent to a User of the Web Portal only on the basis of User’s prior consent which may be revoked at any time.

§5

Personal data provided by Users is processed by Smart Prospects only for the purpose for which it was gathered and for the period necessary for its fulfilment, i.e. for the time of provision of services or the term of an agreement, and after its end:

1. personal data gathered to perform the agreement is processed not longer than until the expiry of the period of limitation of claims,
2. personal data gathered to discharge tax and accounting obligations imposed on the Controller is processed not longer than until the legal obligation ceases to exist,
3. personal data gathered to gather information on the methods of use of the Web Portal by Users is deleted upon closing a web browser or stored for the period specified in parameters of cookies or until they are deleted by a User,
4. personal data obtained on the basis of a consent is processed not longer than until a User makes an objection or withdraws the granted consent.

§6

1. A User has the right to demand access to personal data concerning the User, correct or delete it or limit its processing, and the right to transfer data and the right to file a complaint to a supervising body.

A User has the right to withdraw a granted consent at any time, notifying the Controller about this fact by email or post. Withdrawal of a consent does not affect lawfulness of the processing carried out on the basis of the consent before its withdrawal.

§7

A User has the right to raise an objection against the processing of data by the Controller for a specific purpose (e.g. for marketing purposes). A User may exercise the above right at any time and free of charge.

§8

Provision by a User of data requested by the Web Portal is not a statutory requirement. Data which must be provided in the Web Portal is necessary for rendering services by Smart Prospects or entering by a User into an agreement and performing it. The consequence of the refusal to provide it is the impossibility of rendering services by Smart Prospects or the impossibility of entering into an agreement. The lack of consent to the use of cookies may limit functionality of the Web Portal website. 

§9

Smart Prospects will not take decisions with respect to a User based exclusively on automated processing, including in the form of profiling.

Cookies

§10

The Web Portal uses information recorded with cookies and similar technologies, and obtains access to this information to ensure correct functioning of the Web Portal website, and for statistical purposes.

Cookies are small text files automatically stored on an end device which contain a character string. Their purpose is, among others, to allow the website to identify a web browser in case of another visit of a User, and to store data concerning User’s preferences and other data.

Session cookies used by the Web Portal are temporary files which are stored on User’s end device until logging off, leaving the website or turning off software (closing a web browser). Persistent cookies are stored on User’s end device for the time specified in cookies parameters or until they are deleted by User.

To use full functionality of the Web Portal it is necessary to accept cookies stored on a User’s device.

Software used for browsing websites by default allows for storage of cookies on a User’s end device. Users may at any time change settings of their web browser concerning cookies (among others in such a way as to block automatic support of cookies or inform every time they are saved on an end device). Detailed information on the possibility and methods of supporting cookies is available in web browser settings.

Using the Web Portal without changing standard web browser settings means that a User consents to saving cookies in memory of an end device and obtaining access to information recorded in these files.

Google Analytics

§11

To pursue the Controller’s legally justified interest which is improvement of functionality of the Web Portal website, the Web Portal uses Google (Universal) Analytics ‒ an Internet analytics tool of Google LLC (more information: http://www.google.com/analytics/learn/privacy.html).

Full IP addresses of Users are not stored as the Web Portal uses the possibilities of anonymisation and IP address masking offered by Google. Anonymisation/IP address masking takes place immediately after Analytics Collection Network receives information, and before any data processing or storage activities.

By using a web browser add-on made available by Google a User may block Google Analytics without blocking at the same time sending data to the Web Portal website.

ZOHO

§12

The Web Portal uses external mailing / CRM systems of ZOHO company. Zoho Corporation with its registered office in the USA meets the European requirements for safe processing of data ‒ it belongs to the EU-US Privacy Shield programme guaranteeing proper protection of provided personal data.

Data contained in system logs

§13

Information contained in system logs in relation to the general principles of connections in the Internet is used by a hosting company supporting the Web Portal only for technical and statistical purposes.

Other

§14

Smart Prospects reserves the possibility of introducing amendments to the content of this Privacy Policy. The amendments may be made in relation to launching new services or amendments to the applicable laws.