Information Clause for Users of Astrafox Sp. z o.o. Fan Pages on Facebook and LinkedIn

Information Clause for Users of Astrafox Sp. z o.o. Fan Pages on Facebook and LinkedIn

Pursuant to General Data Protection Regulation (EU) 2016/679 (the “GDPR”), we provide the following information about the processing of the personal data of users of our fan pages:

Controller and Data Protection Officer

1. Astrafox Sp. z o.o., with its registered office at ul. Poloneza 93, 02-826 Warsaw, telephone: +48 22 355 21 60, email: office@astrafox.pl, is the Controller of the personal data that you make available while using:

a) the following fan pages on Facebook:

• ASTRAFOX – https://www.facebook.com/AstrafoxPL,
• Amodit.pl – https://www.facebook.com/amoditpl,

b) the following fan pages on LinkedIn:

• Astrafox – https://www.linkedin.com/company/astrafox/,
• Amodit – https://www.linkedin.com/company/amodit/,
• BI Expert Services – https://www.linkedin.com/company/bi-expert-services/.

2. The Controller has appointed a Data Protection Officer (DPO), who can be contacted in all matters related to the processing and protection of personal data by email at iod@astrafox.pl.

Social media platform owners as joint controllers of personal data

3. According to the case law of the Court of Justice of the European Union, the creator of a fan page on a social media platform is a joint controller of the personal data of users of that fan page together with the owner of the social media platform.

4. However, we inform you that the provisions of this information clause do not apply to the processing of your personal data by the owner of Facebook, Meta Platforms Ireland Limited, or the owner of LinkedIn, LinkedIn Ireland Unlimited Company. For detailed information about the processing of your data by Meta Platforms Ireland Limited and LinkedIn Ireland Unlimited Company, please read their Privacy Policies, which are available at:

• Facebook: https://www.facebook.com/about/privacy.
• LinkedIn: https://pl.linkedin.com/legal/privacy-policy

5. Please also read the information on the processing of your data for page statistics purposes:

https://www.facebook.com/legal/terms/information_about_page_insights_data.

Scope of data processed

6. Astrafox processes your personal data if you have left any trace of activity on one of our fan pages, for example, if you clicked the “Like,” “Follow,” or “Share” icon, left a comment, or sent a message.

7. We process the following data: your first and last name or profile name; your image, if it appears in your profile picture; and data provided in a message, comment, or conversation via Messenger.

Purposes and legal bases for processing

8. We process your data for the following purposes:

a) operating fan pages under the terms and conditions established by Meta Platforms Ireland Limited, the provider of Facebook, and LinkedIn Ireland Unlimited Company, the provider of LinkedIn, and using them to provide information about our activities, products, and services, which constitutes our legitimate interest under Art. 6(1)(f) GDPR;

b) communicating through the available Facebook and LinkedIn features (comments, chat, posts, conversations via Messenger, and messages), which constitutes our legitimate interest under Art. 6(1)(f) GDPR;

c) analyzing the operation, popularity, statistics, and use of the fan pages through available features, which constitutes our legitimate interest under Art. 6(1)(f) GDPR.

Rights of natural persons

9. You have the following rights:

a) access your data and obtain a copy of it;

b) request rectification of your data;

c) request erasure of your data;

d) request restriction of the processing of your data;

e) object to processing based on the Controller’s legitimate interest.

10. If you wish to exercise your rights, please contact us at the email address specified in Section 1 or 2 above.

11. You also have the right to lodge a complaint with the President of the Personal Data Protection Office (UODO) if you believe that we process your personal data in violation of the law.

Data retention period

12. We will process your personal data for the period necessary to fulfill the stated processing purposes, but no longer than until you submit an effective objection to the processing. We will process data contained in messages for the period necessary to resolve the matter about which you contact us.

13. Please remember that you can always delete a comment you have left on our fan page or unfollow our fan page yourself.

Information on the voluntary provision of data

14. Any activity that leaves your personal data on our fan page is entirely voluntary. You decide which of your personal data we will be able to access by applying the appropriate privacy settings to your personal profile.

Information on cookies used for statistical and advertising purposes

15. We may obtain anonymous statistical data about individuals visiting our Facebook fan pages through the “Meta Business Suite” feature provided by the owner of Facebook, Meta Platforms. This data is collected using cookies. Meta Platforms stores the cookies on the end devices of individuals visiting the fan pages.

16. Information on Meta Platforms’ use of cookies is available at the following link: https://www.facebook.com/policies/cookies.

17. We may obtain anonymous statistical data about individuals visiting our LinkedIn fan pages using cookies provided by LinkedIn Ireland Unlimited Company. LinkedIn Ireland Unlimited Company stores the cookies on the end devices of individuals visiting the fan pages.

18. Information on LinkedIn Ireland Unlimited Company’s use of cookies is available at the following link: https://pl.linkedin.com/legal/cookie-policy.

19. The information obtained in the manner described above does not allow us to unambiguously identify individuals visiting our fan pages.

Data recipients

20. Recipients of your personal data may include entities that provide us with administration services for our fan pages. If you make your data public on our fan page, it will be visible to other users who also visit our fan page.

Transfers of data to third countries or international organizations and information on profiling

21. Astrafox does not transfer your data outside the European Union or to international organizations.

Please remember, however, that by having an account on Facebook or LinkedIn, you have accepted the terms and conditions and privacy policies of those platforms, in which their owners, Meta Platforms Ireland Limited and LinkedIn Ireland Unlimited Company, describe the rules for transferring personal data to third countries, including, among others, to servers in the United States. Astrafox has no control over how Meta Platforms Ireland Limited and LinkedIn Ireland Unlimited Company process your personal data.

22. Your personal data will not be subject to automated decision-making, including profiling, by Astrafox.