Privacy Policy
Effective from 1 December 2024
Horyzont Psychoterapia
What does this Policy contain and what is its purpose?
- We have prepared and provided this document so that you can easily find out how we process your data, for what purposes and on what legal basis. We take responsibility for protecting your personal data.
| You will learn, for example, how we use your email address when you subscribe to our Newsletter and how we process your data in this connection. |
- Our Privacy Policy contains up-to-date information. We always publish its latest version on our website. We may amend it. If a change affects our mutual rights and obligations, we will inform you.
- We are committed to transparency in processing your personal data and want you to have clear information about what happens to your data in our organisation and why.
- You will find details of the tools we use on our website and the recipients of your personal data (entities that have access to your data).
Important:
- We process your personal data as a data controller or joint controller (in relation to our social media profiles), i.e. an entity that has access to your data in connection with our relationship. We are responsible for ensuring that your data are properly protected and managed in accordance with our arrangements.
Example: When you purchase a Service from us, we hold your data in connection with our agreement to provide that Service. If you subscribe to our Newsletter, we hold your data in connection with that subscription. |
- We process your personal data on an appropriate legal basis and for an appropriate period.
Example: We process the data you provide when entering into a contract to perform that contract and issue proof of payment in accordance with our legal obligations. We retain these data for the statutory period until any potential claims become time-barred. |
- The General Data Protection Regulation (GDPR) grants you rights relating to our processing of your personal data, and we respect those rights.
- You can always access the Privacy Policy easily on our website. We enable you to view and save it.
- We work with entities that ensure a high level of protection for personal data and use trusted tools in our business.
PLEASE NOTE! In this Privacy Policy:
“Our website” means www.psychoterapiahoryzont.pl. If you have any questions, please contact us by email or telephone:
|
We have divided this Privacy Policy into six parts. To help you quickly find the information you need, some parts are divided into sections.
Contents
I. Key information: what data we process, why and on what legal basis; your rights under the GDPR; how long we process your data; profiling
1. What data do we process, for what purposes and on what legal basis?
2. Do you have to provide us with your personal data?
3. What rights do you have under the GDPR?
4. How long do we process your data?
5. Do we profile your data?
II. Data recipients: who has access to your data
6. Who has access to your data?
III. Social media
7. Social media
IV. Cookies and tools implemented on the website
8. Cookies
9. What are cookies and what are they used for?
10. Do you have to accept all cookies used on our website?
11. What tracking technologies do we use on our website?
12. Tools implemented on the website
13. Google Consent Mode
14. Google Analytics
15. Google Search Console
16. Meta Pixel
17. Server logs
V. Final provisions
I. Key information
1. What data do we process, for what purposes and on what legal basis?
a) This is one of the most important parts of this document. Here we explain what personal data we receive from you and from other people, and how we process those data.
b) We also identify the legal basis for our access to your data, so that it is clear how the law governs our relationship.
| PURPOSE OF PROCESSING | CATEGORIES OF DATA | LEGAL BASIS |
|---|---|---|
| Contacting you | Email address (first and last name), information contained in your message, telephone number and any other data provided in correspondence. | We process your data under Article 6(1)(a) GDPR, which permits processing based on consent in order to respond to your message. We also rely on Article 6(1)(f) GDPR: our legitimate interest in ensuring efficient and effective communication between the website administrator/seller and the user/client. |
| Placing and fulfilling an order for services | First and last name; email address; telephone number; additionally, NIP (tax identification number) and business activity details. Providing data is voluntary, but necessary to provide the service. | Article 6(1)(b) GDPR, which permits processing for entering into a contract and fulfilling an order. |
| Archival and evidentiary purposes, including preserving information that may be used to establish facts | All data listed in the table concerning our processing of data. | Article 6(1)(f) GDPR… |
| Establishment, exercise or defence of legal claims | All of the above data. | Article 6(1)(f) GDPR… |
2. Do you have to provide us with your personal data?
a) Providing personal data is generally voluntary and is your decision.
b) However, we need certain data to meet your expectations regarding entering into a contract, using our services or contacting us.
If you make a booking, you must provide your details so that we can process the booking, provide the service and issue proof of payment.
If you ask us to contact you, you must provide your contact details so that we can email or call you.
Where providing your data is required by law, you provide those data in accordance with the applicable provisions.
3. What rights do you have under the GDPR?
a) You may email us at the address provided, or contact us by other means, at any time to obtain information about our processing of your data.
b) As a data controller, we must respond without undue delay and no later than one month. If we cannot do so, we will inform you whether we process your data. We may extend the deadline for handling your request by up to two additional months. We will endeavour to respond as quickly as possible.
c) The GDPR grants you the following rights in connection with the processing of personal data:
Right to information and transparency obligations – you have the right to know what happens to your personal data.
Right of access to personal data – if you request access to your data, we as the controller are obliged to provide the relevant information.
Right to rectification – you may ask us to correct data you consider inaccurate or to complete incomplete data.
Right to erasure (right to be forgotten) – you may ask us, as controller, to erase your personal data and inform persons to whom we disclosed them of the erasure. You may also ask that data we made public be erased by other controllers. At your request, we must also inform you of the recipients to whom we disclosed data subject to erasure.
Right to restriction of processing – you may request that we restrict processing of your personal data, for example if you dispute the accuracy of the data being processed or consider that we no longer need them for processing purposes.
Right to object – you may object to our processing of your personal data.
Right to data portability – subject to certain conditions, you may request that your data be transferred directly to another controller designated by you.
Right to lodge a complaint – if you believe that our processing of your personal data infringes the law, you may lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).
d) Please remember that not all of these rights apply in every situation. This follows from legal provisions, not from any unwillingness on our part.
e) Withdrawal of consent to data processing does not affect the lawfulness of processing carried out on the basis of your consent before its withdrawal.
Example: You submit a review of our services and consent to its publication. Later you ask us to remove it. In that case we will remove your review. Its removal does not change the fact that it was lawfully published before your request and during the time necessary for us to remove it. |
4. How long do we process your data?
a) In accordance with applicable law, we process your data only for as long as necessary to achieve the specified purpose. Afterwards, we permanently erase or destroy your personal data. The additional year of processing data collected for contract performance reflects the possibility that you may submit a request to exercise your rights just before the limitation period expires.
b) We process your data for different periods depending on the legal basis (purpose) of processing. The following table summarises these periods.
| RETENTION PERIOD | LEGAL BASIS (PURPOSE) OF PROCESSING |
|---|---|
| 3 or 6 years + 1 year | For personal data processed to establish, exercise or defend claims, the choice between 3 and 6 years depends on whether both parties are businesses. |
| Until an effective objection is made or the processing purpose is achieved | For personal data processed on the basis of the controller’s legitimate interests. |
| Until the data become outdated or no longer useful | For personal data processed mainly for website administration. |
| Until consent is withdrawn or the data are no longer useful | For personal data processed on the basis of your consent, unless otherwise expressly indicated when consent was given. |
5. Do we profile your data?
a) We may profile your data, meaning that we may use automated processes to process them. We do not use your data for automated decision-making that could affect your legal situation or produce similarly significant effects for you.
This means that the automated tools we use cannot, for example, automatically decide not to enter into a contract with you based on your individual characteristics. If an automated tool could negatively affect our relationship, we apply human review: someone on our team checks whether the automation is working correctly in the particular case.
a) Tools operating on our website may profile user behaviour to improve the website and tailor displayed content. In this case we analyse anonymous data (location, age, interests), unless you consent to tools collecting other data (by agreeing to particular cookies).
b) Like other websites, we use cookies and analytics tools. The following parts of this Privacy Policy explain how cookies work and how they affect you.
II. Data recipients
6. Who has access to your data?
a) We may share your personal data with third parties whose services we use to operate psychoterapiahoryzont.pl and our social media profiles.
b) We assure you that we carefully select the entities we work with or whose services we use, always taking appropriate data protection into account.
c) Below is a list of entities whose services we use and which may have access to your data as a result of our cooperation. We identify each recipient and the scope of our cooperation.
d) We divide recipients into two groups: entities processing data within the European Economic Area (EEA), and entities processing data outside the EEA (for example, in the USA).
e) When personal data are transferred outside the EEA, the entities processing them maintain an appropriate level of protection consistent with EU standards, including through the use of Standard Contractual Clauses adopted by the European Commission.
Entities processing data within the European Economic Area
| ENTITY | SERVICES |
|---|---|
| IT system maintenance and hosting service (data storage on a server) | IT system maintenance and hosting |
| KDP LEX Sp. z o.o., represented by Jacek Grobelny – President; ul. Nowa 28, 90-031 Łódź; KRS: 0000608513; NIP: 7282806886; REGON: 364005426 | Accounting services |
| TAXEON Sp. z o.o., ul. Kamionkowska 51, 03-812 Warsaw; KRS: 0000436069; NIP: 1132859317; REGON: 146337539 | Accounting support |
| Łukasz Szmidt, trading as Xonosoft Łukasz Szmidt, ul. Sarmacka 13/71, 02-972 Warsaw; NIP: 9512338327; REGON: 369720903 | Booking tool provider |
| Kamil Tekiela, trading as AleSeo Kamil Tekiela, ul. Przyzby 7/63, 30-385 Kraków; NIP: 679-29-19-293; REGON: 123181785 | Business and technical support |
Entities processing data outside the European Economic Area
| ENTITY | SERVICES |
|---|---|
| Google LLC | Marketing tools |
| META Inc. | Marketing tools |
III. Social media
7. Social media
a) We maintain profiles on social media platforms, and our website includes plugins linking to them.
b) We administer our profile on each platform and process your data (first name, surname, username and other details you provide on your profile), mainly to manage our profile, build a community and interact with followers.
c) Each social media platform provider sets its own platform rules and rules for processing data for its own purposes. We therefore encourage you to read the terms and privacy policy of each platform. We do not process data collected by social media platforms for our own purposes.
d) Together with the platform provider, we act as joint controllers of data associated with our profile for our shared business purposes (marketing and statistics), including processing data on visits to our profile and views of our profile through a plugin on our website.
e) Plugins linking to our profiles allow you to access them directly by clicking the platform icon. The social media platform may learn that you use our website, especially if you are logged into the platform.
f) If you do not want social media services to obtain information about your activities, we recommend logging out of your profiles and using your browser in incognito/private mode.
g) Our website contains plugins linking to our profiles on the following platforms. We also provide links to their privacy policies to make them easier to consult:
Facebook: www.facebook.com/centrumterapiihoryzont
Facebook privacy policy: www.facebook.com/privacy/explanation
Instagram: www.instagram.com/centrum_terapii_horyzont/
Instagram privacy policy: https://help.instagram.com/519522125107875?helpref=page_content
IV. Cookies and tools implemented on the website
8. Cookies
We encounter cookies every day when using the internet. Our website also uses them.
9. What are cookies and what are they used for?
a) Cookies are small text files stored on the device you use to browse websites. They may be read by us (“first-party cookies”, which we use to ensure this website functions properly and to improve our offering) or by systems belonging to other entities whose services we use (“third-party cookies”).
b) Our website uses first-party and third-party cookies (as other websites do).
c) More information about cookies can be found in the Cookie Information notice in the bottom-left corner of https://psychoterapiahoryzont.pl/.
d) The notice is marked with a cookie icon.
10. Do you have to accept all cookies used on our website?
a) No. On your first visit, we display a banner about cookies used on our website. You can decide which cookies to allow. We identify the cookies necessary for the website to function (essential cookies) and divide the others into categories to help you choose according to your preferences. All of this is described in the Cookie Information notice in the bottom-left corner of www.psychoterapiahoryzont.pl (marked with a cookie icon).
b) You can change cookie settings in your browser or delete cookies.
c) If you do not want our website to collect cookies, you can use your browser in incognito/private mode. Remember to log out of services that independently collect information about your online activities.
11. What tracking technologies do we use on our website?
a) Social media plugins linking to our profiles, as described above.
b) Analytics and marketing tools such as Meta Pixel, ManyChat, Google Analytics and Google Search Console.
12. Tools implemented on the website
Below we provide information about the tools operating on our website.
13. Google Consent Mode
a) We use tools provided by Google on our websites.
b) Google requires us to inform it whether users of our website consent to the processing of their personal data collected through Google cookies, using Google Consent Mode, which has been implemented on our website.
c) If you consent to Google cookies, we can use them for marketing activities (including remarketing and measuring advertising effectiveness, i.e. conversions).
d) Our website uses the basic version of Google Consent Mode. No data about you are sent to Google until you choose to accept cookies. Google activates its tags and collects activity data only if you consent. Without your consent, we do not send any data to Google.
e) More about consent collection in Google Consent Mode: https://support.google.com/google-ads/answer/10000067?hl=pl.
f) We recommend reading the information above.
14. Google Analytics
a) Google Analytics enables analysis of online services and activities. It uses cookies stored on your computer to analyse how users interact with the website.
b) You can disable cookies in your browser settings. However, doing so may prevent you from using all features of this website.
c) The data collected through this tool are anonymous (location, gender, age and online activity), although the provider may combine them with data collected about you through its browser and/or services.
d) We use Google Analytics to analyse website usage and improve the website according to user preferences. The resulting statistics may, for example, help us tailor our services.
e) Details of Google Analytics: https://analytics.google.com/analytics/web/provision/?hl=pl#/provision.
f) Google states that it uses data protection and security mechanisms provided for under European law. Details: https://policies.google.com/privacy?hl=pl.
15. Google Search Console
a) Google Search Console allows us to check the position of our website in Google search results, verify that it works correctly and detect errors.
b) You can disable cookies in your browser settings. However, doing so may prevent you from using all features of this website.
c) The data collected through this tool are anonymous (location, gender, age and online activity), although the provider may combine them with data collected about you through its browser and/or services.
d) Details of Google Search Console: https://support.google.com/webmasters/answer/96568?hl=en.
e) Google states that it uses data protection and security mechanisms provided for under European law. Details: https://policies.google.com/privacy?hl=pl.
16. Meta Pixel
a) This is an analytics tool consisting of a piece of code implemented on the website.
b) It allows us to target marketing activities at people who have visited our website or are interested in our activities.
c) The data collected by the tool are anonymous (location, gender, age and online activity), although the provider may combine them with data it has collected about you through your use of its platform.
d) It helps us measure the effectiveness of our advertising, reach specific audiences and understand their responses to our activities.
e) More information is available on the provider’s website: https://pl-pl.facebook.com/business/help/742478679120153?id=1205376682832142.
17. Server logs
a) Using our website involves sending requests to the server hosting it.
b) We record every request sent to the server in server logs. These records include, among other things:
IP address (a number identifying your device on the network);
date and time of the connection;
information about your web browser;
information about your operating system.
We do this to ensure the security of our services and better understand how you use them.
c) We do not link server-log data to specific users of the website. We use them only as supporting material for administrative purposes.
d) We do not disclose server-log contents to anyone other than persons authorised to administer the server.
V. Final provisions
a) Our materials: Content published on our website and profiles may be protected by copyright. Do not use it for purposes other than viewing our website unless we expressly state otherwise.
b) Questions? If you have any doubts about the legal status of content we provide (or how you may use it without legal risk), please email us at the address given at the beginning of this document. We will be happy to respond. Using our content beyond permitted personal use (i.e. for private purposes) without our consent may have legal consequences, including potential criminal and civil liability.
c) Nature of the content: Please remember that the content we provide is educational and does not replace individual professional advice.
d) Changes to the Privacy Policy: This Privacy Policy may change, for example if we change service providers or website functionality.
e) Date of update: For your convenience, we provide the date of the latest update at the beginning of this document.
Thank you for your time!
Katarzyna Wieczorek-Borek and the Horyzont Psychoterapia Team