Privacy policy

Hello!
If you've come here, it's a sure sign that you value your privacy. I understand this perfectly, which is why I'm providing you with a document where you will find, in one place, the rules for the processing of personal data and the use of cookies and other tracking technologies in connection with the operation of the website https://www.butraconsulting.com/
 

Formal information to start – the administrator of the website is Andrzej Butra, conducting business activity under the name Butra Consulting, ul. Kanadyjska 30, 32-087, Zielonki, NIP: 6791873583. This privacy policy has been structured in the form of questions and answers. The choice of this form was dictated by the desire for transparency and readability of the information presented to you. Below you will find a table of contents of this policy corresponding to the questions I answer in turn.
 

# 1: Who is the administrator of your personal data?

# 2: Who can you contact regarding the processing of your personal data?

# 3: What information do I have about you?

# 4: Where do I get your personal data from?

# 5: Is your data safe?

# 6: For what purposes do I process your personal data?

# 7: How long will I store your personal data?

# 8: Who are the recipients of your personal data?

# 9: Do I transfer your data to third countries or international organizations?

# 10: Do I use profiling? Do I make automated decisions based on your personal data?

# 11: What rights do you have in relation to the processing of your personal data?

# 12: Do I use cookies, and what are they exactly?

# 13: On what basis do I use cookies?

# 14: Can you disable cookies?

# 15: For what purposes do I use my own cookies?

# 16: What third-party cookies are used?

# 17: Do I track your behavior on my website?

# 18: Do I send you targeted ads?

# 19: How can you manage your privacy?

# 20: What are server logs?

# 21: Is there anything else you should know?
 

If you have any doubts regarding the privacy policy, you can contact me at any time by sending a message to andrzej.butra@gmail.com.
 

# 1: Who is the administrator of your personal data?

The administrator of your personal data is Andrzej Butra, conducting business activity under the name Butra Consulting, ul. Kanadyjska 30, 32-087, Zielonki, NIP: 6791873583.
 

# 2: Who can you contact regarding the processing of your personal data?

As part of the implementation of personal data protection in my company, I have decided not to appoint a data protection officer due to the fact that it is not obligatory in my situation. In matters related to personal data protection and broadly understood privacy, you can contact me at the following e-mail address: andrzej.butra@gmail.com
 

# 3: What information do I have about you?

Depending on the purpose, I may process the following information about you:

• first name and last name,
• home address,
• business address,
• NIP number (Tax Identification Number),
• e-mail address,
• phone number,
• data contained in correspondence addressed to me,
• bank account number,
• IP address,
• image (profile picture),
• activity in relation to messages sent within the newsletter,
• information about the operating system and web browser you are using,
• viewed subpages,
• time spent on the website,
• transitions between individual subpages,
• clicks on individual links,
• the source from which you came to my website,
• your age range,
• your gender,
• your approximate location limited to the town,
• your interests determined based on online activity.

I have precisely described the scope of processed data in relation to each processing purpose. Information in this regard can be found in the further part of this policy.
 

# 4: Where do I get your personal data from?

In most cases, you provide them to me yourself. This happens when: you contact me, you subscribe to the newsletter. In addition, some information about you may be automatically collected by the tools I use: the website and newsletter system mechanism collect your IP address, the newsletter system mechanism collects information about your activity in relation to the content sent to you as part of the newsletter, such as opening messages, clicking on links, etc., Google Analytics collects a number of information about how you use my website.
 

# 5: Is your data safe?

I care about the security of your personal data. I have analyzed the risks associated with individual processes of processing your data, and then implemented appropriate security measures and personal data protection. I constantly monitor the state of my technical infrastructure, review the procedures used, and introduce necessary improvements. If you have any questions regarding your personal data, I am at your disposal at andrzej.butra@gmail.
 

# 6: For what purposes do I process your personal data?

There is more than one purpose. Below is a list of them, followed by a more detailed discussion. I have also assigned appropriate legal bases for processing to individual purposes: 

• newsletter delivery – Art. 6 sec. 1 lit. a of the GDPR,
• correspondence handling – Art. 6 sec. 1 lit. f of the GDPR,
• fulfillment of tax and accounting obligations – Art. 6 sec. 1 lit. c of the GDPR,
• creating an archive for the purpose of potential necessity to defend, establish or pursue claims, as well as to identify a returning customer – Art. 6 sec. 1 lit. f of the GDPR.
   

Newsletter – details
By subscribing to the newsletter, you provide me with your name and e-mail address. Providing data is voluntary, but necessary to subscribe to the newsletter. In addition, my system used to handle the newsletter saves the IP number you used when subscribing to the newsletter, determines your approximate location, the e-mail client you use to handle e-mail, and tracks your actions taken in connection with the messages sent to you. Therefore, I also have information about which messages you opened, which links you clicked in the messages, etc. The data provided to me by you in connection with subscribing to the newsletter are used to send you the newsletter, and the legal basis for their processing is your consent (Art. 6 sec. 1 lit. a of the GDPR) expressed when subscribing to the newsletter. As for the processing of information that does not come from you, but has been collected automatically by my mailing system, I rely in this regard on my legitimate interest (Art. 6 sec. 1 lit. f of the GDPR) consisting in analyzing the behavior of newsletter subscribers in order to optimize mailing activities. You can unsubscribe from the newsletter at any time by clicking on the dedicated link in each message sent as part of the newsletter or by simply contacting me. Despite unsubscribing from the newsletter, your data will still be stored in my database to identify a returning subscriber and for the possible defense of claims related to sending you the newsletter, in particular for the purpose of proving the fact that you gave your consent to receive the newsletter and the time of its withdrawal, which constitutes my legitimate interest, referred to in Art. 6 sec. 1 lit. f of the GDPR. You can modify your data provided for the purpose of receiving the newsletter at any time by clicking on the appropriate link visible in each message sent as part of the newsletter or by simply contacting me.  

Correspondence handling – details
By contacting me, you naturally provide me with your personal data contained in the content of the correspondence, in particular your e-mail address and name. Providing data is voluntary, but necessary to establish contact. Your data is in this case processed for the purpose of contacting you, and the basis for processing is Art. 6 sec. 1 lit. f of the GDPR, i.e., my legitimate interest. The legal basis for processing after the contact has ended is also my justified purpose in the form of archiving correspondence to ensure that I can prove certain facts in the future (Art. 6 sec. 1 lit. f of the GDPR). The content of the correspondence may be archived and I am not able to definitively determine when it will be deleted. You have the right to request the history of correspondence you have had with us (if it was archived), as well as to request its deletion, unless its archiving is justified due to my overriding interests, e.g., defense against potential claims from you.  

Tax and accounting obligations – details
If I issue an invoice to you, it is part of the accounting documentation, which will be stored for the period of time required by law. Your personal data is in such a situation processed for the purpose of fulfilling my tax and accounting obligations (Art. 6 sec. 1 lit. c of the GDPR in connection with the provisions regulating tax and accounting obligations).
 

Archive – details
As part of the description of the individual purposes of personal data processing, which are listed above, I have indicated the data storage periods. These periods are often related to my archiving of certain data to ensure that I can prove certain facts in the future, recreate the course of cooperation with the client, exchanged correspondence, and defend, establish or pursue claims. In this regard, I rely on my legitimate interest, referred to in Art. 6 sec. 1 lit. f of the GDPR.  

# 7: How long will I store your personal data?

The data storage periods have been indicated separately for each processing purpose. You will find this information in the details devoted to each separate processing purpose.  

# 8: Who are the recipients of your personal data?

I would risk saying that modern business cannot do without the services provided by third parties. I also use such services. Some of these services involve the processing of your personal data. External service providers who participate in the processing of your personal data are:

• hosting provider, who stores data on the server,
• cloud computing service provider, where backup copies that may contain your personal data are stored,
• mailing system provider, where your data is stored if you are a newsletter subscriber,
• CRM system provider, where I store your data to improve the customer service process and for archival purposes,
• invoicing system provider, where your data is stored for the purpose of issuing an invoice,
• accounting office, which processes your data visible on invoices,
• law firm, which gains access to data if it is necessary to provide legal assistance to me,
• entity providing technical support services, which gains access to data if the technical work concerns areas where personal data are located,
• other subcontractors who gain access to data if the scope of their activities requires such access.  

Your personal data may also be transferred to tax offices to the extent necessary to fulfill tax, settlement, and accounting obligations. This applies in particular to all declarations, reports, statements, and other accounting documents that contain your personal data. In addition, if necessary, your personal data may be made available to entities, bodies, or institutions authorized to access data based on legal provisions, such as police, security services, courts, and prosecutors' offices.  

What's more, I use tools that collect a number of information about you related to your use of my website. This applies, in particular, to the following information: information about the operating system and web browser you are using, viewed subpages, time spent on the website, transitions between individual subpages, clicks on individual links, the source from which you came to my website, your age range, your gender, your approximate location limited to the town. Your interests determined based on online activity.  

This information in itself does not, in my opinion, constitute personal data. Since this information is collected by external tools that I use, this information is also processed by the tool providers on the terms resulting from their regulations and privacy policies. Basically, this information is used to provide and improve services, manage them, develop new services, measure the effectiveness of advertisements, protect against fraud and abuse, as well as personalize the content and advertisements displayed on individual services, websites, and applications. I have tried to describe the details in this regard in the further part of this policy, within the explanations devoted to individual tools.  

# 9: Do I transfer your data to third countries or international organizations?

Yes, some of the processing operations of your personal data may involve their transfer to third countries. I transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular in the USA. The providers of these tools guarantee an adequate level of personal data protection through appropriate compliance mechanisms provided for by the GDPR, in particular through the use of standard contractual clauses.  

The storage of personal data on servers located in third countries takes place within the framework of the following tools: MailChimp mailing system, provided by Rocket Science Group LLC, 675 Ponce de Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA – in the scope of your name, e-mail address, IP address and statistical information related to your reactions to the messages I send, Google services within the G-Suite package, provided by Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland - in the scope of all data processed within Google services, including also those data that are contained in files subject to synchronization with Google Drive.  

I would like to remind you here that I use external tools that may collect anonymous information about you. I have already mentioned this several times in this policy, including in response to the previous question. The providers of these tools often use servers located all over the world, in particular in the United States of America (USA), to store the collected information.  

# 10: Do I use profiling? Do I make automated decisions based on your personal data?

I do not make decisions about you based solely on automated processing, including profiling, which would produce legal effects concerning you or similarly significantly affect you.  

However, I do use tools that can take certain actions depending on the information collected through tracking mechanisms, but I believe that these actions do not significantly affect you, as they do not differentiate your situation as a customer, do not affect the terms of the contract you can conclude with me, etc.  

By using certain tools, I can, for example, send you personalized advertisements based on your previous actions on my website or suggest products that may interest you. This is referred to as behavioral advertising. I encourage you to learn more about behavioral advertising, especially regarding issues related to privacy. Detailed information, along with the ability to manage settings for behavioral advertising, can be found here: http://www.youronlinechoices.com.
 

I emphasize that within the tools I use, I do not have access to information that would allow for your identification. The information I am talking about here is, in particular: information about the operating system and web browser you are using, viewed subpages, time spent on the website, transitions between individual subpages, the source from which you came to my website, your age range, your gender, your approximate location limited to the town, your interests determined based on online activity.  

I do not combine the information indicated above with your personal data that are in my databases. This information is anonymous and does not allow me to identify you. This information is stored on the servers of the providers of individual tools, and these servers can most often be located all over the world.
 

# 11: What rights do you have in relation to the processing of your personal data?

The GDPR grants you the following potential rights related to the processing of your personal data:

• the right to access your data and receive a copy of it,
• the right to rectification (correction) of your data,
• the right to erasure of data (if, in your opinion, there are no grounds for me to process your data, you can request that I delete them),
• the right to restriction of processing (you can request that I restrict the processing of data only to their storage or performing actions agreed with you, if in your opinion I have incorrect data or process them without a valid basis),
• the right to object to the processing of data (you have the right to object to the processing of data based on a legitimate interest; you should indicate a specific situation which, in your opinion, justifies my ceasing to process the data covered by the objection; I will cease processing your data for these purposes, unless I demonstrate that the grounds for my processing of the data are overriding your rights or that your data are necessary for me to establish, pursue or defend claims),
• the right to data portability (you have the right to receive from me in a structured, commonly used and machine-readable format the personal data that you have provided to me on the basis of a contract or your consent; you can instruct me to send these data directly to another entity),
• the right to withdraw consent to the processing of personal data, if you have previously given such consent,
• the right to lodge a complaint with a supervisory authority (if you find that I am processing data unlawfully, you can lodge a complaint with the President of the Personal Data Protection Office or another competent supervisory authority).  

The rules related to the exercise of the above-mentioned rights are described in detail in Art. 16 – 21 of the GDPR. I encourage you to familiarize yourself with these provisions. For my part, I consider it necessary to explain to you that the above-mentioned rights are not absolute and will not be available to you in relation to all processing activities of your personal data.  

I emphasize that one of the rights indicated above is always available to you - if you believe that I have violated the provisions on personal data protection when processing your personal data, you have the right to lodge a complaint with a supervisory authority (the President of the Personal Data Protection Office).  

You can also always ask me to provide you with information about what data I have about you and for what purposes I process it. All you need to do is send a message to andrzej.butra@gmail.com. However, I have made every effort to ensure that the information you are interested in is comprehensively presented in this privacy policy. You can also use the e-mail address provided above in case of any questions related to the processing of your personal data.  

# 12: Do I use cookies, and what are they exactly?

My website, like almost all other websites, uses cookies. Cookies are small text information, stored on your end device (e.g., computer, tablet, smartphone), which can be read by my ICT system (first-party cookies) or the ICT systems of third parties (third-party cookies). Certain information can be saved and stored in cookies, to which ICT systems can then gain access for specific purposes. Some of the cookies I use are deleted after the end of the web browser session, i.e., after it is closed (so-called session cookies). Other cookies are stored on your end device and allow me to recognize your browser the next time you visit the website (persistent cookies). If you want to learn more about cookies as such, you can read, for example, this material: https://pl.wikipedia.org/wiki/HTTP_cookie.  

# 13: On what basis do I use cookies?

I use cookies based on your consent, except when cookies are necessary for the proper provision of the service to you by electronic means. Cookies that are not necessary for the proper provision of the service by electronic means remain blocked until you consent to my use of cookies. During your first visit to my website, I will show you a message asking for your consent. Remember that disabling or restricting the handling of cookies may prevent you from using some of the functions available on my website and may cause difficulties in using my website, as well as many other websites that use cookies. For example, if you block cookies for social networking site plugins, the buttons, widgets, and social functions implemented on my website may be unavailable to you.  

# 14: Can you disable cookies?

Yes, you can manage cookie settings in your web browser. You can block all or selected cookies. You can also block cookies from specific websites. You can also delete previously saved cookies and other website and plugin data at any time. Web browsers also offer the option of using incognito mode. You can use it if you do not want information about visited pages and downloaded files to be saved in your Browse and download history. Cookies created in incognito mode are deleted when all windows of this mode are closed.  
 

There are also browser plugins available that allow you to control cookies, such as Ghostery (https://www.ghostery.com). Additional software, in particular antivirus packages, etc., may also provide the option of controlling cookies. In addition, tools are available on the Internet that allow you to control certain types of cookies, in particular to collectively manage behavioral advertising settings (e.g., www.youronlinechoices.com/, www.networkadvertising.org/choices).  

Remember that disabling or restricting the handling of cookies may prevent you from using some of the functions available on my website and may cause difficulties in using my website, as well as many other websites that use cookies. For example, if you block cookies for social networking site plugins, the buttons, widgets, and social functions implemented on my website may be unavailable to you.  

# 15: For what purposes do I use my own cookies?

First-party cookies are used to ensure the proper functioning of individual website mechanisms. Information about your defined cookie settings made from the level of the cookie management mechanism is also stored in first-party cookies.
 

# 16: What third-party cookies are used?

The following third-party cookies are used on my website: Google Analytics, Google Tag Manager, Google AdWords, Google AdSense, Facebook Custom Audiences, Facebook, LinkedIn, Pinterest (social media tool cookies), Webwave
 

Details regarding individual third-party cookies are described below.
 

Google Analytics - details
I use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. I carry out these activities based on my legitimate interest, which consists in creating statistics and analyzing them in order to optimize my websites.

To use Google Analytics, I have implemented a special Google Analytics tracking code in the code of my website. The tracking code uses cookies from Google LLC regarding the Google Analytics service. You can block the Google Analytics tracking code at any time by installing a browser add-on provided by Google: https://tools.google.com/dlpage/gaoptout. Google Analytics automatically collects information about your use of my website. The information collected in this way is most often transferred to Google servers, which may be located all over the world, and stored there.  

Due to the IP address anonymization activated by me, your IP address is shortened before being further transmitted. Only in exceptional cases is the full IP address transferred to Google servers and only there shortened. The anonymized IP address transmitted by your browser as part of Google Analytics is generally not combined with other Google data.  

I emphasize that within Google Analytics I do not collect any data that would allow for your identification. Therefore, the data collected within Google Analytics does not constitute personal data for me. The information I have access to within Google Analytics is, in particular: information about the operating system and web browser you are using, the subpages you view on my website, the time spent on my website and its subpages, transitions between individual subpages, the source from which you came to my website.  

In addition, I use the following Advertising Features within Google Analytics: demographics and interests reports, remarketing, advertising reporting features, user-ID.

Within the Advertising Features, I also do not collect personal data. The information I have access to is, in particular: your age range, your gender, your approximate location limited to the town, your interests determined based on online activity.  

Google Analytics and Google Analytics 360 services have obtained the ISO 27001 independent security standard certificate. ISO 27001 is one of the most widely recognized standards in the world and certifies that the systems supporting Google Analytics and Google Analytics 360 meet the relevant requirements. If you are interested in the details related to Google's use of data from websites and applications that use Google services, I encourage you to read this information: https://policies.google.com/technologies/partner-sites.  

Google Tag Manager – details
I use the Google Tag Manager tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, which allows me to manage tags, i.e., small code snippets, thanks to which I am able to control user traffic and behavior, collect information about the effectiveness of advertisements, and take actions aimed at improving my website. Google Tag Manager does not collect any information that allows for your identification, however, this tool triggers other tags, which in turn can collect data.
 

Google AdWords - details
I use the remarketing functions available within the Google AdWords system operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. I carry out these activities based on my legitimate interest, which consists in marketing my own products or services.  

When you visit my website, a Google remarketing cookie is automatically left on your device, which collects information about your activity on my website. Thanks to the information collected in this way, I am able to display advertisements to you within the Google network depending on your behavior on my website. For example, if you view a product, information about this fact will be recorded by the remarketing cookie, which will allow me to send you an advertisement regarding this product or any other that I deem appropriate. This advertisement will be displayed to you within the Google network while you are using the Internet, Browse other websites, etc.  

I emphasize that when using Google Ads, I do not collect any data that would allow for your identification. Any combination of data in such a way that it takes on the nature of personal data may be done by Google, but in this regard I am no longer responsible for it, because Google carries out these activities based on an agreement concluded with you as a user of Google services.

When using Google AdWords, I am only able to define the target groups that I would like my ads to reach. Based on this, Google decides when and how to present my advertisement to you.

Further processing of information takes place only if you have given Google your consent to link your Browse history with your account and to use information from your Google account to personalize the ads that are displayed on websites. In such a situation, Google will use your data to create and define target group lists for remarketing purposes on various devices. For this purpose, Google temporarily combines the collected information with other data it has to create target groups.  

If you do not want to receive personalized ads, you can manage your ad settings directly on the Google side: https://adssettings.google.com/. If you are interested in the details related to Google's use of data from websites and applications that use Google services, I encourage you to read this information: https://policies.google.com/technologies/partner-sites.  

Google AdSense – details
I display advertisements on my websites within the Google AdSense network operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. I carry out these activities based on my legitimate interest, which consists in monetizing the content I publish.

My website, in connection with the display of advertisements on it within the AdSense network, contains advertising tags that instruct your web browser to send a request for advertising content from Google servers. Along with the advertising content, the server also sends a cookie file. Cookies are used to display ads based on your previous visits to my website or other websites. AdSense also uses cookies to improve the quality of ads. Often the applications  

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