INFORMATION ON THE PROCESSING OF PERSONAL DATA ON THE EURODEBT.EU PROFILE ON THE FACEBOOK SOCIAL PLATFORM
1. WHO WE ARE
EURODEBT.EU limited liability company, Pl. Bankowy 2, 00-095 Warsaw, KRS: 0000859424, NIP: 6182186461, REGON: 387015071 (hereinafter referred to as "EURODEBT"). You can contact us by e-mail: info@eurodebt.eu, by phone at: +48 22 266 24 88 or by post to the address of the registered office.
Eurodebt manages the Eurodebt.eu profile on Facebook at https://www.facebook.com/EurodebtEu/ (hereinafter referred to as "our profile"), placed on the Facebook social platform. The provider of the social platform Facebook is Meta Platforms Ireland Ltd., based at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland (hereinafter: "Meta" or "Facebook").
Eurodebt and Meta are joint data controllers in the processing of personal data, the purposes of which are jointly defined by us and Meta, in particular in the scope of aggregate data ("Page Insights Data") provided by Facebook regarding the use of our profile (more information on this subject can be found here: https://www.facebook.com/legal/terms/page_controller_addendum).
2. METHOD OF PROCESSING PERSONAL DATA OF USERS OF OUR PROFILE
Eurodebt has no control over how Meta processes personal data (including when interacting with Facebook Pages in general). For information on the processing of personal data by Meta, please refer to Facebook's privacy policy, available here: https://www.facebook.com/policy.php.
When visiting our website, Meta as the administrator collects user data through cookies. Eurodebt has no information on what user data is collected by Facebook. Eurodebt also does not have full access to collected user data. Eurodebt can only access public profile information.
https://www.facebook.com/policies/cookies/
3. WHAT PERSONAL DATA IS PROCESSED
A. Personal data visible when interacting with our profile
As part of our profile, we have access to the following personal information, which is visible when a user decides to like or follow our profile and/or interact with its content:
- if you send us a message, we have access to your public profile What is public information on Facebook? | Facebook Help Center) (including his username), as well as the content and date and time of sending this message;
- if you comment on a post on our profile, we have access to your public profile (including your username), as well as the content, date and time of that comment;
- if you interact with our profile content (like, share), we may view your public profile (including your username) and your reaction;
- if the user participates in advertising campaigns organized by us (e.g. such as competitions), we have access to the data provided by him necessary to participate in them. More details on the collection and processing of this personal data can be found in the Information Note on the processing of personal data included in the Terms and Conditions for a given campaign.
The above-mentioned personal data are processed in our legitimate interest pursuant to art. 6 sec. 1 lit. f RODOto manage user interaction when you voluntarily use our site or send us a private message on Facebook. These data are stored for the duration of our profile. You can unfollow our profile at any time.
If you post photos or other comments/posts containing other people's personal information (profile name, photo, etc.), make sure that these people have been informed about it in advance. If your photos or comments/posts concern minors, we will assume that you are acting as the legal representative of that minor (parent, guardian, etc.) or that you have obtained prior consent from the minor's legal representative (if you are not the legal representative).
B. Data processed for Page Insights
When a user interacts with our website, Facebook processes his personal data, on the basis of which he provides us with aggregate statistics (so-called "PageInsights").
More information about Page Insights is available from Facebook here: https://www.facebook.com/legal/terms/information_about_page_insights_data.
Facebook is responsible for providing information on the processing of personal data for Page Insights and responding to users' requests to exercise their rights under the GDPR. In order to obtain information on data processing in the context of Page Insights and submit requests in this matter, please use the contact details provided by Facebook (https://www.facebook.com/legal/terms/information_about_page_insights_data). Any Page Insights inquiries you send to us will be directed to Facebook.
C. Personal data related to the personalization of content in terms of recipients
When we personalize the audience for our Facebook posts or advertising campaigns, we establish categories of interests that may include you (e.g. men or women aged 20-25 in certain locations).
Personal data that may be collected and processed by Facebook for the above purposes personalization, are determined by Facebook without our participation and may include age, gender, occupation, interaction history, lifestyle data, online purchases of products and services, and other data, in accordance with Facebook's policy. This data is collected and processed by Facebook, but we only have access to those categories that have already been established by Facebook. Information on the collection and processing of data can be found in the information provided by Facebook here:
(https://www.facebook.com/full_data_use_policy) and you can use the options for Facebook ads in the user settings for Facebook Adds (https://www.facebook.com/adpreferences/?entry_product=ad_preferences_delegation).
This personal data is processed in our legitimate intereststo promote our business.
These data are stored for the duration of our profile.
4. HOW WE ADMINISTRATE THE CONTENT OF OUR FACEBOOK PROFILE
4.1 We reserve the right to remove any comments from our Facebook profile:
- unlawful or inciting unlawful activities;
- defamatory, vulgar, racist or xenophobic;
- infringing copyright;
- advocating discrimination based on race or ethnicity, religion, disability, age or sexual orientation;
- inconsistent with Facebook's policies, including Facebook's Social Standards.
4.2 We strive to ensure safety and comfort when using our Facebook profile and we expect users of this profile to refrain from placing prohibited commercial advertisements in comments or private messages to us or to users of our profile; sending viruses or other malicious codes in comments or private messages to us or to users of our profile; collect content or information about you by automated means and access our Facebook profile in any other way using automated means (such as data collection bots, spider or scraper bots or programs) without our consent.
5. SHARING PERSONAL DATA
Users' personal data is made available only in the cases described below. We will take appropriate measures to ensure that personal data is processed, secured and transferred in accordance with legal requirements.
Regarding sharing information via Facebook, please refer to Facebook's policies (https://www.facebook.com/full_data_use_policy).
5.1 Disclosure of personal information to third parties
Your personal data may be made available only to the extent necessary and only to the following categories of third parties:
(a) Facebook, which is a co-administrator of your personal data;
(B) third parties that may administer our Facebook page (e.g. marketing agencies);
(C) other entities, such as public authorities and institutions, accountants, auditors, lawyers and other external professional advisors, if their work requires us to know such data or if we are obliged by law to disclose it;
(D) companies that provide us with products and services (contractors), such as IT system providers and related support service providers, telecommunications service providers, backup and disaster recovery services, IT security services.
Users' personal data will also be disclosed to third parties:
- if you request or consent to it;
- persons who can demonstrate that they are legally authorized to act on your behalf;
- when we move our Facebook page, which may be in our legitimate interest to expand or develop our business, e.g.:
- in the event of a business transfer that is related to the profile you are following, the buyer will take over the profile along with your personal data;
- if the Operator (or a significant part of its assets) is acquired by a third party, in which case our Facebook page will be one of the transferred assets;
- where we are required to disclose your personal information to comply with legal obligations, comply with any lawful request by government authorities, and where it may be necessary to comply with security requirements onrodoor law enforcement, or to prevent certain unlawful activities;
- in response to any claims, to protect our rights or the rights of third parties.
Personal data may also be shared with another group company where we believe it is in our legitimate interest, for internal administrative purposes (e.g. data storage, organization of promotional activities) or to control and monitor our internal processes.
6. TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
As a rule, your personal data is not transferred by us to recipients outside the European Economic Area (EEA). However, if this happens, we will take steps to ensure that the recipient adequately protects your personal data, such as the inclusion of standard clauses approved by the European Commission or the existence of an adequacy decision issued by the European Commission in the recipient's country, and we will update this notification.
Facebook may transfer your personal data outside the EEA. To do this, please refer to Facebook's policy (https://www.facebook.com/full_data_use_policy).
7. USER RIGHTS
As a data subject, you have certain specific rights related to the personal data we collect from you. We can only consider requests that relate to the processing of personal data by Eurodebt. If you wish to exercise your rights with respect to Facebook, please contact Facebook as set out in its policy (https://www.facebook.com/policy.php).
In addition, for any issues related to the processing of personal data as part of the Page Insights service, you should use the contact details provided by Facebook (https://www.facebook.com/legal/terms/information_about_page_insights_data).
The user has the following rights:
(a) Right of Access: You may request information about the personal information we hold about you, including the categories of information we hold or control, what it is used for, where we collected it from if we obtained it indirectly, and to whom they are disclosed, if they are disclosed at all.
(b) Right to rectification: You have the right to rectify your personal data that we process.
(c) Right to restriction of processing: You have the right to limit the processing of your personal data if:
- you contest the accuracy of your personal data, for the period we need to verify its accuracy,
- the processing is unlawful, but instead of deleting your personal data, you request the restriction of their use instead,
- we no longer need your personal data, but you request it for the establishment, exercise or defense of legal claims, or
- you object to the processing and we check whether our legitimate grounds are sufficient.
(d) Right to erasure: You have the right to delete the personal data we process if:
- personal data is no longer necessary for the purposes for which it was collected or otherwise processed;
- the data subject has withdrawn the consent on which the processing is based and there is no other basis for processing;
- the data subject objects to the processing for reasons related to their particular situation and there are no overriding legitimate grounds for processing;
- personal data was processed unlawfully;
- personal data must be deleted in order to comply with a legal obligation to which the data controller is subject.
unless these data are necessary for:
- exercising the right to freedom of expression and information;
- complying with a legal obligation to which we are subject;
- for archiving purposes in the public interest, for scientific or historical research or for statistical purposes; or
- establishment, exercise or defense of legal claims.
(e) Right to object: You may object to the processing of your personal data at any time for reasons related to your particular situation, provided that the processing is based on our legitimate interests or the interests of a third party. In this case, we will not process your personal data unless (i) we can demonstrate compelling legitimate grounds for processing that override the interests, rights and freedoms of the data subject, or (ii) processing is necessary to establish, exercise or protect legal claims.
8. RIGHT TO LODGE A COMPLAINT
In any case, you have the right to lodge a complaint with the President of the Office for Personal Data Protection (ul. Stawki 2, 00-193 Warsaw, tel. 22 531-03-00, e-mail: rekrutia@uodo.gov.pl), if you decide that the processing of personal data violates the law RODO or other applicable regulations regarding the processing of personal data. The Office for Personal Data Protection can also be contacted via the website: www.uodo.gov.pl
9. CONTACT DETAILS OF EURODEBT.EU sp. z o. o.:
Questions regarding the protection of personal data and requests to exercise your rights related to the processing of personal data by Eurodebt should be sent to the following contact details:
Eurodebt EU limited liability company, address: Pl. Bankowy 2, 00-095 Warsaw.
Email: info@eurodebt.eu
Phone: +48 22 266 24 88
Eurodebt has appointed a data protection officer who can be contacted by e-mail:spekt@eurodebt.eu, contact form at: https://eurodebt.eu/kontakt/ in the "contact" tab or in writing to the address of the administrator's seat. The data protection officer can be contacted in all matters regarding the processing of personal data and the exercise of rights related to data processing.