Kluazula Instagram

1. personal data controller

a) within the framework of using the functionality of the Account is Magnicity Warsaw Spółka z ograniczoną odpowiedzialnością with its seat in Warsaw, 59 Złota Street, 00-120 Warsaw, registered in the register of entrepreneurs, kept by the District Court for the Capital City of Warsaw in Warsaw, XII Economic Department of the National Court Register, under KRS number: 0001043051, NIP: 5252961210, REGON: 525637863 (“Administrator”),

(b) in connection with the processing of statistical data about your activity on the Account, the controller is the Administrator and Meta Platforms Ireland Limited with its registered office at Serpentine Avenue, Block J, Dublin 4, Ireland (“Meta Ireland”), together acting as joint controllers. For more on Meta Ireland’s processing of your data, please visit https://privacycenter.instagram.com/. For information on the data co-management by the Controller and Meta Ireland, please visit: https://www.facebook.com/legal/terms/page_controller_addendum.

2 Contacting the Administrator

The Administrator can be contacted by mail at the registered office address given above, as well as by email at info@highlinewarsaw.com.

3 Purpose of processing

Personal data processed in connection with visiting or using the functionality of the Account will be processed for:

(a) administration and management of the Account, including:

• Supervision of published content to ensure order and security of users of the Account, to prevent fraud, to ensure the security of the ICT environment,
• To respond to comments posted by users in order to ensure proper communication,
• Analyzing the activity of users of the Account, including for the purpose of collecting data on the number of interactions (e.g., likes), comments, tags and shares of the Account or the content posted therein – for analytical and statistical purposes in order to better understand the market and the needs of users, which allows us to adjust the content and communication strategy,
• Marketing and promotion of the Administrator’s and the Administrator’s group companies’ products and services in order to identify users interested in a given topic and to carry out activities aimed at increasing the number of observers and active members of the Account community; based on the Administrator’s legitimate interest in marketing its own and the Administrator’s group companies’ products and services, ensuring continuity of business communications and taking care of the brand image of the Administrator and the Administrator’s group companies (Article 6(1)(f) RODO)

b) to conduct communication via Instagram tools on the basis of the Administrator’s legitimate interest, which is to maintain contact with persons interested in the Administrator’s business, to conduct all communications in connection with the Administrator’s business in a timely manner, to ensure the quality of cooperation with customers and other interested parties (Article 6(1)(f) RODO);

(c) to establish, assert or defend against claims on the basis of the Administrator’s legitimate interest in securing information for the purpose of proving certain facts, establishing, asserting and defending against claims (Article 6(1)(f) RODO).

4 Data sources

The source of data related to the maintenance of the Account is primarily you as a user of the Instagram portal. Your statistical data is also obtained by the Administrator from Meta Ireland.

5 Data categories

Information about users is processed depending on how users use the Account. The Administrator may process the following information:

• (b) the information you provide that is in your individual account that you have marked as public, such as, for example, your account name, which may include your name, your profile photo, your circle of watchers and followers, your posts, which may take the form of photos, your markings on other users’ photos, testimonials, and the data in your description;
• (c) Your activity on the Account including information such as observing the Account, sending messages to the Administrator, liking posts on the Account, commenting on posts on the Account, sharing posts on the Account, marking the Administrator in your posts;
• (d) private messages addressed to the Administrator: the content of these messages and any personal data related to them;
• e) statistical data: Meta Ireland provides the Administrator with aggregate statistics created on the basis of certain events recorded by Meta Ireland’s servers when users use the Account and related content. Site Administrators (including the Administrator) do not have access to the data processed from events – they only have access to the aggregate statistics of the site (their Account). For more information, please visit: https://www.facebook.com/legal/terms/page_controller_addendum.

6 Data recipients

The recipients of your personal data are:

• (a) Meta Ireland. Your personal data provided on Instagram in connection with the use of your Account is available to Meta Ireland as administrator of the Instagram portal;
• (b) other Instagram users. Any personal information contained in comments, likes, tags and other publicly available data posted on the Account may also be available to other Instagram users;
• (c) other recipients, if necessary to achieve the purpose of processing. In such a case, the Administrator will transfer personal data in particular to the following recipients: entities that provide IT support services to the Administrator, including IT systems maintenance and servicing, data hosting and cloud services, authorized employees and associates, marketing agency, postal operators and couriers, law firms, Magnicity Warsaw group companies;
• (d) The Administrator may be required to make the data available to authorities and institutions authorized to access the data by law, such as the police, the prosecutor’s office, the courts.

7 Processing outside the EEA

As a general rule, the Administrator does not transfer your personal data to a third country (i.e. a country outside the European Economic Area). If such a transfer of your personal data were to take place – the Administrator will do so on the basis of standard safeguard clauses (based on Article 46(2)(c) of the RODO) or provide another mechanism that is lawful and legalizes such a transfer and provides adequate guarantees for the protection of personal data in accordance with the applicable legal provisions in this regard.

In connection with the use of Instagram, data is transferred to third countries by Meta Ireland. The Administrator has no control over how Meta Ireland handles your personal data and transfers it to third countries.

8 Data retention period

Personal data processed under the Account will be processed by the Administrator for the duration of the Account or the period for which you are an active user of the Account (e.g., until you quit observing the Account), unless an effective objection to such processing is raised beforehand. After this time, your personal data will be processed for the period specified by the statute of limitations for claims, unless you have previously raised an effective objection to such processing. As a general rule, the Administrator has no control over the period of processing of your personal data for Meta Ireland’s own purposes, which results from Meta Ireland’s processing rules available on Instagram (in Instagram’s Terms of Service and Privacy Policy).

9 [Your powers].

You have the right to request from the Administrator access to your personal data, rectification, erasure, restriction of processing and data portability. You have the right to object to the processing of your personal data, whereby the right to object will not be exercised if there are valid legitimate grounds for processing that override your interests, rights and freedoms.

As indicated in this notice, the Administrator has limited ability to set the rules for the processing of personal data on the Account. Meta Ireland is responsible for enabling users to exercise their rights under the RODO to the extent that it processes the data itself and to the extent that it processes personal data as part of its co-administration for site statistics. Under the RODO, users have the right to access, rectify, transfer, delete their data, to object to the processing of their data, and to have their data restricted. You can learn more about these rights in the settings of your page on Instagram and at https://privacycenter.instagram.com/. You may also contact Meta Ireland’s Data Protection Officer, whose contact details can be found in Meta Ireland’s privacy policy. Notwithstanding the above division of tasks between the Controller and Meta Ireland, you have the right to exercise your rights against either Controller.

10 [Right to file a complaint].

You may complain about the Administrator’s actions to the competent supervisory authority, in particular in the country of your habitual residence, your place of work or the place where the alleged violation was committed. In Poland, the supervisory authority is the President of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw.

Meta Ireland and the Controller have agreed that the Irish Data Protection Commission is the primary supervisory authority responsible for overseeing the processing of data for site statistics (Accounts). You have the right to lodge a complaint with the Irish Data Protection Commission (see www.dataprotection.ie) or any other supervisory authority.

11 [Voluntariness of providing data].

Providing data in the use of the Account is voluntary. Failure to provide data may prevent the use of certain functionalities (such as the ability to post comments or contact the Administrator using Instagram).

12 [Profiling].

The administrator does not perform profiling, including automated decisions against you.