PRIVACY POLICY

1. This Privacy Policy sets out the rules for the processing of personal data obtained via the covingtontax.net (hereinafter referred to as: ” Website “).

2. The owner of the website and at the same time the Data Administrator is Toya simmons , hereinafter referred to as the Administrator .

3. Personal data collected by the Administrator via the Website are processed in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (General Data Protection Regulation), also referred to as the GDPR .

4. The Administrator takes special care to respect the privacy of Customers visiting the Website.

§ 1 Type of data processed, purposes and legal basis

1. The administrator collects information on natural persons performing legal transactions not directly related to their activity, natural persons conducting business or professional activity on their own behalf, and natural persons representing legal persons or organizational units that are not legal persons, to whom the law grants legal capacity, conducting on their own behalf business or professional activity, hereinafter jointly referred to as Clients.

2. Customers’ personal data is collected in the case of:

using the contact form service on the Website in order to perform the contract provided electronically. Legal basis : necessity to perform the contract for the provision of the contact form service (Article 6(1)(b) of the GDPR)

3. When using the contact form service, the Customer provides the following data:

– e-mail adress

– name

– Phone number

4. When using the Website, additional information may be downloaded, in particular: the IP address assigned to the Customer’s computer or the external IP address of the Internet provider, domain name, browser type, access time, operating system type.

5. Navigational data may also be collected from the Customers, including information about links and references which they decide to click or other activities undertaken on the Website. Legal basis – legitimate interest (Article 6(1)(f) of the GDPR), consisting in facilitating the use of services provided electronically and improving the functionality of these services.

6. The transfer of personal data to the Administrator is voluntary.

§ 2 Who are the data made available to or entrusted to and how long are they stored?

1. The Customer’s personal data is transferred to service providers used by the Administrator when running the Website. Service providers to whom personal data are transferred, depending on contractual arrangements and circumstances, or are subject to the Administrator’s instructions as to the purposes and methods of data processing (processors) or independently determine the purposes and methods of their processing (administrators).

1.1. Processors . The Administrator uses suppliers who process personal data only at the Administrator’s request . They include e.g. suppliers providing hosting services, accounting services, marketing systems, systems for analyzing traffic on the Website, systems for analyzing the effectiveness of marketing campaigns

1.2. Administrators . The Administrator uses suppliers who do not act only on instructions and set the goals and methods of using Customers’ personal data themselves. They provide electronic payment and banking services.

2. Location . Service providers are mainly based in Poland and other countries of the European Economic Area (EEA).

3. Customers’ personal data is stored:

3.1. If the basis for the processing of personal data is consent, then the Customer’s personal data are processed by the Administrator until the consent is revoked, and after the consent is revoked, for a period of time corresponding to the period of limitation of claims that may be raised by the Administrator and which may be raised against him. Unless a special provision provides otherwise, the limitation period is six years, and for claims for periodic benefits and claims related to running a business – three years.

3.2. If the basis for data processing is the performance of the contract, then the Customer’s personal data is processed by the Administrator for as long as it is necessary to perform the contract, and after that time for a period corresponding to the period of limitation of claims. Unless a special provision provides otherwise, the limitation period is six years, and for claims for periodic benefits and claims related to running a business – three years.

4. In the event of a request , the Administrator provides personal data to authorized state authorities, in particular organizational units of the Prosecutor’s Office, the Police, the President of the Office for Personal Data Protection, the President of the Office of Competition and Consumer Protection or the President of the Office of Electronic Communications.

§ 3 Cookie mechanism, IP address

1. The website uses small files called cookies. They are saved by the Administrator on the end device of the person visiting the Website, if the web browser allows it. A cookie file usually contains the name of the domain from which it comes, its “expiration time” and an individual, randomly selected number identifying this file. Information collected using this type of files helps to adapt the products offered by the Administrator to the individual preferences and real needs of people visiting the Website ..

2. The administrator uses two types of cookies:

2.1. Session cookies : after the browser session ends or the computer is turned off, the saved information is deleted from the device’s memory. The session cookies mechanism does not allow for downloading any personal data or any confidential information from the Customers’ computers.

2.2. Persistent cookies : they are stored in the memory of the Customer’s end device and remain there until they are deleted or expire. The mechanism of persistent cookies does not allow downloading any personal data or any confidential information from the Customer’s computer.

3. Administrator uses own cookies in order to:

3.1. analyzes and research as well as audience audits, and in particular to create anonymous statistics that help to understand how customers use the Website, which allows improving its structure and content.

4. The administrator uses external cookies to:

4.1. presenting on the information pages of the Website, a map showing the location of the Administrator’s office , using the website maps.google.com (administrator of external cookies: Google Inc with its registered office in the USA)

5. The cookie mechanism is safe for the computers of Customers visiting the Website. In particular, this way is not possible to get viruses or other unwanted software or malicious software to the Customers’ computers. However, in their browsers, customers have the option of limiting or disabling the access of cookies to computers. If you use this option, the use of the Website will be possible, except for the functions that by their nature require cookies.

6. The Administrator may collect Customers’ IP addresses. The IP address is a number assigned to the computer of the person visiting the Website by the Internet service provider. The IP number allows access to the Internet. In most cases, it is assigned to your computer dynamically, i.e. it changes each time you connect to the Internet, and for this reason it is commonly treated as non-personally identifiable information. The IP address is used by the Administrator when diagnosing technical problems with the server, creating statistical analyzes (e.g. determining from which regions we record the most visits), as information useful in administering and improving the Website, as well as for security purposes and possible identification of burdening the server , undesirable automated programs to view the content of the Website.

§ 4 Rights of data subjects

1. The right to withdraw consent – legal basis: art. 7 sec. 3 GDPR.

1.1. The customer has the right to withdraw any consent he has given

1.2. Withdrawal of consent takes effect from the moment of withdrawal of consent.

1.3. Withdrawal of consent does not affect the processing carried out by the Administrator and in accordance with the law before its withdrawal.

1.4. Withdrawal of consent does not entail any negative consequences for the Customer, however, it may prevent further use of services or functionalities that, according to the law, the Administrator may only provide with consent.

2. The right to object to data processing – legal basis: art. 21 GDPR.

2.1. The customer has the right to object at any time – for reasons related to his particular situation – to the processing of his personal data, including profiling, if the Administrator processes his data based on a legitimate interest, e.g. marketing of the Administrator’s products and services , keeping usage statistics individual functionalities of the Website and facilitating the use of the Website, as well as satisfaction surveys.

2.2. Resignation in the form of an e-mail from receiving marketing messages regarding products or services will mean the Customer’s objection to the processing of his personal data, including profiling for these purposes.

2.3. If the Customer’s objection turns out to be justified, the Administrator will have no other legal basis for the processing of personal data, the Customer’s personal data will be deleted, to the processing of which the Customer has objected.

3. The right to delete data (“the right to be forgotten”) – legal basis: art. 17 GDPR.

3.1. The customer has the right to request the deletion of all or some of his personal data.

3.2. The customer has the right to request the deletion of personal data if:

3.2.1. the personal data are no longer necessary for the purposes for which they were collected or processed

3.2.2. withdrew a specific consent to the extent that personal data was processed based on his consent

3.2.3. objected to the use of his data for marketing purposes

3.2.4. personal data is processed unlawfully

3.2.5. personal data must be deleted in order to comply with a legal obligation provided for in Union law or the law of a Member State to which the Administrator is subject

3.2.6. personal data has been collected in connection with offering information society services

3.3. Despite the request to delete personal data, in connection with raising an objection or withdrawing consent, the Administrator may retain certain personal data to the extent that processing is necessary to establish, pursue or defend claims, as well as to fulfill a legal obligation requiring processing under the law Union or Member State law to which the Administrator is subject . This applies in particular to personal data including: name, surname, e-mail address, which data is retained for the purpose of handling complaints and claims related to the use of the Administrator’s services, or additionally the address of residence / correspondence address, order number, which data are kept for the purpose of considering complaints and claims related to concluded sales contracts or the provision of services.

4. The right to limit data processing – legal basis: art. 18 GDPR.

4.1. The customer has the right to request the restriction of the processing of his personal data. Submitting a request, until it is considered, prevents the use of specific functionalities or services, the use of which will involve the processing of data covered by the request. The administrator will also not send any messages, including marketing ones.

4.2. The customer has the right to request the restriction of the use of personal data in the following cases:

4.2.1. when he questions the correctness of his personal data – then the Administrator limits their use for the time needed to verify the correctness of the data, but not longer than for 7 days

4.2.2. when the processing of data is unlawful, and instead of deleting the data, the Customer requests the restriction of their use

4.2.3. when personal data are no longer necessary for the purposes for which they were collected or used, but they are needed by the Customer in order to establish, pursue or defend claims

4.2.4. when he objected to the use of his data – then the restriction takes place for the time needed to consider whether – due to the particular situation – the protection of the interests, rights and freedoms of the Customer outweighs the interests pursued by the Administrator by processing the Customer’s personal data.

5. Right of access to data – legal basis: art. 15 GDPR.

5.1. The customer has the right to obtain confirmation from the Administrator whether he processes personal data, and if this is the case, the customer has the right to:

5.1.1. access your personal data

5.1.2. obtain information about the purposes of processing, categories of personal data being processed, about the recipients or categories of recipients of this data, the planned period of storing the Customer’s data or about the criteria for determining this period (when determining the planned period of data processing is not possible), about the rights of the Customer under the GDPR and on the right to lodge a complaint with the supervisory authority, on the source of this data, on automated decision-making, including profiling, and on the safeguards applied in connection with the transfer of such data outside the European Union

5.1.3. obtain a copy of your personal information.

6. The right to rectify data – legal basis: art. 16 GDPR.

6.1. The customer has the right to request the Administrator to immediately rectify his personal data that are incorrect. Taking into account the purposes of processing, the data subject has the right to request completion of incomplete personal data, including by submitting an additional statement, sending a request to the e-mail address in accordance with §6 of the Privacy Policy.

7. The right to transfer data – legal basis: art. 20 GDPR.

7.1. The customer has the right to receive his personal data, which he provided to the Administrator, and then send them to another personal data administrator of his choice. The customer also has the right to request that personal data be sent by the Administrator directly to such an administrator, if it is technically possible. In this case, the Administrator will send the Customer’s personal data in the form of a file in the csv format, which is a commonly used, machine-readable format and allows the received data to be sent to another personal data administrator.

8. In the event of the Customer exercising the right resulting from the above rights, the Administrator fulfills the request or refuses to comply with it immediately, but not later than within a month after receiving it. However, if – due to the complicated nature of the request or the number of requests – the Administrator will not be able to meet the request within a month, he will meet them within the next two months informing the Customer in advance within one month of receiving the request – about the intended extension of the deadline and its reasons.

9. The customer may submit complaints, inquiries and requests to the Administrator regarding the processing of his personal data and the exercise of his rights.

10. The customer has the right to lodge a complaint with the President of the Office for Personal Data Protection in the scope of violation of his rights to the protection of personal data or other rights granted under the GDPR.

§ 5 Changes to the Privacy Policy

1. The Privacy Policy may change, which the Administrator is not obliged to inform about.

2. Questions related to the Privacy Policy should be sent to the following address: info@covingtontax.net

3. Date of last modification:  09/08/2023