Privacy Policy

1. General Information

1. This policy applies to the Website operating at the URL: https://esumo.agency
2. The Website operator and Personal Data Administrator is: Esumo sp. z o.o. ul. Gałczyńskiego 14, 05-091 Ząbki, Tax ID: 1251686662
3. Operator’s contact email address: hello@esumo.agency
4. The Operator is the Administrator of your personal data in relation to data voluntarily provided on the Website.
5. The Website uses personal data for the following purposes:
   • Newsletter management
   • Handling inquiries through forms
   • Fulfillment of ordered services
   • Presentation of offers or information
6. The Website performs functions of obtaining information about users and their behavior in the following ways:
   1. Through data voluntarily entered in forms, which are entered into the Operator’s systems.
   2. By saving cookie files on end devices.

2. Selected Data Protection Methods Used by the Operator

1. Login areas and personal data entry are protected at the transmission layer (SSL certificate). Thanks to this, personal data and login credentials entered on the website are encrypted on the user’s computer and can only be read on the target server.
2. Personal data stored in the database is encrypted in such a way that only the Operator holding the key can read it. Thanks to this, data is protected in case of database theft from the server.
3. User passwords are stored in hashed form. The hashing function works one-way – it is not possible to reverse its operation, which is currently the modern standard for storing user passwords.
4. The Operator periodically changes its administrative passwords.
5. To minimize the risk of unauthorized data access, the Operator uses complex passwords containing lowercase and uppercase letters, numbers, and special characters, no shorter than 8 characters.
6. The website uses two-factor authentication, which constitutes an additional form of protection for logging into the Website.
7. An important element of data protection is regular updates of all software used by the Operator to process personal data, which in particular means regular updates of programming components.
8. To protect data, the Operator regularly performs security backups.

3. Hosting

1. The Website is hosted (technically maintained) on the operator’s server: LH.pl
2. The hosting company maintains server-level logs to ensure technical reliability. The following may be recorded:
   • Resources identified by URL (addresses of requested resources – pages, files)
   • Time of request arrival
   • Time of response sent
   • Client station name – identification performed by HTTP protocol
   • Information about errors that occurred during HTTP transaction execution
   • URL of the page previously visited by the user (referrer link) – if the transition to the Website occurred through a link
   • User browser information
   • IP address information
   • Diagnostic information related to the process of self-ordering services through recorders on the website
   • Information related to handling email directed to the Operator and sent by the Operator

4. Your Rights and Additional Information on How Data is Used

1. In some situations, the Administrator has the right to transfer your personal data to other recipients if it is necessary to fulfill a contract with you or to fulfill obligations incumbent on the Administrator. This applies to such groups of recipients:
   • Hosting company on an entrustment basis
2. Your personal data processed by the Administrator no longer than is necessary to perform activities related to them specified by separate regulations (e.g., on accounting). With regard to marketing data, data will not be processed for longer than 3 years.
3. You have the right to request from the Administrator:
   • Access to your personal data
   • Their correction
   • Deletion
   • Restriction of processing
   • And data portability
4. You have the right to object to the processing indicated in point 3.3 c) regarding the processing of personal data for the purpose of performing legally justified interests pursued by the Administrator, including profiling, provided that the right to object may not be exercised in the case of important legally justified grounds for processing, superior to your interests, rights and freedoms, in particular establishing, pursuing or defending claims.
5. You have the right to file a complaint against the Administrator’s actions to the President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw.
6. Providing personal data is voluntary but necessary to operate the Website.
7. Actions involving automated decision-making, including profiling, may be taken in relation to you in order to provide services under the concluded contract and for the Administrator to conduct direct marketing.
8. Personal data is transferred from third countries within the meaning of data protection regulations. This means we send it outside the European Union.

5. Information in Forms

1. The Website collects information provided voluntarily by the user, including personal data, if provided.
2. The Website may record information about connection parameters (time stamp, IP address).
3. The Website, in some cases, may record information facilitating the linking of form data with the email address of the user filling out the form. In such a case, the user’s email address appears inside the URL of the page containing the form.
4. Data provided in the form is processed for the purpose resulting from the function of a specific form, e.g., to carry out the process of handling a service request or business contact, service registration, etc. Each time the context and description of the form clearly informs what it is for.

6. Administrator Logs

1. Information about user behavior on the website may be logged. This data is used to administer the website.

7. Important Marketing Techniques

1. The Operator uses statistical analysis of website traffic through Google Analytics (Google Inc. based in the USA). The Operator does not transfer personal data to the operator of this service, only anonymized information. The service is based on the use of cookies on the user’s end device. Regarding information about user preferences collected by the Google advertising network, the user can view and edit information resulting from cookies using the tool: https://www.google.com/ads/preferences/
2. The Operator uses Facebook pixel. This technology causes Facebook (Facebook Inc. based in the USA) to know that a person registered with it uses the Website. In this case, it is based on data for which it is itself the administrator; the Operator does not transfer any additional personal data to Facebook. The service is based on the use of cookies on the user’s end device.
3. The Operator uses remarketing techniques, allowing advertising messages to be matched to user behavior on the website, which may give the illusion that the user’s personal data is being used to track them, but in practice no personal data is transferred from the Operator to advertising operators. The technological condition for such actions is enabled cookie support.
4. The Operator uses a solution that examines user behavior by creating heat maps and recording behavior on the website. This information is anonymized before being sent to the service operator so that it does not know which physical person it concerns. In particular, entered passwords and other personal data are not recorded.
5. The Operator uses a solution automating the Website’s operation in relation to users, e.g., it may send an email to the user after visiting a specific subpage, if they have consented to receiving commercial correspondence from the Operator.
6. The Operator may use profiling within the meaning of data protection regulations.

8. Information About Cookies

1. The Website uses cookies.
2. Cookies are IT data, in particular text files, which are stored on the Website User’s end device and are intended for using the Website’s web pages. Cookies usually contain the name of the website they come from, their storage time on the end device, and a unique number.
3. The entity placing cookies on the Website User’s end device and accessing them is the Website operator.
4. Cookies are used for the following purposes:
   1. Maintaining the Website User’s session (after logging in), thanks to which the user does not have to re-enter their login and password on each subpage of the Website
   2. Achieving the purposes specified above in the „Important Marketing Techniques” section
5. Within the Website, two basic types of cookies are used: „session cookies” and „persistent cookies.” „Session” cookies are temporary files that are stored on the User’s end device until logging out, leaving the website, or turning off the software (web browser). „Persistent” cookies are stored on the User’s end device for the time specified in the cookie parameters or until they are deleted by the User.
6. Web browsing software (web browser) usually allows cookies to be stored on the User’s end device by default. Website Users can change settings in this regard. The web browser allows cookies to be deleted. It is also possible to automatically block cookies. Detailed information on this is contained in the help or documentation of the web browser.
7. Restrictions on the use of cookies may affect some functionalities available on the Website’s web pages.
8. Cookies placed on the Website User’s end device may also be used by entities cooperating with the Website operator, in particular this applies to companies: Google (Google Inc. based in the USA), Facebook (Facebook Inc. based in the USA), Twitter (Twitter Inc. based in the USA).

9. Managing Cookies – How to Express and Withdraw Consent in Practice?

1. If the user does not want to receive cookies, they can change their browser settings. We reserve that disabling cookies necessary for authentication processes, security, and maintaining user preferences may hinder, and in extreme cases may prevent the use of websites.
2. To manage cookie settings, select the web browser you use from the list below and follow the instructions:
   • EdgeInternet ExplorerChromeSafariFirefoxOpera
   Mobilne devices:
   • Android
   • Safari (iOS)
   • Windows Phone