1. Basic Information
1.1 This privacy policy describes the principles of handling personal data of Users using the website https://alterdata.com (hereinafter referred to as the “Website”), Users of Alterdata’s social media fan pages, and the principles of using cookies by the Website.
1.2 The Administrator of the Website and the personal data collected through it is:
Alterdata.io sp. z o.o. with its registered office in Warsaw, ul. Domaniewska 47/10, 02-672 Warsaw, KRS: 0000672717, NIP: 521-377-59-57, REGON: 36700511900000,
hereinafter referred to as the “Administrator” or “We” or “Alterdata.”
1.3 You can contact us via email at: office@alterdata.com, or by traditional mail at the Administrator’s registered office address.
1.4 Anyone who uses the Website is its “User.”
1.5 We process your personal data in accordance with applicable laws, in particular with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) – hereinafter referred to as “GDPR.”
1.6 The Administrator has appointed a Data Protection Officer (DPO), whom you can contact regarding all matters related to the processing and protection of personal data by writing to: iod@alterdata.com.
2. Purposes and Legal Bases for Processing Personal Data
2.1 Contact Forms, Email and Traditional Correspondence
2.1.1 Personal data sent to us via the contact forms available on our Website, as well as by email or traditional mail, will be processed to respond to your inquiries and handle the matter you are addressing. The legal basis for processing your personal data is the legitimate interest of the Administrator in responding to received messages, correspondence, and conducting communication (Article 6(1)(f) GDPR).
2.1.2 If you request us to present our offer, your personal data will be processed for this purpose based on Article 6(1)(b) GDPR, i.e., taking steps at the request of the data subject prior to entering into a contract (if you will be a party to the contract), or based on our legitimate interest in presenting the requested offer (Article 6(1)(f) GDPR) if you represent a legal entity.
2.1.3 If you are a party to a contract already concluded with the Administrator, the processing of your personal data contained in correspondence may take place based on that contract (Article 6(1)(b) GDPR) to properly execute it (necessary communication for the proper performance of the contract/order).
2.1.4 If you are a person designated for contact by our Contractor for the purpose of fulfilling the contract, we will process your data based on the legitimate interest of the Administrator (Article 6(1)(f) GDPR), which is conducting communication in connection with the concluded contract.
2.1.5 Personal data contained in messages from contact forms, electronic and traditional correspondence may also be processed for the purpose of possible assertion of claims or defense against claims, which constitutes our legitimate interest (Article 6(1)(f) GDPR).
2.2 Newsletter, Marketing Contact
2.2.1 Under the contact forms and registration forms for conferences and webinars, there may be a checkbox for marketing consent. If you voluntarily check the box for email marketing consent, we will process your data to send marketing and commercial content regarding our offer or invitations to events organized by us, such as conferences, in the future.
2.2.2 We emphasize that our marketing contact will be unobtrusive and will only occur when we want to invite you to a webinar, conference, or present our valuable service or product.
2.2.3 Remember, you can withdraw your marketing consent at any time.
2.2.3 The legal basis for processing personal data for marketing purposes is the legitimate interest of the Administrator (Article 6(1)(f) GDPR in connection with the expressed marketing consents) involving the marketing and promotion of its services and activities.
2.3 Scheduling a Meeting
2.3.1 To schedule a remote meeting with us, you are required to provide your name and email address.
2.3.2 The basis for our processing of your data is our legitimate interest (Article 6(1)(f) GDPR) in scheduling and conducting a meeting at the User’s request.
2.4 Recruitment, Job Candidates
2.4.1 If you send us application documents in response to a recruitment advertisement, your personal data will be processed to conduct the recruitment process based on actions aimed at concluding a contract in accordance with Article 6(1)(b) GDPR (data necessary for concluding a contract), and in the case of providing data other than necessary—based on your consent (applies to applying for a position under a civil law contract—B2B, mandate contract).
2.4.2 If you are applying for a position under an employment contract, your personal data within the scope specified in labor law regulations (Article 22(1) of the Labor Code) will be processed to conduct the current recruitment process based on the fulfillment of legal obligations imposed on the Administrator (Article 6(1)(c) GDPR), while other data, e.g., photo, contact details, and other information contained in a cover letter, based on your consent (Article 6(1)(a) GDPR), which may be withdrawn at any time.
2.5 Social Media
2.5.1 ALTERDATA.IO sp. z o.o. with its registered office in Warsaw is the Administrator of your personal data made available during the use of fan pages:
a) https://www.facebook.com/alterdata.io on the social media service Facebook
b) https://www.linkedin.com/company/alterdata.io/ on the social media service LinkedIn.
2.5.2 We process your personal data if you have left any trace on any of our fan pages, e.g., you clicked the “Like,” “Follow,” “Share” icon, left a comment, or sent a message. The personal data we process then are: your first and last name or your profile name, image—if it appears in your profile picture, data provided in a message, comment, or within a conversation via Messenger.
2.5.3 We process the personal data of Users of our social media fan pages for the following purposes:
a) Operating fan pages under the conditions and terms specified by Meta Platforms Ireland Limited—the provider of Facebook, as well as LinkedIn Ireland Unlimited Company—the provider of LinkedIn, and informing through them about our activities and offered services, which constitutes our legitimate interest in accordance with Article 6(1)(f) GDPR;
b) Communication via available functionalities of the Facebook and LinkedIn services (comments, chat, posts, conversation via Messenger, messages), which constitutes our legitimate interest in accordance with Article 6(1)(f) GDPR;
c) Conducting analyses of the functioning, popularity, statistics, and manner of using the fan pages using available functionalities, which constitutes our legitimate interest in accordance with Article 6(1)(f) GDPR.
2.5.4 According to the case law of the Court of Justice of the European Union, the creator of a fan page on a social networking site is a joint controller of the personal data of users of that fan page together with the owner of the social networking site.
2.5.5 However, we would like to inform you that the provisions contained in this Privacy Policy do not apply to the processing of your personal data by the owner of the Facebook service—Meta Platforms Ireland Limited, and the owner of the LinkedIn service—LinkedIn Ireland Unlimited Company. To obtain detailed information on how your data is processed by Meta Platforms Ireland Limited and LinkedIn Ireland Unlimited Company, please refer to their Privacy Policies, which are available on the websites:
Facebook: https://www.facebook.com/about/privacy.
LinkedIn: https://pl.linkedin.com/legal/privacy-policy
2.5.6 Also familiarize yourself with the information regarding the processing of your data for page statistics purposes: https://www.facebook.com/legal/terms/information_about_page_insights_dataRights of
3. Data Subjects
3.1 Under the terms described in the GDPR, you have the following rights concerning your personal data:
a) The right to access your data and request a copy thereof (Article 15 GDPR);
b) The right to request rectification of your personal data (Article 16 GDPR);
c) The right to request erasure of data (Article 17 GDPR);
d) The right to request restriction of data processing (Article 18 GDPR);
e) The right to data portability, i.e., to receive from the Administrator personal data in a structured, commonly used, machine-readable format, to the extent that the data is processed based on consent or for the conclusion and performance of a contract in an automated manner (Article 20 GDPR);
f) The right to object to the processing of personal data based on a legitimate interest, including for marketing purposes (Article 21 GDPR);
g) The right to withdraw marketing consent—if you have given consent to receive messages about events organized by us (webinars and training sessions) to the email address provided by you in the form, you have the right to withdraw such consent at any time.
3.2 To exercise your rights, please send a request with your demand to the email address: office@alterdata.com, or to the email address iod@alterdata.com.
3.3 If you receive messages from us about organized events (webinars and training sessions) to your email address, you always have the option to unsubscribe from the mailing list (cancel subscription) and thus withdraw your consent by clicking the link available at the bottom of the message.
3.4 You also have the right to lodge a complaint with the President of the Personal Data Protection Office if you believe that the processing of your personal data violates data protection laws.
4. Data Recipients
4.1 For the proper functioning of our company and Website, it is necessary for us to use the services of external entities. We only use the services of such entities that provide sufficient guarantees for the implementation of appropriate technical and organizational measures so that the processing meets the requirements of the GDPR and protects the rights of data subjects.
4.2 Personal data of Users may be transferred to the following recipients or categories of recipients: service providers supplying the Administrator with IT, technical, and organizational solutions that enable the Administrator to run the company’s activities, including the website and the electronic services provided through it (in particular, providers of computer software for running the Website, providers of email and server hosting, and providers of software for managing the company, sending mailings, and providing technical assistance to the Administrator), as well as providers of legal and advisory services providing appropriate support to the Administrator (e.g., law firms or debt collection companies).
4.3 Recipients of your personal data may also be law enforcement agencies and state authorities if this results from applicable laws.
5. Retention Period
5.1 Personal data from contact forms and electronic and traditional correspondence will be processed for the period necessary to handle the conducted correspondence, extended appropriately by the period resulting from the relationship of the correspondence with the concluded legal relationship, archiving obligations, assertion of possible claims, or other obligations required by generally applicable laws.
5.2 Other personal data processed based on a legitimate interest (Article 6(1)(f) GDPR) will be processed for the duration of that interest or until an effective objection to the processing of personal data is lodged.
5.3 Data processed for marketing contact purposes will be processed until an objection to processing for this purpose is raised or until the consent for marketing contact is withdrawn.
5.4 Personal data of job candidates from application documents will be stored for 30 days after the recruitment process is completed, and if the job candidate gives consent, their data will be processed for future recruitments for a period of 1 year or less if they have earlier withdrawn consent to process their data.
5.5 Data processed based on a contract (Article 6(1)(b) GDPR) will be processed for its duration and then for the period of limitation of mutual claims.
5.6 In the case of data processed on our social media fan pages, we remind you that you always have the option to delete the comment you left or stop following our fan page.
6. Information About the Requirement/Voluntariness of Providing Data
6.1 Providing personal data is voluntary but may be necessary to achieve a given purpose of processing.
6.2 In the forms provided on the Website, required fields are marked with an asterisk. Entering other data into the forms is voluntary.
6.3 Any activity that leaves your personal data on our fan page is entirely voluntary. You decide which of your personal data we will have access to by applying the appropriate privacy settings on your personal profile on the given social media platform.
7. Information About Lack of Profiling and Data Transfer Outside the EEA
7.1 Users’ personal data will not be subject to automated decision-making, including profiling.
7.2 Users’ personal data may be transferred to third countries, in particular to the USA, in connection with our use of electronic services and tools provided by foreign suppliers. Providers of these services (systems for sending emails, systems for registering for webinars and training) have their servers, among others, in the USA, and your data may be stored on these servers. Data transfer takes place based on Standard Contractual Clauses while maintaining an appropriate level of personal data protection.
7.3 Alterdata.io does not transfer Users’ data from our social media fan pages outside the European Union or to international organizations. However, please remember that by having an account on social media services Facebook and LinkedIn, you have accepted the terms and privacy policies of these portals, in which their owners: Meta Platforms Ireland Limited and LinkedIn Ireland Unlimited Company, discussed the rules for transferring personal data to third countries, including servers in the United States. Alterdata has no influence on how Meta Platforms Ireland Limited and LinkedIn Ireland Unlimited Company process your personal data.
8. What Are Cookies
8.1 Cookies are small text information in the form of text files sent by a server and saved on the side of the person visiting the Website (e.g., on the hard drive of a computer, laptop, or on a smartphone’s memory card—depending on the device used by the visitor).
8.2 Data is collected and stored exclusively in anonymous or pseudonymized form and does not enable the Administrator to identify the User. Cookies do not harm the User’s computer and do not contain viruses.
9. What Cookies Do We Use and For What Purposes?
9.1 The Website uses the following cookies:
a) Necessary – these cookies are essential for the basic functions of the website, and the site will not function as intended without them. They do not store any personally identifiable data and are always active.
b) Functional – cookies that help perform certain functions like sharing website content on social media platforms, collecting feedback, and other third-party features.
c) Analytical – cookies used to understand how users interact with the website. These cookies help provide information on metrics such as the number of visitors, bounce rate, traffic source, etc.
d) Performance – cookies used to understand and analyze key performance indicators of the website, which helps to provide a better User experience for visitors.
e) Advertising – cookies used to deliver personalized ads to users based on the pages they previously visited and to analyze the effectiveness of the advertising campaign.
f) Third-party cookies – help us analyze how Users use the site, store User preferences, and deliver content and ads relevant to them. Such cookies will be stored in the browser only with the User’s prior consent.
10. How to Manage Cookies?
10.1 Upon first entering the Website, the User is informed about the use of cookies by the Website. In the window with information about the use of cookies, the User has the option to:
a) Express consent to save all cookies,
b) Reject all cookies (except necessary ones),
c) Adjust their cookie preferences.
10.2 When the User clicks the “Customize” button, detailed information appears regarding the types of cookies used, purposes of use, names, and durations of individual cookies.
10.3 The User can change their consents at any time by accessing “Cookie Settings”—the cookie icon displayed at the bottom left side.
10.4 The User can also configure their web browser so that it does not store cookies on the User’s device.
10.5 All cookies can be deleted by the User after they have been saved by the Administrator, using the appropriate functions of the web browser (clearing cookies), programs designed for this purpose, or using appropriate tools available within the operating system used by the User.
10.6 Detailed information on the possibilities and methods of handling cookies is available in the settings of the web browser. Below we present how to change the settings of web browsers regarding the use of cookies:
a) Mozilla Firefox Browser
b) Chrome Browser
c) Safari Browser
d) Opera Browser
11. Third-Party Cookies
11.1 Google Analytics
11.1.1 The Administrator may use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to collect and analyze data about Users’ interactions with the Website.
11.1.2 Data for this purpose is processed based on the User’s consent expressed by accepting analytical cookies upon first entering the Website.
11.1.3 The operation scheme of Google Analytics cookies is as follows:
a) Tracking Visits and Sessions
b) Cookies in Google Analytics are used to track User visits and sessions on the Website. The most commonly used cookie is “_ga,” which uniquely identifies Users.
c) Collecting Demographic and Geographic Data
Cookies help Google Analytics collect demographic (e.g., age, gender) and geographic (e.g., country, city) information about Users. This data helps understand who the visitors are.
d) Tracking User Behaviors
Google Analytics uses cookies to track various User behaviors on the site, such as:
- Opening specific pages.
- Clicking on links and buttons.
- Time spent on the site.
- Scrolling through pages.
- Filling out forms.
e) Measuring Conversions
Cookies allow tracking conversions, i.e., specific actions taken by Users, such as registrations or form submissions. This enables the Administrator to measure the effectiveness of marketing campaigns.
f) Creating Audience Segments
Based on data from cookies, Google Analytics allows creating audience segments that can be used for more precise analysis and targeting of marketing information.
g) Analyzing Website Traffic
Thanks to cookies, Google Analytics collects data about site traffic, such as:
- Number of visits.
- Traffic sources (e.g., organic, paid, referral).
- User navigation paths.
- Bounce rates.
Site Optimization
Collected data allows identifying areas for optimization on the Website. For example, if Google Analytics shows that Users often leave the site on a specific subpage, actions can be taken to improve that page.
h) Reporting
Google Analytics generates various reports based on data collected via cookies. These reports include:
- User reports (e.g., number of new and returning users).
- Behavior reports (e.g., most visited pages, user paths).
- Conversion reports (e.g., goal tracking, conversion paths).
i) Disabling Cookies
Users have the option to disable Google Analytics cookies by using the Google Analytics Opt-out Browser Add-on. This allows users to control their data and privacy protection.
11.2 Google Ads
11.2.1 The Administrator may use the Google Ads marketing program operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA, to conduct marketing campaigns, including remarketing campaigns. Data for this purpose is processed based on the User’s consent expressed by accepting marketing cookies upon first entering the Website.
11.2.2If the User consents to the use of marketing cookies, upon entering the Website, Google cookies will be saved on the User’s device, which, based on the pages visited by the User, will enable displaying information/ads based on the User’s interests. The process is as follows:
a) Data Collection via Cookies
When Users visit the Website, Google Ads uses cookies to collect various information. Cookies may contain data such as:
Browsing information (e.g., which pages the User visited, how long they stayed).
Demographic and geographic data.
Device and browser information.
Actions taken on the site (e.g., filling out a registration form).
b) Conversion Tracking
Google Ads uses cookies to track conversions, i.e., specific actions that Users take on the Website, such as form submissions. This allows us to see which information/ads are most effective and yield the expected results.
c) Remarketing
One of the main functions of cookies in Google Ads is remarketing. Remarketing allows displaying information/ads to Users who have previously visited the Website. Thanks to cookies, Google Ads identifies these Users and enables re-reaching them with personalized information/ads.
d) Personalizing Information/Ads
Google Ads uses data from cookies to personalize marketing information/ads, which means tailoring content to Users’ interests and behaviors. Based on the collected data, Google Ads can display information/ads that are more interesting to specific Users.
e) Campaign Optimization
Data from cookies allows for continuous optimization of marketing campaigns. Google Ads analyzes the collected information to adjust bids, keywords, and marketing content to improve campaign results.
f) Creating Audience Lists
Google Ads uses cookies to create audience lists that can be used to target marketing information/ads. For example, the Administrator can create lists of users who visited their site but did not register for an event and display ads encouraging them to return and sign up.
g) Analyzing Effectiveness
Google Ads uses data from cookies to analyze the effectiveness of marketing campaigns. The Administrator can gain insights into various metrics such as click-through rate (CTR), cost per click (CPC), conversion rate, and more. This data is crucial for making decisions about future marketing strategies.
11.3 LinkedIn Insight Tag
11.3.1 Our Website may use the LinkedIn Insight Tag tool, which allows us to better understand visitor behaviors and optimize our advertising activities on the LinkedIn platform. The LinkedIn Insight Tag enables us to collect data about visits to our site and analyze their effectiveness, which supports our marketing efforts and allows for better tailoring of advertising content to our users’ needs.
11.3.2 The LinkedIn Insight Tag collects data such as:
- Visited subpages,
- Time spent on our site,
- Clicks and interactions with our site,
- Demographic data (if the user has consented to tracking by LinkedIn).
11.3.3 Information is collected in an anonymized manner, meaning it does not identify a specific user. The LinkedIn Insight Tag places a cookie in the user’s browser, allowing us to analyze site visits and the effectiveness of ads displayed, but without direct access to users’ personal data.
11.3.4 Users have the option to manage consents for the use of advertising cookies, including cookies associated with the LinkedIn Insight Tag, which allows control over the processing of marketing data. To learn more about how LinkedIn processes data and manages privacy, please review LinkedIn’s Privacy Policy: https://www.linkedin.com/legal/privacy-policy.
11.3.5 If you wish to withdraw consent for tracking via the LinkedIn Insight Tag, you can do so in your browser settings or directly on the LinkedIn site.
11.4 Meta (Facebook) Pixel
11.4.1 Our site may use the Meta Pixel tool (formerly Facebook Pixel), which allows us to better understand how users interact with our site and enables more effective advertising activities on Meta platforms (Facebook, Instagram). Thanks to the Meta Pixel, we can analyze actions taken by users on our site and tailor advertising content to their interests, helping us precisely reach people interested in our services or products.
11.4.2 The Meta Pixel collects information about user activity on our site, including:
11.4.3 Visited pages and subpages,
11.4.4 Actions taken, such as clicks, newsletter sign-ups, or purchases,
11.4.5 Demographic data and interests, if the user has consented to tracking.
11.4.6 To learn more about how Meta processes data via the Meta Pixel, you can review Meta’s Privacy Policy: https://www.facebook.com/privacy/policy.
11.4.7 Data collected by the Meta Pixel is anonymized and does not allow direct identification of users. The Meta Pixel installs a cookie in the user’s browser, enabling tracking of actions on the site and analyzing the effectiveness of ads displayed on Facebook and Instagram, as well as displaying remarketing ads to users who previously visited our site.
11.4.8 Each user has the option to manage their preferences regarding advertising cookies on our site, including cookies related to the Meta Pixel. By consenting to these cookies, you allow us to better tailor ads to your needs and interests.