Last updated: 20 May 2018, Version: 2.0
This policy of D-RAFT S.A. operating under the trade name of The Heart, hereinafter referred to as ‘TH’, to comply with applicable legal regulations concerning privacy and data protection.
Issues related to data processing as part of subscription or other services purchased from TH are regulated by separate procedures and agreements.
TH declares that it will make every effort to ensure adequate security of the data transmitted, and agrees to carry out measures to prevent third-party interference in the personal data and privacy of the data subjects. Personal data provided will be used for the purposes specified further in the document.
This policy tells you:
what information we might collect about you
how we might use that information
when we might use your details to contact you
what information of yours we might share with others
your choices about the personal information you give us
This policy covers the services that are offered by the TH. And sometimes it covers services offered by parts of our Partner that operate as separate companies. But only when those services link to this policy or tell you it applies.
User – a data subject; a person who provides his/her personal data in connection with the use of TH websites.
TH websites – Internet websites operated by or on behalf of TH and its subsidiaries worldwide.
Commercial Information – any information intended directly or indirectly for promoting subscription, services or image of TH.
Data integrity – refers to a situation in which data consistency is maintained during such operations as reading, saving, transmission or storage.
Partner – an entity, in favour of whom TH provides services or an entity that provides its services in favour of TH.
3. Personal information
Please be advised that the User may contact TH directly (by phone) or by accessing TH’s websites in order to get acquainted with information about the company, programmes and services and to view or listen to specific programmes, without the need to provide his/her personal information. Irrespective of the above, circumstances may arise when the User’s personal information is required to perform a requested service or process. In such cases the User shall be informed about the necessity to provide the data and the ways in which it will be used, thus enabling the User to decide whether to provide or refuse to provide his/her data. Making personal data available may be required when the User is interested in requesting performance of a particular service (for example preparation of an offer, receiving information about subscription) by an entity owned by TH or in situations when the User is interested in taking part in a process or event (for example participation in a conference). The User may then be asked to fill out and send a form/ questionnaire in which he/she will be clearly advised about what kind of personal data will be collected. In situations when the User discloses personal data of a third party (e.g. of a colleague) in a form/questionnaire, TH shall assume the User is in possession of an appropriate permission from the person whose data he/she has disclosed.
Data provided by the User in the abovementioned way is used by TH solely and exclusively for the purpose of performance of a service requested by the User, carrying out a process or arranging participation in an event.
4. How do you protect my personal information?
We’re strongly committed to keeping User information safe and to do this we design our services with maximum safety in mind. At the same time, no service can be completely secure – if you have any concerns that your TH personal information has been put at risk, please get in touch straight away: firstname.lastname@example.org
4.1 Where we store your information
Companies that provide services to us run their services in the European Economic Area. When you give us personal information it could not be being transferred, stored or processed in a location outside the EEA.
5. What types of personal information does the TH collect about me?
We’ll give details about why we need your personal information and how we’ll use it before you begin, unless it’s obvious.
5.1 Information that User give TH
We might ask for your name and contact details, your date of birth or financial details, depending on what you’re doing.
5.2 Device information
Devices are lots of things like:
your voice-enabled device
5.3 Information on your activities outside the TH when you talk about us.
Like if you’ve mentioned us in a Twitter post, we’ll collect your Twitter handle.
6. How long will the TH keep my information?
When you give us any personal information we’ll always stick to these principles:
we don't hold your information any longer than we have to
we only hold your information for as long as we do the activities we told you about or have a valid reason to keep it
we think about what type of information it is, the amount collected, how sensitive it might be and any legal requirements
7. How can the TH use my personal information?
TH has to have a valid reason to use your personal information. It's called the "lawful basis for processing". Sometimes TH might ask your permission to do things, like when you subscribe to an email. Other times, when you'd reasonably expect us to use your personal information, we don't ask your permission, but only when:
the law says it's fine to use it, and
it fits with the rights you have
We use your information for these types of things:
to deliver our services and to provide you with information about them
to deal with your requests, complaints and enquiries
to personalize services and give you things more tailored to your tastes
If you don't want to receive personalised email you can turn this option off. Email us: email@example.com
to help us understand what kind of services you might use and sometimes how you might share things with other people
to recommend things we think might interest you
to research and innovate
to contact you about various things
You're not a guinea-pig here, but knowing how you use our services could lead to the next big technology breakthrough.
8. When will the TH use my information to contact me?
We might use your information to contact you about different things, like:
to update you on any changes to the TH's policies and practices
to contact you about a request you sent us
to answer you when you've contacted us, or to respond to a comment or complaint
to invite you to take part in TH’s events
for marketing purposes
to send you notification on your device if you've selected them in your settings
We'll only contact you when we need to or when you've given us permission.
9. What are my rights?
Remember, you're in control of your personal information. You have the right to:
request a copy of your information
not let robots make big decisions about you
to ask us to correct information that's wrong, to delete it or to request that we only use it for certain purposes
to change your mind, and ask us to stop using your information. For example, unsubscribing from any marketing emails or turning off personalization
Bear in mind, sometimes we might not be able to help. Like if the law tells us we can't.
10. Use of information
10.1 Performance of services
By informing TH about his/her willingness to get acquainted with commercial information, specifically including subscription offer, services, receipt of newsletters, the User agrees that he/she or a third party indicated by him/her may be contacted directly. TH has the right to share personal data with entities whose involvement in the execution of a service is absolutely necessary (e.g. technological partners, application developers, financial and government institutions, postal services, transport companies), provided that such entity has been entrusted with processing of personal data by TH as the personal data controller under separate agreement. Such entities are required to use personal data provided to them only for the purpose of rendering a service on behalf of TH and shall treat the User’s personal data as strictly confidential.
Data provided by the User may be used to maintain or develop business relations, as well as in order to ensure adequate provision of services. TH may contact the User in order to conduct customer satisfaction survey or market research.
10.2 Marketing purposes
Personal data and information shared by the User through TH websites or provided while attending a conference or an event, may be used by TH for marketing purposes. This data may be also made available to selected third parties with whom TH cooperates in providing products and services to its clients and with whom it cooperates in the field of marketing, provided that such entity has been entrusted with processing of personal data by TH as the personal data controller under separate agreement. Personal data shall be used in the abovementioned way only in the case when the User express his/her consent to such action. The User’s consent shall be understood as consent to receive commercial information. We'll only send you marketing emails or contact you about TH programmes and events if you've agreed to this.
Keep in mind, even if you unsubscribe, we may still contact you.
We might use information that we hold about you to show you relevant and “targeted advertising” through other companies' sites, like Facebook, Google, Snapchat or Twitter for example.
If you don't want to see our targeted advertising, you can set ad preferences in your social media companies' settings. Also, you can sent us that information firstname.lastname@example.org
TH provides its Partners with dedicated websites containing information necessary for cooperation with TH. Access to these websites requires registration and a proper logging of a registered User with each visit. Personal data and information provided through such services may be used by TH to manage business relations with the User or a Partner represented by the User, as well as with all Partners and to develop such relations, which may occur in particular by transferring commercial information, product information, marketing information and information about partnership programmes. TH reserves the right to share personal data and information with its Partners and suppliers in order to render a service or carry out a process, provided that such entity has been entrusted with processing of personal data by TH as the personal data controller under separate agreement unless additional obligations to keep the data confidential have been reserved.
TH provides its Tenants with dedicated websites which constitute a database of knowledge about services that the Tenants use. Access to these websites requires registration and a proper logging of a registered User with each visit Information provided through such services may be used by TH to manage business relations with the User or Tenants represented by the User, as well as with all Clients and to develop such relations, which may occur in particular by transferring commercial information, product information, marketing information and offers. TH reserves the right to share personal data and information with its Partners and suppliers in order to render a service or carry out a process, provided that such entity has been entrusted with processing of personal data by TH as the personal data controller under separate agreement, unless additional obligations to keep the data confidential have been reserved.
10.5 Electronic advertisements
TH uses services of external entities providing interactive electronic advertising (for example banner advertisements). These entities are authorised to collect and use information about Clients solely for the purpose of ensuring optimal service provision to TH, as well as in order to determine which offers, promotions and types of advertisements are best received by TH’s Clients. Information collected in such manner is aggregated and thus cannot be used to identify a single User.
10.6 When does the TH share my personal information with others?
We'll never sell your personal information. We do share it with others in these ways:
When you make something public
Like post a comment which the public can see.
When we use other companies to power our services
In order for us to give you quality experiences and to understand how you're using our services we often use other companies to process your personal information on our behalf. For example, sending you emails about things we think might interest you, or to ask you what you think about our services.
We make sure that your personal information is looked after as if we were handling it directly. We carefully select these companies, only share with them what they need to do the work and we make sure they keep your information secure.
When we do collaborative research
We do research activities and sometimes collaborate with research partners. Every now and then we share our content and data with them. This might include information we've collected about you. But we're careful about what we share and what our research partners can do with it.
Sometimes by law we have to pass on your information to other organizations
We might also share your information if we have to by law, or when we need to protect you or other people from harm.
11. System logs
Each User’s visit to the TH websites is automatically registered on the server, in the so called system logs. The data saved this way includes, among other things,: date, time of the visit and the IP address. The data from system logs is used solely for the purposes of administering the servers and gathering website traffic statistics.
12. Cookies and similar technologies
Cookie technology is used by most highly developed Internet sites in order to enhance the quality of service and perform certain functions, including
creating individual content viewing statistics,
personalization of services performed using the service,
maintaining user sessions,
authentication of people using the service,
providing Users with personalised advertising content.
TH websites use the following types of cookies:
‘Essential’ cookies, which enable the use of our website services, for example to allow the use of sessions,
‘Functional’ cookies, used to remember the settings chosen by a User and to personalize the User’s interface, e.g. in terms of selected mobile/classic version, last phrases typed by the User, the appearance of a website, the state mechanism bookmarks, etc.
‘Analytical’ cookies, used to monitor the activity of Users on the site.
Cookies are not used for processing or storing personal details, they cannot be used for direct identification of a User and they do not change browser options or terminal device configuration. The User can independently determine and modify browser settings so that they will not accept cookies. If this option is selected many websites may not function properly or at all. It may be possible to set your browser to ask for the User’s consent before each cookie is used. This allows the User to have control over what is set on their device, however it may slow down the browser. In order to manage your cookies, please select your browser from the list below and follow the instructions:
No change in cookies configuration means they will be stored in the User’s terminal device, and therefore TH will keep information regarding the User’s terminal device and gain access to this information.
13. Modification of Personal Information
The User is entitled to become acquainted with his/her data stored by TH, and to correct and update any inaccurate or incomplete personal data, should it be necessary. Moreover, the User is entitled at any time to request the removal of his/her personal data from TH’s database. In order to do the above, please send an email to the following address: email@example.com with a request to modify or remove personal data.
14. Disclosure required by Law
Under certain, limited circumstances, TH may make available or provide personal information to third parties not affiliated with TH. In particular, TH may transfer personal data to a third party: upon User’s request;
in order to comply with legal requirements or a court order;
in order to verify the possibility of committing an offense of identity theft;
in connection with a sale, purchase, merger, reorganisation, liquidation or dissolution of TH;
under other similar circumstances.
15. Data protection
TH implements appropriate measures to protect the confidentiality of personal data and to preserve the integrity thereof. TH uses an encrypted connection for protecting the data being transmitted. TH is not responsible for data sent by third parties, and for data transmitted over unsecured connections.
16. Links to websites of other companies/organisations
TH’s website may include links to websites of other companies or organisations. TH shall not be liable for procedures and data protection mechanisms used by these companies/ organisations or the content of other websites.
17. Notices of Policy updates
If you don't agree to the changes, then you can always stop using our services and stop giving us any more personal information. We'd be sorry to see you go.
18. Questions and complaints about Privacy
For potential questions or complaints on how TH uses personal data, please contact us at the following address:
by email: firstname.lastname@example.org
by post: The Heart Warsaw, Warsaw Spire, 38th floor, Plac Europejski 1, 00-844 Warszawa, Polska.