PRIVACY POLICY

1. GENERAL PROVISIONS

1.1. This Privacy Policy applies to all Users of the website ip-mc.com (the “Website”).

1.2. The Privacy Policy is provided for information purposes only and does not impose obligations on Users of the Website.

1.3. The Privacy Policy applies to individuals visiting the Website to the extent that their Personal Data is processed.

1.4. In the event of any doubt or inconsistency between this Privacy Policy and consent given by an individual, the Controller’s actions and the scope of processing will be based on the voluntarily given consent or applicable law. For further information, please contact the Data Controller by email at anna.miniewicz@miniewicz.com or by post at: ul. S. Żeromskiego 33/9, 50-321 Wrocław, Poland.

2. DEFINITIONS

2.1. “Controller” means Anna Miniewicz, conducting business under the name Anna Miniewicz – Kancelaria radcy prawnego, with its registered office in Brzeg (49-300), ul. Szkolna 13/11, Poland, NIP: 7471819677, REGON: 022083150.

2.2. “Personal Data” means any information relating to an identified or identifiable natural person, including information enabling identification through one or more factors specific to that person’s physical, physiological, genetic, mental, economic, cultural or social identity. This may include the IP address of an end device, such as a mobile phone, tablet or desktop computer, location data, online identifiers and information collected through cookies or similar technologies.

2.3. “User” means any natural person visiting the Website or using one or more of its functionalities.

3. PROCESSING OF DATA IN CONNECTION WITH USE OF THE WEBSITE

3.1. The principal legal sources governing the rights and obligations relating to the processing of Personal Data are:

3.1.1. 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 (“GDPR”);

3.1.2. the Polish Data Protection Act of 10 May 2018, as amended.

3.2. In connection with the provision of legal services and operation of the Website, Users’ Personal Data may be processed for different purposes, always in accordance with applicable law. Providing Personal Data is voluntary, although failure to provide certain data may make it difficult or impossible to conclude or perform an agreement for legal services.

3.3. The scope of Personal Data collected by the Controller depends on the type of service concerned.

3.4. For analytical purposes, including analysing activity on the Website, the following information may be processed:

3.4.1. date and time of a Website visit;

3.4.2. type of operating system;

3.4.3. approximate location;

3.4.4. type of web browser used to access the Website;

3.4.5. time spent on the Website;

3.4.6. subpages visited.

Where analytical data is collected through cookies or similar technologies that are not necessary for the operation of the Website, the legal basis for their use is the User’s consent under Article 6(1)(a) GDPR, to the extent that the GDPR applies.

3.5. Cookies and similar technologies that are not necessary for the operation of the Website are used only after the User has given consent. Further information on cookies is provided in section 11 of this Privacy Policy.

3.6. In order to comply with obligations arising under tax, anti-money laundering and other applicable laws, including obligations relating to the retention of accounting records, the following Personal Data may be processed:

  • name and surname;

  • email address;

  • residential address;

  • telephone number;

  • tax identification number (NIP).

The legal basis for such processing is Article 6(1)(c) GDPR, where processing is necessary for compliance with a legal obligation to which the Controller is subject.

3.7. For the purpose of maintaining records required in connection with the GDPR, including records relating to individuals who have exercised their rights or submitted objections, the following Personal Data may be processed:

  • name and surname;

  • email address.

The legal basis is Article 6(1)(c) GDPR where processing is necessary to comply with a legal obligation, and Article 6(1)(f) GDPR where processing is necessary for the Controller’s legitimate interest in documenting the exercise of data subjects’ rights.

3.8. For the purpose of establishing, exercising or defending legal claims, the following Personal Data may be processed:

  • name and surname;

  • residential address, if provided;

  • email address.

The legal basis is Article 6(1)(f) GDPR, namely the Controller’s legitimate interest in establishing, exercising or defending legal claims.

4. RECIPIENTS OF PERSONAL DATA

Personal Data may be processed by service providers whose services are necessary for the operation of the law firm, in particular:

  • Squarespace – in connection with hosting and operation of the Website and the contact form;

  • Google Workspace – in connection with email, office services and data storage;

  • IT, accounting and other service providers supporting the law firm, where access to Personal Data is necessary for the performance of their services.

Personal Data may also be disclosed to public authorities or other entities where such disclosure is required by law.

5. TRANSFERS OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA

In connection with the use of Squarespace and Google Workspace, Personal Data may be processed outside the European Economic Area, including in the United States.

The providers of these services use mechanisms provided for under the GDPR for international transfers of Personal Data, including applicable European Commission adequacy decisions and Standard Contractual Clauses. Google also indicates that it relies on the EU-U.S. Data Privacy Framework where applicable.

6. RIGHT TO WITHDRAW CONSENT

6.1. Where Personal Data is processed on the basis of consent, you may withdraw that consent at any time.

6.2. To withdraw your consent, please contact the Controller at anna.miniewicz@miniewicz.com.

6.3. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal.

7. REQUIREMENT TO PROVIDE PERSONAL DATA

7.1. Providing Personal Data is voluntary. However, in certain circumstances, providing specific Personal Data may be necessary in order to respond to an enquiry, enter into an agreement or provide legal services.

7.2. Personal Data necessary for entering into and performing an agreement may be required if we decide to work together. The scope of required data will depend on the nature of the matter and the services concerned.

7.3. In order to issue an invoice, it may be necessary to provide information required under applicable tax law, including the name and surname or business name, residential or registered address and tax identification number where applicable.

7.4. If you wish to be contacted by telephone, providing a telephone number is necessary for that purpose.

8. AUTOMATED DECISION-MAKING AND PROFILING

The Controller does not use automated decision-making, including profiling.

The content of an enquiry submitted through the contact form is not subject to automated assessment by an IT system. Any proposed fee for legal services is not determined through automated decision-making.

9. RETENTION OF PERSONAL DATA

9.1. Personal Data is processed for the period necessary to achieve the purpose for which it was collected and thereafter, where justified, for the period required by law or necessary for the establishment, exercise or defence of legal claims.

9.2. Where no operations other than storage need to be performed on Personal Data, for example where an agreement is retained for the purpose of defending potential claims, the data is appropriately secured until it is permanently deleted or destroyed.

9.3. Data relating to use of the Website is processed for a period appropriate to the purpose for which it was collected, taking into account the settings of the relevant tools and applicable legal requirements.

9.4. Personal Data relating to legal services is processed for the duration of the relevant agreement and thereafter for the period resulting from applicable legal obligations and limitation periods for legal claims.

9.5. Personal Data processed for compliance with anti-money laundering obligations is retained for the period required under applicable law, where such obligations apply.

9.6. Where Personal Data is processed on the basis of consent, it is processed until the purpose for which it was collected has been fulfilled or until consent is withdrawn, whichever occurs first, without prejudice to further processing on another lawful basis where such basis exists.

10. DATA SUBJECT RIGHTS

10.1. Subject to the conditions set out in the GDPR, you may have the right to:

  • access your Personal Data;

  • rectify your Personal Data;

  • erase your Personal Data;

  • restrict the processing of your Personal Data;

  • object to the processing of your Personal Data;

  • receive or transfer your Personal Data where the right to data portability applies.

10.2. These rights are not absolute. In certain circumstances, the Controller may lawfully refuse to comply with a request where grounds for doing so are provided by applicable law.

10.3. Where Personal Data is processed on the basis of the Controller’s legitimate interest, you may object to such processing on grounds relating to your particular situation. The Controller may continue processing where compelling legitimate grounds for the processing override your interests, rights and freedoms, or where processing is necessary for the establishment, exercise or defence of legal claims.

10.4. You may exercise your rights by contacting the Controller at anna.miniewicz@miniewicz.com.

10.5. If you consider that your Personal Data is being processed unlawfully, you have the right to lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych – UODO) in Poland.

11. COOKIES

11.1. The Website uses cookies and similar technologies that are necessary for its proper operation.

11.2. In connection with the use of the Squarespace platform, analytical and performance cookies may also be used to provide information about how the Website is used, including information concerning visited pages, the device and browser used and the source of a visit.

11.3. Cookies that are not necessary for the operation of the Website are used only after the User has given consent through the cookie management mechanism available on the Website.

11.4. Users may accept or reject non-essential cookies and may change their preferences at any time through the cookie settings available on the Website.

11.5. Where required by applicable law, the legal basis for the use of non-essential cookies and the processing of Personal Data obtained through them is the User’s consent. Withdrawal of consent does not affect the lawfulness of processing carried out before withdrawal.

11.6. Further information about the cookies used by Squarespace is available in Squarespace’s documentation.

12. SERVER LOGS

12.1. Use of the Website involves requests being sent to the server on which the Website is hosted. Requests made to the server may be recorded in server logs.

12.2. Server logs may include, among other information, the User’s IP address, date and time of the request, browser information and the operating system used by the User.

12.3. Information recorded in server logs is not used by the Controller to identify Users unless this is necessary for security, technical or legal reasons.

Server logs are used as supporting technical information for administration of the Website and may be disclosed only to persons or entities authorised to administer the technical infrastructure or where required by law.

13. FINAL PROVISIONS

Matters not addressed in this Privacy Policy are governed by the applicable laws of Poland, in particular laws relating to the protection of Personal Data.