1. GENERAL PROVISIONS
1.This Privacy Policy sets out the rules for the processing of personal data obtained through the iCode Trust e-learning Platform, hereinafter referred to as the Platform, or obtained in any other way in connection with the operation of the Platform and offering Training.
2.The owner of the Platform and at the same time the Administrator of Personal Data is iCode Trust Sp. z o. o. using the Future Collars trademark with its registered office in Warsaw at ul. Bukowińska 24D/7, 02-703 Warsaw, entered into the Register of Entrepreneurs of the National Court Register by the District Court for the Capital City of Warsaw, 13th Commercial Division of the National Court Register under KRS number 0000777251, NIP 5213861303, REGON 382934531, hereinafter referred to as iCode Trust.
3.Personal data collected by iCode Trust via the e-learning Platform 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 and the repeal of Directive 95/46/EC (General Data Protection Regulation), also referred to as the GDPR.
4.iCode Trust takes special care to respect the privacy of customers visiting the website of the iCode Trust e-learning platform.
5.Whenever the following terms and definitions are used in this Policy, they should be understood as follows:
a) Administrator or Company – iCode Trust Sp. z o. o. using the Future Collars trademark with its registered office in Warsaw at ul. Bukowińska 24D/7, 02-703 Warsaw, entered into the Register of Entrepreneurs of the National Court Register by the District Court for the capital city of Warsaw, 13th Commercial Division of the National Court Register under KRS number 0000777251, NIP 5213861303, REGON 382934531, e-mail address: b.jarosz@ futurecollars.com
b) Cookies – means IT data, in particular small text files, saved and stored on devices through which the User uses the websites of the e-learning Platform.
c) Administrator’s Cookies – means Cookies placed by the Administrator, related to the provision of electronic services by the Administrator via the e-learning Platform.
d) External Cookies – means Cookies placed by the Administrator’s partners via the website of the e-learning Platform e
e) Personal data – all information about a natural person identified or identifiable by one or several specific factors determining physical, physiological, genetic, economic, cultural or social identity, including device IP, location data, online identifier and information collected through cookies and other similar technology.
f) Policy – this Privacy Policy.
g) Device – means an electronic device through which the User gains access to the e-learning Platform.
h) GDPR – 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 personal data and on the free movement of such data, and repealing Directive 95/46/EC.
i) E-learning platform – an Internet application operating in the domain https://coderstrust.pl made available by Futur Collars, used for online learning, including conducting training, lessons, lectures, multimedia presentations, tests, etc.
j) Client person visiting the e-learning Platform or using one or more services or functionalities described in the Policy

2. Type of data processed, purposes and legal grounds

1.iCode Trust gathers information regarding persons’ natural business or professional activity on its own behalf, of natural persons representing legal persons or organizational units that are not legal persons and natural persons who are participants or potential participants of courses and trainings, hereinafter jointly referred to as Clients.
2.Customers’ personal data is collected in the event of:
a) taking action before concluding the contract at your request (e.g. setting up an Account), i.e. data provided in the registration form on the Website, i.e. e-mail address and established password; if the Account is registered via an external authentication service (e.g. Google+, Facebook), we collect your name and last name; in order to provide Services that require setting up an Account, we process your data provided in the Account, including data on services provided and paid services;
b) in order to provide Services that do not require the creation of an Account, i.e. browsing the website of the Website, search engine for content or Services, we process personal data regarding your activity on the Website, i.e. data regarding the content or Services you browse, data regarding your device session, operating system, browser, location and unique ID, IP address;
c) performance of the Agreement for the provision of Services and the use of functionalities both requiring and not requiring the creation of an Account, i.e. access to the resources of the Website, tracking and changes in the scope of goals, achievements, adding materials, publications, training and other content, we process personal data provided by you in the Account and as part of the forms and data on your activity on the Website, as well as data on the session, your device and operating system, browser, location and unique ID. Providing certain data is a condition for using individual Services and functionalities (obligatory data). Our system automatically marks mandatory data. The consequence of not providing this data is the inability to provide certain Services and functionalities. Apart from the data marked as obligatory, providing other personal data is voluntary;
d) subscription to the newsletter (Newsletter), in order to perform the contract, the subject of which is the service provided electronically.
e) for the purpose of statistics on the use of individual functionalities available on the Website, facilitating the use of the Website and ensuring the IT security of the Website, we process personal data regarding your activity on the Website and the amount of time spent on each of the subpages on the Website, your search history location, IP address, device ID, data about your web browser and operating system;
f) in order to establish, pursue and enforce claims and defend against claims in court proceedings and other enforcement authorities, we may process your personal data provided when registering on the Website (setting up an Account), ordering services and other data necessary to prove the existence of a claim or which result from from a legal requirement, court order or other legal process;
g) in order to consider complaints, complaints and requests and to answer Users’ questions, we process the personal data provided by you in the contact form, complaints, complaints and requests, or in order to answer questions contained in a different form and some personal data provided by you in Account, as well as data on the Services we provide, which are the cause of the complaint, complaint or request, and data contained in the documents attached to the complaint, complaint or request;
h) for the purpose of marketing our Services and the services of our partners, including remarketing, for this purpose we process personal data provided by you when creating an Account and updating it, data regarding your activity on the Website, including activities that are registered and stored via cookies, in particular the history of activity, ordered services, search history, clicks on the Website, login and registration dates, history and your activity related to our communication with you. In the case of remarketing, we use data about your activity to reach you with our marketing messages outside the Website and we use the services of external providers for this purpose. These services consist in displaying our messages on websites other than the Website. Details on this subject can be found in the records regarding Cookies;
i) in order to organize competitions and loyalty programs, i.e. notifications about accumulated points, notifications about winning and advertising our offer, we use your personal data provided in the Account and when registering in a competition or loyalty program. Detailed information on this subject is provided each time in the terms of participation of a given contest or loyalty program;
j) for the purpose of market and opinion research by us or our partners, i.e. information about services, your data provided in the Account or when using services, e-mail address. Data collected as part of market research and opinion polls are not used by us for advertising purposes. Detailed instructions are given in the information about the given survey or in the place where you enter your data.
3.In the case of registering an account on the e-learning Platform, the Customer provides:
a) name and surname;
b) e-mail address.
c) address details
d) telephone number.
4.In the case of Entrepreneurs, the above scope of data is additionally extended to include:
a) the Entrepreneur’s company;
b) NIP number,
c) KRS number.
5.When registering an account on the e-learning Platform, the Customer independently sets an individual password to access his account. The Customer may change the password at a later time, on the terms set out in the Regulations.
6.When placing an order on the e-learning Platform, the Customer provides the following data:
a) e-mail address;
b) address details:
zip code and city;
country (state);
street and house/apartment number.
c) name and surname;
d) phone number.
7.In the case of Entrepreneurs, the above scope of data is additionally extended to include:
a) the Entrepreneur’s company;
b) NIP number.
8.In the case of using the Newsletter service, the Customer only provides his e-mail address.
9.In the case of using the contact form service, the Customer provides the following data:
a) e-mail address;
b) phone number.
10.If you use the notify about availability service, the customer only provides his e-mail address.
11.If you use the post an opinion service, the Customer provides the following data:
a) e-mail address;
b) name.
12.When using the E-Learning Platform 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.
13.Navigational data may also be collected from customers, including information about links and references that they decide to click or other activities undertaken on our e-learning platform. 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.
14.In order to establish, pursue and enforce claims, some personal data provided by the Customer as part of using the functionalities on the e-learning Platform may be processed, such as: name, surname, data on the use of services, if the claims result from the manner in which the Customer uses services, other data necessary to prove the existence of the claim, including the extent of the damage suffered. Legal basis – legitimate interest (Article 6(1)(f) of the GDPR), consisting in determining, pursuing and enforcing claims and defending against claims in proceedings before courts and other state authorities.
15.The transfer of personal data to iCode Trust is voluntary, in connection with concluded sales contracts or the provision of services via the website on the e-learning Platform, however, with the proviso that failure to provide the data specified in the forms in the Registration process prevents Registration and setting up a Customer Account .

3. WHOM ARE THE DATA DISCLOSED OR ENROLLED AND HOW LONG ARE THEY STORED?

1.The Customer’s personal data is transferred to service providers used by iCode Trust when running the e-learning Platform. Service providers to whom personal data are transferred, depending on contractual arrangements and circumstances, or are subject to iCode Trust’s instructions as to the purposes and methods of data processing (processors) or independently determine the purposes and methods of their processing (administrators).
2.Personal data of Service Recipients and Customers of the e-learning Platform may be transferred to the following recipients or categories of recipients
a) personal data of the Customer to the selected entity handling the above payments on the Platform at the request of the Administrator to the extent necessary to handle payments made by the Customer.
b) service providers supplying the Administrator with technical, IT and organizational solutions, enabling the Administrator to run a business, including the e-learning Platform and Electronic Services provided through it (in particular suppliers of computer software to run the e-learning Platform, e-mail providers and hosting and supplier of software for managing the company and providing technical assistance to the Administrator) – the Administrator provides the collected personal data of the Customer to a selected supplier acting on his behalf only in the case and to the extent necessary to achieve a given purpose of data processing in accordance with this privacy policy.
c) providers of accounting, legal and advisory services providing the Administrator with accounting, legal or advisory support (in particular an accounting office, law firm or debt collection company) – the Administrator provides the collected personal data of the Customer to a selected supplier acting on his behalf only in the case and to the extent necessary to achieve a given purpose of data processing in accordance with this privacy policy.
d) Facebook Ireland Ltd. – If the Administrator uses Facebook social plug-ins on the E-learning Platform website (e.g. Like button, Share or logging in using Facebook login data), therefore collects and shares personal data of the Customer using the e-learning Platform website to Facebook Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland) to the extent and in accordance with the privacy rules available here: https://www.facebook.com/about /privacy/ (this data includes information about activities on the e-Learning Platform website – including information about the device, visited websites, purchases, displayed advertisements and the way of using services – regardless of whether the Service Recipient has a Facebook account and is logged in to Facebook).
e) to any other entities, only after obtaining the express written consent of the data subject (e.g. in a situation where a course participant expresses interest in taking advantage of the possibility of transferring his personal data to potential employers).
3.Data retention period. Customers’ personal data are stored:
a) If the basis for the processing of personal data is consent, then the Customer’s personal data is processed by iCode Trust until the consent is revoked, and after revoking the consent for a period of time corresponding to the period of limitation of claims that may be raised iCode Trust and what may be invoked against it. 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.
b) If the basis for data processing is the performance of the contract, then the Customer’s personal data is processed by iCode Trust 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.If the Customer selects payment via the TPay system, his personal data is transferred to the extent necessary for the payment to be made. iCode Trust Sp. z o. o. using the Future Collars trademark with its registered office in Warsaw at ul. Bukowińska 24D/7, 02-703 Warszawa, entered into the Register of Entrepreneurs of the National Court Register by the District Court for the Capital City of Warsaw, 13th Commercial Division of the National Court Register, under the number KRS 0000777251, NIP 5213861303, REGON 382934531.
5.Navigation data may be used to ensure Customers better service, analysis of statistical data and adaptation of the e-learning Platform to Customers’ preferences, as well as administration of the website.
6.If the Customer subscribes to the newsletter (Newsletter) to his e-mail address, iCode Trust will send electronic messages containing commercial information about promotions and new products available on the e-learning Platform.
7.In the event of a request, iCode Trust 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.

4. COOKIES, IP ADDRESS

1.The e-learning platform uses small files called cookies. They are saved by iCode Trust on the end device of the person visiting the Platform website, if the web browser allows it. A cookie file usually contains the name of the domain it comes from, 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 iCode Trust to individual preferences and real needs of people visiting the Platform’s website. They also give the opportunity to develop general statistics of visits to the presented products on the e-learning platform.
2.iCode Trust uses two types of cookies:
a) 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.
b) 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.iCode Trust uses its own cookies in order to:
a) authenticate the Customer on the e-learning Platform and ensure the Customer’s session on the e-learning Platform (after logging in), thanks to which the Customer does not have to re-enter the login and password on each subpage of the e-learning Platform;
b) analyzes and research as well as audience audits, and in particular to create anonymous statistics that help to understand how customers use the e-learning Platform Website, which allows improving its structure and content.
4.iCode Trust uses external cookies to:
a) popularize the e-learning Platform using the facebook.com social networking site (administrator of external cookies: Facebook Inc based in the USA or Facebook Ireland based in Ireland);
b) facilitating communication via the Website of the e-learning Platform via chat (administrator of external cookies: LiveChat Inc. based in the USA);
c) collecting general and anonymous static data via Google Analytics analytical tools (administrator of external cookies: Google Inc based in the USA);
d) presenting advertisements tailored to the Customer’s preferences using the Google AdSense online advertising tool (administrator of external cookies: Google Inc with its registered office in the USA);
5.The cookie mechanism is safe for the computers of the Customers of the e-learning Platform. 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 e-learning Platform will be possible, except for the functions that by their nature require cookies.
6.iCode Trust may collect Customers’ IP addresses. The IP address is a number assigned to the computer of the visitor to the e-learning platform by the Internet service provider. The IP number allows access to the Internet. In most cases, it is assigned to the computer dynamically, i.e. it changes each time you connect to the Internet. The IP address is used by iCode Trust 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 e-learning Platform, as well as for security purposes and possible identification burdening the server, undesirable automatic programs for viewing the content of the e-learning Platform.
7.The e-learning platform contains links and references to other websites. iCode Trust is not responsible for their privacy policies.

5. SERVICES TAILORED TO PREFERENCES AND INTERESTS (PROFILING)

1.Profiling means any form of automated Processing of Personal Data, which consists in the use of Personal Data to evaluate certain personal factors of a Natural Person, in particular to analyze or forecast aspects concerning the effects of this Natural Person’s work, his situation economic, health, personal preferences, interests, reliability, behaviour, location or movements.
2.Customers’ personal data may be processed in an automated manner (profiling), however, this will not have any legal effects on them or similarly significantly affect the situation of Customers.
3.Profiling of personal data by iCode Trust consists in the processing of Customer data in an automated and manual manner, by using them to evaluate some information about the Customer, in particular to analyze or forecast his personal preferences and interests.
4.In order to reach the Customer with marketing messages outside the e-learning Platform Website, Future Collar will use the services of external suppliers. These services consist in displaying marketing messages on pages other than the e-learning platform website. For this purpose, external providers install, for example, an appropriate code or pixel to download information about the Customer’s activity on the E-learning Platform Website. Details on the cookies used can be found in §3. Legal basis – legitimate interest (Article 6(1)(f) of the GDPR), consisting in matching marketing messages to preferences and interests.
5.In order to reach the Customer with marketing messages via the e-learning Platform Website, iCode Trust uses the services of external providers. These services consist in displaying marketing messages on the Websites of the e-learning Platform. For this purpose, external providers install, for example, an appropriate code or pixel to download information about the Customer’s activity on the E-learning Platform Website. Details on the cookies used can be found in §3. Legal basis – legitimate interest (Article 6(1)(f) of the GDPR), consisting in matching marketing messages to preferences and interests.
6.In order to reach the Client with marketing messages via the e-learning Platform Website, iCode Trust uses its own cookie mechanisms to download information about the Client’s activity on the e-learning Platform Website. Details on the cookies used can be found in §3. Legal basis – legitimate interest (Article 6(1)(f) of the GDPR), consisting in matching marketing messages to preferences and interests.

6. SECURITY MANAGEMENT – PASSWORD

1.iCode Trust provides customers with a secure and encrypted connection when transferring personal data and when logging in to the Customer Account on the Website. iCode Trust uses an SSL certificate issued by one of the world’s leading companies in the field of security and encryption of data sent over the Internet.
2.In the event that the Customer with an account on the e-learning Platform has lost the access password in any way, the e-learning Platform allows you to generate a new password. iCode Trust does not send a password reminder. The password is stored in an encrypted form, in a way that makes it impossible to read it. In order to generate a new password, you must provide your e-mail address in the form available under the “Remind me password” link provided in the account login form on the e-learning Platform. The Customer will receive an e-mail to the e-mail address provided during registration or saved in the last change of the account profile, containing a redirection to a dedicated form available on the Website of the e-learning Platform, where the Customer will be able to set a new password.
3.iCode Trust never sends any correspondence, including electronic correspondence, asking for login details, in particular the access password to the Customer’s account.

7. CHANGES TO THE PRIVACY POLICY

1.The Privacy and Cookies Policy has been in force since August 5, 2021. The
2.current Privacy Policy is available to Customers at the Internet address […]
3.The Service Provider undertakes to inform the Service Recipient about changes made to the Regulations by placing a consolidated text of the Regulations on the Platform’s website.
4.iCode Trust has the right to change the provisions of the Policy or introduce a new one. The Service Recipient will be informed about the change in the provisions of the Policy or the introduction of a new Policy by means of a message sent to the e-mail address provided by the Service Recipient.
5.The new Policy or changes to the existing Policy enter into force after 14 days from the date of informing the Customer, and with regard to persons who have consented to the processing of their personal data during the period of validity of the previous Policy, the changes may not have a negative effect on these persons.
6.The law applicable to all legal relationships arising from the Regulations is Polish law.
7.Questions related to the Privacy Policy should be directed to: [email protected]