I Introduction
When conducting business activities, JWP Group collects and processes personal data of users in accordance with applicable provisions of law, including 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, GDPR).
Below please find the information that may be relevant in connection with the use of the services provided by JWP Rzecznicy Patentowi Dorota Rzążewska sp.k. (hereinafter: JWP) or another entity from JWP Group (listed here) which is a party to a provision of services agreement, or an entity contacted for another purpose.
Personal data means any information about the natural person identified or identifiable through one or more specific factors determining their physical, physiological, genetic, mental, economic, cultural or social identity, including their image, voice recording, contact details, location data, information included in correspondence, information collected via recording equipment or other similar technology.
The function of a personal data controller making decisions about the purposes and manner of data processing is jointly performed by the entities constituting JWP Group (hereinafter referred to as JWP Group):
In order to ensure an adequate level of personal data protection, JWP Group has appointed Data Protection Officer, to be contacted by email at: dane@jwp.pl or by mail at: uul. Mińska 75, 03-828 Warsaw.
II Personal Data Collection, Processing and Use
The manner and scope of personal data collection depends in particular on whether you visit our website for information purposes or use the services offered via the website or the services described therein, but provided otherwise.
The provision of personal data is voluntary, but necessary to accomplish the purposes for which we have collected personal data.
We process personal data for the following purposes and with reference to the following legal basis (Article 6(1)(a)-(c),(f) of GDPR):
We process the personal data provided to us for the period necessary to accomplish the above purposes. Depending on the legal basis, this will be respectively:
Taking into account the trust that users place in JWP Group when using our legal advisory services, we reserve the right to retain, in individual cases, personal data allowing to identify a conflict of interest should a case regarding a specific user be conducted by us for the opposing party.
III Cookie Policy
JWP Group uses the following Websites:
When you uses the Website, your data is automatically collected. The data include: IP address, domain name, browser type or operating system type. The data may be collected by web cookies, Google Analytics, and may be stored in server logs.
Web cookies are small text files sent to your computer or another terminal device when you are browsing the Website. Web cookies remember user preferences, which helps enhance the quality of provided services, improve search results or the accuracy of displayed information, personalize a website, and create website statistics.
JWP Group is a controller of web cookies.
You may opt out of web cookies (or set preferences for their use by your web browser) by selecting appropriate settings in your web browser.
You agree to the storage of or access to the web cookies by the Service Provider by reading a web cookies use notification message during your first visit to the Website, closing the notification message and keeping the default settings of your web browser unchanged. You may change the way web cookies are used at any time by changing the settings of the browser installed on your device.
JWP Group uses the types of web cookies listed below:
JWP Group uses the Google Analytics system, which serves for web analytics and gives insight into the Website traffic useful in marketing activities.
Third-party social media (e.g. Facebook, Twitter, LinkedIn) may record information about you, for example, when you click on an “Add” or “Like” button connected with a particular social networking site during your stay on the Website. The Service Provider has no control over third-party entities or their activities. Information about social media sites is available thereon.
JWP Group uses the data provided by you or collected automatically to:
Should you have any additional questions related to the use of web cookies, please send them to the following email address: info@jwp.pl. The rules set out in the Cookie Policy are governed by Polish law.
IV Transfer of Personal Data to Third Parties
Subject to data security guarantees, we may transfer personal data to other entities, including:
Personal data may also be transferred to countries outside the European Economic Area (i.e. countries other than the European Union or Iceland, Norway and Liechtenstein), provided that conditions set out in Chapter V of the GDPR are met. The entrusting of personal data of JWP Group clients to foreign attorneys established outside the European Economic Area takes place after this has been agreed with the user.
The entities with whom user data is shared may use it in the manner and to the extent necessary to accomplish the purpose set by JWP Group. In addition, JWP Group cooperates with advisors who are obliged to comply with security rules and regulations as regards personal data processing. JWP enters into agreements for entrusting individual entities with personal data specifying terms and conditions for the use of such personal data by these entities.
V Google Analytics
JWP Group uses Google Analytics, which uses web cookies stored in your computer. As a result, we obtain personal data identifying the entity using JWP Group’s Website, such as an IP address. The information resulting from web cookies is provided to Google Inc. and stored on the server of this company. Google Inc. collects and processes data in accordance with its own privacy policy.
VI Personal Data in Social Media
JWP Group provides content via social media such as: Twitter, Facebook, LinkedIn and Youtube. When you use specific social media, your personal data is collected and processed by these entities under the terms and conditions set out by their owners, outside the control of JWP Group.
VII Data Security
In order to ensure data confidentiality, JWP Group has implemented procedures as well as organizational and technical solutions allowing access to data by authorized persons who process it in connection with the tasks with which they have been entrusted. Necessary actions are taken to ensure that subcontractors and other cooperating entities also guarantee the use of appropriate security measures whenever they process data on behalf of JWP Group.
The information sent via the Website, including via the contact form, newsletter or as part of JWP Online service, is encrypted by means of SSL protocol and remains invisible to third parties.
Risk analyses are carried out on an ongoing basis and the adequacy of data safeguards applied to identified risks is monitored.
In addition, JWP Group complies with the duty of professional secrecy binding patent attorneys, attorneys-at-law and advocates.
VIII User Rights
Any person whose personal data is held by JWP Group has the right to request access to their personal data, to have the data transferred, rectified and erased or to have the processing of their personal data restricted. Any restriction in this respect may only arise from regulations.
Notwithstanding the rights mentioned above, any data subject may object to the processing of the data where the data is used on the basis of a legitimate interest. Having accepted such a relevant request, JWP Group is obliged to cease the processing of data for a specific purpose.
The withdrawal of consent to the processing of personal data does not affect the lawfulness of data processing made on the basis of the consent before its withdrawal.
Should you wish to exercise these rights, please send an email to dane@jwp.pl.
Any data subject also has the right to file a complaint with the President of the Personal Data Protection Office if they consider that the processing of personal data by JWP Group violates the provisions of law.
IX Regulations on the Provision of Services
As required by law, detailed terms and conditions for the provision of remote services are set out in The Regulations on the Provision of Services.
X Copyrights
The Website content is protected by copyright. Its content may not be used in any fields of use otherwise than upon JWP’s written consent stipulating that only non-commercial use for personal purposes is allowed.
The logo of any entity belonging to JWP Group placed on the Website is a registered trademark subject to protection.
The content in the form of works disseminated in the blog, social media and the newsletter is also protected by the copyright held by JWP Group.
XI Final Provisions
The content in the materials posted on the Website, in social media and in the newsletter is designed for informational purposes only and cannot be treated as advice, consultation or recommendation.
JWP Group reserves the right to make changes to this information at any time and to any extent, without prior notice.
Commercial information on provided services is informative in character and constitutes an invitation to negotiate; it is not a commercial offer within the meaning of Article 66(1) of the Civil Code.
The rules set out in the Cookie Policy are governed by Polish law.
The Privacy and Cookie Policy may be updated, in particular when amendments are made to relevant regulations or guidelines issued by competent authorities.
As part of the fan page, due to Facebook specificity, information about fan page followers, likes, and the content of comments, posts and other information provided by users are public.
8. We may share your data with the entities of the following categories:
on the terms set out in the Facebook terms and policies;
You have the right to
Providing your data is voluntary, but the failure to provide your data will make it impossible for you to view the fan page or make comments.
Pursuant to Article 13(1) and (2) and Article 14 of 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”), below we provide information on how we will process your personal data made available during the use of our social networking site profile (hereinafter referred to as the “fan page”):
In addition, please note that YouTube retains your data as user profiles and uses it for advertising, market research and/or its non-standard website design. Such assessment is carried out (even for users who are not logged in) in particular to provide relevant advertising and inform other social network users about their activities on our website.
The data Controller will not transfer data outside the territory of Poland/EU/European Economic Area, subject to a transborder nature of data flow as part of YouTube service, pursuant to contractual clauses used by YouTube and approved by the European Commission and the decisions of the European Commission acknowledging an appropriate level of data protection as regards specific countries in accordance with the principles specified by YouTube at
https://www.youtube.com/intl/en/about/ or www.privacyshield.gov/EU-USFramework
In connection with the processing of personal data, you gave the right to:
We obtain your data from YouTube and from your public profile and fan page posts on the YouTube platform.
Personal data will not be subject to automated decision-making, including profiling. The data obtained from you by the Controller will be processed on the basis of its voluntary submission when your personal data is processed on the basis of your consent. Processing may also be required by law, e.g., when documentary archiving is necessary.
Pursuant to Article 13(1) and (2) and Article 14 of 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”), below we provide information on how we will process your personal data made available during the use of social networking media profile (hereinafter referred to as the “fan page”):
The Controller processes the data of persons who:
In addition, please note that the LinkedIn platform controller, as a tool provider, is jointly responsible for the processing of data of persons using the Controller’s company profile, and may process their data for its own purposes based on other legal basis. In particular, LinkedIn may, pursuant to its own provisions and regulations, collect and process information contained in the cookies of profile visitors. On the basis of the data so collected, LinkedIn may have anonymous summaries and statistics (e.g., on the number or profile of visitors) created, which can be made available to the Controller as the entity running the profile.
In connection with the processing of personal data, you gave the right to:
We obtain your data from the LinkedIn provider, from your public profile and from posts in the Controller’s profile.
Pursuant to Article 13(1) and (2) and Article 14 of 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”), below we provide information on how we will process your personal data during the use of our social networking media profile (hereinafter referred to as the “fan page”):
The Controller of data of persons using the JWP profile is the JWP Group, which consists of the entities being Members of the JWP Group:
and the Twitter platform controller, as an entity jointly responsible for the processing of data of persons using the JWP profile. For further information on Twitter’s data processing, please visit https://cdn.cms-twdigitalassets.com/content/dam/legal-twitter/site-assets/privacy-page-gdpr/pdfs/PP_Q22018_April_EN.pdf
The Controller may be contacted by mail at the following address: ul. Mińska 75, 03-828, by email: info@jwp.pl or by phone: 22 436 05 07.
We’ve appointed a data protection officer. This is a person you may contact in all matters regarding the processing of personal data and the exercise of your rights related to the processing of data. You may contact the officer as follows: by mail to the Controller’s address or by email at: iod@odosc.pl
Your data will be processed to:
In addition, please note that the Twitter controller, as a tool provider, is jointly responsible for the processing of data of profile users and may process their data for its own purposes on other legal basis.
In particular, Twitter may, on the basis of its own provisions and regulations, collect and process the information contained in the cookies of profile visitors.
On the basis of the data so collected, Twitter may have anonymous summaries and statistics (e.g., on the number or profile of fan page visitors) created, which can be made available to the JWP GROUP as the entity running the fan page.
Your personal data provided on Twitter in connection with the use of the JWP GROUP profile may be available to the controller of this platform – i.e., Twitter.
At the same time, any personal data contained in the comments posted on the JWP GROUP’s fan page may also be accessible to other Twitter users.
Your personal data will be processed by the JWP GROUP for the period necessary to accomplish the above purposes of processing, in particular for the period in which you are an active fan page user or until you object to the processing of data.
The data contained in posts or comments can be processed until they are deleted. Should you be unable to delete a specific comment, you can ask us to do so.
You can always opt out of following the profile of the JWP GROUP, you can also object to the processing of your data for these purposes.
Regardless of the retention of data by the JWP GROUP, the Twitter controller may use its own retention periods.
You have the right to access your data and the right to request its rectification, its erasure or restriction of its processing.
To the extent that your personal data is processed on the basis of the JWP GROUP’s legitimate interest, you have the right to object to the processing of your personal data.
You also have the right to file a complaint with a supervisory authority dealing with the protection of personal data.
In order to exercise the above rights, please contact the data controller. Contact details are indicated above.
The JWP GROUP may implement your rights within the scope of its technical capabilities (e.g. by deleting a comment or a post containing personal data at your request).
Regardless of your contact with the JWP GROUP regarding the processing of your data via Twitter, you may also contact the Twitter controller.
Providing data as part of using the profile is voluntary. Failure to provide such data may prevent your from using certain functionalities (such as those used to post comments or contact the JWP GROUP).