Table of Contents

• Introduction
• Useful definitions
• Cookies
• Plugins and social media
• Processing Personal Data by Laurens Coster
• Who we may transfer your Personal Data
• Rights of persons whose data is processed by Laurens Coster
• Information clause
• Information clause in the recruitment process
• Contact with Laurens Coster

Introduction

The Policy has been developed based on the provisions of the GDPR. The Operator of the Website and the Controller of the Personal Data collected through the Website is: 

Laurens Coster Sp. z o.o. with its registered office in Warsaw (00-032) at Przeskok 2, Warszawa, entered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw, XII Commercial Division of the National Court Register, under KRS No. 0000396367, NIP: 7010317469, REGON: 145830835, with share capital of PLN 54,000.00 (hereinafter: Laurens Coster).

Laurens Coster is a company that is committed to providing an appropriate level of privacy protection for users of the Website. We believe that this Policy will fully explain to you how the processing and protection of Personal Data works in our company. The data processing policy applicable at Laurens Coster has been established on the legal basis of GDPR and best practices. By familiarizing yourself with the Policy, you will know what actions we take in respect of Personal Data. These actions are intended to ensure security and fulfillment of obligations incumbent on Laurens Coster as a data Controller.

You should read this Policy before using the Website. Please be advised that if you use our Website, this means that you accept the Policy. However, if after reviewing the Policy, you find it to be unacceptable, you may not continue to use our Website.

If you have any questions or concerns regarding this Policy, you may contact us. Contact information is located in the Contact Laurens Coster section.

Useful definitions

Personal Data – information about an identified or identifiable natural person, defined in accordance with the GDPR and Polish regulations on the protection of personal data, e.g. name, surname, identification number, factor determining mental or physiological identity, IP address.

Policy – this document.

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 the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC.

Website – a website available at https://laurenscoster.com, with an SSL certificate installed, which, by encrypting data, secures your Personal Data and their transmission.

User – a person who uses the Website.

Cookies

The Website uses cookies in order to provide you with services of the highest quality. Files of cookies (so-called "cookies") are IT data, in particular text files, which are stored in the end  device of the Website User and are intended for use on websites.

Cookies usually contain the name of the website they come from, the time they are stored on the end device and a unique number. Laurens Coster is the provider who places and accesses cookies on the Website User's end device  

We use cookies for the following purposes:

• creating statistics, which help to understand how the Website Users use the websites, which allows to improve their structure and content,
• determining user profile in order to display tailored material on advertising networks and provide you with remarketing advertising. We also use cookies to determine whether Users have seen a particular advertisement and visited the advertiser's website.

The Website uses two basic types of cookies:

• session (session cookies) - temporary files that are stored in the User's end device until logging out, leaving the website or turning off the software (web browser), 
• persistent (persistent cookies) - files stored in the User's end device for the time specified in the parameters of cookies or until they are deleted by the User. For example, we use the Google Analytics service commonly used by websites for analytics purposes. These cookies are also used for remarketing services in Facebook Pixel, LinkedIn Insight Tag, Twitter Pixel tools.

The web browsers usually allow the storage of cookies on the User's end device by default. Website Users can change their settings in this regard. The web browser allows deleting cookies. It is also possible to block cookies automatically. Detailed information on this subject can be found in help or documentation of the web browser used. For your convenience we present below sample information on managing cookies for the most popular web browsers:

• Chrome
• Firefox
• Safari.

However, changes in the settings of cookies can affect the operation of the website you are viewing. Cookies do not change the configuration of the device you are using. They make it easier to adapt the browsed content to your expectations and preferences, e.g. language version, proper display of a page on a device, interests or individual needs. Cookies used for authentication enable e.g. easy form filling or logging in.

Cookies placed on the User's end device can also be used by advertisers and partners cooperating with the Website operator.

Please be informed that information about certain User behaviour is subject to logging in the server layer of our hosting operator. This data is used by us solely for the purpose of administering the Website and to ensure the most efficient operation of the hosting services provided. Viewed resources are identified by URLs. In addition , the following can be recorded: 

• time of request arrival, 
• time of response sending,
• client station name - identification carried out by the HTTP protocol,
• information about errors that occurred during the HTTP transaction,
• the URL address of the page previously visited by the user (referrer link), in case the Website was accessed through a link,
• information about your browser,
• information about your IP address.

Information about our hosting provider's privacy policy can be found HERE.

Importantly, the above data is not associated with specific visitors and is only used for server administration purposes.

The Website collects information voluntarily provided by the User through forms available on the Website. Please note that the Website may also record information about your connection parameters (time stamp, IP address). The data provided on the form may constitute a collection of potential clients of Laurens Coster. The data provided on the form is processed for a purpose stemming from the function of the specific form, e.g., to process a request or to conduct a business contact.

Plugins and social media

Social Media

Social media are one of the main channels of contact with our customers and potential customers. Through them we provide up-to-date information about our activities, services, promotions, news about our services and create a place for common exchange of ideas.

Therefore, on the basis of legitimate interests, we process Personal Data of people who use our websites on social networking sites (e.g., to respond to comments and inquiries) and data that we access if you use the social networking plug-in available on our Website (in terms of statistics purposes  our Website).

The processing of Personal Data on social networking is subject to the privacy rules of the respective social media provider. Therefore, we encourage you to read  the rules of the social media providers we use to maintain our social media profiles: 

• Facebook, provided by  Meta Platforms Inc. (1601 S. California Ave, Palo Alto, CA 94304, United States of America) and for users from the European Union Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) | Privacy policy, Information on statistics

• LinkedIn, provided byLinkedIn Corporation (1000 W. Maude Avenue, Sunnyvale, CA 94085, United States of America) and for users in the European Union, European Economic Area and Switzerland LinkedIn Ireland Unlimited Company (Wilton Plaza, Wilton Place, Dublin 2, Ireland) | Privacy policy

• Instagram, provided by Meta Platforms Inc. (1601 S. California Ave, Palo Alto, CA 94304, United States of America) and for users from the European Union Meta Platforms Ireland Ltd. (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland) | Privacy policy

If you use our profiles on social media, Laurens Coster also acts as a Controller of Personal Data. This data is processed by us on the terms of the Policy.

Please be advised  that,in terms of the processing of Personal Data in connection with your use of the social plugins available on our Website, i.e. for the purpose of so-called web tracking (if applicable), Laurens Coster and the social media provider act as joint controllers of the Personal Data in accordance with Article 26 of the GDPR. Web tracking also takes place if you use the plugin as a not logged in social media user.

Web tracking consists in creating aggregate statistics based on events recorded by social media providers while users use  the website. You must know that these events are logged by the social network providers without the participation of Laurens Coster. Information regarding the processing of Personal Data by the social network provider, contact data and information regarding the right to object can be found in social media providers privacy documents indicated above.

Plugins

On our Website we also use:

• Google Analytics

Using Google Analytics software, our Website places a counting code on your computer to collect data about you. Please be advised  that we are party to an agreement with Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland, registration no: 368047) and we use a mechanism to anonymize the user's IP number. The user may at any time object to the collection of data by the Google Analytics software by changing the web browser settings. Information about Google Analytics is available HERE.

• Google Ads

Regarding the information about your preferences collected by the Google advertising network, you can view and edit the information resulting from the cookies using a tool. Please be advised that we concluded a respective agreement with Google Ireland Limited (Gordon House, Barrow Street, Dublin 4, Ireland, registration no: 368047), which is the provider of the tool.

• Amplitude

The platform is designed to help businesses gain insights into user behavior, understand how users interact with their products, and make data-driven decisions to optimize user experiences and drive growth. It includes features such as user segmentation, funnel analysis, retention analysis, and more. Amplitude is provided by Amplitude, Inc. 201 Third Street, Suite 200, San Francisco, CA 94103. More information can be found here. 

• Albacross

We use the Albacross tool on the Website, provided by Albacross Nordic AB (registration number: 556942-7338, Tegelbacken 4A, 111 52 Stockholm, Sweden). The tool uses a so-called Tracking Script that makes it possible, in some cases, to indicate which company a user of our Website is associated with (as part of the Lead Generation service). As part of the Albacross Reveal service, it is also possible to identify companies in real time using IP mapping. More information about privacy and objections to the use of this mechanism can be found HERE.

• Cookie Consent Manager

We want to make our cookie policy clear for you, so we use the Cookie Consent Manager tool. This tool allows us to display a "pop-up" window on our Website that informs you about our use of cookies. We want you to be in control of your activities on our Website so you may choose to accept our use of cookies or object to it. More information about our privacy policy and the tool itself can be found HERE. 

Users are recommended to review the above mentioned privacy rules of third-party tools and services to understand the use of cookies used by these tools and social plugins. You can object to data collection at any time by changing your web browser settings.

• Hubspot

We use Hubspot as a tool for inbound marketing, sales, and customer service. HubSpot's platform includes tools for content management, social media marketing, email marketing, lead generation, customer relationship management (CRM), and more. For more information go to. 

Remarketing tools

• Facebook Pixel, LinkedIn Insight Tag

Our Users are of utmost importance to us, which is why we care about conducting data analysis in order to optimize our operations and carry out marketing activities aimed at people interested in our services.

Above mentioned remarketing tools are based on a piece of code that we have placed on our Website. It allows us to analyze data about Users who use the Website in order to display our ads to those Users on Facebook, Twitter and LinkedIn. Our advertisements may be targeted to audience groups based on collected information. Collected information may include information about your device, the websites you visit, the purchases you make, or how you use our services. The data collected through the Website is then transmitted to the tool provider for usage of the tool's functionality. When you use our Website, remarketing tools send a signal to the tool provider and its servers regarding your visit on our Website. The information collected for remarketing purposes is anonymous - we only see information related to your behavior on the Website.

If you have an account within social media mentioned above, the provider may link the data collected on the Website with your social media account data. Such actions are beyond our control, as they are related to your social media account.

Useful information about Facebook Pixel

• Facebook Privacy Policy - link may be found in Social Media section
• Information regarding the tool
• How deactivate Facebook Pixel in relation to your data - you must be logged in to Facebook to do this

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Useful information about LinkedIn Insight Tag

• LinkedIn's privacy policy - link may be found in Social Media section
• Information regarding the tool

Processing Personal Data by Laurens Coster

When you provide us with your Personal Data, we become their controller.

Laurens Coster's basis for processing your Personal Data may be: 

• Your consent (if applicable),
• the relevant legal provision (e.g. the grounds indicated by Article 6 of the GDPR) or 
• the fact that the processing is necessary for the performance of a contract or taking steps prior to entering into a contract.

We may process your Personal Data, depending on the basis of our contact, for the purposes of:

• providing services related to our business, e.g. by providing your Personal Data, you enable us to contact you in order to present our offer,
• marketing, so that we can inform you about the best and latest offers and functionalities provided by our partners, e.g. in the form of a newsletter,
• statistics related to the operation of the Website.

More details are provided in the section Information clause.

The maximum scope of Personal Data we process depends on the basis of our relationship and includes:

• if you use services related to our business or have sales conversations with us: name, surname, company name, e-mail address, telephone number, position, tax identification number, information about your services, information about your company data (company size, number of employees, contact details of people responsible for cooperation with Laurens Coster),
• if you provided data in the contact form/messengers: name, surname, e-mail address, telephone number, company name, tax identification number,
• if you give us a consent for processing data for marketing purposes: name, surname, e-mail address, telephone number,

• if you use our Website: IP address, device information, cookies (including for remarketing purposes), other data that you provide e.g. by filling in the contact form on our Website.

Please be advised that we do not process specific categories of your Personal Data referred to in Article 9 - 10 of the GDPR such as: ethnic origin, political views or biometric data.

By using our contact forms or the messengers available on the Website, contacting us via our social media profiles, you consent to the processing of Personal Data by us.

If we ask you to provide Personal Data on our Website (e.g. for the use of the contact form), you must know that providing it is a condition for concluding an agreement to access the functionalities available on our Website. If you do not provide this data, you will be, unfortunately, unable to use them.

The period for which Personal Data may be stored depends on the legal basis for processing your Personal Data and the purpose for which they are processed. More details are provided in the section Information clause.

Who we may transfer your Personal Data

Please also be informed that from time to time we may transfer or share your Personal Data with entities that cooperate with us e.g. accounting companies, legal advisors, courier companies, advertising and marketing companies, hosting providers, payment providers. The transfer may take place only when we have concluded appropriate agreements with these entities in order to ensure that they will protect your Personal Data at least as responsibly as we do.

If you were interested in cooperation under the partnership program in which we participate and you have granted a consent to Laurens Coster to share the information about the services which you are interested in and information about the data characterizing the company (size of the company, number of employees, contact details of persons responsible for cooperation) with our partner, or the necessity to share this data results from the agreement concluded by you with Laurens Coster regulating the rules of cooperation within the partnership program, this data may be provided to Google Ireland Limited or Google Cloud Polska sp. z o.o. (depending on the type of service). Here you could find more information about Google processing of personal data.

Personal Information may also be shared by Laurens Coster with government authorities or other entities authorized to access the data and according to the law.

Transfer to such entities may only take place after we have obtained your consent (where required) or where such admissibility is provided for by law, e.g. where Laurens Coster processes data on the basis of a legitimate interest. 

As we use tools for our daily operations whose providers may process Personal Data outside the European Economic Area, your Personal Data may also be transferred for processing outside the European Economic Area. In this case, we ensure that the processing is carried out on a lawful basis, such as standard contractual clauses. Please also note that such transfer may only take place if the third country or international organization meets the conditions set out in the GDPR.

Rights of persons whose data is processed by Laurens Coster

If you consent to the processing of Personal Data, remember that the consent is given by you voluntarily. You have the right to withdraw your consent at any time. However, remember that the withdrawal of consent does not affect the processing carried out by us prior to the withdrawal.

You have the right to access your Personal Data at any time. You can always ask us, as the controller of your Personal Data, for informing you whether your Personal Data is being processed by us, to provide you with an access to your Personal Data, and to receive other information such as, but not limited to, the duration of the processing, the purposes of the processing, information on to whom we provide the data, information on automated decision-making or profiling.

Remember that you also have the right to lodge a complaint with the supervisory body (the President of the Personal Data Protection Office).

You have the right to rectify your Personal Data by changing or supplementing it.

You have the right to delete your Personal Data, known as the “right to be forgotten”. You can request us to delete your data without undue delay in the following situations:

• the data is not necessary for the purpose of processing or is processed in a different way
• consent to processing has been withdrawn previously, and we have no basis for processing
• you have objected to data processing
• the data was processed unlawfully
• the personal data controller is obliged to delete data resulting from legal provisions
• the data was collected in relation to the offering of information society services.

More details about the right to be forgotten can be found in Article 17 of the GDPR.

You also have the right to restrict processing by the controller. You can request a restriction when:

• you question the accuracy of the data
• the processing is unlawful, but you are opposed to deletion by only requesting a restriction
• the controller no longer needs the data for processing purposes, but you need them to establish, assert or defend claims
• you object to processing, but only until its grounds are resolved.

If the processing is performed based on consent or in an automated manner, you also have the right to transfer data that we should provide to you at your request in a commonly used format. You can also request that the data be transferred by us directly to another controller.

If the processing is based on Article 6 (1) (e) or (f) of the GDPR, you have the right to object to the processing. In this case, we can no longer process your Personal Data unless we demonstrate the grounds required by the GDPR.

You also have the right not to be subject to a decision based on automatic processing, including profiling, if such a decision has legal effects on you or otherwise significantly affects you. Please be advised that this right does not apply if: such a decision is necessary for the performance/conclusion of the contract, is permitted by law or is based on your express consent.

Information clause

Controller’s data

The Controller of the personal data is Laurens Coster Sp. z o.o. seated in Warsaw at ul.Przeskok 2, 00-032 Warsaw, entered into the register of entrepreneurs kept by the District Court for capital city Warszawy XII Division of the National Court Register, under the KRS number 0000396367, NIP (tax identification number): 7010317469, REGON: 145830835.

Purpose of processing 

 Depending on the circumstances, the provided personal data may be processed for the purposes of:

• answering questions asked in the forms/via messengers available on the Website,

• receiving marketing e-mails (newsletters), if you consent to it,
• conducting sales talks via emails, social media or phone calls,
• conduct remarketing or analytical and statistical activities,
• if you express a desire to cooperate with us under the partnership program in which Laurens Costers participates - in order to perform the actions necessary to verify the possibility of cooperation under the partnership program in which Laurens Coster participates and to present you with an offer in this regard, and then, if you decide to cooperate with under the partnership program in order to implement and settle this cooperation (i.e. to conclude and perform a contract in this regard),
• in order to conclude and perform a contract with a customer/contractor,
• in order to fulfill legal obligations related to the data processing for the above purposes,
• for the purpose of asserting and defending against claims in connection with the processing for the aforementioned purposes.

Please be advised that providing data is voluntary, but necessary to use the data for above mentioned purposes.

Legal basis and time of the processing

• We process the data provided in the contact form/via messengers based on the legitimate interest of the controller, which is communication with Users of our Website or social media. We will process your data for the time necessary to provide an answer to your question.

• We process the data used for the purpose of sending the newsletter after obtaining your consent, until consent to the processing of this data is revoked. 

• We process data obtained for the purpose of concluding and performing a contract with a customer/contractor for the duration of the contract.

• We process the data obtained during sales talks via email, social media or phone calls after obtaining your consent or on the basis of Laurens Coster legitimate interest (e.g. when we answer your questions about services or carry out our activities aimed at acquiring customers). We process the data for the time necessary to examine the needs of our customers and determine the willingness to start the cooperation with us.

• We process the data collected during your visit to our Website saved in cookies used for advertising purposes on the basis of a legitimate interest of the controller, which is to conduct remarketing activities. The data saved in cookies will be used by us for advertising purposes. For this purpose, we transmit the anonymized identifier of your device to our marketing partners, who may also process personal data outside the European Economic Area.
• Data collected for the purpose of performing activities necessary for verifying the possibility of cooperation under the partnership program in which Laurens Coster participates and presenting you with an offer in this regard will be processed until the completion of these activities or until you withdraw your consent in this regard/resign from cooperation - depending on which of the events occurs first. In the case of entering into an agreement within the partnership program, the data will be processed for the purpose of entering into, executing and settling this agreement for the period of its validity and the period necessary for its settlement with the partner, or longer, if it results from the agreement.
• Data collected for the purpose of fulfilling legal obligations related to processing for the above purposes will be processed for the time necessary to fulfill such obligation.
• Data collected for the purpose of asserting claims and defending against claims in connection with the processing for the above purposes will be processed for the limitation period and, if proceedings are initiated before the expiration of the limitation period, until the date of final settlement of the dispute.

Personal Data recipients

The recipients of your data may be relevant state authorities operating on the basis of generally applicable law. Your data may also be transferred to entities, as defined within Who we may transfer your Personal Data to part, processing data at the request of the controller - remember, however, that such entities process data on the basis of a contract with the controller and only in accordance with his/her instructions.

Processing data outside the EEA

Due to the fact that for our business we use tools whose suppliers may process Personal Data outside the European Economic Area, your Personal Data may also be transferred for processing outside the European Economic Area. In this case, we make sure that the processing takes place on a legal basis, which are, for example, standard contractual clauses.

Rights of data subject

You have the right to request the controller to access your personal data, rectify it, delete it or restrict the processing of, as well as the right to withdraw consent if it is expressed and a complaint is lodged with the supervisory body (for Poland: President of Personal Data Protection Office, Stawki 2, 00-193 Warsaw). In matters related to data protection, you can contact us at: iod@laurenscoster.com 

Information clause in the recruitment process

If you are participating in the Laurens Coster recruitment process or have sent us your application documents yourself, please read this information clause.

Controller’s data

The Controller of the personal data is Laurens Coster Sp. z o.o. seated in Warsaw at ul. Przeskok 2, 00-032 Warsaw, entered into the register of entrepreneurs kept by the District Court for capital city Warszawa XII Division of the National Court Register, under the KRS number 0000396367, NIP (tax identification number): 7010317469, REGON: 145830835.

‍Purposes and period of processing

Personal data will be processed in order to conduct the recruitment process. The data contained in the application documents will be processed by us for the duration of the recruitment process and for a period of 6 months after its completion, and in the case of consent from the candidate for future recruitment for 2 years.

Providing personal data is voluntary and necessary to handle your inquiry, and the basis for data processing is your consent.

‍Recipients of personal data

Recipients of your data may be relevant state authorities acting on the basis of generally applicable law. Your data may also be transferred to entities processing data on behalf of the controller, as mentioned in the section To whom we may transfer Personal Data - please note, however, that such entities process data on the basis of a contract with the controller and only in accordance with the controller's instructions.

Processing data outside the EEA

Due to the fact that for our business we use tools whose suppliers may process Personal Data outside the European Economic Area, your Personal Data may also be transferred for processing outside the European Economic Area. In this case, we make sure that the processing takes place on a legal basis, which are, for example, standard contractual clauses.

Rights of data subject

You have the right to request the controller to access your personal data, rectify it, delete it or restrict the processing of, as well as the right to withdraw consent if it is expressed and a complaint is lodged with the supervisory body (for Poland: President of Personal Data Protection Office, Stawki 2, 00-193 Warszawa). In matters related to data protection, you can contact us at: iod@laurenscoster.com 

Specimens of the consents that the candidate should/can give by sending us the application documents:

Current recruitment process – consent mandatory:

I agree and my consent is freely-given, to processing my personal data from application documents by Laurens Coster Sp. z o.o. with a registered office in Warsaw (00-032), ul. Przeskok 2 for the purpose of the current recruitment process conducted by Laurens Coster sp. z o.o. I have read the information clause.

Future recruitment process – consent optional:

I agree and my consent is freely-given, to processing my personal data from application documents by Laurens Coster Sp. z o.o. with a registered office in Warsaw (00-032), Przeskok 2 for the purpose of a future recruitment process conducted by Laurens Coster sp. z o.o. I have read the information clause.

Contact with Laurens Coster

Laurens Coster, acting as data controller, has appointed a Data Protection Officer to ensure the security and correctness of the processing of Personal Data. 

All inquiries and requests related to the processing of Personal Data can be directed to:

• postal address: Laurens Coster Sp. z o.o., ul. Przeskok 2, 00-032 Warszawa 
• e-mail address: iod@laurenscoster.com 

We may change our Policy from time to time to take account of the changing legal and technological environment. However, the most up-to-date version will always be available on our Website.