Privacy policy

1. General Information

The Data Controller is Velis RET Sp. z o.o. with its registered office in Kraków, at ul. Podole 60, 30-394 Kraków, entered in the Register of Entrepreneurs of the National Court Register maintained by the District Court for Kraków-Śródmieście, 11th Commercial Division of the National Court Register under KRS number 0001035946, Tax Identification Number (NIP): 6772333578, National Business Registry Number (REGON): 121036866.

In this notice, “SINGU”, “we”, “us” and “our” refer to Velis RET Sp. z o.o. operating under the SINGU brand.

You may contact us using the form available at: https://singu.com/contact/

This notice applies in cases where we act as the “controller” of personal data, i.e., in particular with regard to the data of our clients’ representatives, including users of the SINGU platform, users of our website, and persons who correspond with us.

2. Categories of Personal Data Collected

We collect and process the following categories of personal data depending on the manner of interaction with us:

2.1. Contact and Business Data

First and last names, email addresses, telephone numbers, company name, job title, correspondence address of contact persons who are representatives of our clients, prospective clients, partners, and service providers.

2.2. Marketing Data

Data concerning communication preferences, marketing consents, history of interaction with our marketing materials.

2.3. Website User Data

First name, last name, email address, telephone number, company name, IP address, browser data, cookies, device information, geographic location. We collect this data through contact forms on the website https://www.singu.com and through analytical tools.

2.4. Data Sources

We obtain data: (a) directly from data subjects; (b) through forms on the website https://www.singu.com; (c) from email correspondence; (d) during industry events; (e) automatically through cookies and analytical tools; (f) from our clients in connection with the provision of services.

3. Purposes and Legal Bases for Processing Personal Data (Article 6(1) GDPR)

We process your personal data for the following purposes and on the following legal bases:

3.1. Performance of Business Relations

We use contact and business data for communication with clients, in particular to inform them about the functionalities and development of the SINGU platform, handle complaints, negotiate and perform contracts, and manage business relationships. Legal basis: Article 6(1)(b) GDPR (performance of a contract – where the client is a natural person) and Article 6(1)(f) GDPR (legitimate interest of the controller, which is the performance of a contract concluded with an entity other than a natural person, and maintenance of business relationships).

3.2. Marketing

We use personal data for direct marketing of SINGU services. Legal basis: Article 6(1)(f) GDPR (legitimate interest) consisting in presenting the scope, quality, or prices of SINGU services, whereby the sending of commercial information to natural persons by electronic means takes place only after obtaining prior consent in this regard.

3.3. Research and Analysis

Monitoring the use of the website www.singu.com, analysis of user behaviour, improvement of service quality. Legal basis: Article 6(1)(f) GDPR (legitimate interest of the controller – improvement of services) and Article 6(1)(a) GDPR (consent to cookies).

3.4. Record Keeping

Creation and maintenance of databases necessary for managing client relationships. Legal basis: Article 6(1)(f) GDPR (legitimate interest of the controller – organisation of business operations).

3.5. Security

Prevention of fraud, protection of IT system security, detection and counteracting of threats. Legal basis: Article 6(1)(f) GDPR (legitimate interest of the controller – security).

3.6. Legal Claims

We process personal data for the purpose of establishing, pursuing, or defending against legal claims. Legal basis: Article 6(1)(f) GDPR (legitimate interest of the controller – protection of rights).

3.7. Compliance with Legal Obligations

We process data for the purpose of fulfilling legal obligations, in particular in the area of accounting and taxation. Legal basis: Article 6(1)(c) GDPR (compliance with a legal obligation to which the controller is subject).

4. Disclosure of Personal Data to Other Entities

We use IT service providers that process data on our behalf on the basis of data processing agreements (Article 28 GDPR). These entities include, among others:

– Google LLC (Google Analytics, Google Tag Manager) – web analytics;

– Microsoft Corporation (Microsoft Clarity) – user behaviour analysis;

– HubSpot, Inc. – CRM and marketing automation;

– Cloudflare, Inc. – website security and performance;

– CookieYes Limited – cookie consent management;

– Vimeo, Inc. – video content distribution platform;

– LinkedIn Ireland Unlimited Company (LinkedIn Insight Tag) – B2B remarketing.

We also use other professional services that involve the disclosure of data to entities providing services on our behalf, such as law firms, tax advisors, auditors, and insurers – to the extent necessary to protect our legal interests and conduct our business operations.

We may disclose personal data where required by Polish law or European Union law, including at the request of authorised authorities (courts, prosecutors, administrative bodies).

We may disclose personal data in connection with the establishment, pursuit, or defence of legal claims.

5. International Transfers of Personal Data

SINGU may transfer personal data to third countries (outside the European Economic Area), in particular to the United Kingdom, the USA, and Australia.

The transfer of personal data to third countries takes place exclusively on the basis of:

a) an adequacy decision of the European Commission (Article 45 GDPR) – in the case of the United Kingdom;

b) standard contractual clauses adopted by the European Commission (Article 46(2)(c) GDPR) – in the case of the USA and Australia.

A copy of the safeguards applied is available upon request. You may contact us using the form available at: https://singu.com/contact/.

6. Personal Data Retention Periods

We retain personal data for no longer than is necessary for the purposes for which the data is processed (principle of storage limitation – Article 5(1)(e) GDPR).

Data necessary for the defence of legal claims is retained until the expiry of the limitation periods for claims.

After the expiry of the retention periods, data is permanently deleted or anonymised. Data may be retained for longer only where there is a legal obligation to do so (e.g., accounting or tax requirements to retain evidence of economic events) or until the final conclusion of proceedings, if the data is necessary for the pursuit or defence of claims.

7. Rights of Data Subjects (Articles 15–22 GDPR)

Under the GDPR, you are entitled to the following rights:

– Right of access to data (Article 15 GDPR);

– Right to rectification of data (Article 16 GDPR);

– Right to erasure of data (“right to be forgotten”, Article 17 GDPR);

– Right to restriction of processing (Article 18 GDPR);

– Right to object to processing (Article 21 GDPR);

– Right to data portability (Article 20 GDPR);

– Right to lodge a complaint with a competent supervisory authority (The supervisory authority competent for SINGU with regard to personal data protection is the President of the Personal Data Protection Office (UODO), ul. Stawki 2, 00-193 Warsaw, tel. 22 531 03 00, www.uodo.gov.pl);

– Right to withdraw consent at any time, without affecting the lawfulness of processing carried out on the basis of consent prior to its withdrawal (Article 7(3) GDPR).

To exercise the above rights, you may contact us using the form available at: https://singu.com/contact/.

8. Automated Decision-Making and Profiling (Article 22 GDPR)

SINGU does not make decisions based solely on automated processing, including profiling, which would produce legal effects concerning you or similarly significantly affect you. We use analytical tools (Google Analytics, Microsoft Clarity, Hotjar) solely for statistical purposes and for the improvement of service quality, without making automated decisions concerning individual persons.

9. Cookies

The website www.singu.com uses cookies. Detailed information on the cookies used:

– Necessary cookies (Cloudflare) – ensuring the security and proper functioning of the website;

– Analytical cookies (Google Analytics, Microsoft Clarity, Hotjar) – analysis of website traffic and user behaviour;

– Marketing cookies (HubSpot, ZoomInfo/WebSights) – personalisation of content and advertisements;

– Consent management cookies (CookieYes) – saving cookie preferences.

Consent to cookies (other than necessary cookies) is voluntary and may be withdrawn at any time through the CookieYes panel available on the website.

10. Obligation to Provide Data and Consequences of Refusal

The provision of personal data is voluntary; however:

– to the extent necessary for the conclusion and performance of a contract – refusal to provide data will prevent the conclusion of the contract and the provision of services;

– to the extent required by law – refusal to provide data may prevent the fulfilment of legal obligations.