Privacy policy

Privacy Policy

Basic information

Protecting privacy of all persons using our services is important to us. 

Nais Application is of a closed nature. Service Provider’s software is intended for (i) Program Participants to use the offer of Service Provider’s Partners within the Program, (ii) Partners to confirm the Program Participants and Program Organizers’ entitlements to purchase services or goods from Partners and (iii) Program Organizers to register Program Participants to the Program, and administer part of their rights as part of the Application features.

Nais website (nais.co, nais.pl or other used by Nais Service Producer) is aimed at informing Visitors, Users, Partners and other interested persons about the advantages and capabilities of the Nais Application, organization and participation in the Program.

The information we collect may be used by Nais Affiliates or our Partners for the purposes of administering the Application, managing entitlements and offers in the Program as well as for the needs of our Partners to enable them to offer the Program Organizers and Participants the best possible offer and to correctly conduct the sale process, including verification of the rights of the Program Organizers and Participants to use Partners’ offer. Some of our contacts with the use of Users and Partners data will concern marketing communication.

This Privacy Policy covers all data provided to us through the Nais Application, in particular for the purpose of providing access to the Application and participating in the Program (the “Service”).

Hereunder, we describe what kind of information we gather in connection with the provision of the Service, for what purpose and how are they used. 

The Privacy Policy also contains information on data security as well as access rights and supervision over the information provided to us.

Capitalized terms that are not defined in this document have the meaning assigned to them in the General Terms of Use (“GTU”) of the User, Program Organizer or Partner.

The list of Nais Affiliates can be found at https://nais.co/legal/nais-affiliates

Information on Personal Data Controller

The controller of the Visitors’ Personal Data is the Nais Service Producer who provides online content directly to the Visitor.

The controller of Users’ Personal Data is the Nais Service Provider who provides the Service directly to the User.

You can contact us by sending correspondence to the above-mentioned address of our registered office, by sending an e-mail to the address dziendobry@nais.co or hello@nais.co, by sending us a message using the chat function available on our website or by sending an inquiry in the contact form provided on https://www.nais.co/contact/.

The list of Nais Service Providers can be found at https://nais.co/legal/nais-service-provider 

Information on the Data Protection Officer

Our Data Protection Officer is Łukasz Kołodziejczyk. You can contact our Data Protection Officer by sending an email to iod@nais.co or privacy@nais.co or by sending appropriately addressed correspondence to the address of our office:

Nais Sp. z o.o.
Data Protection Officer
Plac Europejski 3
00-844 Warsaw

Information on purposes of processing of personal data

Your Personal Data will be processed in connection with visiting our websites and using the Application. Essentially, we need personal data to correctly identify Visitors and Users and to ensure the proper provision of the Service and the functioning of the Program.

Personal data will also be processed for purposes related to providing Users with information about the functioning of the Service, new products and services available as part of the offer of our Partners, as well as in connection with ensuring communication between the Program Organizer and the Program Participant.

More detailed information on this subject can be found in the relevant document  Information Clause.

Information on the methods of processing of personal data

The personal data of our Users, for which we are the Data Controller, are obtained by us directly in the process of setting up a User Account. In addition, we may process your data at the request of your Program Organizer, before you create a User account. We process this data mainly using IT systems in an automated manner.

Personal data that you provide to us directly

Personal data for which we are the Data Controller, are obtained by us directly from you in the process of setting up a User Account. These include primarily the first name, surname and mobile phone number as well as an email address. In case you make a payment or in connection with the purchase of certain products and services, you may be asked to provide more data – but only if it is absolutely necessary for the proper performance of the service or for complying with legal obligations or if it is necessary for exercise or defence of legal claims. 

These data constitute an individual set of data, the Nais User Profile, the Data Controller of which is the Nais Service Provider.

Personal data that we obtain indirectly – from the Program Organizer who invites you to the Program organized by him

We may also collect our Users personal data from the Program Organizers. These data are entered into the IT system of the Application by Users having appropriate entitlements granted by the Program Organizer. These data are processed to invite Program Participants to the Program and are used by the Program Organizer for ongoing work in the Application and Program management.

These data constitute an individual set of data, Program Participant Profile, Data Controller of which is the Program Organizer.

In this respect and in relation to these data, the Program Organizer entrusts their processing to Nais Service Provider.

In accordance with the privacy principles of our Users, we hereby inform that none of the Program Organizers has access to the Application User Profile data. The Program Organizers also do not receive any detailed information about the way the User uses the Application. More detailed information on this issue can be found in the description of recipients of the data.

Data automatically obtained while using the Application

While you are using the Application, we also obtain data provided by your browser or your device that you use in order to connect to the Internet. These data primarily refer to the use of the Application and are used to monitor the proper functioning of the system, improve the applied solutions or adapt content and offers of products and services. This information may relate to the IP address of your Internet connection, the type of web browser, and the type of operating system.

More detailed information on this subject can be found in the document Information Clause

Information on legal basis for processing of personal data

Personal data for which the Data Controller is the Nais Service Provider. are processed primarily in connection with the provision of the Service. The legal basis for the processing of this data is the performance of the agreement, the conclusion of which takes place at the time of acceptance of each of the GTUs.

Users’ personal data are also processed after the completion of the provision of the Service to the extent necessary to fulfil the obligations arising from legal provisions and where it is necessary for the exercise or defence of legal claims.

Personal data for which the Nais Service Provider is a the Processor, i.e. an entity entrusted by the Program Organizer as the Data Controller with the processing of personal data, are processed on the basis of the Data Entrustment Agreement.

More detailed information on this subject can be found in the relevant document Information Clause

Information on period of personal data processing

Personal data are processed by us throughout the period of providing the Service to the extent necessary for its proper implementation, and after that period only to the extent necessary to meet the obligations arising from the law and where it is necessary for the exercise or defence of legal claims.

More detailed information on this subject can be found in the relevant document Information Clause

Information on recipients of personal data

Personal data shall be shared primarily with our Partners – service and products providers which you decide to use, only in cases when it shall be necessary for the correct implementation of the service and only to the necessary extent.

Access to Users’ personal data is also obtained by our Application administrators, solely for the purpose and to the extent that is necessary for the proper service support for our Users.

In justified cases, your personal data may also be shared with trusted cooperating entities only for purposes related to the provision of the Service or for ensuring its proper provision. Your personal data may also be shared with our Data Protection Officer in situations when it shall be necessary to perform the Officer’s tasks provided for in the law and internal procedures.

Your personal data or detailed information about services or products you use is not shared with your Program Organizer. Your Program Organizer receives only statistical and analytical (qualitative) information about the funds used by the invited Program Participant. This information does not disclose which services or which products the specific Program Participant has used in the system.

More detailed information on this subject can be found in the relevant document Information Clause

Information on the exercised rights of the data subject

We provide all possible and available technical and organizational measures so that our Users could freely exercise their rights. Therefore, please send us any notifications and requests regarding the exercising of rights to our e-mail address dziendobry@nais.co or hello@nais.co.

In justified cases, in order to perform correct identification of a person, we may ask you provide additional information or the necessary documents confirming your identity.

Right to freely give or withdraw consent to data processing

You have the right to freely give or withdraw consent to data processing. In the event that your personal data are processed on the basis of your consent, we shall provide you with the possibility to withdraw the consent at any time. Your personal data may also be processed by us for a legally justified purpose, including (but not limited to) marketing of own products and services. In such case, we also allow you to withdraw your consent to such activity or  to object to such action.

The withdrawal of consent shall have an immediate effect and shall not affect the processing of data that was carried out prior to such withdrawal. Withdrawal of consent has no negative consequences for you, but it may prevent you from further use of the Service in a certain way or of a certain part of the features available in the Application.

Right of access to personal data

You have the right to access the personal data provided to us. We implement this right primarily via Application, providing you with the information you have provided us  – which we currently have.

You may also receive from us copies of the information we have. In this case, we will provide you with a copy of the personal data provided by you in a structured, commonly used, machine-readable format. We do not charge a fee for preparing, processing and issuing the first copy of the data.

In case of further requests we may charge a fee for the costs resulting from the preparation, development and delivery of the data records. In such case, you shall be informed about the amount of the fee before another copy of the data records is prepared.

Right to rectification of personal data

You have right to rectification (correction) of your personal data. We exercise this right primarily via Application, providing you with the possibility to edit your personal data. In the event it is impossible, you have the right to demand that we immediately rectify, supplement or erase the data.

Right to erasure of personal data

You have the right to request the erasure of your personal data. We implement this right on the basis of a clear request provided to us to erase the data. The request to erase the personal data may result in the deletion of the User Account in the Application.

You may exercise the right to erase the data if:

  • personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
  • you withdraw your consent to the processing of the data on which the processing is based and there is no other legal ground for further processing;
  • personal data have been processed unlawfully;
  • personal data must be removed in order to comply with the legal obligation provided for in EU or Member State law.

The exercise of the right to request the erasure of personal data may, however, be limited if this processing is necessary for the Nais Service Provider to fulfil its obligation under the law or it is necessary for the establishment, exercise or defence of legal claims.

Right to restriction of processing of personal data

You have the right to request the restriction of the processing of your personal data. We implement this right on the basis of a clear request to limit processing with justification.

You may exercise the right to restriction of processing of personal data:

  • if you question the correctness of the personal data provided – for a period enabling the correctness of the questioned data to be verified;
  • the processing of your personal data is unlawful, but you object to the erasure of your personal data;
  • the personal data we process are no longer necessary to achieve the purpose for which we processed them, but you need them to establish, exercise or defend legal claims;
  • you object to the processing of your personal data due to the special situation indicated in the provisions of law on the protection of personal data.

Right to object to processing of personal data

You have the right to object to the processing of your personal data. We implement this right on the basis of a clear objection to the processing of your data, provided to us.

You can exercise the right to object to the processing of your personal data in a situation where the processing takes place in connection with the implementation of our legitimate interest – e.g. marketing of own products and services.

Right to data portability

You have the right to submit a request to transfer your personal data to another service provider. However, for security reasons and in the absence of standards related to data portability, we are not able to fulfil such a request. In accordance with our policies, you can receive a copy of the personal data provided to us.

Right to lodge a complaint with supervisory authority

You have the right to, at any time, to lodge a complaint related to the processing of your personal data with the national supervisory authority competent for the Nais Service Provider in the field of personal data processing.

We respect your privacy and we guarantee you the opportunity to exercise legal rights regarding the processing of personal data. In order to avoid unnecessary disputes, before submitting such a complaint we encourage you to contact our Data Protection Officer (iod@nais.co or privacy@nais.co) or our team directly (dziendobry@nais.co or hello@nais.co).

Restrictions related to the exercise of the rights of the data subject 

The above-mentioned rights and the manner of their implementation may, in justified cases, be subject to restrictions. Such a situation will take place when this restriction results from obligations specified in legal provisions to complying with which we are obliged. In this case, we will provide you with relevant information along with the justification for our decision.

Information on obligation to submit personal data

Providing some personal data is necessary for the proper provision of the Service. By applying the principle of minimization, we do not collect more data than necessary. You will receive appropriate information each time the provision of additional personal data is necessary to achieve a specific purpose.

Failure to provide the required information may result in the restriction or termination of the Service.

Information on automated personal data processing

The Application is an IT system in which data processing procedures are carried out in an automated manner. However, this processing is not connected with the profiling process in a way that could cause negative legal, financial or other consequences for the User.

Information on profiling of personal data

In order to adapt the offer, improve the features and functionality of the Application, we collect and process information in reference to the manner in which our Users use the Service. The information is also used for statistical and analytical purposes and can be used for automatic processes of adjusting the offer.

Information on the location of personal data processing

The Application’s ICT infrastructure, including servers on which we store the Application Users’ personal data, are located within the European Economic Area.

Information on the transfer of personal data outside the European Economic Area

As a rule, we do not transfer personal data outside the European Economic Area.

However, for technical and technological reasons, in justified cases, we may use services supporting the functioning of the Application and Program or the operation of our company offered by suppliers from outside the European Economic Area.

More detailed information on this subject can be found in the relevant document Information Clause

Rules for amendments and updates

According to the needs and applicable privacy protection rules, we can amend, supplement and adapt the Privacy Policy at any time.

We will inform about any changes by posting relevant information on the website, and in the event of significant changes, we can also send separate notifications to the provided e-mail address or post a message in the User’s Account.

The Privacy Policy does not limit any rights of Users in accordance with the General Terms of Use and the provisions of law.

This document applies from 25/05/2018.

The update of the document is valid on UK market from 26/05/2021.