Protecting and defending user privacy is paramount to GLOSS EDUCATION LLC and it is built into our core DNA. Therefore, we strive towards maintaining a high level of data security and guarantee it to our Users on www.gloss.education. As the Data Controller, GLOSS EDUCATION LLC ensures the security measures of personal data provided by the Users.
Another objective of the Data Controller is to properly inform the Users on the rights and obligations related to the personal data processing, in particular with regard to the the content of the provisions on the protection of personal data set out in 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 the repeal of Directive 95/46/EC (General Data Protection Regulation hereinafter referred to as “GDPR”). We believe that great privacy rests on great security, so in this document the Controller informs the Users of the legal basis for the processing of personal data provided by the Users of www.gloss.education website (hereinafter the "Site"), the way we collect your data, process and protect it, as well as the rights of the Users.
The User is any natural person who is a subject to personal data and who uses www.gloss.education or the electronic services available via the Site.
The Controller of personal data provided by the Users of www.gloss.education shall be GLOSS EDUCATION LLC with its legal address at 28-02.17 Zygmunta Vogla street, Warsaw, 02-963, (hereinafter referred to as the "Controller").

I. USER AGREEMENT
Using www.gloss.education website means that the User agrees that the Controller collects and uses personal data in accordance with this privacy policy. The Controller processes the Site User’s personal data on the basis of their consent, and in some cases described in this document, within the legitimate interests of the Controller. The User has the right to withhold the previously expressed consent at any time. The withdrawal of the agreement does not affect the lawfulness of the data processing that was carried out on the basis of the agreement prior to the withdrawal. If the User continues using the Site in case of the change in this privacy policy, he will be considered to accept the current terms of the privacy policy.

II. PERSONAL DATA WE COLLECT FROM YOU
1. How personal data is obtained.
The Controller can process the personal data directly from the User via the Site, using the functionality and the means of communication available on the Site, as well as by sending messages to the Controller. Providing personal data by the User is voluntary.
2. What personal data is processed.

Full name,
E-mail address,
Phone number,
The content of the message.

III. PURPOSES OF PERSONAL DATA PROCESSING
The way we process user data depends on how the User uses the Site and the available functionality. The Controller processes the User’s personal data for the following purposes:

Communication with the User.

The Controller uses the personal data to personalise the communication with the User. The information provided to the user has to do with the products and services offered, personal data security, updates and reminders as well as special offers from the Controller and/or the partners. Communication with the User also covers User’s support. Personal data can be used to assist the User and respond to their complaints or claims.

Providing digital commercial offers to the User.

The purpose of collecting User's personal data provided by the User on the Site is marketing communication conducted by the Controller as a part of their work, in particular by providing commercial offers to the User digitally.

Providing commercial offers to the User via telephone call.

The purpose of collecting User's personal data provided by the User is marketing communication conducted by the Controller as a part of their work, in particular by providing commercial offers to the User via telephone call or via messengers.

Allowing the User to post comments or leave feedback.

The Controller uses the personal data to enable the User to comment/leave feedback on the activity, services or products of the Controller or those who cooperate with the Controller.
Apart from this, the Controller may also process User’s personal data, obtained through the Site, for the following purposes:

in order to enter into and implement a possible agreement between the User and the Controller and to serve the User as a customer of the Controller in accordance with Article 6(1) lit.b) of the GDPR;
in order to make financial settlements with the User, as Controller’s customer, to implement a potential agreement concluded between the parties, as well as for the submission of potential claims of the User, who is a customer, within the legitimate interest of the Controller in accordance with Article 6 para. 1 lit. f) GDPR and fulfilling the Administrator's legal obligations to tax authorities under separate provisions in accordance with Art. 6 para. 1 lit. c) GDPR;
in order to carry out marketing activity within Data Controller’s legitimate interests in accordance with Article 6 para. 1 lit. f) GDPR and also in accordance with the expression of will in relation to marketing communications submitted to the Controller. The consent given in the context of marketing communications (e.g. to send commercial information digitally or via telephone for direct marketing purposes) may be withdrawn at any time, which does not affect the lawfulness of the personal data processing that has been carried out on the basis of the agreement prior to its withdrawal;
in order to implement the Controller's legal obligations to the User as stated in GDPR, Art. 6 para. 1 lit. c) GDPR.

IV.THIRD PARTIES PROCESSING YOUR PERSONAL DATA
The Controller will not disclose your personal data with any third party.

V. YOUR PRIVACY RIGHTS

User Rights.

At each stage of the personal data processing, the User is granted a number of rights enabling them to access their personal data, to check the correctness of the data processing, to rectify it, and to have the right to object to its processing as well as to request to delete data and restrict the processing or transfer of the data. If the User wishes to exercise their rights as a data subject, they may contact the Controller at the following contact addresses: GLOSS EDUCATION LLC, legal address: 28-02.17 Zygmunta Vogla street, Warsaw, 02-963; info@gloss.education.

The right to file a complaint to the supervisory authority.

The User whose personal data is processed by the Controller shall have the right to file a complaint with the supervisory authority competent in the matters of personal data protection (the President of the Personal Data Protection Office).

VI. COOKIES

The Controller informs that while using the Site, brief text information, called cookies, is stored on the User's end device. Cookies contain information, such as: the User's IP address, the name of the website where they originate, the time they are stored on the User's end device, saving parameters and statistics, as well as a unique number. Cookies are sent to the website server via the web browser installed on the User's end device.

Cookies are used on the Site in order to:

maintain the technical correctness and continuity of the session between the Site server and the User's end device;
optimise the use of the Site pages by the User and customise the way they are displayed on the User's end device;
ensure the security of using the Site;
collect statistics on the visits to the Site's pages to help improve their structure and content;
display advertising content on the end device of the User that is best adapted to their preferences.

The Controller informs that:

web browsers allow the installation of cookies on the User's end device by default. Each User of the Site can change the "cookies" settings in the web browser at any time, so that the browser automatically blocks the use of cookies or informs the User each time a cookie is placed on their end device. More information on the options and methods of processing cookies is available in the settings of the web browser used by the Site User.
Restricting the use of cookies by the User may have an adverse effect on the accuracy and continuity of the provision of services on the Site. Cookies installed on the end device of the User may be used by advertisers or business partners cooperating with the Controller. Cookies may be regarded as personal data only in relation to other personal identifying data provided to the Controller by the User while using the Site. Only the Controller has access to the cookies processed by the server of the Site. If the User does not agree to store and receive the data in cookies, they can change settings in their web browser and disable cookies.

VII. OTHER IMPORTANT INFORMATION

Protecting the personal data security

The Controller takes relevant measures to ensure the security of the User's personal data. The safe use of the Site is ensured by the systems and procedures used to protect against the access and disclosure of data to unauthorized individuals. In addition, the systems and processes used by the Controller are regularly monitored to identify possible threats. Personal data received by the Controller is stored in the computer systems with strictly limited access.

Personal data storage

The data retention period depends on the purposes of data processing by the Data Controller. The Controller shall store personal data for the period necessary to reach the particular purposes of their business activities. In each of the aforementioned cases, once the necessary period of processing has expired, the data may be processed only with the purpose to claim the established relationship between the parties until the final settlement of these claims is in court.

Changes to the Privacy Policy

In order to keep the information in this Privacy Policy up to date and in accordance with the legislation, this Privacy Policy may be amended. If the Privacy Policy content changes, the date indicated at the end of its text will be updated. The Controller recommends the Users to review the provisions of the Privacy Policy on a regular basis in order to obtain the information on the methods of personal data security.

Contact information

If you have any questions about how we process our personal data or want to request to invoke your rights concerning this Privacy Policy, you may contact the Data Controller at: GLOSS EDUCATION LLC, 28-02.17 Zygmunta Vogla street, Warsaw, 02-963, or using the following contact details: info@gloss.education.
Alternatively, you may contact us by postal address 28-02.17 Zygmunta Vogla street, Warsaw, 02-963.
This document was last updated on 3 March 2023.