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Privacy policy

This subpage defines the rules of conduct for the processing of personal data of users of the Service available at https://competencegame.com and http://hrpanel.competencegame.com, as well as others contacting Salander Sp. z o.o. with its registered office in Warsaw, Puławska 39/2, 02-508 Warsaw, e-mail in the domains @competencegame.com and @experiencecorner.com and receiving the newsletter.

Read the policy - you will find out who handles your data, why and on what basis, and what your rights are. If you do not accept the content of this document, stop using the Service.

Each person using the Service remains anonymous until he or she decides to reveal his or her identity. As Administrators of your personal data, we assure you that we do not process any data without your consent, where consent means checking a box, clicking on a confirmation link and any other statement or behavior that, in the given context, clearly indicates that you have accepted the proposed processing. We process personal data of different types and for different purposes - always in accordance with the law.

Concerned about the security of your data, I select technical measures to ensure their protection against, among other things, access to unauthorized persons or processing in violation of the law.

     1.Definitions

    1. Service - this website
    2. Administrator - Salander Sp. z o.o. with its registered office in Warsaw, 39/2 Pulawska Street, 02-508 Warsaw, Poland
    3. User - a natural person using the Site
    4. Client - natural or legal person using the Administrator's services and/or products.
    5. Newsletter - a service allowing the User to receive free information from the Administrator to the e-mail address provided.
  2. General provisions
    1. The User's personal data shall be processed in accordance with the Personal Data Protection Act and the Act on Rendering Electronic Services, as well as GDPR.
    2. The Administrator is aware of the risks arising from the processing of personal data on the Internet, and therefore declares that it makes efforts to ensure an adequate level of protection of privacy and security of Users.
    3. The Administrator's website and services are not intended for or directed to children under the age of 18, and the Administrator does not knowingly collect information regarding children under the age of 18.
    4. The Administrator undertakes to ensure that personnel authorized to process personal data are required to do so in accordance with this Policy and the Administrator's internal procedures and standards applicable to legal advisors.
  3. Scope of collected data
    1. The personal data of the User collected by the Administrator are used to contact the User and to market and distribute the Newsletter.
    2. The Administrator processes the following personal data of the User: name and surname or company name, e-mail address.
    3. rovision of personal data referred to in para. 2 is necessary for the Administrator to provide the activities indicated in point 1.
    4. The Administrator shall make it possible to use the information provided free of charge through the Service in the form of a Newsletter. The User may unsubscribe from receiving the Newsletter at any time.
    5. In the case of a visit to the site, during which the User does not fill out forms, statistical data is collected, such as pages and subpages visited and the amount of time spent on each of them, date and time of visit, operating system and web browser, location. The legal basis is the legitimate interest of the Administrator to improve the structure of the site and services.
    6. Data may be processed for marketing purposes. These are activity data - search history, clicks on the site, etc. The Administrator does not profile the data, and the legal basis for processing this data is the Administrator's legitimate interest in marketing the site and services.
    7. In the case of filling out the contact form, the User's email address is processed, and the legal basis is the consent of the subject being processed.
    8. In the case of filling out the contact form, only the data provided by the user will be processed - by default the email address, name, phone number and company name. The content of the form is not evaluated by the computer system.
    9. In the case of becoming a customer, "invoice" data will be processed - name, company, address and VAT number. The basis for processing is the need for the Administrator to comply with legal and tax obligations. The Administrator also reserves the right to process this data in order to assert claims due to him.
    10. In the case of Users expressing a desire to become Customers, their data will be stored for a period of time to enable the conclusion of a contract in accordance with the terms and conditions previously proposed by the Administrator. The basis for processing is the legitimate interest of the Administrator.
    11. The Administrator reserves the right to process the data of persons for the purpose of creating records and registers of persons resulting from the regulations on the protection of personal data, as well as for archival purposes and for the purpose of proving facts of evidentiary and legal significance.
  4. Method of data processing
    1. The use of the Website is voluntary.
    2. Personal data of Users and Customers will not be transferred to third parties for marketing purposes.
    3. The Administrator shall transfer personal data in order to perform the contract to the Administrator's employees and associates.
    4. The Administrator shall transfer personal data if requested by authorized state authorities - in particular, the Police and prosecutor's office organizational units or the Presidents of UODO, UKE, UOKiK.
    5. The Administrator transfers data to the following third parties:
      1. entities that process data outside the territory of the European Union
        • Google - only non-identifying a specific person data analytically, Google Analytics to analyze website statistics
        • Facebook - social plugins, commenting system, pixel to support measuring the effectiveness and optimization of advertising
    6. The Administrator informs that the entities listed in point 4 a) are based outside the European Union, and are therefore treated as so-called third countries under the provisions of the GDPR. 

Google Inc. (headquarters address: 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA) - the data collected prevents the identification of a specific person, and more information about the tool's privacy standards is available at the link www.google.com/intl/pl/policies/privacy/partners/. In addition, using the following link: https://tools.google.com/dlpage/gaoptout it is possible to disable activity measured by Google Analytics.

Facebook (headquarters address: Facebook Inc., 1601 S. California Ave. Palo Alto, CA 94304, USA). As a rule, the data collected prevent identification of a specific person, and more information about the tool's privacy standards is available at the link https://www.facebook.com/about/privacyshield.

The above companies guarantee compliance with data protection standards analogous to the Regulation, and the Administrator's use of their technology in processing personal data is lawful.

    1. The Administrator informs that due to the failure to meet the prerequisites of obligatoriness, it has not appointed a Data Protection Officer. The Administrator is not a public authority or entity, and its main activity does not consist of processing operations that, due to their nature, scope or purposes, require regular and systematic monitoring of data subjects on a large scale. In addition, the main activity of the Administrator does not involve large-scale processing of special categories of personal data, and personal data relating to criminal convictions and violations of the law. Thus, the method of contact on personal data issues is the Administrator's email address.
    2. The Administrator, in accordance with applicable laws, does not process personal data indefinitely, but only for the time necessary to achieve the following purposes:
      • offer - for a period of 3 years
      • establishment and performance of the contract - for a period resulting from the statute of limitations for claims under the contract
      • issuing invoices - for a period of 6 years
      • for other purposes mentioned in §3 of this policy - for a period of 2 years or until withdrawal of consent
      • sending of newsletters - until deletion or discontinuation of the Newsletter service by the Administrator.

The period of data storage will not be shorter than it results from the applicable laws (special laws), i.e.: the Accounting Act, the Tax Ordinance Act, among others.

Periods in years are counted by the Administrator from the end of the year in which he began processing personal data, in order to improve the process of deletion or destruction of personal data. Counting the period for each event separately would be a technical difficulty, hence establishing a single date for the deletion or destruction of personal data allows for more efficient management of the process.

After this period, personal data will be irreversibly deleted or destroyed.

  1. Obligations and rights of the User
    1. The User shall be obliged to use the Website in a manner consistent with the law and good morals, taking into account respect for personal property and intellectual property rights of third parties.
    2. The user is obliged to enter data consistent with the facts. The Administrator shall not be liable for any undesirable consequences and inaccuracies resulting from the provision of data inconsistent with the facts.
    3. All content posted on the Service enjoys copyright protection and is the property of the Administrator or other persons clearly identified as the author next to the content. The User shall bear full responsibility for any damage caused to the Administrator or other person identified as the author of the content, resulting from the use of any content of the Service without the consent of the Administrator or the author.
    4. Any use by anyone, without the express consent of the Administrator, of any of the elements comprising the content and contents of the Service shall constitute a violation of copyright law.
    5. The Administrator shall ensure that the User realizes the rights indicated below by contacting the Administrator's e-mail address no later than 30 days after receiving the request (if, due to the complicated nature of the request or the number of requests - it will not be able to fulfill the request within 30 days, it will fulfill it within the next month informing the User in advance of the intended extension of the deadline):
      1. The right to withdraw consent - withdrawal of consent, however, may prevent further use of services that the Administrator can legally provide only with consent. In addition, withdrawal of consent does not render the processing of personal data unlawful until the moment of withdrawal.
      2. The right to object to the use of data - if the Administrator processes data based on a legitimate interest, the User may object to its use. If the objection proves to be legitimate and the Administrator has no other legal basis for processing the data - it will delete the objected data.
      3. The right to erasure of data ("right to be forgotten") - the Administrator will, upon request, erase data in the event of withdrawal of consent, raising a legitimate objection to use for marketing or statistical purposes, unlawful processing, or when they are no longer necessary for the purposes for which they were collected or for which they were processed. The Administrator stipulates that it may retain certain personal data to the extent necessary for backup or for the purposes of establishing, asserting or defending claims and relations with state authorities.
      4. The right to restrict data processing - in case you question the accuracy of the data and the lawfulness or necessity of its processing and object.e. Right of access to data - The Administrator undertakes to confirm the processing of personal data, if any. In this case, the User shall be able to obtain a copy of the data and access it, and obtain the information contained herein and other requested information.
      5. Right of access to data - The Administrator undertakes to confirm the processing of personal data, if any. In such case, the User shall be able to obtain a copy of and access the data and obtain the information contained in this Policy and other requested information.
      6. Right to rectification of data - the Administrator, at the request of the User or Customer, undertakes to rectify data (for incorrect data) and to complete data (for incomplete data).
      7. Right to data portability - at the request of the User or Customer, the Administrator will send in the form of a file in pdf or other established format the personal data to the requesting party or directly to another Administrator designated by the User or Customer.
      8. In addition, the User has the right to file a complaint with the President of the Office for Personal Data Protection.

The Administrator indicates that it respects personal data protection rights and strives to exercise them to the fullest extent possible. At the same time, the rights in question are not absolute, so it is possible to lawfully refuse to exercise them - the Administrator ensures that a possible refusal is preceded by a necessary analysis of the issue and is made only if the refusal is necessary due to grounds that override the interests of the User.

  1. Cookies
    1. The Administrator's website uses "cookies", which the user agrees to by acccpeting a pop-up when entering the site. These are short text information, stored on the user's computer, phone, tablet or other device. They can be read by the Administrator, as well as by systems belonging to other entities whose services it uses (e.g. Facebook, Google). Cookies usually contain the name of the website from which they come, the time they are stored on the end device and a unique number. For more information on cookies, please visit www.allaboutcookies.org.
    2. Cookies used on the site do not store personal data or other information collected from the User. The site uses a cookie to identify your browser session, which allows you to use the features of the site. The use of "cookies" techniques does not allow the collection of any personal and address data of the User or any confidential information from the User's computer.
    3. Cookies are used for the following purposes: maintaining the security of the service and preventing fraud, facilitating site performance, recording visits for marketing and statistical purposes, using social features, supporting website personalization (e.g., saving language settings). Cookies may also be used and placed by partners cooperating with the Administrator - they are then subject to the cookie policies or privacy policies of the entities placing them.

In case of playback on the Website of materials posted on Spotify or Youtube, the Administrator informs about the possibility of installing cookies of these services.In addition, the Website has social network cookies - they allow you to share content or comment on it (for example, in accordance with these rules - https://developers.facebook.com/docs/web).When using such services of the Website, the User's browser will establish a direct connection with the servers of these services.The Administrator feels obliged to inform that information about commenting or sharing, depending on privacy settings, will appear to persons added as contacts or to all visitors to the User's profile on a given service.

The scope and purpose of data collection and the way to contact and exercise rights or make settings to ensure privacy are described in the privacy policies of individual service providers (links in par. 4, item 6 of this Policy).

    1. By default, the web browser allows the use of cookies on the device. The Administrator informs that you can change the settings in your web browser - completely block the automatic handling of cookies or request notification each time cookies are placed on your device.

If using Google Chrome, instructions can be found here - https://support.google.com/chrome/answer/95647?hl=en.

If using Mozilla Firefox, instructions can be found here - https://support.mozilla.org/en-US/kb/cookies-information-websites-store-on-your-computer.

If using Safari, the instructions can be found here - https://support.apple.com/en-gb/guide/safari/sfri11471/mac.

If using Microsoft Edge, the instructions can be found here - https://docs.microsoft.com/en-us/microsoft-edge/edgehtml/index..

If using Internet Explorer, the Administrator suggests changing the tool to any of the above, and in addition, the instructions can be found here - https://support.microsoft.com/en-US/topic/168dab11-0753-043d-7c16-ede5947fc64d..

If using Windows Phone, instructions can be found here - https://support.microsoft.com/en-us/windows/windows-phone-7-3ebc303c-59c0-d367-3995-f258b184fabb.

    1. The administrator feels obliged to warn that disabling or limiting the use of cookies may cause difficulties in using the website and limit its functionality.
  2. Final provisions
    1. The Administrator shall apply technical and organizational measures to ensure the protection of the processed personal data appropriate to the risks and categories of data protected, and in particular shall protect the data against unauthorized access, acquisition by an unauthorized person, processing in violation of applicable laws, and alteration, loss, damage or destruction.
    2. The Administrator shall provide technical means to prevent unauthorized persons from acquiring and modifying personal data sent electronically.
    3. In matters not covered by this Privacy Policy, the relevant provisions of Polish and European law shall apply. On this website there may be additional provisions on users' privacy regulating specific issues - they take precedence over this Policy.(
    4. This document may be updated by the Administrator from time to time by publishing new versions on the Website. In addition, the Administrator may notify changes to this Privacy Policy by email. Your continued use of the Service or your continued provision of personal information to the Administrator will be subject to the terms of the Privacy Policy in effect at that time.