Privacy Policy

General information

By using the services of („Website””), you can provide APN Promise your identity data.

APN Promise and the APN Promise Group, which includes affiliates and subsidiaries of APN Promise respects the right to the privacy of the Users of their services, in particular, ensures the protection of their personal data and applies appropriate technological and legislative solutions preventing interference with Users’ privacy by the third party.

All activities related to the collection and processing of all data are aimed at guaranteeing the User a sense of complete security at a level appropriate to applicable law, including Regulation (EU) 2016/679 of the European Parliament and ot 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 (General Data Protection Regulation – GDPR)

Please be advised that the Service may also include external links enabling direct access to other websites (eg Facebook , LinkedIn, YouTube). Each of the suppliers defines the rules of using cookies in their privacy policy, therefore we have no influence on the privacy policy of the providers and their use of Cookies.

For security reasons, we recommend that before You use the resources offered by other websites, read the document regarding the privacy policy, if they have been made available, or in the absence of them contacted by the administrator of the site or service in order to obtain information in this subject.

This privacy policy will tell you:

  • why we are able to process your information
  • what purpose we are processing it for
  • whether you have to provide it to us
  • how long we store it for
  • whether there are other recipients of your personal information
  • what rights You have


The operator of and at the same time controller of personal data (unless otherwise stated) is A.P.N. Promise S.A. (Domaniewska 44A, 02-672 Warsaw), entered into the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under number 0000375933, Tax Identification Number: 5210088682, share capital PLN 1 011 060.60 (paid up in full).

As part of particular services of the Website, it happens that the information about you is also passed to Partners or third parties with whom APN Promise cooperates directly or indirectly, primarily in order to provide you with services at the highest level.

Data Protection Officer (DPO)

In order to ensure the security of data collected by us and the necessity of constant monitoring of their processing, we have appointed a data protection officer for the whole APN Promise Group.

You can contact the appointed DPO in all matters regarding data processing and in order to execute your rights to the processing

Address: APN Promise , Data Protection Officer, Domaniewska 44A, 02-672 Warsaw

What data are we processing?

We process data that you provide or leave as part of the use of individual Website services. These are data that you provide as part of the shared forms, as well as data that you leave as part of navigating the Website, i.e. data you leave in the Cookies or those you provide to us during contact.

We also store http queries addressed to the server. The browsed resources are identified by URL addresses and concern, among others, public IP address of the terminal device from which the query came, time of arrival of the query, number of data sent by the server, URL of the page previously visited by the User (link referer) – when the Website was accessed via an external reference, information about errors that occurred during execution of the http transaction.

Purposes, legal basis, period for whith data will be stored

The purpose of the processing

Legal basis

Period for whith data will be stored

1. Registration and participation in the event.

By using the registration form, you can register your participation in an organized or promoted event. The collected personal data will be processed in order to enable you to participate.

article 6(1)(b) of the GDPR

For the period necessary to achieve the purpose of processing.

2. Conclusion and performance of the contract.

You can use the services we provide, including using the Website. The collected data will be processed in order to cooperate and provide the service under certain conditions.

article 6(1)(b) of the GDPR

For the duration of the negotiations or provision of the service.

3. Contact

You can contact us including using the shared contact forms. The collected data will be processed to make contact, including to respond to your request.

article 6(1)(b) of the GDPR

For the period necessary to achieve the purpose of processing.

4. Publishing comments on the blog.


You can comment on the blog entry published by us on the Website. The collected data will be processed in order to implement the publication of the comment.

article 6(1)(b) of the GDPR

For a period necessary to complete the purpose of processing, no longer than to delete the comment.

5. Recruitment

You can send us your application (CV). The collected personal data will be processed for recruitment purposes, or in case of additional consent also for the purpose of future recruitment or sending information about recruitments.

article 6(1)(a-b) of the GDPR

For a period necessary to complete the purpose of processing, in the case of additional consent, no longer than until the consent is withdrawn.

6. Sending commercial information


If We have your prior consent, we can send you commercial information using an email or phone number.

article 6(1)(a) of the GDPR

For the period necessary to achieve the purpose of processing, however, not longer than until you withdraw your consent.

7. Marketing


As regards the promotion of our activities, we may send you or provide information on our activities on the website (web push).

article 6(1)(f) of the GDPR

Until the objection to processing has been filed.

8. Legal obligation


Sometimes we are required to process your personal information by law or the processing of your personal information is necessary for the establishment, exercise or defence of legal claims or whenever courts are acting in their judicial capacity.

article 6(1)(c,f) of the GDPR

For the period necessary to fulfill legal obligation or over the limitation period of potential claims

9. Safety and security


We can use your personal information to help provide safe and secure environments for our services.

article 6(1)(f) of the GDPR

Until an effective opposition to processing has been reported.

Is there an obligation to provide data?

Providing any personal data on the Website is completely voluntary, however, it may be necessary to perform specific services or requests of the User, eg in the area of contact, conclusion of a contract, performance of the data subject’s rights or participation in an event or competition.

The recipients of the personal data

We use data processors who who provide elements of services for us. We have contracts in place with our data processors. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will not share your personal information with any organisation apart from us. They will hold it securely and retain it for the period we instruct.
In some circumstances we are legally obliged to share information. For example under a court order or where we cooperate with other European supervisory authorities in handling complaints or investigations. We might also share information with other regulatory bodies in order to further their, or our, objectives. In any scenario, we’ll satisfy ourselves that we have a lawful basis on which to share the information and document our decision making and satisfy ourselves we have a legal basis on which to share the information.

Your data protection rights

Your personal data will be processed for the purposes of providing proper service and, if you submit such a statement, in order to: send you messages, conduct direct marketing, in particular for the purpose of sending commercial information. Remember that you can contact us at any time to obtain information about the use of your personal data and you have rights:

Right of access

You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.

Right to rectification

You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

Right to erasure

You have the right to ask us to erase your personal information in certain circumstances. You can ask us to delete data about you and, in some circumstances, We must then do so. This is known as the right to erasure. You may sometimes hear it called the ‘right to be forgotten’. You should contact us and let us know what you want erased. You don’t have to ask a specific person – you can contact any part of our organisation with your request. A request can be verbal or in writing. We recommend you follow up any verbal request in writing because this will allow you to explain your concern, give evidence and state your desired solution.

We Can refuse to erase your data in the following circumstances:
– when we are legally obliged to keep hold of your data
– when keeping your data is necessary for establishing, exercising or defending legal claims.

Right to restriction of processing

You have the right to ask us to restrict the processing of your information in certain circumstances ex. a challenge you have made to the accuracy of your data, or an objection you have made to the use of your data.

Right to object to processing

You have the right to object to the processing (use) of your personal data in some circumstances. If we agrees to your objection, we must stop using your data for that purpose unless we can give strong and legitimate reasons to continue using your data despite your objections.

You have an absolute right to object to us using your data for direct marketing – in other words, trying to sell things to you. This means it must stop using the data if you object.

Right to data portability

This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

Right to withdraw consent

If your data is processed on the basis of consent, You can use the right to withdraw it at any time – remember that this withdrawal does not affect the compliance of the processing before it is made.

Right to lodge a complaint with a supervisory authority

If You consider that the processing of your data infringes GDPR without prejudice to any other administrative or judicial remedy, You have the right to lodge a complaint with a supervisory authority in particular in the Member State (EU) of Yours habitual residence, place of work or place of the alleged infringement.If You consider that the processing of your data infringes GDPR without prejudice to any other administrative or judicial remedy, You have the right to lodge a complaint with a supervisory authority in particular in the Member State (EU) of Yours habitual residence, place of work or place of the alleged infringement.

Execution of your rights

You can request the execution of your rights in oral or written form. If you give us your request orally, we recommend that you also send it in writing or via email – in order to leave a clear evidence of your correspondence. This will also provide us with confirmation of your position or requests and will allow us to respond to your requests and in accordance with the content of your expectations as soon as possible.

You are not required to pay any charge for exercising your rights.

We can also refuse your request if it is ‘manifestly unfounded or excessive’. In any case w‘ll need to tell you and justify our decision. We should also let you know about your right to complain to the supervisory authority, or through the courts.

We have one month to respond to your request. In certain circumstances it may need extra time to consider your request and can take up to an extra time. If we are going to do this, we’ll let you know within one month that we need more time and why.

We might need you to prove your identity. However, we‘ll only ask you for just enough information to be sure you are the person whose data it holds. If we do this, the one-month time period to respond to your request begins from when we receive this additional information.

There are many ways You can contact us, including by phone, email and post:


The Website uses cookies that are text files, which are stored on the User’s device. Cookies typically contain the name of the website from which time store them on a terminal device and a unique number.

Cookie files are not to collect any data about the user but to set his personal preferences. For us, cookies are to better understand traffic on our website, for further improvements, updates and maintenance.

You can decide about how cookies are stored on your device. To do this, change the settings/preferences in the web browser. The default settings for popular browsers usually allow you to store Cookies. By using this Website you expressly consent to the use of cookies in accordance with the browser settings.

We use Cookies for the following purposes:

  • providing Website services
  • facilitate the use of the Website while browsing
  • subsequent identification in the event of the Service being re-connected to the device on which it was saved
  • creating statistics that help us to understand how Website Users use websites, which allows improving their structure and content
  • the adaptation of web content to the specific preferences of the service and optimize the use of websites tailored to the individual needs of the user
  • exchange of information with Partners to mediate in the provision of their services

What Cookies do we use?

We use the following Cookies:

  • „session” – which are stored in the User’s device until they leave the website or turn off the web browser
  • „permanently” – stored on the User’s device for a definite period of time in Cookie parameters or until they are deleted by the User
  • „performance” – enabling the collection of information on the use of Website pages
  • „finctionality” – enables us to personalise our content for you, greet you by name and remember your preferences (for example, your choice of language or region)
  • „own” – posted by us
  • „external” – coming from an external site than the Website