Privacy Policy

1. Basic information

This version of the Jewish Czulent Association’s Privacy Policy is effective as of September 1, 2022. It represents an updated version of the May 25, 2018 document effective until September 1, 2022.

The personal data administrator is the Jewish Czulent Association with its headquaters in Cracow, ul. Sebastiana 36/1, 31-051 Kraków. NIP: 6762300850; KRS: 0000226390; REGON: 120081681.

The purpose of this Privacy Policy is to compile the most important rules regarding the processing of personal data by the Jewish Czulent Association. In it, we introduce the key groups of people whose data we process, describe for what purposes and on what legal basis we do so. We also inform you of the rights of those whose data we process.

Concerned about the security of the data entrusted to us, we have developed internal procedures and recommendations to prevent the release of data to unauthorized persons. We control their execution and constantly check their compliance with the relevant legal acts – the Data Protection Act, the Act on the Provision of Electronic Services, as well as applicable implementing acts and Community legislation, such as the General Data Protection Regulation of April 27, 2016 (RODO).

For the purpose of easier perception of the Privacy Policy, we have replaced the term “Data Owner” with “You”, “Administrator” with “We”, “Association”, ” Czulent Jewish Association”. The term “RODO” means Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016. on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC. The term “CRM” (from Customer Relationship Management) refers to an IT program used by the Czulent Jewish Association for relationship management.

2 Whose data do we process and on what terms?

Data of users of czulent.pl, library.czulent.pl, czulent.org

Through our websites, we collect data only to the extent necessary to manage these websites, ensure the smooth operation of the functionalities offered within them and analyze the effectiveness of communications.

During the use of the Association’s services, the so-called “data” are automatically recorded: System logs – anonymous information such as the time of the user’s visit to the site, the user’s IP address, URL, browser type, data on downloaded files, etc. The data collected is not associated with specific people browsing our pages. Anyone can use them anonymously – we do not require registration. We do not solicit identification unless it is necessary due to the nature of the action being taken, i.e., for example, when making a donation, renewing a book, etc.

We keep statistical data on website usage until the end of the Association’s operations based on our legitimate interest.

Data of users of www.zglosantysemityzm.pl

As part of the functionality of the www.zglos-antysemityzm.pl website, you can provide us with data on incidents that you believe are manifestations of anti-semitism. The data contained in the application forms is immediately encrypted to protect them from unauthorized access.

The data contained in incident reports submitted using www.zglosantysemityzm.pl may be transferred by us to the processors providing us with servers, and only to that extent processed by them. Such processing entity (processor) is the Jewish Religious Community in Warsaw Twarda 6, 00-105 Warsaw.

Submitting the form with the application requires your email address. This address is processed by us for possible verification of your application and further correspondence with you. If your report concerns an incident that we have already confirmed, we will not contact you unless you are the victim of the incident and ask us to assist you in asserting your rights before state authorities.

Once the incident is confirmed, the data contained in the report is anonymized by us and processed as such for statistical purposes. Original submissions are kept for a period of 2 years, after which they will be irreversibly deleted from our servers.

If you have asked us to assist you in asserting your rights before state authorities, your personal data and the data of third parties that you have provided to us or that we have collected independently from publicly available sources will be processed by us for a period of 2 years from the decision to initiate proceedings, and in the case of proceedings before a competent authority, for a period of 2 years from the final conclusion of the proceedings.

The legal basis for processing your data contained in the incident report is your consent (Article 6(1)(a) and Article 9(2)(a) of the DPA). The legal basis for the processing of third-party data contained in the application is the protection of your and the administrator’s legitimate interests (Article 6(1)(f) and Article 9(2)(f) RODO).

In cases where we decide to file a report of a suspected crime in an incident on our own behalf, the data contained in the report may also be processed by us after you have possibly withdrawn your consent to its processing, pursuant to Article 6 (1)(f) RODO with reference to article 304 Code of Criminal Procedure.

Data of people using the ReMU Jewish Library

Support for people using the Library is based on the Mak+ IT system (for more information:data security in the Mak+ system). The Association processes the data of persons using the ReMU Jewish Library in order to ensure the use of the library’s resources, for statistical purposes and in connection with the return of borrowed library resources or their equivalent. The basis for data processing is the Law of January 27, 1997 on libraries and the Law of June 29, 1995. about public statistics. Your data will be entrusted to the library system provider for proper maintenance of the MAK+ system and shared, if you agree, with other libraries and the Book Institute. The entrustment of personal data, regulates the principles of personal data processing, in particular, the responsibilities of the parties and the scope and purpose for which the Book Institute (the institute that created and administers the MAK+ library system) may process personal data. The Book Institute does not become the administrator of personal data collected in the library, it is only a processor acting on behalf of and in accordance with the will of the Association.

You have the right to access the content of your data, to correct it, to lodge a reasoned objection to further processing, to portability, as well as the right to be forgotten and to lodge a complaint against the data processing rules with the data protection supervisory authority. Data will be processed only as long as it is necessary to carry out the statutory duties of the library under the terms of the Library’s regulations . Providing data is voluntary, however, it is necessary to use the library’s resources.

Data of those who support us with donationsDetails of those who support us with donations

Financial support of the Association is possible by making a donation by wire transfer to a bank account or through the PayU system that supports online payments in Polish banks and through payment cards.

In the case of a donation made to us by wire transfer to a bank account, we process personal information provided to us by the bank, namely: name, account number, donation amount, address. It is necessary for the performance of the contract and the fulfillment of the Association’s legal obligations (e.g., accounting regulations).

We process the additional information provided in the transfer title (e.g., email address) based on our legitimate interest to send a thank you for your support. For the same purpose, we also use the addresses from the bank transfers of those who donate to us. If you do not wish this form of contact from our side, please send your objection (e.g., stating “I ask that you do not send me thanks for your support by mail”) to: office@czulent.pl. We may also address correspondence to an address other than the one shown on the transfer or contact you by e-mail – in this case, too, please contact us or include your e-mail address in the title of the transfer.

In the case of a donation made through PayU, we ask for your name so that we know who we are contracting with (e.g., so that we can issue a certificate to deduct the donation from tax or return money paid in error), the amount of the donation, and the email address that is necessary for the CRM system to technically process the payment. This is necessary for the performance of the contract and the fulfillment of the Association’s legal obligations. Provision of data is voluntary, but necessary to make a donation. The email address is also used by us, based on legitimate interest, to send confirmation of the transfer and to thank you for your support. If you do not wish to be thanked, please send your objection to: office@czulent.pl. If your home address is also provided in the PayU system, we process it as part of our legitimate interest for statistical purposes.

It is also possible to make a donation through the wpłacam.ngo.pl system implemented at czulent.pl. Before you make a donation, please also read our Donation Regulations.

We process the data of people who support us with donations for 5 years from the end of the calendar year in which we recorded the last interaction with the person in the CRM system (e.g., receiving a donation, or participating in an event organized by us that requires registration).

Data of newsletter subscribers

On our Website, we use the newsletter service offered by FreshMail Sp. z o.o. (Al. 29 Listopada 155, 31-406 Kraków) to which company we entrust the processing of data for the purpose and to the extent necessary to perform FreshMail’s obligations arising from the implementation of the e-mail marketing service and activities accompanying this service.We process the names and e-mail addresses of subscribers to the Association’s newsletter in order to send information about the Association’s activities and issues related to the area of our activity.

The basis for data processing is the consent given, which can be revoked at any time. Provision of data is voluntary, but necessary to order mailings. We process your data until the end of the Association’s existence or until you withdraw your consent.

We process the data of former newsletter subscribers on the basis of our legitimate interest to manage the relationship for 2 years from the end of the calendar year in which we recorded the last interaction with the person in the CRM system (e.g., we received a donation, recorded an unsubscribe from the newsletter or participation in an event organized by us that requires registration). If you would like us to remove the information that you have ever subscribed to our newsletter in advance and stop contacting you altogether, please email us at office@czulent.pl

Media people’s data

The Czulent Jewish Association processes the data of journalists (also editors and publishers) obtained directly from them, from editors or from the Internet. The scope of data processed may include: name, email address, phone number, affiliation (including previous affiliations), editorial address, interaction and publication history. We process this data on the basis of our legitimate interest to inform you about the Association’s activities and relationship management.

We process data until the end of the Association’s activities. If you do not want to receive press releases from us, you can object to the processing of your data. If this is the case and if you have additional questions, please send an email to: office@czulent.pl.

Data of employees of CSR (Corporate Social Responsibility) departments or other persons representing companies and institutions with which we have relations

The Association processes data of employees of CSR or related departments obtained directly from them, from their employer or from the Internet. The scope of data processed may include: name, email address, phone number, affiliation (including previous ones), company address, history of interaction and cooperation. We process this data on the basis of our legitimate interest to encourage support for the Association’s activities and to manage the relationship.

We process the data until the end of the Association. If you do not want to receive information from us with cooperation proposals, you can object to the processing of your data. If this is the case, and if you have additional questions, please send an email to: office@czulent.pl

Data of people using non-public communication channels

We process the data of persons with whom we contact via e-mail (addresses in the domain czulent.pl), telephone, SMS or letter on the basis of legitimate interest, in order to handle the correspondence, for purposes arising from the content of the communication or to establish contact in the future. This data may include name, address, e-mail address, telephone number and any other information contained in the body of the message. Provision of this data is voluntary. We process data for archiving purposes and for relationship management until the end of the Association’s operations, except for data of a sensitive nature, which we delete or anonymize as soon as the case is closed. When writing or calling us, try not to give unnecessary data. If we need additional information, we will ask for it.

Data of persons communicating with the Association through social networking sites.

Facebook and Twitter are controllers of their users’ personal data and process it under their own terms of service. When you interact with us via Facebook or Twitter (liking/watching the page, joining a group administered by us, reacting to posts, shares/retweets, comments, private messages), the Association becomes the controller of your personal data in addition to Facebook or Twitter. We process data such as name/nick, image, public profile and other information provided in messages or comments until the end of the Association’s activities on the basis of our legitimate interest, in order to respond to comments and messages, maintain relationships with those interacting with us, and to analyze the effectiveness of communications.

Data of participants in events organized by the Czulent Jewish Association

When organizing events that require registration, as a rule, we ask for: name, email address, phone number, unless the nature of the event (such as training) will require the collection of other information. We process the data for the purpose of organizing the event, and the basis for the processing is the performance of tasks in the public interest resulting from the statute of the Czulent Jewish Association (art. 6.1.e. RODO).

After the event, we process participant data on the basis of our legitimate interest to manage the relationship, for 5 years from the end of the calendar year in which we recorded the last interaction with the person in the CRM system. If you would like us to remove them sooner, please email us at office@czulent.pl. For events organized with grantor funds that require us to keep records for a longer period of time, we will provide the appropriate information when you sign up for the event.

Dane uczestniczek i uczestników szkoleń i kursów

When we organize a contest, the scope of the information we will process is stated in the contest rules. Typically, we limit ourselves to collecting the e-mail address of the participants and the name and mailing address of the winners. We process the data for the purpose of adjudicating the competition and sending prizes, and the basis for the processing is the performance of tasks in the public interest resulting from the statute of the Czulent Jewish Association (Art. 6.1.e. RODO).

After the contest ends, we process participants’ data on the basis of our legitimate interest to manage the relationship for 5 years from the end of the calendar year in which we recorded the last interaction with the person in the CRM system. If you would like us to remove it sooner, please email us at: office@czulent.pl

Data of job candidates.

We process the data of job applicants/candidates on the basis of our entitlement under the provision of the law, namely Article 22 of the Labor Code, in order to carry out the recruitment procedure. We process this data until the respective recruitment process is completed.

In justified cases, we may ask you to include in your recruitment materials (resume and/or cover letter) your consent to process your data also in future recruitment processes, in order to send you job offers. The relevant information will then be included in the job advertisement. In this situation, your data will be processed until you revoke your consent, but no longer than 5 years from the end of the last recruitment in which you participated.

3. Statistics (Google Analytics)

Our Website uses Google Analytics, a web analytics service offered by Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, United States (“Google”).

Google analyzes the use of our website on our behalf. Among others, the following are used for this purpose cookie files described in section 9. The information collected by Google in connection with the use of our website (e.g. referring URL, pages visited, browser type, language settings, operating system, screen resolution) is transferred to a Google server in the USA, where it is stored and analyzed. Their results are made available to us in anonymous form. Your usage data is not linked to your full IP address in this process.

It is possible to withdraw consent to the use of web analytics at any time by downloading and installing the appropriate Google browser plug-in.

Further information about Google Analytics is available in the Google Analytics Terms of Service, the Google Analytics Privacy and Data Protection Guidelines, and the Google Privacy Policy.

4. Complaints

If you would like to exercise your rights regarding your personal information, or simply ask a question related to our Privacy Policy, please email us at: office@czulent.pl

You also have the right to file complaints on issues related to the problems regulated by our Privacy Policy.

Complaints can be submitted in writing, by registered mail to the Association’s address.

A properly submitted complaint should include at least the name of the submitter, his/her/their mailing address and the content and basis of the complaint. Providing the above data is the basis for processing the complaint. Complaints that do not meet the above requirement will not be considered.

Complaints will be considered within 14 days of receipt by the Association.

If you believe that your data is being processed illegally, you can also file a complaint with the supervisory authority – the President of the Office for Personal Data Protection.

5. Sharing data

The Jewish Czulant Association will only transfer your personal information:

entities that process data on our behalf, on our instructions and for the same purpose under an authorization or contract of entrustment of personal data processing (e.g. IT or accounting service of the Association).
entities authorized under applicable law (e.g., law enforcement agencies).

In addition, if you use traditional mail communication, we entrust your personal data to postal intermediaries (the Polish Post and other companies operating under postal law) for processing on the basis of entrustment agreements and service regulations.

Personal data collected in the framework of publicly financed projects may be made available for the purpose of monitoring, reporting and auditing of the implemented project, only to entities authorized to carry out the above activities or their representatives.

Your data is not subjected to automated decision-making, including profiling.

6. Data retention

The Association’s identifiable retention periods for personal data are described in Section 2 of this Privacy Policy.

In addition to the situations described in Section 2, we also reserve the right to process your data after termination of the Agreement or withdrawal of consent to the extent arising from the need to pursue possible claims in court or if national or EU regulations or international law oblige us to retain the data.

7. Your rights

You have the following rights regarding our processing of your personal data:

If you wish to access, correct, update or request deletion of your personal information, you can always do so by contacting us at any time: office@czulent.pl.

In addition, you can object to the processing of your personal data, ask us to restrict the processing of your personal data, or request a transfer of your personal data. And here, too, you can exercise these rights by contacting us office@czulent.pl.

Where we have collected and processed your personal data with your consent, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of processing that took place before such withdrawal, nor will it affect the processing of your personal data based on lawful grounds for processing other than consent.

You also have the right to lodge a complaint with the data protection supervisory authority if you consider that the processing of your personal data violates the law.

We respond to all requests we receive from individuals who wish to exercise their data protection rights in accordance with applicable data protection laws.

8 Data security

When processing your personal data, we use organizational and technical measures in accordance with the relevant legal regulations. We store most of our data electronically: primarily on our own and rented servers, and, to a limited extent, on office computers, external drives and phones. We process data through IT tools used by the team and entities working with the Czulent Jewish Association, primarily the CRM relationship management system (hereafter: CRM system), email and cloud for file storage. We keep some of the data in the form of paper records, in properly secured cabinets and rooms.

9. Cookie files

Cookies are small text files sent to your device when you visit our websites: czulent.pl, biblioteka.czulent.pl and www.zglosantysemityzm.pl.

Cookies include, but are not limited to. address of the website from which they originate, settings made by the website user regarding page layout, text size, colors, contrast version, data entered into forms, and a value, which is usually an automatically generated unique number. The cookie mechanism does not collect any personal data or any confidential information from the end user’s device.

By using the Association’s sites, you agree to the use of cookies. As an end user, you have the option to use the website without using cookies, but this means that some features of the website will not work properly. Remember that you can change your cookie settings yourself and at any time, as well as delete cookies using the available functions in the web browser you are using. If you do not agree to the use of cookies, it is possible to select in your browser settings the option to reject cookies or signal their transmission.

Our websites may use the following cookie files:

Authentication files – used for services that require end-user authentication on the website and for detecting authentication abuse on the website;
Statistical files – used to collect information about the end user’s use of the website;
functional files – used to remember the settings selected by the end user and personalize the user interface, e.g. with regard to the selected language, font size, website design, etc.

To manage your cookie settings, select the application you are using from the list of official websites of the manufacturers of the most commonly used web browsers and follow the manufacturer’s instructions:

Internet Explorer – http://support.microsoft.com/
Chrome – http://support.google.com/chrome/
Safari – http://support.apple.com/
Firefox – http://support.mozilla.org/pl/
Opera – http://help.opera.com/Windows/

Mobile devices:

Android – http://support.google.com/chrome/
Safari – http://support.apple.com/
Windows Phone – http://www.windowsphone.com/pl-pl/how-to/(12).

10. Changes in the Privacy Policy

The Jewish Czulent Association reserves the right to unilaterally make changes to the content of this Privacy Policy at any time. Amendments take effect on the date they are published within www.czulent.pl, biblioteka.czulent.pl, czulent.org, and www.zglosantysemityzm.pl