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General provisions

Protection of natural persons in connection with processing of their personal data is one of the basic rights of each data subject. The National Information Processing Institute pays particular attention to respecting the privacy of data subjects whose data are processed, regardless of whether the data have been acquired directly from a data subject or from other sources. This privacy policy (hereinafter referred to as 'Policy') provides persons whose data are processed in connection with the use of the NAVOICA Platform with information on how their data are acquired, processed and secured. The Policy contains basic information on data processing and data protection.If other rules than those specified in the Policy are applied, you will be informed about them on a case by case basis.

Personal data controller

The personal data controller responsible for the data processed in connection with the service related to the user's account on the NAVOICA Educational Platform or in connection with any sent or received correspondence shall be the National Information Processing Institute (hereinafter referred to as 'OPI PIB') headquartered in Warsaw at the following address: al. Niepodległości 188 B, entered in the Register of Entrepreneurs maintained by the Regional Court for the capital city of Warsaw, Commercial Court, 12th Commercial Division of the National Court Register, under No. 0000127372, tax identification number (NIP): 525-000-91-40, business entity statistical number (REGON): 006746090.

The personal data administrator may be contacted by e-mail: opi@opi.org.pl, by phone: 22 570 14 00 or by post: Ośrodek Przetwarzania Informacji – Państwowy Instytut Badawczy, al. Niepodległości 188b, 00-608 Warsaw, Poland.

The personal data administrators responsible for the data that concern participants and that are processed in connection with their participation in the courses offered on the platform shall be the entities that have uploaded the information on such courses and that organize such courses, e.g. universities, research institutes, entities uploading the information on the courses (so-called educational units within the meaning of the terms of use of the NAVOICA platform).In the case of these data OPI PIB shall be identified as the processor.

Data protection officer

The personal data controller has appointed the data protection officer. The data protection officer may be contacted by e-mail: iod@opi.org.pl or by post: Ośrodek Przetwarzania Informacji – Panstwowy Instytut Badawczy, 'IOD', al. Niepodległości 188b, 00-608 Warsaw, Poland.

Legal regulations, grounds for data processing

The OPI PIB privacy policy of the NAVOICA Platform is based on the following legal documents:

  1. 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 repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L No. 119, p. 1) – hereinafter referred to as 'GDPR',
  2. Act of 10 May 2018 on Personal Data Protection (Polish Journal of Laws of 2019, item 1781),
  3. Telecommunications Act of 16 July 2004 (Polish Journal of Laws of 2019, item 2460, as amended),
  4. Electronic Services Act of 18 July 2002 (Polish Journal of Laws of 2020, item 344, as amended),
  5. Act on Higher Education and Science of 20 July 2018 (Polish Journal of Laws of 2020, item 85, as amended),
  6. Act on Research Institutes of 30 April 2010 (Polish Journal of Laws of 2018, item 736).

All personal data processed in connection with the use of the NAVOICA Platform shall be processed under Article 6 paragraph 1 point (b) of GDPR - the data are necessary to conclude and to perform the contract related to the use of the NAVOICA Platform services (provision of the service in accordance with the Terms of Use of the NAVOICA Platform). Personal data of Users representing an Educational unit are processed on the basis of the premise specified in Article 6 paragraph 1 point (f) of GDPR, as the controller's legitimate interest to perform the contract.

Categories, scope and purpose of data processing

Personal data on the NAVOICA Platform are processed only for specific and lawful purposes referred to in detail in the 'Terms of Use of the NAVOICA Platform' and the 'Honor Code'. The main purpose of the processing is to make it possible for every user in the world who has access to the Internet to take part in courses prepared by the best universities and educational institutions in Poland and to provide top quality education services. The scope of personal data, including the name and surname as well as the e-mail address, is necessary for registration of an account on the NAVOICA Platform, provision of the services offered by the Platform, possible establishment, assertion or defense of claims, explaining the circumstances of unauthorized use of the services provided electronically, making copies and storing data. Providing other data, e.g. country of origin, level of education, gender or year of birth, is not obligatory and is used only for statistical purposes. Data are also collected automatically in the case of data contained in system logs and cookies.

Data recipients

Under relevant agreements, the controller may transfer your data or entrust the task of their processing to recipients providing advisory, legal, auditing or IT services, as well as substantive and technical support for the NAVOICA Platform. Furthermore, the data may be made available to public administration authorities in connection with their tasks performed under the rules of law. The data may also be made available to educational units to confirm participation in the course.

Data storage period

The data processed in connection with the use of the account service on the NAVOICA Platform will be stored throughout the period during which this service is provided, but no longer than until the claims under this title are time barred. In the case of correspondence sent by e-mail or via the contact form the data will be stored until either the objection is raised, or the consent is withdrawn, or the purpose of the processing ceases, but for no longer than 3 years.

Rights of data subjects

A data subject whose personal data are processed on the NAVOICA Platform, excluding the exceptions as stated in the rules of law, is entitled to:

  1. withdraw their consent to process their personal data at any time only if the consent is the legal basis of data processing
  2. access the data, i.e. the data subject has the right to receive information from OPI PIB confirming that their personal data are processed by OPI PIB and stating the purpose for which they are processed, how they are processed and for how long they have been or will be processed,
  3. clarify out-of-date or incomplete personal data, as well as complete them if they are incomplete,
  4. object to the processing of personal data if OPI PIB processes personal data based on a legitimate interest (e.g. for analytical, statistical, evidence or archiving purposes). In the case of objection, OPI PIB shall cease to process data, unless OPI PIB demonstrates relevant, legitimate grounds for processing which, objectively, ought to have priority over the interest of the data subject, or are essential to determine, assert or defend claims (e.g. for evidence purposes or assertion of claims),
  5. delete their personal data ('the right to be forgotten'). As a rule, the controller requests to immediately delete their personal data under Article 17 of GDPR. However, there are exceptions to this rule (particularly in the case of determining, asserting or defending claims),
  6. restrict the processing of personal data, which, in practice, may consist in temporarily blocking the access to the data or in transferring the data to another system,
  7. transfer the data, i.e. the data subject is entitled to receive backup copies they have provided to OPI PIB if their data are processed on the basis of their consent, on the basis of a contract, or in an automated manner,

All applications or requests pertaining to the processing of personal data, including the ones pertaining to enforcement of rights should be sent by e-mail to: mooc_help@opi.org.pl or iod@opi.org.pl, or by mail to the following address: Ośrodek Przetwarzania Informacji – Państwowy Instytut Badawczy, al. Niepodległości 188b, 00-608 Warszawa .

OPI PIB shall reply to the applications/requests without unreasonable delay, but in no event later than within 30 days as from the moment of receiving the application/request. The above deadline may be extended by another two months if a particular request proves complex or if there are many requests, of which the applicant shall be notified.

The applications/requests ought to include the name and surname of the applicant as well as other contact data (their telephone number, e-mail address and, in the case of application/requests in writing, correspondence address). If the applications/requests pertain to the use of websites, please provide the address of the website or the information about the Service provided by our websites and additional clarifications supplementing the submitted application (in order to speed up the application handling process). In the case of handing some applications/requests, OPI PIB may ask for additional information to confirm the identity of the applicant.

Each of the data subjects whose data are processed in OPI PIB is also entitled to submit a complaint to the supervisory body , i.e. to the President of the Personal Data Protection Office headquartered in Warsaw at the following address: ul. Stawki 2.

Transferring data to third countries and international organizations

We do not transfer your personal data processed on the NAVOICA Platform to third countries or to international organizations.

Automatic processing (including profiling) of personal data

Personal data processed on the NAVOICA Platform will not be subject to automated decision making, including decision making based on profiling.

Amendments to the Privacy policy

OPI PIB reserves the right to amend this Policy, which may result from the need to adapt to changes in legal regulations or in applicable privacy standards. OPI PIB will publish relevant notifications on any amendments on the website of the NAVOICA Platform.

Data processing with the use of cookies and other Internet technologies

Whenever a person uses the website of the NAVOICA Educational Platform, we are collecting data contained in system logs and cookies; we may also use other similar Internet technologies. For more information regarding the use of cookies and other Internet technologies go to the cookies policy of the NAVOICA Educational Platform at Cookies policy.