Privacy and cookie policy

The administrator of the website www.bravenew.agency is Brave New Sp. z o.o., 31-051 Krakow, Berka Joselewicza street 14/8, NIP (tax ID number): 675 163 89 82, REGON (company ID number): 369646874, KRS (National Court Register) 722284.

This privacy policy has been structured in the form of questions and answers. Below you will find the table of contents of this policy corresponding to the questions we answer in turn.

  1. Who is the administrator of personal data?
  2. Who can you contact regarding personal data?
  3. What information do we have about you?
  4. Where do we get your personal data from?
  5. Is your data safe?
  6. For what purposes do we process your personal data?
  7. How long will we keep your personal data?
  8. Who are the recipients of your personal data?
  9. Do we transfer your data to third countries?
  10. Do we use profiling?
  11. What are your rights in relation to data processing?
  12. Do we use cookies and what are they actually?
  13. On what basis do we use cookies?
  14. Can you disable cookies?
  15. For what purposes do we use our own cookies?
  16. What third party cookies are used?
  17. Do we track your activity on our website?
  18. Do we direct targeted advertising at you?
  19. How can you manage your privacy?
  20. What are server logs?
  21. Is there anything else you should know?
  22. Can this privacy policy be subject to change?

In case of any doubts related to the privacy policy, you can contact us at any time by sending a message to the address rodo@bravenew.pl

1: Who is the administrator of your personal data?

The administrator of your personal data is Brave New Sp. z o.o., 31-051 Krakow, Berka Joselewicza street 14/8, NIP: 675 163 89 82, REGON: 369646874, KRS 722284

2: Who can you contact regarding the processing of your personal data?

As part of the implementation of personal data protection in our organisation, we decided not to appoint a personal data protection officer due to the fact that in our situation it is not mandatory. In matters related to the protection of personal data and broadly understood privacy, you can contact the following e-mail address: rodo@bravenew.pl.

3: What information do we have about you?


Depending on the purpose, we may process the following information about you:

  • Name and surname,
  • Address of residence,
  • Business address,
  • Tax identification number,
  • E-mail address,
  • Phone number,
  • Data contained in e-mail correspondence,
  • Bank account number,
  • IP address,
  • Approximate location,
  • Image (profile picture),
  • Statistics related to received newsletters,
  • Favourite e-mail client,
  • Interests in specific topics,
  • Content of comments/opinions added on the website.

We have described the scope of processed data in detail in relation to each purpose of processing, further in this policy.

We also use tools that collect a range of information about you related to the use of our website. This is, in particular, the following information:

  • Information about the operating system and web browser,
  • Subpages viewed,
  • Time spent on the site,
  • Transitions between individual subpages,
  • Clicks on individual links,
  • Source from which you go to the website,
  • Age range in which you are placed,
  • Your gender,
  • Your approximate location limited to the city.
  • Your interests based on your online activity.

This information is referred to in the remainder of this privacy policy as „Anonymous Information”.

Anonymous Information by itself is not, in our opinion, personal information, as it does not allow us to identify you and we do not match it with the typical personal information we collect about you. Nevertheless, taking into account the strict case law of the Court of Justice of the European Union and the divided opinions among lawyers, as a precautionary measure, in the event that Anonymous Information is assigned the nature of personal data, we have also included detailed explanations in this privacy policy regarding the processing of this information.

As Anonymous Information is collected by external tools we use (Google Analytics, Facebook Custom Audiences, Hotjar, Google Ads, Facebook Connect, YouTube, Spreaker, Instagram, Behance, LinkedIn, Clutch), Anonymous Information is also processed by tool providers on the rules resulting from their regulations and privacy policies.

The processing of Anonymous Information allows us to provide you with the possibility of using the YouTube player and Spreaker embedded on blog pages. In addition, Anonymous Information is used for analytical, statistical and marketing purposes (creating Custom Audience Groups on Facebook, setting, targeting and targeting advertisements).

Anonymous Information is also used by the providers of individual tools to provide and improve services, manage them, develop new services, measure the effectiveness of advertising, protect against fraud and abuse, as well as personalise the content and advertisements displayed on individual websites, sites and applications.

4: Where do we get your personal data from?


In most cases, you pass them on to us yourself. This happens when you:

  • Subscribe to the newsletter,
  • Add a comment/opinion,
  • Contact us via e-mail,
  • Follow our profiles on social media or interact with the content we publish on social media.

In addition, some information about you may be automatically collected by the tools we use:

  • The website and newsletter system mechanisms collect your IP address,
  • The newsletter system mechanism collects information about your activity in relation to the content sent to you as part of the newsletter, such as openings messages, clicking on links, etc.,
  • Facebook Custom Audiences, w tym Facebook Pixel, Google Analytics, Google Ads, Facebook Connect, Hotjar, YouTube, Spreaker collect Anonymous Information related to your activities on the website.

 

5: Is your data safe?


We care about the security of your personal data. We have analyzed the risks associated with individual data processing processes, and then implemented appropriate security and personal data protection measures. We monitor the condition of the technical infrastructure on an ongoing basis, train staff, review the procedures applied and introduce necessary improvements. If you have any questions regarding your personal data, we are at your disposal at rodo@bravenew.pl.

6: For what purposes do we process your personal data?


There is more than one purpose. Below is a list of them, followed by a more detailed discussion. We have also assigned appropriate legal grounds for the processing to individual purposes:

  • Newsletter service – Article 6(1) (a) of the GDPR and Article 6(1) (f) of the GDPR,
  • Comment handling – Article 6(1) (f) of the GDPR,
  • handling correspondence – Article 6(1) (f) of the GDPR,
  • Implementation of tax and accounting obligations – Article 6(1) (c) of the GDPR in connection with the relevant tax law provisions,
  • Creating an archive for the possible need to defend, determine or pursue claims – Article 6(1) (f) of the GDPR,
  • Creating groups of recipients on Facebook – Article 6(1) (f) of the GDPR,
  • Social media support – Article 6(1) (f) of the GDPR,
  • Analysis and statistics using only Anonymous Information – Article 6(1) (f) of the GDPR,
  • Own marketing using only Anonymous Information – Article 6(1) (f) of the GDPR,
  • Ensuring the functioning of the YouTube player and Spreaker, social plugins using only Anonymous Information – Article 6(1) (f) of the GDPR.

Newsletter – details

By subscribing to the newsletter, you provide your name and e-mail address. Providing data is voluntary, but necessary to subscribe to the newsletter.

In addition, the system used to handle the newsletter saves your IP number that you used when subscribing to the newsletter, determines your approximate location, the e-mail client you use to handle e-mail and tracks your actions taken in connection with the messages sent to you. Therefore, we also have information about the messages you opened, the messages in which you clicked on links, etc.

The data provided by you in connection with the subscription to the newsletter is used to send you the newsletter, and the legal basis for their processing is your consent (Article 6(1) (a) of the GDPR) expressed when subscribing to the newsletter.

As for the processing of information that does not come from you, but was collected automatically by the mailing system, I rely in this respect on my legitimate interest (Article 6(1) (f) GDPR) in analysing the behaviour of newsletter subscribers in order to optimisation of mailing activities.

You can unsubscribe from the newsletter at any time by clicking on the dedicated link in each message sent as part of the newsletter or by simply contacting us.

Despite unsubscribing from the newsletter, your data will still be stored in the database in order to identify the returning subscriber and possibly defend claims related to sending you the newsletter, in particular to demonstrate that you consented to receive the newsletter and the moment of withdrawal of the consent, which is our legitimate interest referred to in Article 6(1) (f) of the GDPR.

You can modify your data provided for the purposes of receiving the newsletter at any time by clicking on the appropriate link visible in each message sent as part of the newsletter or by simply contacting us.

Comments/opinions – details

When adding a comment, you must provide at least the username that will be assigned to the comment (the name may contain personal data, such as name or surname) and e-mail address. Providing this data is voluntary, but necessary to add a comment.

The comment you added along with your public data will be visible on the page. If you want to delete or modify a comment, please contact us at rodo@bravenew.pl.

The legal basis for our processing of your personal data in the case of the comment system is the legitimate interest referred to in Article 6(1) (f) of the GDPR, which in this case consists in handling the comment system.

Correspondence handling – details

By contacting us via e-mail, you naturally provide your personal data contained in the correspondence, in particular your e-mail address and name and surname. Providing data is voluntary, but necessary to make contact.

In this case, your data is processed in order to contact you, and the basis for processing is Article 6(1) (f) of the GDPR, i.e. our legitimate interest. The legal basis for processing after the end of contact is also our legitimate interest in the form of archiving correspondence for the purpose of ensuring the possibility of proving certain facts in the future (Article 6 (1) (f) of the GDPR).

The content of the correspondence may be archived and we are not able to clearly determine when it will be deleted. You have the right to request a history of correspondence with us (if it was subject to archiving), as well as request its removal unless its archiving is justified due to our overriding interests, e.g. defence against potential claims on your part.

Tax and accounting obligations – details

If we issue an invoice for you, it is included in the accounting documentation, which will be kept for the period required by law. In such a situation, your personal data is processed in order to fulfil our tax and accounting obligations (Article 6 (1) (c) of the GDPR in connection with the relevant provisions governing tax and accounting obligations).

Archive – details

As part of the description of the individual purposes of personal data processing, we have indicated the dates of personal data storage. These terms are often related to the archiving of specific data for the purpose of ensuring the possibility of proving certain facts in the future, reconstructing the course of cooperation with the client, exchanged correspondence, defence, establishing or pursuing claims. In this regard, we rely on our legitimate interest, referred to in art. 6(1) (f) of the GDPR.

Groups of recipients – details

Your e-mail address stored in the newsletter database or in the store’s database may be sent to Facebook in order to create a group of ad recipients using this e-mail address.

When using this feature, the email address is hashed before being sent to Facebook to form an audience.

The e-mail address will be used in the matching process conducted by Facebook.

Facebook does not share the e-mail address with third parties or other advertisers and deletes the e-mail address as soon as the matching process is completed.

Facebook has implemented processes and procedures to ensure the confidentiality and security of the e-mail address sent to it and the set of Facebook user identifiers that create a group of recipients created using the e-mail address, i.e. through the use of technical and physical security.

Creating a group of recipients of Facebook ads using your e-mail address is our legitimate interest, as referred to in Article 6(1) (f) of the GDPR. You can object to the use of your e-mail address for this purpose at any time, just write to us at  rodo@bravenew.pl.

Social media – details

If you follow our profiles on social networks or interact with the content we publish on social media, we naturally see your data, which is publicly available on your social profile. We process this data only within a given social networking site and only for the purpose of operating a given social networking site, which is our legitimate interest referred to in Article 6(1) (f) of the GDPR.

Your use of social networks is subject to the regulations and privacy policies of the administrators of these websites, and these administrators provide you with services by electronic means, fully individually and independently of us.

We encourage you to consciously use social networking sites and take care of your privacy within them, in particular by careful selection of published content and managing privacy settings.

Analysis and statistics – details

We conduct analytical and statistical activities using Google Analytics, Facebook Pixel and Hotjar. As part of the analytical tools, we only have access to Anonymous Information.

We base the processing of Anonymous Information on the legitimate interest referred to in Article 6(1) (f) of the GDPR. The legitimate interest lies in the creation, review and analysis of statistics related to user activity on the website in order to draw conclusions that allow for the subsequent optimisation of the website.

Details related to Google Analytics and Hotjar are presented in the sections devoted to these tools when describing cookies. Facebook Pixel functions as part of cookies detected as Facebook Custom Audiences, so details related to it are presented in the section dedicated to Facebook Custom Audiences when describing cookies.

We are unable to provide you with access to Anonymous Information about you, as we cannot assign any of the Anonymous Information to any particular user. From the level of Google Analytics, Hotjar and Facebook tools, we only have access to a set of statistics and information not assigned to specific people.

You can, however, object to the processing of Anonymous Information about you by disabling Google Analytics, Hotjar and Facebook Custom Audiences cookies in the cookie settings triggered by clicking the appropriate link in the footer of the page.

Own marketing – details

We conduct marketing activities using Facebook Custom Audiences, including Facebook Pixel and Google Ads. As part of the marketing tools, we only have access to Anonymous Information.

We base the processing of Anonymous Information on the legitimate interest referred to in Article 6(1) (f) of the GDPR. The legitimate interest is the creation of Custom Audience Groups based on Anonymous Information and targeting ads on Facebook and within the Google Ads system based on Anonymous Information, which are part of the marketing of own products and services.

Details related to Facebook Custom Audiences and Google Ads are presented in the sections devoted to these tools when describing cookies.

We are unable to provide you with access to Anonymous Information about you, as we cannot assign any of the Anonymous Information to any particular user. From the level of Facebook and Google tools, we only have access to a collection of statistics and information not assigned to specific people.

You can, however, object to the processing of Anonymous Information about you by disabling Facebook Custom Audiences and Google Ads cookies in the cookie settings triggered by clicking on the relevant link in the footer of the page.

Additional tools – details

We embed videos from YouTube and audio recordings from Spreaker on the website. All these tools process Anonymous Information.

We base the processing of Anonymous Information on the legitimate interest referred to in Article 6(1) (f) of the GDPR. In this case, the legitimate interest consists in ensuring the possibility of using additional functions on the website – player, social plugins.

Details related to YouTube, Spreaker and social plugins are presented in the section dedicated to these tools when describing cookies.

We are unable to provide you with access to Anonymous Information about you, as we cannot assign any of the Anonymous Information to any particular user. Moreover, when it comes to Anonymous Information processed as part of YouTube, Spreaker and social plugins, we do not even have access to this information, and we do not need this information for anything – it is processed solely for the purpose of YouTube player, Spreaker and social plugins being able to work.

You can, however, object to the processing of Anonymous Information about you by disabling YouTube cookies, Spreaker and social plugins in the cookie settings triggered by clicking the appropriate link in the footer of the page. However, please note that you will not be able to use the YouTube player, Spreker and social plugins in this way.

7: How long will we keep your personal data?


The data storage periods have been indicated separately for each processing purpose. You will find this information under the details for each separate processing purpose. Most of the data is deleted after the expiry of the limitation period for claims.

8: Who are the recipients of your personal data?


We would venture to say that modern business is not able to do without services provided by third parties. We also use such services. Some of these services are related to the processing of your personal data. External service providers that participate in the processing of your personal data are:

  • The hosting provider that stores the data on the server,
  • The provider of the cloud computing service in which files that may contain your personal data are stored,
  • The provider of the mailing system in which your data is stored, if you are a newsletter subscriber,
  • a CRM system provider where we store your data to improve the customer service process and for archival purposes,
  • an invoicing system provider where your data is stored in order to issue an invoice,
  • an accounting office that processes your data visible on invoices,
  • an entity providing maintenance services that gain access to data, if the technical works carried out relate to areas where personal data are located,
  • Other subcontractors who gain access to data, if the scope of their activities requires such access.

All entities mentioned above process your data on the basis of concluded personal data processing agreements and guarantee an adequate level of personal data protection.

If necessary, your data may be made available to a legal advisor or attorney bound by professional secrecy. The need may arise from the necessity to use legal assistance that requires access to your personal data.

Your personal data may also be transferred to tax offices to the extent necessary to fulfil tax, accounting and accounting obligations. It concerns in particular all declarations, reports, statements and other accounting documents in which your personal data is located.

In addition, if necessary, your personal data may be made available to entities, bodies or institutions authorised to obtain access to data on the basis of legal provisions, such as the police, security services, courts, prosecutor’s offices.

Your data is made available to postal and courier companies to the extent necessary to deliver correspondence. These companies become independent administrators of your personal data.

Moreover, when it comes to Anonymous Information, the providers of tools or plugins that collect Anonymous Information have access to it. The providers of these tools are independent administrators of the data collected in them and may share this data on the terms specified by them in their own regulations and privacy policies, over which we have no influence.

9: Do we transfer your data to third countries or international organisations?


Yes, part of the processing of your personal data may involve their transfer to third countries.

We transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular in the USA. The providers of these tools guarantee an adequate level of protection of personal data through appropriate compliance mechanisms provided for by the GDPR, in particular through the use of standard contractual clauses.

Personal data is stored on servers located in third countries using the following tools:

  • MailerLite mailing system, the provider of which is MailerLite, Inc. (Delaware corporation at 548 Market St, PMB 98174, San Francisco, CA 94104-5401, United States) regarding your name, e-mail address, IP address and statistical information related to your responses to sent messages.

MailerLite, Inc. ensures an adequate level of protection of personal data through the use of compliance mechanisms provided for by the GDPR, in particular through the use of standard contractual clauses.

We also remind you here that we use external tools that may collect Anonymous Information. The providers of these tools often use servers located all over the world, in particular in the United States of America (USA), to store the collected information.

10: Do we use profiling? Do we make automated decisions based on your personal data?


We do not make decisions for you based solely on automated processing, including profiling, that would have legal effects on you or similarly significantly affect you.

Yes, we do use tools that can take certain actions depending on the information collected as part of the tracking mechanisms, but we believe that these actions do not have a significant impact on you because they do not differentiate your situation as a customer, they do not affect the terms of the contract, which you can conclude with us, etc.

By using certain tools we can, for example, direct personalised advertisements to you based on your previous actions taken on the website or suggest products that may be of interest to you. We are talking about the so-called behavioural advertising. We encourage you to learn more about behavioural advertising, in particular regarding privacy issues. Detailed information, along with the ability to manage your behavioural advertising settings, can be found here.

We emphasise that as part of the tools we use, we only have access to Anonymous Information. This information is stored on the servers of the suppliers of individual tools, and these servers can most often be located all over the world.

11: What rights do you have in relation to the processing of your personal data?


The GDPR grants you the following potential rights related to the processing of your personal data:

  • The right to access your data and receive a copy of it,
  • The right to rectify (correct) your data,
  • The right to delete data (if in your opinion there are no grounds for us to process your data, you can demand that we delete them),
  • The right to limit data processing (you can request that we limit the processing of data only to their storage or performance of activities agreed with you if in your opinion we have incorrect data or we process it unjustifiably),
  • The right to object to the processing data (you have the right to object to the processing of data on the basis of a legitimate interest; you should indicate a special situation that, in your opinion, justifies the discontinuance of the processing covered by the objection; we will stop processing your data for these purposes unless we prove that the grounds for our data processing are overriding your rights or that your data is necessary for us to establish, assert or defend claims),
  • The right to transfer data (you have the right to receive from us in a structured, commonly used, machine-readable format, personal data that you provided to us on the basis of a contract or your consent; you can commission us to send this data directly to another entity),
  • The right to withdraw consent to the processing of personal data, if you previously gave such consent,
  • The right to lodge a complaint with the supervisory authority (if you find that we are processing data unlawfully, you can submit a complaint to The President of the Personal Data Protection Office or another competent supervisory authority).

The rules related to the implementation of the above-mentioned rights are described in detail in Art. 16 – 21 of the GDPR. We encourage you to familiarise yourself with these regulations. For our part, we consider it necessary to explain to you that the above-mentioned rights are not absolute and you will not be entitled to all activities of processing your personal data.

We emphasise that you always have one of the rights indicated above – if you believe that we have violated the provisions on the protection of personal data while processing your personal data, you have the option to lodge a complaint with the supervisory body (the President of the Office for Personal Data Protection).

You can also always ask us to provide you with information about what data we have about you and for what purposes we process it. All you need to do is send a message to rodo@bravenew.pl. However, we have made every effort to ensure that the information you are interested in is comprehensively presented in this privacy policy. You can also use the e-mail address provided above if you have any questions related to the processing of your personal data.

12: Do we use cookies and what are they exactly?


Our website, like almost all other websites, uses cookies.

Cookies are small text information stored on your end device (e.g. computer, tablet, smartphone) that can be read by our ICT system (own cookies) or ICT systems of third parties (third-party cookies). In cookies, specific information can be saved and stored, which IT systems can then access for specific purposes.

Some of the cookies we use are deleted after the end of the web browser session, i.e. after closing it (so-called session cookies). Other cookies are stored on your end device and make it possible to recognise your browser the next time you visit the website (persistent cookies).

If you want to learn more about cookies as such, you can see, for example, this material. 

13: On what basis do we use cookies?


We use cookies on the basis of your consent, except when cookies are necessary for the proper provision of electronic services to you.

Cookies that are not necessary for the proper provision of electronic services remain blocked until you agree to the use of cookies. During your first visit to the website, we display a message asking for your consent along with the possibility of managing cookies, i.e. deciding which cookies you agree to and which you want to block.

Please note that disabling or restricting cookies may prevent the use of some of the functions available on our website and cause difficulties in using the website, as well as many other websites that use cookies. For example, if you block cookies for social plug-ins, buttons, widgets and social functions implemented on the website may not be available to you.

14: Can you disable cookies?


Yes, you can manage cookie settings within your web browser. You can block all or selected cookies. You can block cookies from specific websites. You can also delete previously saved cookies and other websites and plug-in data at any time.

Web browsers also offer the option of using incognito mode. You can use it if you do not want information about visited pages and downloaded files to be saved in your browsing and download history. Cookies created in Incognito mode are deleted when all Incognito windows are closed.

There are also browser plug-ins to control cookies, such as Ghostery. The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc.

In addition, there are tools available on the Internet that allow you to control certain types of cookies, in particular for collective management of behavioural advertising settings.

We also give you the ability to control cookies directly from our website. We have implemented a special cookie management mechanism that allows you to block cookies that you do not want.

Remember that disabling or limiting the use of cookies may prevent you from using some of the functions available on our website and cause difficulties in using the website, as well as from many other websites that use cookies. For example, if you block cookies from social plug-ins, buttons, widgets and social functions implemented on my website may not be available to you.

15: For what purposes do we use our own cookies?


Own cookies are used to ensure the proper functioning of the various mechanisms on the page, such as memorising contents of the basket for a certain time after adding the selected products, the correct transmission of the form shown on the page, servicing of newsletter forms, etc.

Own cookies also store information about cookie settings defined by you that are made from the level of the cookie management mechanism.

16: What third party cookies are used?


As part of our website are the following third-party cookies:

  • Google Analytics,
  • Google Ads,
  • Hotjar,
  • Facebook Custom Audiences,
  • Facebook Connect and other social plug-ins,
  • Spreaker,
  • YouTube.

Details about individual cookies by third parties are described below.

Google Analytics – details

We use the Google Analytics tool provided by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. We carry out activities in this area based on our legitimate interest, consisting in the creation of statistics and their analysis in order to optimise the website.

In order to use Google Analytics, we have implemented a special Google Analytics tracking code in the website code. The tracking code uses Google LLC cookies for the Google Analytics service. You can block the Google Analytics tracking code at any time by installing the browser add-on provided by Google.

Google Analytics automatically collects information about your use of the website. The information collected in this way is most often transferred to Google servers, which can be located all over the world and stored there.

Due to the IP anonymisation activated by us, your IP address is shortened before forwarding. Only in exceptional cases is the full IP address sent to Google servers and shortened there. The anonymised IP address provided by your browser as part of Google Analytics is, as a rule, not combined with other Google data.

We emphasise that as part of Google Analytics, we only have access to Anonymous Information.

Google Analytics and Google Analytics 360 services have been certified by the independent security standard ISO 27001. ISO 27001 is one of the most recognised standards in the world and certifies compliance with the relevant requirements by systems that support Google Analytics and Google Analytics 360.

If you are interested in details related to the use of Google data from websites and applications that use Google services, we encourage you to read this information.

Hotjar – details

We use the Hotjar tool to better understand your needs and to optimise our website in terms of your experience with using it, which is our legitimate interest. The tool is provided by an external entity, i.e. Hotjar Limited, Level 2, St Julian’s Business Center, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta.

Hotjar registers every visitor to our website and allows you to play a video recording of their traffic on our website, as well as generate the so-called heat maps. As part of the Hotjar tool, we do not have access to information that allows us to identify you, because Hotjar does not register the process of filling in the forms. The information that we have access to on Hotjar is, in particular:

  • information about the operating system and the web browser you use,
  • subpages that you browse as part of our website,
  • time spent on our website and on its subpages,
  • transitions between individual subpages in as part of our website,
  • the source from which you go to our website,
  • the place where you click with the mouse.

In order to use Hotjar, we have implemented a special Hotjar tracking code in the code of our website. The tracking code uses Hotjar Limited cookies. The information collected as part of cookies is stored by Hotjar as part of a pseudonymous user profile. Neither Hotjar nor we use this information to identify you.

You can object to Hotjar creating your user profile, Hotjar’s storage of information about your use of our website and the use of Hotjar cookies here.

If you are interested in the details related to data processing under Hotjar, we encourage you to read the Hotjar privacy policy.

Google Ads – details

We use remarketing functions available as part of the Google AdWords system operated by Google LLC, 1600 Amphitheater Parkway, Mountain View, CA 94043, USA. We carry out activities in this area based on our legitimate interest, consisting in the marketing of our own products or services.

When you visit our website, a Google cookie remarketing file is automatically left on your device, which collects information about your activity on our website. Thanks to the information collected in this way, we are able to display advertisements to you within the Google network depending on your behaviour on our website. For example, if you display a product, the information about this fact will be recorded by the remarketing cookie file, which will allow us to send you an advertisement about that product or any other that we deem appropriate. This advertisement will be displayed to you within the Google network when you use the Internet, browse other websites, etc.

We emphasise that when using Google Ads, we only use Anonymous Information.

By using Google AdWords, we are only able to define the target groups we would like our ads to reach. On this basis, Google decides when and how to present our advertisement to you.

Further processing of the information takes place only if you have given your consent to Google to link your browsing history with your account and to use the information from your Google account to personalise the advertisements displayed on websites. In this case, Google will use your data to create and define lists of target groups for remarketing purposes on various devices. To this end, Google combines the temporarily collected information with other data it holds to form target groups.

If you do not want to receive personalised ads, you can manage your ad settings directly on the Google site.

If you are interested in details related to Google’s use of data from websites and applications that use Google services, we encourage you to read this information.

Facebook Custom Audiences – details

As part of the Facebook Ads advertising system provided by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA, we use the Custom Audience Groups feature to direct targeted advertising messages to specific user groups. We carry out activities in this area based on our legitimate interest, consisting in the marketing of our own products or services.

In order to send you personalised ads in terms of your behaviour on our website, we have implemented Facebook as part of the Pixel website, which automatically collects information about your use of the website. The information collected in this way is most often transferred to Facebook servers, which may be located all over the world, in particular in the United States of America (USA).

The information collected as part of Facebook’s Pixel is anonymous, i.e. it does not allow us to identify you. Depending on your activity on our website, you can reach a specific group of recipients, but we do not identify individuals belonging to these groups in any way.

Facebook Pixel can track and record, among others the following your behaviour:

  • displaying the content of a specific page,
  • proceeding to checkout as part of the blog store,
  • finalising the purchase as part of the blog store,
  • filling out a specific form, e.g. subscribing to the newsletter.

However, we inform you that Facebook may combine the collected information with other information collected about you as part of your use of Facebook and use it for its own purposes, including marketing. Such Facebook activities are no longer dependent on us, and you can search for information about them directly in Facebook’s privacy policy. You can also manage your privacy settings from your Facebook account. Here you will find useful information in this regard.

Facebook Connect and other social plugins – details

Our website uses plugins, buttons and other social tools, hereinafter collectively referred to as “plugins”, provided by social networks such as Facebook, Instagram, LinkedIN, Behance.

When displaying a website containing a plugin of a given social networking site, your browser sends information about the visit to the administrator of that social networking site. Since the plugin is a part of the social networking site embedded in our website, the browser sends information about the request to download the content of the social networking site to our site.

The plugins collect certain information about you, such as user ID, website visited, date and time, and other information about your web browser.

Social network administrators use some of this information to personalise the viewing conditions of our website. For example, when you visit a page with a “Like” button, the administrator of the social networking site needs to know who you are to show you which of your friends also like our page.

The information collected by the plugins may also be used by the administrators of social networking sites for their own purposes, such as, for example, improving their own products, creating user profiles, analysing and optimising their own activities, advertising targeting. We have no real influence on how the information collected by the plugins is then used by the administrators of social networks. You can look for details in this regard in the regulations and privacy policies of individual social networking sites.

Social network plugins collect and transmit information to the administrators of these websites even when you browse our website without being logged in to your account on the social network. However, then the browser sends a more limited set of information.

If you have logged in to one of the social networking sites, the website administrator will be able to directly assign a visit to our site to your profile on a given social networking site.

If you do not want social networking sites to assign the data collected during your visit to our website directly to your profile on a given website, you must log out of this website before visiting our website. You can also completely prevent the loading of plugins on the website by using appropriate extensions for your browser, e.g. blocking scripts.

In addition, the use of some plugins may involve the publication of certain information within your social profiles. For example, information about clicking the “Like” button may be available on your Facebook timeline. Of course, if you share some content on your social media using plugins embedded on our website, this sharing will naturally be visible in your profile.

As for the details related to the processing of information collected by plugins by social network administrators, in particular about the purpose and scope of data collection and their further processing and use by administrators, as well as the possibility of contact and your rights in this regard and the possibility of making settings to protect your privacy, you can find everything in the privacy policies of individual service providers:

Spreaker – details

Spreaker widgets are embedded in our pages, allowing you to play recordings available on the SoundCloud service directly from our pages. Spreaker is operated by Spreaker, Inc.195 Montague Street, 11th Floor, Brooklyn, NY, 11201, USA

When you visit a page with an embedded Spreaker widget, Spreaker receives certain information, including information about the website you visited and about your interaction with the widget. Spreaker and widget can recognise you, in particular with the use of cookie technology. Spreaker uses the information collected in this way to ensure the proper and safe functioning of the widget, to analyse and optimise the services provided by Spreaker, as well as for personalisation and advertising purposes.

Remember that while playing the recordings available on the Spreaker website, you use the services provided electronically by Spreaker. Spreaker is an independent entity that provides services to you by electronic means. Details on the rules of using Spreaker, including privacy protection, can be found in the documents provided directly by Spreaker:

YouTube – details

Our websites are embedded with YouTube widgets that allow you to play recordings available on YouTube directly from our websites. YouTube is operated by Google LLC.

Videos are embedded on the website in the privacy protection mode. Based on the information provided by YouTube, this means that no cookies are stored on your device, and Google does not collect any information about you until you play the recording.

When you play a recording, YouTube saves cookies on your device and receives information that you have played the recording from a specific website, even if you do not have a Google account or are not currently logged in. If you are logged in to your Google account, this service provider will be able to directly assign the visit to our website to your account. The purpose and scope of data collection and their further processing and use by Google, as well as the possibility of contact and your rights in this regard and the possibility of making settings to protect your privacy, are described in the Google privacy policy.

If you do not want Google to assign data collected during video playback directly to your profile, you must log out of your account before playing the video. You can also completely prevent the loading of plugins on the website by using appropriate extensions for your browser, e.g. blocking scripts.

The information collected as part of cookies related to YouTube videos embedded on our websites is used by Google to ensure the proper and safe functioning of the widget, to analyse and optimise the services provided by YouTube, as well as for personalisation and advertising purposes.

Remember that while playing the recordings available on YouTube, you are using the services provided electronically by Google LLC. Google LLC is an independent entity that provides electronic services to you. Details on the rules of using YouTube, including privacy protection, can be found in documents provided directly by YouTube:

17: Do we track your behaviour on our website?


Yes, we use Google Analytics, Google AdWords, Hotjar and Facebook Custom Audiences, which collect information about your activity on our website. These tools are described in detail in the third party cookie question, so we will not repeat this information here as well.

18: Do we direct targeted advertising at you?


Yes, we use Facebook Ads and Google Ads, in which we can target specific target groups defined on the basis of various criteria such as age, gender, interests, profession, job, activities previously undertaken on our website. These tools are described in detail in the third party cookie question, so we will not repeat this information here as well.

19: How can you manage your privacy?


The answer to this question can be found in many places in this privacy policy when describing individual tools, behavioural advertising, consent to cookies, etc. However, for your convenience, we have collected this information once again in one place. Below you will find a list of options for managing your privacy.

20: What are server logs?


Using the website involves sending queries to the server on which the website is stored. Each query directed to the server is saved in the server logs.

Logs include Your IP address, server date and time, information about the web browser and operating system you use. Logs are saved and stored on the server.

The data stored in the server logs are not associated with specific people using the website and are not used by us to identify you.

The server logs are only auxiliary material used to administer the website, and their content is not disclosed to anyone except those authorised to administer the server.

21: Is there anything else you should know?


As you can see, the subject of personal data processing, the use of cookies and general privacy management is quite complicated. We have made every effort to ensure that this document provides you with as much knowledge as possible on issues important to you. If anything is unclear to you, you want to know more or just talk about your privacy, please write to us at rodo@bravenew.pl.

22: Could this privacy policy be subject to change?


Yes, we can modify this privacy policy, in particular due to technological changes and changes in the law. All archived versions of the privacy policy are linked below.

Hi, I’m Andrzej, the CEO of Brave New. We've delivered more than 300 projects for 120 satisfied customers from all around world. This year we plan to deliver 50 projects for more than 20 clients.

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