Privacy Policy
Good morning!
If you have arrived here, it is a reliable sign that you value your privacy. We understand this perfectly, so we are giving you a document in which you will find in one place the rules for the processing of personal data and the use of cookies and other tracking technologies in connection with the operation of the site office@managershaven.com.
Formal information to start – the administrator of the site is Zuma Consulting – Krzysztof Wawrzynkowski NIP: 7181812589.
This privacy policy is structured in the form of questions and answers. The choice of this form was dictated by the concern for clarity and legibility of the information presented to you. Below you will find a table of contents of this policy corresponding to the questions we answer in turn.

1. Who is the controller of your personal data?
2. Who can you contact regarding the processing of your personal data?
3. What information do we have about you?
4. Where do we get your personal information from?
5. Is your data safe?
6. For what purposes do we process your personal data?
   • User account – details
   • Orders – details
   • Complaints and withdrawals – details
   • Newsletter – details
   • Comments and product reviews – details
   • Mail handling – details
   • Tax and accounting obligations – details
   • Archive – details
   • Self-marketing – details
   • Analysis, statistics, optimization – details
7. How long will we keep your personal information?
8. Who are the recipients of your personal data?
9. Do we transfer your data to third countries or international organizations?
10. Do we use profiling? Do we make automated decisions based on your personal data?
11. What rights do you have in relation to the processing of your personal data?
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?
    • Google Analytics – details
    • Google Tag Manager – details
    • Google AdWords – details
    • Google AdSense – details
    • You Tube – details
    • Vimeo – details
17. Do we track your behavior taken within our site?
18. Are we targeting you with targeted ads?
19. How can you manage your privacy?
20. What are server logs?
21. Is there anything else you should know about?

If you have any concerns about the privacy policy, you can contact us at any time by sending a message to office@managershaven.com.

1: Who is the controller of your personal data?

The administrator of your personal data is Zuma Consulting – Krzysztof Wawrzynkowski NIP: 7181812589.

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

As part of the implementation of data protection in our organization, we have decided not to appoint a data protection
officer due to the fact that it is not mandatory in our situation. For matters related to data protection and privacy in
general, you can contact us at email office@managershaven.com.

3: What information do we have about you?

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

• name
• residential address
• business address
• tax ID number
• email address
• phone number
• data contained in correspondence addressed to us
• bank account number
• IP address
• image (profile photo)
• products you’ve been looking at
• details of orders placed
• Details of abandoned shopping carts
• activity with regard to messages sent as part of the newsletter
• information about the operating system and web browser you are using
• REVIEWED POST
• time spent on the site
• transitions between different subpages
• clicks on individual links
• The source from which you go to our site
• The age range you are in
• Your gender
• Your approximate location limited to localities
• Your interests determined by your online activity

We have described the scope of data processing precisely for each processing purpose. Information in this regard can
be found later in this policy.

4: Where do we get your personal information from?

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

• You register a user account
• placing an order
• You send complaints or withdraw from the contract
• you sign up for the newsletter
• Add a comment or feedback on the product
• you contact us

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

• The mechanism of the site and the newsletter system collect your IP address
• The mechanism of the site collects information about the products you have viewed, details of orders placed,
  including unfinished ones
• The newsletter system mechanism collects information about your activity with regard to the content sent to you
  within the newsletter, such as opening messages, clicking on links, etc
• Google Analytics collects a range of information about how you use our site

5: Is your data safe?

We care about the security of your personal data. We have analyzed the risks involved in the various processes of
processing your data, and then implemented appropriate security and data protection measures. We constantly monitor
the state of our technical infrastructure, train our staff, look at the procedures in place, and make the necessary
improvements. If you have any questions about your personal data, we are at your disposal at office@managershaven.com.

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

There are more than one of these targets. Below is a list of them, followed by a more detailed discussion. We have
also assigned to each purpose the corresponding legal basis for processing.

• Registration and maintenance of a user account – Article 6(1)(b) of the DPA
• Order processing – Article 6(1)(b) of the RODO
• Handling of complaints or withdrawal from the contract – Article 6(1)(f) RODO
• newsletter mailing – Article 6(1)(a) of the RODO
• handling comments or product reviews – Article 6(1)(a) of the RODO
• Handling of correspondence – Article 6(1)(f) RODO
• Fulfillment of tax and accounting obligations – Article 6(1)(c) RODO
• To create an archive for the possible need to defend, establish or assert claims, as well as to identify a
  returning
  customer – Article 6(1)(f) of the DPA
• Self-marketing – Article 6(1)(f) RODO
• Analysis, statistics and optimization – Article 6(1)(f) RODO

User account – details
When you create a user account, you will need to provide the data necessary to create an account: email address and
password. Providing data is voluntary, but necessary to create an account.
As part of editing your account data, you can enter your further data, in particular, data that may be used in placing orders, such as your name, address of residence or place of business, VAT number, telephone number. As part of editing your account data, you can also set your avatar, such as a profile picture that includes an image. If you create an account through integration with a social network account, based on your prior authorization, we will gain access to certain data collected within the social network account (name, email address, profile picture).
In addition, our system used for user accounts records your IP number, which you used when registering a user account.
Moreover, we use the integration of the Google Analytics tool with the user account mechanism. In this way, the data
collected by the Google Analytics tracking code about your use of our site is assigned to your user account. This
includes information such as:

• information about the operating system and web browser you are using
• REVIEWED POST
• time spent on the site
• transitions between different subpages
• clicks on individual links
• The source from which you go to our site
• The age range you are in
• Your gender
• Your approximate location limited to localities
• Your interests determined by your online activity

We analyze such information about you in order to optimize our websites for user experience, efficiency and conversion,
which is our legitimate interest as referred to in Article 6(1)(f) of the DPA.
You can modify the information about you provided to us in connection with the registration of a user account at any
time. However, in a situation where you have created an account using an integration with a social network account, the
data retrieved from that social network cannot be modified.
The data provided by you in connection with the creation of an account is processed in order to provide you with an
electronic service consisting of providing you with the possibility of using a user account. This service is provided on
the basis of an agreement concluded according to the terms and conditions described in the regulations, which means that
in this regard the legal basis for processing your personal data is Article 6(1)(b) of the RODO.
The data will be kept for the duration of your account. At any time you can decide to delete your account, however, this
will not lead to the removal of information about your orders placed using your account from our database. Order data is
stored in our archive until the expiration of the statute of limitations for claims under the contract / for the entire
period of operation of the site due to ensuring the possibility of identifying a returning customer, reconstructing
their purchase history, discounts granted, etc., which is our legitimate interest referred to in Article 6(1)(f) of the RODO.

Orders – details
When placing an order, you need to provide the data necessary to process the order. Depending on the details of your
order, the catalog of data may be different. For example, if you are ordering physical products, we need to know the
address where we will deliver the order to you. If you are requesting a VAT invoice for a company, we need to know the
tax ID number and business address. Providing data is voluntary, but necessary to place an order.
In addition, our system used to handle the order process records your IP number, which you used to place the order.
Each order is saved in our database, which means that your personal information assigned to the order is also
accompanied by information about the order, such as the products ordered, the selected payment method, the selected
delivery method, the date of payment.
Data collected in connection with an order, is processed for the purpose of executing the contract concluded by placing
the order (Art. 6(1)(b) RODO), issuing an invoice (Art. 6(1)(c) RODO in connection with the regulations governing the
issuance of invoices), including the invoice in the accounting records and fulfilling other tax and accounting
obligations (Art. 6(1)(c) RODO in connection with the provisions governing tax and accounting obligations) and for
archival purposes for the possible need to defend, establish or assert claims, as well as to identify a returning
customer, which is our legitimate interest (Art. 6(1)(f) RODO).
Order data will be processed for the time necessary to process the order, and then until the expiration of the statute
of limitations for claims under the contract. In addition, after the expiration of this period, the data may still be
processed by us for archival purposes for the possible need to defend, establish or assert claims, as well as to identify a returning customer. Remember also that we are required to keep accounting records, which may contain your personal data, for the period required by law.

Complaints and withdrawals – details
If you make a complaint or withdraw from the contract, you provide personal data contained in the body of the complaint
or withdrawal statement, which includes name, address, telephone number, e-mail address, bank account number. Providing
data is voluntary, but necessary to make a complaint or withdraw from the contract. The data provided to us in connection with the filing of a complaint or withdrawal from the contract is used for the
purpose of the complaint procedure or withdrawal procedure, and then for archival purposes, which is our legitimate interest (Article 6(1)(f) RODO).
The data will be processed for the time necessary to carry out the complaint procedure or the withdrawal procedure.
Complaint documents will be stored until the expiration of warranty rights. Statements of withdrawal will be stored
along with accounting records for the period required by law.

Newsletter – details
By signing up for the newsletter, you provide us with your name and email address. Providing data is voluntary, but necessary to subscribe to the newsletter. In addition, our system used for the newsletter, records your IP number you used when signing up for the newsletter,
determines your approximate location, the mail client you use for email, and tracks your actions taken in connection
with messages sent to you. As such, we also have information about which messages you opened, within which messages you
clicked on links, etc. The data you provide to us in connection with signing up for the newsletter, is used for the purpose of sending you the
newsletter, and the legal basis for its processing is your consent (Article 6(1)(a) RODO) given when signing up for the
newsletter. As for the processing of information that does not come from you, but is collected automatically by our mailing system, we rely in this regard on our legitimate interest (Article 6(1)(f) RODO) to analyze the behavior of newsletter subscribers in order to optimize mailing activities.
You can unsubscribe from the newsletter at any time by clicking on the dedicated link included in each message sent as
part of the newsletter or by simply contacting us. Despite opting out of the newsletter, your data will continue to be
stored in our database for the purpose of identifying the returning subscriber and for the possible defense of claims
related to the sending of the newsletter to you, in particular for the purpose of proving the fact that you gave your
consent to receive the newsletter and when you withdrew it, which is our legitimate interest referred to in Article 6(1)(f) of the RODO.
You can modify your information provided for 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 and product reviews – details
When adding a comment or opinion about a product, you must provide at least a username that will be assigned to the
comment or opinion (the name may include personal information, such as first or last name) and an e-mail address.
Providing this data is voluntary, but necessary to add a comment or opinion. You can also add your avatar (which can
include your image, such as a photo) and provide your website address, but this is not mandatory.
Data provided in connection with the addition of a comment or opinion will be processed for the purpose of publishing
the comment or opinion on the site. The basis for processing is your consent (Article 6.1.a) resulting from the
submission of the form used to publish the comment or opinion. You can revoke your consent at any time by requesting
that the comment or opinion be deleted.
Your comment or opinion will be publicly available on the site for the duration of its availability on the Internet,
unless you request the removal of the comment or opinion beforehand. You can also modify the content of the comment at
any time, as well as modify the data assigned to it as about the person who added the comment or opinion.

Mail handling – details
When you contact us, you naturally provide us with your personal data contained in the body of your correspondence, in
particular your e-mail address and name. Providing the data is voluntary, but necessary to make contact.
Your data is processed in this case for the purpose of contacting you, and the basis for processing is Article 6(1)(f)
RODO, i.e. our legitimate interest. The legal basis for post-contact processing is also our legitimate purpose of
archiving correspondence for the purpose of ensuring that we can prove certain facts in the future (Article 6(1)(f) RODO).
The content of your correspondence may be subject to archiving and we are not in a position to clearly determine when it
will be deleted. You have the right to request the history of any correspondence you have had with us (if it was subject
to archiving), as well as to request its deletion, unless its archiving is justified by our overriding interests, such as defense against potential claims on your part.

Tax and accounting obligations – details
If we issue an invoice to you, it becomes part of your accounting records, which will be kept for the period of time required by law. Your personal data in such a situation is processed in order to fulfill our tax and accounting obligations (Article 6(1)(c) of the RODO in connection with the provisions governing tax and accounting obligations).

Archive – details
As part of the description of the various purposes for processing personal data above, we have indicated the time limits
for storing personal data. These time limits are often related to our archiving of certain data for the purpose of
ensuring that we can prove certain facts in the future, reconstruct the course of cooperation with the customer,
exchanged correspondence, defense, establishment or assertion of claims. In this regard, we rely on our legitimate
interest as referred to in Article 6(1)(f) of the RODO.

Self-marketing – details
As part of our site, we use an abandoned cart recovery mechanism. In a situation where you start the ordering process
but do not complete it, our system will note this fact in order to take actions to induce you to finalize your order.
These actions may include, in particular, sending you an email with an incentive to finalize your order or displaying a
targeted advertisement while you are browsing the Internet.

Analysis, statistics, optimization – details
We collect statistical information about users’ browsing behavior on our websites, such as clicks on links, transitions
between sub-pages, time spent on individual pages, etc. We analyze this information in order to optimize our sites for
user experience, efficiency and conversion. In most cases, the information processed in this way is not personal data.
The exception is if you are a registered user. Then we may collate this information with other data you have collected
in your user account.
We carry out the activities described above based on our legitimate interest referred to in Article 6(1)(f) of the
RODO
to optimize our websites.

7: How long will we keep your personal information?

Data retention periods are indicated separately for each processing purpose. You will find this information within
the
details dedicated to each separate processing purpose.

8: Who are the recipients of your personal data?

We would venture to say that modern business cannot do without services provided by third parties. We also use such
services. Some of these services involve the processing of your personal data. Third-party service providers that
are
involved in the processing of your personal data are:

• A cloud service provider that stores backups that may contain your personal information
• the provider of the mailing system where your data is stored if you are a newsletter subscriber
• provider of the CRM system where we store your data to improve the customer service process and for archival
  purposes
• provider of an invoicing system that stores your data for invoicing purposes
• The accounting office that processes your data shown on invoices
• courier companies that process your data to the extent necessary to deliver your order to you
• A law firm that accesses the data if necessary to provide legal assistance to us
• a maintenance service provider who accesses the data if the technical work carried out concerns areas where
  personal
  data is located
• other subcontractors who gain access to the data if the scope of their activities requires such access

Your personal data may also be transferred to the tax authorities to the extent necessary for the performance of tax and
accounting duties. This includes, in particular, all declarations, reports, statements and other accounting documents
containing your personal data.
In addition, if necessary, your personal data may be shared with entities, authorities or institutions entitled to
access the data under the law, such as police, security services, courts, prosecutors.
Moreover, we use tools that collect a range of information about you related to your use of our site. This includes, in
particular, the following information:

• information about the operating system and web browser you are using
• REVIEWED POST
• time spent on the site
• transitions between different subpages
• clicks on individual links
• The source from which you go to our site
• The age range you are in
• Your gender
• Your approximate location limited to localities
• Your interests determined by your online activity

This information in itself does not, in our opinion, have the nature of personal data. Since the information is
collected by third-party tools we use, the information is also processed by the tool providers under the terms of their
terms of service and privacy policies. Generally, this information is used to provide and improve services, manage them,
develop new services, measure the effectiveness of advertisements, protect against fraud and abuse, and personalize the
content and advertisements displayed on individual services, sites and applications. We have tried to describe the
details in this regard later in this policy, as part of the explanations devoted to each tool.

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

Yes, part of the processing operations 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 United States. The providers of these tools guarantee an
adequate level of personal data protection through the relevant compliance mechanisms provided for by the RODO, in
particular by joining the Privacy Shield program or using standard contractual clauses.

• ActiveCampagne’s mailing system, whose provider is ActiveCampagne LLC, 1 North Dearborn Street, Suite 500,
  Chicago, IL
  6062, USA – in terms of your name, e-mail address, IP address and statistical information related to your
  reactions to
  the messages we send
• Google services as part of the G-Suite, whose provider is Google Ireland Limited, Gordon House, Barrow Street,
  Dublin
  4, Ireland – to the extent of all data that is processed as part of Google services, including those data
  contained in
  files subject to synchronization with Google Drive.
• Google: https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI
• Vimeo INC, 555 West 18th Street, New York, New York 10011-in order to use Vimeo’s video recordings, which
  involves the
  use of cookies
• Owners of social networks: Facebook, Instagram, LinkedIn, YouTube under the data processing rules set by the
  owners of
  these portals, in the event that you like my social profiles hosted within these portals.2) Your data may be
  transferred
  by data recipients outside the EEA. Guarantees for the protection of your data arise from the participation of
  data
  recipients in the Privacy Shield program established under Commission Implementing Decision (EU) 2016/1250 of
  July 12,
  2016 on the adequacy of protection provided by the EU-US Privacy Shield (ActiveCampaign LLC:
  https://www.privacyshield.gov/participant?id=a2zt0000000GnH6AAK, Google LLC:
  https://www.privacyshield.gov/participant?id=a2zt000000001L5AAI&status=Active, Vimeo INC:
  https://www.privacyshield.gov/participant?id=a2zt00000008V77AAE&status=Active)

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

We do not make decisions with respect to you that are based solely on automated processing, including profiling, which
would produce legal effects with respect to you or similarly materially affect you.Yes, we do use tools that may take certain actions depending on the information collected by the trackingmechanisms,
but we believe that these actions do not have a significant impact on you, as they do not differentiate your situation
as a customer, do not affect the terms of the contract you may enter into with us, etc. Using certain tools, we can, for example, target you with personalized advertisements based on previous actions you
have taken on our site or suggest products that may interest you. We are talking here about so-called behavioral
advertising. We encourage you to learn more about behavioral advertising, particularly with regard to privacy issues. You can
find detailed information, along with the ability to manage your behavioral advertising settings, here:
http://www.youronlinechoices.com.
We emphasize that within the tools we use, we do not have access to information that would allow us to identify you.
The information we are talking about here is, in particular:

• information about the operating system and web browser you are using
• REVIEWED POST
• time spent on the site
• transitions between different subpages
• The source from which you go to our site
• The age range you are in
• Your gender
• Your approximate location limited to localities
• Your interests determined by your online activity

We do not collate the information indicated above with your personal information that is in our databases. This information is anonymous and does not allow us to identify you. This information is stored on the servers of the providers of the various tools, and these servers can most often be located around the world. An exception to the anonymous nature of the information mentioned above is when you have a user account. Then this
information may be compiled with your data collected in your user account. However, we still do not, with the use of
this information, make decisions towards you based solely on automated processing, including profiling, which would
produce legal effects towards you or similarly significantly affect you. We believe that activities in targeting you
with advertisements based on your activity on our website and taking optimization measures do not materially affect you.
Therefore, we rely on our legitimate interest referred to in Article 6(1)(f) of the RODO in this regard.

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

The RODO 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 (amend) your data
• The right to erasure (if, in your opinion, there is no basis for us to process your data, you can request that we
  erase it)
• The right to restrict data processing (you can request that we restrict the processing of your data only to storing it
  or performing activities agreed with you, if in your opinion we have incorrect data or are processing it unduly)
• The right to object to processing (you have the right to object to processing on the basis of a legitimate
  interest;
  you should indicate the particular situation that you think justifies us stopping the processing covered by the
  objection; we will stop processing your data for these purposes unless we demonstrate that the grounds for our
  processing override your rights or that your data are necessary for us to establish, assert or defend claims)
• The right to data portability (you have the right to receive from us in a structured, commonly used
  machine-readable
  format the personal data you have provided to us under a contract or your consent; you can have us send this data
  directly to another entity)
• The right to withdraw consent to the processing of personal data, if you have previously given such consent
• The right to lodge a complaint with a supervisory authority (if you find that we are processing your dat unlawfully,
  you can file a complaint about it with the President of the Office for Personal Data Protection or any other competent
  supervisory authority)

The rules related to the exercise of the rights indicated above are described in detail in Articles 16 – 21 of the RODO. We encourage you to familiarize yourself with these provisions. For our part, we deem it necessary to explain to you that the rights indicated above are not absolute and you will not be entitled to them in relation to all processing
activities of your personal data. We emphasize that one of the rights indicated above is always available to you – if you consider that we have violated data protection regulations in the processing of your personal data, you have the opportunity to file a complaint with
the supervisory authority (President of the Office for Personal Data Protection).
You can also always request that we 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 office@managershaven.com. However, we have made every effort to
ensure that the information of interest to you is comprehensively presented in this privacy policy. You can also use the
e-mail address provided above if you have any questions about the processing of your personal data.

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

Our website, like almost all other websites, uses cookies.
Cookies are small text information stored on your terminal device (e.g. computer, tablet, smartphone), which can be
read
by our ICT system (our own cookies) or by third-party ICT systems (third-party cookies). Cookies may record and
store
certain information, which can then be accessed by ICT systems for specific purposes.
Some cookies we use are deleted when your browser session ends, i.e. when you close it (so-called session cookies).
Other cookies are retained on your terminal device and allow us to recognize your browser the next time you visit
the
site (persistent cookies).
If you want to learn more about cookies as such, you can read, for example, this resource:
https://pl.wikipedia.org/wiki/HTTP_cookie.

13: On what basis do we use cookies?

We use cookies based on your consent, except when cookies are necessary for the proper provision of an electronic
service to you.
Cookies that are not necessary for the proper provision of the electronic service remain blocked until you agree to
our
use of cookies. When you visit our site for the first time, we display a message asking for your consent along with
the
option to manage cookies, i.e. decide which cookies you agree to and which you want to block.
Regarding your consent to cookies, we accept the option that you give such consent through the settings of your
browser
or additional software that supports the management of cookies. We assume that you consent to all cookies used by us
that are not blocked by your browser or additional software you use.
Please note that disabling or restricting cookies may prevent you from using some of the features available on the
site
and cause difficulties in using our site, as well as many other websites that use cookies. For example, if you block
social media plug-in cookies, buttons, widgets and social features implemented on our site may not be available to
you.

14: Can you disable cookies?

Yes, you can manage your cookie settings within your web browser. You can block all or selected cookies. You can also
block cookies of specific sites. You can also delete previously saved cookies and other site and plug-in data at any
time.
Web browsers also offer the possibility to use incognito mode. You can use it if you don’t want information about
the
pages you visit and files you download to be saved in your browsing and download history. Cookies created in
incognito
mode are deleted when you close all windows in this mode.
There are also browser plug-ins available to control cookies, such as Ghostery (https://www.ghostery.com). The
option to
control cookies may also be provided by additional software, particularly antivirus packages, etc.
In addition, there are tools on the Internet that allow you to control certain types of cookies, in particular to
collectively manage behavioral advertising settings (e.g., ,
).www.youronlinechoices.com/www.networkadvertising.org/choices

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

Proprietary cookies are used to ensure the proper functioning of the various mechanisms of the site, such as
maintaining
the session after logging into the account, remembering recently viewed products and products added to the shopping
cart.

16: What third-party cookies are used?

The following third-party cookies operate as part of our site:

• Google Analytics
• Google Tag Manager
• Google AdWords
• Google AdSense
• Facebook Custom Audiences
• Facebook, Twitter, LinkedIN, Pinterest (social media tool cookies)
• Vimeo
• Hotjar
• YouTube

Details of individual third-party cookies are described below.

Google Analytics – details
We use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. We
perform activities in this regard based on our legitimate interest in creating statistics and analyzing them in
order to
optimize our websites.
In order to use Google Analytics, we have implemented a special Google Analytics tracking code in the code of our
website. The tracking code uses cookies from Google LLC regarding the Google Analytics service. You can block the
Google
Analytics tracking code at any time by installing a browser add-on provided by Google:
https://tools.google.com/dlpage/gaoptout.
Google Analytics automatically collects information about your use of our website. The information collected in this
way
is mostly transmitted to Google’s servers, which may be located around the world and stored there.
Due to the IP address anonymization activated by us, your IP address is shortened before being passed on. Only in
exceptional cases is the full IP address transmitted to Google’s servers and only shortened there. The anonymized IP
address transmitted by your browser within the framework of Google Analytics is, as a rule, not combined with other
Google data.
We emphasize that within the framework of Google Analytics we do not collect any data that would allow us to
identify
you. Accordingly, the data collected as part of Google Analytics is not personal to us. The information we have
access
to within Google Analytics is, in particular:

• information about the operating system and web browser you are using
• The subpages you view within our site
• time spent on our site and its sub-sites
• transitions between different subpages
• The source from which you go to our site

In addition, we use the following Advertising Functions within Google Analytics:

• demographic and interest reports
• remarketing
• ad reporting functions, user-ID

As part of the Advertising Functions, we also do not collect personal information. The information we have access to is,
in particular:

• The age range you are in
• Your gender
• Your approximate location limited to localities
• Your interests determined by your online activity

Google Analytics and Google Analytics 360 services have been certified to the independent security standard ISO 27001.
ISO 27001 is one of the most widely recognized standards in the world and certifies that the systems that support Google
Analytics and Google Analytics 360 meet the relevant requirements.
If you are interested in details related to Google’s use of data from sites and applications that use Google services,
we encourage you to read this information: https://policies.google.com/technologies/partner-sites.

Google Tag Manager – details
We use the Google Tag Manager tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA
and
allows us to manage tags, which are small pieces of code through which we are able to control user traffic and
behavior,
collect information about the effectiveness of ads and take action to improve our site. Google Tag Manager does not
collect any personally identifiable information about you, however, this tool triggers other tags, which in turn may
collect data.

Google AdWords – details
We use remarketing functions available within the Google AdWords system operated by Google LLC, 1600 Amphitheatre
Parkway, Mountain View, CA 94043, USA. We perform activities in this regard based on our legitimate interest in
marketing our own products or services.
When you visit our website, a remarketing cookie from Google 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
ads to you within the Google network depending on your behavior on our site. For example, if you view a certain
product,
this information will be noted by a remarketing cookie, which will make us able to target you with an ad for that
product or any other ad we deem appropriate. This advertisement will be displayed to you within the Google network
when
you use the Internet, browse other websites, etc.
We emphasize that we, using Google Ads, do not collect any data that would allow you to be identified. The possible
compilation of data in such a way that it acquires the character of personal data may be carried out on Google’s
part,
but to this extent we are no longer responsible, since Google performs these activities on the basis of the
agreement
concluded with you as a user of Google services.
We, using Google AdWords, are only able to define the audience groups we would like our ads to reach. Based on this,
Google decides when and how it will present our advertisement to you.
Further processing of information takes place only if you have given your consent to Google to link your browsing
history to your account and to use information from your Google account to personalize the ads that are displayed on
the
websites. In such a situation, Google will use your data to create and define target group lists for remarketing
purposes on different devices. For this purpose, Google temporarily combines the information it collects with other
data
it has to create targeting groups.
If you do not want to receive personalized ads, you can manage your ad settings directly on Google’s website:
https://adssettings.google.com/.
If you are interested in details related to Google’s use of data from sites and applications that use Google
services,
we encourage you to read this information: https://policies.google.com/technologies/partner-sites.

Google AdSense – details
We display advertisements on our sites within the Google AdSense network operated by Google LLC, 1600 Amphitheatre
Parkway, Mountain View, CA 94043, USA. We perform activities in this regard based on our legitimate interest in
monetizing the content we publish.
Our website, in connection with the display of ads on it within the AdSense network, contains ad tags that issue a
command to your web browser to send a request for advertising content from Google’s servers. Along with the
advertising
content, the server also sends a cookie. Cookies are used to display ads based on your previous visits to our site
or
other websites. AdSense also uses cookies to improve the quality of ads. Common uses include targeting ads based on
topics of interest to you, improving campaign performance reports and skipping ads you’ve already seen.
We emphasize that we, using Google AdSense, do not collect any data that would allow you to be identified. The
possible
compilation of data in such a way that it acquires the character of personal data may be carried out on Google’s
part,
but in this respect we are no longer responsible, since Google performs these activities on the basis of the
agreement
concluded with you as a user of Google services.
Further processing of information takes place only if you have given your consent to Google to link your browsing
history to your account and to use information from your Google account to personalize the ads that are displayed on
the
websites. In such a situation, Google will use your data to create and define target group lists for remarketing
purposes on different devices. For this purpose, Google temporarily combines the information it collects with other
data
it has to create targeting groups.
If you do not want to receive personalized ads, you can manage your ad settings directly on Google’s website:
https://adssettings.google.com/.
If you are interested in details related to Google’s use of data from sites and applications that use Google
services,
we encourage you to read this information: https://policies.google.com/technologies/partner-sites.

Facebook Custom Audiences – details
As part of the Facebook Ads system provided by Facebook Inc., 1601 S. California Ave., Palo Alto, CA 94304, USA, we
use
the Custom Audience Groups feature to target specific groups of users with targeted advertising messages. We perform
activities in this regard based on our legitimate interest in marketing our own products or services.
In order to target you with ads personalized to your behavior on our site, we have implemented the Facebook Pixel
within
our site, which automatically collects information about your use of our site. The information collected in this way
is
mostly transmitted to Facebook’s servers, which may be located around the world, particularly in the United States
of
America (USA).
The information collected as part of Facebook Pixel is anonymous, i.e. it does not allow us to identify you.
Depending
on your activity on our pages, you may end up in a specific audience, but we do not in any way identify individuals
belonging to these groups.
However, we would like to inform you that Facebook may combine the information it collects with other information
about
you collected through your use of Facebook and use for its own purposes, including marketing. Such activities of
Facebook are no longer dependent on us, and you can look for information about them directly in Facebook’s privacy
policy: https://www.facebook.com/privacy/explanation. From your Facebook account, you can also manage your privacy
settings. Here you will find useful information in this regard: https://www.facebook.com/ads/settings.

Social media tools – details
Our website uses plug-ins, buttons and other social media tools, collectively referred to as “plug-ins”, provided by
social networks such as Facebook, Instagram, LinkedIN, Twitter, Pinterest.
When you view our website containing a plug-in of a particular social network, your browser sends information to the
administrator of that social network about your visit. Since the plug-in is a fragment of a social network embedded
in
our website, your browser sends information about the request to download the content of a particular social network
to
our website.
The plug-ins collect certain information about you, such as your user ID, the site you visited, the date and time,
and
other browser information.
Social network administrators use some of this information to personalize the viewing conditions of our site. For
example, when you visit a page with a “Like” button, the social network administrator needs information about who
you
are to show you which of your friends also like our page.
Information collected by plugins may also be used by social network administrators for their own purposes, such as
improving their own products, creating user profiles, analyzing and optimizing their own activities, and targeting
advertisements. We have no real influence on how the information collected by the plugins is then used by the social
network administrators. You can look for details in this regard in the rules and privacy policies of individual
social
networks.
Social network plug-ins collect and transmit information to the administrators of these sites even when you browse
our
site without being logged into your social network account. Then, however, the browser sends a more limited set of
information.
If you have logged in to one of the social networks, the site administrator will be able to directly attribute your
visit to our site to your profile on the respective social network.
If you do not want social networks to attribute the data collected during your visit to our website directly to your
profile on a particular service, then you must log out of that service before visiting our website. You can also
completely prevent plug-ins from loading on the site by using the appropriate extensions for your browser, such as
script blocking.
In addition, the use of certain plug-ins may involve the publication of certain information within your social
profiles.
For example, information about clicks on 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 site, that sharing will naturally show up on
your
profile.
As for the details related to the processing by social network administrators of information collected by plug-ins,
in
particular the purpose and scope of data collection and its further processing and use by the administrators, as
well as
the possibility of contacting you and your rights in this regard and the possibility of making settings to ensure
the
protection of your privacy, you will find everything in the privacy policies of the individual service providers:

• Facebook – https://www.facebook.com/privacy/explanation
• Twitter – https://twitter.com/en/privacy
• LinkedIN – https://www.linkedin.com/legal/privacy-policy
• Instagram – https://www.facebook.com/help/instagram/155833707900388
• Pinterest – https://policy.pinterest.com/pl/privacy-policy

Hotjar – details
We use the Hotjar tool to better understand your needs and to optimize our website for your user experience, which
is
our legitimate interest. The tool is provided by a third party entity, i.e. Hotjar Limited, Level 2, St Julian’s
Business Centre, 3, Elia Zammit Street, St Julian’s STJ 1000, Malta.
Hotjar records every visitor to our site and allows us to play a video recording of their traffic on our site, as
well
as generate so-called heat maps. Within the Hotjar tool, we do not have access to information that allows us to
identify
you, as Hotjar does not record the process of filling out forms. The information we have access to within Hotjar is,
in
particular:

• information about the operating system and web browser you are using
• The subpages you view within our service
• time spent on our site and its sub-sites
• transitions between different sub-pages within our site
• The source from which you go to our site
• places you click the mouse

In order to use Hotjar, we have implemented a special Hotjar tracking code in the code of our site. The tracking code
uses cookies from Hotjar Limited. The information collected through cookies is stored by Hotjar as part of a
pseudonymous user profile. Neither Hotjar nor we use this information to identify you.
You may object to Hotjar’s creation of your user profile, Hotjar’s storage of information about your use of our
site,
and Hotjar’s use of cookies here: https://www.hotjar.com/legal/compliance/opt-out.
If you are interested in details related to Hotjar’s data processing, we encourage you to read Hotjar’s privacy
policy:
https://www.hotjar.com/legal/policies/privacy.

YouTube – details
YouTube widgets are embedded on our pages, allowing you to play recordings available on YouTube directly from our
pages.
YouTube is operated by Google LLC.
Videos are embedded on the site in privacy mode. Based on information provided by YouTube, this means that no
cookies
are stored on your device, nor does Google collect any information about you until you play the video.
When you play a video, YouTube saves cookies on your device and receives information that you played the video from
a
specific website, even if you do not have a Google account or are not logged in at the time. If you are logged into
a
Google account, this service provider will be able to directly associate your visit to our site with your account.
The
purpose and scope of data collection and their further processing and use by Google, as well as the possibility of
contacting us and your rights in this respect and the possibility of making settings to ensure your privacy are
described in Google’s privacy policy.
If you do not want Google to attribute the 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 plug-ins from loading on the site by
using
the appropriate extensions for your browser, such as script blocking.
The information collected as part of the cookies associated with YouTube videos embedded on our pages is used by
Google
to ensure the correct and safe functioning of the widget, analysis and optimization for the services provided by
YouTube, as well as for personalization and advertising purposes.
Please note that by playing recordings available on YouTube, you are using services provided electronically by
Google
LLC. Google LLC is an independent, third-party provider of electronic services to you. You can look for details on
YouTube’s terms of use, including privacy protection, in documents provided directly by YouTube:

• regulations: https://www.youtube.com/t/terms
• privacy policy: https://policies.google.com/privacy

Vimeo – details
Vimeo widgets are embedded on our pages, allowing you to play recordings available on Vimeo directly from our pages.
The
Vimeo service is operated by Vimeo INC.
Videos are embedded on the site in privacy mode. Based on information provided by Vimeo, this means that no cookies
are
stored on your device, nor does Vimeo collect any information about you until you play the video.
When you play a recording, Vimeo saves cookies on your device and receives information that you played the recording
from a specific website, even if you do not have a Vimeo account or are not currently logged in. If you have logged
into
your Vimeo account, this service provider will be able to directly associate your visit to our site with your
account.
The purpose and scope of data collection and their further processing and use by Vimeo, as well as the possibility
of
contacting us and your rights in this regard and the possibility of making settings to ensure your privacy are
described
in Vimeo’s privacy policy.
If you do not want Vimeo to attribute the 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 plug-ins from loading on the site by
using
the appropriate extensions for your browser, such as script blocking.
The information collected through cookies related to videos from Vimeo embedded on our pages is used by Vimeo to
ensure
the correct and safe functioning of the widget, analysis and optimization for the services provided by YouTube, as
well
as for personalization and advertising purposes.
Please note that by playing the recordings available on Vimeo, you are using the services provided electronically by
Vimeo INC, 555 West 18th Street, New York, New York 10011 is a stand-alone, independent entity providing electronic
services to you. You can look for details on Vimeo’s terms of use, including privacy protection, in documents
provided
directly by Vimeo:

• regulations: https://www.vimeo/terms
• privacy policy: https://vimeo.comm/privacy

17: Do we track your behavior taken within our site?

Yes, we use Google Analytics, Google AdWords, Hotjar and Facebook Custom Audiences tools that involve collecting
information about your activities on our site. These tools are described in detail under the question on third-party
cookies, so we will not repeat that information here either.

18: Are we targeting you with targeted ads?

Yes, we use Facebook Ads and Google Ads, where we can target ads to specific groups defined based on various criteria
such as age, gender, interests, occupation, job, activities previously undertaken on our site. These tools were
described in detail within the question on third-party cookies, 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 specific tools,
behavioral advertising, cookie consent, etc. Nevertheless, we have once again gathered this information in one place
for your convenience. Below you will find a list of options for managing your privacy.

• cookie settings within your web browser
• Browser plug-ins that support cookie management, e.g. Ghostery
• Additional software that manages cookies
• incognito mode in the web browser
• behavioral advertising settings, such as youronlinechoices.com
• A mechanism for managing cookies from within our website
• Google Analytics Opt-out:
• Google Ads Settings: https://adssettings.google.com/
• Facebook Ads Settings: https://www.facebook.com/ads/settings
• HotJar Opt-out: https://www.hotjar.com/legal/compliance/opt-out

20: What are server logs?

Use of the site involves sending queries to the server where the site is stored. Each query directed to the server is
recorded in the server logs.
The logs include, among other things, your IP address, the date and time of the server, information about the web
browser and the operating system you are using. Logs are saved and stored on the server.
The data stored in the server logs are not associated with specific individuals using the site and are not used by
us to
identify you.
The server logs are only auxiliary material for the administration of the site, and their contents are not disclosed
to
anyone except those authorized to administer the server.

21: Is there anything else you should know about?

As you can see, the topics of personal data processing, the use of cookies and the management of privacy in general are quite complex. We have done our best to ensure that this document provides you with the most far-reaching knowledge
on
the issues that are important to you. If anything is unclear to you, you would like to learn more or simply discuss
your
privacy, please email us at office@managershaven.com.