Privacy Policy and Use of Cookies


This document outlines how we handle personal data and utilize cookies, governed by the entity specified as the Controller.

Our policy serves to meet the informational requirements stipulated in Articles 13 and 14 of the General Data Protection Regulation (GDPR) – Regulation (EU) 2016/679, passed by the European Parliament and Council on 27 April 2016, which focuses on the protection and mobility of personal data.

This policy applies to:

a) Individuals affiliated with our clients and contractors, with whom we interact for current or potential business engagements.

b) Persons reaching out to us or those we might contact, through means such as phone, email, mail, chat, or other communication channels.

c) Users visiting our website at

Stay informed: This policy may undergo changes occasionally. For the most recent version, please refer back to this page regularly.

Personal Data Collection

The entity responsible for managing your personal data is Clarna Agency, located at Mogilska 16/7, 30-516 Kraków. You can refer to this entity as the “Controller” or simply “us”.

For any queries, please reach out via email at:

Types of Personal Data We Collect

1. Employees or Associates of Clients and Contractors:
If you are our point of contact at a client or contractor firm (either existing or prospective), we gather your personal information to ensure we deliver top-notch marketing services. This data typically comprises your full name, contact details, and the specific issues assigned to you for communication or representation purposes.

2. Individuals Contacting Us:
For those reaching out to us (and not affiliated with our clients or contractors) or if we contact you (perhaps upon a recommendation from a client or partner), we will only use your personal information to maintain consistent communication. We may store details like your full name, contact info, or any relevant information pertaining to your inquiry or received from our partners.

3. Website Users:
For our website’s users, we collect basic data to enhance your browsing experience and manage our services. This includes metrics related to website usage, access frequency, and peak traffic times.

How we collect your personal data?

  1. Directly from You: This is often the result of interactions you have with us. It could be through emails you send us, activities you perform on our website, or if you make use of tools like our contact form or chat feature.
  2. From Third Parties: Sometimes, we might receive your data from other entities, such as your employer, colleagues, or a client who provides us with relevant information.
  3. Publicly Available Sources: We might also access your personal data from online platforms that are open to the public, including but not limited to, your personal websites or professional profiles.
  4. Through Cookies: Our website utilizes cookies, which gather data based on your browser settings and online activity. This helps us understand how visitors interact with our site and make improvements accordingly.

Purpose and Legal Basis for Using Your Personal Data

  1. Employees or Associates of Clients and Contractors:
    • Purpose: We process your personal data to engage with you on matters related to existing or potential contracts between us and the entity you represent. This includes presenting offers, negotiations, receiving orders, and answering questions.
    • Legal Basis: Our actions are underpinned by our legitimate interests (Article 6 (1) (f) of the GDPR). This interest lies in sustaining ongoing contact with our clients and contractors (their employees or associates) and fostering relationships within our business operations.
  2. Individuals Contacting Us:
    • Purpose: Your personal data aids us in initiating and sustaining communication with you, answering your queries, presenting collaboration offers, and exchanging pertinent correspondence.
    • Legal Basis: Processing your data is justified by our legitimate interests (Article 6 (1) (f) of the GDPR). These interests include maintaining continuous business-related communication with you.
  3. Website Users:
    • Purpose: We harness your personal data to ensure the safety and proper functioning of our website. Additionally, we strive to tailor the content and operations of the site to user preferences through analytical and statistical pursuits.
    • Legal Basis: Our operations are backed by our legitimate interests (Article 6 (1) (f) of the GDPR). These interests focus on guaranteeing the security and optimal performance of our website, and modifying its content and functionalities to cater to user needs via analytics and statistics.
  4. Defence of Legal Claims:
    • Purpose: Across all the aforementioned categories, we might process personal data to determine, enforce, or protect against potential legal claims.
    • Legal Basis: The grounding for this processing is our legitimate interests (Article 6 (1) (f) of the GDPR), which revolves around the capability to identify, enforce, or safeguard against possible legal allegations.

Recipients of Your Personal Data

Regardless of your association with us, whether as an employee or associate of our clients and contractors, someone who contacts us, or as a website user:

  • Service Providers: We may share your personal data with entities that offer advisory services to us, including but not limited to legal, tax, and accounting consultants. Additionally, IT service providers assisting us may also have access to your data.
  • Legal Obligations: In certain scenarios, we might be compelled to disclose your personal data to other entities if such an action is mandated by the law. Rest assured, any such disclosure will always align with the prevailing legal provisions.

Transfer of Personal Data Outside the EEA

Your personal data might be shared with entities in countries outside the European Economic Area (often termed as “third countries”). Such transfers are carried out to meet service requirements, especially IT-related services. But, it’s worth noting that any such transfer is based on legally robust safeguards to ensure that your data enjoys a protection level similar to what it would receive within the EEA. Common mechanisms to achieve this include the standard contractual clauses endorsed by the European Commission.

To delve deeper into our data transfer protection mechanisms or to get a copy of these safeguards, feel free to reach out using the contact details mentioned in the “Who is the controller of your personal data?” section.

Ensuring the Security of Your Personal Data

Your data’s security is paramount to us. Our commitment to safeguarding your information is backed by significant measures aimed at averting unauthorised access or potential misuse. To fortify data protection, we’ve integrated both technical and organisational strategies. Examples include the deployment of SSL certificates for our website and multi-step authentication processes.

Duration and Preservation of Your Personal Data

How long we retain your personal data is determined by the specific purpose for which we collected it:

  1. Employees or Associates of Our Clients and Contractors: We will retain your personal data for as long as our cooperation with the client or contractor you represent lasts.
  2. Contacting Persons: Your data will be kept for the duration of our correspondence. Following the end of active correspondence, your data will be retained for up to 2 years, facilitating the possibility of re-establishing contact or maintaining existing relations.
  3. Website Users: We will hold onto your data for the life span of the cookies or other comparable technologies employed on our website. This means your personal data will be stored until the expiration of these cookies or until you actively remove them.

Moreover, it’s worth noting that if your personal data is used by us for purposes such as establishing, exercising, or defending against legal claims, we may retain this data for the duration that these claims can be legally pursued. This is in line with the limitations period for such claims.

Your Rights Regarding Your Personal Data

As an individual whose personal data is in our possession, you have several rights regarding your data. Here’s a detailed breakdown of your rights, and you can exercise any of these by getting in touch with us through the contact details provided under the “Who is controller of your personal data?” section. We assure you of a prompt response in alignment with the stipulations of relevant laws. Additionally, we might maintain records of your interactions to ensure the effective resolution of any concerns you raise.

  1. Right of Access: You can ask for confirmation regarding the processing of your personal data by us and request access to the said data and relevant information, based on Articles 13 and 14 of the GDPR.
  2. Right to Rectification: If any of your personal data we hold is incorrect, you have the right to request its correction. Depending on the context of the data processing, you can also complete any partial data.
  3. Right to Erasure: In specific scenarios (like when the data is no longer required for the purpose it was collected or if it was processed unlawfully), you have the right to ask us to erase your personal data. However, exceptions, as stated in Article 17 sec. 3 of the GDPR, might apply.
  4. Right to Restriction of Processing: In circumstances delineated in Article 18 sec. 1 of the GDPR, you can request that we limit the processing of your personal data. In such cases, except for storage, the data will be processed only with your consent or for the protection of rights of another entity or person or due to significant public interest.
  5. Right to Data Portability: For automated data processing based on consent or a contract, you can request a copy of your personal data in a structured and machine-readable format or ask us to transfer it to another entity.
  6. Right to Object: If we process data based on our legitimate interests, you can object to this processing if you have specific reasons related to your situation.
  7. Right to Withdraw Consent: If we process your data based on your consent, you can withdraw this consent at any time. It’s important to note that withdrawing consent won’t impact the processing that occurred before the withdrawal.

Always remember, these rights are designed to give you more control and understanding of how your data is used. You’re entitled to exercise these rights to ensure your personal information is treated with respect and transparency.

Implications of Not Submitting Personal Data

Understanding the importance and implications of not providing your personal data is vital. Here’s a summary based on the different categories:

  1. Employees or Associates of Our Clients and Contractors:
    • Voluntary Submission: It’s up to you to decide whether or not to provide your personal data.
    • Consequences: Not providing your data might make it challenging for us to maintain continuous communication with our clients and contractors. This could adversely impact our business relationships and operations.
  2. Contacting Persons:
    • Voluntary Submission: Sharing your personal data is a choice you make.
    • Consequences: If you decide not to share your data, it might prevent us from reaching out or responding to you.
  3. Website Users:
    • Voluntary Submission: You have the discretion to decide whether or not to share your personal data while using our website.
    • Consequences: Failing to provide necessary data might compromise the security and overall functionality of our website. Furthermore, we might not be able to tailor the website’s content and features to meet user needs.

Cookie Policy

Effective Date: 08-Sep-2023
Last Updated: 08-Sep-2023

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