Privacy Policy

  1. General provisions
    1. This Privacy Policy governs the principles of protection of the Users confidential data, including personal data, by the Controller which is ALTO Tax spółka z ograniczoną odpowiedzialnością with its registered seat in Warsaw (02-366), ul. Bitwy Warszawskiej 1920 r. 7, entered into the register of entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under KRS number: 0000465944, share capital: PLN 110.000, hereinafter referred to as “ALTO”.
    2. While maintaining the website www.altoadvisory.pl, ALTO endeavors to protect the right of the Users, specifically in terms of protection of privacy and data, handed to ALTO and related to the Users. These information (including personal data of the Users) is properly secured, and the on-line forms used to transfer these data are protected by SSL security protocol, which is why the process of transferring data is encrypted. While processing the personal data of the Users, ALTO gives special notice to protecting these data against accessing them by unauthorized persons, acquiring them by unauthorized persons, unlawful processing and against accidental loss, destruction or damage.
  2. Personal data
    1. While using the website www.altoadvisory.pl, the User might be asked to provide his personal data, necessary for providing services by ALTO:
      • a. while giving consent for subscribing to the Newsletter (first and last name, e-mail address),
      • b. while filling out the contact form (first and last name, phone number, e-mail address).
    2. Providing any of the personal data by the User is voluntary. Providing data stipulated in p. 2.1. is necessary for objectives, stipulated in p. 2.5.
    3. The Users may view content of the website www.altoadvisory.pl without prior registration and providing their personal data.
    4. Personal data of the Users being natural persons (including natural persons conducting an individual business activity) will be processed by given entities from ALTO group, acting as controller of the personal data subject to Regulation (EU) 2016/679 of The European Parliament and of The Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as “GDPR”).
      The User has the right to file a complaint to the President of the Office of Personal Data Protection if he considers that processing his data by ALTO is non-compliant with GDPR.
    5. Personal data of the Users will be processed in order to fulfil respective obligations arising from the agreements binding between ALTO and ALTO’s clients, as well as for marketing purposes, being legitimate interests pursued by ALTO, including services presented on website www.altoadvisory.pl. Personal data will be processed until the termination of providing the services, and after that – for archiving purposes within legally fixed period, or – if processed based on consent – until the consent for processing is revoked.
    6. The User’s personal data may be shared with entities, entitled to receive these data based on applicable provisions of law. Personal data of the Users may be also shared with or disclosed to – in necessary and required scope – third parties, including entities performing on behalf of ALTO activities related to the agreement concluded with the User, inter alia entities operating the IT infrastructure or entities providing documents archiving and destroying services.
    7. In circumstances and based on principles stipulated in art. 15-22 of GDPR, ALTO ensures that the User which personal data is processed may execute the rights arising from GDPR:
      • the right to obtain information from ALTO whether personal data is being processed,
      • the right to obtain access to own personal data (their copy) and to its rectification,
      • the right to demand erasure of personal data from ALTO’s databases, if:
        • personal data of the User is no longer necessary for purposes for which it has been collected or for which it is being processed,
        • the User has removed the consent the processing was based on, and there is no other legal basis for processing,
        • the User objects against processing and there are no other justified grounds for processing the data by ALTO, or objects against processing for marketing purposes,
        • personal data is processed unlawfully,
        • personal data must be erased in order to fulfil legal obligation arising from Polish or EU law.

        However, the User’s right to demand erasure of personal data cannot be executed to the extent where ALTO must process the data in order to fulfil legal obligation, or if further processing is necessary for the establishment, exercise or defense against legal claims.

      • the right to restrict processing – to withhold processing until the objections, reported by the User to ALTO, are explained; in case of restriction of processing, ALTO may process personal data solely under consent of the User (not concerning the possibility of its storage or processing for the purposes of establishment, exercise or defense against legal claims by ALTO),
      • the right to object against processing for marketing purposes; in case such objection is raised, ALTO will not be entitled to process the Users data for such purposes.

      The User may execute the abovementioned rights by:

      Should ALTO has justified doubts regarding the identity of the User, submitting his demand, ALTO may request for additional information, necessary for confirming the Users identity.
      If the personal data is processed on the basis of the consent of the User, the User has the right to withdraw the consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal. Withdrawal of the consent may be:

      • submitted via e-mail on: privacy@altoadvisory.pl,
      • submitted via traditional mail on the given address: ALTO, ul. Bitwy Warszawskiej 1920 r. 7, 02-366 Warszawa.

      The withdrawal of the consent will result in termination of ALTO’s services provision, to the extent provided in the withdrawal of the consent.

    8. In terms of the right to control the processing of own’s personal data, the User has inter alia right to submit a written, justified request regarding cessation of processing of the User’s data, due to his specific situation, as well as the right to submit the petition against processing of his data, in case of processing data by ALTO in order to fulfil ALTO’s legally justified purposes, or in case processing data by ALTO for marketing purposes, or against sharing the User’s personal data by ALTO with a other controller than ALTO.
    9. Confidential information regarding Users, including personal data of the Users, is protected by ALTO against accessing them by unauthorized persons, as well as against other cases of their exposure or loss and against destruction or unauthorized modification of given data and information by using proper technical and organizational security.
  3. “Cookies” files
    1. ALTO uses cookies files. Cookies files are small pieces of text information, stored on the User’s computer. They are sent by a Web server, for example after visiting some pages. Most often, they are used to facilitate and automate the use of the site by the User. The content of cookies does not allow identification of the User. Cookies files typically contain the name of the website from which they come, the time of storage on the hard drive and a unique number.
    2. Cookies files are used to store small User data, allowing him to automatically login or saving the preferences of interface, layout and language of the site. Information gathered with the use of cookies allows us to adjust the services and content to individual needs and preferences of the Users, as well as they allow us to define general statistics regarding the use of ALTO’s website by the Users.
    3. The User has the possibility to block cookies files or prevent only certain functions of cookies. In order to block or prevent only certain functions of cookies files, it is necessary to change the User’s web browser settings. Turning off in web browser’s settings the one that allows the browser to save “cookies” files generally does not prevent the User from using the ALTO’s website, although it might cause certain difficulties.
  4. Modifying the scope of Privacy Policy
    1. ALTO reserves the right to amend this Privacy Policy, in a discretionary and temporary manner.
    2. The modifications will consider any generally applicable provisions of law regarding personal data protection and will not infringe the rights of data subjects.
    3. Any modifications in this Privacy Policy will be published on website www.altoadvisory.pl and will be applicable for all of the Users from the moment of the publication.


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