Privacy policy

Privacy Policy

Version valid from August 23, 2023

This website has been prepared at the request of LUMOS ADVISORY Law and Tax Office. The content presented on this website is for information purposes only, does not constitute legal advice or an offer within the meaning of the Civil Code and does not involve the Law Firm’s liability due to their content, or due to any errors, omissions, or inaccuracies they may contain. The website does not constitute advertising.

The privacy policy describes the rules of processing information about you, including personal data and so-called cookie files (cookies).

1. General information – Personal data protection policy

  1. This policy applies to the Website operating at the url address:
  2. The Operator of the Website and the Administrator of personal data is Lumos Advisory Żemantowska and Dąbek Radcowie Prawni, Doradcy Podatkowi sp.j. Puławska 257 / 150, 02-769 Warsaw, correspondence address: Mokotowska 1, 00-640 Warsaw.
  3. Operator’s email address:
  4. The Operator is the Administrator of your personal data in relation to the data provided voluntarily on the Website.
  5. The Website uses personal data for the following purposes:
    • Presentation of offers or information.
  6. The Website performs the functions of obtaining information about users and their behavior in the following way:
    1. Through data entered voluntarily in the forms, which are entered into the Operator’s systems;
    2. By saving cookies in end devices.

2. Selected data protection methods used by the Operator

  1. The places of logging in and entering personal data are protected in the transmission layer (SSL certificate). Thanks to this, personal data and login details entered on the Website are encrypted on the user’s computer and can only be read on the destination server.
  2. An important element of data protection is regular updating of all software used by the Operator to process personal data, which in particular means regular updates of programming components.

3. Hosting

  1. The Website is hosted (technically maintained) on the servers of the operator: OVH.

4. Your rights and additional information on how the data is used

  1. In some situations, the Administrator has the right to transfer your personal data to other recipients if it is necessary to perform the contract concluded with you or to fulfill the obligations of the Administrator. This applies to the following groups of recipients:
    • persons authorized by the operator, employees, and associates who must have access to personal data to perform their duties,
    • hosting company,
    • mailing companies,
    • companies that support SMS messages,
    • companies with which the Administrator cooperates in the field of its marketing,
    • couriers,
    • insurers,
    • law firms and debt collectors,
    • banks,
    • payment operators,
    • public authorities.
  2. The legal basis for processing your personal data is:

a) Art. 6 sec. 1 letter b of the GDPR, i.e., the necessity of processing data to perform a contract to which you are a party or to take action at your request before entering into a contract, or

b) Art. 6 sec. 1 letter c of the GDPR, i.e., the necessity to fulfill legal obligations incumbent on the Administrator, or

c) Art. 6 sec. 1 letter f of the GDPR, i.e., for analytical and statistical purposes as part of the legitimate interest of the Administrator, or

d) Art. 6 sec. 1 letter f of the GDPR, i.e., the Administrator’s legitimate interest, which is to establish, investigate, or defend claims until their limitation period or the end of relevant proceedings if initiated within this period, or

e) Art. 6 sec. 1 letter a of the GDPR, i.e., your consent to the processing of personal data for specific purposes, where other legal bases for processing personal data do not apply – e.g., in the case of providing the newsletter service.

  1. Your personal data is processed by the Administrator for no longer than is necessary to perform activities related to them specified by separate regulations (e.g., on accounting). As for marketing data, they will not be processed for more than 3 years.
  2. Personal data processed based on your voluntary consent, where other legal bases for processing personal data do not apply – e.g., in the case of providing a newsletter service, sending marketing information – will not be processed for more than 3 years or until you withdraw your given consent.
  3. You have the right to request from the Administrator:
    • access to personal data concerning you,
    • their rectification,
    • deletion,
    • restriction of processing,
    • data portability.
  4. You have the right to object to processing as referred to in point 4.2 c) regarding the processing of personal data for the purpose of pursuing legally justified interests by the Administrator, including profiling. However, the right to object will not be exercised if there are valid legitimate grounds for processing, superior to your interests, rights, and freedoms, especially the establishment, exercise, or defense of claims.
  5. You have the right to lodge a complaint with the President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw.
  6. Providing personal data is voluntary but necessary for the operation of the Website and the provision of services electronically.
  7. Actions may be taken with respect to you consisting of automated decision-making, including profiling, in order to provide services under the concluded contract and for the Administrator to conduct direct marketing.
  8. Personal data is not transferred to third countries within the meaning of provisions on personal data protection. This means that the Operator does not transfer them outside the European Union.

5. Information in forms

  1. The Website collects information provided voluntarily by the user, including personal data if provided.
  2. The Website may save information about connection parameters (time stamp, IP address).
  3. In some cases, the Website may save information that facilitates linking data in the form with the email address of the user completing the form. In this case, the user’s email address appears within the URL of the page containing the form.
  4. Data provided in the form is processed for the purpose resulting from the specific form’s function, e.g., processing service requests or commercial contacts, registering services, etc. Each time, the context and description of the form clearly inform its purpose.

6. Operator Logs
Information about user behavior on the Website may be logged. This data is used for administering the Website.

7. Significant Marketing Techniques

  1. The operator uses statistical analysis of website traffic through Google Analytics (Google Inc. based in the USA). The operator does not provide personal data to the operator of this service, only anonymized information. The service is based on the use of cookies on the user’s end device. Regarding information about user preferences collected by the Google advertising network, the user can view and edit information resulting from cookies using the tool:

8. Newsletter and marketing information

  1. A newsletter service may be launched on the Website. If the newsletter service is launched, the user will be able to subscribe to the newsletter run by LUMOS ADVISORY (“Newsletter”) and receive marketing information.
  2. Subscribing is voluntary, and you can unsubscribe at any time.
  3. When subscribing to the newsletter, the user must provide the following categories of personal data: email address, name, and consent to their processing by the Administrator, which is necessary for subscription.
  4. Providing personal data for marketing purposes is voluntary.
  5. The above data is collected and will be processed solely for the purpose of sending the newsletter and marketing information to the email address provided by you.
  6. The processing of personal data provided for sending the newsletter and marketing information is based on your voluntary consent. You can withdraw your consent at any time.
  7. The administrator may profile your personal data. This means that the collected information, such as the postal code provided by you and declared interests, can be used to tailor communication to your needs. In this case, however, your data is not used for profiling involving automated decisions affecting your legal situation (i.e., algorithms are not used to make decisions affecting your individual rights).
  8. The administrator processes personal data indicated in paragraph 3 based on: Article 6(1)(a) of GDPR, i.e., your consent to processing personal data for specific purposes, namely for direct marketing through a newsletter.
  9. We send the newsletter only based on your voluntary consent. You can withdraw your consent at any time.

9. Cookies policy

  1. The Website uses cookies.
  2. Cookies are IT data, particularly text files, stored in the user’s end device of the Website and intended for using the Website’s internet pages. Cookies typically contain the name of the website they come from, their storage time on the end device, and a unique number.
  3. The entity placing cookies on the user’s end device and accessing them is the Website Operator.
  4. Cookies are used for the following purposes:
    1. to achieve the objectives set out above in the “Significant Marketing Techniques” section;
  5. The Website uses two basic types of cookies: “session” cookies and permanent “persistent” cookies. Session cookies are temporary files stored on the user’s end device until logging out, leaving the Website, or turning off the software (web browser). “Persistent” cookies are stored on the user’s end device for the time specified in the cookie file parameters or until they are deleted by the user.
  6. Software for browsing websites (web browser) usually allows cookies to be stored on the user’s end device by default. Website users can change settings in this regard. The web browser allows you to delete cookies. It is also possible to automatically block cookies. Detailed information on this topic can be found in the help or documentation of the web browser.
  7. Limiting the use of cookies may affect some functionalities available on the Website.
  8. Cookies placed on the user’s end device of the Website may also be used by entities cooperating with the Website Operator, particularly the following companies: Google (Google Inc. based in the USA), Facebook (Facebook Inc. based in the USA), Twitter (Twitter Inc. based in the USA).

10. Managing Cookies – How to Give and Withdraw Consent in Practice?

  1. If you do not wish to allow the use of cookies, you can adjust your browser settings. The Administrator notes that disabling cookies necessary for authentication processes, security, and maintaining user preferences may potentially hinder usage and, in extreme cases, prevent access to websites.
  2. To manage cookie settings, choose your web browser from the list below and follow the provided instructions:

Mobile devices:

Any personal data entered into the contact form with the Law Firm available on the Law Firm’s Website is processed in accordance with the Personal Data Protection Policy published on that Website.

11. Change in Privacy Policy

Any changes to the Privacy Policy will be published on the website and will be applicable only from the date of their publication for future interactions.