 
PRIVACY POLICY 
GenerateCreatives.com 
 
DEAR USER  
in this Policy you will find the following information 
 
DEFINITIONS ................................................................................................................................ 2 
DATA PROCESSING IN CONNECTION WITH THE USE OF THE PORTAL AND APPLICATIONS ............... 2 
PURPOSES AND LEGAL BASIS OF DATA PROCESSING IN THE PORTAL AND APPLICATION ................. 2 
MARKETING ................................................................................................................................. 4 
SOCIAL NETWORKS ...................................................................................................................... 5 
COOKIES AND SIMILAR TECHNOLOGY ........................................................................................... 6 
PERIOD OF PERSONAL DATA PROCESSING..................................................................................... 7 
YOUR ENTITLEMENTS ................................................................................................................... 7 
DATA RECIPIENTS ......................................................................................................................... 8 
TRANSFER OF DATA OUTSIDE THE EOG ......................................................................................... 8 
SECURITY OF PERSONAL DATA ...................................................................................................... 9 
CONTACT DETAILS ........................................................................................................................ 9 
PRIVACY POLICY CHANGES ........................................................................................................... 9

DEFINITIONS

1. Administrator (We) - JustFilm.it sp. z o.o. with its registered seat in Warsaw at Puławska street

12/3, 2nd floor, 02-566 Warsaw, Poland whose registration files are kept by the District Court for

the Capital City of Warsaw in Warsaw, XIII Economic Department of the National Court Register

under the KRS number: 0001032165, having NIP number: 5214016076, with the share capital of

PLN 5,000.00, having, e-mail address: hello@generatecreatives.com and tel number: +48 452 113

114.

2. Personal data - all information about a natural person identified or identifiable by one or more

specific factors that determine physical, physiological, genetic, mental, economic, cultural or

social identity, including device IP, location data, Internet ID and information collected through

cookies and other similar technology.

3. Policy - this Privacy Policy.

4. GDPR - Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016

on the protection of individuals with regard to the processing of personal data and on the free

movement of such data and repealing Directive 95/46/EC.

5. Portal - the web portal owned by the Administrator and available at https://justfilm.it.

6. Application - software operating in the SaaS (Software as a Service) model, based on cloud

computing, installed on and managed by the Administrator's servers, made available through a

web browser at https://app.justfilm.it.

7. User (You) - any natural person who visits the Portal or Application or uses one or more of the

services or functionalities described in the Policy.

8. Regulations - regulations of the Portal and Application.

PROCESSING OF DATA IN CONNECTION WITH THE USE OF PORTAL OR APPLICATION

In connection with your use of the Portal or the Application, we collect your data to the extent

necessary to provide the particular services offered, as well as information about your activity on the

Portal or the Application. The detailed rules and purposes of the processing of personal data collected

during your use of the Portal or the Application are described below.

PURPOSES AND LEGAL BASIS OF DATA PROCESSING IN PORTAL AND APPLICATION

USE OF A PORTAL OR APPLICATION

1. We process personal data of all persons using the Portal or the Application (including IP address

or other identifiers and information collected through cookies or other similar technologies), and

who are not registered Users (i.e., persons without an account) for the following purposes:

1.1. for the purpose of providing services electronically in terms of providing Users with access to

content collected on the Portal or Application - in which case the legal basis for processing is

the necessity of processing to perform the agreement (Article 6(1)(b) GDPR);

1.2. for analytical and statistical purposes, in which case the legal basis for the processing is our

legitimate interest (Article 6(1)(f) GDPR) consisting in conducting analyses of Users' activities,

as well as their preferences in order to improve the functionalities used and services

provided;

1.3. for the purpose of possible establishment, investigation or defense of claims - the legal basis

for the processing is our legitimate interest (Article 6(1)(f) GDPR) in protecting our rights;

1.4. for marketing purposes (ours and those of our partners), in particular related to the

presentation of behavioral advertising - the principles of processing personal data for

marketing purposes are described in the "MARKETING" section.

2. Your Activity on the Portal or Application, including your personal information, is recorded in

system logs. The information collected in the logs is processed primarily for purposes related to

the provision of services. We also process them for technical, administrative purposes, for the

purposes of ensuring the security of the IT system and the management of this system, as well as

for analytical and statistical purposes - in this regard, the legal basis for processing is our legitimate

interest (Article 6(1)(f) GDPR).

3. We process your data provided in the Application in the Azure cloud computing provided by

Microsoft.

4. The portal is hosted by CloudFlare.

REGISTRATION

5. During registration, you will be asked to provide the data necessary to create and operate your

account. In order to facilitate service, you can provide additional data, thereby giving your consent

to their processing. Such data can be deleted at any time. Provision of data marked as mandatory

is required to create and operate your account, and failure to provide such data will result in our

inability to create your account. Provision of other data is voluntary.

6. Your personal data is processed:

4.1. for the purpose of providing services related to the maintenance and operation of the

account - the legal basis for processing is the necessity of processing for the performance of

the contract (Article 6(1)(b) GDPR), and with regard to data provided optionally - the legal

basis for processing is consent (Article 6(1)(a) GDPR);

4.2. for analytical and statistical purposes - the legal basis for the processing is our legitimate

interest (Article 6(1)(f) GDPR) consisting in conducting analyses of Users' activity on the Portal

and Application, as well as the way they use their account, and their preferences in order to

improve the functionalities used;

4.3. for the purpose of possible establishment, investigation or defense of claims - the legal basis

for the processing is our legitimate interest (Article 6(1)(f) GDPR) in protecting our rights;

4.4. for marketing purposes (ours and those of our partners) - the principles of processing

personal data for marketing purposes are described in the "MARKETING" section.

5. In the event that the Application allows you to log in via other services (such as, for example,

Facebook, Google, Instagram, Twitter, Apple), we will only retrieve from your account within the

respective service the data necessary to register and operate your account. By changing the plug-

in's settings yourself, you can easily expand the scope of the downloaded data to include such

data as may be useful for using your account functionality.

6. We use the Auth0 authorization system for logging in, registering and storing User account data.

CHAT

7. If you contact us via chat, we will process your personal data for the following purposes:

7.1. for the purpose of processing your request - the legal basis for the processing is the necessity

for the performance of a contract to which the data subject is a party, or to take action at the

request of the data subject prior to entering into a contract (Article 6(1)(b) GDPR);

7.2. for analytical and statistical purposes - the legal basis for the processing is our legitimate

interest (Article 6(1)(f) GDPR) consisting in conducting analyses of Users' activity on the Portal

and the Application, as well as the way they use them, and their preferences in order to

improve the functionalities used;

7.3. for the purpose of possible establishment, investigation or defense of claims - the legal basis

for the processing is our legitimate interest (Article 6(1)(f) GDPR) in protecting our rights.

8. We use an external chat provided by Crisp.

USE OF PAID SERVICES

9. If you place an order with us (to purchase a service), we will process your personal data for the

following purposes:

9.1. for the purpose of fulfilling a submitted order - the legal basis for processing is the necessity

of processing for the performance of the contract (Article 6(1)(b) GDPR); for data provided

optionally, the legal basis for processing is consent (Article 6(1)(a) GDPR);

9.2. in order to comply with statutory obligations incumbent on us, and arising in particular from

tax and accounting regulations - the legal basis for processing is a legal obligation (Article

6(1)(c) GDPR);

9.3. for analytical and statistical purposes - the legal basis for processing is our legitimate interest

(Article 6(1)(f) GDPR) consisting in conducting analyses of your activity on the Portal or

Application, as well as your shopping preferences in order to improve the functionalities

used;

9.4. for the purpose of possible establishment, investigation or defense of claims - the legal basis

for processing is our legitimate interest (Article 6(1)(f) GDPR) in protecting our rights.

10. We use EasyCart payment system, which allows you to make payments via Stripe, Przelewy24 and

BLIK (the payment method is selected by the User).

MARKETING

11. We process your personal data to carry out marketing activities, which may consist of:

11.1. displaying marketing content that is not tailored to your preferences (contextual

advertising);

11.2. displaying marketing content that matches your interests (behavioral advertising);

11.3. targeting e-mail notifications of interesting offers or content, which in some cases contain

commercial information (newsletter service);

11.4. Directing e-mail notifications about offers or promotions of our own services or on behalf of

third parties, which in some cases contain commercial information, in connection with an

interrupted shopping process (abandoned shopping cart);

11.5. carrying out other activities related to direct marketing of goods and services (sending

commercial information by electronic means and telemarketing activities).

12. In order to carry out marketing activities, in some cases we use profiling (if you agree). This means

that through automated data processing, we evaluate selected factors about individuals in order

to analyze their behavior or create a forecast for the future.

13. The legal basis for processing your personal data for marketing purposes is always your consent

(Article 6(1)(a) of the DPA), which you can withdraw at any time.

CONTEXTUAL ADVERTISING

14. We process your personal data for marketing purposes in connection with targeting you with

contextual advertising, i.e. advertising that is not tailored to your preferences. The processing of

your personal data is then done in connection with the fulfillment of our legitimate interest

(Article 6(1)(f) of the GDPR).

BEHAVIORAL ADVERTISING

15. We and our trusted partners process your personal data, including personal data collected

through cookies and other similar technologies, for marketing purposes in connection with

targeting you with behavioral advertising, i.e. advertising that is tailored to your preferences. The

processing of personal data then includes profiling. The use of personal data collected through

this technology for marketing purposes, in particular for the promotion of services and goods of

third parties, requires your consent, which you may withdraw at any time.

NEWSLETTER

16. We provide the newsletter service under the terms of the Terms and Conditions only if you

provide us with your e-mail address for this purpose. Provision of data is required to provide the

newsletter service, and failure to do so will result in the inability to send the newsletter.

17. We use an external entity, Brevo (formerly Sendinblue), to handle our mailing list.

18. Personal data collected for the newsletter are processed:

18.1. for the purpose of providing the newsletter mailing service - the legal basis for processing is

the necessity of processing for the performance of the contract (Article 6(1)(b) of the DPA);

18.2. in the case of targeting you with marketing content within the newsletter - the legal basis

for processing, including profiling, is our legitimate interest (Article 6(1)(f) GDPR) in

connection with your consent to receive the newsletter;

18.3. for analytical and statistical purposes - the legal basis of the processing is our legitimate

interest (Article 6(1)(f) GDPR) consisting in conducting analyses of your activity on the Portal

or Application in order to improve the functionalities used;

18.4. for the purpose of possible establishment, investigation or defense of claims - the legal basis

for processing is our legitimate interest (Article 6(1)(f) GDPR).

DIRECT MARKETING

19. Your Personal Data may also be used by us so that we can target you with marketing content

through various channels, i.e. via email, via MMS / SMS or by phone. We only undertake such

activities if you have given your consent, which you may withdraw at any time.

SOCIAL NETWORKS

We process your personal data when you visit our profiles maintained on social media (Facebook,

YouTube, Instagram, Twitter, TikTok). This data is processed solely in connection with the operation

of the profile, including to keep you informed about our activities and to promote various events,

services and products. The legal basis for processing personal data for this purpose is our legitimate

interest (Article 6(1)(f) GDPR) in promoting our own brand.

COOKIES AND SIMILAR TECHNOLOGY

Cookies are small text files installed on your device when you browse the Portal or Application. Cookies

collect information that makes it easier for you to use the website - for example, by remembering your

visits and the actions you perform.

We may use the following types of cookies within the Portal and Application:

"SERVICE" COOKIES

20. We use so-called service cookies primarily to provide you with electronically delivered services

and to improve the quality of these services. In this regard, we and other entities providing

analytical and statistical services to us use cookies to store information or access information

already stored on your telecommunications end device (computer, phone, tablet, etc.). Cookies

used for this purpose include:

20.1. cookies with data you input (session ID) for the duration of the session (user input cookies);

20.2. authentication cookies used for services that require authentication for the duration of the

session (authentication cookies);

20.3. Security cookies, such as those used to detect authentication abuse (user centric security

cookies);

20.4. multimedia player session cookies (e.g. flash player cookies), for the duration of the session

(multimedia player session cookies);

20.5. Persistent cookies used to personalize the user interface for the duration of the session or

slightly longer (user interface customization cookies),

20.6. cookies used to monitor website traffic, i.e. data analytics, including Google Analytics,

Meta Pixel, HotJar and Microsoft Clarity cookies (these are cookies used to analyze how

you use the Portal or Application, to create statistics and reports on their operation). These

entities do not use the collected data to identify you, nor do they combine this information

to enable identification.

"MARKETING" COOKIES

21. We and our trusted partners also use cookies for marketing purposes, including in connection with

targeting you with behavioral advertising. For this purpose, we and our trusted partners store

information or access information already stored on your telecommunications end device

(computer, phone, tablet, etc.). The use of cookies and personal data collected through them for

marketing purposes, in particular for the promotion of services and goods of third parties, requires

your consent, which can be withdrawn at any time.

COOKIE MANAGEMENT

22. If you do not want to receive cookies, you can change your browser settings. We stipulate that

disabling cookies necessary for authentication processes, security, maintenance of user

preferences may hinder, and in extreme cases may make it impossible to use the Portal or the 
Application.  
23. To manage your cookie settings, select the web browser you are using from the list below and 
follow the instructions: 
23.1.  Edge 
23.2.  Internet Explorer 
23.3.  Chrome 
23.4.  Safari 
23.5.  Firefox 
23.6.  Opera 
Mobile devices: 
23.7.  Android 
23.8.  Safari (iOS) 
23.9.  Windows Phone 
 
ESSENTIAL MARKETING TECHNIQUES 
24. We use statistical analysis of website traffic, through Google  Analytics, Meta Pixel, HotJar and 
Microsoft  Clarity.  We  do  not  transmit  personal  data  to  the  operator  of  these  services,  only 
anonymized information. The service is based on the use of cookies on your end user device.  
25. We use remarketing techniques that allow us to tailor advertising messages to your behavior on 
the Portal and Application, which may give the illusion that your personal information is being 
used for tracking, but in practice we do not pass any of your personal information to advertising 
operators. A technological prerequisite for such activities is that cookies are enabled. 
26. We use a solution to study the behavior of Users by creating heat maps and recording behavior 
on the Portal and Application, This information is anonymized before  it  is  sent to  the service 
operator so that he does not know which individual it refers to. In particular, typed passwords and 
other personal information are not recorded. 
27. We use a solution that automates the operation of the Portal or Application with respect to Users, 
e.g., that can send you an email to when you visit a particular subpage.   
 
PERIOD OF PROCESSING OF PERSONAL DATA 
 
28. The period for which we process  your data  depends on  the type  of service provided and the 
purpose of the processing. As a general rule, your data is processed for the duration of the service 
or order processing, until  you  withdraw your  consent  or make  an  effective objection to  data 
processing (in cases where the legal basis for data processing is our legitimate interest).  
29. The  period  of  data  processing  may  be  extended  if  the  processing  is  necessary  for  the 
establishment, investigation or defense of possible claims, and thereafter only if and to the extent 
required by law.  
30. After the end of the processing period, your data is irreversibly deleted or anonymized.  
 
YOUR POWERS  
 
31. As we process your personal data, you have the following rights: 

31.1. The right to information about the processing of personal data - on this basis, at your

request, we will provide you with information about the processing of your data, including,

in particular, the purposes and legal grounds for processing, the scope of the data held, the

entities to which they are disclosed, and the planned date of deletion;

31.2. The right to obtain a copy of the data - on this basis, upon your request, we will provide

you with a copy of the processed data concerning the person making the request;

31.3. The right to rectification - at your request, we are obliged to remove any inconsistencies

or errors in the processed personal data and complete it if it is incomplete;

31.4. The right to erasure - on this basis you can request the erasure of data, the processing of

which is no longer necessary to carry out any of the purposes for which they were collected;

31.5. The right to restrict processing - on this basis, at your request, we will stop performing

operations on your personal data - except for operations to which you have given your

consent - and their storage, in accordance with accepted retention rules or until the

reasons for restricting processing cease to exist;

31.6. The right to data portability - on this basis - insofar as your data is processed in connection

with a contract concluded or consent given - we will release the data provided by you in a

computer-readable format. You may also request that we send the data to another entity

- provided, however, that we have the technical capacity to do so;

31.7. The right to object to the processing of data for marketing purposes - you can object to

the processing of personal data for marketing purposes at any time, without having to

justify such objection;

31.8. The right to object to other purposes of processing - you may object at any time to the

processing of personal data that is carried out on the basis of our legitimate interest (e.g.,

for analytical or statistical purposes or for reasons related to property protection); an

objection in this regard should contain a justification;

31.9. The right to withdraw consent - if the data is processed on the basis of your consent, you

have the right to withdraw it at any time, which, however, does not affect the legality of

the processing carried out before the withdrawal of consent;

31.10. The right to complain - if you believe that the way we process your personal data violates

the provisions of the GDPR or other data protection laws, you may file a complaint with

the President of the Office for Personal Data Protection.

DATA RECIPIENTS

32. As we want to perform the best possible services for you, we will disclose your personal data to

our trusted partners, subcontractors and entities working with us, including, in particular,

suppliers responsible for operating IT systems, entities such as banks and payment operators,

accounting service providers, marketing agencies (for marketing services) and our affiliates.

33. Your personal data will be shared with other entities for their own purposes, including marketing

purposes only if you consent.

TRANSFER OF DATA OUTSIDE THE EOG

34. The level of protection of personal data outside the European Economic Area (EEA) may differ

from that provided by European law. For this reason, we will transfer your personal data outside

the EEA only when necessary and with an adequate level of protection. You will be notified each

time.

35. We use companies that are based in the United States, viz:

35.1. Your personal data is processed in the Azure cloud computing provided by Microsoft,

35.2. The portal is hosted by CloudFlare,

35.3. We use the Auth0 authorization system as part of the login, registration and storage of your

account data,

35.4. we use statistical analysis of site traffic through Google Analytics provided by Google,

Microsoft Clarity provided by Microsoft, and Meta Pixel provided by Meta.

SECURITY OF PERSONAL DATA

36. Know that we take all steps to ensure that your personal data is processed by us in a secure

manner - ensuring, above all, that only authorized persons have access to your data and only to

the extent necessary for their tasks.

37. We take all necessary measures to ensure that our subcontractors and other cooperating entities

provide guarantees to apply appropriate security measures whenever they process your personal

data on our behalf.

CONTACT DETAILS

38. For all matters referred to in this policy, in particular related to the processing of your personal

data, you can contact us through:

38.1. e-mail: hello@generatecreatives.com

38.2. by mail to the address: JustFilm.it sp. z o.o., street: Pulawska, 12/3, 2nd floor, 02-566

Warsaw, Poland.

39. This Policy is reviewed on an ongoing basis and updated as necessary. The current version of the

Policy has been adopted and is effective as of 06.05.2023.