Privacy Policy

Privacy Policy | Smart People

Privacy Policy

Last updated: February 11, 2026

General Information

This Privacy Policy describes the principles of personal data processing by SmartPeople Sp. z o.o., based in Gdynia, Al. Zwycięstwa 241/13, 81-521 Gdynia, Poland, Tax ID (NIP): 9581730991, National Court Register (KRS): 0001015866, hereinafter referred to as "SmartPeople" or the "Controller."

Contact: kontakt@smartpeople.com.pl

Scope of Collected Data

SmartPeople may process the following personal data:

  • first and last name,
  • email address,
  • phone number,
  • job title or company name (for B2B contacts),
  • data provided in messages sent via the contact form,
  • information in CVs and application documents (if submitted by candidates),
  • automatically collected data (IP address, device and browser information, cookies).

Additionally, for Smart People Global Academy participants:

  • course registration details (selected course, registration date),
  • payment and billing information (invoice data, payment confirmations),
  • learning progress data (attendance in training sessions, course completion status),
  • access logs to the training platform (login times, accessed materials),
  • participation in Q&A sessions and feedback surveys,
  • certification exam results (if applicable),
  • correspondence related to course enrollment and participation,
  • image and voice (in case of active participation in live online sessions with camera or microphone enabled, which are recorded for educational purposes for course participants).

Purposes of Data Processing

Personal data is processed for the following purposes:

  • responding to inquiries sent via the contact form,
  • preparing business offers or establishing cooperation,
  • conducting marketing and remarketing activities (e.g., Google Ads, LinkedIn Ads),
  • creating Custom Audiences on advertising platforms (LinkedIn, Facebook, Google) for targeted advertising to similar users (Lookalike Audiences) or retargeting,
  • analyzing website traffic (Google Analytics),
  • marketing automation and customer relationship management (HubSpot CRM),
  • identifying website visitors for B2B prospecting purposes (Apollo.io),
  • conducting recruitment and evaluating candidates,
  • performing contracts and cooperation with clients or partners,
  • fulfilling legal obligations incumbent upon the Controller.

For Academy participants, data is additionally processed to:

  • provide access to purchased courses and training materials,
  • conduct online training sessions,
  • record live sessions for educational purposes (recordings are made available to course participants for learning and review),
  • monitor attendance and learning progress,
  • issue course completion certificates and support SAP SuccessFactors certification exam preparation,
  • provide technical support and respond to course-related inquiries,
  • process payments and issue invoices in accordance with tax and accounting regulations,
  • improve course content based on participant feedback,
  • send course-related notifications (schedule changes, new materials, exam dates),
  • comply with legal obligations related to consumer protection and contract performance.

Legal Basis for Data Processing

Data is processed in accordance with Article 6(1) of the GDPR (Regulation (EU) 2016/679):

  • (a) based on consent (e.g., newsletter subscription, marketing communications),
  • (b) for contract performance or pre-contractual actions (e.g., course enrollment, training delivery),
  • (c) to comply with legal obligations (Polish Accounting Act, VAT Act, Tax Ordinance Act),
  • (f) for legitimate interests of the Controller (direct marketing, traffic analysis, B2B contact, fraud prevention, quality improvement, B2B lead identification).

Recipients of Data

Data may be shared with the following categories of recipients:

  • IT and hosting service providers,
  • analytics and advertising tools providers (Google LLC, LinkedIn Corporation),
  • marketing automation and CRM systems providers (HubSpot Inc.),
  • prospecting and sales automation tools providers (Apollo.io Inc.),
  • educational platform providers (Evol Campus – for Smart People Global Academy participants),
  • SAP demo and practice systems providers (for Smart People Global Academy participants),
  • recruitment and ATS system providers,
  • accounting and legal service providers,
  • entities authorized by law (Tax Office, law enforcement agencies).

For Academy participants, data may additionally be shared with:

  • online training platform providers,
  • payment processors and financial institutions,
  • email and communication service providers,
  • certification exam providers (if applicable).

International Data Transfers:

If data is transferred outside the EEA, it is only to entities ensuring adequate protection (participants in EU-U.S. Data Privacy Framework or entities bound by Standard Contractual Clauses approved by the European Commission).

Data Retention Period

Data is retained:

  • until consent is withdrawn (if processed on that basis),
  • for the period necessary to fulfill the processing purpose,
  • for periods required by law or legitimate interests of the Controller.

For Academy participants:

  • During enrollment: for the course duration,
  • Certificates: 2 years after course completion,
  • Invoices: 5 years (Polish Tax Ordinance Act, Art. 70 § 1),
  • Accounting records: 5 years (Polish Accounting Act, Art. 74(1)),
  • Legal claims: up to 6 years (Polish Civil Code, Art. 118).

Data Subject Rights

You have the right to:

  • access your personal data (Article 15 GDPR),
  • rectify inaccurate data (Article 16 GDPR),
  • delete data – "right to be forgotten" (Article 17 GDPR),
  • restrict processing (Article 18 GDPR),
  • data portability (Article 20 GDPR),
  • object to processing (Article 21 GDPR),
  • withdraw consent at any time (Article 7(3) GDPR),
  • lodge a complaint with the President of the Personal Data Protection Office (Poland).

To exercise these rights: kontakt@smartpeople.com.pl

Right to Withdraw from Contract (Academy Participants)

Under the Polish Consumer Rights Act of 30 May 2014 (implementation of EU Directive 2011/83/EU), consumers have the right to withdraw from a distance contract within 14 days without giving any reason.

However, pursuant to Article 38(1) and (13):

The right of withdrawal does not apply in case of:

  • provision of services if the service has been fully performed with the consumer's express consent,
  • delivery of digital content not supplied on a tangible medium, if performance began with the consumer's express consent before the withdrawal period expired.

By registering for a Smart People Global Academy course:

  1. You expressly consent to the commencement of service provision before the 14-day period expires, and
  2. You acknowledge that you have been informed about the loss of the right of withdrawal once you begin accessing the course content.

Evol Campus Educational Platform

Smart People Global Academy uses Evol Campus as an educational platform for conducting online courses in SAP SuccessFactors.

Evol Campus processes Participants' data for the following purposes:

  • providing access to purchased courses,
  • conducting online training sessions (live),
  • providing session recordings and training materials,
  • monitoring learning progress and session attendance,
  • logging user activity on the platform,
  • communication between participants and instructors.

Data processed by Evol Campus:

  • login data (email address as login, encrypted password),
  • first and last name,
  • activity logs (login times, accessed materials, time spent on platform),
  • learning progress (completed modules, test and practical exercise results),
  • attendance at live sessions and participation in discussions,
  • image and voice (if participant enables camera/microphone during live sessions).

Legal basis: Article 6(1)(b) GDPR (performance of training contract).

Retention period: Data on the Evol Campus platform is retained for the duration of the course and for the period of access to recordings and materials (typically 12 months from course completion). After this period, data may be deleted or anonymized.

Technical cookies: Evol Campus may use technical cookies necessary to ensure proper platform operation (e.g., session cookies, authentication). These are necessary cookies that do not require user consent.

Security: Evol Campus applies appropriate technical and organizational measures to protect personal data, including connection encryption (SSL/TLS) and access control.

SAP Demo Instance – Practical Training System

As part of Smart People Global Academy, SAP SuccessFactors course participants receive access to SAP Demo Instance – a SAP test environment for practical configuration exercises.

SAP Demo Instance processes Participant data for:

  • enabling practical exercises in SAP SuccessFactors Employee Central configuration,
  • learning in a real SAP environment,
  • completing assignments and training projects,
  • testing various configuration scenarios.

Data processed in SAP Demo Instance:

  • login credentials (username and password assigned by Smart People),
  • first name and last name (for user identification in the demo system),
  • activity logs (login times, operations performed in the system),
  • test data entered by Participant during exercises (fictitious employee data, organizational structures, configurations).

Important: SAP Demo Instance is a test environment. Participants should not enter real personal data (their own or others') into the demo system. All data used in exercises should be fictitious.

Legal basis: Art. 6(1)(b) GDPR (performance of training contract).

Retention period: Data in SAP Demo Instance is retained for the duration of the course and the demo environment access period (typically up to 12 months after course completion). User accounts may be deleted or deactivated after course completion.

Provider: SAP Demo Instance is provided by SAP SE or authorized SAP partners. Detailed information about the provider and server location is communicated to Participants after course commencement.

Data transfer: SAP Demo Instance may be located outside the European Economic Area (EEA). In such cases, data transfer is conducted with appropriate safeguards (Standard Contractual Clauses or other GDPR-compliant mechanisms).

Security: SAP applies industry-standard security measures, including connection encryption (SSL/TLS), access control, and regular security audits.

Cookies and Analytical Tools

The smartpeople.com.pl website uses:

  • Google Analytics (traffic analysis),
  • Google Ads and LinkedIn Ads (remarketing),
  • HubSpot CRM (marketing automation),
  • Apollo.io (B2B visitor identification).

Evol Campus educational platform (for Academy participants) uses technical cookies necessary for platform operation.

SAP Demo Instance (for Academy participants) uses technical cookies necessary for authentication and user session management in the SAP test environment.

You can manage cookie preferences through the consent banner or browser settings. Details in our Cookie Policy.

Apollo.io – B2B Visitor Identification

We use Apollo.io (Apollo.io Inc., USA) technology to identify companies and individuals visiting our website in the context of B2B activities.

How it works:

Apollo.io analyzes technical data (IP address, browser data) and identifies the company from which the connection originates. If a visitor uses a corporate internet connection, Apollo may associate the visit with publicly available company and contact data.

Data collected:

  • IP address,
  • device and browser data (user agent),
  • time and scope of visit (pages viewed, time spent),
  • traffic source,
  • company identification data (company name, industry, location),
  • contact data of company representatives (name, title, email) – if publicly available.

Processing purposes:

  • identification of potential B2B clients,
  • personalization of sales communication,
  • analysis of marketing effectiveness,
  • establishing business relationships.

Legal basis: Article 6(1)(f) GDPR (legitimate interest of the Controller in acquiring business clients and business development).

Right to object: You can object to processing by Apollo.io at any time: kontakt@smartpeople.com.pl

International transfer: Apollo.io Inc. is based in the USA. Data transfer to the USA is based on Apollo.io's participation in the EU-U.S. Data Privacy Framework.

More information: https://www.apollo.io/privacy

Changes to Privacy Policy

The Controller reserves the right to make changes to this Privacy Policy. The current version is always available at: www.smartpeople.com.pl/privacy-policy

Automated Decision-Making

SmartPeople does not apply automated decision-making that produces legal effects or similarly significantly affects individuals (Article 22 GDPR).

However, we may use profiling for marketing purposes (e.g., tailoring course recommendations or content to users' interests based on browsing history and past interactions). Such profiling does not produce legal effects and you have the right to object at any time.

Custom Audiences

For marketing purposes, we may upload lists of email addresses to advertising platforms (LinkedIn Ads, Facebook Ads, Google Ads) in order to:

  • Retargeting – displaying ads to people who have already had contact with our website or services,
  • Lookalike Audiences – creating groups of similar users to reach new potential clients with similar characteristics.

Legal basis: Article 6(1)(f) GDPR (legitimate interest in effective marketing and customer acquisition).

Right to object: You can object to the use of your email address in such campaigns at any time. Contact: kontakt@smartpeople.com.pl

Advertising platforms process data in accordance with their own privacy policies and provide data protection mechanisms (hashing of email addresses before transmission).

Data Protection Measures

SmartPeople implements technical and organizational measures:

  • access control and authentication mechanisms,
  • data encryption (SSL/TLS),
  • regular security assessments,
  • confidentiality obligations for employees,
  • data processing agreements with processors (Article 28 GDPR).

Prohibition on Special Categories of Data

Do not provide special categories of data (Article 9 GDPR) via forms: health information, religious beliefs, sexual orientation, political opinions, genetic data.

List of Cookies

Below is a list of main cookies used on our website:

Cookie Name Provider Purpose Duration Category
_ga Google Analytics Website traffic analysis 2 years Analytical
_gid Google Analytics Website traffic analysis 24 hours Analytical
_fbp Meta (Facebook) Remarketing and ad targeting 3 months Marketing
li_fat_id LinkedIn Remarketing and LinkedIn Insight Tag 30 days Marketing
_gcl_au Google Ads Google Ads conversions and remarketing 3 months Marketing
_apollo_* Apollo.io B2B visitor identification 1 year Marketing
__hstc HubSpot User tracking, CRM 13 months Analytical
hubspotutk HubSpot User identification in CRM 13 months Analytical
cookieyes-consent CookieYes Storing cookie preferences 1 year Necessary
evol_session Evol Campus User session on educational platform Session Necessary
evol_auth Evol Campus User authentication 7 days Necessary
sap_session SAP Demo Instance User session in SAP demo environment Session Necessary
sap_auth SAP Demo Instance Authentication in SAP system 12 hours Necessary