An information clause regarding personal data processing
Pursuant to the Regulation of the European Parliament and Council (EU) 2016/679 of 27th April 2016 on the protection of individuals with regard to personal data processing, on free movement of such data, and repealing directive 95/46/WE (General Data Protection Regulation) (hereinafter referred to as the “GDPR”), we hereby inform you that:
1. Elsta Sp. z o.o., ul. Janińska 32, 32-020 Wieliczka (KRS [National Court Register] number: 0000100416), hereinafter referred to as “the Administrator”, is the Personal Data Administrator, or an entity deciding on the purpose and manner of processing your data.
2. The Data Protection Supervisor (DPS). We hereby inform that we have appointed a Data Protection Supervisor. This function is performed by Rafał Andrzejewski. You can contact the DPS via e-mail: firstname.lastname@example.org or in writing to the address of the Administrator.
3. We process your data for the following purposes and on the following legal grounds:
a. concluding and execution of contracts and complaint process implementation (legal basis: art. 6.1 b) of the GDPR);
b. sending commercial information via electronic means of communication, marketing (upon your consent; legal basis: art. 6.1 a) of the GDPR or with due regard to our legitimate interest – art. 6.1 f) of the GDPR – direct marketing);
c. for archival (evidentiary) purposes to secure information in the event of a legal necessity to demonstrate facts, which is our legitimate interest (legal basis: art. 6.1 f) of the GDPR, pursuant to art. 7.1 and 7.3 of the GDPR);
d. for the purpose of possible determination, assertion or defence against claims, which is our legitimate interest (legal basis: art. 6.1 f) of the GDPR);
e. for the purpose of customer satisfaction survey and determination of the quality of our service, which is our legitimate interest (legal basis: art. 6.1 f) of the GDPR);
f. fulfilment of legal obligations incumbent on the Administrator (art. 6.1 c) of the GDPR), e.g. for the purpose of accounting and for tax reasons.
4. Information regarding personal data recipients: your personal data may also be processed by entities with which the Administrator concluded personal data processing entrustment agreements, in particular within the scope of IT, legal, personnel and accounting services. Your personal data shall not be transferred to any third country (from outside the EEA).
5. The retention period, in other words, how long will we process your personal data?
We will process your personal data no longer than necessary.
a. For accounting or tax reasons, we will process them as long as we are obliged to do so by the applicable provision of law. On the basis of existing law it is a period of 5 years counted from the end of the calendar year in which the tax obligation arose;
b. Should you express your consent on personal data processing, e.g. for marketing purposes, we will process them until you revoke the consent;
c. Upon the fulfilment of the primary purpose for which your data has been collected, they shall be processed for archiving purposes for a time period that complies with our applicable archival regulations, as well as for a time period necessary to defend ourselves against claims lodged against us, by virtue of generally applicable provisions of law, taking into account limitation periods for claims referred to in generally applicable provisions of law.
6. We hereby inform that you are entitled to:
a. access the content of your personal data and receive a copy thereof; transfer your data;
b. rectify (correct) your data;
c. remove your data;
d. limit your data processing;
e. oppose to your data processing;
f. withdraw your consent on personal data processing – you are allowed, at any time, to withdraw your consent on processing the personal data we process upon your consent. The withdrawal of your consent shall not affect the lawfulness of the processing carried out by virtue of the consent before its withdrawal, provided that the execution of the rights is consistent with the GDPR and other rules governing the personal data protection issue.
g. lodge a complaint with a supervisory authority – should you consider your data to be processed unlawfully, you are allowed to lodge a relevant complaint to the President of the Office for Personal Data Protection.
7. Providing data is voluntary, yet often necessary to conclude a contract with us or access our services. A failure to provide such data may, for instance, prevent the conclusion of the contract.
8. Your personal data shall be processed by automatic means, since they are processed both in a paper version and repeatedly in IT systems. Nevertheless, this does not entail automatic decision making, in which profiling.
The ELSTA Group websites may automatically create users’ statistics. We use the statictical data in order to improve our websites and other services avaibalbe on our domains. By following the trends of particular users’ visits, we may adjust the content of prestented materials to meet our customers’ and guests’ needs as best as we can. Therefore, we collect and process the following information regarding visiting our websites and services:
- visting computer’s IP address
- canonical name of the assessing computer’s IP
- operating system of the accessing computer
- screen resolution of the accessing computer
- type and version of the Internet browser
- time and date of initiating the connection
- URL addresses of visited websites and subpages
- names and types of other visited websites and services
- number and total time of visits
Implemented mechanisms do not infringe the anonymisation of users who visit our services. ELSTA Group does not share processed data with third-parties. The data is collected within logs and may be used only in case of user’s illegal or undesirable behaviour.
In case of presumed or definite law violation, the case will be reported to the competent authorities who will conduct the criminal proceeding.
If you do not agree with the above rules, please quit visiting our websites and other services made available by ELSTA Group.
ELSTA Group reserves the right to introduce any changes to the Privacy and Cookies Policies.