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Personal data policy - Information obligation
05.24.2018

Myślęcin, the 18th of May 2018

To whom it may concern,

the Regulation of the European Parliament and Council (EU) 2016/679 of the 27th of 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 ‘RODO’) comes into force on the 25th of May 2016. Below you will find the information how your personal data will be processed after the 25th  of May 2018.

The processor of your personal data will be COMPLET Chmielewscy Sp. J. with its registered office in Myślęcin 4a; 62-260 Łubowo (hereinafter referred to as ‘the Company’).

The Company will process the data obtained from you in relation with the intention of concluding an agreement or execute the concluded agreement for the product or service offered by the Company. The obtained data shall be processed according to the law.

The legal grounds for data processing may be:

1)                The consent – it means the consent for personal data processing that you expressed voluntarily – indicated in art. 6 item 1 letter a) of RODO

2)                The agreement requirements – it means the necessity of having the access to the data for the needs of executing the concluded Agreement or initiating the activities before concluding an agreement on your request – indicated in art. 6 item 1 letter b) of RODO

3)                The statutory requirements – it means the necessity of following legal regulations by the Company resulting from the provisions of law – indicated in art. 6 item 1 letter c) of RODO

4)                The legitimate requirements of the processor – it means the necessity of implementing legitimate interests of the Company – indicated in art. 6 item 1 letter f) of RODO

Based on the abovementioned legal grounds for data processing, the Company shall process the data obtained from you for the following purposes:

1)                The purposes indicated in the consent – based on such consent – in such case you may withdraw your consent at any time, which will not impact the legal conformity on processing the data, when the processing was made based on the consent before its withdrawal; however, the refusal on expressing the consent or its withdrawal will cause that the Company will not be allowed to process your data for the purposes indicated in the consent

2)                The purpose of preparing the initial calculations for the Agreement, analyzing the possibility of its concluding, risk assessment related with its conclusion or implementation, including by constructing the profile of your Company, analyzing it and creating the forecast, and following that  – in case of concluding the Agreement – in order to implement it, including for the purposes of dealing with inquiries and claims, executing your orders or concluding the supplementary agreements e.g. agreement for transport of goods, agreements securing the Company's receivables or agreements on the insurance of goods during the transport.

3)                The purpose of following the provisions of law by the Company, including but not limited to prevent money laundering or finance the terrorism or for tax regulations – based on statutory requirements

4)                The purpose of pursuing the claims and defending against claims under the concluded Agreement, for marketing of products and services of the Company  during the term of the Agreement, in order to provide safety in the area of IT – based on the justified Processor’s requirements

5)                The purpose of dealing with the inquires submitted by the contact form  – based on the agreement requirements or justified processor’s requirements, depending on the subject of the inquiry.

The period of processing the obtained personal data is related with the above indicated purposes of data processing. Therefore, the personal data shall be processed for a longer term from the following ones:

1)                The period when the provisions of law require storing the data or

2)                The period of limitations for claims, if the availability of data is necessary to pursue the claims or

3)                The period of 10 years from the date of obtaining the data.

The personal data obtained from you, under the processing purposes indicated hereinabove,  may be made available to other subjects than the company, it means:

1)                The subjects providing the services to the Company e.g. IT services suppliers, auditors, advisors, accounting office, on the basis of agreements for entrusting the processing of personal data

2)                Other authorized subjects, solely for the purposes determined in the provisions of the law.

The processing of the data obtained from you by the Company will be based on a voluntary basis. The refusal to provide the data may make it impossible to take up the activities you are requesting e.g. considering the application for conclusion of the Agreement or its implementation.

In cases and based on the regulations defined in the provisions on personal data protection you will have the right to access your data, rectify or delete the data or limit data processing, the right to object the processing based on the legal grounds in form of justified processor’s requirements or transferring the personal data.

You will also have the right to file a claim to a competent supervisory authority, indicated in the binding act defining the regulations on personal data protection.

The Company does not have the obligation to appoint the Inspector of Data Protection, however all issues concerning your personal data can be reported to the Authorized Representative for Data Protection under the address: Pełnomocnik ds. ochrony danych [Representative for Data Protection], COMPLET Chmielewscy Sp. J., Myślęcin 4a, 62-260 Łubowo, e-mail address: ochronadanych@complet.com.pl, tel.: 61 424 76 37

In case you make available to the Company the personal data of your employees,  representative, members of the Management Board, partners, co-workers, clients, suppliers, beneficiaries or other persons, please inform these persons about:

1)                The scope of personal data concerning these persons, and transferred to the company

2)                About the fact that the Company is the Processor of their personal data and that the Company processes their personal data according to the regulations provided above

3)                About the fact that you are the source from which the Company obtained their data.

 

Yours sincerely

 

 

Robert Chmielewski

Representative of Data Processor



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