PRIVACY POLICY OF VERTRAPOL SP.K. FOUNDATION

1. WHAT DOES THIS POLICY REFER TO?

This privacy policy (“Policy”) sets out information about the processing of personal data by Vertrapol Sp. k. Foundation with its registered office in Otrębusy, Poland (“Company”), i.e.:

specifies the types of data collected by the Company;clarifies the mode and the purpose for which the Company collects and uses your personal data;explains when and why the Company is going to share personal data with other entities; andpresents rights and possibilities of choice that you have as far as your personal data are concerned.

This Policy is applicable if you are:

Þ a User of the Company’s Website, i.e. you are using the www.vertrapol.com website (“Website”) or have completed one of the contact forms available on the Website;

Þ a candidate for work in the Company, i.e. a person taking part in the recruitment processes carried out by the Company and making your data available to the Company for this purpose;

Þ a Potential Contracting Partner of the Company, i.e. a person interested in the Company’s offer in the area of specific services and you are contacting the Company with the aim of procuring specific information or commissioning services/ entering into a contract or you are a contracting partner’s Representative, i.e. you represent or act on behalf of a Company’s Potential Contracting Partner;

Þ the Company’s Contracting Partner, i.e. a person with whom the Company entered into a service provision contract or the Company’s Contracting Partner’s Representative, i.e. you represent or act on behalf of the Company’s Contracting Partner;

Þ the Company’s Supplier, i.e. you supply specific goods or services to the Company or the Supplier's Representative, i.e. you represent or act on behalf of the Company’s Supplier;

Þ a Recipient of the Company’s Marketing Actions, i.e. an addressee of e-mails or marketing actions carried out by the Company.

Your personal data are processed pursuant to Regulation 2016/679 of the European Parliament and of the Council (EU) of 27 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 Processing Regulation, hereinafter also referred to as the “GDPR”).

2. WHO IS THE DATA CONTROLLER OF YOUR PERSONAL DATA?

The Data Controller of your personal data is:

Vetrapol Sp. k. Foundation
ul. Kępińska 90
05-805 Otrębusy, Poland
(“Data Controller”, “We”)

With respect to issues related to the processing of your personal data, you can contact us at the above-listed correspondence address or you can contact our Data Protection Officer at the following e-mail address: Ten adres pocztowy jest chroniony przed spamowaniem. Aby go zobaczyć, konieczne jest włączenie w przeglądarce obsługi JavaScript..

3. WHICH INFORMATION DO WE COLLECT AND FROM WHICH SOURCES?

If you are a User of the Company’s Website, we collect information received from you in relation to your activity on the Website. This will be, in particular, information provided by you in contact forms presented on the website, the IP address and information contained in cookies.

If you are a candidate for work in the Company, we collect information received from you during the conducted recruitment processes. This will be, in particular, personal data contained in the application documents sent to the Company (e.g. CV) and other data provided during the conducted talks, job interviews and in e-mail correspondence.

If you are the Company’s Potential Contracting Partner, we collect information received from you during telephone talks, e-mail correspondence and meetings. This may be, in particular: first name and surname, business name, contact details, information pertaining to the request for services offered by the Company and other data - if you voluntarily decided to furnish the Company with them.

If you are the Company's Contracting Partner, we collect information received from you in relation to conclusion and performance of a service provision contract. This may be, in particular, such data as the first name and surname, business name and address, correspondence address, VAT Reg. No. (NIP), State Statistical No. (REGON), bank account No., e-mail address, telephone No., information about a contract binding us. Your data may also derive from generally available sources.

If you are a Representative of a Contracting Partner or a Potential Contracting Partner of the Company, we collect information provided by you or by an entity that you represent for the purpose of entering into or performing the concluded service provision contract. This may be, in particular, such information as the first name and surname, position, name of the represented entity, correspondence address and contact details.

If you are the Company’s Supplier, we collect information provided by you in submitted documents, information shared during telephone talks, e-mail correspondence and meetings. This may be, in particular, information necessary for entering into and performing a contract, such as: first name and surname, business name and address, correspondence address, VAT Reg. No. (NIP), State Statistical No. (REGON), bank account No., e-mail address, telephone No., information about a contract binding us. Your data may also derive from generally available sources.

If you are a Representative of the Company’s Supplier, we collect information provided by you or by the Supplier whom you represent for the purpose of entering into or performing a contract with the Supplier. This may be, in particular: first name and surname, position, name of the represented Supplier, correspondence address and contact details.

If you are the Recipient of the Company’s Marketing Actions, we collect information necessary for performance by the Company of specific marketing actions (informing you about the Company's offer, promoting the Company's services), including marketing e-mailing. This may be, in particular, such data as the first name and surname, business e-mail, name and address of the represented company, position in the company.

4. FOR WHAT PURPOSE AND ON WHICH LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

If you are a User of the Company's Website, we process your data:

· based on the Data Controller’s legitimate interest, i.e. for the purpose of contacting you and processing the request sent via the contact form, also for purposes necessary to administer (manage) the Website (Art. 6(1)(f) of the GDPR);

· based on your consent, in case of provision of personal data which are necessary to establish contact or to process a request sent via a contact form (Art. 6(1)(a) of the GDPR).

If you are a Candidate for Work, we process your personal data:

· for the purpose of meeting the legal obligations to which the Data Controller is subject, resulting from legal provisions, including labour law provisions (Art. 6(1)(c) of the GDPR);

· based on your consent, in case of provision of personal data in a scope exceeding the scope indicated in legal provisions, including labour law provisions and for the purpose of future recruitment processes - provided you agreed for it (Art. 6(1)(a), Art. 9(2)(a) of the GDPR);

· for purposes resulting from legitimate interests pursued by the Data Controller, such as assertion of or seeking of potential claims or defence of such claims (Art. 6(1)(f) of the GDPR);

If you are the Company’s Potential Contracting Partner, we process your personal data:

for purposes resulting from legitimate interests pursued by the Data Controller, such as presentation of the offer at your explicit request, maintaining relations, assertion or seeking of potential claims or defence of such claims (Art. 6(1)(f) of the GDPR);for the purpose of taking action at your request, necessary before conclusion of a service provision contract/ cooperation contract (Art. 6(1)(b) of the GDPR).

If you are the Company’s Contracting Partner, we process your personal data:

for the purpose of entering into and performing a contract (Art. 6(1)(b) of the GDPR);

· for the purpose of meeting legal obligations resulting from legal provisions to which the Data Controller is subject (Art. 6(1)(c) of the GDPR);

for purposes resulting from legitimate interests pursued by the Data Controller, such as maintenance of business relations, ongoing contacts, performance of marketing activities, assertion of or seeking of potential claims or defence of such claims (Art. 6(1)(f) of the GDPR).

If you are the Representative of a Contracting Partner or a Potential Contracting Partner of the Company, we process your personal data:

for purposes resulting from legitimate interests pursued by the Data Controller, such as presentation of the offer, ongoing contacts in relation to the offer, assertion or seeking of potential claims or defence of such claims (Art. 6(1)(f) of the GDPR).

If you are the Company’s Supplier, we process your personal data:

for the purpose of entering into and performing a contract (Art. 6(1)(b) of the GDPR);

· for the purpose of meeting legal obligations resulting from legal provisions to which the Data Controller is subject (Art. 6(1)(c) of the GDPR);

for purposes resulting from legitimate interests pursued by the Data Controller, such as maintenance of business relations, ongoing contacts, assertion of or seeking of potential claims or defence of such claims (Art. 6(1)(f) of the GDPR).

If you are a Supplier’s Representative, we process your personal data:

· for purposes resulting from legitimate interests pursued by the Data Controller, such as entering into and performance of a contract concluded with the Supplier whom you represent, maintenance of business relations, ongoing contacts, assertion or seeking of potential claims or defence of such claims (Art. 6(1)(f) of the GDPR).

If you are a Recipient of the Company's Marketing Activities, we process your personal data:

· pursuant to your consent, provided it is a valid and efficient basis of data processing, for the purpose of marketing our products and services (Art. 6(1)(f) of the GDPR);

· for the purpose of pursuing our legitimate interests related to direct marketing activities (Art. 6(1)(f) of the GDPR).

5. WHO ARE YOUR PERSONAL DATA MADE AVAILABLE TO?

When it is necessary for the meeting of purposes for which your data are processed, we may transfer them:

· to entities authorised to receive data based on legal provisions;

· to entities processing your personal data on our behalf (e.g. entities providing consulting, IT and other services for our benefit);

· to entities in reference to which you expressed a consent for making your personal data available.

In every case of making personal data available and data outsourcing, we will make sure that only the minimum information necessary for meeting the processing purposes is provided.

Your personal data will not be transferred outside of the European Economic Area (EEA).
In case your personal data were transferred outside of the EEA territory, we make sure that cooperation with such entities takes place on the basis of a relevant legal basis and that they guarantee proper standards of protection.

6. HOW LONG ARE YOUR PERSONAL DATA STORED?

If you are a User of the Company’s Website, your personal data will be processed for the period of their utility, however not longer than it results from the purpose for which such data were collected.

If you are a Candidate for Work, your personal data will be processed until the purpose for which they were collected was met, i.e. completion of the recruitment process to which you applied. If you agreed for the processing of your personal for future recruitment processes, your personal data will be stored for a period of two years from the moment of collecting them. If you decide to withdraw the consent that you gave, your personal data will be stored at the latest until the moment of consent withdrawal. In justified cases, personal data will be stored as long as they are necessary for meeting our legitimate interests.

If you are the Company’s Potential Contracting Partner or its Representative, your personal data will be stored as long as they are necessary for meeting the purpose for which they were provided to us, however not longer than until the moment of filing an objection for the processing of such data for this purpose.

If you are the Company’s Contracting Partner, Supplier or a Representative of one of these entities, your personal data will be processed for the period of performance of a contract concluded with you or an entity that you represent. After the end of such period, we will store your personal data in the necessary scope for a period of time resulting from legal requirements (e.g. obligation of archiving financial documents for 5 years). In justified cases, your personal data will be stored as long as they are necessary for meeting our legitimate interests.

If you are a Recipient of the Company's Marketing Activities, your personal data will be processed as long as it is necessary for performance of the Company's marketing activities, however not longer than until withdrawal of the consent given by you (if it is the valid and effective premise for the processing of your personal data).

7. WHICH RIGHTS ARE YOU VESTED WITH?

In exercise of the rights with which you are vested with respect to the processing of your personal data, you can furnish us with the following demands:

a) if we process your personal data based on your consent, you can withdraw it at any moment; the withdrawal of consent does not affect the legitimacy of the processing performed on its basis prior to the withdrawal;

b) you can request access to your personal data and receive a copy of your data;

c) you can exercise the right to transfer your personal data;

d) you can request rectification of your personal data if they are incorrect or incomplete;

e) in relation to your specific circumstances, you can file an objection against the processing of your personal data if we process them referring to our legitimate interest;

f) in legally justified cases, e.g. when your data are invalid, unnecessary, processed inconsistently with the law, as well as when you withdrew your consent for the processing of data (if the consent was the basis of such processing) or you filed an efficient objection against the processing of your personal data - you can demand removal of your personal data;

g) you can also request limitation of personal data processing.

For the purpose of exercising the above-listed rights, send us a letter or an e-mail to the address specified in Section 2 of the Policy.

In case you decide that the processing of your personal data by us violates the GDPR provisions, you have a right to file an objection to the President of the Personal Data Protection Office.

8. DO YOU HAVE TO PROVIDE US WITH YOUR DATA?

Provision of your data is, in every case, voluntary, but please remember that refusal to provide data will make it impossible for us to meet the purposes for which the data are collected, e.g.:

· it will prevent or greatly hinder us from contacting you or presenting you with the offer that you are requesting;

· it will prevent you from taking part in recruitment proceedings carried out by the Company;

· it will prevent conclusion or performance of a contract concluded with the Company.

9. PERSONAL DATA SECURITY

The Data Controller carries out activities to make sure that your personal data are processed in a secure mode, in compliance with the requirements of the GDPR. The Data Controller made sure that only authorised persons have access to data and only within a scope in which it is necessary on account of the tasks performed by them. Furthermore, the Data Controller takes any necessary measure to make sure that its subcontractors and other entities processing data at its request offer proper guarantees of data security.

10. CHANGES IN PRIVACY POLICY

This Policy is verified on an ongoing basis and up-dated if necessary. The current version of the Policy was adopted and is binding as of [_] 2020.

Nasze doświadczenie

10500Osób zatrudnionych

100Partnerów

15Lat doświadczenia