3. What are the Purposes and Grounds for Personal data Processing? To Which Extent do We Process your Personal Data?
3.1. Your personal data is only processed for the following specific purposes set forth in legal acts:
3.1.1.1. The purpose of Company internal agreements, when it is necessary to process data in order to fulfill an agreement concluded with a person;
3.1.1.2. The purpose of provision of services, the conclusion and performance of contracts, when it is necessary to process data in order to fulfill an agreement concluded with a person;
3.1.1.3. The purpose of selection of the staff provided that you give your consent thereto, which is expressed by sending us your CV;
3.1.1.4. The purpose of sales and service quality assurance;
3.1.1.5. The purpose of direct marketing;
3.1.1.6. The the purpose of conducting market research and surveys;
3.1.1.7. The purpose of dealing with requests, complaints or suggestions made to the Company
3.2. We process personal data for purpose of conclusion and execution of contracts in order to conclude and properly fulfil the Company’s contracts/obligations. On this basis, the data may be obtained either on a contractual basis. Personal data that is processed for this purpose:
Title |
Description |
Data categories |
Name, a surname, phone number, residential address, email address, date of birth, bank account, email address, and other information necessary for contract signing |
Data legal basis |
Contractual (GDPR Article 6(1)(b) subparagraph) |
Data processing period |
The legal basis for storing personal data after the termination of an employment contract is GDPR Article 6(1)(c) subparagraph, which refers to compliance with a legal obligation |
3.3. We process customer personal data, including the data of prospect customers, for the purpose of provision of services, conclusion and performance of contracts seeking to conclude and properly fulfil the Company’s contracts / obligations. This is done with due consideration of the Company’s legitimate interests. On this basis, the data may be obtained either on a contractual basis or via direct communication between the Company and individuals, or via remote communication means (by telephone or e-mail) and etc. More information about about the personal data processed you can find here. Personal data that is processed for this purpose:
Title |
Description |
Data categories |
Data categories: Name, surname, phone number, email address, bank account number, signature, representation basis (authorization, statutes, etc.), position, payment information, payment period, other information related to the conclusion and performance of the contract, depending on the nature of the contract |
Data legal basis |
Contractual (GDPR Article 6(1)(b) subparagraph) |
Data processing period |
Personal data is stored during the validity of the contract and for 5 years after the contract has expired |
3.4. The personal data of applicants for employment is processed based on the consent of an individual as a part of the current and future recruitment process for employment purposes. When filling in an employment form, a user gives his consent to participation in the current or future recruitment process of the Company. This consent is applicable to all the documents submitted during the recruitment process. Personal data that is processed for this purpose:
Title |
Description |
Data categories |
Name, surname, date of birth, phone number, workplace, email address, residential address, education, date of receipt of CV, personal qualities, work experience, proficiency in foreign languages, ability to work with computer programs, other information in the CV, recommendation, and/or motivational letter, signature, information provided in the candidate’s application to participate in the selection process |
Data legal basis |
Your consent GDPR Article 6(1)(a) subparagraph |
Data processing period |
1 years from the date of your consent until you withdraw your consent, after the selection has ended and if the Candidate does not consent to the retention of his/her personal data for future selections, his/her personal data will be deleted within 30 days after |
3.5. For purpose of internal and external communication, which aim publicizing the Company’s activities in order to ensure the dissemination of information about key company events, operational goals, strategies, and change. Personal data that is processed for this purpose:
Title |
Description |
Data categories |
Name, surname, position, phone number, and email address, career facts and achievements, start date of the current position, qualifications, current managerial positions in other legal entities, education, work phone number, work email address, as well as photographs and video footage related to employment that were taken of the employee in the course of performing their direct duties. |
Data legal basis |
Your consent GDPR Article 6(1)(f) subparagraph |
Data processing period |
Data of media representatives (e.g., responsible journalists) are retained as long as they are actively working for the respective media outlet or responsible department. The personal data of Company employees are retained for 5 years after the end of the contract. |
3.6. For purpose of conflict of interest prevention and management to ensure transparency, fairness, and reliability in the Company. Personal data that is processed for this purpose:
Title |
Description |
Data categories |
We process the personal data that you provide in your private interest declaration: name, surname, place of employment, position, names and circumstances of connections with other companies, institutions, organizations, associations, foundations, etc., with which the person declaring interests is affiliated, nature of individual activities, other data provided in the declaration, name, surname, position, and the date of submission of the notification |
Data legal basis |
Your consent GDPR Article 6(1)(f) subparagraph |
Data processing period |
1 year after the termination of the employment contract |
3.7. We conduct information about gifts received by the Company employees for the purpose of corruption prevention. Personal data that is processed for this purpose:
Title |
Description |
Data categories |
Name, surname, position, the date of receipt of your gift, a description of the gift you received, the circumstances of the gift-giving, the donor, and the value of the gift |
Data legal basis |
Your consent GDPR Article 6(1)(f) subparagraph |
Data processing period |
1 year from the date the gift is recorded |
3.8. For purpose external and internal audits of the Company to ensure the transparency, efficiency, and compliance of the Company’s financial and operational activities with legal requirements and internal policies. Personal data that is processed for this purpose:
Title |
Description |
Data categories |
Name, surname, position, career facts and achievements, start date of current position, qualifications, current management positions in other legal entities, education, email address. Personal data that may be recorded in documents, including but not limited to emails and similar communications, which are provided for the purpose of conducting the audit |
Data legal basis |
Your consent GDPR Article 6(1)(f) subparagraph |
Data processing period |
10 years after the report is approved |
3.9. For the purpose of sales and service quality assurance, which means for the purpose of response to your inquiries regarding our decisions or services. You provide us with your personal data in writing or by telephone when you submit requests or lodge complaints regarding our services. When you contact us in writing, by e-mail or by phone, we will save correspondence data. Personal data that is managed for this purpose:
Title |
Description |
Data categories |
Name, a surname, a telephone number, e-mail and the data of a request regarding our services which is delivered by e-mail (e.g., the wording of a message) |
Data legal basis |
Your consent and our legitimate interest in enhancing the quality of our activities and services. |
Data processing period |
1 year from the date of your enquiry |
3.10. For direct marketing purpose, seeking to provide you with offers, newsletters and information about the Company’s services. Personal data that is processed for this purpose:
Title |
Description |
Data categories |
Name, a surname, a telephone number and e-mail. |
Data legal basis |
Your consent, GDPR Article 6(1)(a) subparagraph |
Data processing period |
Personal data is stored for 3 years if not revoked earlier. Upon subscribing to a newsletter, your personal data will be stored by the Company for the duration of your consent, as well as for 2 years after the expiration of the consent period for the purpose of ensuring archival requirements |
3.11. For purpose of conducting market research and surveys, personal data that is processed for this purpose:
Title |
Description |
Data categories |
Name, surname, email address, phone number, Contact information provided in the content of the survey, which may include email addresses |
Data legal basis |
The processing of your personal data is based on legitimate interest (GDPR Article 6(1)(f) subparagraph). Additionally, we have obtained your consent (GDPR Article 6(1)(a) subparagraph) |
Data processing period |
2 years from the date of your consent until you withdraw your consent |
3.12. Purpose of dealing with requests, complaints or suggestions made to the Company, personal data that is processed for this purpose:
Title |
Description |
Data categories |
Name, surname, e-mail address, telephone number, signature, date of referral, referral number (registration number), the information contained in the referral, the outcome of the referral, and, in the case of an e-mail communication with the person submitting the request, complaint or suggestion, the personal data recorded in the e-mail communication |
Data legal basis |
The processing of your personal data is based on legitimate interest (GDPR Article 6(1)(f) subparagraph) |
Data processing period |
3 years from the date of receipt of the request, complaint or proposal |
3.13. The Company may also process personal data for other purposes provided that an individual gives his consent thereto. Anyway, personal data is processed by the Company in compliance with the requirements of legal acts.
3.14. We may merge the personal data received from you with the data collected by us from other public or available sources (e.g., your personal data may be merged with the data legally obtained from third parties). To exercise your rights, you will always be able to request correction of errors in your personal data.
4. Do We Use Your Personal Data for Direct Marketing?
4.1. Yes, we may use your personal data for direct marketing purposes in order to provide you with offers, newsletters and information about our services, which, in our opinion, may be of interest to you. Nevertheless, we will use your personal data for this purpose provided only that you give your consent thereto.
4.2. For this purpose, we process your personal data specified in par. 3.6 of this Privacy Statement.
4.3. By granting the right to process your personal data for a direct marketing purpose, you also authorize us to contact you via communication means (e.g., by e-mail or a telephone) or other communications.
4.4. We may match available information about you with information available to third parties so that we would be able to provide you with offers and newsletters.
4.5. Notwithstanding the fact that you have given your consent to the processing of your personal data for direct marketing purposes, you may revoke this consent at any time with regard to all or some of personal data management actions. For this purpose you may:
4.5.1. Report withdrawal of your consent in the way indicated in e-offers and newsletters delivered to you (e. g., by clicking on the link ‘Unsubscribe newsletters’), or
4.5.2. Send a request to the e-mail address indicated in this Privacy Notice. The request must clearly indicate your name and surname. If you submit your request to cancel your consent in this way, we may ask for proof of identity.
4.6. If you withdraw your consent, we will terminate the processing of your personal data for direct marketing purposes as soon as possible.
5. How Long Do We Store Your Personal Data?
5.1. We store your personal data no longer than it is required by the data management purposes or stipulated by legal acts unless they provide for a longer data storage period.
5.2. The periods of storage of your personal data referring to each specific purpose of use are indicated in clause 3 of this Privacy Statement.
6. How Do We Secure Your Personal Data Protection?
6.1. We take the due technical and organizational measures to protect your personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure or access.
7. Who Do We Provide Your Personal Data To?
7.1. We guarantee that your personal data will not be sold, submitted or otherwise transferred to third parties without legal basis or used for purposes other than those for which data was collected. We will not transfer your personal data otherwise than in accordance with the provisions set forth in this Privacy Statement. Information regarding your personal data will be only provided in cases and in accordance with the procedures prescribed by law, e.g., if this is required by law enforcement authorities in the course of criminal proceedings.
7.2. We may disclose your personal data collected by us to the following third parties:
7.2.1. Third parties – service providers (e.g., technical service providers during the performance of our contracts with these service providers, including distribution of newsletters or execution of other marketing actions);
7.2.2. Service providers of third parties, whose services we normally use for data storage, telecommunication and website hosting purposes. In these cases, the Company will exert every effort to ensure the safety of your personal data in compliance with the highest standards and applicable legal requirements.
7.2.3. Third parties that perform an internal and external audit.