[Definitions]
For the Information Clause to be transparent and precise, we use the following definitions:
Information Clause: this Information Clause that fulfils the information obligations within meaning of articles of 13 and 14 of GDPR.
Data: Personal data, that is all information about an identified or identifiable data subject – in relation to which the information obligation is fulfilled through ongoing disclosure of information included in the Privacy Policy and the Information Clause.
You: You, that is the persons, whose data is processed according to the Information Clause.
We or the Controller of Predica: Predica LLC with registered office in Warsaw, ul. Altowa 2, 02-386 Warsaw, entered into the register of entrepreneurs of the National Court Register kept by the District Court for the city of Warsaw in Warsaw, 12th Commercial Department of the National Court Register under number KRS 0000908473, REGON (statistical number):280404074, NIP (tax identification number) : 5783048378 – the entity that discloses the Information Clause and is also the Data Controller;
GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council 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 Protection Regulation).
[Data]
We may receive your Data:
(a) directly from you or (b) from third parties.
In particular, but not always, the Data may include: contact data, such as name, surname, e-mail address, address of the registered office or correspondence address, registration or verification data (if applicable, e.g. in case of cloud services); information necessary for accounting and fiscal purposes, as defined in the legal provisions; possible other data that you decide to disclose to us.
[Purpose, legal grounds and period of personal data processing]
We process personal data for the following purposes. In case of every purpose, we have presented legal grounds of processing and period of personal data processing for that purpose.
I.
PURPOSE: Marketing activities. Delivery of newsletters. Closed e-mail advertising campaign and direct electronic mailing of offers, regarding the Administrator and his business partners.
PROCESSING GROUND: Art. 6 sec. 1 letter a of GDPR – processing of data related to the Company’s marketing activities is performed always upon consent of the data subject.
PROCESSING PERIOD: Immediately after withdrawal of consent by the data subject.
II.
PURPOSE: Data processing for the purpose of protection of rights and assertion of claims, to which the Company is entitled.
LEGAL GROUND: art. 6 sec. 1 letter f of GDPR – processing is necessary for purposes resulting from reasonable interests of the Controller or a third party. The Controller’s legitimate interest is in particular defence and possible assertion of claims resulting from the Act on Copyrights and Related Rights of 4 February 1994 (Journal of Laws of 2019, item 1231, as amended) and the personality rights of the Controller of a third party.
PROCESSING PERIOD: Data may be processed only until the period of limitation of claims.
III.
PURPOSE: Data processing for the purpose of rendering of services and ongoing contacts with customers.
LEGAL GROUND: Art. 6 sec. 1 letter f of GDPR – the controller’s legitimate interest. In this case, the controller’s legitimate interest means a possibility to contact customers in respect to the services that we render.
Processing may be also based on art. 6 sec. 1 letter b of GDPR – processing in order to execute a contract with a data subject, if you are a natural person who uses our services.
Processing period: Until a valid objection is raised in compliance with art. 21 of GDPR.
IV.
PURPOSE: Statistical measurements of use of the website (cookies).
LEGAL GROUND: Art. 6 sec. 1 letter a) of GDPR – cookies are used upon your consent.
PROCESSING PERIOD: Used cookie files are installed for various periods of time. Some of them expire when a browser is closed, other are active for a few days, months or even years, mainly to ensure that the information on choices made by the user is not lost. They are deleted after such period.
You may find out more about cookie files further in this document.
V.
PURPOSE: Recruitment of employees or associates via electronic forms
LEGAL GROUND: Art. 6 sec. 1 letter a GDPR – the data is processed for the purpose of carrying out a given (individual) recruitment process based on your consent; we collect a separate consent from you in order to create and maintain a permanent database of job candidates for the purposes of subsequent recruitment processes.
PROCESSING PERIOD: Your Data will be deleted immediately after the end of the recruitment process, unless you have consented to the processing of Data for the purposes of subsequent recruitment – in such case, data is deleted within 2 years from the end of the recruitment process, during which you consented to further data processing.
[Retention period]
We process the data only as long as it is necessary. After fulfilment of the purpose of Data processing, the Data will be deleted or anonymised, if the legal provisions do not require from us or entitle us to retain some or all your Data.
[Consequences of refusal to provide data]
In relationships with you, we process data only under an agreement with you or a third party. When entering into an agreement with you, we process only data necessary for execution of the agreement. So if we ask you to provide your data, the refusal to provide them makes it impossible to enter into the agreement (disclosure of data is a condition of conclusion of the agreement).
[Data Recipients]
Recipients of the particular categories of Data may be: authorities, where proceedings are pending or which require disclosure of such Data, including from foreign jurisdiction, in the scope and for the purpose that have been agreed with you. Moreover, recipients may include persons who render services for us, including IT, legal, accounting services, etc., as well as carriers and couriers. We do not expect to transfer your Data to third countries, that is countries outside the EEA (European Economic Area). However, if it takes place, we will make sure that all requirements defined in the applicable legal provisions are met.
In the case of the recruitment process described in point V of this Information Clause, your Data is also processed by:
· Predica BMC sp. z o.o, with its registered office in Warsaw, at ul. Altowej 2, 02-386 Warsaw – as the Administrator;
· eRecruitment Solutions sp. Z o.o. with headquarters in Warsaw, at ul. Prosta 68, 00-838 Warszawa – acting as a processor within the provided recruitment tool
[Your rights]
Depending on circumstances, GDPR grants you a number of rights related to you Data processing. These are, for instance: (a) the right to access your Data, including to obtain copies of the Data; (b) right to demand rectification of Data; (c) right to delete Data; (d) right to restrict processing of your Data; (e) right to withdraw consent – in the scope, in which your Data are processed under consent. Remember that withdrawal of a consent does not affect legitimacy of data processing under a consent before it is withdrawn; (f) right to transfer Data; (g) right to object to Data processing; (h) right to file a complaint to the supervisory authority – the President of the Data Protection Office.
[Cookies]
The website uses cookies. Cookie is a file with an ID (a series of letters and digits) that is sent by a WWW server to an Internet browser and saved by it. Cookies used by websites enable recognition of the User’s computer during next visits on the website and are aimed only at facilitation of use of the website.
The website uses to types of cookies, that is permanent and session cookies. Permanent cookie files are saved by the browser and are retained there for a period defined in their parameters or until they are removed by the User, while session cookies are kept until the browser is closed by the User.
We use the following types of cookies for User’s identification and traceability, and for identification of Users who come back to the website:
Necessary cookies of the first site to remember details of the User’s session and ensure coherent review of the site.
Necessary cookies of other companies in order to use the security settings.
Monitoring of third party’s cookies for the purpose of traceability and analysis of use of the website and enable re-marketing.
Google Analytics is used for analysis of use of the Website, generation of statistical data and other information on use of the Website in order to analyse use and usability and remarketing. We also use Facebook Pixel to trace visits on the website in order to use it in the remarketing process.
[Updating of information]
The Information Clause is the current information about personal data processing. The contents of the Information Clause may change in order to ensure its compliance with the actual circumstance of your personal Data processing by us.
[Contact]
If you have any doubts about your Data processing, please contact us via e-mail at [email protected]
DPO: Przemyslaw Wrzesinski, [email protected]