GDPR Information Obligation

On May 25, 2018, new regulations regarding the protection of personal data came into effect, resulting from the Regulation of the European Parliament and the Council (EU) 2016/679 of April 27, 2016, concerning the protection of individuals with regard to the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (GDPR).

We would like to assure you that we exercise particular care when processing personal data, we act in compliance with the law, and we implement appropriate technical and organizational measures to ensure the security of personal data entrusted to our company. We care for the protection of personal data already at the design stage of new activities.

DATA CONTROLLER

Agencja Wrocławska Sp. z o.o., with its registered office at ul. Powstańców Śląskich 7A, 53-332 Wrocław, Poland, is the data controller of personal data of its employees, collaborators, clients, and individuals who have provided their data via the website form or email, as well as other entities that have consented to the processing of personal data.

DATA PROCESSOR

Agencja Wrocławska Sp. z o.o. also processes personal data entrusted to it for processing by other data controllers, particularly when carrying out tasks where Agencja Wrocławska Sp. z o.o. acts as a subcontractor. In such cases, Agencja Wrocławska Sp. z o.o. acts as a processor of personal data.

LEGAL BASES AND PURPOSES OF PERSONAL DATA PROCESSING

Agencja Wrocławska Sp. z o.o. processes personal data only when at least one of the following conditions is met:

• The data subject has given consent to the processing of their personal data (Article 6(1)(a) GDPR),

• Processing is necessary for the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract (Article 6(1)(b) GDPR),

• Processing is necessary for compliance with a legal obligation to which Agencja Wrocławska Sp. z o.o. is subject (Article 6(1)(c) GDPR),

• Processing is necessary to protect the vital interests of the data subject or another natural person (Article 6(1)(d) GDPR),

• Processing is necessary for the performance of a task carried out in the public interest (Article 6(1)(e) GDPR),

• Processing is necessary for the purposes of the legitimate interests pursued by Agencja Wrocławska Sp. z o.o. or by a third party (Article 6(1)(f) GDPR).

The processing of data provided to Agencja Wrocławska Sp. z o.o. via email or the website form is based on Article 6(1)(a), (b), (c), or (f) GDPR and includes, among others, data such as name, surname, email address, and other data provided in electronic correspondence. These data are processed for the purpose for which they were provided.

Data processed based on consent (Article 6(1)(a) GDPR), particularly name, surname, email address, are used for the purpose for which the consent was given and are processed until the consent is withdrawn or until the purpose for which the consent was given is fulfilled.

Data processed in connection with the conclusion of a contract based on Article 6(1)(b) GDPR include, in particular, name, surname, address, email address, NIP/PESEL, bank account number, and other data resulting from the specifics of the particular contract, and are used for the purpose of performing that contract.

Data of individuals through whom our contractors perform contracts with Agencja Wrocławska Sp. z o.o. are processed based on Article 6(1)(f) GDPR and include, among others, name, surname, email address. These data are used for the purpose of fulfilling the contract.

Data entrusted for processing by other data controllers, particularly for the purpose of performing services provided by Agencja Wrocławska Sp. z o.o., are processed based on Article 6(1)(c) or (f) GDPR and include, among others, name, surname, correspondence address, email address, PESEL number, and other data necessary for the performance of services, depending on their nature. Processing takes place to fulfill the commissioned service.

OBLIGATION TO PROVIDE DATA AND CONSEQUENCES OF FAILURE TO PROVIDE DATA

Providing personal data in connection with the concluded contract is voluntary, but necessary for the conclusion and performance of the contract and the settlement of financial obligations related to it.

Giving consent to the processing of personal data, particularly for marketing or informational purposes, is voluntary, and consent can be withdrawn at any time without affecting the lawfulness of processing based on consent before its withdrawal.

Providing an email address and other data in electronic correspondence is voluntary. Withdrawal of consent to data processing will result in the inability to continue email correspondence.

RETENTION PERIOD FOR PERSONAL DATA

Personal data obtained for the purpose of performing a contract is retained until the claims arising from the concluded contract are time-barred or until the obligation to retain data arising from legal regulations expires, particularly the obligation to retain financial-accounting or employee documents.

If the sole basis for processing is consent, the withdrawal of consent will result in the cessation of data processing without affecting the lawfulness of processing based on consent before its withdrawal.

RIGHTS OF DATA SUBJECTS

The data subject has the right to access their personal data, the right to rectify it, request deletion, as well as the right to restrict processing, the right to data portability, and the right to object to the processing of personal data.

Where the legal basis for processing personal data is consent, the data subject has the right to withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

Moreover, if it is found that the processing of personal data violates the provisions of the GDPR, the data subject has the right to lodge a complaint with the supervisory authority – the President of the Office for Personal Data Protection (https://uodo.gov.pl/pl/p/kontakt).

RECIPIENTS OF PERSONAL DATA

Personal data may be disclosed to third parties with the consent of the data subject.

Furthermore, personal data may be disclosed when it is required for the performance of the contract between the parties or for the fulfillment of the obligations of the Data Controller.

In the case of processing personal data on behalf of third parties, Agencja Wrocławska Sp. z o.o. acts as a processor, and data are disclosed in accordance with the principles established by the Data Controller.

Entities that may be disclosed data include, depending on the category of data: entities processing personal data on behalf of Agencja Wrocławska Sp. z o.o., the Controller’s subcontractors, IT service providers, accounting service providers, entities providing occupational health and safety training, entities entering into insurance contracts, and other institutions authorized by law, such as the Tax Office, Court, or Social Insurance Institution (ZUS).

PROFILING

Agencja Wrocławska Sp. z o.o. may automatically adjust certain content to the needs of customers and individuals who have provided their data via the website form or email, as well as other entities that have consented to the processing of personal data, i.e., carry out profiling using the personal data provided by them.

Profiling primarily involves the automatic assessment of which products these individuals may be interested in, based on their previous actions taken on the Internet, including on the websites of Agencja Wrocławska Sp. z o.o., and displaying advertisements for products profiled in this way.

Profiling carried out by Agencja Wrocławska Sp. z o.o. does not result in decisions that produce legal effects concerning these individuals or significantly affect them in a similar way.

INFORMATION ON AUTOMATED DECISION-MAKING

Data will not be subject to profiling, which means they will not be used to automatically assign certain characteristics, properties, or to predict behaviors and preferences.

Contact details:

You can contact us in the following ways:

• By mail to the registered address: Agencja Wrocławska Sp. z o.o., ul. Powstańców Śląskich 7A, 53-332 Wrocław, Poland

• By email: hello@primeavenuegroup.com

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