Privacy policy - Limpol - Food Distributor

27 July 2018

1. GENERAL PROVISIONS
1.1. This document is a description of the Privacy Policy of LIMPOL spółka z ograniczoną odpowiedzialnością with registered office in Kraków (address: ul. Ludwinowska 7, 30-331 Kraków), entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Kraków Śródmieście in Kraków, XI Economic Department of the National Court Register under KRS number: 0000146934, NIP: 6771735027 and REGON: 351196391, hereinafter referred to as the "Company". Its purpose is to determine the principles, manner of processing and use of data and information originating from the users of the website administered by the Company, including contacting the Company through the contact indicated therein, and also contains information on the rights of natural persons with respect to the personal data provided by them.
1.2 Please read this policy carefully. By accessing or using this website, submitting any personal information to us or contacting us using the telephone number, fax number or email address indicated on the Company's website, you accept the terms of this Privacy Policy.
1.3 Please note that when you leave the Company's website (e.g. by following a link to a website located on another domain), you are entering an area where this Privacy Policy does not apply. The Company is not responsible for the privacy policies of sites operated by other parties.
2. PERSONAL DATA CONTROLLER
2.1 The Company is the Data Controller of the personal data of users contacting and using the Company's website https://limpol.pl/.
2.2 The Company shall take special care to ensure that all personal data is processed in accordance with the purpose for which it was collected and used in accordance with the grounds and categories of data processed permitted by law.
3 CONTACT
3.1 For all matters relating to data protection and the processing of personal data originating from users of the website administered by the Company, as well as contacting the Company via the telephone number, fax number or email address indicated on the Company's website, you may contact via email: [email protected] or in writing at the Company's address indicated in point. 1.1. above.
4. SECURITY AND STORAGE OF INFORMATION AND RULES FOR DATA PROCESSING
4.1 The Company shall ensure the security of personal data by means of appropriate technical and organisational measures to prevent unlawful data processing and accidental loss, destruction and damage.
4.2 The Company shall take special care to ensure that personal information is processed in accordance with the principles of personal data processing set out in the DPA, that is:
(a) processed lawfully, fairly and in a manner transparent to the data subject (principle of lawfulness, fairness and transparency);
b) collected for specific, explicit and legitimate purposes and not further processed in a way incompatible with those purposes (purpose limitation principle);
c) adequate, relevant and limited to what is necessary for the purposes for which they are processed (principle of data minimisation);
(d) correct and updated as necessary; personal data which are inaccurate in the light of the purposes for which they are processed shall be deleted or rectified without delay (principle of accuracy);
(e) kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which the data are processed (principle of restriction of processing);
(f) processed in a manner that ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, by means of appropriate technical or organisational measures (principle of integrity and confidentiality).
5. PURPOSE OF PROCESSING OF PERSONAL DATA AND LEGAL BASIS
5.1 The Company collects personal data when:
a) the data subject shall contact the Company via the email address or fax address provided on the website,
(b) the data subject shall contact the Company via the telephone number provided on the website,
c) a user of a website administered by the Company subscribes to a newsletter,
d) a user of a website administered by the Company contacts the Company via a contact form.
5.2 In each case, the purpose of data processing by the Controller derives from the actions taken by users of the website administered by the Company, as well as those making contact with the Company via the telephone number, fax number or email address indicated on the Company's website.
5.3 The purposes and legal bases for the collection of personal data in such cases are:
a) In the case of contact via email/fax address or contact form (including for the purpose of subscribing to a newsletter), personal data will be processed for the purpose of a one-off contact in the indicated form with the data subject in relation to the request made, e.g. presentation of an offer, provision of information - legal basis: Article 6(1)(f) RODO (responding to requests and enquiries made using the contact form or in any other form, including storage of relevant requests and responses provided in order to maintain the principle of accountability);
(b) in the case of telephone contact, during which personal data may be transferred, the data will be processed in order to enable the data subject to be contacted in relation to the request made, e.g. to provide an offer, to provide information - legal basis: Article 6(1)(f) RODO (responding to requests and enquiries made using the contact form or in any other form, including storing relevant requests and answers provided in order to maintain the principle of accountability);
c) in the case of simultaneous consent to receive marketing communications, personal data will be used to present information about the Company's products and services; providing the data and giving such consent is voluntary, however, their absence will prevent the receipt of marketing communications - legal basis: Article 6(1)(a) RODO (conducting marketing activities promoting the conducted activity using e-mail addresses and telephone numbers);
d) If you enter into a contract with the Company, including in the case of claims, your personal data will be used for the purpose of performing the contract and claims arising therefrom - legal basis: article 6(1)(b) RODO;
(e) in the case of a recruitment application with simultaneous consent to the processing of personal data for recruitment purposes, personal data will be used for recruitment purposes for the position advertised - legal basis: article 6(1)(a) RODO.
6. PERIOD OF PROCESSING OF PERSONAL DATA
6.1 The Company shall examine whether personal data processed by it is processed for a longer period than is necessary for the purposes for which the data are processed.
6.2 Personal data processed on the basis of the consent given will be processed until the consent is withdrawn or the purpose for which the data was collected ceases. The consent given may be withdrawn at any time without affecting the lawfulness of the processing carried out on the basis of the consent before its withdrawal.
6.3 Data provided via the contact form or by telephone, fax or email will be processed for the duration of the request, e.g. for the provision of an offer or information, but no longer than 2 years in order to maintain accountability.
6.4 Data processed in connection with the presentation of an offer, the provision of a service, the recognition of a complaint, the conclusion and performance of a contract shall be processed in accordance with the applicable regulations, but no longer than until the expiry of the period in which the Company or the data subject may assert claims in connection therewith.
6.5 Data processed for direct marketing purposes will be processed until you withdraw your consent or object.
7. USER RIGHTS
7.1 The Company is responsible for the exercise of the rights of data subjects whose data it processes, in accordance with the applicable legislation. If you have any questions or requests regarding the scope and exercise of your rights, or if you wish to contact us specifically to exercise a specific data protection right, please contact us at the following email address: [email protected]. The Company reserves the right to exercise the following rights upon positive verification of the identity of the person requesting the activity in question.
7.2 Access to personal data. Individuals have the right to access the data that the Company holds.
7.3 Amendment of personal data. Individuals have the right to change, including update, their personal data that the Company processes.
7.4 Withdrawal of consent. Where personal data is processed on the basis of consent, individuals have the right to withdraw that consent at any time.
7.5 Right to restrict processing or object to the processing of personal data. Individuals have the right to restrict processing or to object to the processing of their personal data at any time on the grounds of their particular situation, unless the processing is required by law.
7.6 Right to request erasure and right to data portability. Individuals have the right to request the erasure of data when they are no longer necessary for the purposes for which they were collected, when consent is withdrawn, when objections to processing are raised or when processing is unlawful. The right to data portability, on the other hand, applies when the processing of a person's data is based on consent or contract and when the processing is carried out by automated means. In this case, the Company shall issue or transmit to the designated entity the data of the person requesting it in a structured, commonly used machine-readable format.
7.7 The Company informs you that there is no obligation to delete data where the processing is necessary for: complying with a legal obligation to process under Union or Polish law, or performing a task carried out in the public interest, or for establishing, pursuing or defending claims.
7.8 Whenever an individual's rights under the law and this Privacy Policy are considered to be violated, the individual shall have the right to lodge a complaint with the President of the Data Protection Authority.
8. SCOPE OF SHARING USER DATA
8.1 The Company declares that it does not sell, share or transfer the personal data collected for processing to other persons or institutions, except with the express consent or at the request of the person concerned or at the request of state authorities authorised by law for the purpose of their investigations.
8.2 The Company informs that the personal data processed by the Company, including the data processed for marketing purposes, may be made available to an affiliated entity, in particular the company QUISELLE LIMPOL spółka z ograniczoną odpowiedzialnością S.K.A. with its registered office in Kraków (KRS no. 0000290483). The legal basis for the above is Article 6(1)(f) of the RODO (and recital 48 of the RODO), and therefore such processing of personal data will occur when it is necessary for the purposes of the legitimate interests pursued by the Company, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require the protection of personal data, in particular where the data subject is a child.
8.3 The Company informs that personal data processed by the Company, including data processed for marketing purposes, may be shared with other entities only if permitted by law. In such case, the Company shall provide for provisions and security mechanisms in the relevant agreement concluded with the third party in order to protect the data and maintain the Company's standards of data protection, confidentiality and security. Contracts of this kind are called entrustment agreements for the processing of personal data, and the Company has control over how and to what extent the entity to which the Company has entrusted the processing of certain categories of personal data processes such data. In connection with the above, we would like to point out that the recipients of the personal data that the Company processes as a personal data controller may be entities that process personal data pursuant to personal data processing entrustment agreements concluded with the Company, including financial institutions, with the proviso that the Company transfers personal data to such entities only to the extent that it is actually necessary to achieve the purpose in the form of concluding and performing a contract with the data subject.
9. TRANSFER OF YOUR DATA OUTSIDE THE EEA AREA
The Company informs you that personal data processed by the Company is not transferred outside the EEA.
10. CHANGES TO THE PRIVACY POLICY
The Company undertakes to review this Privacy Policy on a regular basis and to amend it when it becomes necessary due to: new legislation, new guidelines from authorities responsible for overseeing data protection processes, practices in the area of personal data protection. The Company also reserves the right to amend this Privacy Policy in the event of changes in the technology by which it processes personal data (insofar as such change affects the wording of this document), as well as in the event of changes in the methods, purposes or legal basis for the processing of personal data by the Company.