By concluding any agreement with us, you provide us with your personal data. On account of the specific nature of activities pursued by us, personal data provided to us is also provided to our employees or subcontractors. It may happen that in execution of agreements your personal data will be provided to third parties, with which we cooperate directly or indirectly. The purpose of provision of such data is performance, for your benefit, of the agreement on the top level.

This Privacy Policy provides information on which personal data are collected by us and for what purpose.

Which data are processed by us?

We process data that you provide or leave as part of the agreement concluded with us. These are, in particular, such data as the first name and surname, address and telephone number. We also process data received from other entities as a result of performance, for your benefit, of agreements, enabling your identification.

We do not process any data that is redundant with respect to performance of the agreement.

Who is the data controller?

The data controller is SFB Polska Sp. z o. o., ul. Rycerska 6, Rojów, 63-500 Ostrzeszów, Poland.

What are the purposes and the legal bases for processing your personal data and for how long is such data processed?

The legal bases for the processing of your data are:

  1. Art. 6.1.a) of the GDPR: your consent that we can process your personal data for purposes other than related to performance of agreements, for example for carrying our a recruitment process;

  2. Art. 6.1.b) of the GDPR: necessity for performance of the agreement to which you are a Party - for the purpose of performing such agreement;

  3. Art. 6.1.c) of the GDPR: necessity of compliance with a legal obligation to which we are subject - for the purpose of fulfilling any obligation to which we are subject on the basis of legal provisions;

  4. Art. 6.1.d) of the GDPR: necessity of protecting your vital interests - for the purpose of performing activities aimed at protection of your interests, when we are unable to procure your statement of will with respect to the conclusion of the agreement;

  5. Art. 6.1.f) of the GDPR: necessity for purposes of legitimate interests pursued by the controller or by a third party.

 

Term of data storage

Your data collected by us will be processed for a period of time specified in relevant provisions of the commonly applicable law. After such period, the data collected by us is processed for a period necessary to destroy documents or to permanently delete the data from our data media.

Is there a requirement to provide data?

Provision of personal data is voluntary; however, failure to provide data marked as necessary for performance of an agreement for your benefit will prevent execution of such agreement.

To which recipients will your data be provided to?

Your data may be provided to processors processing personal data at our order, whereas such entities process data on the basis of an agreement concluded with us and exclusively in compliance with our instructions. Your data may also be provided to entities authorised to receive such data on the basis of an applicable law, e.g. law enforcement agencies in case such agency has filed a request based on a relevant legal basis. Your data may be, in certain cases, provided to recipients from third countries, i.e. from countries outside of the European Economic Area, should it be necessary for provision of services for your benefit or if it is conditioned by another, important legal basis.

What are your rights related to personal data processing?

You are vested with the following rights related to the processing of your personal data by us:

  • right of access to your data, including receipt of copies of data;

  • right to demand rectification of data;

  • right to remove data (in specific situations);

  • right to lodge a complaint to a supervisory body involved in personal data protection;

  • right to limit data processing.

If your data is processed on the basis of a consent, you may additionally exercise the rights below:

  • right to withdraw your consent within a scope in which data is processed on this basis. Withdrawal of your consent will not affect the legitimacy of processing performed on the basis of your consent prior to its’ withdrawal.

If your data are processed on the basis of a consent or as part of the provided service (data are necessary for the purpose of service performance), you can additionally exercise the rights below:

  • right to transfer personal data, i.e. the right to receive your personal data from the data controller, in a structured, commonly used, machine-readable format. You can send such data to another data controller.

To exercise the rights above, please get in touch with us (contact data provided above).

Furthermore, you have a right to lodge a complaint to the supervision authority: the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw, Poland.

Cookies

Our websites and applications use web beacons, such as, e.g., cookies or local storage, to collect and process personal data for the purpose of customising the content and advertisements as well as analysing traffic on websites, applications and on the Internet. This is the manner in which such technology is used by our Trusted Partners, who also wish to adjust their advertisements to your preferences.

By using our websites and having the settings of your browser properly configured, you agree for the use of cookies and other similar technologies in compliance with our Privacy Policy. If you do not agree for the use of cookies or other similar technologies by us or if you wish to restrict the potential scope of use of cookies and similar technologies, you should change the settings of your browser in a relevant manner or resign from using our websites.

What are cookies?

Cookies are small data files, stored on the end device of the User of our websites, which the browser sends to the server every time a connection is established with our websites from a given end device, i.e. when you visit various websites (i.e. your computer, tablet, smart phone, etc.).

Cookies usually contain the name of the website from which they originate, their lifetime and a generated unique number used to identify the browser from which a connection is made with the website and other necessary data. In this Policy, information pertaining to cookies is also applicable to other similar technologies applied on our websites.

Other technologies similar to cookies (hereinafter referred to as: “other similar technologies”)

To guarantee efficient use of our websites, we also use technologies other than cookies, i.e. Local Storage, which is used to store data that was saved when visiting a website in a separate part of the browser's memory. The access to data in Local Storage may only be obtained by a website the data of which was saved in the browser. Data in the Local Storage are retained in the browser after its’ closing.

What is the purpose of cookies and other similar technologies?

Cookies and other similar technologies are used for the following purposes:

- to make our websites operate faster and to make them easier to use;

- to customise the content and the advertisements available on our websites to the user’s interests and expectations;

- to facilitate presentation of advertisements to the user on our websites, customised to the user’s interests;

- to collect aggregate statistics that allow us to understand the way in which people use our websites (including: our services, our applications) and help us improve their functionalities and content.

The following cookies may be used on our websites:

- session cookies: they are retained on your device only during the use of our websites;

- permanent cookies: they are retained on your device for the period of their life-time or until you remove them.

Types of cookies or similar technologies used on our websites:

Type of cookies:

What are they used for and in which manner:

Authentication

To identify a logged-in User, in order to show proper information to such User, corresponding to his/ her interests.

Safety

Support for mechanisms preventing abuse on our websites.

Necessary for website operation

Necessary for correct operation and display of our websites; they allow you to browse the site and use the site’s elements. Optimising the use of our websites, e.g. they may remember previous activities (e.g. open texts) when returning to the website during the same session.

Improving functionality

Remembering your settings and choices (e.g. User name, region in which you are, customised settings, language and communication preferences, user activity history) in order to provide you with more customised content and services. They also allow you to watch films and use social media tools and are helpful when filling in forms. Irrespective of the above, via the so-called social media plugs, they provide the User with functions, important information and content adjusted to his/ her needs.
To improve the functionalities of our websites, data pertaining to activities on websites are used, such as geo-location data (city) and demographic data (age, sex) - these data are aggregated in a manner that the group segment does not allow for identification of a User’s individual identifier.

Advertisement

Providing you with advertisements corresponding to your activities on our websites, your interests, habits, with simultaneous restriction of display of the same advertisement or an advertisement not adjusted to your interests on our Websites, or advertisements and on websites of third parties. Along with the necessary analytics and measures, to present advertisements to specific target groups, data pertaining to the history of visited websites, activity on websites (e.g. your clicks, history of purchases, manner of using services), geo-location data and demographic data may be used for marketing purposes. The above-listed data about the Users’ activity on websites may be combined with demographic data provided to us by Users during registration for our services (e.g. age, sex, size of city): the data are aggregated in a manner that the constructed group segment of interest does not allow for selecting an individual User identifier, and thus the User identification is not possible. Data aggregated in this manner may be used by us, and also made available to third parties, if there is a specific legal basis. Advertising cookies also allow for measuring the efficiency of advertising campaigns (e.g. by calculating the number of persons who clicked a given advertisement and were transferred to the advertiser’s website).

Do we use cookies or other similar technologies of third parties?

Yes; by using our websites, you may receive cookies deriving from our Trusted Partners. Marketing purposes of our Trusted Partners: our Trusted Partners may use cookies or other similar technologies in order to determine whether a specific advertisement was displayed by them or on their commission and to collect information about the manner in which users react to the advertisements displayed to them. Our Trusted Partners may also, pursuant to the user's consent, customise the presented advertisements to the user’s interests specified on the basis of information made available to our Trusted Partners by the user in the course of using websites or applications. If the User gave his/ her consent, referred to in the previous sentence, then the information may also be made available for further marketing purposes to other entities displaying advertisements or commissioning advertising activities on the Internet. For these purposes, we may also cooperate with Trusted Partners in order to display advertisements to the Users on our websites or outside of them, after the User has visited a specific site or application. Apart from the Local Storage technology, our websites may also use other technologies and technical solutions that allow for gaining access to information stored in a browser/ on an end device, whose operation is necessary to use our websites or desired on account of their specific nature. We also use analytical software of third parties (e.g. Google Analytics) which places, on the user’s end devices, codes that enable collection of data about the Users.

How can I change cookie settings or delete them?

A majority of Internet browsers is set for automatic acceptance of cookies. However, you can change the browser settings to block cookies - fully or in part, e.g. only from third parties or in order to receive a notification every time cookies are sent to your device. You need to remember that if you block cookies used by us, it may adversely impact the comfort of using our websites; for example, you may not receive personalised information when browsing. It will also prevent us from collecting information about the use of our websites for ongoing improvement of their content and our services.

Document status/ Date of creation

Version I/ 25.05.2018

Prepared by:

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Content verification

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Formal verification

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Approved for use

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Confidentiality level

A – generally available