(A) General Information
The present Policy has been issued by LINK Sp. z o.o., a company with its registered office in Wiązowna (hereinafter: “LINK”), and is intended for persons from outside the LINK Sp. z o.o. organization, subsidiaries of LINK Sp. z o.o. and its affiliates (hereinafter: the “Capital Group”) with whom we maintain relations, including Customers and users of our Website (hereinafter: “Website”), as well as for other users of our services (referred to jointly as “You”). The definitions used in the present Policy are explained in detail under Item (M) below.
For the purpose of the present Policy, LINK shall act in the capacity of a data Controller. Additional contact details of the Controller are provided under Item (L) below.
The present Policy may be amended and updated to reflect changes in our Personal Data Processing practices, or to reflect changes to applicable legal regulations. You are encouraged to become acquainted with the present Policy and to regularly check this website in order to verify whether any changes have been introduced to the present Policy, in accordance with the provisions thereof.
(B) Processing Your Personal Data
Collection of Personal Data: We may collect your Personal Data, such as: first name, last name, address and contact details, including e-mail, phone number, as well as position within and information about your company. Below is a list of examples of the sources from which we may collect your Personal Data:
- Your Personal Data may be acquired after they have been provided by You personally (e.g. when you contact us via our website, by e-mail, by phone or in any other manner).
- Your Personal Data may be collected in the course of our business relationship / while concluding or performing an agreement (e.g. when you purchase our product or service).
- Your Personal Data may be collected if you have decided to publish these on social media sites (e.g. we may collect information from your social media profile, to the extent to which such information is visible publicly).
- We may receive your Personal Data from third parties (e.g. from your business partners, from financial brokers, from law enforcement agencies, including administration bodies or courts, etc.).
- We may collect your Personal Data or ask for their provision during your visit on our Website, or while You are using any of the functionalities or resources made available via the Website. Whenever you visit the Website, your device and browser may automatically provide certain types of information (such as type of the device, operating system, type of browser used, browser settings, IP address, language settings, dates and times at which connections with the Website are established, as well as other technical information related to the connection). Some of them may constitute your Personal Data. None of your Personal Data shall be stored during your visit on the Website, unless you provide an express consent. However, temporary storage of journal and cookie files enhances your Website user experience. Therefore, you are requested to provide your consent for such use of data on our Website. You are by no means required to provide such a consent. The Website may also be taken advantage of if no consent has been provided. However, in some cases in which the consent has not been given, the functionality of our Website may be limited to a certain extent.
Creation of Personal Data: We may also create your Personal Data, such as a log of your contacts with us, and a log containing your transaction history details.
Processed Personal Data: The categories of your Personal Data that we may process include the following:
- Personal details: first name (first names), last name (last names), name actually used, sex, date of birth/age, nationality, occupation.
- Contact details: delivery address, company (employer) address, phone number, fax number, e-mail address, social media profile details.
- Payment details: billing address, bank account number, first and last name of the bank account holder, account security data.
- Message wording: all messages, inquiries, statements, views and opinions about us you have decided to provide us with or You have published in social media or via the Website.
Legal basis for the processing of Personal Data: while processing your Personal Data for purposes referred to in this Policy, we may quote, depending on the circumstances, one or more of the legal bases referred to below:
- We have received your prior consent to process (this legal basis applies only to the processing of data you are allowed to provide on a voluntary basis - it does not apply to the processing of data which you are required and obliged to provide);
- The processing is required in connection with any agreement You have concluded or intended to conclude with us;
- The processing is required under a legal obligation;
- The processing is required in order to protect the crucial interest of any person; or
- We have a substantiated need to process, in order to manage, conduct and promote our activity, and the processing does not infringe any of your interests, as well as fundamental rights and freedoms.
Processing your Sensitive Personal Data: We do not collect or process, in any other manner, your Sensitive Personal Data, with the exception of:
- Processing that is required or permitted under applicable legal regulations (e.g. to comply with our reporting obligations concerning discrimination prevention);
- Processing that is required to detect and counteract offences (including counteracting fraud);
- Processing that is required in order to determine, exercise or protect the rights that one is entitled to; or
- A situation in which we have received from You, in accordance with applicable legal regulations, a prior, express consent for processing your Sensitive Personal Data (as mentioned above, this legal basis applies exclusively to data whose disclosure is voluntary - it does not apply to obligatory or required processing).
Purposes for which your Personal Data may be processed: The purposes for which your Personal Data may be processed in accordance with the applicable legal regulations include the following:
- Our Website: maintaining and managing our Website, presenting its content; publishing advertisements, as well as other promotional and marketing information; communicating with and contacting customers and suppliers, as well as potential employees or associates via our Website.
- Offering our products and services to you: presenting our Website and other services; supplying promotional materials upon your request, communications related to our services.
- Marketing communication: presenting, in any other manner (including by e-mail, telephone, text message, social media, regular mail and personal contact) messages and other information that may be of interest for you, including distribution of the newsletter, upon obtaining, in accordance with appropriate procedures, your prior consent for receiving such information, in line with applicable legal regulations.
- Communications and IT operations: managing communications systems, ensuring security of IT systems, performing IT security audits.
- Finance management: sales, finance, audit and sales management.
- Surveys: involving you in order to acquire your opinions about our products and services;
- Improving our products and services: identifying problems concerning existing products and services; planning improvements of existing products and services; developing new products and services.
(C) Making Personal Data available to third parties
We may make your Personal Data available to other entities within the Capital Group, including our parent company: Waberer’s International Nyrt with its registered office in Budapest, Hungary, in relation to justified needs related to our activity (including for the provision of services and for maintaining our Website), in compliance with applicable legal regulations. Additionally, we may make your Personal Data available to:
- Administration or court authorities, upon their request, in order to inform about actual or suspected violation of applicable legal regulations;
- Accountants, auditors, lawyers and professional advisers of entities comprising the Capital Group, with the confidentiality obligation resulting from a contract or binding upon such entities by virtue of law taken into consideration;
- Third parties processing the personal data they have been entrusted with on our behalf (such as payment intermediaries, transport companies, etc.), regardless of where their registered office is located, in observance of the requirements set forth in the present Item (C) below;
- To any entity, enforcement agency or court, to the extent required to identify, exercise or protect one’s rights;
- To any entity competent for preventing, investigating, detecting or charging with offenses, or for enforcing penal measures, as well as for protecting against and preventing public security threats;
- To any entity taking over, in the case of any part of our company or its shares being sold or handed over (including in the event of reorganization, dissolution or liquidation); or
- Currently, we are using, on our websites, mechanisms redirecting you to the following social media platforms: LinkedIn, Facebook, YouTube.
If any third party is involved by us to process your Personal Data pursuant to a data processing agreement concluded with such an entity, the processor shall be obliged to: (i) process exclusively the Personal Data that will be identified in our prior, written orders; and (ii) apply any and all measures ensuring confidentiality and security of the Personal Data, and comply with all other applicable legal requirements.
Your Personal Data acquired via the Website are processed by the company of Visual Media Polska Sp. z o.o. with its registered office in Bydgoszcz, which has created this Website and which provides, for the benefit of LINK, technical assistance services in relation to the operation of the Website. The processor stores and processes your Personal data collected in the process of your using the Website. The processor ensures complete security of your Personal Data by applying relevant and latest technical and organizational measures. The processor must not use your Personal Data that have been made available to it for any purposes other than those for which the Personal Data has been received. We have concluded, with the processor, a personal data processing agreement, pursuant to which the processor has been obliged to comply with the requirements concerning the protection of your Personal Data.
(D) International Transfers of Personal Data
We can send your Personal Data to a third country other than an EU member state, i.e. the United States of America (USA). This pertains to the processing of personal data in connection with the distribution of newsletter to the recipients indicated by us as our partner in this regard – Agent Buzz Sp. z o.o. with its registered office in Warsaw – is provided with services from entities whose servers are located in the United States of America (USA). Such transfer is possible under the EU-U.S. Privacy Shield and under the Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequacy of the protection provided by the EU-U.S. Privacy Shield (notified under document C (2016) 4176, “Decision”). The recipients of these data in the USA acceded to the EU-U.S. Privacy Shield programme and committed themselves to comply with specific rules and obligations specified in the Decision. Moreover, at present, we do not intend to transfer any of your Personal Data to third countries other than the United States of America (USA) that are not European Union member states, or to any international organisations. Should a need arise, the present Policy will be modified, and your Personal Data will be subject to a transfer only pursuant to the provisions of Standard Contractual Provisions that will be implemented prior to transferring such Personal Data. In such a case, you will be authorized to demand a copy of our Standard Contractual Provisions, by using the contact details specified under Item (L) below.
(E) Protection of Data
We have introduced relevant technical and organizational protection measures dedicated to protecting Personal Data against accidental or illegal destruction, loss, modification, unauthorized publication, unauthorized access, as well as against illegal and unauthorized forms of processing, in line with applicable legal regulations.
You are responsible for making sure that all Personal Data are submitted to us in a secure manner.
(F) Accuracy of Data
We shall take reasonable efforts to ensure that:
- Your Personal Data we are processing are accurate, and, if necessary, up-to-date; and
- Any of your Personal Data we are processing, which are erroneous (with respect to the purpose for which they are processed) are erased or amended without undue delay.
We may ask you, from time to time, about the accuracy of your Personal Data.
(G) Minimizing the Scope of Data
We shall take every reasonable effort to ensure that the scope of your Personal Data we process is limited to the Personal Data that are reasonably required for the objectives identified in the present Policy.
(H) Storing Data
The criteria determining the duration of the period over which we store your Personal Data are as follows: we will store copies of your Personal Data, in a form enabling identification, only as long as required for the achievement of the objectives identified in the present Policy, unless the applicable laws require that such data be stored over a longer period of time. We may, in particular, store your Personal Data over any period of time required to identify, exercise or protect any rights that we or you are entitled to.
(I) Your Rights
According to applicable laws, you may exercise a number of rights concerning the processing of your Personal Data, including:
- The right to access your Personal Data or copies of your Personal Data we are processing, along with information about the nature of processing and about making such Personal Data available;
- The right to rectify any errors in your Personal Data we are processing;
- The right to demand, for justified reasons and if permitted legally:
- That your Personal Data we are processing be erased; or
- That the processing of your Personal Data we are processing be limited;
- The right to transfer the copies of your Personal Data we are processing to another controller, to the extent applicable;
- The right to withdraw the consent to process your Personal Data, if the data are processed based thereon; and
- The right to lodge a complaint with a Personal Data Protection Authority (President of the Office for Personal Data Protection), in relation to the processing of your Personal Data by us on or our behalf;
RIGHT TO LODGE AN APPEAL
If your Personal Data are processed by us for the purpose of performing a task executed as part of public interest, granted public authority or when such processing is necessary due to legally justified interests executed by us, you are entitled to lodge an appeal against the processing of your Personal Data – due to reasons connected with your particular situation. After you lodge such an appeal, we will cease the processing of your Personal Data for the above mentioned purposes unless we are able to indicate that there are legally justified bases concerning this data which are of superior nature to your interests, rights and freedoms, or your Personal Data are necessary for potential determination, pursuit or defence of our claims.
You may lodge an appeal against the processing of your Personal Data for the purpose of direct marketing at any moment. If you exercise this right, we will stop the processing of your data for this purpose.
The above shall be without prejudice to any of your rights under statutory or other acts of law.
In order to take advantage of one or more of your rights, or to ask about those rights or about any other provisions of the present Policy, or about the processing of your Personal Data, please contact us using the contact details provided under Item (L) below.
(J) Cookie Files
If you grant an express consent to receive our newsletter, we may provide you with an electronic newsletter with commercial information, for promotional and information purposes. Personal Data submitted to us in relation to newsletter subscriptions shall be used exclusively for the purpose of distributing the newsletter. You may cancel your newsletter subscription at any time, by using the resignation option provided in the newsletter, by using the opt-out link provided in the footer of the e-mail message, or by contacting the Controller in any other manner.
The data received from you will be stored for the above mentioned purpose exclusively, over the period of time over which you will be subscribing the newsletter, and until you withdraw your newsletter subscription consent.
The Newsletter is distributed by our partner – Agent Buzz Sp. z o.o. with its registered office in Warsaw, which processes your Personal Data on our behalf. The processor also ensures complete security of your Personal Data by applying relevant and latest technical and organizational measures. The processor stores and processes your Personal Data collected during the registration process, i.e.: e-mail address and, if applicable, IP address and newsletter subscription-related data. The processor must not use your Personal Data it has been provided with for any purposes other than those for which the Personal Data have been received. We have concluded, with the processor, a personal data processing agreement, pursuant to which the processor has been obliged to comply with the requirements concerning the protection of your Personal Data.
The provision of your Personal Data in relation to the newsletter subscription is not required for any legal or contractual reasons. It is not required in order to conclude any agreement as well. Hence, your provision of data or your expression of the consent to receive the newsletter is not obligatory. The newsletter may be received exclusively based on the consent you have expressed (Art. 6(1)(a) of the General Data Protection Regulation). If no such consent has been granted by you, the newsletter will not be sent.
(L) Contact Details
If you have any questions, doubts or comments related to the information contained in the present Policy, or to any other issues concerning the processing of your Personal Data by LINK, please contact:
LINK Sp. z o.o.
ul. Nadrzeczna 17
- Controller shall mean a unit that decides how and for what purposes Personal Data are processed. The Controller is responsible for the compliance of processing with the applicable data protection regulations.
- Data Protection Authority shall mean a public authority required by law to oversee the compliance of personal data protection solutions used with the applicable law. In Poland, this role is performed by the President of the Office for Personal Data Protection.
- Personal Data shall mean any information about any identified or identifiable natural person. The examples of Personal Data we may be processing are listed under Item (B) above.
- Processing means any operation related to Personal Data, performed by automated means or otherwise, such as: collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Processor shall mean any person or entity that processes Personal Data on behalf of the Controller (other than the Controller).
- Sensitive Personal Data shall mean Personal Data concerning racial or ethnic origin, political opinion, religion or beliefs, trade union membership, physical or mental health status, sexual orientation, any committed or alleged offenses, convictions, or any other information defined as sensitive under applicable legal regulations.
Last updated on: 26.06.2018 r.