DATA PROTECTION AND THE GENERAL DATA PROTECTION REGULATION
The 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), referred to in the following as ‘the GDPR’, came into force on 25 May 2018. The purpose of the GDPR is to harmonise data privacy laws throughout the European Union.
What follows here is information on the rules applied by ALUPROF SA for processing personal data as of 25 May 2018.
WHO PROCESSES YOUR PERSONAL DATA?
The Data Protection Officer of your personal data is ALUPROF SA, which has its head office at ul. Warszawska 153, 43-300 Bielsko-Biała, Poland, tel.: +48 33 819 53 00), e-mail: email@example.com.
OUR DATA PROTECTION OFFICER
ALUPROF SA has appointed Mr Michał Geilke as its Data Protection Officer. He can be contacted by e-mail at any time regarding any matter relating to the processing of your personal data. His e-mail address is firstname.lastname@example.org.
WHY DO WE PROCESS YOUR PERSONAL DATA?
We process your personal data in accordance with the strict minimum required for the purpose of the processing and on the basis of specific laws (lex specialis) and the GDPR. Depending on the context of the processing, your data will be accessed, in particular, by ALUPROF SA’s authorised staff members and collaborators, subsidiaries, external advisors, auditors and external IT service providers.
Irrespective of the above:
- you have the right to be informed as to both the purpose for which ALUPROF SA is processing your data and the legal basis for the processing;
- you have the right to have access to your data, to rectify them, erase them and limit their processing, the right to object to their processing and the right to transmit them and obtain copies of them. Some of the rights referred to in the foregoing may be limited, depending on the context of the processing
- if your data is being processed on the basis of Article 6 item 1 (a) or Article 9 item 2 (a) of the GDPR, you have the right to withdraw your consent to the processing of your data at any time without affecting the lawfulness of processing carried out on the basis of your consent before its withdrawal;
- if your data is being processed on the basis of Article 6 item 1 (f) of the GDPR, which is to say, for the purposes of legitimate interests pursued by ALUPROF SA, you have the right, at any time, for reasons connected with your specific situation, to object to your personal data being processed on that basis;
- you have the right not to be profiled within the meaning of Article 22 of the GDPR. ALUPROF SA hereby informs you that, should profiling occur, an appropriate notification will accompany any operation of that type;
- the right to lodge a complaint with the appropriate supervisory body, which is the President of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warszawa, Poland; tel. +48 22 531-03-00, https://uodo.gov.pl/en.
If you apply for a job at ALUPROF, your data will be used for the recruitment process. ALUPROF SA neither carries out profiling within the meaning of Article 22 of the GDPR on candidates for jobs, nor does it transmit their data to third countries, which is to say, countries outside the European Economic Area.
What follows here is some information on the data we collect during the recruitment process, why we collect them and how they are used.
When recruiting, we collect three main three types of data, namely, the contact information provided by the candidate, details of their career and employment history and data on their authorisations and skills. We process a candidate’s data on the basis of the provisions of the Labour Code of 26 June 1974, in particular, Article 22 1). The data provided for recruitment purposes are provided voluntarily, but they are essential to verifying a candidate’s qualifications. Failure to provide these data will make participation in the recruitment process impossible. ALUPROF SA does not process data collected for recruitment for other purposes. The data will be processed until a candidate is selected for the job and up to six months after their selection.
If you wish to allow us to use your CV for the purpose of future recruitment carried out by ALUPROF SA, please ensure that it includes the following consent:
Pursuant to Article 6 item 1 (a) of the GDPR, I hereby give my consent to the processing of the data contained in this CV, which I am submitting to ALUPROF SA for the purpose of future recruitment, until such time as this consent is withdrawn.
IMPORTANT! You have the right to withdraw your consent at any time without affecting the lawfulness of any processing carried out on the basis of your consent before its withdrawal. Your personal data will be processed until such time as the consent is withdrawn.
Only ALUPROF SA’s authorised staff members and collaborators have access to your data. In particular, this means the staff of our HR Department, the Management Board and the head of the department you are applying to. Your data may also be disclosed to external advisors, auditors and external IT service providers as and when appropriate.
Providing your data is voluntary. However, not providing them will make it impossible for you to establish an employment relationship with ALUPROF SA. You have the right to access your personal data, to transmit them and to obtain a copy of them. You also have the right to rectify and erase them, to limit their processing and to object to it. Some of the rights referred to in the foregoing may be limited, depending on the context of the processing.
Should you ever have any doubts concerning your personal data, please contact our Data Protection Officer, Mr Michał Geilke. He can be reached by e-mail at email@example.com or by phone, on +48 33 819 53 00.
Our sales and purchasing processes
If you become our client, your data will be used for sales-related purposes, pursuant to Article 6 item 1 (b) (c) of the GDPR. This applies, in particular, to data concerning payments, goods delivery sites, the people authorised to execute the order and the issue of sales documents, as well as enabling you to exercise your warranty rights.
A contracting party’s/potential contracting party’s data are disclosed solely to ALUPROF SA’s staff members, external companies providing services for ALUPROF SA’s online platform and, where justified, to external entities involved in providing ALUPROF SA with legal services or performing contracts, such as freight forwarding companies, for example. When a user operates in an area served by one of ALUPROF SA’s subsidiaries, the staff of the subsidiary may also have access to the user’s data. The user will be informed of this. The areas include third countries, as defined by the GDPR, namely, the United States, the United Kingdom and Ukraine. The data will be stored while negotiations are under way, for the duration of the contract and after its completion for the period stipulated by the applicable law or, when no contract is entered into, for up to three years following the conclusion of the talks.
Maintenance of the www.aluprof.com website
We process your personal data to ensure the functionality of ALUPROF SA’s websites, pursuant to Article 6 item 1 (a), (b) and (f) of the GDPR. Details can be found in the rules pertaining to each of our services. In the case of services based on your voluntary consent, your personal data will be processed until such time as the consent is withdrawn. This applies, in particular, to ensuring that you are able to:
- register for our Catalogue for Architects service;
- register for our Authorised Zone service;
- subscribe to our newsletter;
- register for training courses provided by ALUPROF SA;
- use our window, door and exterior blind configurators.
We process your personal data for marketing purposes, particularly in order to promote our product range. If, in accordance with Article 6 item 1 (a) of the GDPR, you agree to receive the ALUPROF SA Newsletter, we will use the e-mail address you provide to inform you about our new products, events and special offers. Details can be found in the rules pertaining to each of our services.
Ensuring our company’s security
Pursuant to Article 6 item 1 (f) of the GDPR, if you visit any of our premises, we will process your personal data in the form of our visitor records and an image in order to ensure safety of the people there and the company’s property.
WHAT DATA DO WE COLLECT?
The personal data we collect is essential to the conducting of our business and depends on the purpose for which it is processed. In particular, those data are:
- identification data, such as your given name and surname;
- contact details, such as your postal and e-mail addresses and your telephone number;
- tax status, such as your tax identification or VAT number;
- financial details, such as your profit and loss account and PIT documents;
- bank details, such as bank account details;
- details of our collaboration, such as orders and data relating to complaints;
- CCTV material, such as our monitoring of the company’s premises.
In some circumstances, we may collect and use the personal data of people with whom we already collaborate or may start collaborating, such as potential clients.
There are reasons why we might collect information about you even if we do not collaborate with you directly. This could occur, for example, when your data is provided to us by our clients, particularly if: • you are a guarantor; • you hold a power of attorney; • you are a party to a complaint; • you are a family member of one of our staff members or a contracting party; • your personal data is held in the database of a recruitment company.
The legal bases for these operations are specific laws (lex specialis) and the legitimate interest of ALUPROF SA, in accordance with Article 6 item 1 (f) of the GDPR. You have the right, at any time, for reasons connected with your specific situation, to object to your personal data being processed on that basis.
The basis for processing your data relates to the purpose for which they are processed. Those purposes are connected with:
- an order for goods or the execution of our order. Here, we process your data in order to perform a commercial contract, including the delivery of goods, insurance and warranties;
- the recruitment process. We process the personal data you provide in order to take action at your request prior to entering into a contract;
- registrations for our Catalogue for Architects or Authorised Zone at www.aluprof.com and subscriptions for our Newsletter. We process the personal data you provide in the registration and subscription forms in order to perform our agreement with you for the provision of services by electronic means;
- your use of the www.aluprof.com website. We process the data obtained using cookies on the basis of your consent, which is given in accordance with Article 173 of the Telecommunications Law;
- If you visit any of our premises, we process your image on the basis of the legitimate interests of ALUPROF SA.
WHO DO WE PROVIDE YOUR PERSONAL DATA TO?
In order to achieve the above-mentioned goals, we may transmit your personal data to:
- service providers performing services on our behalf, such as credit agencies, consultancies and companies providing IT support. In respect of contracting parties’/potential contracting parties’ data, this also includes our subsidiaries;
- transport companies, in respect of contracting parties’ data;
- the company providing our website hosting and maintenance, in respect of people using the website’s services;
- financial or judicial authorities, state agencies or public authorities, on request and to the extent permitted by law;
- insurance companies, in respect of contracting parties’ data;
- certain people carrying out regulated professions, such as lawyers and auditors;
- brokerage and investment houses, in respect of ALUPROF SA’s shareholders.
At the same time, ALUPROF SA would like to inform you that the Grupa Kęty SA Capital Group companies, of which it is one, may have legitimate interests in transmitting your personal data within the Capital Group for internal administrative or financial purposes. For more information about Grupa Kęty, visit https://grupakety.com/en/.
HOW LONG DO WE PROCESS YOUR PERSONAL DATA FOR?
We store your personal data either for the period required by the applicable law or for another period, depending on the purpose we are processing it for. This applies, in particular, to:
- the data obtained when you register for our Catalogue for Architects, Authorised Zone and Newsletter services. These data will be stored until you unsubscribe from a service, after which, your data will be processed for no longer than three years;
- the data obtained when you register for one of our training courses. These data will be stored for one year after the course finishes;
- the data collected for sales/purchasing purposes will be stored for the duration of the contract, after which, they will be processed for a period of no more than ten years;
- the data collected for recruitment purposes, which will be stored for a period of six months from the conclusion of the recruitment process;
- the data obtained from the CCTV monitoring of ALUPROF SA’s premises, which will be stored for a period of three months from the date it was recorded.
WHAT ARE YOUR RIGHTS?
In accordance with the applicable law, you have the following rights:
- the right to access your data. You can request information about what data we hold about you;
- the right to rectify your data. If you find that the data we process about you is inaccurate or incomplete, you can request us to change them;
- the right to request the erasure of your data. You can request us to erase your personal data as long as the law permits it;
- the right to restrict the processing of your data. If you consider that the scope of your data being processed is too wide, you have the right to request us to restrict it;
- the right to object. You can object to the further processing of your data;
- the right to withdraw your consent. If you have given your consent to the processing of your data, for instance for the purposes of the Newsletter, you can withdraw it at any time;
- the right to transmit your data. You can request us to transmit your data to another entity.
If you wish to exercise any of the rights listed above, please send an e-mail to firstname.lastname@example.org or write to us at ALUPROF SA, ul. Warszawska 153, 43-300 Bielsko-Biała, Poland.
Should you have any questions about how we process your personal data, please contact our Data Protection Officer, Mr Michał Geilke, at email@example.com.