INFORMATION ON PERSONAL DATA PROCESSING UNDER THE GENERAL DATA PROTECTION REGULATION - GDPR

25 May 2018

INFORMATION ON PERSONAL DATA PROCESSING UNDER THE GENERAL DATA PROTECTION REGULATION - GDPR

Ladies and Gentlemen,

Regarding the implementation of the requirements set out in the Regulation of the European Parliament and of the Council (EU) 2016/679 on the protection of natural persons with regard to personal data processing and free movement of such data, as well as the repeal of the Directive 95/46/EC (general data protection regulation, hereinafter referred to as the Regulation), RADMOT company hereby informs about its personal data processing rules:

I. Administrator

The Administrator of your personal data is RADMOT Spółka z ograniczoną odpowiedzialnością Sp. k [Ltd. L.P.] with its registered office in Wola Gutowska 33E, 26-660 Jedlińsk, registered in the District Court for the capital city of Warsaw in Warsaw, 14th Commercial Division of the National Court Register, under the KRS number: 0000448169, VAT No. 796-296-09-65, Statistical business reg. No. 146512178, telephone No. 48 3214940, e-mail: biuro@radmot.pl, hereinafter referred to as the "Administrator".

II. Data Protection Officer

The Administrator has appointed Mr Paweł Waniek as the Data Protection Officer. You can contact him via an e-mail address: biuro@paod.pl or in writing (to the address of the Administrator's office). You can contact the Data Protection Officer on all matters relating to the personal data processing and the use of rights related to such processing.

III. Categories of personal data

The information concerns personal data obtained in other way than from the data subject.

The administrator processes the following categories of data: identification data, address data and contact data.

IV. Objectives and legal basis for personal data processing

Personal data may be processed by the Administrator for the following purposes:

1. in order to implement a recruitment process/and future recruitments - the legal basis for personal data processing in this respect is your consent, i.e. art. 6 par. 1(a) of the Regulation and the Administrator's performance of legal obligations incumbent on him, i.e. art. 6 par. 1(c) of the Regulation in conjunction with the provisions of the Labour Code;

2. to implement your contract of employment or to take necessary actions before concluding the contract - the legal basis for personal data processing in this respect is art. 6 par. 1(b) of the Regulation;

3. to fulfill legal obligations incumbent on the Administrator in connection with the conclusion of your employment contract (preparation of declarations required by the law, HR and payroll services, calculation and payroll payments, issuing health and safety training cards and periodic health and safety certificates) - the legal basis for personal data processing in this respect is Art. 6 par. 1(c) of the Regulation;

4. to grant you benefits from the Company Social Benefit Fund - the legal basis for personal data processing in this respect is your consent, i.e. art. 6 par. 1(a) of the Regulation;

5. to process data for statistics and internal reporting - the legal basis for personal data processing in this respect is art. 6 par. 1(f) of the Regulation;

6. to promote and market the Administrator's business during the term of the contract - the legal basis for personal data processing in this respect is the legitimate interest pursued by the Administrator, i.e. art. 6 par. 1(f) of the Regulation;

7. to promote and market the Administrator's business offer after termination, expiration or withdrawal from the contract - the legal basis for personal data processing in this respect is the consent of the data subject, i.e. art. 6 par. 1(a) of the Regulation;

8. to establish and pursue own claims or defend against claims - the legal basis for personal data processing in this respect is the legitimate interest pursued by the Administrator, i.e. art. 6 par. 1(f) of the Regulation.

V. Information on the periods of personal data processing

The administrator will store your personal data:

1. for the period necessary to implement the recruitment process/for the period necessary to implement this recruitment process and future recruitments;

2. in connection with the conclusion of the contract and to implement it - for the duration of the contract, and then for the period and to the extent required by the law, as well as for the period necessary to establish and assert own claims or defend against claims;

3. for statistical purposes and internal reporting - until the legitimate interest of the Administrator is fulfilled, which is the basis for this processing or until you object to it;

4. for promotion and marketing of the Administrator business during the term of the contract - until you object to it;

5. for promotion and marketing of the Administrator's business after the termination, expiration or withdrawal from the contract - until you withdraw your consent;

6. for establishing and pursuing own claims or defending against filed claims - until the time of prescription of potential claims under the contract or any other title;

7. for fulfilling legal obligations incumbent on the Administrator - for the period the Administrator is required by the law to store the documentation and to fulfill obligations arising therefrom towards you.

VI. Monitoring

The Administrator uses video surveillance to protect the property and persons present in the surveyed area. The basis for processing is the legitimate interest of the Administrator, i.e. art. 6 par. 1(f) of the Regulations. The video surveillance recordings will be kept for a period of up to three months. The recorded person has the right to access the recording via a legally authorized entity such as the Police. The video recorded person has the right to lodge a complaint with the Office for Personal Data Protection.

VII. Information on the recipients of personal data

The data is intended for the Administrator and can be forwarded to the following recipients:

1. entities and bodies to which the Administrator is obliged or authorized to disclose personal data on the basis of a generally applicable law, including entities or bodies entitled to receive personal data from the Administrator or authorized to request access to personal data on the basis of generally applicable law;

2. entities participating, at the request of the Administrator, in the recruitment process/future recruitment processes;

3. entities participating in the processes which are necessary to implement your contract of employment;

4. entities that process your personal data on behalf of the Administrator on the basis of an entrustment  contract for personal data processing.

VIII. Automated decision making, including profiling

Profiling should be understood as any form of automated processing of personal data, which uses it to assess some of the characteristics of an individual, in particular, to analyze or forecast aspects of the individual's work, his economic situation, health, personal preferences, interests, reliability, behavior, location or movements.

Bearing in mind the above, the company RADMOT Spółka z ograniczoną odpowiedzialnością Sp. k [Ltd. L.P.] hereby informs that it does not profile the personal data of the data subjects.

IX. The rights of the data subject

You have the right to access your personal data, including obtaining a copy, the right to demand rectification, deletion (right to be forgotten), or restriction of the processing under the terms of the Regulation.

To the extent that the basis for the processing of your personal data is the premise of the legally justified interest of the Administrator, you have the right to object to the processing of your personal data.

To the extent that the processing of your personal data is based on your consent, you have the right to withdraw your consent. Withdrawal of consent does not affect the compliance of the processing which was made on the basis of a consent before its withdrawal.

To the extent that your personal data is processed for the purpose of conclusion and performance of the contract or processed on the basis of a consent - you also have the right to transfer your personal data, i.e. the right to receive personal data from the Administrator in a structured, commonly used machine-readable format (you may send this data to another Administrator) and the right to request the direct transfer of your data by RADMOT Spółka z ograniczoną odpowiedzialnością Sp. k [Ltd. L.P.] to another Administrator as far as it is technically possible.

To the extent that your personal data is processed for the promotion and marketing of the activities carried out by the Administrator - you have the right to object at any time to the processing of your data for the purposes of promotion and marketing of the activities conducted by the Administrator, including profiling, to the extent to which the processing is related to the promotion and marketing of the activities carried out by RADMOT Spółka z ograniczoną odpowiedzialnością Sp. k. [Ltd. L.P.]

You also have the right to lodge a complaint with the authority supervising the compliance with the Regulation, i.e. the President of the Office for Personal Data Protection, when there is a suspicion that the processing of your personal data violates the provisions on the protection of personal data.

X. The source of the data

The information concerns personal data obtained in a way other than from the data subject.

Your data may come from the principal (in case of a power of attorney), a statutory representative, as well as publicly available sources (e.g. databases and registers: REGON, Central Register of Economic Activities (CEIDG), National Court Register).

XI. Transfer of personal data to a third country

The Administrator does not share your personal data with entities located outside the European Economic Area (EEA).

XII. The obligation to provide personal data

Providing your personal data by you is voluntary, however, it is a condition for the conclusion and implementation of the contract and statutory powers and responsibilities of the Administrator related to the implementation of the objectives referred to the above. In the absence of personal data, the Administrator is forced to refuse to conclude the contract. To the extent that personal data is collected on the basis of your consent, providing personal data is voluntary.