What is the purpose and legal basis of processing your personal data?
We may process your personal data in the following situations:
- when you are our prospective or current client, supplier or contractor;
- when you are interested in our business activities (e.g. as the media);
- when you are acting on behalf of one of the persons/entities mentioned above, including when you are its employee or associate.
Therefore, your personal data can be processed in connection with many cases:
- when you have provided us with your personal data through various communication channels (e.g. by sending an inquiry / offer via e-mail or telephone);
- as part of our cooperation when signing or performing the contract, including when your personal data have been disclosed to us as a contact for the purpose of execution of the contracts;
- when we have obtained your personal data from other sources (e.g. from the company which you cooperate with and which is our contractor / client, or from publicly available industry websites).
The scope of personal data we process depends on the information that is vital for a given relationship – it primarily encompasses the content of documents, as well as of our correspondence/communication, along with other information we have obtained from publicly available professional sources (e.g. industry websites). This data in particular includes:
- name and surname,
- information regarding professional activity, including place of employment, position and/or department, qualifications;
- contact details, including correspondence address, telephone number, e-mail address or other contact information.
Therefore, we may obtain the above personal data directly from you or from other people, e.g. from your employers / clients or from public sources.
If we are processing your personal data in conjunction with a contract that is being concluded with you, the purpose for the processing of your personal data is taking steps in order to conclude that contract and its performance. The legal basis for such processing in accordance with this purpose will be Art. 6(1)(b) GDPR (it is necessary for the performance of a contract or in order to take steps at the request of the data subject prior to entering into a contract).
If you are contacting us on your own behalf, including when e.g. you have given us your business card with a request to forward particular information, we process your data in order to respond to your query or request or to perform other actions, which you have agreed to. The legal basis for the processing of your personal data in accordance with this purpose will be your consent (Art. 6(1)(a) GDPR).
In case of processing your personal data based on your consent, please be reminded that you can withdraw your consent at any time without affecting the lawfulness of the processing that has already been made on this basis.
If you are acting on behalf of our client, supplier, or another entity, we process your data in order to make a contact with you in the context in which you are acting on behalf of that entity, as well as for the conclusion and/or performing a contract with that third party and/or conducting a joint project. The legal basis for processing your personal data in accordance with this purpose will be our legitimate interest (Art. 6(1)(f) GDPR) – building and maintaining relations with the third party on whose behalf you are acting, including the conclusion and performance of relevant contracts with that party, as well as the intention of building our positive image.
Regardless of the foregoing, your personal data, that is, in particular, your first name and last name, as well as correspondence address and/or e-mail address, may be used by us in order to contact you from time to time (e.g. to say thank you, or to send holiday season greetings).The legal basis for processing your personal data in accordance with this purpose will be our legitimate interest (Art. 6(1)(f) GDPR) – maintaining relations and building a positive image.
Additionally, with regard to the processing of your personal data in order to:
- defend against potential claims, as well as for the purpose of potential directing claims, the legal basis for processing of your personal data will be our legitimate interest (Art. 6(1)(f) GDPR);
- fulfil the legal obligations of the data controller (e.g. tax, accounting), the legal basis for processing of your personal data will be the necessity for compliance with a legal obligation to which the controller is a subject (Art. 6(1)(c) GDPR).
Your submission of personal data is voluntary, but sometimes it may be necessary for purposes related to our cooperation, e.g. in order to conclude or execute the contract or to respond to your query or to conduct further correspondence. This means that failure to provide data may constitute grounds for our refusal to enter into cooperation, or to take legal measures to terminate possible contract.
Duration of retention of your personal data.
We are processing your personal data only for such period that is necessary for the purposes for which it was initially collected. After that time, it will be deleted or archived, except for cases in which we are obliged to process such data for a longer period in order to meet legal obligations.
If you are our prospective or current client, or an employee/contractor thereof, we will store your personal data for the duration of the contract or the period necessary for its conclusion, and then for a maximum of:
- for current clients: 10 years from the end of the year in which we ended providing services to you;
- for prospective clients: 2 years since the last contact/end of negotiations.
Personal data processed on the basis of your consent will be stored until such consent is revoked or the purpose for which it was given is fulfilled.
The above periods may be extended, as appropriate, in the event of any claims and court proceedings – for the duration of these proceedings and their settlement, and also if the legal provisions, in certain situations, oblige us to process them for a longer period.