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The Joint Controllers (controllers who jointly determine the purposes and means of processing) of your personal data are GWW Grynhoff i Partnerzy Radcowie Prawni i Doradcy Podatkowi Spółka Partnerska with its registered office in Warsaw, ul. Dobra 40 (00-344 Warsaw), entered in the Register of Entrepreneurs of the National Court Register held by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number 0000541501, NIP (tax ID) 7792022623, REGON (statistical no.) 631226810 (“GWW Legal”) GWW Ladziński, Cmoch i Wspólnicy Spółka komandytowa with its registered office in Warsaw, ul. Dobra 40 (00-344 Warsaw), entered in the Register of Entrepreneurs of the National Court Register held by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number 0000956566, NIP (tax ID) 7010313649, REGON (statistical no.) 145496595 (“GWW Tax”).
In fulfilment of the obligations imposed by 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 (“GDPR”), below the Joint Controllers provide information on the principles of processing of your personal data by the Joint Controllers, including the purposes of processing, the legal basis for processing, the retention period, the recipients of personal data, as well as your rights in connection with the processing.
As part of the Co-Controlling Agreement concluded between the Joint Controllers, the Joint Controllers have agreed their respective responsibilities regarding the fulfilment of their obligations under the GDPR, including in particular that:
- with regard to the fulfilment of the obligation to provide information to data subjects, in accordance with the provisions of Articles 12–14 of the GDPR, the Joint Controller who collects the personal data or initiates the process of collecting the personal data shall be responsible;
- with regard to the exercise of the rights of data subjects set out in Article 7(3) and Articles 15–22 of the GDPR, i.e. withdrawal of consent, exercise of the right of access to personal data, rectification, erasure, restriction of processing, portability of personal data, objection to the processing of personal data, the Joint Controller who received such request shall be responsible;
- with regard to the fulfilment by the Joint Controllers of their obligations concerning the management of personal data breaches, their notification to the supervisory authority (Article 33 GDPR) and to the data subject (Article 34 GDPR), the Joint Controller who first obtained information about the breach shall be competent; and if the information about the breach is obtained simultaneously, the Joint Controller on whose side the breach occurred shall be competent;
- if it is not possible to determine based on the above rules which Joint Controller is responsible for the fulfilment of the obligations set out in these paragraphs, GWW Legal shall be responsible.
Notwithstanding the above arrangements, the data subject may exercise his or her rights under the GDPR in respect of and against each of the Joint Controllers.
- CONTACT DETAILS
The Joint Controllers have designated a single point of contact for all requests and inquiries relating to the personal data they process:
- if contacted by post, by sending a letter to: Personal Data Coordinator: ul. Dobra 40, 00-344, Warsaw, marked “Dane osobowe” [Personal Data],
- if contacted by e-mail, by sending an e-mail to: odo@gww.pl
- PURPOSE OF PERSONAL DATA PROCESSING AND LEGAL BASIS
In connection with subscribing to the GWW Newsletter your personal data shall be processed by the Joint Controllers:
- in order to implement the GWW Newsletter Service Regulations, including the provision of the GWW Newsletter service (legal basis: Article 6(1)(b) GDPR);
- for the purposes arising from the legitimate interests pursued by the Joint Controllers or third parties (legal basis: Article 6(1)(f) GDPR), which include: establishing, pursuing or defence against claims; implementation of internal procedures (e.g. related to personal data protection, fraud prevention);
- for other purposes under a separate consent given by you (legal basis: Article 6(1)(a) GDPR).
Although provision of the personal data is voluntary, it is necessary for the purpose of delivery of the GWW Newsletter.
- RECIPIENTS OF PERSONAL DATA
The Joint Controllers shall share personal data with other entities (recipients of personal data) only if they have a legal basis for doing so. If the Joint Controllers transfer personal data to recipients located outside the European Union or the European Economic Area (EEA), this is only done if in relation to that third country, the European Commission has confirmed an adequate level of data protection or an adequate level of data protection has been agreed with the data recipient (e.g. using so-called standard contractual clauses).
Your personal data may be made available to public authorities or other entities authorised by law to access such data.
The recipients of your personal data may also include: entities providing ICT services to the Joint Controllers, entities providing IT/technical/service support services, providers of software used by the Joint Controllers, and other entities cooperating with the Joint Controllers in connection with the services provided to you.
The processing of personal data in ICT systems may result in the transfer of such data to the servers of software and IT service providers, in connection with the use by the Joint Controllers of the services/software provided by the aforementioned providers. Some of these servers are located in the US. The transfer of data to the United States shall take place using the so-called standard contractual clauses referred to above. You have the right to obtain a copy of such personal data.
- PERSONAL DATA RETENTION PERIOD
The Joint Controllers shall not keep personal data longer than necessary to achieve the purposes for which the data were collected.
Your personal data obtained in connection with the conclusion and performance of an agreement on GWW Newsletter service (GWW Newsletter Service Regulations) shall be processed for the period of subscription to the GWW Newsletter, while your personal data processed in order to pursue legitimate interests of Joint Controllers or third parties shall be processed until the purpose of processing ceases or you make an effective objection.
The personal data processed on the basis of your consent shall be processed until the purpose of the processing ceases to exist or the consent is withdrawn (whichever occurs earlier).
Your personal data shall not be processed in a solely automated manner (including in the form of profiling) that may arise legal effects to you or similarly significantly impact your situation.
Within the scope and in the cases specified by the law, and by the GDPR in particular, you shall have the right to obtain from the Joint Controllers information about the processing of your personal data and obtain a copy of the processed data (right of access to data), the right to demand rectification (correction) of your data, the right to demand erasure of your personal data, the right to restrict the processing of your personal data, the right to data portability, as well as the right to withdraw consent (if the processing of personal data is based on consent).
You shall also have the right to object to the processing of your personal data based, among others, on the legitimate interests of the Joint Controllers, including profiling – in such a case, the Joint Controllers shall cease data processing for these purposes, unless the Joint Controllers demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims.
Where your personal data are processed by the Joint Controllers for direct marketing purposes, you shall have the right to object to processing of your personal data for such marketing, which includes profiling to the extent that it is related to such direct marketing. The exercise of this right shall mean that the Joint Controllers would not process personal data for such purposes.
The Joint Controllers shall effect the above rights in accordance with the provisions of the GDPR and other relevant legislation. In order to exercise your rights or to obtain further information on your rights, you should contact the Joint Controllers (contact details are found in Section 2).
- RIGHT TO COMPLAIN
If the you believe that the processing of your personal data by the Joint Controllers violates the provisions of the GDPR or other generally applicable data protection regulations, you may file a complaint with the President of the Personal Data Protection Office.
