Identity of the Controller 

The administrator of the personal data of users of the website https://www.intereuropol.pl (hereinafter referred to as the “Website”) and the personal data of persons visiting our profiles on social networks:

https://www.facebook.com/InterEuropol

https://www.facebook.com/interEuropolPiekarnia

https://www.facebook.com/InterEuropolCompetition

(hereinafter referred to as the “Social Networking Profiles”)

is INTER EUROPOL SPÓŁKA AKCYJNA with its registered office in Marki at ul. Słoneczna 22 (postal code: 05-270), entered into the Register of Entrepreneurs of the National Court Register, maintained by the District Court for the capital city of Warsaw in Warsaw, 14^th Commercial Division of the National Court Register under KRS number 0000674460; NIP: 5260301089 and the share capital of PLN 300,000.00 and paid-in capital in the amount of PLN 300,000.00, BDO registration number 000017332 (hereinafter referred to as the “Controller” or the “Company”).

How to contact us?

You can contact the Controller:

• a) in writing to the registered address of Inter Europol S.A., ul. Słoneczna 22, 05-270 Marki, Poland
• b) by e-mail to the following address: rodo@intereuropol.pls

Our Data Protection Officer is: Tomasz Frąckiewicz

The Data Protection Officer can be contacted by e-mail at the following address: rodo@intereuropol.pl.

Purposes and grounds for the processing of personal data

We process your personal data for different purposes and on different legal grounds. The information on the purposes of processing, legal grounds and periods of processing are provided in the following sections dedicated to particular categories of data subjects.

Business contacts

If we have obtained your data in the course of business contacts, e.g. during a meeting, correspondence, via our website or otherwise, we process your personal data for the following purposes and on the following legal grounds: 

Legal basis	Purposes of processing	Period of processing
Article 6(1)(f) of the GDPR legitimate interests of the Controller	Establishing business contacts Direct marketing of the Company’s products and services Developing the Company’s business and services Presenting information on the Company and the scope of our services Developing market analyses Improving the quality of our services Determining, investigating and defending against claims	Your data will be processed for the period of mutual business contacts and for 3 years from the end of the calendar year in which the mutual business contacts have been completed

 Providing personal data for each of the above purposes is voluntary.

Representatives of our contractors

If we have obtained your data in connection with a contract concluded with our contractor or you are a contact person indicated in the contract or dedicated to performing the contract on behalf of our contractor, we process your personal data for the following purposes and on the following legal grounds:

Legal basis	Purpose of processing	Period of processing
Article 6(1)(f) of the GDPR legitimate interests of the Controller	Performing the contract with our contractor (applies only to contact persons indicated in the contract) Managing relationships with contractors Developing analyses of the market and cooperating with the contractor Improving the quality of our services Direct marketing of the Company’s products and services Determining, investigating and defending against claims	Your data will be processed for the duration of the concluded contract and for 3 years from the end of the calendar year in which the contract expires. To the extent that your personal data are included in the accounting documents, we will process your data for 5 years from the beginning of the year following the financial year in which mutual settlements with our contractor have been finally completed. To the extent that the proceedings would be brought before a competent common court or an arbitration tribunal in connection with a contract concluded between us and the contractor you represent, your personal data will be processed until the decision becomes final, until the awarded claims become enforceable or until the claims covered by the final judgement become time-barred.

Providing personal data for each of the above purposes is voluntary, but the failure to provide them may prevent the Company from establishing cooperation with the contractor or the mutual provision of services.

Contractors who are natural persons

If you are our contractor, we process your personal data for the following purposes and on the following legal grounds: 

Legal basis	Purposes of processing	Period of processing
Article 6(1)(b) of the GDPR performance of the contract or taking actions at the request of the data subject prior to the conclusion of the contract	Establishing cooperation with the contractor Performing the contract with our contractor Determining, investigating and defending against claims	Your data will be processed for the duration of the concluded contract and for 3 years from the end of the calendar year in which the contract expires. To the extent that your personal data are included in the accounting documents, we will process your data for 5 years from the beginning of the year following the financial year in which mutual settlements have been finally completed. To the extent that the proceedings would be brought before a competent common court or an arbitration tribunal in connection with a contract concluded with us, your personal data will be processed until the decision becomes final, until the awarded claims become enforceable or until the claims covered by the final judgement become time-barred.
Article 6(1)(c) of the GDPR the processing is necessary to fulfil the legal obligation imposed on the Company	Implementing our tax obligations Implementing accounting obligations Complying with the sectoral rules governing the rules for the production, transport and sale of food	To the extent that your personal data are included in the accounting documents, we will process your data for 5 years from the beginning of the year following the financial year in which mutual settlements with our contractor have been finally completed
Article 6(1)(f) of the GDPR legitimate interests of the Controller	Managing relationships with contractors Developing analyses of the market and cooperating with the contractor Improving the quality of our services Direct marketing of the Company’s products and services	Your data will be processed for the duration of the contract concluded between us and for 3 years from the end of the calendar year in which the contract expires

 

Providing personal data is a precondition for the conclusion and performance of the contract with you. As regards the objectives based on the premise of Article 6(1)(f) of the GDPR, the provision of data is voluntary.

Candidates for work

If you participate in recruitment processes for positions in our Company, you have submitted your CV via our website or otherwise, we process your personal data for the following purposes and on the following legal grounds: 

Legal basis	Purpose of processing	Period of processing
Article 6(1)(c) of the GDPR, the legal obligation under Article 221 § 1 and § 2 of the Labour Code	Conducting a recruitment procedure for a given position Candidate Evaluation	Your data will be deleted after the recruitment process for a given position has been completed
Article 6(1)(a) of the GDPR in connection with Article 221a § 1 of the Labour Code or Article 9(2)(a) of the GDPR in connection with Article 221b § 1 of the Labour Code If you provide us with data going beyond the data specified in Article 22[1] § 1 of the Labour Code, including sensitive data, you do this on your own initiative and with your consent.	Processing of data voluntarily provided by a candidate in the recruitment process for the purpose of assessing the candidate’s ability to occupy a particular job position	Your data will be deleted after the recruitment process for a given position has been completed
Article 6(1)(a) of the GDPR Candidate’s consent	Data processing for future recruitment purposes on the basis of the Candidate’s voluntary consent	Your data will be processed for 12 months from the end of the calendar year in which the consent was expressed
Article 6(1)(b) of the GDPR taking action at the request of the data subject, prior to the conclusion of the contract	Conducting a recruitment procedure for a given position Candidate Evaluation	Your data will be deleted after the recruitment process for a given position has been completed.

Providing personal data to the extent specified in the above-mentioned provisions of labour law is necessary to participate in the recruitment procedure. In the remaining scope, the provision of data is voluntary.

In the case of recruitment processes, where we will use the assistance of recruitment agencies:

the source of personal data of the applicant is the recruitment agency in which you participated in the first stage of recruitment;

the categories of personal data we process

• first name and surname
• date of birth
• contact details
• education
• professional qualifications
• course of previous employment
• other data voluntarily provided by the Candidate.

Persons visiting the Social Networking Profiles

If you visit our Social Networking Profile on Facebook, we process your personal data for the following purposes and on the following legal grounds:

Legal basis	Purposes of processing	Period of processing
Article 6(1)(f) of the GDPR legitimate interests of the Controller	Keeping our profile on social networking sites; Informing people visiting the Social Networking Profiles about offers, products, services, promotions, contests of the Controller Interacting with persons visiting the Social Networking Profiles, including answering questions, enabling them to express their opinion on the Company’s services and products; Marketing of the Company’s products and services; Analysing preferences and behaviour of visitors to our profiles.	Your data will be processed for the period during which you will be involved in our Social Networking Profile, for example, the period of subscribing to it through the “Like” function. Detailed rules and deadlines for removing personal data from social networks are provided in the regulations of these portals.

Providing personal data for each of the above purposes is voluntary.

Persons indicated in the contact form on the Website

If you leave your data in the contact form on our website, we process your personal data for the following purposes and on the following legal grounds:

Legal basis	Purposes of processing	Period of processing
Article 6(1)(f) of the GDPR legitimate interests of the Controller	Providing answers to the inquiry sent to us; Keeping correspondence for business purposes; Handling complaints and requests from Customers;	Your data will be processed for a period of 12 months from the end of the calendar year in which we completed the correspondence – in the case of inquiries and correspondence for business purposes. In the case of complaints and requests, your data will be processed for 3 years from the end of the calendar year in which we completed mutual correspondence.

Providing personal data is voluntary.

Cookie files

In connection with the use of the Website and our Social Networking Profiles, we also process the data contained in cookie files. Please refer to our Cookie Policy for more information.

Redirecting to other websites

Our Website contains links that redirect the User to other websites – e.g. to our Social Networking Profiles or websites of our partners. We are not responsible for the manner of processing personal data of users by other parties, as well as the content of other websites. We are only responsible for the content on our Social Networking Profiles and only to the extent specified by the regulations of portals on which our profiles are located. Facebook privacy policy is available at: https://pl-pl.facebook.com/about/privacy/

Who do we transfer your data to?

 Your personal data may be transferred to:

• entities belonging to the same capital group as the Controller, i.e., among many, to Inter Europol Piekarnie S.A. and Inter Europol Management S.A.,
• partners cooperating with us, providing us with services related to maintaining and running the Website and the Social Networking Portals,
• entities providing us with services, such as IT companies, accounting and bookkeeping offices, law firms, enforcement agencies and firms, couriers and postal operators, external auditors,
• in the case of data obtained in recruitment processes, we can transfer data to the recruitment agencies cooperating with us,
• entities authorised by law, e.g. supervisory authorities, law enforcement authorities, courts.

Transmission of data outside the European Economic Area

We do not transfer your personal data to entities outside the European Economic Area (EEA).

Your rights

In connection with the processing of data, you have the following rights:

1. The right to access the data.

This right allows you to obtain information about whether we process your personal data and what personal data we process and to receive a copy of your personal data.

2. The right to rectify the data.

If you believe that your personal data is incorrect, you have the right to request us to rectify them. This right provides for the possibility to request a correction of incomplete, false or outdated data that we process. In some cases, before implementing your request, we will have to verify the correctness of the new data provided by you.

3. The right to data portability.

You have the right to receive the personal data you have provided to us and to send them to another controller you have selected. The right to portability is granted if we process your personal data on the basis of your consent or for the purpose of performing the contract and processing takes place in an automated manner, i.e. in ICT systems. In order to exercise your right, we will provide your personal data in a structured, commonly used, machine-readable format.

4. The right to restrict processing.

In connection with the processing of your personal data, you have the right to request restriction of their processing if you:

• question the correctness of the personal data;
• the processing of the data is unlawful, and you oppose the erasure of the data, requesting their restriction in return;
• we no longer need data for our purposes, but you need them to establish, defend or assert claims;
• an objection has been filed against the processing of data – we limit the processing of data until the legitimate grounds on our side prevail over the grounds for objection.

5. The right to object.

You have the right to object to the processing of your personal data at any time if we process data on the basis of a legitimate interest (Article 6(1)(f) of the GDPR).

You have right to object in particular if we process your personal data for direct marketing purposes.

6. The right to erasure.

You have the right to request the erasure of your Personal Data if, for example:

• the data are no longer necessary for the purposes for which they were collected or otherwise processed;
• an objection has been filed against the processing of personal data and has proved to be justified;
• the consent on which the processing is based has been withdrawn and there is no other legal basis for processing.

In some cases, we are obliged to process your data on the basis of applicable laws (e.g. tax and accounting regulations) and we will not be able to fulfil your request.

7. The right to withdraw your consent.

If you have given us your consent to the processing of your personal data, you have the right to withdraw it at any time. The withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

8.The right to file a complaint with the competent supervisory authority

 i.e. the President of the Personal Data Protection Office (ul. Stawki 2, 00-193 Warsaw).