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Privacy Policy
PRIVACY POLICY
Under what legal provisions is or may your personal data be processed?
The principles concerning the protection of personal data (hereinafter ODO) are set out, inter alia, in the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016[1] on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (General Data Protection Regulation, hereinafter RODO), the Act on the Protection of Personal Data of 10 May 2018 (hereinafter DPA[2] ) and in special laws (lex specialis) also in the national order.
To whom does this Privacy Policy apply?
This Privacy Policy (hereinafter PP) applies to the processing of personal data of natural persons, sole proprietors and persons acting on behalf of legal persons, i.e. persons appointed to represent the legal person, agents,
employees and/or collaborators acting on behalf of the legal person.
Who is the Data Controller of the personal data?
Pursuant to Article 13 RODO, i.e. the right to be informed, we would like to inform you that the data controller is Fabryka Automatów Tokarskich Wrocławiu S.A., based in Wrocław (53-234) at Grabiszyńska 281, (NIP: 896-000-01-38).
Contact details for the Data Controller
Please address your data protection queries directly to the Data Controller (by post) or to the dedicated email address: odo@fathaco.com
Please be informed that the Data Controller has not appointed a Data Protection Officer.
For what purposes is or may your personal data be processed?
Personal data are processed or may be processed for the following purposes:
|
Lp. |
Purpose of processing |
Scope of data |
Lawfulness of processing |
|
1. |
Personal data processed for contact purposes - replying to correspondence received |
name, surname, telephone number, e-mail address, information provided in the body of the e-mail: position, place of work, |
1) Article 6(1)(a) RODO - consent of the data subject, 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
|
2. |
Personal data processed for the purpose of preparing and presenting an offer in respect of own products and services |
name, surname, telephone number, e-mail address, company name, registered office |
1) Article 6(1)(a) RODO - consent of the data subject, 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
|
3. |
Personal data processed e for the purpose of sending commercial information regarding own products and services electronically |
name, e-mail, |
1) Article 6(1)(a) RODO - consent of the data subject [Article 10 Act on Provision of Electronic Services]. 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
|
4. |
Personal data processed for the purpose of sending marketing information in relation to own products and services by telephone in the form of a voice call |
name, surname, telephone number, |
(1) Article 6(1)(a) RODO - consent of the data subject [Article 172 Telecommunications Act]. 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
|
5. |
Personal data processed for the purpose of concluding and performing the contract |
name, surname, identity card number, taxpayer identification number (NIP), correspondence address, contact data: telephone number, e-mail address, bank account number, data of persons representing legal entity, data of persons indicated on behalf of the legal entity for contact, other data necessary to conclude and perform the provisions of the agreement, |
1) Article 6(1)(b) RODO - processing is necessary for the performance of a contract to which the data subject is party, or to take steps at the request of the data subject before entering into a contract (2) Article 6(1)(c) of the DPA - processing is necessary for compliance with a legal obligation incumbent on the controller 3) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
|
6. |
Personal data processed in connection with participation in the current or future recruitment process - a full information clause is available in the body of this Privacy Policy (Information on the processing of personal data in connection with participation in the recruitment process) |
name(s) and surname, date of birth, contact details indicated by the person, education, professional qualifications, previous employment history, other data provided in the submitted application documents (e.g. image in the form of a photograph), |
1) Article 22'1 § 1. of the Labour Code Act (hereinafter the Labour Code), 2) Article 6(1)(c) of the DPA - processing is necessary for the fulfilment of a legal obligation incumbent on the controller, 3) Article 6(1)(a) RODO - consent of the data subject, |
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7 |
For other purposes - whereby the content of Article 13 of the RODO will then be presented individually, for the respective purpose of processing |
- |
- |
Disclosure of personal data by the Data Controller
Please be advised that personal data is or may be disclosed by the Data Controller:
Transfers of personal data to a third country (i.e. outside the EEA)
|
Lp. |
Name of the entity |
Link to information |
Potential negative consequences for the data subject |
|
1. |
Facbook |
1) unauthorised access to data, 2) loss of control over their data, 3) the impossibility of exercising your rights under the RODO, 4. other negative impacts indicated in recital (75) of the preamble to the RODO: tangible and intangible impacts |
|
|
2. |
YouTube |
1) unauthorised access to data, 2) loss of control over their data, 3) the impossibility of exercising your rights under the RODO, 4. other negative impacts indicated in recital (75) of the preamble to the RODO: tangible and intangible impacts |
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3. |
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1) unauthorised access to data, 2) loss of control over their data, 3) the impossibility of exercising your rights under the RODO, 4. other negative impacts indicated in recital (75) of the preamble to the RODO: tangible and intangible impacts |
|
|
4. |
Microsoft |
1) unauthorised access to data, 2) loss of control over their data, 3) the impossibility of exercising your rights under the RODO, 4. other negative effects indicated in recital (75) of the preamble to RODO: tangible and intangible effects |
How long, according to the principle of temporality, will personal data be processed?
Please be advised that your personal data is or may be processed for a period of:
|
Lp. |
Purpose of processing |
Lawfulness of processing |
Processing period |
|
1. |
Personal data processed for contact purposes - replying to correspondence received |
1) Article 6(1)(a) RODO - consent of the data subject, 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) until you withdraw the consent you have given, 2) until you object to the processing, 3) for a period of 5 years for internal administrative purposes |
|
2. |
Personal data processed for the purpose of preparing and presenting an offer in respect of own products and services |
1) Article 6(1)(a) RODO - consent of the data subject, 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) until you withdraw the consent you have given, 2) until you object to the processing, 3) for a period of 5 years in internal administrative purposes |
|
3. |
Personal data processed for the purpose of sending commercial information regarding own products and services electronically |
1) Article 6(1)(a) RODO - consent of the data subject [Article 10 Act on the provision of electronic services]. 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) until you withdraw the consent you have given, 2) until you object to the processing, 3) for a period of 5 years for internal administrative purposes |
|
4. |
Personal data processed for the purpose of sending marketing information in relation to own products and services by telephone in the form of a voice call |
(1) Article 6(1)(a) RODO - consent of the data subject [Article 172 Telecommunications Act]. 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) until you withdraw the consent you have given, 2) until you object to the processing, 3) for a period of 5 years for internal administrative purposes |
|
5. |
Personal data processed for the purpose of concluding and performing the contract |
1) Article 6(1)(b) RODO - processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract (2) Article 6(1)(c) of the DPA - processing is necessary for compliance with a legal obligation incumbent on the controller 3) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) for a minimum period of 6 years from the completion of the contract, subject to change, 2) for the period provided for by the applicable legislation, not less than for a period of 6 years after the financial settlements related to the implementation of the contract provisions, 3) for a minimum of 10 years for internal administrative purposes, although this period may vary and in some cases for an indefinite period, |
|
6. |
Personal data processed in connection with participation in a current or future recruitment process - the full information clause is available in the body of this Privacy Policy |
- |
|
|
7. |
For other purposes - whereby the content of Article 13 RODO will then be presented on an individual basis, for the respective purpose of processing |
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- |
What rights does the data subject have?
We inform you of your right to request the Data Controller to exercise the following rights:
Please be advised that due to the particular purposes of processing mentioned in this Privacy Policy, the exercise of the rights of data subjects may be limited in whole or in part, e.g. due to applicable laws that oblige the Data Controller to process the data.
Who is the supervisory authority?
Under what circumstances is the provision of personal data a statutory or contractual requirement or a condition for entering into a contract?
We inform you that the provision of personal data is:
|
Lp. |
Purpose of processing |
Lawfulness of processing |
Provision of personal data |
|
1. |
Personal data processed for contact purposes - replying to correspondence received |
1) Article 6(1)(a) RODO - consent of the data subject, 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) is voluntary, whereby failure to provide personal data will result in the impossibility of responding to enquiries, correspondence received, |
|
2. |
Personal data processed for the purpose of preparing and presenting an offer in respect of own products and services |
1) Article 6(1)(a) RODO - consent of the data subject, 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) is voluntary, failure to provide personal data will result in the impossibility to prepare and send an offer |
|
3. |
Personal data processed for the purpose of sending commercial information in regarding own products and services by e-mail |
1) Article 6(1)(a) RODO - consent of the data subject [Article 10 Law on provision of services by electronic means]. 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) is voluntary; failure to provide personal data will result in the impossibility to prepare and send commercial information |
|
4. |
Personal data processed for the purpose of sending marketing information in relation to own products and services by telephone in the form of a voice call |
(1) Article 6(1)(a) RODO - consent of the data subject [Article 172 Telecommunications Act]. 2) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) is voluntary, failure to provide personal data will result in the impossibility to prepare and send marketing information |
|
5. |
Personal data processed for the purpose of concluding and performing the contract |
1) Article 6(1)(b) RODO - processing is necessary for the performance of a contract to which the data subject is party or to take steps at the request of the data subject prior to entering into a contract (2) Article 6(1)(c) of the DPA - processing is necessary for compliance with a legal obligation incumbent on the controller 3) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
1) is contractual in nature and is a condition for the conclusion of the contract, failure to provide personal data will result in the impossibility of preparing and concluding and implementing the contractual provisions, 2) is of a statutory nature, failure to provide personal data will result in the impossibility to fulfil the obligations incumbent on the Data Controller under the law |
|
6. |
Personal data processed in connection with participation in a current or future recruitment process - the full information clause is available in the body of this Privacy Policy |
- |
|
|
7. |
For other purposes - whereby the content of Article 13 RODO will then be presented on an individual basis, for the respective purpose of processing |
- |
- |
Information on automated decision-making, including profiling
What is the source of the data?
Personal data can be:
What range of personal data is processed?
The data controller processes personal data ordinarily and to the extent necessary to fulfil the purposes indicated in the Privacy Policy, including name, telephone number and/or e-mail address, registration data of a legal entity or sole proprietorship, correspondence data, bank account number and other personal data. In accordance with the principle of minimisation, we only process as much personal data as is necessary to fulfil the purpose of the processing or as is required by current legislation.
How do we secure personal data?
Please be informed that, in order to protect your privacy and personal data, the Data Controller has implemented appropriate technical and organisational measures to ensure the security of the processing of your personal data.
Processing of personal data using social media
We inform you, the Data Controller operates a Fanpage via social media such as Facebook, YouTube, Google. We inform you that in the event that the Data Controller decides on the purposes and means of data processing, the Data Controller becomes the Data Controller for such data and entrusts the processing of personal data to social media. In the case of the processing of personal data by social media for purposes not specified by the Data Controller, the Data Controller is not responsible for the further processing of personal data, including, among others, in the form of cookies, profiling tools, statistics tools and other purposes used by them, and is therefore not responsible for the consequences resulting from breaches of security of the processing of personal data by social media. Please be informed that in the case of the Facebook Fanpage held by the Data Controller, personal data is transferred outside the EEA (to a third country), to entities that may not guarantee a sufficient level of personal data protection, privacy protection, may not ensure the realisation of the rights and/or freedoms of the data subjects. The negative consequences of the transfer of personal data outside the EEA may be material or non-pecuniary damage, loss of control over one's data, inability to exercise the data subjects' rights or freedoms under the DPA. We would like to inform you that the use of the Fanpage on FB by individuals is completely voluntary and depends solely on the decision of the data subject. In addition, we would like to inform you that negative consequences for the protection of personal data, the protection of the privacy of users of the Fanpage operated by the Data Controller, may be, among others. (based on Recital 75 of the RODO/GDPR): property or non-property damage, discrimination, identity theft, identity fraud, financial loss, damage to reputation, breach of confidentiality of personal data protected by professional secrecy, unauthorised reversal of pseudonymisation or any other significant economic or social damage, deprivation of an individual's rights and freedoms or the ability to exercise control over his/her personal data, and other material and non-material effects on an individual. We would like to remind you that each FB user may, within the framework of his/her rights under the current legal provisions on privacy, data protection, on his/her own request comprehensive information on the aforementioned infringement from social media and inquire into claims (Articles 80 and 82 RODO/GDPR). We would like to inform you that Fanpage users can file a complaint directly with the PUODO via the form available at: https://uodo.gov.pl/pl/.
Joint controllers and joint management of personal data
We would like to inform you that in connection with the Administrator's operation of the Facebook Fanpage, a process of joint control of personal data is taking place between the Data Controller and Facebook Ireland Limited, with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland (the Data Controller). Pursuant to Article 26 of the DPA, we would like to inform you that the aforementioned joint controllers have entered into joint arrangements in respect of their obligations under the DPA. Information on the joint arrangements between the Joint Administrators is available at the following link: https://www.facebook.com/legal/controller_addendum - effective date: 31 August 2020. Please be advised that due to the occurrence of a joint control process with Facebook Ireland Limited, there may be transfers of personal data outside the EEA (to a third country) by FB, which may not ensure sufficient protection of personal data, the exercise of the rights and/or freedoms of data subjects, the protection of privacy. We inform you of the right to address queries about the co-management process for each of the co-managers individually. We inform you that the supervisory authority responsible for Facebook Ireland Limited is the Data Protection Commission, 21 Fitzwilliam Square South, Dublin 2, D02 RD28, Ireland (as amended): https://www.dataprotection.ie/.
Processing of personal data based on the consent of the data subject
Please be informed that in the case of processing of personal data based on the consent of the data subject (Art. 6(1)(a) RODO):
|
Lp. |
Purpose of processing |
Lawfulness of processing |
Article 6(1)(a) RODO |
|
1. |
Personal data processed for contact purposes - replying to correspondence received |
1) Article 6(1)(a) RODO - consent of the data subject,
|
The data subject has the right to withdraw his or her consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal. The withdrawal of the consent given should be notified to the email address: odo@fathaco.com |
|
2. |
Personal data processed for the preparation and presentation of offers for own products and services |
1) Article 6(1)(a) RODO - consent of the data subject,
|
The data subject has the right to withdraw his or her consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal. The withdrawal of the consent given must be notified to the email address: odo@fathaco.com |
|
3. |
Personal data processed for the purpose of sending commercial information regarding own products and services electronically |
1) Article 6(1)(a) RODO - consent of the data subject [Article 10 Act on the provision of electronic services].
|
The data subject has the right to withdraw his or her consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal. The withdrawal of the consent given should be notified to the email address: odo@fathaco.com |
|
4. |
Personal data processed for the purpose of sending marketing information in relation to own products and services by telephone in the form of a voice call |
(1) Article 6(1)(a) RODO - consent of the data subject [Article 172 Telecommunications Act].
|
The data subject has the right to withdraw his or her consent at any time. The withdrawal of consent does not affect the lawfulness of the processing carried out on the basis of consent before its withdrawal. The withdrawal of the consent given must be notified to the email address: odo@fathaco.com |
|
5. |
Personal data processed in connection with participation in a current or future recruitment process - the full information clause is available in the body of this Privacy Policy |
- |
Processing of personal data based on a legitimate interest pursued by the Data Controller
Please be informed that in the case of processing of personal data based on a legitimate interest pursued by the Data Controller (Art. 6(1)(f) RODO):
|
Lp. |
Purpose of processing |
Lawfulness of processing |
Article 6(1)(f) RODO |
|
1. |
Personal data processed for contact purposes - replying to correspondence received |
1) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
The legitimate interest of the Data Controller is considered to be the processing of personal data for the purpose of responding to received correspondence, enquiries - keeping in touch with the data subject on an ongoing basis |
|
2. |
Personal data processed for the purpose of preparing and presenting an offer in respect of own products and services |
1) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
A legitimate interest is considered to be a binding relationship between the parties, including a business relationship, an ongoing contract with the data subject and the processing of data for internal administrative purposes, also with regard to the exercise of the data subject's rights in connection with the possibility of exercising the data subject's right and provided for by legislation (e.g. documenting the withdrawal of granted consent) |
|
3. |
Personal data processed for the purpose of sending commercial information regarding own products and services electronically |
1) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
A legitimate interest is considered to be a binding relationship between the parties, including a business relationship, an ongoing contract with the data subject and the processing of data for internal administrative purposes, also with regard to the exercise of the data subject's rights in connection with the exercise of the data subject's rights and as provided for by law (e.g. documenting the withdrawal of consent granted) |
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4. |
Personal data processed for the purpose of sending marketing information in relation to own products and services via by telephone in the form of a voice call |
1) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
A legitimate interest is considered to be a binding relationship between the parties, including a business relationship, an ongoing contract with the data subject, and the processing of data for internal administrative purposes, also in relation to the exercise of the data subject's rights as provided by law (e.g. documenting the withdrawal of granted consent) |
|
5. |
Personal data processed for the purpose of concluding and performing the contract |
1) Article 6(1)(f) RODO - legitimate interest pursued by the controller |
A legitimate interest is considered to be a binding relationship between the parties, including a business relationship, an ongoing contract with the data subject, and the processing of data for internal administrative purposes, also with regard to the exercise of the data subject's rights in connection with the possibility of exercising the data subject's right and provided for by law, the exercise of possible claims (e.g. debt collection, court cases, warranty or guarantee cases) |
Information on the processing of personal data in connection with participation in the recruitment process
Pursuant to Article 13 RODO, we would like to inform you that the Administrator of the data in relation to applicants for employment is Fabryka Automatów Tokarskich we Wrocławiu S.A. with its registered office at Grabiszyńska 281, 53-234 Wrocław (NIP: 896-000-01-38). Contact details to the Data Protection Administrator:odo@fathaco.com or by post at the above address. Please be informed that the Data Protection Inspector has not been appointed. We would like to inform you that personal data is or may be processed for the following purposes:
Please be informed that, pursuant to Article 34 RODO, in the event of a personal data breach which may result in a high risk of infringement of the rights or freedoms of natural persons, the Data Controller shall, without undue delay, notify the data subject of such breach. We inform you that pursuant to Article 34 of the RODO, personal data may be processed in connection with the occurrence of the breach referred to above. We inform you that the legal basis for the processing of personal data is Article 6(1)(c) RODO. We inform you that in the event of a personal data breach, the Data Controller will take all possible and available technical and organisational measures to comply with the requirements set out in Article 33 and Article 34 of the RODO.
[1] RODO: https://uodo.gov.pl/pl/404/224