PRIVACY POLICY

PROCESSING OF PERSONAL DATA

 

Ladies and Gentlemen,
 

Please be advised that as of May 25, 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), called GDPR. Therefore, we would like to inform you that you have certain rights related to the processing of your personal data by us. The full content of the information obligation referred to in Art. 13 or 14 GDPR, you will receive:
 

• when obtaining your personal data - in the event that you provide it to us yourself,

• no later than one month after obtaining them, at our first communication or when disclosing data to another recipient - in the event that we obtain your personal data from another entity.

 

In case of any doubts related to the privacy policy, you can contact us at any time by sending a message to the following e-mail address:poc.poland@atlanticcontract.com or rodo@atlanticcontract.com

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By sending us an e-mail, you provide us with your personal data, and we guarantee that the data provided will remain confidential, secure and will not be disclosed to any third parties contrary to this policy.
 

1. We use analytical tools, such as Google Analytics, which collect anonymous information about your visits to the website, such as the subpages viewed, time spent on the website or transitions between individual subpages. This involves the use of Google cookies.
    

2. We may share your personal data with other entities related to the company and selected third parties cooperating with us.

 

What data are we talking about?
 

Personal data is information relating to an identified or identifiable natural person. Therefore, it is primarily about data enabling your identification, including name and surname, numerical identification data, such as: PESEL, NIP, REGON, KRS, ID card number and series, address and contact details, e.g. telephone number, e-mail address.

 

Personal data administrator.
 

The administrator of your personal data is ATLANTIC CONTRACT Sp. z o. o. Sp. k. with its registered office in Warsaw (00-195), at ul. Zygmunta Słomińskiego 7/203, entered into the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under KRS number: 0000796049, NIP: 5252795869, REGON 383935969.
 

Why and on what basis do we process your personal data?

Your personal data may be processed by us on the basis of the legitimate interest pursued by the administrator (Article 6(1)(f) of the GDPR) for the following purposes:
 

1. take action before concluding the contract or when it is necessary to conclude and perform the contract concluded with you (Article 6(1)(b) of the GDPR); 
    

2. handling your requests and inquiries, consisting in their acceptance and consideration (Article 6(1)(a) of the GDPR); 
    

3. researching your  preferences, including through profiling, consisting in adjusting the method of contacting you to your needs and selecting the optimal  offer;
    

4. marketing, in particular in order to present you with an offer related to finance, if you have given us your voluntary consent; the legal basis for processing is therefore your consent (Article 6(1)(a) of the GDPR);
    

5. in order to test customer satisfaction - the legal basis for data processing is the necessity of processing to implement the legitimate interest of the administrator; the legitimate interest of the administrator is to maintain the high quality of our service and the level of satisfaction of our customers with products and services - (Article 6(1)(f) of the GDPR);
    

6. storing information for tax and accounting purposes, which is our obligation under the law (Article 6(1)(c) of the GDPR); 
    

7. consideration of your complaints, which is our obligation under the law (Article 6(1)(c) of the GDPR);
    

8. fulfilling our legal obligations under the provisions on counteracting money laundering and financing of terrorism (Article 6(1)(c) of the GDPR);
    

9. protection of the rights of ATLANTIC CONTRACT Sp. z o. o. Sp. k. in accordance with the law;
    

10. Your personal data may be processed by us on the basis of a legitimate interest pursued by the administrator (Article 6(1)(f) of the GDPR).

 

Email contact.
 

When contacting us via e-mail, you provide us with your e-mail address as the address of the sender of the message. In addition, you can also include other personal data in the content of the message. The legal basis for the processing of personal data in this case is the consent resulting from initiating contact with us. Your personal data provided to us as part of the e-mail contact is processed only for the purpose of handling the inquiry. The content of correspondence may be archived.

 

Marketing agreement.
 

The legal basis for the processing of personal data in this case is consent, which may be withdrawn at any time. The data will be processed in an automated manner, including in the form of profiling, automated decision making, and the consequence of such processing will be the receipt of selected marketing information. Providing personal data is voluntary, however, failure to provide data may result in the inability to receive marketing offers.

 

 

How do we protect your personal data?
 

We are aware that your personal data is confidential. The Company maintains confidentiality, security and protects your personal data in accordance with applicable law, including the provisions of the GDPR, as well as internal policies and instructions adopted by the Company. The Company has implemented technological and operational security measures to protect your personal data against loss, misuse, or unauthorized modification or destruction. Such measures include, among others: use, encryption, appropriate management processes regarding access rights and other technical and organizational measures to ensure the proper protection of your personal data. These measures ensure an appropriate level of security with regard to the risks inherent in the nature of the personal data to be protected. Please note, however, that when you transmit information over the Internet, it cannot be guaranteed to be 100% secure. This site uses SSL or TLS encryption in whole or in part for security reasons and to protect the transmission of confidential content, such as inquiries sent to us as the site operator. You can recognize an encrypted connection in your browser's address line when it changes from "http: //" to "https: //" and a lock icon is displayed in your browser's address bar. If SSL or TLS encryption is activated, the data you transmit to us cannot be read by third parties. We ensure that all security and personal data protection measures required by the provisions on the protection of personal data are taken. Personal data is collected with due diligence and properly protected against access by unauthorized persons

 

How long do we store your personal data?
 

The period of processing your personal data by the Administrator depends on the purpose of their processing.
 

1. we process your data for the period necessary to fulfill the contract and the claims arising from it expire, or until the consent is withdrawn, e.g. for the purpose of marketing products and services, your personal data will be processed until its withdrawal,
    

2. we store the user's personal data for the duration of archiving accounting documents in accordance with applicable law, including tax and accounting obligations,
    

3. pursuing claims in connection with the performance of the contract,
    

4. preventing abuse and fraud,
    

5. for statistical purposes,
    

6. for a maximum period of 10 years from the date of completion of the contract.

 

Who can we transfer your personal data to?
 

ATLANTIC CONTRACT Sp. z o. o. Sp. k. may transfer your personal data to other entities that have been authorized or obliged to do so by the provisions of law, including the provisions on counteracting money laundering and financing terrorism, in particular:
 

• entities operating under the law (public authorities), including e.g. the prosecutor's office, the Police and the Tax Office - in connection with the implementation of legal obligations incumbent on the Company,
   

• entities providing marketing and advertising services to the Company (e.g. marketing agencies, interactive agencies) - to the extent necessary to provide these services;
   

• entities providing IT services to the Company (e.g. hosting websites) - to the extent necessary to provide these services;
   

• entities providing other types of services to the Company, e.g. law firms  - in connection with the provision of these services.
   

• entities supporting the process of providing our services, such as companies dealing with the storage and archiving of documents, entities providing postal and courier services, as well as our consultants.

 

Do you have to provide us with your personal data?
 

Providing your personal data is voluntary. To the extent that the processing of your personal data takes place in order to conclude and perform the contract, failure to provide them will result in the inability to conclude and perform the contract.

 

Profiling and automated decision making.
 

Please be advised that as part of our activities, your data will be processed in an automated manner, including in the form of profiling. Profiling means the use of your personal data to assess your preferences as to how and when to contact you.

 

Transferring your personal data outside the European Economic Area (EEA).

Your personal data is not transferred to third countries or international organizations.

 

Rights related to the processing of personal data.
 

In our activity, we guarantee the possibility of exercising the rights resulting from the GDPR. According to the GDPR, you have:
 

1. the right to access data - you have the right to obtain confirmation from the Company as to whether your personal data is processed by the Company, as well as in the scope of certain other information (e.g. regarding the purposes of processing, as well as the categories of processed personal data about your personal data) . You also have the right to access your personal data in the form of obtaining a copy of your personal data. This is to make you aware and able to check how the Company uses your personal data. The company may refuse to provide a copy of personal data in a situation where it could adversely affect the rights of another person;
    

2. the right to rectify data - you have the right to request the Company to correct your personal data immediately if they are incorrect or incomplete (e.g. when the Company processes your incorrect name or address); for this purpose, you can provide an additional statement;
    

3. the right to delete data (also known as the "right to be forgotten") - it allows you to request the deletion of your personal data in the event that, for example, the data has been used unlawfully or your consent has been withdrawn (when it was the only the basis for processing your data). However, the "right to be forgotten" does not constitute an absolute right to delete your personal data, because there are some exceptions to it, e.g. when the Company needs to continue to use the data to establish, pursue or defend legal claims or to fulfill an obligation legal;
    

4. the right to limit processing - you have the right to stop the Company from further using your personal data in the event that, for example, the Company is in the process of assessing a request to correct your data. In the event of limiting the processing of personal data, the Company may continue to store your personal data, but it may no longer actively use them (e.g. for the purpose of performing the contract);
    

5. the right to transfer data - you have the right to receive and reuse certain personal data for your own purposes with other entities (which are separate data administrators). This right applies only to your personal data that you have provided to us and that we process (in an automated manner) with your consent or for the performance of a contract. In this case, we will provide you with a copy of your personal data in a structured, commonly used and machine-readable format or (where technically possible) we may send your data directly to another data controller. The Company may refuse to exercise this right in a situation where it could adversely affect the rights of another person.

 

To the extent that the basis for the processing of your personal data is the implementation of legitimate interests, you have the right to object to the processing of this data, in particular in connection with their processing for direct marketing purposes. However, the company has the option to continue processing personal data if it is possible to demonstrate valid and legally justified grounds for processing that override your interests, rights and freedoms, or if it is necessary to establish, pursue or defend claims. If you object to the processing of your personal data for direct marketing purposes, we will no longer process your personal data for such purposes.

 

To the extent that the basis for the processing of your personal data is consent, you have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of processing based on consent before its withdrawal.

 

You have the right to lodge a complaint with the body supervising compliance with the provisions on the protection of personal data (the Inspector General for Personal Data Protection or the successor of this body - the President of the Office for Personal Data Protection).

If you want to exercise the above rights, you can: submit your request to us via:  
 

• by e-mail to:poc.poland@atlanticcontract.com or rodo@atlanticcontract.com
   

• by traditional mail to the following address: ATLANTIC CONTRACT Sp. z o. o. Sp. k. with its registered office in Warsaw (00-195), at ul. Zygmunta Slomińskiego 7/203,
   

• in person, during contact with our advisor or at the headquarters of ATLANTIC CONTRACT Sp. z o. o. Sp. k. with its registered office in Warsaw (00-195), at ul. Zygmunta Słomińskiego 7/203.
   

• Email:gdpr@atlanticcontract.com