Privacy policy

PRIVACY POLICY – DPE International sp. z o.o.

This Policy aims to provide you with information on how we process personal data and to fulfill the informational obligation.

WHO IS THE DATA CONTROLLER?

Please be informed that the controller of your personal data is DPE International sp. z o.o., located at Rodawska 32A, 61-312 Poznań, registered in the District Court of Poznań, Tax ID Number 7822923680, REGON 525383150, hereinafter referred to as the “Data Controller”.

Contact regarding personal data protection is possible at the company’s address or by email: gdpr@dpeint.com with the note “GDPR”.

JOINT ADMINISTRATION OF PERSONAL DATA

We inform that within the scope of common purposes for DPE International sp. z o.o. and its affiliated companies, joint administration occurs. Within the shared infrastructure, personnel, and IT systems in companies associated with us, we have common business processes. These include handling inquiries, marketing, recruitment, settlements, reporting, auditing, customer service, quality control of customer service, handling complaints, warranties, claims, accounting.

Each of the joint administrators may be involved in the processing of personal data of customers or potential customers at different stages and to varying degrees, sometimes pursuing their own, individual goals, which may be interrelated. The common goal of the affiliated companies is the sale of products and services of each of the companies separately. Each of the joint administrators is responsible within its own scope for the realization of your rights related to personal data.

WHAT ARE OUR GOALS AND LEGAL BASIS FOR PROCESSING PERSONAL DATA?

Below are the specified purposes of personal data processing along with the legal bases:

A. To undertake actions at your request before entering into a service contract in accordance with our business scope, we process the following personal data:

First and last name, home address, company name, company headquarters, correspondence address, address of planned works, email address, phone number, Tax ID Number, REGON, information contained in public registers, bank account number, IP address, and other information that was included in the documentation we received from you;

The legal basis for such processing of data is:

Article 6(1)(a) of the GDPR, your consent to the processing of personal data for one or more specific purposes;

Article 6(1)(b) of the GDPR, which allows processing personal data if it is necessary for the performance of a contract or to take steps at your request before entering into a contract;

Article 6(1)(f) of the GDPR – legitimate interest of the data controller.

B. To conclude and execute the contract, i.e., provide services, we process the following personal data:

First and last name, home address, company name, company headquarters, correspondence address, work address, email address, phone number, Tax ID Number, REGON, information contained in public registers, bank account number, IP address, and other information that was included in the documentation we received from you;

the legal basis for such processing of data is Article 6(1)(b) of the GDPR, which allows processing personal data if it is necessary for the performance of a contract or to take steps at your request before entering into a contract between us.

C. To fulfill legal obligations resting on us, e.g., issuing a VAT invoice and making tax settlements, we process the following personal data:

First and last name, company name, home address, company headquarters, correspondence address, email address, Tax ID Number, REGON, information contained in public registers, bank account number.

the legal basis for such processing of data is Article 6(1)(c) of the GDPR, which allows processing personal data if such processing is necessary for the Data Controller to comply with legal obligations.

D. To consider matters directed directly to the Data Controller, e.g., consideration of warranty claims, we process the following personal data:

First and last name, home address, company name, company headquarters, correspondence address, address of completed works, email address, phone number, Tax ID Number, REGON, and other information that was provided to us for this purpose.

the legal basis for such processing of data is:

Article 6(1)(b) of the GDPR, which allows processing personal data if it is necessary for the performance of a contract;

Article 6(1)(a) of the GDPR, which allows processing personal data based on voluntarily given consent.

E. To convey information related to the execution of the contract binding us, we process the following personal data:

the legal basis for such processing of data is Article 6(1)(b) of the GDPR, which allows processing personal data if it is necessary for the performance of a contract.

F. To establish, pursue, and protect claims, we process the following personal data:

First and last name, home address, company name, company headquarters, correspondence address, address of completed works, email address, phone number, Tax ID Number, REGON, information contained in public registers, bank account number, IP address, and other information that was included in the documentation we received from you;

the legal basis for such processing of data is Article 6(1)(f) of the GDPR, which allows processing personal data if by doing so the Data Controller realizes its legally justified interest (in this case, the interest of the Data Controller is having personal data that will allow to establish, pursue, or defend against claims, including those of customers, contractors, and third parties.

G. To store left unanswered offers/inquiries, we process the following personal data:

First and last name, company name, email address, phone number, or other data you have provided us;

It may happen that you decide to use our services after some time from receiving our offer, and the legal basis for such processing of data is Article 6(1)(f) of the GDPR, which allows processing personal data if by doing so the Administrator realizes its legally justified interest (in this case, the interest of the Administrator is enabling the use of our services for a specified period without the need to renew the offer).

H. For archival and evidential purposes, we process the following personal data:

First and last name, home address, company name, company headquarters, correspondence address, address of completed works, email address, phone number, Tax ID Number, REGON, information contained in public registers, bank account number, IP address, and other information that was included in the documentation we received from you;

the legal basis for such processing of data is:

Article 6(1)(f) of the GDPR, which allows processing personal data if by doing so the Administrator realizes its legally justified interest (in this case, the interest of the Administrator is having personal data that will allow proving certain facts related to the performance of the contract

Article 6(1)(c) of the GDPR, which allows processing personal data if such processing is necessary for the Data Controller to comply with legal obligations.

I. To administer the website (automatic recording of the following data in so-called server logs, each time you use our website www.dpeint.com) we may process personal data such as:

IP address, date and time of the server, information about the internet browser, information about the operating system;

the legal basis for such processing of data is Article 6(1)(f) of the GDPR, which allows processing personal data if by doing so the Administrator realizes its legally justified interest. In this case, the interest of the Administrator is having the ability to administer the website. More information can be found in our Cookies Policy.

J. For direct marketing purposes, we process the following data

First and last name, company name, email address, phone number, correspondence address, data contained in public registers e.g. KRS, CEIDG;

the legal basis for such processing of data is:

Article 6(1)(a) of the GDPR, which allows processing personal data based on voluntarily given consent

Article 6(1)(f) of the GDPR, which allows processing personal data if by doing so the Administrator realizes its legally justified interest.

HOW TO EXERCISE THE RIGHT TO WITHDRAW CONSENT?

If the processing of personal data is based on your consent, you can withdraw this consent at any time — at your discretion.

If you wish to withdraw consent to the processing of personal data, it is enough to send a letter directly to the Data Controller or send an email with the note “GDPR”.

If the processing of your personal data was based on consent, its withdrawal does not mean that the processing of personal data up to that moment was illegal. In other words, until the withdrawal of consent, we have the right to process your personal data, and its revocation does not affect the legality of the processing carried out so far.

REQUIREMENT TO PROVIDE PERSONAL DATA

Providing any personal data is voluntary and depends on your decision. However, in the case of entering into a contract with us for the provision of our services, providing certain personal data is necessary.

To receive a commercial offer, it is necessary to provide an email address and phone number — without this, we are unable to meet your expectations and maintain the highest quality of service, which we highly value.

DO WE CONDUCT AUTOMATED DECISION-MAKING AND PROFILING?

We kindly inform you that we use Facebook, Google, Hotjar cookies, and others, which allow us to collect information about the way users use the website, including profiling. We collect such information as the frequency of use by users of our website, the pages they visit, etc. The information we receive is used to improve our website, services, and advertising campaigns. There may be profiling in campaigns related to marketing, however, it obviously does not cause legal effects and does not have a significant impact on our customers.

WHO MAY WE TRANSFER YOUR PERSONAL DATA TO?

We may transfer your data to:

a) our employees and associates who must have access to the data in order to fulfill our obligations or actions on your behalf.

Like most entrepreneurs, we also use the help of other entities in our activities, which often involves the need to transfer personal data. Therefore, if necessary, we transfer your personal data to the following recipients:

a) entities providing marketing services, training, events organization for us;

b) entities servicing our IT and telecommunication system;

c) entities conducting payment activity (banks, payment institutions);

d) entities conducting credit activities (banks), leasing, factoring;

e) entities conducting postal, courier activities;

f) entities providing advisory, audit, or legal, tax, accounting, HR, training services for us;

g) entities that are our subcontractors.

In justified cases, data may be made available to other data administrators if there is a legal basis for it (consent, contract, or legitimate interest) e.g., trusted partners providing complementary (supplementary) services to our services.

In addition, it may happen that, for example, based on the relevant legal provision or the decision of the competent authority, we will have to transfer your personal data to other entities, whether public or private, such as the Social Insurance Institution, Tax Office, National Revenue Administration, etc. Therefore, it is extremely difficult for us to predict who may request the provision of personal data. Nevertheless, we assure you that each case of a request for the provision of personal data is analyzed very carefully and very thoroughly, so as not to accidentally provide information to an unauthorized person.

In the event that the recipients of the data will independently and on their own behalf process your personal data, e.g., offer their products and services, they will become separate data controllers in this respect and bear their own responsibility for processing such personal data, not subject to the terms of our Policy.

DO WE TRANSFER YOUR PERSONAL DATA TO THIRD COUNTRIES?

We kindly inform you that your personal data is transferred outside the European Economic Area due to the use of tools and technologies of trusted suppliers from outside the EEA.

HOW LONG CAN WE STORE YOUR PERSONAL DATA?

In accordance with the applicable legal provisions, we process your personal data for the time necessary to achieve the specified purpose. After this period, your personal data will be irreversibly deleted or destroyed.

Regarding specific periods of personal data processing, we kindly inform you that we process personal data for the period of:

a) up to 10 years — in relation to personal data processed for the purpose of establishing, pursuing, or defending claims, but no longer than required by applicable laws;

b) the duration of the contract, but also after its termination, but no longer than for a period of 5 years — in relation to personal data processed for the purpose of concluding and executing the contract; in relation to personal data related to the fulfillment of tax law obligations, e.g., storing invoices, bills; in relation to data related to provided warranties;

c) 2 years — in relation to personal data collected in connection with sending an offer, and at the same time, no immediate conclusion of the contract occurred;

d) until the withdrawal of consent, effective objection, or achievement of the processing purpose — in relation to personal data processed based on consent; in relation to personal data processed based on the legally justified interest of the Administrator or for marketing purposes;

Periods in years are counted from the end of the year in which we started processing personal data to streamline the process of deleting or destroying personal data. Separate counting of the term for each event would involve significant organizational and technical difficulties, as well as a significant financial outlay, therefore establishing one date for deleting or destroying personal data allows us to manage this process more efficiently.

Right to be forgotten: Of course, in the case of using your right to be forgotten, such situations are considered individually.

WHAT RIGHTS DO YOU HAVE?

We kindly inform you that you have the right to:

• The right to access the content of your personal data – i.e., obtaining information about the purpose and manner of processing your personal data as well as a copy of the data.

• The right to rectification of data – i.e., correcting data when they are incorrect, have changed, or have become outdated.

• The right to partial or complete deletion of data („Right to be forgotten”) – i.e., deletion of data that are processed without justified legal grounds.

• The right to restrict processing – i.e., limiting the processing of data exclusively to their storage.

• The right to data portability – i.e., obtaining your personal data that you have provided us with or indicating another administrator to whom we should transfer them, if it is technically possible.

• The right to object to the processing of personal data, the provision of which is voluntary – including, for example, for direct marketing purposes.

• The right to withdraw consent – you may withdraw any consent you have expressed at any time. Please remember that from the submission of the disposition, we will no longer process data for the purpose indicated by you, but until the withdrawal of consent, we have the right to process your data.

We respect your rights arising from data protection regulations and try to facilitate their realization to the highest possible extent.

We indicate that the listed entitlements are not absolute, and therefore in some situations, we may legally refuse to fulfill them. However, if we refuse to consider the request, it is only after thorough analysis and only in a situation where the refusal to consider the request is necessary.

Regarding the right to object, we explain that you have the right to object to the processing of personal data based on the legally justified interest of the Data Controller /they have been listed in the third point of this Privacy Policy/ in connection with your particular situation. However, you must remember that according to the regulations, we may refuse to consider the objection if we demonstrate that:

a) there are legally justified grounds for processing that are overriding to your interests, rights, and freedoms, or;

b) there are grounds for establishing, pursuing, or defending claims.

In addition, at any time, you can object to the processing of your personal data for marketing purposes.

The Administrator has not appointed a Data Protection Officer.

In such a case, after receiving the objection, we will cease processing for this purpose.

You can realize your rights by sending a letter directly to the Data Controller at the company’s address or by sending an email to: gdpr@dpeint.com with the note “GDPR”.

YOU HAVE THE RIGHT TO FILE A COMPLAINT TO THE PERSONAL DATA PROTECTION AUTHORITY

If you believe that your personal data is processed contrary to the applicable law, you can file a complaint to:

President of the Personal Data Protection Office Office for Personal Data Protection

ul. Stawki 2, 00-193 Warsaw

FINAL PROVISIONS

To the extent not regulated by this Privacy Policy, the provisions on personal data protection apply, including, among others:

a) Regulation on the Protection of Personal Data (Regulation of the European Parliament and of the Council (EU) of 27 April 2016 2016/679)

b) Act of 10 May 2018 on personal data protection

c) Act of 18 July 2002 on providing services by electronic means

d) Act of 16 July 2004 – Telecommunications Law

You will be informed about any changes made to this Privacy Policy by email or through a notice on our website: www.dpeint.com.

This Privacy Policy is effective from 1.03.2024.

COOKIES POLICY

What is a “cookie”?

“Cookies”, also known as cookies, are short information/text files saved on your computer, phone, tablet, or other device by websites you visit. Cookies are encrypted in such a way that people who do not have permissions do not have access to them.

They can be read by Us as the Data Controller, as well as by systems belonging to other trusted entities from which we use technologies.

What is the purpose of using “cookies”?

Cookies fulfill many functions on the website, most often useful, which we will try to describe below (if the information is insufficient, please contact us):

• ensuring security — cookies are used to authenticate users and prevent unauthorized use of the customer panel. They serve to protect the user’s personal data from access by unauthorized persons;

• impact on processes and performance of using the website — cookies are used so that the website works efficiently and you can use the functions available on it, which is possible, among others, thanks to remembering settings between subsequent visits to the site. Thanks to them, you can therefore move efficiently on the website and individual subpages;

• session state — cookies often store information about how visitors use the website, e.g. which subpages they display most often. They also allow the identification of errors displayed on some subpages. Cookies used to save the so-called “session state” therefore help improve services and increase the comfort of browsing pages;

• maintaining the session state — if the customer logs into their panel, cookies allow maintaining the session. This means that after going to another subpage, you do not have to enter your login and password each time, which promotes the comfort of using the website;

• creating statistics — cookies are used to analyze how users use the website (how many open the website, how long they stay on it, which content arouses the most interest, etc.). This allows us to continuously improve the website and adjust its operation to user preferences. To track activity and create statistics, we use various analytical and statistical tools.

• targeting ads – these files are placed on our websites by our advertising partners. They can be used by these companies to create a profile of your interests and display relevant ads on other websites. Advertising cookies operate based on the unique identification of the browser and the device. If you do not agree to the use of these cookies, ads displayed on various websites will not be tailored to you.

Importantly, many cookies are anonymous for us — without additional information, based on them, we are unable to identify your identity.

How can you control cookies?

Your web browser by default allows the use of cookies on your device, so when visiting for the first time, we ask for consent to use cookies.

However, control and management of installed cookies are possible. How to do it?

Control – web browser: if you do not wish to use cookies when browsing the website, in most web browsers you can change the settings – completely block the automatic handling of cookies or request notification each time cookies are placed on the device. Settings can be changed at any time. You can find more information in this regard on the website: https://www.aboutcookies.org/

What will happen if you do not consent to our use of cookies?

Respecting the autonomy of all people using the website, however, we feel obliged to warn that disabling or limiting the handling of cookies may cause quite serious difficulties in using the website, e.g. the need to log in on each subpage, a longer period of loading the page, limitations in using functionalities, limitations in liking the page on Facebook, LinkedIn, Instagram, etc.

How long will we use cookies?

Cookies remain on your device:

• until you leave the website or also turn off the software (web browser) – applies mainly to technical cookies;

• some cookies may remain on your device until you manually delete them.

A short guide on how to disable cookies from your web browsers

For Firefox browser:

https://support.mozilla.org/pl/kb/enabling%20and%20disabling%20cookies

For Google Chrome browser:

https://support.google.com/chrome/answer/95647?hl=pl

For Internet Explorer 9 browser:

https://support.microsoft.com/pl-pl/hub/4338813/windows-help

Additional information about processing your data

You can find other information related to the process of processing your personal data and the rights that you are entitled to in our Privacy Policy or by contacting us:

DPE International sp. z o.o., ul. Rodawska 32A, 61-312 Poznań, e-mail: gdpr@dpeint.com.