PRIVACY POLICY regarding personal data of clients and suppliers

PRIVACY POLICY

-regarding personal data of clients and suppliers-

Who are we and how to find us

We are DOTLINKERS and we are processing your personal data in a way presented in our PRIVACY POLICY.

We are a group of companies listed below:

DOTLINKERS spółka z ograniczoną odpowiedzialnością (address: ul. Przemysłowa 12, 30-701 Kraków, Polska),
DOTLINKERS spółka z ograniczoną odpowiedzialnością spółka komandytowa (address: ul. Przemysłowa 12, 30-701 Kraków, Polska).

Both entities are co-administrators of your personal data, and as a result:

If one entity will get access to your personal data, the second one will have access to it too.
Both companies together deciding about why and how they process your personal data.
This PRIVACY POLICY applies to both companies.
You can contact any of them to obtain information or use other rights that you are entitled to as per the GDPR. You can do it via rodo@dotlinkers.pl or +48 505 184 303.

Why do we process your personal data

We process your personal data for the purposes of execution of the contract concluded with you and fulfilment of tax obligations.

The legal basis for the processing of your personal data is point (b) of Article 6(1) of GDPR (processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract), and point (c) of Article 6(1) of GDPR (the processing is necessary for compliance with a legal obligation to which the controller is subject).

What personal data do we process

We process the following personal data:

first name and last name,
position,
e-mail address,
telephone number,
fax number,
address of business activity run by you,
your business name,
NIP (Tax Identification Number),
REGON (Statistical Number),
KRS (National Court Register),
history of our transactions with you,
history of our correspondence with you (including via e-mail).
To whom do we disclose your personal data

Your personal data will be disclosed within the required scope to state administration bodies authorised to receive them by law (e.g. tax authorities).

Your personal data are processed in the IT system which is partially placed in the so-called computing cloud delivered to us by bitebyte.pl Maciej Kupiec (NIP [Tax Identification Number]: 6292368157). The same entity deals with IT-related issues in our company and, on this occasion, may have access to some of your personal data. This does not involve the transfer of your personal data to third countries.

In addition, we use the computing cloud provided by Microsoft, within the framework of the Office 365 tools. This does not involve the transfer of your personal data to third countries.

We also use dedicated software for HR companies provided by a renowned supplier. Your personal data processed in this software will be transferred to third countries. This transfer takes place on the basis of a legal instrument provided for in GDPR, and is absolutely safe.

Your personal data will be disclosed to WL Finanse sp. z o.o., with its registered office in Kraków, that runs our accounts. In a relevant contract with this entity, we have ensured that your data entrusted to it will not be transferred to third countries.

How long will we process your personal data

Your personal data will be processed so long as it is necessary for tax purposes, that is, pursuant to the currently applicable provisions of the Polish law, for 5 tax years. You are certainly aware that five tax years may as well mean six or even nearly seven calendar years.

If we regularly cooperate with you (e.g. on the basis of a framework agreement), some of your data which are necessary for this purpose will obviously be processed for the entire term of cooperation.

How do we allow you to exercise your rights

We make every effort for you to be satisfied with cooperation with us. Remember that you have many rights that will help you influence the way we process your personal data and, in some cases, cause such processing to stop. These rights include:

right of access to personal data (provided for in Article 15 of GDPR)

Article 15

Right of access by the data subject

The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
a) the purposes of the processing;
b) the categories of personal data concerned;
c) the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organisations;
d) where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
e) the existence of the right to request from the controller rectification or erasure of personal data or restriction of processing of personal data concerning the data subject or to object to such processing;
f) the right to lodge a complaint with a supervisory authority;
g) where the personal data are not collected from the data subject, any available information as to their source;
h) the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) and, at least in those cases, meaningful information about the logic involved, as well as the significance and the envisaged consequences of such processing for the data subject.
Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
The controller shall provide the data subject with a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

right to rectification (provided for in Article 16 of GDPR)

Article 16

Right to rectification

The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

right to erasure (provided for in Article 17 of GDPR)

Article 17

Right to erasure (“right to be forgotten”)

The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
b) the data subject withdraws consent on which the processing is based according to point (a) of Article 6(1) or point (a) of Article 9(2), and where there is no legal ground for the processing;
c) the data subject objects to the processing pursuant to Article 21(1) and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2);
d) the personal data have been unlawfully processed;
e) the personal data have to be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject;
f) the personal data have been collected in relation to the offer of information society services referred to in Article 8(1).
Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data.
Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
a) for exercising the right of freedom of expression and information;
b) for compliance with a legal obligation which requires processing by Union or Member State law to which the controller is subject or for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller;
c) for reasons of public interest in the area of public health in accordance with points (h) and (i) of Article 9(2) as well as Article 9(3);
d) for archiving purposes in the public interest, scientific or historical research purposes or statistical purposes in accordance with Article 89(1) in so far as the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or
e) for the establishment, exercise or defence of legal claims.

right to restriction of processing (provided for in Article 18 of GDPR)

Article 18

Right to restriction of processing

The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
a) the accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data;
b) the processing is unlawful and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
c) the controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defence of legal claims;
d) the data subject has objected to processing pursuant to Article 21(1) pending the verification whether the legitimate grounds of the controller override those of the data subject.

Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject’s consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.

right to object to the processing (provided for in Article 21 of GDPR)

Article 21

Right to object

The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims.
Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her rights to object by automated means using technical specifications.
Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out of reasons of public interest.

right to data portability (provided for in Article 20 of GDPR)

Article 20

Right to data portability

The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
a) the processing is based on consent pursuant to point (a) of Article 6(1) or point (a) of Article 9(2) or on a contract pursuant to point (b) of Article 6(1); and
b) the processing is carried out by automated means.
In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

In order to exercise any of the above-described rights, please contact us via e-mail at the address from which we have contacted you or at the address: RODO@dotlinkers.pl. You may also contact us for these purposes by phone at +48 505 184 303.

Complaint to a supervisory authority

Pursuant to Article 77 of GDPR, you have the right to lodge a complaint to a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the provisions of GDPR.

Is it necessary to provide personal data to conclude a contract with us

We collect your personal data within the scope necessary to conclude and execute the contract. Some data are also necessary for the execution of our obligations imposed by the provisions of the law (tax regulations, accounting regulations). If you do not provide personal data, this will, unfortunately, make the conclusion and execution of the contract impossible.

Where have we obtained your personal data

We have obtained your personal data only from you.

Automated processing and profiling

We do not perform automated processing of your data and their profiling within the meaning adopted by GDPR.