enpl

dotLinkers

PRIVACY POLICY regarding personal data of clients and suppliers

PRIVACY POLICY 

– regarding personal data of clients and suppliers – 

 

1. Who we are and how to find us 

We are DOTLINKERS, and we process your personal data as described in this Privacy Policy. 

We operate as a group of companies. The details of these companies are as follows: 

  • DOTLINKERS Limited Liability Company, based in Kraków (address: ul. Przemysłowa 12, 30-701 Kraków, Poland) 
  • DOTLINKERS Limited Liability Company – Limited Partnership, based in Kraków (address: ul. Przemysłowa 12, 30-701 Kraków, Poland) 

Both of our companies are so-called joint controllers of your personal data, which means that: 

  • When one of the companies obtains your personal data, the other will also have access to it. 
  • Both companies jointly decide how and why they process your personal data. 
  • This Privacy Policy applies to both companies. 

You can contact either of them to obtain information or exercise your rights under the GDPR. We have established a common contact point for this purpose — namely, an email at rodo@dotlinkers.pl and a phone number +48 505 184 303. 

 

2. Why we process Your personal data 

We process your personal data to fulfill our contract with you and to meet our tax obligations. 

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

 

3. What personal data we process 

We process the following personal data about you: 

  1. First and last name 
  2. Position 
  3. Email address 
  4. Phone number 
  5. Fax number 
  6. Business address 
  7. Company name under which you operate 
  8. Tax Identification Number (NIP) 
  9. Business Registration Number (REGON) 
  10. National Court Register Number (KRS) 
  11. History of transactions with you 
  12. History of correspondence with you (including emails) 

 

4. Whom we disclose Your personal data to 

We disclose your personal data to state administration authorities, as required by law (such as tax authorities). 

Your personal data is processed in an IT system that is partially located in a so-called cloud service provided by bitebyte.pl Maciej Kupiec (NIP: 6292368157). This same entity manages the IT services for our company and may have access to some of your personal data. This does not involve the transfer of your personal data to third countries. 

Additionally, we use a cloud service provided by Microsoft as part of Office 365 tools. We also utilize Skype, which is provided by Microsoft. This does not involve the transfer of your personal data to third countries. 

We also use software dedicated to HR companies, provided by an international entity. Your personal data processed within this software will be transferred to third countries. This transfer is based on legal instruments provided for under the GDPR and is completely secure. 

Your personal data will also be disclosed to WL Finanse sp. z o.o., based in Kraków, which handles our accounting. In the appropriate agreement with this entity, we have ensured that your data entrusted to them will not be transferred to third countries. 

 

5. How long we will process Your personal data 

We will process your personal data for as long as necessary for tax purposes, which—according to currently applicable Polish law—means for 5 tax years. As you may know, five tax years can translate to six or sometimes nearly seven calendar years. 

If we are in a continuous collaboration with you (e.g., based on a framework agreement), we will process certain necessary data throughout the entire period of our cooperation. 

 

6. How we enable You to exercise Your rights 

We strive to ensure your satisfaction in our collaboration. However, you have various rights that allow you to influence how we process your personal data, and in some cases, to stop such processing. These rights include: 

  • the right to access personal data (as regulated in Article 15 of the GDPR). 

 

Article 15 

Right of access for the data subject 

  1. A data subject has the right to obtain confirmation from the administrator as to whether personal data concerning them is being processed, and if that is the case, they have the right to access such data and the following information:
  2. a) the purposes of the processing;
  3. b) the categories of personal data concerned;
  4. c) information about the recipients or categories of recipients to whom the personal data has been or will be disclosed, in particular, recipients in third countries or international organizations;
  5. d) where possible, the planned duration of the storage of personal data, or if not possible, the criteria used to determine that duration;
  6. e) information on the right to request from the administrator the rectification, erasure, or restriction of the processing of personal data concerning the data subject, as well as to object to such processing;
  7. f) information on the right to lodge a complaint with a supervisory authority;
  8. g) if the personal data has not been collected from the data subject, any available information as to their source;
  9. h) information on automated decision-making, including profiling, as referred to in Article 22(1) and (4), and at least in those cases, significant information on the logic involved in the decision-making, as well as the significance and the anticipated consequences of such processing for the data subject.
  10. If the personal data is transferred to a third country or an international organization, the data subject has the right to be informed about the appropriate safeguards referred to in Article 46 related to the transfer.
  11. The administrator shall provide the data subject with a copy of the personal data undergoing processing. For any further copies requested by the data subject, the administrator may charge a reasonable fee based on administrative costs. If the data subject requests a copy electronically and does not specify otherwise, the information shall be provided by commonly used electronic means.
  12. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.

 

  • right to rectification of data (regulated under Article 16 of the GDPR) 

 

Article 16 

Right to rectification of data 

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

 

  • right to erasure of data (regulated under Article 17 of the GDPR) 

 

Article 17 

Right to erasure (“right to be forgotten”) 

  1. The data subject has the right to obtain from the controller the erasure of personal data concerning them without undue delay, and the controller has the obligation to erase personal data without undue delay where one of the following grounds applies: 
  2. a) the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed;
  3. b) the data subject withdraws consent on which the processing is based according to Article 6(1)(a) or Article 9(2)(a), and where there is no other legal ground for the processing;
  4. 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);
  5. d) the personal data have been unlawfully processed;
  6. e) the personal data must be erased to comply with a legal obligation under Union or Member State law to which the controller is subject;
  7. f) the personal data have been collected in connection with 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 processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copies or replications of, those personal data. 

Paragraphs 1 and 2 do not apply to the extent that processing is necessary:  

  1. a) for exercising the right of freedom of expression and information;
  2. 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;
  3. c) for reasons of public interest in the area of public health in accordance with Article 9(2)(h) and (i) and Article 9(3);
  4. d) for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes in accordance with Article 89(1) to the extent that the right referred to in paragraph 1 is likely to render impossible or seriously impair the achievement of the objectives of that processing; or 
  5. e) for the establishment, exercise, or defense of legal claims.

 

  • right to restriction of processing (regulated under Article 18 of the GDPR) 

 

Article 18 

Right to restriction of processing 

  1. The data subject has the right to obtain from the controller restriction of processing where one of the following applies: 
  2. 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;
  3. b) the processing is unlawful, and the data subject opposes the erasure of the personal data and requests the restriction of their use instead;
  4. 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 defense of legal claims;
  5. d) the data subject has objected to processing pursuant to Article 21(1) pending the verification of whether the legitimate grounds of the controller override those of the data subject.
  6. 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 defense 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.
  7. The controller shall inform the data subject who has obtained restriction of processing under paragraph 1 before the restriction is lifted.

 

  • right to object to processing (regulated under Article 21 of the GDPR) 

 

Article 21 

Right to object 

  1. The data subject shall have the right to object, on grounds relating to their particular situation, at any time to the processing of personal data concerning them which is based on Article 6(1)(e) or (f), 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 defense of legal claims.
  2. 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 them for such marketing, which includes profiling to the extent that it is related to such direct marketing.
  3. If the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
  4. The right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject at the latest at the time of the first communication with the data subject and shall be presented clearly and separately from any other information.
  5. In the context of the use of information society services and notwithstanding Directive 2002/58/EC, the data subject may exercise their right to object by automated means using technical specifications.
  6. 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 their particular situation, shall have the right to object to processing of personal data concerning them, unless the processing is necessary for the performance of a task carried out for reasons of public interest.

 

  • right to data portability (regulated under Article 20 of the GDPR) 

 

Article 20 

Right to data portability 

  1. The data subject has the right to receive the personal data concerning them, which they have provided to a controller, in a structured, commonly used, and machine-readable format, and has the right to transmit those data to another controller without hindrance from the controller to whom the personal data have been provided, where: 
  2. a) the processing is based on consent pursuant to Article 6(1)(a) or Article 9(2)(a) or on a contract pursuant to Article 6(1)(b); and 
  3. b) the processing is carried out by automated means.
  4. When exercising their right to data portability as referred to in paragraph 1, the data subject has the right to have the personal data transmitted directly from one controller to another, where technically feasible.
  5. Exercising the right referred to in paragraph 1 of this Article does not prejudice Article 17. This 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.
  6. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.

 

7. Complaint to the supervisory authority
According to Article 77 of the GDPR, you have the right to lodge a complaint with a supervisory authority, particularly in the member state of your habitual residence, your place of work, or the location of the alleged infringement, if you believe that the processing of personal data concerning you infringes the provisions of the GDPR.

 

8. Is providing data necessary for entering into a contract with us?
We collect your personal data to the extent necessary to enter into and fulfill a contract. Some data is also necessary for us to comply with legal obligations (tax regulations, accounting regulations). Failure to provide personal data may unfortunately prevent the conclusion and performance of the contract.

 

9. Where we obtain Your personal data
We obtain your personal data solely from you.

 

10. Automated processing and profiling
We do not process your data in an automated manner, and we do not engage in profiling as understood by the GDPR.