Privacy Policy

PRIVACY POLICY ON PERSONAL DATA AND COOKIES

§ 1
GENERAL PROVISIONS

1. This privacy policy fulfils the information obligation under Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and superseding Directive 95/46/EC (General Data Protection Regulation) (GDPR).
2. The privacy policy is addressed to the users of the website: www.swgk.pl and is informative, which means that it is not a source of obligations for the users of the website or the clients of SWGK.
3. The privacy policy primarily contains the principles and rules relating to the processing of personal data by the SWGK Group, including the legal grounds, legitimate purposes and scope of personal data processing and the rights of data subjects, as well as information on the use of cookies on the website: www.swgk.pl.
4. The data controller/processor will take special care to protect the interests of individuals whose personal data they collect and process, and in particular, will ensure that the data they collect are:

⎯ processed in accordance with the law,

⎯ collected for designated lawful purposes, not subjected to further processing in consistent with these purposes,

⎯ substantively correct, and appropriate to the purposes for which they are processed,

⎯ stored in a form which permits the identification of data subjects, no longer than is necessary to achieve the purpose of the processing; and

⎯ processed in a manner which ensures appropriate security of personal data, including protection against unauthorised or unlawful processing and accidental loss, destruction or damage, by             appropriate technical or organisational measures.

§ 2
PERSONAL DATA CONTROLLER

1. The controller of the personal data provided during the use of the service maintained under the name: www.swgk.pl is the company under the name: SWGK Centrum Spółka z ograniczoną odpowiedzialnością with its registered office in Poznań, address: ul. Wojskowa 4, 60-792 Poznań, entered in the register of entrepreneurs kept by the District Court Poznań – Nowe Miasto and Wilda in Poznań, VIII Economic Department of the National Court Register, under KRS number: 0000563325, with REGON number: 361789717 and NIP number: 7792432120, e-mail address: biuro@swgk.pl.
2. Data is processed in accordance with the currently applicable law; i.e. Regulation 2016/679 of the European Parliament and of the Council of the EU of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and superseding Directive 95/46/EC (hereinafter: GDPR), the Data Protection Act of 10 May 2018, as well as the Act of 18 July 2002 on the provision of electronic services.
3. This privacy policy includes the rules for the processing of data of users of the www.swgk.pl website, as well as data collected by contacting the Controller (via email or by telephone) or written correspondence, as well as those who like and/or follow the Controller’s fanpage on social media.

§ 3
 DEFINITIONS

1. The following definitions apply in this privacy policy:

a) Privacy Policy – this privacy policy for personal data and cookies.

b) Service – the website available at: www.swgk.pl, through which the user can: browse the content, contact the Data Administrator/Controller, solicit commercial and marketing information.

c) Data Controller – the entity that decides how and for what purposes the personal data is processed. In this policy, it is means: SWGK Centrum Spółka z ograniczoną odpowiedzialnością.

d) User – the natural person to whom the data relates, and who uses the services available through the website.

e) Personal data – means information about an identified or identifiable natural person, including the individual’s identification, address and contact details.

f) Third countries – countries outside the European Economic Area (EEA).

g) Cookies – computer data, in particular text files, which are stored in the Service User’s terminal equipment (computer, tablet, smartphone, etc.) and are intended for use of the service                        website  (so-called “cookies”).

§ 4

 PURPOSES FOR WHICH PERSONAL DATA ARE PROCESSED

1. The Data Controller/Processor shall only process personal data where this is permitted by the currently applicable law, for the purpose of:

a) taking action at the request of the data subject, including responding to questions asked via electronic means of communication or for the purpose of handling written correspondence, and                this processing is conducted in accordance with Article 6(1)(b)(GDPR),

b) sending solicited marketing information electronically to the email address provided by the user for this purpose, and this processing, as referred to in Article 6(1)(a)(GDPR), i.e. the                            consent  of the data subject,

c) analysing web traffic, ensuring security within the service and adapting content to users’ needs on the basis of the Controller’s legitimate interest (Article 6(1)(f))(GDPR),

d) marketing the Data Controller’s own products and services by traditional means (by post), under Article 6(1)(f) (GDPR), i.e. to pursue the legitimate interests of the Data Controller or the                  data subject,

e) the assertion of rights and claims by the Data Controller or the data subject on the basis of Article 6(1)(f)(GDPR), and is carried out for a legitimate purpose.

2. The provision of personal data is necessary in order to answer questions via the contact form. The provision of personal data is otherwise voluntary.
3. Failure to provide the required data makes it impossible to contact the data subject upon request/at their request.

§ 5
WAYS OF OBTAINING DATA

1. The user’s personal data is collected directly from the data subjects, i.e. by:

a) filling in a form with your contact details when submitting an enquiry via the contact form available on the Website,

b) filling in the newsletter subscription form,

c) direct contact with the Controller using the contact details available on the Website or at the company premises.

§ 6
SCOPE OF PERSONAL DATA PROCESSING

1. The scope of processed personal data has been limited to the minimum necessary to provide services in the following areas:

a) making an enquiry via the contact form or by using the contact details available on the Website: name, e-mail address, telephone number, any other data provided voluntarily by the data                    subject,

b) subscribing to the newsletter: name, e-mail address.

§ 7
 PERIOD FOR PROCESSING PERSONAL DATA

1. The period for processing personal data depends on the purpose for which the data was collected and is:

a) for the purpose of concluding and executing a sales agreement, including distance sales – for the period necessary to document the performed contract, including an issuance of a bill or                     invoice – 5 years, counting from the end of the calendar year in which the tax payment deadline expired, pursuant to Article 112 of the Act of 11 March 2004 on tax on goods and services, in               connection with Article 70 of the Act of 29 August 1997. – Tax Ordinance,

b) for the purpose of sending commercial information by electronic means (newsletter), until the data subject withdraws consent, without affecting the lawfulness of processing based on                       consent before its withdrawal.

c) for the period necessary to answer a question asked via a contact form or by telephone, but no longer than 6 months, unless the person decides to conclude a contract with the Data                              Controller,

d) for the purpose of asserting legal claims under Article 118 of the Act of 23 April 1964. – Civil Code. Unless a specific provision provides otherwise, the period of limitation is six years, and                    for  claims for periodic benefits and claims related to running a business  – three years.

§ 8
RECIPIENTS OF THE DATA

      1.Personal data of the user may be entrusted to other entities in order to provide services at the request of the Data Controller, in particular to third parties  in the following areas:

a) website hosting ,

b) the service and maintenance of IT systems in which the data are processed,

c) running office services.

2. Your personal data is not transferred to third countries or international organisations.
3. Personal data of the user will be processed by providers whose headquarters and/or servers are located in a third country, i.e. the United States of America (USA). The transfer of data to the USA is based on the European Commission’s decision dated 10 July 2023 stating an adequate level of protection of personal data provided by the so-called “EU-US Data Privacy Framework” for suppliers listed by the US Department of Commerce.

§ 9
DATA CONTROLLER FANPAGE ON SOCIAL MEDIA

1. The Controller also co-controls the data of its observers on social media – in particular, electronic means of communication on fanpages – Facebook, under the account name: SWGK (www.facebook.com/swgkbiurorachunkowe or LinkedIn, under the account name: SWGK (www.linkedin.com/company/swgk).
2. For the rest, the Data Controller of the users of these social networks is: Meta Platforms, Inc., (formerly: Facebook Inc., with its registered office at 1 Hacker Way, Menlo Park, CA 94025, USA) or LinkedIn Ireland Unlimited Company with its registered office at Wilton Place, Dublin 2, Ireland, and the processing of this data is carried out in accordance with the terms and conditions described in the regulations and privacy policies of the users of these websites, including at: www.facebook.com/privacy or www.pl.linkedin.com/legal/privacy-policy.
3. Personal data of the user who likes and/or follows the fanpage of the Controller on social media will be processed outside the European Economic Area in a so-called third country, in particular in the United States of America in connection with the use of IT solutions whose servers are located outside the European Economic Area.
4. Personal data of the user will be processed in a third country, i.e. the United States of America (USA). The transfer of data to the USA is based on the decision of the European Commission dated 10 July 2023 stating an adequate level of personal data protection provided by the so-called “EU-US Data Privacy Framework” with regard to providers listed by the US Department of Commerce, such as Meta Platforms, Inc., Menlo Park, California, USA.

§ 10
RIGHTS OF DATA SUBJECTS

1. Data subjects have the right to:

⎯ access the content of personal data, including the receipt of the first copy of the content of Personal Data free of charge,

⎯ correct data (data rectification – have inaccurate personal data rectified),

⎯ delete data, unless other legal provisions apply that oblige the Controller to archive data for a certain period of time,

⎯ data portability, provided that the basis for data processing is a contract or on the consent of the data subject, and the processing is carried out by automated means (automatically),

⎯ withdraw consent to the processing of personal data – if the basis for such processing was the consent of the data subject, without affecting the lawfulness of processing based on consent                    before its withdrawal.

⎯ object to the processing of personal data – on grounds relating to a specific situation regarding the processing of personal data based on Article 6(1)(e) or (f)(GDPR), as well as the right to                 restrict processing,

⎯ not to be subject to automated profiling if the Data Controller were to make decisions based solely on automated profiling and having legal consequences for the data subjects or similarly                   affecting them,

⎯ control the processing of the data and to be informed of who the Data Controller is, as well as to be informed of the purpose, scope and manner of the processing of personal data, the content           of the data, the source of the data, and the manner of disclosure, including the recipients or categories of recipients of the data.

2. In order to exercise your right to information, access to the content of your data, correction of your data, as well as other rights, you can contact the Data Controller.
3. The data subject also has the right to lodge a complaint with the Data Protection Authority (DPA) if the processing of data has infringed on the legal provisions of the General Data Protection Regulation (GDPR). The complaint may be lodged with a supervisory body electronically or by post to: Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw.

§ 11
COOKIES

The website allows the collection of information about the user through cookies and similar technologies, the use of which most often involves the installation of this tool on the user’s device. This information is used to remember the user’s decisions and configure user settings, maintain user sessions, remember passwords (with consent), collect information about the user’s device, and visit for security purposes, but also to analyse visits and adjust the content displayed.

§ 12
COOKIES

1. Cookies may be temporary, i.e. they are deleted when the browser is closed, or permanent.
2. Persistent cookies are also stored after the use of the pages of the website and allow the user’s settings to be remembered and the user’s interface to be personalised.
3. The service uses the following types of cookies:

a) indispensable – to enable the use of the services available on the website,

b) functional – to ‘remember’ the settings selected by the user, and personalize the website,

c) analytical – to make it possible to monitor user activity on the website.

4. The website uses cookies for the following purposes:

a) to adapt the content of the website to the individual preferences of the user and optimising the use of the websites (functional cookies – display tailored to your needs),

b) to conduct analyses and statistics which will provide information on how a user uses the pages on the website, which will make it possible to improve the structure and content,

c) for marketing and/or re-marketing, to include the targeting of dedicated content, in particular to users who have visited the website or fanpage of the Data Controller on Facebook or                           LinkedIn.

4. The data contained in the cookies will be archived and used for statistical analysis and evaluation of the global traffic of website users.

5. The data contained in the cookies are not combined with the personal data provided by the user when contacting the Data Controller.

§ 13
ACCEPTANCE OR CHANGE OF COOKIES SETTINGS

1. Upon accessing the website, the user may accept the use of cookies for the above purposes, reject them or agree only to selected cookies.
2. The user may also delete and/or disable cookies at any time in the web browser when using the website.
3. Deleting or disabling cookies may cause difficulties or limited functionality in some parts of the website (applies to functional cookies). This is because some cookies may be necessary for the proper functioning of the pages of the website and the display of content on a particular type of device.
4. In order to manage cookies, the user may also use the functions available in the browser he or she is currently using. Instructions for managing cookies are available on the websites of the browser providers, in particular:

a) Google Chrome – manual

b) Mozilla Firefox – manual

c) Apple Safari – manual

d) Microsoft Edge – manual

§ 14
FINAL PROVISION

In the event of any changes to the current Privacy Policy, in particular, if required by the technical solutions used or changes to the legal regulations in regard to users’ privacy, appropriate modifications to the above-mentioned provision will be introduced, which will be effective 14 days after their publication on the website.