GDPR REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL (EU) 2016/679 OF 27 APRIL 2016 ON THE PROTECTION OF INDIVIDUALS WITH REGARD TO THE PROCESSING OF PERSONAL DATA AND THE FREE MOVEMENT OF SUCH DATA AND REPEALING DIRECTIVE 95/46/EC (GENERAL DATA PROTECTION REGULATION)
Due to the legal changes related to the entry into force of the new regulation – GDPR – REGULATION OF THE EUROPEAN PARLIAMENT AND THE COUNCIL (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and the free movement of such data and repealing Directive 95/46/EC (General Data protection Regulation “GDPR”), we would like to inform you that:
the Data Controller, i.e. the entity that decides how your personal data will be used, is Pathways Polska Sp. z o.o. ul. Wyczółkowskiego 10/2, 30-118 Krakow, Tax Number NIP 6762101872
Contact in order to obtain information on personal data processing through Pathways Polska Sp. z o.o. ul. Wyczółkowskiego 10/2, 30-118 Krakow, Tax Number NIP 6762101872 T: 698 981 334 e:mail: firstname.lastname@example.org
We collect personal data when we recruit for specific training projects, during telephone or e-mail contact. The data is obtained directly from individuals who want to participate in our projects, as per their freely given consent, and from the employers. In the latter case, the consent is not required by the Data Privacy rules.
We process personal data for the following purposes:
- presenting a commercial offer,
- concluding and performing the agreement concluded with you,
- managing marketing activities with regards to you, including direct marketing of our own services;
- contacting you, including for the purposes related to the permitted marketing activities, using available communication channels, in particular – following your consent – by email and phone;
- debt recovery; managing court proceedings, arbitration and intermediary proceedings;
- conducting statistical analyses;
- storing data for archiving purposes, and guaranteeing accountability (proving that we have fulfilled the obligations imposed by the law).
As per your free and express consent, we process your personal data for the following purposes:
- saving the data in cookies, collecting the data from websites and mobile applications;
The consent to personal data processing may be freely modified (restricted) or withdrawn at any time in the same manner in which it was provided. We will process you personal data until the consent is withdrawn.
Is it mandatory to provide your personal data? We require that you provide the following data, so that we can conclude and perform an agreement concluded with you, in order to provide a service to you:
- email address, name, surname, contact phone number, contact details,
If you fail to provide your personal data for some reason, the unfortunately, as per the mandatory contract law (Civil Code, Code of Civil Procedure, Public Procurement Law etc.), we will not be able to conclude a legally effective agreement with you. If it is required by law, we can ask you to provide other data necessary in order to perform the agreement/provide a service. The need to provide other data follows from fiscal or accounting requirements. Except for these situations, providing your personal data is voluntary.
What rights do you have towards the Company with regard to data processing? We guarantee all your rights following from the General Data Protection Regulation will be observed, i.e.: the access right, the right to adjust and delete your data, restrict the processing, the right to transfer data, the right not to be subject to automated decision-making, including profiling, as well as the right to object against personal data processing. You can exercise these rights if:
- with regard to the request for data adjustment: you notice that your data is incorrect or incomplete;
- with regard to the request for data deletion: your data is no longer necessary for the purposes for which it was collected by the Company; you withdraw your consent to data processing; you object against data processing; your data is processed against the law; the data should be deleted in order to comply with an obligation following from legal provisions;
- with regard to the request for the restriction of data processing: you notice that your data is incorrect – you can demand that the data processing is restricted for a period that will make it possible for us to check the correctness of the data; your data is processed against the law, but you choose not to demand that the data be deleted; your data is no longer needed, but you may need it for defence or to assert a claim; or you offer an objection against data processing – until it is determined whether our legally justified basis takes precedence over the basis for objections;
- with regard to the request for data transfer: your data is processed as per your consent or an agreement concluded with you, and when the data processing is automatic.
You have a right to offer a complaint against the way we process your data to the supervisory authority, which is Inspector General for the Protection of Personal Data (address: Inspector General for the Protection of Personal Data, ul. Stawki 2, 00-193 Warsaw). As of 25.05.2018, it will be the President of the National Data protection Authority, at the same address.
When can you offer an objection against data processing? You have a right to offer an objection against data processing when:
- your personal data is processed as per a legitimate interest or for statistical purposes, and the objection is justified because of your specific situation.
- Your personal data is processed for the purposes of direct marketing, including profiling for this purpose.
You can exercise the right to object as of 25 May 2018.
Who do we share your personal data with? Your personal data will not be shared with other entities, except for legitimate situations, at the request of specific authorities.
How long do we keep your personal data? We keep your personal data for the effective period of the agreement concluded with you, and after the end of this period for the following purposes:
- asserting claims with regard to performing the agreement,
- fulfilling obligations as per the mandatory law, including in particular fiscal and accounting laws,
- statistical and archiving purposes,
- for a maximum of 10 years after the end of the performance of the agreement.
We keep your personal data for marketing purposes for the effective period of the agreement or until you offer an objection against data processing for this purpose, depending on which occurs earlier. In order to guarantee accountability, i.e. to prove we follow the mandatory law on data processing, we will keep the data for the period in which Pathways Polska Sp. z o.o.
is obliged to keep the data or documents including the data in order to document the fulfilment of legal requirements and to enable the control this fulfilment by public authorities.
Do we share your personal data with countries from outside the European Economic Area? No.
Do we process your data automatically (including profiling) in a way that affects your rights? Your personal data will be processed in an automated manner (including profiling), but this will have no legal effect on you and similarly it will not impact your situation to a significant extent. Data profiling by Pathways Polska Sp. z o.o.
includes processing your data (also in an automated manner) by using it to evaluate certain information about you, in particular for analysing or forecasting your personal preferences or interests.
THE COOKIES POLICY
The pathways.com.pl website owned by Pathways Polska Sp. z o.o. uses the so called cookies mechanism (text files saved and stored on the computer disk of the Website user, in order to retain the user’s navigation parameters and the logging status). The cookies mechanism does not purport to obtain any information about Website users and it is only meant to provide Pathways Polska Sp. z o.o. with statistical data about user traffic and about how Pathways Polska Sp. z o.o. websites are used.
Switching the cookies mechanism off by the user
The user may object to cookies being placed on his/her computer and may switch off cookies options in his/her browser at any time, which will not make it difficult to use the Website.
Excluding the liability as regards the cookies mechanism
Pathways Polska Sp. z o.o. shall not be liable for using the cookies mechanism on websites other than the Pathways Polska Sp. z o.o. website, available to the users via links placed on Pathways Polska Sp. z o.o. websites.
While using websites owned by Pathways Polska Sp. z o.o. you may be asked to provide some personal data by filling it a form or in another way. The data you will be asked for most often includes name and email address. We only require this data that is necessary for the operation of the website. Failure to provide the data will block the activity the data pertains to.
Non-Confidential Personal Data