1.What is personal data and what does processing mean?
Personal data means information about an identified or identifiable natural person. The processing of personal data is basically any activity on personal data, regardless of whether it is performed in an automated manner or not, e.g. collecting, storing, recording, organizing, modifying, viewing, using, sharing, limiting, deleting or destroying. SYSTEM 3E processes personal data for various purposes, and depending on the purpose, different collection methods, legal grounds for processing, use, disclosure and storage periods may apply.
SYSTEM 3E S.A. (Joint Stock Company) with its registered office in Warsaw at Rondo Organizacji Narodów Zjednoczonych 1, 00-124 Warszawa, entered into the Register of Companies of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Department of the National Court Register under the number KRS (National Court Register) number 0000687344, NIP (Tax Identification) number 5223096436, REGON (Statistical) number 367862355.
3. Purposes and legal basis for processing personal data
Our goal is to maintain transparency regarding the methods and legal grounds for processing personal data, as well as the purposes for which SYSTEM 3E processes personal data. We make every effort to indicate the necessary information in this regard to each person whose personal data we process as a data controller. Below we present the legal grounds for processing and categories of operations carried out in the field of data processing together with their description.
We process personal data obtained from customers, potential customers, suppliers, collaborators or potential collaborators or other third parties as well as natural persons who are their representatives or cooperating with us on their behalf in the scope necessary to provide services related to the broadly understood implementation of construction projects (consulting, training, design, implementation of construction services, development cooperation), as well as processes preceding the implementation of construction projects, i.e. communication and marketing of our services. This scope includes, but is not limited to:
1) Processing of personal data of visitors to websites maintained by SYSTEM 3E;
2) Processing of personal data of persons contacting SYSTEM 3E in order to obtain information about the offer or share comments regarding SYSTEM 3E services or products, as well as contacting in order to conclude a contract with SYSTEM 3E.
Legal grounds for processing
The processing of personal data of natural persons who are our clients/associates is based on:
– legitimate interest of SYSTEM 3E as a data controller (e.g. in the field of database creation, analytical and profiling activities, including activities regarding the analysis of product use, direct marketing of own products, securing documentation for the purposes of defense against possible claims or for the purpose of pursuing claims)
– consent (including in particular consent to e-mail marketing or telemarketing)
– performance of the concluded contract
– Obligations arising from law (e.g. tax law or accounting regulations).
The processing of personal data of natural persons who are potential clients/potential collaborators is based on:
– legitimate interest of SYSTEM 3E as a data controller (e.g. in database creation, direct marketing of own products)
– consent (including in particular consent to e-mail marketing or telemarketing)
4. Voluntary choice
5. Automatic collection of information
It should be noted that the information collected in this way is not always personal data as in some cases it allows us to identify a specific user, but this can happen, for example, when it is possible to associate the IP address or location information with a specific user’s email address.
An IP address is an individual number assigned to a user’s computer during an Internet connection that enables communication between the given computer and the server. The IP addresses of users visiting the site may be recorded, inter alia, to ensure the security of the IT system and for diagnostic purposes. This information may also be used in aggregate form to analyze Internet trends and evaluate the operation of the website.
SYSTEM 3E may collect and use data about the geographical location of a user’s computer or mobile device. Location data are collected to provide users with information about services that we think may be of interest to them because of their location. They are also collected to improve our products and services based on geolocation solutions.
Social media widgets and applications
There may be functions on SYSTEM 3E websites that allow you to share content using third-party social media applications (Facebook, Twitter). All personal data provided by users through such social media applications can be collected and used by other users of the above social media applications, and the interactions carried out through them are subject to the privacy policies of the companies that are the providers of the applications. We have no influence and take no responsibility for the above companies and their use of user data.
6. Time of data processing
The time for which we can process personal data depends on the legal basis which is the legal condition for the processing of personal data:
1) in the event that SYSTEM 3E processes personal data on the basis of consent, the processing period lasts until the consent is withdrawn by the user;
2) in the event that SYSTEM 3E processes personal data on the basis of the legitimate interest of the data controller, the processing period lasts until the above-mentioned interest (e.g. limitation period for civil law claims) or until such time as the data subject opposes further processing in situations where such an objection is in accordance with the law;
3) the case when SYSTEM 3E processes personal data because it is necessary due to applicable laws, the periods of data processing for this purpose are determined by these provisions;
4) in the absence of specific legal or contractual requirements, the basic period of data storage in the case of records and other documentary evidence drawn up during the performance of the contract is no longer than 10 years.
7. Sharing data with third parties
We only transfer personal data to others when permitted by law. In this case, in an appropriate contract with a third party, we provide security provisions and mechanisms to protect data and maintain the highest standards in the field of data protection, confidentiality and security. Agreements of this type are agreements for entrusting the processing of personal data and specify how and to what extent the entity entrusted with the processing of certain categories of personal data by SYSTEM 3E processes these data. However, we point out that the recipients of personal data that DOM 3E processes as the personal data controller can be:
1) entities processing personal data under contracts entrusting the processing of personal data;
2) hosting service providers;
3) providers of accounting and computer software services;
4) entities implementing marketing or sales campaigns;
5) contractors and subcontractors cooperating with SYSTEM 3E as part of the core business;
6) entities providing survey research services;
7) auditors and statutory auditors, legal advisors, tax advisors;
8) debt collection companies;
At the same time, we inform you that we transfer personal data only to the extent that it is actually necessary to achieve a given purpose and in accordance with the mandatory provisions of law.
8. Transfer of personal data of non-EU/EEA countries
Personal data are processed only within the European Union or the European Economic Area.
9. Rights apply to data subjects and the manner of their implementation.
Natural persons have specific rights regarding their personal data, and SYSTEM 3E as the data controller is responsible for the implementation of these rights in accordance with applicable law. For all questions and requests regarding the scope and exercise of rights, as well as to contact us precisely in order to use specific rights in the field of personal data protection please contact us at the email address: email@example.com
We reserve the right to exercise the following rights after having successfully verified the identity of the person applying for the activity.
Access to personal data
Individuals have the right to access data that we store as a data controller. This right can be exercised by sending an email to: :firstname.lastname@example.org
Change of personal data
Changes, including the update of your personal data, which are processed by SYSTEM 3E, can be made by sending an email to the following email address: email@example.com or, if applicable, contacting us via the appropriate registration page or changing personal data stored in relevant applications in which registration has been made.
Withdrawal of consent
In the case of processing personal data on the basis of consent, natural persons have the right to withdraw this consent at any time. We inform you about it almost at any time when collecting consents and allow you to withdraw your consent as easily as it was given. In the absence of other information, i.e. if we have not provided another address or contact number to withdraw consent, please send us an email to firstname.lastname@example.org
The right to limit processing or object to the processing of personal data
Natural persons have the right to limit the processing or object to the processing of their personal data at any time, due to their special situation, unless the processing is required by law.
An individual may object to the processing of their personal data when:
– the processing of personal data is based on a legitimate interest or for statistical purposes, and the opposition is justified by the particular situation in which they find themselves,
– personal data are processed for the purposes of direct marketing, including being profiled for this purpose.
You can exercise your right of objection from May 25th, 2018.
In turn, with regard to the request for limitation of data processing, we inform you that it applies, e.g. when a person notices that their data are incorrect. Then it may request that your data be restricted for a period of time that allows us to check that the data is correct.
The right to request deletion of data and the right to transfer data
If you wish to exercise these rights, please send an email to: email@example.com
The right to delete data can be used, e.g. when the data of a natural person are no longer necessary for the purposes for which they were collected by SYSTEM 3E or when a natural person withdraws their consent for data processing by SYSTEM 3E. In addition, if a natural person objects to the processing of their data or if their data will be processed unlawfully. The data should also be deleted in order to fulfill the obligation arising from the provision of law.
In turn, the right to transfer data is granted when the processing of a person’s data takes place on the basis of the consent of a natural person or a contract concluded with them and when the processing is carried out automatically.
All other questions, doubts and complaints
Last updated: February 21st, 2020