Privacy Policy

1. General

NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k. (hereinafter referred to as NETFORMERS) regards personal data protection very seriously. We make all efforts to ensure that your personal data are processed in compliance with the applicable law.

2. How do we protect your personal data?

We are committed to the security of the personal data we process. That is why we design our services with your security in mind. We have implemented suitable procedures, policies and safeguards. We conduct training in data protection, confidentiality and security. We conduct regular audits of the implemented security measures to determine if they are adequate to the security of the personal data we process.

3. Are personal data transferred outside the European Economic Area (EEA)?

NETFORMERS does not transfer the personal data it acquires outside the EEA. However, during the term of the contract, NETFORMERS may decide to transfer data outside the EEA – only to the extent permitted by the law and after informing you about the intent to transfer your data outside the EEA.

4. Purposes of using your data

We process your personal data for the following purposes:

• entering into and performing the contract between you and NETFORMERS, including providing correct service quality;
• performing the legal duties of NETFORMERS, e.g.:
• issuing and keeping invoices and accounting documents;
• replying to complaints within the periods prescribed by the law;
• considering your requests, complaints and enquiries;
• detecting and preventing fraud;
• establishing, exercising or defending claims, which includes, in particular, the assignment of receivables by NETFORMERS,
• verifying financial credibility when entering into, prolonging or extending the scope of the contract and considering related complaints,
• after obtaining your consent – for marketing purposes – for NETFORMERS to organise and conduct various types of events and send the newsletter;
• sending you best wishes;
• using our website;
• conducting recruitment;
• contacting you if required due to our legitimate interest.

5. How long do we keep your personal data?

When you provide us with your personal data, we inform you how long we are going to keep them.

We keep your data for a specific period, depending on their purpose:

• duration of the contract and then for the period of limitation of the claim arising from the contract, and if NETFORMERS pursues claims or notifies relevant authorities – for the duration of such proceedings;
• period required to perform relevant duties, e.g. issue the invoice;
• period during which we are required to keep the data by the law (e.g. tax law);
• period required to consider your requests, complaints and enquiries;
• period during which NETFORMERS may suffer legal consequences of defaulting on an obligation, e.g. be charged with a fine by state authorities;
• period required to asses financial credibility;
• period during which we have your consent, i.e. until you withdraw it;
• duration of recruitment, and if you also consent to the use of your personal data for future recruitment processes – until you withdraw this consent;
• until you object, if the legal basis for processing is a legitimate interest of the controller.

6. Our principles

We make every effort to protect the interests of data subjects; in particular, we try to ensure that the data collected by NETFORMERS are:

• processed lawfully, fairly and in a transparent manner,
• collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with these purposes;
• adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
• accurate and, where necessary, kept up to date;
• processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures;
• kept in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed.

7. When do we provide your personal data to other entities?

We never sell the personal data we keep.

We provide your personal data to other recipients:

• when we use the services of entities that cooperate with us or services of our subcontractors;
  * In order for us to be able to provide you with the highest quality of service, we may use services of other companies, entrusting them with the processing of your personal data on our behalf. We also make efforts to ensure that your personal data are treated as if they were processed directly by us. We carefully pick the external entities we cooperate with, and we only share the personal data necessary in order for such entities to perform their services. We make sure that your personal data are safe.

• when we are obliged by the law to provide your data to other organisations;
• when necessary in order to protect the vital interests of the data subject or of another natural person.

8. What kind of rights do you have?

You have full control over your personal data.
You have the right to:

• access the data we keep as the data controller;
• obtain a copy of the personal data undergoing processing;
• rectification of your personal data;
• withdraw your consent to data processing if the basis for data processing is your consent;
• object to data processing due if we process the data based on our legitimate interest;
• restriction of processing of your personal data;
• data portability;
• erasure of your personal data where we are not obliged by the law to process them;
• lodge a complaint with the President of the Personal Data Protection Office (UODO) (to the address of the Personal Data Protection Office: ul. Stawki 2, 00-193 Warszawa).

9. Cookies on the NETFORMERS website

Cookies are small pieces of text information placed on your device in order to:

• implement the service provided by the website and ensure maximum comfort to website users (e.g. saving and remembering your settings and preferences, including profiling for Google AdWords, entering and recording specific information, automatic log-in);
• create counters and statistics, monitor activity and assess use of the website by the visitors;
• create reports on traffic on the websites for the operators of the websites and provide other services to operators of the websites in relation to the traffic on the websites and Internet use;
• log in and establishing the session on the website.

This website uses Google Analytics, a service provided by Google, Inc. (hereinafter referred to as “Google”) to analyse and monitor website activity/traffic. Google Analytics uses cookies. The data generated by the cookies regarding your use of the website (including your IP address) will be provided to Google and kept by Google on its servers. Information about protection of the data processed by Google can be found at: http://www.google.com/analytics/learn/privacy.html.

Google may also transfer this information to third parties if it is obliged to do so pursuant to the applicable law or in the situation where such parties process this information on behalf of Google. Google will not associate your IP address with any other data it has.

By using this website, you consent to the use of cookies, including the use of cookies for the purposes of “Google Analytics”. By using this website, you consent to the processing of your data in the cookies by Google in the manner and for the purpose specified above.

You may choose to disable cookies by selecting suitable browser settings; however, this may disable some of the functions of the website. In particular, if you disable cookies, you will be unable to log in to the website, and services that require being logged in and having an established session will not be provided by NETFORMERS.

For more information, including information on how to disable cookies for different browsers, go to: https://en.wikipedia.org/wiki/HTTP_cookie.

10. How to contact NETFORMERS

If you have any other questions or comments regarding this policy, contact us:

• by mail: ul. Mińska 75, 03-828 Warszawa;
• by e-mail: rodo@netformers.pl.

11. Privacy notice for employees or associates of business partners – contact persons

NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warszawa is the controller of your personal data.

You may contact us as follows:

• by mail: ul. Mińska 75, 03-828 Warszawa;
• by e-mail: rodo@netformers.pl.

We will process your personal data because you are a contact person for NETFORMERS at our business partner or potential business partner. Consequently, we will process your data to:

• contact you regarding routine matters, including the performance of contracts between us and your employer / entity you represent, submit proposals, receive orders and reply to enquiries. The legal basis for data processing is our legitimate interest, i.e. to be able to routinely contact our business partners (i.e. their employees/associates);
• invite you to participate in our events, provide other information about our activities and available forms of cooperation. The legal basis for data processing is our legitimate interest, i.e. to maintain relations with employees and associates of our business partners;
• defend against claims or seek claims (if any) in relation to the contract with the entity you work for or represent, i.e. our business partner – in case of a dispute regarding the contract. The legal basis for data processing is our legitimate interest, i.e. to be able to defend against claims or seek claims.

We have received your data directly from you or from your employer / entity you represent.

From your employer / entity you represent, we receive data such as your first name and last name, company phone number and e-mail address, workplace, position or information about the matters you deal with.

We will process your personal data throughout the term of the contract signed with us by your employer / entity you represent and throughout the limitation period for claims under the contract.

Your personal data may be transferred to our subcontractors that are going to perform services for your employer / entity you represent and to law firms we work with.

You have the following rights relating to the processing of your personal data:

• right to access your data and obtain their copy, right to rectify (correct) your data, right to erasure of your personal data, right to restriction of processing, right to object to processing of your personal data due to your particular situation as well as the right to data portability; you may send requests in this regard to the contact address of the data controller indicated above;
• right to lodge a complaint with the President of the Personal Data Protection Office (UODO) (to the address of the Personal Data Protection Office: ul. Stawki 2, 00-193 Warszawa).

The data controller does not intend to transfer your personal data to a third country or international organisation. However, such a situation may occur. Your data may be transferred to a third country if they are processed using cloud tools whose disk space is located on servers located outside the EEA or if the administrator of the e-mail account you use to in your contacts with the Controller uses servers physically located outside the EEA.

The data you provide will not be used for automated decision-making, including profiling.

12. Privacy notice for other persons contacting NETFORMERS (by phone or e-mail or via the contact form) and persons contacted by NETFORMERS (by phone or e-mail)

NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warszawa, ul. Mińska 75, 03-828, is the controller of your personal data.

You may contact us as follows:

• by mail: ul. Mińska 75, 03-828 Warszawa;
• by e-mail to: rodo@netformers.pl.

We will process your personal data to process the enquiry based on our legitimate interest in accordance with Article 6(1)(f) of the GDPR[1] and for marketing purposes pursuant to your consent in accordance with Article 6(1)(a) of the GDPR.

Your personal data may be provided to entities we cooperate with and to our subcontractors.

We will process your personal data throughout the exchange of correspondence and for one year afterwards. After this period, we may contact you to inquire about the possibility of continued processing of your data.

Under the GDPR, you have the following rights:

• right to access your data and receive their copy;
• right to rectify (correct) your data;
• right to erasure of your personal data;
• right to restriction of data processing
• right to object to processing of your data due to your particular situation;
• right to data portability;

* Requests in this regard may be sent to the contact address of the data controller indicated above.

• right to lodge a complaint with the President of the Personal Data Protection Office (UODO) (to the address of the Personal Data Protection Office: ul. Stawki 2, 00-193 Warszawa).

Regarding the data processed for marketing purposes, you may withdraw your consent at any time by contacting us at: rodo@netformers.pl. The withdrawal of consent will not affect the lawfulness of processing based on the consent before its withdrawal.

The data controller does not intend to transfer your personal data to a third country or international organisation. However, such a situation may occur. Your data may be transferred to a third country if they are processed using cloud tools whose disk space is located on servers located outside the EEA or if the administrator of the e-mail account you use to in your contacts with the Controller uses servers physically located outside the EEA.

The data you provide will not be used for automated decision-making, including profiling.

13. Privacy notice for newsletter subscribers

NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warszawa, ul. Mińska 75, 03-828, is the controller of your personal data included in the request.

You may contact us as follows:

• by mail: ul. Mińska 75, 03-828 Warszawa;
• by e-mail to: rodo@netformers.pl.

Your personal data are processed in order to deliver the newsletter, pursuant to Article 6(1)(a) of the GDPR.

Your personal data may be provided to entities we cooperate with and to our subcontractors.

The data controller does not intend to transfer your personal data to a third country or international organisation. However, such a situation may occur. Your data may be transferred to a third country if they are processed using cloud tools whose disk space is located on servers located outside the EEA or if the administrator of the e-mail account you use to in your contacts with the Controller uses servers physically located outside the EEA.

Your personal data are kept for 2 years. After this period, we may contact you to inquire about the possibility of continued processing of your data.

You have the following rights relating to the processing of your personal data:

• right to access your data and receive their copy;
• right to rectify (correct) your data;
• right to erasure of your personal data;
• right to restriction of data processing
• right to data portability;

* Requests in this regard may be sent to the contact address of the data controller indicated above.

• right to lodge a complaint with the President of the Personal Data Protection Office (UODO) (to the address of the Personal Data Protection Office: ul. Stawki 2, 00-193 Warszawa).

You may withdraw your consent at any time by contacting us at: rodo@netformers.pl. The withdrawal of consent will not affect the lawfulness of processing based on the consent before its withdrawal.

Providing the data is voluntary, not statutorily required; however, if you do not provide them, you will be unable to order the newsletter.

Other information: the data you provide will not be used for automated decision-making, including profiling.

14. Applicants

NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warszawa, ul. Mińska 75, 03-828, is the controller of your personal data.

You may contact us as follows:

• by mail: ul. Mińska 75, 03-828 Warszawa;
• by e-mail to: rodo@netformers.pl.

Data processing purpose: recruitment for a job opening at NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k.

The legal basis for the processing of your personal data is as follows:

• Provision of the law (Article 22[1] § 1 of the Labour Code) – regarding the following data:
• first name and last name;
• parents’ names;
• date of birth;
• place of residence (mailing address);
• education;
• record of employment.
• Your consent to the processing of your data provided in the CV and in the cover letter, if you provide us with information other than the above-mentioned information stipulated in Article 22[1] § 1 of the Labour Code.
• Our legitimate interest – regarding the data acquired during the job interview and results of employment tests. We have a legitimate interest to verify your abilities and skills – we need this information to determine if you are the right person for the position we recruit for.

Your personal data are not provided to other recipients.

The data controller does not intend to transfer your personal data to a third country or international organisation. However, such a situation may occur. Your data may be transferred to a third country if they are processed using cloud tools whose disk space is located on servers located outside the EEA or if the administrator of the e-mail account you use to in your contacts with the Controller uses servers physically located outside the EEA.

We will keep your personal data until the end of recruitment for the position you apply for. However, if you have given a separate consent for data processing for purpose of future recruitment processes, we will keep your data until you withdraw your consent to their processing, but in any case not longer than for 5 years from the time they were collected.

Under the GDPR, you have the following rights:

• right to access your data and receive their copy;
• right to rectify (correct) your data;
• right to erasure of your personal data;
• right to restriction of data processing
• right to object to processing of your data due to your particular situation;
• right to data portability;

* Requests in this regard may be sent to the contact address of the data controller indicated above.

• right to lodge a complaint with the President of the Personal Data Protection Office (UODO) (to the address of the Personal Data Protection Office: ul. Stawki 2, 00-193 Warszawa).

You may withdraw your consent at any time by contacting us at: rodo@netformers.pl. The withdrawal of consent will not affect the lawfulness of processing based on the consent before its withdrawal.

Consenting to data processing is voluntary, but it is required in order to participate in the recruitment process. Without your consent, we will not be able to consider your application documents.

Other information: the data you provide will not be used for automated decision-making, including profiling.

15. Privacy notice to persons affiliated with NETFORMERS

NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warszawa, ul. Mińska 75, 03-828, is the controller of your personal data.

You may contact us as follows:

• by mail: ul. Mińska 75, 03-828 Warszawa;
• by e-mail to: rodo@netformers.pl.

Your personal data will be processed in order to send you best wishes.

The legal basis for personal data processing is the legitimate interest of the controller (Article 6(1)(f) of the GDPR), i.e. to maintain good relations with persons affiliated with the Company.

Your data may be provided to the following recipients or categories of recipients of personal data, i.e. postal operators, courier companies, security companies.

The data controller does not intend to transfer your personal data to a third country or international organisation. However, such a situation may occur. Your data may be transferred to a third country if they are processed using cloud tools whose disk space is located on servers located outside the EEA or if the administrator of the e-mail account you use to in your contacts with the Controller uses servers physically located outside the EEA.

Under the GDPR, you have the following rights:

• right to access your data and receive their copy;
• right to rectify (correct) your data;
• right to erasure of your personal data;
• right to restriction of data processing
• right to object to processing of your data due to your particular situation;
• right to data portability;

* Requests in this regard may be sent to the contact address of the data controller indicated above.

• right to lodge a complaint with the President of the Personal Data Protection Office (UODO) (to the address of the Personal Data Protection Office: ul. Stawki 2, 00-193 Warszawa).

Your personal data will be kept for the period required to fulfil the purpose for which they have been collected, until you object to their processing.

Providing your personal data is voluntary, but such data will be necessary to send you best wishes.

Other information: the data you provide will not be used for automated decision-making, including profiling.

16. Privacy notice for persons subscribing for the webinars organised by NETFORMERS

NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warszawa, ul. Mińska 75, 03-828, is the controller of your personal data.

You may contact us as follows:

• by mail: ul. Mińska 75, 03-828 Warszawa;
• by e-mail to: rodo@netformers.pl.

Your personal data will be processed in order to organise and conduct the webinar to which you have subscribed by filling in the application form. The legal basis for data processing is our legitimate interest, i.e. to efficiently organise and conduct the particular webinar.

Your personal data may be provided to entities we cooperate with and to our subcontractors.

The data controller does not intend to transfer your personal data to a third country or international organisation. However, such a situation may occur. Your data may be transferred to a third country if they are processed using cloud tools whose disk space is located on servers located outside the EEA or if the administrator of the e-mail account you use to in your contacts with the Controller uses servers physically located outside the EEA.

Your personal data are kept for 2 years after the end of the webinar. After this period, we may contact you to inquire about the possibility of continued processing of your data.

Under the GDPR, you have the following rights:

• right to access your data and receive their copy;
• right to rectify (correct) your data;
• right to erasure of your personal data;
• right to restriction of data processing
• right to object to processing of your data due to your particular situation;
• right to data portability;

* Requests in this regard may be sent to the contact address of the data controller indicated above.

• right to lodge a complaint with the President of the Personal Data Protection Office (UODO) (to the address of the Personal Data Protection Office: ul. Stawki 2, 00-193 Warszawa).

Providing your personal data is voluntary, but such data will be necessary to invite you to our webinar.

Your data will be processed automatically, including processing in the form of profiling. Automated decision-making will be done by categorising the people subscribing to the webinars depending on their actions. This processing will enable you to obtain information related to your interests.

¹ Of 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 repealing Directive 95/46/EC (GDPR) and the actions taken.

17. Privacy notice for persons taking part in contests organised by NETFORMERS

NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warszawa, ul. Mińska 75, 03-828, is the controller of your personal data.

You may contact us as follows:

• by mail: ul. Mińska 75, 03-828 Warszawa;
• by e-mail to: rodo@netformers.pl.

Your personal data will be processed in order to organise and conduct the contest/quiz to which you have subscribed by filling in the application form. The legal basis for data processing is our legitimate interest, i.e. to efficiently organise and conduct the particular contest/quiz.

Your personal data may be provided to entities we cooperate with and to our subcontractors.

The data controller does not intend to transfer your personal data to a third country or international organisation. However, such a situation may occur. Your data may be transferred to a third country if they are processed using cloud tools whose disk space is located on servers located outside the EEA or if the administrator of the e-mail account you use to in your contacts with the Controller uses servers physically located outside the EEA.

Your personal data are kept for 2 years after the end of the contest/quiz. After this period, we may contact you to inquire about the possibility of continued processing of your data.

Under the GDPR, you have the following rights:

• right to access your data and receive their copy;
• right to rectify (correct) your data;
• right to erasure of your personal data;
• right to restriction of data processing
• right to object to processing of your data due to your particular situation;
• right to data portability;

* Requests in this regard may be sent to the contact address of the data controller indicated above.

• right to lodge a complaint with the President of the Personal Data Protection Office (UODO) (to the address of the Personal Data Protection Office: ul. Stawki 2, 00-193 Warszawa).

Providing your personal data is voluntary, but such data will be necessary to invite you to our webinar.

Your data will be processed automatically, including processing in the form of profiling. Automated decision-making will be done by categorising the people subscribing to the webinars depending on their actions. This processing will enable you to obtain information related to your interests.

¹ Of 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 repealing Directive 95/46/EC (GDPR) and the actions taken.

18. Privacy notice for business partners and employees or associates of business partners using eu

NETFORMERS spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Warszawa is the controller of your personal data.

You may contact us as follows:

• by mail: ul. Mińska 75, 03-828 Warszawa;
• by e-mail: rodo@netformers.pl.

We will process your personal data because you are a contact person for NETFORMERS at our business partner or potential business partner. Consequently, we will process your data to:

• contact you regarding routine matters, including the performance of contracts between us and your employer / entity you represent, submit proposals, receive orders and reply to enquiries. The legal basis for data processing is our legitimate interest, i.e. to be able to routinely contact our business partners (i.e. their employees/associates);
• invite you to participate in our events, provide other information about our activities and available forms of cooperation. The legal basis for data processing is our legitimate interest, i.e. to maintain relations with employees and associates of our business partners;
• defend against claims or seek claims (if any) in relation to the contract with the entity you work for or represent, i.e. our business partner – in case of a dispute regarding the contract. The legal basis for data processing is our legitimate interest, i.e. to be able to defend against claims or seek claims.

We have received your data directly from you or from your employer / entity you represent.

We will process your personal data throughout the term of the contract signed with us by your employer / entity you represent and throughout the limitation period for claims under the contract.

Your personal data may be transferred to our subcontractors that are going to perform services for your employer / entity you represent and to law firms we work with.

We will process your personal data to process the enquiry based on our legitimate interest in accordance with Article 6(1)(f) of the GDPR[1] and for marketing purposes pursuant to your consent in accordance with Article 6(1)(a) of the GDPR.

Under the GDPR, you have the following rights:

• right to access your data and receive their copy;
• right to rectify (correct) your data;
• right to erasure of your personal data;
• right to restriction of data processing
• right to object to processing of your data due to your particular situation;
• right to data portability;

* Requests in this regard may be sent to the contact address of the data controller indicated above.

• right to lodge a complaint with the President of the Personal Data Protection Office (UODO) (to the address of the Personal Data Protection Office: ul. Stawki 2, 00-193 Warszawa).

Regarding the data processed for marketing purposes, you may withdraw your consent at any time by contacting us at: rodo@netformers.pl. The withdrawal of consent will not affect the lawfulness of processing based on the consent before its withdrawal.

The data controller does not intend to transfer your personal data to a third country or international organisation. However, such a situation may occur. Your data may be transferred to a third country if they are processed using cloud tools whose disk space is located on servers located outside the EEA or if the administrator of the e-mail account you use to in your contacts with the Controller uses servers physically located outside the EEA.

The data you provide will not be used for automated decision-making, including profiling.

¹ Of 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 repealing Directive 95/46/EC (GDPR) and the actions taken