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Privacy policy

PRIVACY POLICY

– PERSONAL DATA PROTECTION INFORMATION CLAUSES

1. GENERAL PROVISIONS

2. CONTACT DETAILS OF THE CONTROLLER AND DATA PROTECTION OFFICER

3. SCOPE OF PERSONAL DATA PROCESSED BY THE CONTROLLER

4. INFORMATION CLAUSE FOR JOB APPLICANTS

5. INFORMATION CLAUSE FOR TRAINEES

6. INFORMATION CLAUSE FOR CUSTOMERS - CONTRACTORS

7.INFORMATION CLAUSE FOR THE EMPLOYEES OF THE CUSTOMER/CONTRACTOR/MANAGEMENT BOARD/PARTNERS/PROXIES

8. INFORMATION CLAUSE FOR AGENTS

9. INFORMATION CLAUSE FOR PERSONS CONTACTING THE CONTROLLER BY E-MAIL AND POST

10. INFORMATION CLAUSE FOR PERSONS CONTACTING THE CONTROLLER BY PHONE (CONVERSATIONS RECORDED)

11. INFORMATION CLAUSE FOR RECIPIENTS OF COMMERCIAL INFORMATION

12.INFORMATION CLAUSE RELATED TO PROCESSING OF DATA FOR VIDEO SURVEILLANCE PURPOSES

13. DATA SUBJECT'S RIGHTS RELATED TO THE PROTECTION OF PERSONAL DATA

14. INFORMATION ON COOKIES

 

1. GENERAL PROVISIONS

1. This Policy incorporates information clauses on the processing of personal data by the Data Controller - KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin.

2. The Policy was created to explain how we protect personal data. We use personal data only for the purposes and in the manner described in this Policy. The Data Protection Policy satisfies KAN Spółka z o.o.'s obligation to provide information within the meaning of Article 13(1) and (2) of the Regulation of the European Parliament and of the Council (EU) 2016/679 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 (General Data Protection Regulation), hereinafter GDPR.

3. Below you can find information on what personal data we collect, process and store. We always indicate for which specific purpose we process data and what rights data subjects have.

4. For the purposes of this Policy, the following definitions shall mean:

(a) "Candidate" -  means a person, in particular, a participant in our courses, as well as an individual taking part or intending to take part in a recruitment process conducted by the Controller or in future recruitment processes conducted by the Controller, or who has consented in the past to the storage of their personal data in the Candidate Database,  

(b) "Data Subject" means an entity whose personal data is processed by the Controller, including the Candidate, the Customer and their employees, agents, representatives, persons who have consented to marketing communications, persons contacting the Controller,   

(c) Supervisory "Authority" means the President of the Office for the Protection of Personal Data,

(d) "GDPR" means 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 (General Data Protection Regulation).

 

2. CONTACT DETAILS OF THE CONTROLLER AND DATA PROTECTION OFFICER

1. The Controller of personal data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin, hereinafter "PDC" or "Controller".

2. You can contact the Controller at any time regarding data protection issues:

(a) Using a contact form available at the website: http://pl.kan-therm.com/contact/formularz_zapytanie.html

(b) Using traditional post service to the Controller's address: ul. Zdrojowa 51, 16-001 Kleosin,

(c) By e-mail: [email protected]

3. The Data Protection Officer at KAN Spółka z o.o. is Agnieszka Kondel. You can contact the Data Protection Officer at the following e-mail address: [email protected]

4. If:

(a) You want to contact PDC on matters concerning the protection of personal data

(b)  You have questions about your personal data, the way it is processed by PDC or comments on this Policy

(c) You want to exercise your rights concerning your personal data processed by KAN Spółka z o.o. as their controller, you can contact us by e-mail or post at the contact details indicated in point 2 above.

 

3. SCOPE OF PERSONAL DATA PROCESSED BY THE CONTROLLER

1. "Personal data" shall mean information relating to an identified or identifiable natural person. An identifiable natural person is a person who can be identified, directly or indirectly, in particular, based on an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person. This includes the following information: IP address, form of addressing, name, address, e-mail address, telephone number.

2. KAN Sp. z o.o. process the personal data of:

(a) Job applicants,

(b) Persons participating in our product and other training courses related to the activities of KAN Sp. z o.o.

(c) Customers, business partners and their employees/co-workers/attorneys/proxies/management board members - including: name, e-mail address, position, telephone number, data of the company they represent

(d) Employees and co-workers of KAN Sp. z o.o.

(e) Persons who have given their consent to marketing communications, the sending of newsletters, persons who contact the Company by telephone or by traditional or electronic correspondence

(f) Persons covered by the video surveillance system used on the premises of KAN Spółka z o.o. with its registered office in Kleosin.

 

4. INFORMATION CLAUSE FOR JOB APPLICANTS

1. The Controller of your data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin. In matters concerning personal data processed by the Controller, queries may be addressed to the data indicated in point 2 of the Policy.

2. If you have sent your CV to us, we would like to inform you that the submission of your personal data included in your CV to the Controller, including in a broader scope than that set out in Article 22(1) of the Labour Code, constitutes your consent to the processing of such data by the Controller for the purpose of the recruitment process, regardless of the preferred legal basis for employment by the Controller's Customer. The consent can be withdrawn at any time. The withdrawal of the consent does not affect the legality of the processing carried out before it was withdrawn. The Controller processes the personal data on behalf of the Customer as soon as the Candidates' data are made available to the Customer, which is always performed with the prior consent of the data subject (Candidate).

3. Your personal data obtained during the recruitment process shall be processed:

(a) In the case of recruitment aiming at employment based on an employment contract, to comply with the obligations arising from the provisions of the law, related to the recruitment process, including, above all, the Labour Code - the legal basis for processing is the legal obligation of the Controller (Article 6(1) points (b) and (c) of the GDPR in relation to the provisions of the Labour Code)

(b) In the case of recruitment aimed at employment based on a civil law contract - the legal basis for the processing of the data contained in the application documents is to take action before concluding the contract (Art. 6(1)(b) GDPR)

(c) For the purposes of conducting future recruitment processes, including adding to the Candidate Database in the case of consent to the processing of data for this purpose - the legal basis for data processing is the consent (Art. 6(1)(a) GDPR)

(d) For the purpose of selection of candidates, verification of your qualifications and skills and determination of the terms and conditions of cooperation - the legal basis for data processing is the legitimate interest of the Controller (Art. 6(1)(f) GDPR). The legitimate interest of the Controller is to verify job candidates and determine the terms and conditions of possible cooperation,

(e) to establish or assert possible claims or defend against such claims by the Controller - the legal basis for data processing is the legitimate interest of the Controller (Article 6(1)(f) GDPR).

4. The data recipients are entities providing recruitment services to the Controller and other supporting services, i.e. providers of IT systems and IT services [hosting poczty i systemy bazodanowe], postal operators and couriers.

5. Your personal data shall be processed until the completion of the current recruitment process and the selection of the candidate(s) by the Controller and, to the extent that the processing is based on consent, until the consent is withdrawn, however, in the event that you consent to the processing of your data for the purposes of future recruitment, your data shall be processed for no longer than 2 years. Each time, the time of processing may be extended by the period of the statute of limitations for claims, if the processing of personal data is necessary for establishing or asserting possible claims or defending against such claims by the Controller. After this period, data shall be processed only to the extent and for the time required by law.

6. The consents referred to in the paragraph above can be withdrawn at any time. The withdrawal of the consent does not affect the legality of the processing carried out before it was withdrawn. The Controller shall ask you to withdraw your consents in writing or electronically.

7. You have the rights set out in point 13 of this Policy.

8. Providing data within the scope of Article 22(1) of the Labour Code is required:

(a) By law - in the case of employment based on an employment contract - including, in particular, the Labour Code. Failure to provide this data shall result in your application not being considered for the recruitment process

(b) In the case of employment based on a civil law contract - by the Controller. Failure to provide this data shall result in your application not being considered for the recruitment process

c)  Providing other data is voluntary.

9. The personal data of Candidates may be profiled [but no
automated decision-making is used] to select
candidates who match the requirements of the Controller's Customer in terms of
education, skills and expected financial requirements or
work conditions.

 

5. INFORMATION CLAUSE FOR TRAINEES

1. The Controller of your data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin. In matters concerning personal data processed by the Controller, queries may be addressed to the data indicated in point 2 of the Policy.

2. Your data shall be processed to:

(a) Execute the contract and take actions in relation to the concluded contract on the provision and organisation of training courses (Art. 6(1)(b) GDPR)

(b) Comply with legal obligations arising from the law, insurance regulations, tax regulations - in this regard, the legal basis is the legal obligation of the PDC (Art. 6(1)(c) GDPR)

(c) Establish or assert possible claims or to defend against such claims by the Controller - the legal basis for data processing is the Controller's legitimate interest (Art. 6(1)(f) GDPR)

(d) Market the company's own products or services (Art. 6(1)(a) GDPR - if you have given your consent or (f) GDPR -  our legitimate interest is to inform you about our commercial offer.

 

6. INFORMATION CLAUSE FOR CUSTOMERS - CONTRACTORS

1. The Controller of your data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin. In matters concerning personal data processed by the Controller, queries may be addressed to the data indicated in point 2 of the Policy.

2. Your data shall be protected and processed to:

(a) Execute contracts to which the data subject is a party, i.e. a Customer or Contractor, or to take action at the request of the data subject before entering into a contract (based on Article 6(1)(b) GDPR).

(b) Marketing the company's own products or services (Article 6(1)(a) if you have given your consent or (f) GDPR) -  our legitimate interest is to inform you about our commercial offerings.

(c) Exercise our legitimate interest to establish or assert or defend against any possible claims (the legal basis for the processing is Article 6(1)(f) GDPR)

3. Your personal data shall be kept for the period necessary to fulfil the purpose for which you have given your consent, with a systematic review of the assessment of its relevance. In particular, the data shall be processed for the duration of the contract, but not longer than for the duration of the contract. Each time, the time of processing data may be extended by the period of the statute of limitations for claims, if the processing of personal data is necessary for asserting possible claims or defending against such claims by the Controller. After this period, data shall be processed only to the extent and for the time required by law, including tax and accounting law. To the extent that data is processed for the purpose of directing marketing content to you, it shall be processed until you withdraw your consent or object to such processing.

4. The recipients of the data shall be: carriers delivering shipments/deliveries for the company, banks intermediating in payments, selected entities assisting in handling marketing campaigns and promotion of offers if you have consented to receive commercial information electronically, including information about the current offer of the company, suppliers of IT systems and services of the company, entities rendering services to the company necessary for the performance of a contract concluded with you, including legal services, postal operators and couriers.

6. You have the rights set out in point 13 of this Policy.

7. You are entitled to object to the processing of your personal data for the purpose of directing marketing content to you. Moreover, with regard to the processing of personal data for purposes arising from the company's legitimate interests  you are entitled to object on grounds relating to your particular situation.

8. Should the personal data be processed based on consent – the consent given above may be withdrawn at any time. The withdrawal of the consent does not affect the legality of the processing carried out before it was withdrawn. The Controller shall ask you to withdraw your consents in writing or electronically.

9. The provision of your personal data is necessary for the execution of the contract concluded with the customer, and otherwise voluntary.

 

7. INFORMATION CLAUSE CUSTOMER'S/CONTRACTOR'S EMPLOYEES/MANAGEMENT/SHAREHOLDERS/PROXIES

1. The Controller of your data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin. In matters concerning personal data processed by the Controller, queries may be addressed to the data indicated in point 2 of the Policy.

2. Your personal data has been made available to the Controller by our contractor, whom you  represent/are an employee/co-employee, or obtained from public registers (e.g. business registers, KRS/CEIDG court registers) in connection with the performance by the Controller of a commercial contract between the Controller and the entity you represent/are an employee/co-employee of. We shall process the following categories of your personal data:

(a) In the case of representatives: name(s) and surname, function in the entity they represent, position, e-mail address, telephone number

(b) In the case of other persons: name(s) and surname, e-mail address, telephone number, position.

 

8. INFORMATION CLAUSE FOR AGENTS

1. The Controller of your data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin. In matters concerning personal data processed by the Controller, queries may be addressed to the data indicated in point 2 of the Policy.

2. Your data shall be processed to:

(a) Execute contracts to which the data subject is a party, i.e. a contractor/contracting party, or to take action at the request of the data subject before entering into a contract (Article 6(1)(b) GDPR)

(b) Perform legal obligations arising from the law, insurance regulations, tax regulations - in this regard the legal basis is the legal obligation incumbent on the Controller (Article 6(1)(c) GDPR)

(c) Establish or assert possible claims or defend against such claims by the Controller - the legal basis for data processing is the Controller's legitimate interest (Article 6(1)(f) GDPR).

3. The recipients of the data shall be: entities providing services to the Controller, i.e. providers of IT systems and services, postal operators and couriers, banks with regard to the payment of remuneration, entities authorised by law, entities providing the company with services necessary for the performance of the contract concluded with you, including legal services.

4. Your data shall be processed for the duration of the contract, and after its termination – in general, no longer than 6 years. Each time, the time of processing may be extended by the period of the statute of limitations for claims, if the processing of your personal data is necessary for establishing or asserting possible claims or defending against such claims by the Controller. After this period, data shall be processed only to the extent and for the time required by law, e.g. for the archiving of documentation.

5. You have the rights set out in point 13 of this Policy.

6. With regard to the processing of personal data for purposes arising from the company's legitimate interests, you are entitled to object on grounds relating to your particular situation.

7. The provision of data is a contractual requirement.  As a consequence of failing to provide this data, the contract cannot be concluded.

 

9. INFORMATION CLAUSE FOR PERSONS CONTACTING THE CONTROLLER

1. The Controller of your data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin. In matters concerning personal data processed by the Controller, queries may be addressed to the data indicated in point 2 of the Policy.

2. Your data shall be processed for the purpose of handling your enquiry/correspondence - answering your questions, as the legitimate interest of the Controller is to handle enquiries and correspondence, establish or assert possible claims or defend against such claims by the Controller (Article 6(1)(f) GDPR).

3. The recipients of the data shall be: entities providing services to the Controller, i.e. providers of IT systems and services [hosting poczty i systemy bazodanowe], legal services, postal and courier operators, entities authorised by law.

4. Your data shall be processed for the duration of the correspondence, and after their completion – in general, no longer than for the period of the statute of limitations for claims. Each time, the time of processing may be extended by the period of the statute of limitations for claims, if the processing of your personal data is necessary for establishing or asserting possible claims or defending against such claims by the Controller. After this period, data shall be processed only to the extent and for the time required by law, e.g. for the archiving of documentation.

5. You have the rights set out in point 13 of this Policy.

6. With regard to the processing of personal data for purposes arising from the company's legitimate interests, you are entitled to object on grounds relating to your particular situation.

7. The provision of data is a contractual requirement.  As a consequence of failing to provide this data, the contract cannot be concluded.

 

1O. INFORMATION CLAUSE FOR PERSONS CONTACTING THE CONTROLLER BY PHONE (CONVERSATIONS RECORDED)

1. The Controller of your data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin. In matters concerning personal data processed by the Controller, queries may be addressed to the data indicated in point 2 of the Policy.

2. Your data shall be processed to handle your query/phone call – to answer your questions. Personal data shall be processed to monitor the quality of the Controller's service to the Customer, secure the legal interest of the person whose personal data is recorded in the phone recording system, and the legal interest of the Controller.

3. The data shall be processed based on consent – that is under Article 6(1)(a) GDPR.

4. The recipients of the data shall be entities providing services to the Controller, that means of IT and service providers [hosting poczty i systemy bazodanowe], the provider of telecommunication services – KOBA Spółka z o.o., legal services, postal and courier operators, entities entitled under the provisions of law, as well as the Company KANEX Sp. z o.o. with its registered office in Kleosin.

5. Your data shall be processed for the duration of the conversations, and after their completion – in general, no longer than 12 months. Each time, the time of processing may be extended by the period of the statute of limitations for claims, if the processing of your personal data is necessary for establishing or asserting possible claims or defending against such claims by the Controller.

6. Should the personal data be processed based on consent –
the consent given above may be withdrawn at any time.
The withdrawal of the consent does not affect the legality of the processing
carried out before it was withdrawn. The Controller shall ask you to withdraw your
consents in writing or electronically.

7. The provision of data is completely voluntary.

8. You have the rights set out in point 13 of this Policy.

 

11. INFORMATION CLAUSE FOR RECIPIENTS OF COMMERCIAL INFORMATION

1. The Controller of your data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin. In matters concerning personal data processed by the Controller, queries may be addressed to the data indicated in point 2 of the Policy.

2. Your data shall be processed:
(a) For the purpose of sending marketing information based on your consent -  Article 6(1)(a) GDPR for the purpose of marketing the company's own products or services (Article 6(1)(f) GDPR) -  our legitimate interest is to inform you about our commercial offer.

3. The recipients of the data shall be: entities providing services to the Controller, i.e. providers of IT systems and services [hosting poczty i systemy bazodanowe, email-marketing, agencje marketingowe], entities entitled under the provisions of law, legal services, postal and courier operators, entities authorised by law.

4. Your data shall be processed until the withdrawal of your consent, verifying periodically its relevance. Each time, the time of processing may be extended by the period of the statute of limitations for claims, if the processing of your personal data is necessary for establishing or asserting possible claims or defending against such claims by the Controller.

5. You have the rights set out in point 13 of this Policy.

6. You are entitled to object to the processing of your personal data for the purpose of directing marketing content to you. Moreover, with regard to the processing of personal data for purposes arising from the company's legitimate interests  you are entitled to object on grounds relating to your particular situation.

7. Should the personal data be processed based on consent – the consent given may be withdrawn at any time. The withdrawal of the consent does not affect the legality of the processing carried out before it was withdrawn. The Controller shall ask you to withdraw your consents in writing or electronically.

8. Profiling - we profile, i.e. automatically assess certain personal factors, based on the personal data provided.We use profiling to better understand your interests and needs regarding the products and services we offer. Based on your profile, we shall send you information matching your preferences in terms of, among other things, customising the subject of the content and promotional, educational and informational material we send you, offering products, market research and public opinion polling, taking measurements to improve our services.We use the following data for profiling: name, surname, age, gender, language, date of birth, town/city, type of product purchased, source of data acquisition.

9. The provision of data is voluntary, but necessary to contact the PDC for the purposes described in section 2 above.

 

12. INFORMATION CLAUSE RELATED TO PROCESSING OF DATA FOR VIDEO SURVEILLANCE PURPOSES

1. To ensure the safety of persons remaining in the premises of KAN Spółka z o.o., protection of property and production control, as well as to keep confidential any information the disclosure of which could expose the Controller to damage, the Controller has introduced special supervision in the form of technical measures enabling image registration - video monitoring.

2. The Controller of your data is KAN Spółka z o.o. ul. Zdrojowa 51, 16-001 Kleosin. In matters concerning personal data processed by the Controller, queries may be addressed to the data indicated in point 2 of the Policy.

3. Your data shall be processed to ensure the safety of persons remaining in the premises of KAN Spółka z o.o., to protect property and to control production, as well as to keep confidential information the disclosure of which could expose the Controller to damage, i.e. on the basis of the Controller's legitimate interest (Article 6(1)(f) GDPR.

4. The recipients of the data shall be: entities providing services to the Controller, i.e. providers of IT systems and services, a company providing security services for persons and property, entities authorised by law. Surveillance recordings may be disclosed to authorised employees of the Controller, members of the Controller's bodies.

5. Your data in the form of the image captured on the video surveillance recordings shall be stored for a maximum of 3 months and then overwritten by further recordings.

6. You have the rights set out in point 13 of this Policy.

7. With regard to the processing of personal data for purposes arising from the company's legitimate interests, you are entitled to object on grounds relating to your particular situation.

8. Providing the data involves being on the Company's premises. The monitored area is appropriately marked by the Controller.

 

13. DATA SUBJECT'S RIGHTS RELATED TO THE PROTECTION OF PERSONAL DATA

1. Should you assert your rights, please address your correspondence to the e-mail address set out in point 2. or via a contact form. At the same time, please send us all the information necessary to enable us to identify you unambiguously.

2. You have the right to: 

(a) Access the content of your personal data, including requesting a copy

(b) Require rectification of your data

(c) Have your personal data deleted (the right to be forgotten) 

(d) Restriction of personal data processing 

(e) Have your personal data transferred to another controller if the processing is based on a contract [art. 6 ust 1 lit b RODO]  albo o zgodę [art. 6 ust. 1 lit. a RODO]

(f) Object to the processing of personal data, in particular, to direct marketing based on Article 6(1)(f) GDPR. You have the right to object to the processing of your personal data for purposes based on Article 6(1)(f) of GDPR due to your particular situation

(g) Complain with the President of the Data Protection Office

(h) Withdraw your consent, which may be done at any time. The withdrawal of consent shall not affect the processing carried out before it. Consents may be revoked by them at any time, without affecting the legality of the processing.

Data Protection Office, ul. Stawki 2  00-193 Warszawa, [email protected]

 

14. INFORMATION ON COOKIES

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Cookies are used by KAN sp. z o.o. to optimise the functioning of the website and for statistical analysis. This website uses the following cookies:

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Session-specific cookies expire (are deleted) when the user closes the browser.

Google Analytics cookies generally expire no later than 6 months after your last visit to the website.

The user can delete cookies at any time using the functions available in the browser or the operating system.

It is entirely up to the website visitor to decide whether cookies are stored on their device.

Cookies can be blocked and managed (in particular deleted) using the settings of the browser - usually in the privacy settings - for more information, please refer to the documentation of the browser.

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