This policy has been published by Rö Radwan-Röhrenschef Petruczenko sp.k. with its registered seat in Warsaw (Rö) in order to inform the persons whose data is processed by Rö on how Rö obtains and processes personal data, what is the scope, purpose and period of their processing and what rights the data subject has. Information on the processing of the personal data of Rö’s clients and their representatives is provided to these persons at the time of the conclusion of the contract or at the time of obtaining the personal data.
Rö is aware of the seriousness of the risks involved in the data processing process and approaches the processing of personal data and other confidential information responsibly and in accordance with the law – in particular provisions 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). Rö applies security and protection practices for processed information based on the requirements of the international standard PN-EN ISO/IEC 27001:2017 – Information Security Management System Standard.
PERSONAL DATA CONTROLLER
The controller of the personal data is Rö Radwan-Röhrenschef Petruczenko sp.k. with its registered office in Warsaw (address: ul. Przyokopowa 33, 01-208 Warsaw) entered in the register of entrepreneurs kept by the District Court for the capital city of Warsaw in Warsaw, 13th Commercial Department of the National Court Register under KRS number 0000372682, NIP 7010272821, REGON 142716151.
Contact with Rö is possible e.g. through the correspondence address: ul. Przyokopowa 33, 01-208 Warsaw or the e-mail address: email@example.com.
SCOPE OF PERSONAL DATA PROCESSED
The scope of the personal data processed by Rö depends on what information is necessary in connection with the relationship between Rö and the data subject, i.e. the purpose of the processing of the personal data.
It may include, in particular, identification data (including name and surname), information concerning employment or the entity the data subject represents (name of the employer/represented entity, official position), contact details (e-mail address, correspondence address, address of residence, telephone number, NIP, REGON, PESEL), data concerning the date of contact with Rö and its duration as well as the content of communication with Rö, data of persons using Rö’s profiles in social media such us Facebook and Linkedin (comments, likes, user name) and other data which was provided in the course of Rö’s communication or cooperation with a given person. To some extent, this may also include information obtained from publicly available sources.
PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA.
Rö processes personal data for the following purposes:
- In order to establish a business relationship, to make an offer, to conclude a contract and subsequently to perform this contract or cooperation (with the data subject or the entity represented by him/her), to conduct correspondence and further communication. The legal basis in this case is Rö’s legitimate interest (Article 6(1)(f) of GDPR) or, in the case of the processing of a person’s personal data in connection with concluded contract or planned
conclusion of a contract with him or her, the legal basis may be the taking of steps at the request of the data subject prior to entering into a contract or the necessity to process the data to perform the contract (Article 6(1)(b) of GDPR).
- For the purposes of marketing, sending commercial information or making an offer or for other legitimate purposes relating to establishing and maintaining business contacts and networking. The legal basis in this case is Rö’s legitimate interest (Article 6(1)(f) of GDPR).
- In order to defend against potential claims or for Rö to pursue claims. The legal basis in this case is Rö’s legitimate interest (Article 6(1)(f) of GDPR).
- In order for Rö to perform its legal obligations, including accounting or tax obligations. The legal basis in this case is the provision stipulating such an obligation and Article 6(1)(c) ofGDPR.
- For the purpose of correspondence (email or traditional) or telephone communication with persons contacting Rö in this way for various purposes. The legal basis in this case is Rö’slegitimate interest (Article 6(1)(f) of GDPR).
- In order to maintain Rö’s profiles on the social media such us Facebook and Linkedin, to enable visitors to these profiles to use their functionality (observing, recommending, commenting) and for statistical and analytical purposes. The legal basis in this case is Rö’s legitimate interest (Article 6(1)(f) of GDPR).
- In order to organise courses, events, webinars (stationary or online), to identify participants, to contact them and to service the event. The legal basis in this case is Rö’s legitimate interest (Article 6(1)(f) of GDPR).
The provision of data is voluntary, but may be necessary for specific purposes, e.g. to conclude contracts, provide services, conduct correspondence.
SOURCE OF PERSONAL DATA
Rö obtained the processed personal data directly from the data subject or from the entity in which the person works or which he or she represents, or from publicly available sources (e.g. public records).
PERIOD OF PROCESSING OF PERSONAL DATA
Rö processes personal data for the purpose of entering into and performing a contract or for the purpose of maintaining a business relationship and marketing for the duration of the contract, the duration of the business relationship or until the data subject objects to the processing based on legitimate interest.
Personal data used solely for the purpose of correspondence or communication will be processed until such correspondence is completed.
The processing period may be extended, within the limits of the law, in the event that the processing of personal data is necessary for the investigation or defence against claims or in the event that the processing of data is mandated by law for a specific period of time.
RECIPIENTS OF PERSONAL DATA
In connection with Rö’s business activities, to the extent necessary, personal data may be transferred to external entities that provide services to Rö in support of its activities, including, in particular, entities providing accounting services, entities providing postal or courier services, entities responsible for the maintenance of IT systems and equipment.
TRANSFER OF PERSONAL DATA OUTSIDE THE EUROPEAN ECONOMIC AREA
As a general rule, Rö does not transfer personal data outside the EEA. This may happen in exceptional situations, but only to the extent necessary, related to the performance of services for Rö by third parties, in particular when using cloud storage. Data security is ensured in such cases by appropriate security measures, including standard clauses approved by the European Commission.
DATA SUBJECT RIGHTS
Data subjects have the following rights:
- the right to request from Rö access to the content of your data and to information about the data being processed, including the purposes and grounds for processing;
- the right to rectification of inaccurate personal data or to complete incomplete data;
- the right to erasure of personal data (the so-called right to be forgotten) where a. the personal data are no longer necessary for the purposes for which they were collected or otherwise processed, b. the data subject has withdrawn the consent on which the processing is based and there is no other legal ground for the processing, c. the data subject objects to the processing and there are no overriding legitimate grounds for the processing, d. the data subject objects to the processing of personal data for direct marketing purposes, e. the personal data have been processed unlawfully, or f. the obligation to erase the data arises by law;
- the right to restriction of the processing of personal data if a. the data subject questions the accuracy of the personal data – for a period of time allowing Rö to verify the accuracy of the data, b. the processing is unlawful and the data subject objects to the erasure of the personal data, requesting instead the restriction of its use, c. Rö no longer needs the personal data for the purposes of the processing, but the data are needed by the data subject to establish, exercise or defend a legal claim, or d. the data subject has objected to the processing – until it is determined whether the legitimate grounds of Rö override those of the data subject;
- the right to withdraw consent to the processing of personal data at any time without affecting the lawfulness of processing based on consent before its withdrawal, insofar as processing is carried out on the basis of consent;
- the right to data portability, i.e. to receive your personal data provided to Rö in a structured, commonly used and machine-readable format and to transmit it to another controller, if a. the processing is based on consent or contract and b. the processing is carried out by automated means;
- the right to object to processing for marketing purposes or based on Rö’s legitimate interest;
- the right to complain to a supervisory authority, i.e. the President of the Office for the Protection of Personal Data, if it is considered that the processing of personal data violates the law, including the GDPR.
Requests for the exercise of these rights can be made, e.g. in writing or by e-mail to the addresses of Rö indicated here, in the title of the message writing “GDPR request”.
INFORMATION ON COOKIES
Cookies are small textual information sent by a server and stored on the side of your device (usually on your computer’s hard drive). They store information that the website administrator may need to adapt to the user’s use of the website and to collect statistical data.
When you visit the website, Rö has the possibility to collect data concerning the domain name of your Internet service provider, browser type, operating system type, IP address, web pages visited, items downloaded, usage data or information about the location of the device the user is using.
The following cookies are used on Rö’s website: polityka cookies
This policy is kept under review and updated as necessary. Last update: 28 February 2023.