Your privacy is our first priority.
Data Controller
This document (“Privacy Policy“) describes how Radzikowski Szubielska i Wspólnicy spółka jawna, with its registered office in Warsaw, ul. Piękna 18, registered in the Business Register kept by the District Court for the Capital City of Warsaw, 12th Commercial Division of the National Court Register under the KRS number 0000874717, NIP (tax identification number) 5252291040 (“we”, “Controller”) processes your personal data as our client or a person associated with our client (“Client”), a person who visits our website, or a person interested in our services.
When you visit our website or become our Client, we may acquire and process certain information about you (“Data”). Your Data are processed in accordance with applicable laws and in compliance with the highest standards of privacy and security. First of all, we apply 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”, or “GDPR”). We use secure technical and organizational measures to protect all Data we process from loss, destruction or unauthorized access by third parties.
Data received from our Clients
We process the Data that we have received directly from you or from our Client in connection with the negotiation, the process of execution, or performance of a contract related to our services or retention of documents related to our services.
We may also process the data obtained from publicly available databases, such as the Central Register and Information on Business Activity, the National Court Register or the Central Register of Beneficial Owners.
The Data we collect depending on the purposes of their processing may be, without limitation, as follows:
- basic identification details (name and surname),
- company name,
- contact details (telephone number, e-mail address),
- address details (home address, place of residence),
- data on identification numbers (ID card series and number, PESEL, NIP),
- information about the principal,
- data on citizenship,
- information on work experience.
Data collected from visitors to our website
Whether you have provided us with your Data via a contact form or job application form, all the Data you provide are necessary in order for us to be able to contact you and handle your request.
Data we collect automatically
Our website collects some Data automatically when you visit it. We may collect information by automated means, such as browser cookies, pixels, web server logs, web beacons and other technologies. These technologies, among other things, help us (1) remember visitor information so that you do not have to re-enter it, (2) track and understand how visitors use and interact with our website, (3) tailor our website to the visitor’s preferences, (4) manage and measure the usability of our website, (5) understand the effectiveness of our communications, and (6) otherwise improve our website.
The information we collect by automated means includes:
- Data about your device, including MAC address, IP address, log information, device model, hardware model, IMEI number, serial number, subscription information, device settings, connections to other devices, mobile network operator, browser characteristics, app usage information, sales code, access code, current software version, MNC, subscription information, and random, non-persistent and re-settable device identifiers, such as your Personalized Service Identifier (PSID), and advertising identifiers, including Google Ads ID;
- Data about your use of the website, including Clickstream Data, your interactions with websites (such as websites visited, search terms and applications and features used), the webpages that led or directed you to our website, the date and time when you use our website;
- Data relating to your use of third party websites, applications and features that are linked to our services.
Purposes and legal basis of the Data processing
We may process your Data for the following purposes, on the following legal basis and for the periods of time presented in the table below:
| Purpose of Data processing | Legal basis for Data processing | Data storage period |
|---|---|---|
| Performance of the contract with you. We process your personal Data for the purpose of entering into or performing a contract between you and us. | The legal basis for the processing is Article 6(1)(b) GDPR (performance of a contract) – the processing is necessary for the performance of the contract. | The Data are kept for a period of time necessary for the performance, termination or expiry of the contract between you and us. |
| Performance of a contract with an entity you are associated with. We process your Data for the purpose of entering into or performing a contract between us and an entity with which you are associated or on whose behalf you are acting (e.g. Client, contractor or other entity that contacts us). | The legal basis for the processing is Article 6(1)(f) GDPR (legitimate interest of the controller) – the processing is necessary to contact you in connection with the performance of a contract entered into with an entity with which you are associated or on whose behalf you are acting (e.g. Client, contractor or other entity that contacts us). | The Data are kept for a period of time necessary for the performance, termination or expiry of the contract with our Client with whom you are associated or whom you represent. |
| Recruitment. We process your Data that have been sent to us via a form on our website or submitted during the recruitment process. | The legal basis for the processing is: (a) in the case of information set out in the Labour Code, Article 6(1)(c) GDPR (compliance with a legal obligation imposed on the controller); (b) in the remaining scope, Article 6(1)(b) GDPR (performance of a contract) – the processing is necessary for the conclusion of the contract; (c) we process information not related to your qualifications or professional achievements (e.g. photo, interests) on the basis of Article 6(1)(a) GDPR (consent); (d) we process information you have voluntarily provided to us and which is special category data on the basis of Article 9(2)(a) GDPR (consent). | We will process your Data for the purpose of recruitment processes regarding the position described in our job advertisement for the period from receipt of your application until the recruitment process is completed, but for no longer than one year after receipt. If you have given your consent to the processing of your Data in future recruitment processes, we will process your Data until you withdraw that consent, but for no longer than one year after you have given your consent. We will process your Data processed on the basis of your consent until the consent is withdrawn or until we have finished processing the other Data of the candidate concerned. |
| Contact. We process your Data to enable us to communicate with you through various channels. | The legal basis for the processing of your Data is Article 6(1)(f) GDPR (legitimate interest of the controller). This legitimate interest is to enable us to contact you. | We will process your Data until you object to the processing, but in any case for no longer than 5 years. |
| Compliance with legal obligations and the Controller’s internal regulations. We process your Data in order to comply with the law. An example of this is our processing of your Data relating to the identification and verification of the beneficial owner of our client or mutual financial settlements in order to comply with tax and accounting obligations. | The legal basis for the processing is Article 6(1)(c) GDPR (compliance with a legal obligation imposed on the controller). The processing is necessary in order for us to comply with our obligations resulting from the provisions of law, e.g. tax legislation, anti-money laundering and anti-terrorist financing legislation. | We will process your Data as long as the provisions of law entitle us to process them. |
| Exercise or defence of legal claims. We process your Data for the purpose of exercise or defence of our legal claims or interests. | The legal basis is Article 6(1)(f) GDPR (legitimate interest of the controller). This legitimate interest is the exercise or defence of legal claims that we may have or that may be asserted against us. | The Data will be stored for the duration of the legitimate interest pursued by us, but no longer than the period of limitation for claims (the basic limitation period for claims is six years). |
| Website analytics and personalization. We use the Data to personalize content and analyse our website and web traffic. We use cookies for this purpose. | The legal basis for the processing is Article 6(1)(f) GDPR (legitimate interest of the controller). This legitimate interest is analysing the activity of website visitors in order to optimize the services provided. | We will process such Data until you effectively object to the processing, but for no longer than is necessary for the purposes of such processing. |
Voluntary provision of the Data
The provision of your Data is voluntary. However, without the necessary Data, we may not be able to carry out certain activities requested by you or our Clients; therefore, the provision of such Data is a condition for the conclusion of a contract with us or its performance by us.
Recipients of the Data
In some situations, we may need to share your Data with third parties such as:
- Third party service providers – we retain other companies and individuals to perform tasks on our behalf. This includes e.g. administrative services for our office, fulfilling orders for products or services, providing consultancy and accounting services. Such third party service providers have access to the Data to the extent necessary to perform their functions, but may not use the Data for any other purposes. In addition, they must process the Data in accordance with the provisions of the data processing agreements and the applicable data protection legislation.
- Public authorities – in connection with their proceedings on the basis of the relevant legislation.
Transfers of data to countries outside the EEA
We do not transfer and do not plan to transfer the Data to any countries outside the European Economic Area.
Your rights
In relation to our processing of your Data, you have a number of rights, such as:
- the right to demand access to your Data, the right to Data rectification, the right to have your Data erased (“right to be forgotten”);
- the right to object on the grounds relating to your particular situation where we process your Data on the basis of a legitimate interest. However, we will continue to process such Data to the extent necessary if there is a justified reason;
- the right to Data portability or restriction of Data processed in connection with the performance of a contract or on the basis of your consent;
Where the basis for the processing of the Data is your consent, you have the right to withdraw that consent at any time. However, the withdrawal of your consent does not affect the lawfulness of our processing of your Data that we have carried out on the basis of your consent prior to its withdrawal.
For more information about your rights in the context of your personal data, please visit this website: https://uodo.gov.pl/pl/493.
If you believe that our processing of your Data violates the law, you can lodge a complaint with the President of the Personal Data Protection Office. For more information on how to lodge a complaint, please go to https://uodo.gov.pl/pl/83/155 .
Automated decision-making and profiling
Your Data are not subject to automated processing, in particular profiling.
Contact with our Data Protection Officer
In order to maintain the highest standard of protection of your privacy, we have appointed the Data Protection Officer – a person responsible for compliance with data protection laws and for the application of security measures. Our Data Protection Officer is Mr Przemysław Wrzesiński..
You can contact the Data Protection Officer by sending an e-mail to: iod@rslegal.pl. The Data Protection Officer will assist you if you have any questions or comments regarding the protection of your Data or if you would like to exercise your rights resulting from the GDPR. When contacting the Data Protection Officer, please remember to include your contact details and your preferred form of contact. This will enable us to respond to your questions and requests more efficiently.
Cookies
Our website uses cookies. Cookies are small text files that are placed on your computer by websites you visit. They are commonly used to make online services work better or more efficiently. The use of cookies is now a market standard. Cookies may come from us (“first party cookies”) or from third parties whose services we use (“third party cookies”).
As a rule, cookies do not contain personal data. However, some information stored in cookies (e.g. regarding the user’s preferences), especially when combined with other information about the user, may be treated as personal data. Personal data collected through cookies may only be processed for the purpose of performing certain functions for you. These data are encrypted in such a way that they cannot be accessed by unauthorised persons.
Please note that some features of the website may not function properly if cookies are disabled.
We use the following types of cookies:
- Essential cookies – these cookies need to be installed to provide the basic functionality of the website. They are necessary to access certain website functionalities such as contacting us or submitting documentation in a form, they allow the website to remember the visitor’s preferences and choices made on the website, including username, region and language;
| File name | Type of cookie | Duration | Supplier |
|---|---|---|---|
| pll_language | Allowing the tool to work properly on the website | 1 year | RS Legal |
| cc_cookie | Allowing the tool to work properly on the website | 6 months | RS Legal |
- Analytical cookies – We use analytical cookies to understand how users use our website. The data are collected anonymously and are used as a basis for making improvements to ensure the best user experience. For example, when we see that searches carried out by visitors to our site are taking too long, analytical cookies allow us to move an item to a place where it will not be overlooked;
| File name | Type of cookie | Duration | Supplier |
|---|---|---|---|
| _ga | Analytical | 2 years | |
| _ga_4QZT3Z2304 | Analytical | 2 years |
You can manage your consent to the use of cookies via your browser settings.
Most web browsers are configured to automatically accept cookies. However, you can change your browser settings so that cookies are blocked, in whole or in part, e.g. to block third party cookies, or so that you receive a message every time cookies are sent to your device. To find out how to control cookies in popular browsers, please see below.
For more information, please see e.g. the following websites:
http://www.aboutcookies.org/ or http://www.cookiecentral.com/faq/.
Current version of the Privacy Policy
The Privacy Policy provides up-to-date information about our processing of your Data. Its content is subject to review if we change the way we process the Data.