GDPR

HOW PSMM SP. Z O.O. PROCESSES PERSONAL DATA

WHO IS THE CONTROLLER OF YOUR PERSONAL DATA?

The Controller of personal data (hereinafter “Data”) processed by us in connection with our business is the company PSMM Sp. z o. o. having its registered office in Poznań at ul. Marcelińska 14 (60-801), hereinafter referred to as the Controller or PSMM.

The Data is processed in accordance with the currently applicable regulations, including the General Data Protection Regulation (GDPR).

Data is understood as all information about an identified or identifiable natural person. An identifiable natural person is a person who can be directly or indirectly identified, in particular, based on an identifier such as first name and surname, identification number, location data, internet identifier or one or more specific factors which determine the physical, physiological, genetic, psychological, economic, cultural or social identity of the natural person.

HOW DO WE PROCESS DATA?

PSMM takes special care to protect the interests of the Data subjects, and in particular, it ensures that the collected Data is:

• processed in accordance with the law, reliably and transparently for the Data subject;
• collected for specific, explicit and legitimate purposes and further processed in a manner consistent with these purposes;
• adequate, relevant and limited to what is necessary for the purposes for which it is processed;
• correct and, if necessary, updated;
• stored in a form that permits the identification of the Data subject for no longer than is necessary for the purposes for which the Data is processed;
• processed in a manner ensuring adequate Data security, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, by appropriate technical and organizational measures.

WHEN DO WE PROCESS DATA?

We process the Data whenever you have disclosed your Data to us in person via various communication channels (e.g. sending an inquiry/offer by e-mail or telephone, submitting your application) or as part of our cooperation when signing or implementing a contract but also when we have obtained your Data from other sources (e.g. from publicly available internet space or from a company with which you cooperate and which is our contractor/client).

DATA PROCESSING IN CONNECTION WITH BUSINESS RELATIONS AND CONTACT

a/ What kind of Data do we process in connection with business relations and contact?

As the Controller, we process the Data of our business partners (clients, subcontractors, contractors), their employees/co-workers and other people which was provided to us as part of the implementation of contracts as well as other people who contact us via telephone, e-mail or our website.

In connection with business relations and contact, we may process the following Data: Identification Data, contact Data, Data concerning a job position and professional qualifications and other Data provided to us in connection with cooperation or contact.

We obtain the above Data directly from the Data subjects as well as from other people, e.g. from their employers/clients.

b/ What is the purpose and basis of Data processing in connection with business relations and contact?

In connection with business relations and contact, we process Data for the following purposes:

• starting cooperation;
• conclusion and performance of a contract;
• settlement of contracts;
• answering all inquiries or requests and further correspondence/contact in that regard;
• marketing and contact regarding other information and PSMM services;
• defence against potential claims, as well as to pursue claims, if any.

The bases for data processing by PSMM include:

• the necessity for the performance of a contract to which the Data subject is party or in order to take steps at the request of the Data subject prior to entering into a contract (Article 6 (1) (b) of the GDPR);
• compliance with a legal obligation to which the Controller is subject (Article 6 (1) (c) of the GDPR),
• the Administrator’s legitimate interest in the form of marketing of the Administrator’s or third party’s products and services, as well as contact, including correspondence and defence against potential claims (Article 6 (1) (f) of the GDPR);
• Item 6 (1) (a) of the GDPR and Article 10 of the Act on Providing Services by Electronic Means and Article 172 of the Telecommunications Law in the scope of additional marketing activities with the use of the e-mail address.

Providing Data is voluntary but it may be necessary for the conclusion or performance of the contract or for answering an inquiry or for correspondence.

c/ How long will the Data be processed in connection with business relations and contact?

The Data collected to conclude and perform a contract will be processed for the duration of the contract and then until the expiry of the limitation period for claims, if any.

The Data of persons who contacted PSMM will be processed for the period necessary to answer and conduct correspondence and then until the expiry of the limitation period for claims, if any.

With regard to personal data processed based on consent, we will process it until its revocation by the Data subject. It will not affect lawful processing prior to its withdrawal.

d/ Who is the recipient of the Data in connection with business relations and contact?

The data processed by us in connection with business relations and contact may be transferred to our business partners (e.g. subcontractors as part of cooperation on a given project) and our other contractors who support us in the organization of our work, IT services or marketing.

DATA PROCESSING IN CONNECTION WITH RECRUITMENT

a/ What kind of Data do we process in connection with recruitment?

As the Controller, we process the Data of job applicants disclosed to us through all available recruitment channels, in particular, we process all Data disclosed to us as part of the application and collected as part of the recruitment process.

In connection with the recruitment, we may process the following Data (the processing of some Data may depend on your consent): Identification Data, contact Data, education Data, Data on skills and previous employment, Data on qualifications and other Data disclosed to us during the recruitment process.

b/ What is the purpose and basis of Data processing in connection with recruitment?

In connection with recruitment, we process Data for the following purposes:

• to consider the candidacy and run the recruitment process, and, if consent was granted, also for future recruitment,
• for defence against potential claims, as well as to pursue claims, if any.

The processing of Data by the Administrator is based on the provisions of applicable law, in particular the Labour Code and implementing acts, and in the scope broader than specified in these provisions and the field of future recruitment, it is based on your consent (Article 6 (1) (a) of the GDPR).

Providing Data is voluntary but necessary for the recruitment process and possibly starting further cooperation.

c/ How long will the Data be processed in connection with recruitment?

The Data will be processed for the duration of the recruitment process or future recruitment and then until the expiry of the limitation period for claims, if any.

d/ Who is the recipient of the Data in connection with recruitment?

The Data processed by us in connection with recruitment may be transferred to other entities which support us in the recruitment process and provide IT services to us.

IS YOUR DATA TRANSFERRED OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)?

Your Data does not go outside the European Economic Area and if in the future it could be transferred outside the EEA, PSMM takes appropriate steps to ensure Data protection, in particular by:

• application of specific contractual clauses approved by the European Commission;
• transfer to countries for which the European Commission has issued an adequacy decision regarding the safeguards.

In such a case, you have the right to obtain a copy of the relevant safeguards.

WHAT ARE YOUR RIGHTS?

Under the terms specified by applicable law, you have the right to:

• access your Data, including the right to obtain a copy thereof;
• demand its rectification, deletion or limitation of processing;
• object to the processing;
• transfer it to another controller (to the extent that its processing is based on the necessity to perform a contract or your consent).

If the processing of Data is based on consent, you have the right to withdraw it at any time without affecting the lawfulness of the processing that was carried out based on the consent before its withdrawal.

You always have the right to complain with the President of the Personal Data Protection Office.

CONTACT

For any matters connected with Data processing, you can contact PSMM at iod@psmm.pl