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Privacy Policy

With regard to the processing of your personal data – in accordance with Articles 13 and 14 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27.04.2016 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) (Official Journal of the EU L of 04.05.2016, No. 119, p. 1), hereinafter abbreviated as “RODO”, we inform you that:

I DATA CONTROLLER

The administrator of your personal data is Clurgo Sp. z o.o. represented by Michał Kalisiński, with its
registered office at Jasna 14/16a 00-041 Warsaw, website: www.clurgo.com.

II PERSON RESPONSIBLE WITHIN THE ORGANISATION FOR DATA PROTECTION

The controller has appointed a person responsible for data protection in the organisation – Piotr Drajski,
whom you can contact in matters related to data protection as follows:

  • by e-mail: iod@clurgo.com.pl
  • in writing to the Administrator’s registered address.

III LEGAL BASIS AND PURPOSES OF PERSONAL DATA PROCESSING

The processing of your data shall be carried out in connection with the performance of the Administrator’s own tasks or tasks commissioned to the Administrator and specified by law.
Processing may also be necessary for the performance of a contract to which you are a party or to take action, at your request, prior to entering into a contract.
There may also be instances where you will be asked to give your consent to the processing of personal data for a specific purpose and scope.
Personal Data will be processed for the following purposes:
a. to conclude and perform contracts for, inter alia, training, consulting, implementation, analytical, data processing, software development and related services, etc.basis of Art. 6(1)(b) RODO,
b. to perform legal obligations incumbent on the Administrator in connection with the performance of the agreements, in particular obligations to keep accounts and make tax settlements – on the basis of Art. 6(1)(c) RODO,
c for the purpose of establishing, asserting and defending claims between the contractor and the Administrator – on the basis of Art. 6(1)(f) RODO, in the case of using monitoring and processing data in the form of an image – for the purpose of realising the Administrator’s legitimate interest in the form of protecting property and ensuring security in the monitored area – on the basis of Art.6 par. 1 lit. f) RODO,>
d. realization of warranty/complaint service – on the basis of art. 6 par. 1 lit. b) RODO,
e. marketing own products and services by sending electronic information about promotions, novelties – on the basis – art. 61 litf) RODO,
f. statistics as part of the legitimate and justified interest of the personal data controller –
g. for other purposes, specified in detail in separate information clauses – on the basis of art. 6 sec. 1 lit. a) RODO

IV CATEGORIES OF DATA PROCESSED

The controller will process ordinary personal data such as: personal data, data as specified in the Labour Code, necessary for the performance of the contract, image, areas subject to video surveillance, and user traffic on the organization’s website.

V INFORMATION ON THE SOURCE OF THE DATA

We obtained your data either directly from you or from our employees/contractors/co-operators/contractors.

VI RECIPIENTS OF PERSONAL DATA

In connection to the processing of data for the purposes referred to in point III, the recipients of your personal data may be entities which, signed with the Administrator, process personal data on his/her instructions. Your personal data may also be transferred to third countries, such as the United States and Israel, based on separate legal regulations.

VII RETENTION PERIOD OF PERSONAL DATA

Your personal data will only be stored for the period necessary to fulfil the purpose for which they were collected within the period indicated by law or until your consent is withdrawn.
The Personal Data will be stored only for the period necessary for the proper implementation of the above purposes after which the data will be stored for the period of limitation of claims and criminal acts or for the period required by law, e.g. tax regulations. The Administrator may store Personal Data for a longer period than indicated only if it results from an obligation imposed on the Administrator by generally applicable law, or if there will be another basis for data processing as specified in Article 6(1) RODO.

VIII DATA SUBJECTS’ RIGHTS

In accordance with the provisions of the RODO, you have the right to request from the Controller: access to the content of your personal data, rectification (amendment) of your personal data, erasure of your personal data to the extent of the data processed on the basis of your consent, restriction of the processing of your personal data when the correctness of the processing of your personal data is questioned, portability of your personal data to the extent of the data processed on the basis of your consent, to object to the processing of your data, to withdraw your previously expressed consent to the processing of your personal data.
Providing Personal Data is voluntary, but may be necessary for the fulfilment of selected processing purposes, and failure to provide Personal Data:
* in case of data processing for the purpose referred to in point.3 lit. a, b above – it will prevent the conclusion and execution of the contract,
* in case of data processing for the purpose referred to in point 3 lit. d above – it will prevent the performance of the guarantee / complaint service,
* in case of data processing for the purpose referred to in point 3 lit. e above – it will not cause any negative consequences,
* in case of data processing for the purpose referred to in point 3 lit. b, c, f above – it will prevent the fulfilment of the indicated purposes

IX AUTOMATED DECISION-MAKING, PROFILING

Your personal data is not subject to automated decision-making, including profiling.
If you believe that there has been a breach of data protection regulations, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, your place of work or the place where the alleged breach took place.

INFORMATION CLAUSE FOR COOPERATORS/CUSTOMERS

According to Article 13(1) and (2) 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 (General Data Protection Regulation), hereinafter abbreviated as “RODO”, we inform you that:
The administrator of your data is Clurgo Sp. z o.o. with its registered office at ul. Jasna 14/16a 00-041 Warsaw.
You can contact Piotr Drajski, the person responsible for data protection, electronically by writing to: iod@clurgo.com or in writing to the Administrator’s address.
Your personal data will be processed for the purpose of entering into and performing a contract of mandate/work contract/service contract and for the purpose of fulfilling the Administrator’s legal obligations.
The recipients of your personal data will be entities authorised by law and entities processing personal data on the basis of relevant contracts signed with and on the instructions of the Administrator.
Your personal data will be stored for the duration of the cooperation, until the statute of limitations for claims and for the mandatory retention period for insurance, billing and tax documentation, determined in accordance with separate regulations.
Within the limits of the law, you have the right of access to the content of your data, rectification, erasure, restriction of processing and portability.
If you consider that the processing of your personal data violates the provisions of the RODO, you have the right to lodge a complaint with the President of the Data Protection Authority.
The provision of your personal data is voluntary, but necessary for the purposes related to the establishment and course of your cooperation with the Administrator. Failure to provide data will result in an inability to conclude and execute a contract.

INFORMATION CLAUSE FOR TRAINEES

According to Article 13(1) and (2) 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 (General Data Protection Regulation), hereinafter abbreviated as “RODO”, we inform you that:
The administrator of your data is Clurgo Sp. z o.o. with its registered office at ul. Jasna 14/16a 00-041 Warsaw.
You can contact Piotr Drajski, the person responsible for data protection, electronically by writing to: iod@clurgo.com or in writing to the Administrator’s address.
Your personal data will be processed for the purpose of concluding and executing the internship/apprenticeship contract, fulfilling the Administrator’s legal obligations.
The recipients of your personal data will be entities authorised by law and entities processing personal data on the basis of relevant contracts signed with and on the instructions of the Administrator.
Your personal data will be stored for the duration of the internship, until the statute of limitations for claims and for the mandatory retention period for documentation related to the internship agreement and personal files, established in accordance with separate regulations.
Within the limits of the law, you have the right of access to the content of your data, rectification, erasure, restriction of processing and data portability.
If you consider that the processing of your personal data violates the provisions of the RODO, you have the right to lodge a complaint with the President of the Data Protection Authority.
Your provision of personal data is voluntary but necessary for the purposes of the establishment and conduct of your internship. Failure to provide data will result in the impossibility to conclude and implement the internship agreement.

INFORMATION CLAUSE FOR EMPLOYEES/CONTRACTORS

According to Article 13(1) and (2) 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 (General Data Protection Regulation), hereinafter abbreviated as “RODO”, we inform you that:
The controller of your data is Clurgo Sp. z o.o. with its registered office at ul. Jasna 14/16a 00-041 Warsaw.
You can contact Piotr Drajski, the person responsible for data protection, electronically by writing to: iod@clurgo.com or in writing to the Administrator’s address.
Your personal data will be processed for the purpose of concluding and performing an employment contract/service contract/co-operation contract and for the fulfilment of the Administrator’s legal obligations.
The recipients of your personal data will be entities authorised by law and entities processing personal data on the basis of relevant agreements signed with and on the instructions of the Administrator.
Your personal data will be kept for the duration of the employment relationship or for the period specified in the contract, until the statute of limitations for claims and for the mandatory retention period for documentation related to the employment relationship and personal files, established in accordance with separate regulations.
Within the limits of the law, you have the right of access to the content of your data, rectification, erasure, restriction of processing and data portability.
If you consider that the processing of your personal data violates the provisions of the RODO, you have the right to lodge a complaint with the President of the Data Protection Authority.
Your provision of personal data is voluntary, but necessary for the purposes of the establishment and course of your employment. Failure to provide data will result in the impossibility to conclude and perform the contract.

INFORMATION CLAUSE FOR APPLICANTS

According to Article 13(1) and (2) 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 (General Data Protection Regulation), hereinafter abbreviated as “RODO”, we inform you that:
The administrator of your data is Clurgo Sp. z o.o. with its registered office at ul. Jasna 14/16a 00-041 Warsaw.
You can contact Piotr Drajski, the person responsible for data protection, electronically by writing to: iod@clurgo.com or in writing to the Administrator’s address.
Your personal data will be processed for the purpose of the recruitment process on the basis of your consent (Article 6(1)(a) RODO), on the basis of the administrator’s legitimate interest (Article 6(2)(f) RODO) and/or on the basis of the applicable provisions from the Labour Code.
The recipients of your personal data will be persons authorised by the Administrator who are involved in the recruitment process.
Your personal data will be kept for the mandatory retention period of the documentation related to this process and until the statute of limitations for claims. Some of the recruitments in our organisation are continuous, so also after the recruitment process has ended, we will keep your personal data in order to be able to contact you for the re-process, for which we have asked for your consent.
Within the limits of the law, you have the right of access to the content of your personal data, rectification, erasure, restriction of processing, data portability and the right to withdraw your consent at any time, without affecting the lawfulness of the processing of personal data carried out on the basis of consent before its withdrawal.
If you consider that the processing of your personal data violates the provisions of the RODO, you have the right to lodge a complaint with the President of the Data Protection Authority.
Your provision of personal data is voluntary but necessary for the recruitment process. Failure to provide data will result in the impossibility of this process.

INFORMATION CLAUSE ON PERSONAL DATA PROCESSED IN THE VIDEO SURVEILLANCE SYSTEM

According to Article 13 of the General Data Protection Regulation (Official Journal of the EU L 119, p.1) – referred to as RODO, we inform you that:
The administrator of the monitoring system is Clurgo Sp. z o.o. with its registered office at ul. Jasna 14/16a 00-041 Warsaw.
You can contact Piotr Drajski, the person responsible for data protection, electronically by writing to: iod@clurgo.com or in writing to the Administrator’s address.
Monitoring is used for the following purposes: to ensure the safety of employees and to protect property.
The monitoring covers the area of the Clurgo Sp. z o.o. office in Warsaw at ul. Jasna 14/16a.
The basis for the processing is the legally justified interest of the administrator in the form of protecting property and ensuring security in the monitored area – Article 6(1)(f) and also Article 222 of the Act of 26 June 1974. – Labour Code.
Monitoring records are kept for 14 days.
A person recorded by the monitoring system has the right to access personal data.
A person recorded by the monitoring system has the right to lodge a complaint with the supervisory authority, the President of the Data Protection Authority.
Recipients of personal data will only be entities entitled to obtain personal data on the basis of the law and entities that process personal data on behalf of the controller on the basis of relevant contracts.

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