O&W Group Companies data processing information

This information applies to the companies, that constitute Olesiński & Wspólnicy Group (“O&W Group”) as follows. Each of them has its registered seat in Wrocław, ul. Powstańców Śląskich 2-4 (53-333):

 

  • Olesiński i Wspólnicy sp. k; e-mail adress: olesinski@olesinski.com, phone number: (+48) 71 75 00 700, contact to data protection officer: odo@olesinski.com;
  • Gałka Olesiński Business Support sp. z o.o.; e-mail adress: biuro@gobs.pl, phone number: (+48) 71 75 00 400, contact to data protection officer: iod@gobs.pl;
  • Saurus Grow sp. z o.o.; e-mail adress: biuro@saurusgrow.pl, phone number: (+48) 71 75 00 700;
  • O&W Analytics sp. z o.o.; e-mail adress: analytics@ow-analytics.com, phone number: (+48) 71 75 00 880.

 

The following information applies to each of the companies in the O&W Group.

 

I. Information on the Data Controller of your Data

 

Depending on which company you contact, enter a contract or lead business relationship with, as a rule, each of the companies in the O&W Group is a separate controller (“Controller”, “we”) of your personal data (“Data”) and decides on its own about the purposes and the means in which it is processed.

 

The companies of the O&W Group operate jointly:

  • recruitment process;
  • marketing activities, in particular sending newsletters, legal and tax alerts as well as write a blog cowprawiepiszczy.pl;
  • jointly organize professional events

and jointly determine the purposes and means of processing Data in these areas and to this extent are joint controllers of Data (see more below).

 

It may also happen that a certain company performs activities for another company from the O&W Group, e.g. related to administration, marketing – in such a case the company performing these activities does not become the Controller of your personal data, but processes them on the basis of the entrustment agreement concluded with the Controller.

 

II. How do we process the Data?

 

This information regards processing of your Data in situations where:

– you contact us (e.g. by telephone, post or e-mail, including “Contact” tab on the O&W Group’s website);

– you are our business partner or client, or an employee or a co-worker of our business partners or customers;

– you use our marketing activities, in particular you have signed up for our Newsletter, published a comment on our blog cowprawiepiszczy.pl or take part in professional events organized by companies from O&W Group;

– you participate in the recruitment process to our team.

 

We pay particular attention to protect your interests as a Data subject and in particular we assure that:

 

  1. we process Data lawfully, fairly and in a transparent manner;
  2. we collect Data for specific, explicit and legitimate purposes and do not further process them in a manner incompatible with those purposes;
  3. Data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
  4. Data shall be accurate and, where necessary, kept up to date;
  5. we keep Data in a form which permits your identification as a Data subjects for no longer than is necessary, for the purposes for which it is processed;
  6. we process Data in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, using appropriate technical or organizational measures.

 

III.        When do we process Data?

 

As a Controller we process Data in many situations. These may be situations in which you have provided us with your Data in person through various means of communication (e.g. by submitting your application, making an inquiry / offer by e-mail, telephone or via form available on our website) or in relation of our cooperation during signing or performing a contract, but also when we have obtained your Data from other sources (e.g. from a company with which you cooperate and which is our business partner/client. It may also happen that your data was entrusted to us for processing by another entity, including another company from the O&W Group – then we process your data as a processing subject (so-called processor) and the Controller is this entity – an example of such a situation is e.g. entrusting by Olesiński & Wspólnicy sp.k. company to the Saurus Grow sp.k. Data to be processed in accordance with the administrative and office management of the company.

 

IV. Data processing in connection with business relations and contact

 

a) What Data do we process?

 

We process the Data of our clients and business partners as well as their employees / co-workers, Data of other persons transferred to us in accordance to the performance of contracts or persons’ establishing contact with us via telephone, e-mail or forms on our websites.

 

In connection with these relations, we may process the following Data: identification data, contact details, position and professional remits data and other Data provided to us in reference to the cooperation or contact.

 

We collect this data directly from you as well as from other persons, e.g. from your employers/mandator.

 

b) What is the purpose and legal basis of Data processing?

 

In connection with these relations, we process your Data for the following purposes:

– establishing cooperation;

– entering into and performing a contract;

– settling contracts;

– responding to any inquiries or requests made and conducting further correspondence / contact in this respect;

– defending against potential claims, as well as for the purpose of possible claims submission;

– fulfilling our legal obligations (e.g. tax, accounting, complaint examination).

 

The legal basis for the processing of your Data by us is:

– a necessity to perform a contract or to take steps prior to its entering at your request as a Data subject;

– fulfilling our legal obligations;

– our legitimate interest in contact, including correspondence and defence against possible claims.

 

Providing Data is in principle free to give, but it may be necessary to enter into or perform a contract, to respond to a query or to conduct correspondence, including feedback regarding recruitment processes.

 

Regardless of whether you are a client of any  company in the O&W Group, to the relations involving data processing between you and that company apply General Terms and Conditions of Service of that company.

 

c) How long will the Data be processed?

 

Data collected for the purpose of entering into and performing a contract will be processed for the duration of the contract or until you object to the processing, which is  based on our legitimate interest, unless the law (e.g. concerning archiving, tax, accounting) obliges us to process this Data longer or we store the Data for longer in the event of potential claims, for a limitation period specified by law, whichever is longer.

 

Your data provided in accordance to contact with us will be processed for the period of time necessary to respond and eventually to conduct correspondence, and then until the expiry of the limitation period for any claims.

 

V. Data processing in connection with marketing activities – in particular sending a newsletter, legal and tax alerts, maintaining a blog and organizing professional events

a) What Data do we process?

 

As Controller, we process your identification and contact data provided to us in relation to our marketing activities, in particular newsletter subscription, sending our legal and tax alerts, posting a comment on our blog or participating in professional events organized by us (in particular seminars, webinars, conferences, business breakfasts).

 

b) What is the purpose and the legal basis of the data processing?

 

In connection with the abovementioned activities, we process Data for the purpose of marketing activities, in particular such as:

– sending newsletters and our legal and tax alerts;

– organizing professional events (in particular seminars, webinars, conferences and business breakfasts);

– enabling you to publish your comment on the blog cowprawiepiszczy.pl.

 

The legal basis for processing your Data is the legitimate interest of the Controller or the necessity to enter into and to perform a contract between you and the Controller.

 

c) How long will the Data be processed?

 

As a rule, we will process your Data for the purposes specified above, until the time of submitting objection, withdrawal of consent to communication or until the end of the event and sending of summary materials, for the period required by law or for the period of limitation of possible claims – whichever period is longer.

 

VI. Data processing in relation to the recruitment purposes

 

a) What Data do we process?

 

We process all Data provided to us within the application and collected within the recruitment process for the needs of the current recruitment process in the O&W Group, if you have given your consent, also for the future recruitment processes for similar positions.

 

In accordance to the recruitment, we may process the following Data (the processing of some Data may depend on your consent): identification data, contact details, educational data, data concerning skills and current employment, data concerning remits and other Data provided to us during the recruitment process.

 

b) What is the purpose and legal basis of the Data processing?

 

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

– consideration of a candidacy and conduction of a recruitment process, in the case of a given consent, also for the purposes of future recruitment;

– defence against potential claims, as well as for the purpose of possible claims.

 

The legal basis for processing your Data is taking action at your request as a Data subject, before signing a contract, the provisions of applicable law, in particular the Labour Code and executive acts, in a larger scope than specified in these provisions or for the purposes of future recruitment processes at your consent.

 

We will also process your Data for the purpose of potential disputes between you and one of the co-controllers (the legal basis for the processing is in such a case the legitimate interest of the Controller).

 

c) How long will the Data be processed?

 

As a general rule, we will process your Data for the purposes specified above, for the duration of the recruitment process or, depending on your additional free given consent, for the future recruitments or until withdrawal of consent, and then until the expiry of the limitation period for possible claims, unless statutory provisions oblige us to process this Data longer.

 

 

VII.       Arrangements between joint controllers

 

Regardless:

– to which O&W Group company you apply for a job;

– which company’s employees published an article on the blog cowprawiepiszczy.pl;

– from which company you received an invitation to a professional event organized by us;

– from which company you received a newsletter or a legal alert,

 

Your rights related to Data processing in connection with abovementioned activities will be exercised by Olesiński i Wspólnicy sp. k. This applies primarily to ensure you the right of access to the Data, including the request for their copy, the right to rectification or their erasure and the right to restriction of processing, to Data portability, including sending them to another controller, as well as the right to object to the processing.

 

Performance by Olesiński i Wspólnicy sp.k. obligations concerning your rights corresponds to the operations on data carried out by the O&W Group companies in connection with joint recruitment processes, marketing and communication activities conducted within the O&W Group.

 

Olesiński i Wspólnicy sp.k.:

 

– conducts the recruitment process in the O&W Group, as well as identifies the recruitment needs of companies from the O&W Group;

– supervises the marketing processes in the group and manages the organization of professional events;

– supervises communication within the O&W Group and carrying out business relations within the Group.

 

Additionally, Olesiński i Wspólnicy sp.k. is responsible for storing documents related to participation in the recruitment process (in particular CV) conducted for positions available in the structures of each of the O&W Group companies.

 

Despite abovementioned, the decision finalizing candidates’ recruitment process is always the responsibility of the company, which may finally be your employer (which recruitment processes are responsible for your job offer).

 

VIII.      Who is the recipient of the Data?

 

The recipients of your Data can be entities providing courier services, providers of ICT services, companies that provide support and operation of our tools and IT systems (e.g. software service technicians), professional advisors (e.g. law firms), companies providing accounting services to the Controller, companies providing auditing services (e.g. independent auditors), other companies as well as entities providing scanning, printing services, handling correspondence, archiving and destructing of documents, as well as entities that may participate in performance of the contract concluded with you, e.g. notaries, other advisors, legal opponents, etc.

 

Data processed by us may be transferred to entities that support us in sending e-mails, to banks – in the event of conducting financial settlements and in the event of monitoring also to security companies.

 

In the case of the recruitment process, your Data may also be transferred to entities that technically or organizationally help us to conduct employee recruitment, including communication with candidates.

 

IX. What rights do you have?

 

In any event, you have a right to:

 

  1. access to Data (including e.g. obtaining information which Data is processed);
  2. request rectification and restriction of data processing (e.g. if it is incorrect);
  3. erasure of Data (e.g. if it has been unlawfully processed);
  4. Data portability which you have provided to a controller and which are processed automatically and the processing is based on a consent or a contract, e.g. to another controller;
  5. object to the processing of Data based on the necessity for the purposes of legitimate interests pursued by the controller or by a third party, including in particular processing for marketing purposes;
  6. submit a complaint to the President of the Personal Data Protection Office.

 

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 carried out on the basis of consent before its withdrawal.