privacy

privacy policy

In the Privacy Policy (hereinafter: Policy), we explain how we process your personal data, what rights you have in connection with it, and how we use cookies and similar technologies. With it, we also comply with the information obligation under "GDPR" - i.e. Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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).

Whenever you have questions about the Policy or the rules for processing personal data, you can direct your inquiry to us at the following email address: odo@olesinski.com.

The Policy applies to the processing of your data in situations where:

I. DATA CONTROLLER

A. OW Group

In the Policy, the term "administrator" is understood to mean the companies belonging to Olesinski i Wspólnicy Group (hereinafter: OW Group), each of In the Policy, the term "controller" is understood to mean the companies belonging to Olesinski i Wspólnicy Group (hereinafter: OW Group), each of which has its registered office in Wroclaw (50-024), at 40 Świdnicka St. Below is a list of OW Group companies with their contact information - in the Policy we refer to each of them as "Company" and collectively as "Companies".

OW Group companies, depending on the situation, can either act as independent personal data controllers or as joint controllers. We describe these situations below. For full transparency, we also indicate that OW Group Companies may act in other roles provided for by the GDPR - for example, as data processors in marketing activities or when running business social media profiles.

B. Separate controllers

Depending on which OW Group Company you contact, enter into a contract with, or conduct a business relationship with - that Company will be the controller of your personal data. This means that it independently and autonomously decides on the purposes and means of processing them.

C. Joint controllers

In some cases, with selected business processes, OW Group companies set these purposes  and means  jointly. In such a situation, they act as joint controllers. These processes include:

The companies, as joint controllers, have appointed a single point of contact so that you can conveniently contact them about processes where they are joint controllers . This is Olesiński i Wspólnicy ; e-mail: olesinski@olesinski.com, phone: (+48) 71 75 00 700, contact to Data Protection Officer Justyna Korycka: odo@olesinski.com.

For your information, Olesiński i Wspólnicy is the entity responsible for the exercise of your rights in the context of joint administration , while each of the joint administrators is responsible for fulfilling the information obligation under Article 13 and Article 14 of the GDPR.

II. DATA PROCESSING

Areas of data processingScope of data Purpose and legal basis of processing
BUSINESS RELATIONS AND ESTABLISHMENT OF CONTACTWe process the data of our clients and contractors and persons acting on their behalf or performing a contract, including employees and associates. We also process the data of others who provide us with information in the course of performing contracts or contacting us, e.g.,  by e-mail, contact forms on websites, telephone or surveys.
 
In this regard, we may process, among other things:
- identification and contact data (e.g. address, e-mail, telephone),
- data concerning job position and professional qualifications,
- other data provided to us in connection with cooperation or establishment of contact.		- Establishment of cooperation - including conclusion, execution and settlement of the contract.
 The legal basis is Article 6(1)(b) of the GDPR i.e. the necessity to perform the contract or to take action prior to its conclusion at your request.
 
- Conducting offering processes and relations with contractors/clients - including responding to inquiries, conducting further correspondence, as well as establishing, defending or pursuing potential claims.
 The legal basis is Article 6(1)(f) of the GDPR, i.e. our legitimate interest coinciding with the above purposes.
 
- Fulfillment of legal obligations - e.g. tax, accounting.
 The legal basis is Article 6(1)(c) of the GDPR, i.e. fulfillment of our legal obligations.
 
In addition, if you are a client of an OW Group Company, the General Terms and Conditions of Service provided by that Company may also apply to the processing of your data by that Company.
MARKETING ACTIVITIESAs joint controllers, we process your identification and contact data that you have provided to us in the context of marketing activities. This applies in particular to:
- newsletter subscriptions,
- sending our legal and tax alerts,
- participation in events organized by us (e.g. webinars, conferences).		- Conclusion and performance of a contract - including sending newsletters and our legal and tax alerts, and the organization of events.
The legal basis is Article 6(1)(b) of the GDPR, i.e. the necessity to perform the contract or to take action prior to its conclusion at your request.
 
- Ongoing communication in connection with organized events.
The legal basis is Article 6(1)(f) of the GDPR, i.e. our legitimate interest in ensuring the effective organization of events.
 
- Fulfillment of the internal administrative purposes of joint controllers - including for the purpose of personalizing content to your preferences and for statistical or analytical purposes (e.g. client opinion and satisfaction surveys, analysis for optimization of products, services and service processes, quality improvement).
The legal basis is Article 6(1)(f) of the GDPR - i.e. our legitimate interest in analyzing data for the optimization of processes and services and in carrying out administrative activities.
RECRUITMENTWe process data you provide to us as part of an application or recruitment process at OW Group. If you have given your consent, we may also use this data in future recruitment processes for similar positions.
 
In connection with recruitment, we may process, among other things:
- identification data,
- contact data (address, e-mail, telephone),
- data on education, skills and previous employment,
- data on professional qualifications,
- other data provided during the recruitment process.
 
We process some of the above data only after your consent.		- Reviewing applications and conducting the recruitment process - including, if the application is not for a specific advertisement, participation in recruitment for positions corresponding to your professional experience.
 The legal basis, depending on the basis of your employment, the scope of the data you provide and your willingness to participate in future recruitment, may be Article 6(1)(a), (b), (c) of the GDPR, i.e. consent, necessity for the performance of a contract or to take steps at your request prior to entering into a contract, or compliance with a legal obligation.

- Establishing, defending or pursuing potential claims.
The legal basis is Article 6(1)(f) of the GDPR, i.e. our legitimate interest in protecting our rights.
WEBSITEWe process data of persons using our websites. In this regard, we may process, among other things, your IP address and other identifiers and information collected through cookies or similar technologies.
 
For more information in this regard, see Section X of the Policy.		- Provision of electronic services - including providing access to content stored on the websites and use of certain functionalities.
The legal basis is Article 6(1)(b) of the GDPR - i.e. the necessity to perform a contract or take action prior to its conclusion at your request.
 
- Fulfillment of internal administrative purposes - including for statistical or analytical purposes, e.g. analysis of user activities and preferences in order to improve the functionality and quality of services provided.
The legal basis is Article 6(1)(f) of the GDPR - i.e. our legitimate interest in analyzing user activities and optimizing services.
SOCIAL MEDIAIn connection with the operation of business pages on social media (Facebook, Instagram, X, YouTube and LinkedIn), the Company or Companies may process, among other things, the following data:
- identification and contact data,
- data provided to us in private correspondence,
- system / statistical data, including user profiles,
- other data obtained in the course of operating business pages on the indicated platforms.
 
Within the framework of certain functionalities available on the indicated platforms (and the purposes of processing), OW Group Companies and entities operating these platforms may act as joint data controllers. Please refer directly to the individual platforms for details.		- Running business pages - including statistical and marketing activities (e.g., monitoring traffic, user activity, targeting ads and organizing contests, promotional activities and online events), ensuring security and proper moderation of content published on our profiles.
 The legal basis for the above is Article 6(1)(f) of the GDPR, i.e. our legitimate interest.
 
The rules of social media platforms and how these portals themselves process users' personal data (e.g. for their own business or marketing purposes) are regulated separately by their owners. Detailed information in this regard can be found in the privacy policies of the individual sites.

III. SOURCE OF DATA

Your data may be provided to us directly from you - for example, through a contact form, an inquiry, a "Contact Us" tab, e-mail, mail or a phone call.

It may also be provided to us by third parties, such as our clients or contractors, or from publicly available sources (e.g., commercial company registries).

IV. DATA PROCESSING PERIOD

The duration of data processing depends on the purpose and legal basis for processing. Typically, we process data for the duration of the contract or service.

If the basis for processing is consent - we process the data until it is withdrawn or until it is no longer valid. On the other hand, if the basis is our legitimate interest - we process the data for as long as that interest lasts or until an effective objection is lodged .

In some situations, the processing period may be longer than indicated above. This is the case when the processing is necessary for the establishment, defense or pursuit of claims, or when required by law (e.g. tax or accounting)

V. RECIPIENTS OF DATA

The recipients of your data may be OW Group Companies, as well as our business partners and other entities that support us in organizing work, marketing, handling correspondence, providing consulting, legal and accounting services, and maintaining and operating IT tools and systems.

If the obligation to share data is imposed by law, the recipients of your data may also be competent authorities.

VI. DATA TRANSFER

As a general rule, we process personal data within the European Economic Area (hereinafter: EEA). However, there may be situations in which it will be transferred to our partners who process it outside the EEA - but only to the extent necessary to cooperate with them. In such cases, your personal data will be transferred to countries for which the European Commission (hereinafter: EC) has determined an adequate level of protection, and in the absence of such a decision by the EC, we apply other safeguards permitted by law, including standard contractual clauses approved by the EC. You can obtain a copy of the safeguards applied in the transfer of your data to such countries by contacting us directly (contact information indicated in Section I).

VII. AUTOMATED DECISION-MAKING / PROFILING

We may conduct profiling activities. This may be used as part of our marketing purposes or those of third parties, particularly using marketing cookies and similar technologies, as described below in the Policy (Section X).

Profiling may involve personalising content, offers and communications to your needs and expectations. Please note that we do not make decisions that could have a significant impact on you and would be based solely on automated data processing.

VIII. OBLIGATION TO PROVIDE DATA

Provision of data is, as a rule, voluntary, but may be necessary to achieve the purposes of processing. In some cases, the provision of data is mandatory - but only when required by law. Refusal to provide data may result, among other things, in the inability to establish a business relationship or contact, or lack of access to our marketing activities, such as newsletters, legal and tax alerts.

In the case of recruitment, providing the data required by the Labor Code is mandatory in order to participate in the recruitment process. In other cases, the provision of data is voluntary, but the absence of some data (especially those necessary for the evaluation of your candidacy or the conclusion of a civil contract) may prevent the consideration of your candidacy and the conclusion of a contract. 

IX. RIGHTS OF DATA SUBJECTS

Under the provisions of law, you have the following rights regarding the processing of your personal data:

If we process your data on the basis of consent - you can withdraw it at any time. Withdrawal of consent does not affect the lawfulness of the processing that was carried out before its withdrawal.

In order to exercise your rights, you can contact us at the details provided in section I of the Policy.

X. COOKIES AND OTHER SIMILAR TECHNOLOGIES