Privacy Policy - Firma w Niemczech

1. INTRODUCTORY PROVISIONS

The controller of your personal data, within the meaning of personal data protection laws, is Consulting Pohl, located in Görlitz (02826), Berliner Str. 22, registered in the Görlitz business register, with tax number St.Nr.: 207/212/02365 (hereinafter referred to as “CONSULTING POHL”). This means that we are responsible for using your data in a secure manner and in compliance with applicable regulations, in particular 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 referred to as “GDPR.”
This document (hereinafter referred to as the “Privacy Policy”) provides information on the principles of processing and protecting personal data collected by CONSULTING POHL from individuals whose data is processed in connection with their use of CONSULTING POHL’s services (including those provided electronically), inquiries addressed to CONSULTING POHL, the offer process, participation in conferences, webinars, and other similar events organized by CONSULTING POHL, participation in CONSULTING POHL’s recruitment processes, subscription to the Newsletter or other information channels about CONSULTING POHL’s products and services, as well as correspondence exchange, including but not limited to users of our website.
The Privacy Policy is for informational purposes only, which means it does not create any obligations for individuals whose personal data is processed in accordance with its provisions. One of its main functions is to fulfill the information obligation referred to in Article 13 of the GDPR.
CONSULTING POHL is aware of the importance of protecting children’s privacy, especially online. CONSULTING POHL’s websites are not intended for children under the age of 13. One of CONSULTING POHL’s principles in this regard is to refrain from knowingly collecting or storing data about individuals under the age of 13, except in cases where such data is part of activities related to the provision of professional services.
Links posted on CONSULTING POHL’s websites may redirect users to other websites, including those of companies cooperating with CONSULTING POHL. These websites may have their own privacy policies, which may differ from this one. We encourage users to carefully review the privacy policy of each website they visit before providing any personal data.

2. PURPOSES AND LEGAL BASIS FOR THE PROCESSING OF PERSONAL DATA

CONSULTING POHL collects only the personal data necessary to achieve the purposes for which the data was obtained. If additional optional information is required, users are notified before such information is collected.
When contacting CONSULTING POHL via online communicators, email, phone, or by filling out an Information Form, you provide personal data such as your full name, personal identification number (PESEL), phone number, email address, company name, company address, company tax number (NIP), residential address, bank details, or other information necessary for CONSULTING POHL to provide the requested service.
The personal data collected by CONSULTING POHL is processed for the following purposes, depending on the situation in which the data was provided:
1. to conclude and perform the contract between us, to the extent necessary to establish, define, amend, terminate, and properly execute the services provided by CONSULTING POHL;
2. to fulfill our legal obligations, such as issuing and storing invoices and accounting documents, responding to complaints, and ensuring the security of the services provided;
3. to establish, exercise, and defend legal claims;
4. for the direct marketing of CONSULTING POHL’s products and services;
5. to create reports, analyses, and statistics for CONSULTING POHL’s internal purposes, including reporting, marketing research, ad targeting, remarketing, service development planning, IT system development, creating statistical models, and evaluating the performance of CONSULTING POHL’s website, including subpage view statistics;
6. if you consent to receiving commercial information from CONSULTING POHL by electronic means, your personal data will also be processed for the purpose of sending you information about our services, offers, and events we organize, as well as information about the products and services of our partners (with our knowledge and your explicit consent).
Personal data is not used for purposes other than those specified in this Privacy Policy, unless CONSULTING POHL obtains your consent to process the data for other purposes or such use is required or permitted by law.
To the extent that the processing of your personal data is necessary to:
1. perform the contract concluded with you or take steps at your request prior to entering into the contract — the legal basis for the processing of your personal data by CONSULTING POHL is the contract;
2. comply with a legal obligation imposed on us — the legal basis for processing is that legal obligation;
3. purposes arising from the legitimate interests pursued by CONSULTING POHL, such as the direct marketing of our products and services, fraud prevention, or the establishment and defense of claims — the legal basis is CONSULTING POHL’s legitimate interest.
Providing your personal data is not mandatory; however, failure to do so will prevent CONSULTING POHL from carrying out the activities for which the data is required.

3. YOUR RIGHTS

Every individual whose personal data is processed by CONSULTING POHL has the right to access their personal data and to have any inaccurate data corrected without delay. Taking into account the purposes of processing, the data subject also has the right to request the completion of incomplete personal data, including by providing an additional statement.
If you have given consent for the processing of your data, particularly for marketing purposes (including receiving commercial information by electronic means), you may withdraw your consent at any time. A user receiving specific information or services, such as an electronic newsletter, may unsubscribe at any time by following the instructions included in each message sent.
Any person who provides their personal data to CONSULTING POHL has the right to request the immediate deletion of their personal data, and CONSULTING POHL is obliged to delete the data without undue delay if one of the following circumstances applies:
1. the personal data is no longer necessary for the purposes for which it was collected;
2. the data subject has withdrawn the consent on which the processing is based, and there is no other legal basis for the processing;
3. the data subject objects to the processing;
4. the personal data has been processed unlawfully;
5. the personal data must be deleted in order to comply with a legal obligation under European Union law or the law of a Member State to which CONSULTING POHL is subject.
Individuals who provide their personal data to CONSULTING POHL have the right to request the restriction of personal data processing in the following cases:
1. the data subject contests the accuracy of the personal data — for a period enabling CONSULTING POHL to verify the accuracy of the data;
2. the processing is unlawful, and the data subject opposes the deletion of the personal data and requests the restriction of its use instead;
3. CONSULTING POHL no longer needs the personal data for processing purposes, but it is required by the data subject for the establishment, exercise, or defense of legal claims;
4. the data subject has objected to the processing — pending the verification of whether CONSULTING POHL’s legitimate grounds override those of the data subject’s objection.
If the processing of personal data by CONSULTING POHL is carried out by automated means based on consent or a contract, the data subject has the right to receive the personal data they provided to CONSULTING POHL in a structured, commonly used, and machine-readable format and has the right to transmit this data to another controller. The data subject also has the right to request that CONSULTING POHL transfer the personal data directly to another controller, where technically feasible.
To exercise the rights mentioned above, you may contact CONSULTING POHL using the method indicated in Section 8 below.
CONSULTING POHL will inform each recipient to whom personal data has been disclosed of any rectification, erasure, or restriction of processing carried out at your request, unless this proves impossible or would involve a disproportionate effort.
In connection with the processing of your personal data by CONSULTING POHL, you have the right to lodge a complaint with a supervisory authority.

4. RECIPIENTS OF YOUR PERSONAL DATA

We share your data with:
1. entities processing data on our behalf, involved in carrying out our activities:
  1. our sales representatives, advertising agencies, and other entities involved in the sale of our services or the organization of marketing campaigns;
  2. those operating our IT systems or providing us with IT tools;
  3. subcontractors supporting us, for example, in performing the services you have ordered, handling correspondence, or in the customer service process;
  4. entities providing us with advisory, consulting, auditing, legal, tax, and accounting services, as well as research agencies acting on our behalf;
2. entities authorized under the law (e.g., the tax office, prosecutor’s office, court — if they request it)
3. other data controllers processing data on their own behalf:
  1. entities engaged in postal or courier services;
  2. entities purchasing receivables — in the event of non-payment of our invoices by you on time;
  3. entities cooperating with us in handling accounting, tax, legal, and consulting matters — to the extent that they become the data controller.
Currently, CONSULTING POHL does not plan to transfer your data outside the EEA (which includes the European Union, Norway, Liechtenstein, and Iceland). However, it may happen that during the term of the contract, we decide to transfer data outside the EEA — only to the extent permitted by law.
CONSULTING POHL may disclose personal data at the request of authorities or law enforcement agencies, or when required by applicable laws, court orders, or other governmental regulations. The need to disclose personal data may also arise during data privacy or security audits and/or in the course of handling complaints or addressing security threats. CONSULTING POHL does not sell personal data to third parties and does not entrust the processing of users’ personal data to third parties for their marketing purposes.

5. RETENTION PERIOD OF PERSONAL DATA

Your personal data will be stored no longer than necessary, depending on the purpose of its processing:
1. for the conclusion and performance of the contract between you and CONSULTING POHL — for the duration of the contract and the settlement period after its termination;
2. for the fulfillment of a legal obligation imposed on CONSULTING POHL:
  1. for the duration of the performance of the obligations;
  2. for the period required by law to store the data (e.g., tax data); or
  3. for the period during which we may face legal consequences for failing to meet an obligation, such as receiving a financial penalty from government authorities;
3. for purposes arising from the legitimate interests pursued by CONSULTING POHL:
  1. for the direct marketing of our products and services — for the duration of the contract and after its termination — for the period during which you benefit from the results of the services we have provided;
  2. for fraud prevention — for the duration of proceedings before the competent authorities;
  3. for the establishment and defense of claims — for the period during which such claims may become time-barred.

6. AUTOMATED DATA COLLECTION

COOKIES. USAGE DATA. GOOGLE TOOLS

When using the CONSULTING POHL website, user data is also collected automatically. This data may be gathered in the system logs of the website through so-called cookies. Cookies are small text files containing information that are sent by the server and stored on the visitor’s device (e.g., hard drive of a computer or laptop, or on a smartphone’s memory card).
By storing cookies on the user’s device (computer, smartphone, tablet, etc.), CONSULTING POHL can, among other things:
1. Adjust the website’s functionality to your needs.
2. Eliminate the need to log in during each visit to the website (for areas intended for registered users/clients).
3. Remember your settings from session to session.
4. Increase the website’s speed and security.
5. Personalize the website according to your needs and enable users to find the information they need more quickly.
6. Continuously improve the website with users in mind.
7. Increase the effectiveness of marketing activities.
Cookies do not contain any information that identifies the user, and they cannot be used to determine anyone’s identity. These files are not in any way harmful to the user’s device and do not change its settings or the settings of any installed software. Their contents can only be read by the server that created them.
While using our websites, CONSULTING POHL employs three types of cookies: session, persistent, and marketing cookies. Session cookies are temporary files stored on the user’s device until they log out, leave the website, or close the browser. Persistent cookies are stored on the user’s device for the period specified in their parameters or until the user deletes them. Marketing cookies are files stored by external scripts used on our websites. We use them mainly for remarketing purposes (see points 6.11–6.15 below).
By default, most web browsers available on the market accept the storage of cookies. Users can change their cookie settings at any time, specifying how cookies are stored and how they access the user’s device. These settings can be adjusted through the web browser settings or service configuration. In particular, users can configure their browser to block automatic handling of cookies or to notify them each time cookies are placed on their device. Detailed information on how to manage cookies is available in the software (browser) settings.
The user may delete cookies at any time using the available functions of the web browser they are using.
Restricting the use of cookies may affect some of the functionalities available on the Consulting Pohl websites.
Detailed information on how to change cookie settings and delete cookies in the most popular web browsers is available in the browser’s help section.
CONSULTING POHL also processes anonymized usage data related to the use of its websites (so-called logs — IP address, domain) to generate statistics that help administer the sites. From the moment a user connects to the website, the system logs record information about the number (including IP) and type of the user’s device used to connect to the website. This data is aggregated and anonymous, meaning it does not contain information identifying visitors. The logs are not shared with third parties.
CONSULTING POHL may use the Google Analytics service, which collects anonymous information about the pages of CONSULTING POHL’s websites you visit through the use of cookies. Detailed information on Google Analytics’ privacy policy can be found at: http://www.google.com/intl/pl/analytics/privacyoverview.html.
Additionally, CONSULTING POHL may use Google AdWords and Google Analytics remarketing codes from display advertisers. These codes are used to create remarketing lists in order to tailor personalized ads to users who have visited our websites and then display those ads within the Google AdWords advertising network, Google search engine, and on the websites of Google’s partner network participants.
The user has the option to opt out of the collection of remarketing codes through Google AdWords and Google Analytics, as well as display advertiser codes, and to disable personalized ads in the Google advertising network in the manner described in Section 6.5 above.
The CONSULTING POHL website may use remarketing services provided by Facebook Ireland Ltd (“Facebook”). These services enable us to advertise our products and services to users of our websites in a targeted way, based on their interests when using the Facebook social network. The Facebook remarketing tag is integrated into the website to provide this service. Additional information on how Facebook collects and uses data, as well as users’ rights and privacy protection options, can be found in Facebook’s Privacy Policy: https://www.facebook.com/privacy/explanation. If you do not want Facebook to collect information about you, you can disable this service. To do so, you must be logged in to your Facebook account.
The CONSULTING POHL website may include features that allow content sharing through third-party social media applications, such as the Facebook “Like” button, Twitter widget, or Google+ widget. All of these social media applications may collect and use data regarding users’ activity on the CONSULTING POHL website. Any personal data provided by users through such social media applications may be collected and used by other users of those applications, and interactions carried out through them are subject to the privacy policies of the companies that provide these applications. We have no control over and are not responsible for these companies or their use of users’ data.

PERSONAL DATA SECURITY

CONSULTING POHL declares that it makes every effort to ensure a high level of security for the personal data it processes. Any incidents affecting data security, including suspected distribution of files containing viruses or other harmful files or mechanisms, should be reported to CONSULTING POHL’s appointed Data Protection Officer at the email address provided in Section 8 below.
CONSULTING POHL applies technical and organizational measures to ensure the protection of processed personal data appropriate to the risks and categories of data being protected. In particular, it safeguards the data against unauthorized access, acquisition by unauthorized persons, processing in violation of applicable regulations, as well as alteration, loss, damage, or destruction. In addition, CONSULTING POHL takes special care to ensure that personal information is:
1. accurate and processed in accordance with the law,
2. obtained only for specified purposes and not further processed in a manner incompatible with those purposes,
3. adequate, relevant, and not excessive,
4. accurate and up to date,
5. not kept longer than necessary,
6. processed in accordance with the rights of the individuals concerned, including the right to restrict disclosure,
7. securely stored,
8. not transferred without appropriate protection.
Personal data is stored in a database that uses technical and organizational measures ensuring the protection of processed data in accordance with the requirements set by applicable personal data protection laws. Access to the database is granted only to individuals authorized by the data controller.
CONSULTING POHL applies appropriate policies and procedures to protect personal data against unauthorized loss, misuse, alteration, or destruction. We make every effort to ensure that access to users’ personal data is limited to those who need to know this information. Individuals who have access to the data are required to maintain its confidentiality. Additionally, one of CONSULTING POHL’s key principles in this regard is to store personal information only for as long as it is necessary to handle the user’s request or until the user requests the deletion of such information.

8. CONTACT

For matters related to the processing of personal data, you may contact CONSULTING POHL as the data controller at Berliner Str. 22, 02826 Görlitz, or by email at:
info@firma-w-niemczech.pl.

9. CHANGES TO THE PRIVACY POLICY

CONSULTING POHL may make changes to this document to reflect the current Privacy Policy. In the event of modifications, the date of the last update shown below will also change.

Date of last update of the Privacy Policy: 24 May 2018