This Policy also supplements the terms of using the webpages available at https://www.axians.pl (the “Website”)
As part of the performance, first of all, of the legal obligations under 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 the “GDPR”, we would like to inform you that the Controller of your personal data is ATEM-Polska Sp. z o.o., with its registered office in Gdynia, ul. Łużycka 2, 81-537 Gdynia, entered into the Register of Entrepreneurs of the National Court Register maintained by the District Court Gdańsk-Północ in Gdańsk, 8th Commercial Division of the National Court Register, under KRS (National Court Register) entry number 0000019400, NIP (Tax Identification Number) 5271033729, REGON (Polish Business Register Number) 011254858, share capital of PLN 4,000,000.00 (“ATEM-Polska”, “we”, “us”).
ATEM-Polska has appointed a Data Protection Officer, who is Mr Wojciech Michalski. In matters concerning personal data protection you can contact us by e-mail to firstname.lastname@example.org or in writing to the registered address of ATEM-Polska Sp. z o.o., with the note: “Data Protection Officer”.
Your provision of data in connection with the use of the Website or maintaining correspondence with us regarding offers or performance of contracts concluded with ATEM-Polska is voluntary, but provision of certain data may be necessary to analyse or prepare an offer, conclude and perform a contract with ATEM-Polska, provide you with an answer or fulfil our legal obligations, and accomplish other objectives, described in further parts of this Policy.
Purpose of the processing and legal basis for the processing of your personal data by ATEM-Polska
Depending on the situation, ATEM-Polska may process your personal data for the purposes and to the extent necessary to contact, conclude a contract, cooperate with ATEM-Polska and ensure security, in particular in the following events:
- Presentation of an offer, conclusion or performance of a contract with ATEM-Polska – the personal data of our Partners, Clients, Contracting Parties, Subcontractors, Suppliers, Service Providers and the persons designated by you (including your employees and associates), as well as the persons interested in the offer of ATEM-Polska are processed for the purpose of presenting an offer or concluding or performing a contract or on the basis of legitimate interests of ATEM-Polska, which is the direct marketing of products or services of ATEM-Polska (connected in particular with the construction, modernisation and operation of ICT, energy, radio and television networks), facilitating communication with you and preparing for the conclusion and performance of the contract. Additionally, we may process your personal data for the purpose of fulfilment of legal obligations, e.g. to issue an invoice or to ensure security during the performance of a contract. The provision of personal data is always voluntary, but it may be necessary for the conclusion and proper performance of the contract. In the events described above, ATEM-Polska will process your personal data no longer than the period in which we conduct economic activity, but no less than the term of the contract concluded with you and the duration of the proceedings, until the end of the year in which the legal claims relating to the performance of the contract for which it is necessary for ATEM-Polska to process personal data become barred by the statute of limitation, or as long as it is necessary to pursue a legitimate legal interest of ATEM-Polska or any third party.
- Persons contacting ATEM-Polska – the purpose of the processing of personal data is to communicate with the persons contacting ATEM-Polska. The legal basis for the processing of personal data is the legitimate interest of ATEM-Polska, consisting in facilitating communication, possible establishment of relations with the contacting person, providing necessary information. Depending on the content of the correspondence, the processed data may include first name, surname, e-mail address, telephone number, correspondence address and other information provided by the person contacting ATEM-Polska. The provision of personal data is voluntary; however, if personal data are not provided, the communication process may be hindered or prevented. In the event of requests for proposals, requests for products, requests for information and questions regarding the terms and conditions of the cooperation, we may retain your data for as long as ATEM-Polska conducts its economic activity, or until the contacting person requests that his/her data and content of the request be erased from the database, or as long as it is necessary to pursue the legitimate interests of ATEM-Polska or any third party.
- CCTV on the premises of ATEM-Polska and in its vicinity – on the premises of ATEM-Polska and in its vicinity we use CCTV cameras. Video surveillance (image recording) is necessary to ensure the safety of employees and other persons, protect property, control production (including goods and services) and maintain the secrecy of information (including classified information and personal data), the disclosure of which could expose ATEM-Polska to damage. The image recorded as a result of the operation of the CCTV is intended to increase the safety of all persons staying on the premises of ATEM-Polska or in its vicinity, to allow for detection of behaviours that are detrimental to ATEM-Polska, employees and other persons, or expose ATEM-Polska to losses, and it will not be used for any other purpose. The scope of information that may be processed, apart from the image of persons recorded on the surveillance device, includes, in particular, vehicle registration number, time and place of the event covered by the surveillance, behaviour of the persons whose image was recorded on the image-recording device. Video surveillance may be conducted on a 24/7 basis (or at selected times) in the areas and rooms marked in a visible and clear manner with appropriate signs and information boards. The CCTV does not cover sanitary spaces, cloakrooms, canteens or smoking rooms, unless it is necessary to pursue the legitimate interests specified above and does not affect the dignity or other personal interests. The images from CCTV cameras are recorded, and no sound is recorded. Camera records are retained for up to three months and then the data are erased, e.g. by overwriting the data on the recording device. Access to the CCTV system is provided to the entity providing security services on the premises of ATEM-Polska and in its vicinity, the external maintenance service provider, ATEM-Polska and authorised employees. Access by unauthorised employees or third parties to the image recording equipment is prohibited. The information obtained as a result of the surveillance or control may be provided to the competent authorities within the scope of the proceedings conducted by them, in accordance with the applicable laws and regulations. In the event that the image recordings constitute evidence in legal proceedings or ATEM-Polska has become aware that they may constitute evidence in the proceedings, the time limit set out in this Chapter shall be extended until the proceedings have been closed and a final and non-appealable judgment has been issued.
- Other legitimate interests of ATEM-Polska. Based on the legitimate interests of ATEM-Polska, ATEM-Polska may use functionalities on the Website to:
- conduct the research and analysis of your activity and activity of other Website users in order to improve the efficiency of its operation, assess users’ expectations and needs and improve the Website, introduce new products and services, as well as for statistical purposes,
- provide you with commercial information and marketing content, as well as technical information regarding products or services offered by us or our partners, to the extent permitted by law, including with your consent, through the various means of communication available,
- organise or co-organise promotional campaigns for Website users,
- communicate with you for purposes other than those directly relating to the possibility of concluding and performing the contract,
- ensure the security of the use of the Website, prevent fraud and abuse, and maintain the correctness and continuity of operation of the Website, including by making back-up copies,
- establish, exercise or defend legal claims of ATEM-Polska, and demonstrate the fulfilment by ATEM-Polska of its obligations under the applicable laws and regulations, including by developing and archiving registers and records under data protection legislation.
If, in any event, the legal basis for the processing is your consent or our legitimate interests, we will process your data for the period of conducting our economic activity or the duration of a relevant campaign, until you withdraw your consent or your objection based on your particular situation is accepted, respectively.
When processing your data for the purposes described above, ATEM-Polska does not profile you on the basis of the personal data being in its possession, i.e. ATEM-Polska does not use automated decision-making systems in relation to you.
ATEM-Polska takes technical and organisational measures aimed at ensuring the protection of the processed personal data that is appropriate to the threat and category of your data subject to the protection, in particular it secures data, in the technical and organisational terms, against disclosure to unauthorised persons, seizure by an unauthorised person or unlawfully, and against modification, loss, damage or destruction of data, by using, among others, SSL certificates on the Website.
As a rule, personal data processed by ATEM-Polska may only be accessed by authorised employees or associates of ATEM-Polska and persons authorised to maintain the Website who have been granted appropriate authorisations. Such personal data may also be accessed, to a reasonable extent, by entities that cooperate with us (or with us and you) at the time of the implementation of individual projects.
The personal data you provide may be made available to entities authorised to receive them under applicable laws and regulations, in particular to the competent judicial authorities.
In accordance with applicable laws and regulations, we would like to inform you that your data may be transferred by ATEM-Polska, to the extent necessary, to entities processing them on behalf of ATEM-Polska, in particular to carriers cooperating with ATEM-Polska, postal operators, entities operating and maintaining our IT systems and websites, professional advisors, banks and payment companies as well as accounting offices providing accounting services for ATEM-Polska. Such entities process data on the basis of a contract concluded with ATEM-Polska and only to the extent necessary to perform the services provided by the entities indicated above, in accordance with our instructions.
At the same time, we would also like to inform you that ATEM-Polska does not intend to transfer your data to third countries, outside the European Economic Area, unless it is justified by the circumstances of the contract performance, of which you will be informed by ATEM-Polska in advance. In addition, if the transfer of data to a third country proves necessary or justified, it will take place in accordance with the applicable laws and regulations.
Rights in relation to the processing of your personal data
Under the GDPR, you (the data subject) may have a number of rights arising from the processing of your personal data, including:
- the right to access your personal data, including the right to obtain a copy of such data,
- the right to request rectification (correction) of your personal data – if you notice that the data are incorrect or incomplete,
- the right to request erasure of your personal data (the ‘right to be forgotten’), provided that the data are no longer necessary for the purposes for which they were collected or otherwise processed, or you object to the processing of the data, or you withdraw the consent on which the processing is based and there is no other legal basis for the processing, or the data are processed unlawfully or must be erased in order to fulfil a legal obligation,
- the right to request the restriction of the processing of your personal data – if you indicate that your data are incorrect, the processing is unlawful, but you do not wish your data to be erased, if we no longer need your data but you need them to establish, exercise or defend legal claims, or if you object to the processing of your data – until it is determined whether the legitimate grounds for our processing of your data override the grounds for your objection,
- the right to the portability of your personal data – if the processing is carried out automatically on the basis of a contract concluded with you or on the basis of your consent.
You also have the right to object to the processing of your personal data, including profiling, if we process your data on the basis of a legitimate interest and the objection is justified by your particular situation. If the processing of your personal data is based on your consent, you have the right to withdraw the consent at any time, without affecting the lawfulness of the processing based on the consent before its withdrawal.
All requests concerning the exercise of the above rights may be made in writing or by e-mail to the addresses of ATEM-Polska indicated above. We will make every effort to respond to your requests without unnecessary delay, but no later than one month of their receipt, unless they appear to be numerous or complicated. All requests are free of charge, but if they appear to be manifestly unfounded or excessive, we may charge a reasonable fee, taking into account the cost of maintaining the communication or performing the requested action, or refuse to take actions in connection with the request.
If you believe that ATEM-Polska is violating the law by processing your personal data, please contact us, in accordance with the details provided above. Regardless of the above, you have the right to file a complaint with the supervisory authority, which is the President of the Personal Data Protection Office.
ATEM-Polska reserves the right to make changes, withdraw or modify the functions or features of the Website, as well as to cease to conduct its economic activity, transfer the rights to the Website and take any legal actions permitted under applicable laws and regulations. No activities carried out by ATEM-Polska may infringe the user’s rights.