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Polityka prywatności

I. INTRODUCTION

Data protection and information security have always been a priority in the activities of EMS PARTNER. As an organization that is responsible and aware, we strive to provide you with proper information regarding matters related to the processing of personal data, especially in light of the new regulations on data protection, including the 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 (“GDPR”). We are aware that information holds a specific value that needs to be adequately protected. With the security of your data in mind, this document presents key information regarding the legal basis for the processing of personal data, their utilization, and acquisition.

1. EMS PARTNER LLC

EMS PARTNER LLC, with its registered office at 14 Szyperska Street, Poznań 61-754, hereinafter referred to as the “Company,” is a team of qualified salespeople and engineers providing implementation and maintenance services for the solutions we deliver. We focus on IT security issues.

2. WHEN DOES THIS PRIVACY POLICY APPLY?

This privacy policy applies to all cases in which EMS PARTNER LLC is the data controller and processes personal data. This applies to both personal data obtained directly from the data subject and cases where we have obtained personal data from other sources. EMS PARTNER LLC fulfills its information obligations in both of the aforementioned situations, as specified in Articles 13 and 14 of the GDPR, respectively, in accordance with those provisions.

is the administrator of marketing processes (including managing social media accounts), IT (including information systems where personal data, including contractors, is stored), security incidents, and also coordinates the employee recruitment processes. The company also operates the website www.emspartner.pl and, as such, coordinates the processing of personal data submitted through forms on the website (e.g., through a contact form).

3. SCOPE, METHODS, AND PURPOSES OF DATA PROCESSING

We strive to ensure that all information regarding the methods and legal bases of processing personal data, as well as the purposes for which we process them, are clear and understandable. We encourage you to familiarize yourself with the list of personal data processing operations presented below.

II. PROCESSING OF PERSONAL DATA OF INDIVIDUALS VISITING WEBSITES OPERATED BY EMS PARTNER LLC OR USING SERVICES PROVIDED ELECTRONICALLY

  1. General Information

Every individual using our services electronically or visiting our website has control over the personal data they provide to us. We hereby inform you that the data we collect from users is limited to the necessary minimum required to provide services at the expected level.

  1. Cookies

To a limited extent, we may automatically collect personal data through cookies on our websites. Cookies are small computer data files stored on a computer, tablet, or smartphone for the purpose of using websites. “Cookies” typically contain the website’s name of origin, the duration of their storage on the device, and a unique number.

Visitors to the website will be presented with information about cookies in accordance with legal requirements until they accept/close this information. Information about accepting this notice will be stored in cookies on the visitor’s computer.

Our website and the services it offers use cookies for the following purposes:

  • Statistical purposes
  • Website and service configuration (enabling us to place functions and services on the website)
  • Authentication – informing users (including yourself) that they are logged in, enabling the website to display relevant information and functions
  • Analyzing and studying your (as a user of the portal) behaviors – this allows us to understand preferences related to the services we provide, as well as analyze, improve, and develop the products and services offered
  • Advertising – through cookies, we are able to deliver more interesting and personalized advertisements, which may appear in remarketing campaigns on platforms such as Facebook ADS, LinkedIn ADS, and Google ADS after you visit our website.

The collected information includes IP address, browser type, language, operating system type, internet service provider, information about the time and date of visit, and information transmitted to the website through the contact form.

The collected data is monitored by us. For this purpose, we use tools related to profiling contacts through a Marketing Automation system, and for website usage analysis, we utilize Google Analytics tools, which record your activity on the website.

Two types of cookies are used on the website: “session cookies” and “persistent cookies.” “Session cookies” are temporary files stored on the user’s device until logging out, leaving the website, or closing the web browser software. “Persistent cookies” are stored on the user’s device for a specified period or until they are deleted by the user.

The following types of cookies are used on the website:

  • “Essential” cookies, enabling the use of services available on the website
  • Security cookies, ensuring security
  • “Performance” cookies, allowing for the collection of information about the usage of websites
  • “Functional” cookies, enabling the “remembering” of user settings and personalization of the user interface

In many cases, web browsing software (web browser) by default allows the storage of cookies on the user’s device. Users of the website can change their cookie settings at any time. These settings can be changed to block the automatic handling of cookies in the web browser settings or to be notified each time a cookie is placed on the user’s device. Detailed information about the possibilities and methods of managing cookies is available in the software settings (web browser). Deleting or blocking cookies is always possible. Users of the website can do this personally in the appropriate settings of their web browser.

Please note that limiting the use of cookies may affect some functionalities available on the website.

Cookies placed on the user’s device may also be used by our advertising partners and collaborators.

  1. Submissions and Online Forms

Visitors to the EMS PARTNER LLC website have the option to contact the company by completing a contact form. When using the forms, it is necessary to provide personal data. This data is processed only within the scope and for the purpose for which it was provided, and with your explicit consent. Consent regarding contact forms is expressed through your deliberate action (implied consent), i.e., submitting the form and providing personal data.

  1. Use of Social Plugins

On the website www.emspartner.pl, we use Social Plugins (“Plugins”) from the social networks Facebook, LinkedIn, and Google. If a user interacts with a plugin, cookies are used to identify the user and initiate the request.

After activating the plugin, the user’s personal data is transferred to the respective plugin provider and stored on their servers. As the plugin providers primarily collect this data through cookies, we recommend deleting all cookies through the browser’s security settings.

EMS PARTNER LLC has no control over the data collected and the data processing processes, nor the knowledge of the full extent of data collection, the purpose of processing, or the storage period. We also have no information about the deletion of data collected by the plugin providers. Thanks to the plugin mechanism, users have the ability to integrate with social networks and other users, which allows us to improve our offering and make it more tailored to user preferences.

The legal basis for using plugins is defined in Article 6(1)(f) of the GDPR.

Further information regarding the purpose and scope of data collection and their processing by Facebook, LinkedIn, and Google can be found in the privacy policies of the respective plugin providers:

These policies also provide information about user rights and privacy protection settings.

  1. Photos

The photos and icons displayed on the website are owned by EMS PARTNER LLC or sourced from image and icon banks or purchased from agencies as materials for the website.

III. PROCESSING OF PERSONAL DATA OF INDIVIDUALS CONTACTING EMS PARTNER SP. Z O.O. TO OBTAIN INFORMATION ABOUT THE OFFER OR SHARE FEEDBACK REGARDING SERVICES, AS WELL AS INDIVIDUALS CONTACTING US TO ENTER INTO AN AGREEMENT

From individuals contacting EMS PARTNER LLC for the purpose of obtaining information about the offer, expressing their opinions or feedback, as well as contacting us with the intention of entering into an agreement, we collect the following personal data: name, email address, and phone number.

We kindly request that you do not provide any information containing special categories of personal data, as listed in Article 9(1) of the GDPR (information about race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information regarding physical or mental health, genetic data, biometric data, information about sexual life or sexual orientation, and criminal history). If you provide such information for any reason, it will constitute explicit consent for us to collect and use such information as specified in this document or as specified where the information was disclosed.

IV. PROCESSING OF PERSONAL DATA OF CUSTOMERS AND PROSPECTIVE CUSTOMERS

EMS PARTNER LLC processes personal data of its customers and prospective customers. Among them, there may also be personal data of contact persons on the side of customers and prospective customers (their employees). Such personal data is processed in the information systems used by EMS PARTNER LLC, including the CRM system. The personal data processed for these purposes may include, among others, the name and surname, employer’s name, position of the contact person, phone number, email address, or other business contact details.

V. PROCESSING OF PERSONAL DATA OF INDIVIDUALS VISITING THE BUSINESS PROFILE OF EMS PARTNER LLC

The data of users who have liked the business profile of EMS PARTNER LLC, available on Facebook at https://facebook.com/EMS-Partner-111507761277672 or LinkedIn at https://www.linkedin.com/company/ems-partner-sp-z-o-o-, will be processed for the purpose of administering and managing the aforementioned business profiles of EMS PARTNER LLC, communicating with users, including responding to inquiries, engaging in interactions, providing information about organized events, interesting updates, services, and products offered by the Administrator, and creating a community on Facebook. Therefore, EMS PARTNER LLC, as the Administrator of the business profiles, may generate anonymous statistical data regarding visitors to the pages using features provided by Facebook or LinkedIn. The legal basis for data processing is consent. Users voluntarily choose to like/follow/interact with the profile/page/group on the respective social media platform. The rules governing the EMS PARTNER LLC business profile on Facebook/LinkedIn are determined by the Administrator, while the rules of using the Facebook social media platform are governed by Facebook’s regulations (as the Joint Administrator), and LinkedIn’s regulations apply in the case of LinkedIn. At any time, you can stop following and even block the Administrator’s profile created on Facebook/LinkedIn. Due to the specific nature of the platforms used by the Administrator, blocking the user will result in no content created by the Administrator being displayed to you. Other content available on the specific social media platform is of a general nature. Withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal.

The Administrator processes publicly available personal data, such as name, surname, and general information, which are placed on the Users’ profiles and publicly accessible. The processing of other personal data is carried out by the Facebook/LinkedIn social media platform in accordance with its terms and conditions. Under no circumstances will the data of individuals who have liked the business profile of EMS PARTNER LLC on Facebook/LinkedIn be used for any purpose other than the one for which they were provided. Personal data may be transferred outside of Poland, the European Union, and the European Economic Area, within the scope of the functioning of these social media platforms.

In addition, the Administrator specifies that data from Facebook is collected through cookies, each of which contains a unique user code (they are active for two years and stored by Facebook on the hard drive of the computer or any other device of the visitors to the profile). The user code, which can be associated with the connection data of registered users on Facebook, is retrieved and processed when opening the business profile. Although these are anonymous data, EMS PARTNER LLC may request Facebook to process them in the following scope:

  • Demographic data (including age, gender, marital status, and occupational status trends)
  • Information about lifestyle and interests
  • Geographic data that allows for determining where to conduct special promotions or organize events and how to best target informational offerings.

Additional information regarding electronic correspondence

If you wish to send us an email message, please note that unencrypted email messages transmitted over the Internet are not sufficiently protected against unauthorized access by third parties.

VI. PROCESSING OF PERSONAL DATA OF JOB APPLICANTS

The data of job applicants is collected for the purposes of ongoing recruitment processes and taking steps prior to entering into an employment contract. The company may also process data if the job applicant has provided consent for processing, including for future recruitment purposes.

The personal data of job applicants will be processed by us during the recruitment process and for a maximum period of three years after its completion, i.e., until the possibility of making any claims has expired.

In the case where processing is based on consent for participation in future recruitment processes, personal data will be processed until the consent is withdrawn.

VII. LEGAL BASIS FOR PROCESSING

The processing of data of individuals visiting the website operated by EMS PARTNER LLC, using services provided electronically or expressing themselves on the business profile of EMS PARTNER LLC, on social media platforms is based on various legal bases for processing depending on the category of personal data we process and the purpose of processing. The personal data of individuals visiting our websites is processed based on the legitimate interests of the data controller (Article 6(1)(f) of the GDPR) or based on consent when we have requested consent from the individuals to whom the data relates (Article 6(1)(a) of the GDPR). The data of individuals who fill out an online/contact form is processed because it is necessary for the performance of a contract or to take steps prior to entering into a contract, at the request of the individual providing their data (Article 6(1)(b) of the GDPR), based on consent (Article 6(1)(a) of the GDPR), or based on the legitimate interests of the data controller, which include providing a response to the submitted question (Article 6(1)(f) of the GDPR). The data of individuals visiting our fan page is processed in accordance with the terms of use of the Facebook platform, based on the consent of the user (Article 6(1)(a) of the GDPR)..

The processing of personal data of individuals contacting EMS PARTNER SP. Z O.O.

For the purpose of obtaining information about the offer or sharing feedback regarding services, as well as contacting for the purpose of entering into a contract, it is based on the consent expressed by the user initiating the above request to EMS PARTNER LLC (Article 6(1)(a) of the GDPR) or for the performance of a contract (fulfillment of the request) submitted by the individual (Article 6(1)(b) of the GDPR). The provided data may also be processed based on the legitimate interests of the data controller (Article 6(1)(f) of the GDPR).

  1. The processing of personal data of individuals who are potential clients is based on:

a) the legitimate interests of EMS PARTNER LLC as the data controller (especially in terms of creating a database, direct marketing of own products); (Article 6(1)(f) of the GDPR);

b) consent (including consent for email marketing or telemarketing); (Article 6(1)(a) of the GDPR).

VIII. DATA RETENTION PERIOD

EMS PARTNER SP. Z O.O. processes personal data and retains it for a period determined by the legal basis that constitutes a lawful ground for processing personal data. Please be informed that EMS PARTNER SP. Z O.O. processes personal data based on:

Consent: The processing period lasts until the consent is withdrawn by the individual to whom the data relates or the purpose of processing is fulfilled.

Legitimate interests of the data controller: The processing period lasts until the aforementioned interest ceases (e.g., the statutory limitation period for civil claims) or until the individual to whom the data relates objects to further processing, provided that such objection is in accordance with legal regulations.

Compliance with legal obligations: The processing periods for data in this case are determined by the relevant legal provisions.

In the absence of specific legal or contractual requirements, the basic data retention period for records and other evidentiary documentation prepared during the execution of a contract is a maximum of 6 years.

IX. DATA RECIPIENTS

We disclose personal data to other entities based on legal requirements or in connection with the fulfillment of the purpose for which the data was provided to us. At the same time, we declare that we only use services of reliable and well-known entities on the local market that provide guarantees for data security. The agreements under which we entrust the processing of personal data contain provisions regarding the required security measures ensuring the confidentiality, integrity, and availability of the transferred data.

We may disclose personal data to trusted business partners who provide services on behalf of EMS PARTNER SP. Z O.O., as well as to entities with whom we cooperate. Additionally, data may be disclosed to service providers such as debt collection, tax, legal, and accounting services. Personal data is only disclosed to these entities and other third parties if it is necessary to perform the services requested or authorized by the individuals to whom the data relates, to protect rights, property, or safety, or if the Company is obligated to do so under applicable laws, court orders, or regulations of other authorities, or if the disclosure of personal data is otherwise necessary to support legal or criminal proceedings.

Furthermore, authorized employees of the company will have access to personal data.

X. RIGHTS RELATED TO THE PROCESSING OF PERSONAL DATA

The rights of individuals regarding the processing of personal data include:

a) The right to access their personal data;

b) The right to rectify data;

c) The right to restrict the processing of data;

d) The right to request the erasure of data;

e) The right to data portability to another data controller.

The aforementioned rights can be exercised by contacting us via email at rodo@emspartner.pl or by postal mail to EMS PARTNER SP. Z O.O., ul. Szyperska 14, Poznań 61-754.

Individuals have specified rights regarding their personal data, and EMS PARTNER SP. Z O.O., as the data controller, is responsible for fulfilling these rights in accordance with applicable laws.

We would also like to inform you that each individual has the right to object to the processing of their personal data. In the case of personal data processed based on a legitimate interest, an individual has the right to object for reasons relating to their particular situation. If this right is exercised, the Company will cease processing the data for that purpose, unless it can demonstrate compelling legitimate grounds for the processing that override the interests, rights, and freedoms of the individual, or for the establishment, exercise, or defense of legal claims.

The right to object can be exercised by emailing rodo@emspartner.pl or by sending a letter to EMS PARTNER SP. Z O.O., ul. Szyperska 14, Poznań 61-754.

XI. CHANGES TO THIS PRIVACY POLICY

We are committed to regularly reviewing this Privacy Policy and making changes when necessary or desirable due to new legal requirements, guidelines from authorities responsible for supervising personal data protection processes, or best practices in the field of personal data protection.