Privacy and Cookie Policy

What is a Privacy Policy?

At ETL Polska, we take special care to ensure that the personal data we collect is processed in accordance with the law and in a manner that ensures the appropriate security of personal data.

This Privacy Policy is intended for users of the website www.etl.pl (the “Website”) and is provided for informational purposes. It primarily sets forth the rules governing the processing of personal data, including the legal basis, purposes, and scope of such processing, as well as the rights of data subjects.

ETL Polska

The Controller of the personal data provided while using the Website is ETL Polska Spółka Akcyjna, with registered office in Warsaw, Twarda 18, 00-105 Warsaw, entered in the Register of Entrepreneurs maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number: 0000588351, REGON number: 363084903 and NIP: 9571082183, share capital: 1,000,000.00 PLN (“ETL Polska”; “Controller”)

What personal data do we process?

We primarily process personal data that you provide to us directly – for example, when you contact us, use the forms available on the Website, subscribe to the newsletter, participate in events, or use other features of the Website.

We limit the scope of the data we process to the information necessary to achieve a specific purpose. Depending on how you use the Website or contact us, we may process, in particular:

• When you contact us via the contact form, email, phone, or other contact information available on the Website – your first and last name, email address, phone number, and any other information you voluntarily provide to us;
• When you subscribe to the newsletter or receive other marketing information – your first name and email address;
• When participating in events, training sessions, webinars, or other initiatives organised or co-organised by ETL Polska – data necessary for registration and managing your participation in a given event, specifically your first and last name, contact information, job title, or information regarding the organisation you represent, if required;
• When participating in the recruitment process – data contained in application documents and other information you provide in connection with your application;
• When using the Website – information regarding how the Website is used, as well as technical data related to your device and connection, to the extent necessary to ensure the proper functioning, security, and development of the Website.

We may also receive personal data when you contact us or interact with ETL Polska through our social media profiles or other communication channels.

If you provide us with additional information on your own initiative, please limit it to the data necessary for the specific matter at hand.

Why and on what basis do we process personal data?

Data is processed in accordance with currently applicable laws, namely 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) (“GDPR”), the Act of May 10, 2018, on the Protection of Personal Data, as well as other applicable laws.

We process personal data exclusively for specific purposes and only to the extent necessary to achieve them.

Depending on how you use the Website or contact us, we may process your personal data, in particular, for the following purposes:

• Contact and handling correspondence, including responding to questions submitted via the contact form, email, or other available communication channels – pursuant to Article 6(1)(f) of the GDPR, i.e., our legitimate interest in conducting correspondence, and in the case of contact aimed at concluding or performing a contract;
• Sending the newsletter, if you choose to receive it – pursuant to Article 6(1)(a) of the GDPR, i.e., your consent;
• Conducting marketing activities related to ETL Polska’s services, including presenting our offerings and providing information about services, events, publications, reports, training sessions, and other initiatives organised or co-organised by ETL Polska – based on Article 6(1)(a) of the GDPR, i.e., consent granted, or Article 6(1)(f) of the GDPR, i.e., our legitimate interest in promoting ETL Polska’s services and building and developing relationships with customers and individuals interested in our activities – depending on the type of marketing activities undertaken and the method of communication with you;
• Organising events, in particular webinars, conferences, training sessions, meetings, and other events, including handling registrations, contacting participants, and providing organisational information – based on Article 6(1)(a) of the GDPR, i.e., consent granted, Article 6(1)(b) of the GDPR, if processing is necessary to take steps at your request or to perform a contract, or Article 6(1)(f) of the GDPR, i.e., our legitimate interest, depending on the nature of the event and the basis for participation;
• Conducting recruitment processes if you apply for a position for which we are recruiting or otherwise provide us with information regarding your candidacy – pursuant to Article 6(1)(c) of the GDPR to the extent that processing is necessary to comply with legal obligations, in particular labour law provisions, Article 6(1)(b) of the GDPR to the extent necessary to take steps at your request prior to entering into a contract, and Article 6(1)(a) of the GDPR if the processing is based on your consent;
• Ensuring the proper functioning and security of the Website, including analysing how the Website is used, preventing abuse, detecting threats, and resolving technical errors – pursuant to Article 6(1)(f) of the GDPR, i.e., our legitimate interest in ensuring the security, proper functioning, and maintenance of the Website;
• Adapting the Website’s content to users’ needs, including analysing how the Website is used, in order to better understand users’ needs and develop the Website in a way that meets their expectations – pursuant to Article 6(1)(f) of the GDPR, i.e., our legitimate interest in developing the Website and improving the quality and usability of the content and features offered on it, provided that the technologies used do not require prior user consent;
• Establishing, pursuing and defending legal claims by the Controller or the data subject – pursuant to Article 6(1)(f) of the GDPR, i.e., our legitimate interest in establishing, pursuing, and defending against claims.

How do we collect personal data?

We collect personal data primarily directly from you – when you use the Website, contact us, or otherwise provide us with your data.

This may occur, in particular, when you use the contact form available on the Website, subscribe to the newsletter, contact us directly via email, phone, traditional mail, or other available communication channels; when you register for or participate in an event, training session, webinar, or other initiative organised or co-organised by ETL Polska; or when you participate in the recruitment process or otherwise provide us with information regarding your application.

Certain information related to your use of the Website may also be collected automatically, in particular technical data regarding your device, connection, or how you use the Website. You can find more information on this topic in the section on cookies and similar technologies.

Do you have to provide us with your personal data?

Providing personal data is generally voluntary. In some cases, however, it may be necessary to use certain features of the Website, receive a response to an inquiry you’ve submitted, subscribe to the newsletter, participate in an event or recruitment process, or to enter into or perform a contract.

Failure to provide the data necessary to achieve a given purpose may result in our inability to take certain actions, such as responding to your inquiry, sending you the newsletter, registering you for an event, or taking steps to enter into a contract.

If the obligation to provide certain data stems from legal provisions or a concluded contract, we will inform you of this as appropriate.

How long do we process personal data?

The period for which we process personal data depends on the purpose for which it was collected. We retain the data no longer than is necessary to fulfil that purpose.

Depending on the legal basis and purpose of the processing, we may retain personal data for the period necessary to perform a contract or take steps prior to entering into a contract, until consent is withdrawn (notwithstanding that the withdrawal of consent does not affect the lawfulness of processing carried out prior to such withdrawal) or until an objection to the processing of personal data is raised, as well as for the period required by applicable law. If the data may be needed to establish, pursue, or defend against claims, we may retain it until the relevant statutes of limitations expire or until the proceedings concerning such claims are finally resolved.

Who can your personal data be disclosed to?

In connection with our business operations, we may disclose your personal data to entities that assist the Controller in providing services, operating the Website, and fulfilling the other purposes described in this privacy policy.

Depending on the circumstances, these may include, in particular:

• IT and technology service providers, including entities providing hosting, Website maintenance, IT systems, and technical support,
• entities supporting us in marketing and communication activities, including marketing agencies,
• entities supporting the organisation of events, including training sessions, webinars, conferences, and other events organised or co-organised by ETL Polska,
• external advisors and service providers, in particular entities providing legal, auditing, accounting, or administrative services,
• subcontractors and other service providers we use in connection with the provision of our services or the conduct of our business,
• postal operators, courier companies, and other providers of mail-handling services.

Your data may also be disclosed to public authorities or other entities authorised to receive it under applicable law, if they make a valid request or if the obligation to disclose the data arises from legal provisions.

We disclose personal data to entities that process it on our behalf only to the extent necessary for them to perform the tasks entrusted to them.

ETL Polska operates a nationwide network of law firms and consulting companies specializing in accounting, human resources and payroll, legal and business consulting, audit and tax advisory services. You can find information about the entities operating within ETL Polska in the About Us tab.

If your inquiry concerns services provided by one of the companies in the ETL Polska group, we may share your personal data and the content of your inquiry with that company to the extent necessary to handle your request – specifically, to provide a response, prepare an offer, or establish contact regarding potential cooperation.

What are your rights regarding personal data?

In connection with the processing of your personal data, you have certain rights such as:

• the right to access your personal data, including obtaining information about its processing and receiving a first copy of the data free of charge,
• the right to rectify the data if it is inaccurate or incomplete,
• the right to have your personal data erased – if there are no circumstances that justify its continued processing, in particular when applicable laws do not require its continued storage,
• the right to data portability if its processing is carried out by automated means based on your consent or a contract,
• the right to withdraw your consent to the processing of personal data – where the processing is based on your consent. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal,
• the right to object to the processing of personal data – if we process it based on our legitimate interest – as well as to restrict data processing in cases specified by law,
• the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you,
• the right to information about the processing of your data, in particular regarding the data Controller, the purposes and methods of processing, the scope of the data being processed, its source, and the recipients or categories of recipients to whom the data has been or may be disclosed.

The data subject also has the right to lodge a complaint with the Polish Office for Personal Data Protection (Urząd Ochrony Danych Osobowych – UODO) if the processing of data violates the provisions of the GDPR.

Transfer of Personal Data Outside the European Economic Area (EEA)

Personal data may be processed by service providers whose headquarters or IT infrastructure, including servers, are located outside the European Economic Area (EEA), in particular in the United States of America (USA).

In the case of data transfers to third countries for which the European Commission has not issued an adequacy decision confirming an adequate level of protection, the Controller ensures the appropriate safeguards required by the GDPR, in particular by applying the standard contractual clauses adopted by the European Commission or other mechanisms provided for in Chapter V of the GDPR.

In the case of U.S. providers participating in the EU–US Data Privacy Framework, the transfer of data is based on the European Commission’s decision of July 10, 2023, recognizing the adequate level of protection for personal data provided under the EU–US Data Privacy Framework.

Social Media

ETL Polska maintains social media profiles, specifically on Facebook and LinkedIn. In connection with the use of these profiles, we may process personal data that you provide by following our profiles, reacting to published content, posting comments, or contacting us.

Personal data processed in connection with the use of social media may also be processed outside the European Economic Area (EEA), in accordance with the rules applied by the operators of individual social media platforms. Detailed information regarding the data processing rules of individual platform operators is available in their privacy policies.

Cookies

The Website uses cookies and similar technologies that allow information to be stored on or retrieved from the device you use when visiting the Website.

Cookies are pieces of data – most often in the form of text files – stored on the user’s device, such as a computer, tablet, or smartphone.

The information collected through cookies may be used, in particular, to ensure the proper and secure operation of the Website, to remember your selected settings and preferences, to analyse how the Website is used, and – if you give your consent – to conduct marketing activities and customize the content displayed.

What types of cookies do we use?

Cookies may be temporary – that is, they are deleted when you close your browser – or persistent. Persistent cookies remain stored even after you stop using the Website and allow us to remember the settings you have selected and to personalize the user interface.

The Website may use the following types of cookies:

• essential – they enable the use of services available on the Website,

• functional – they allow the Website to “remember” the settings selected by the user and personalize the Website,
• analytical – they enable monitoring of user activity on the Website.

Detailed information regarding the cookies used, including their purpose, provider, and duration, is available in the cookie settings.

The Website uses cookies for the following purposes:

• to personalise the content of the Website’s pages to the user’s individual preferences and to optimize the user experience (customized display – functional cookies),
• to conduct analyses and compile statistics that provide information on how Website users interact with the pages, which enables us to improve their structure and content,
• for marketing and/or remarketing purposes, including delivering targeted content, particularly to users who have visited the Controller’s website or fan page on the Facebook or LinkedIn social media platforms.

The data contained in cookies is archived and used for statistical analysis and to assess overall user traffic on the Website. The data contained in cookies is not combined with the personal data provided by the user when contacting the Controller.

Consent to the use of cookies

When you visit the Website, you can accept the use of cookies for the purposes listed above, reject them, or consent only to selected cookies.

We use non-essential cookies only after obtaining your consent. On your first visit to the Website, you can accept all optional cookies, reject them, or select which types of cookies you consent to.

You can change your cookies preferences or withdraw your consent at any time using the cookie settings available on the Website.

You can also manage cookies through your web browser settings, including deleting stored cookies or limiting their storage. Restricting the use of certain cookies may affect the functionality of selected features on the Website.

Contact with the Data Controller

You may contact the Data Controller regarding matters related to the protection of personal data through the Data Protection Officer.

The Data Protection Officer assists the Data Controller in ensuring the proper processing of personal data and is the person you can contact if you have questions regarding the processing of your personal data or the exercise of your rights related to such processing. The Data Protection Officer is Hanna Rubaszewska, email: hanna.rubaszewska@etl.pl.

Changes to the Privacy and Cookie Policy

The Privacy and Cookie Policy may be updated periodically, particularly in the event of changes to applicable laws, the Website’s operations, the technologies used, or our rules for processing personal data.

The current version of the Privacy and Cookie Policy is always available on the Website. In the event of significant changes regarding the processing of personal data, we will notify you accordingly.