Privacy and Cookie Policy
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What is this privacy policy?
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As ETL Polska, we take particular care to ensure that the personal data we collect is processed lawfully and in a manner that ensures appropriate security of personal data.
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This privacy policy is addressed to users of the website www.etl.pl (the „Website”) and is informational in nature. It primarily sets out the rules concerning the processing of personal data, including the legal basis, purposes and scope of personal data processing, as well as the rights of the data subjects.
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ETL Polska
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The controller of the personal data provided while using the Website is ETL Polska Spółka Akcyjna with its registered office in Warsaw, at ul. Twarda 18, 00-105 Warsaw, entered in the register of entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division of the National Court Register, under KRS number: 0000588351, holding REGON number: 363084903 and NIP: 9571082183, share capital: PLN 1,000,000.00 („ETL Polska”; the „Controller”).
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What personal data do we process?
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We primarily process personal data that you provide to us directly – for example, when contacting us, using forms available on the Website, signing up for the newsletter, participating in events or using other functionalities of the Website.
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We limit the scope of processed data to the information necessary to achieve the given purpose. Depending on how you use the Website or contact us, we may process, in particular:
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- If you contact us via the contact form, email, telephone or other contact details available on the Website – your first and last name, email address, telephone number and any other information you voluntarily provide to us;
- If you sign up for the newsletter or to receive other marketing information – your name and email address;
- If you take part in events, training sessions, webinars or other initiatives organised or co-organised by ETL Polska – data necessary to register for and take part in the given event, in particular your first and last name, contact details, position or information concerning the organisation you represent, if required;
- If you take part in a recruitment process – data contained in your application documents and other information provided by you in connection with your candidacy;
- In connection with your use of the Website – information concerning the way you use the Website and technical data relating to your device and connection, to the extent necessary to ensure the proper functioning, security and development of the Website.
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We may also receive personal data when you contact us or interact with ETL Polska via the social media profiles we run or other communication channels.
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If you provide us with additional information on your own initiative, please limit it to the data necessary for the matter in question.
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For what purpose and on what basis do we process personal data?
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Data is processed in accordance with the currently applicable law, i.e. 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) („GDPR”), the Act of 10 May 2018 on the Protection of Personal Data, as well as other applicable laws.
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We process personal data only for specified purposes and only to the extent necessary to achieve them.
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Depending on how you use the Website or contact us, we may process your personal data in particular for the purpose of:
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- Contact and correspondence handling, including responding to questions sent via the contact form, email or other available communication channels – pursuant to Article 6(1)(f) GDPR, i.e. our legitimate interest in conducting correspondence, and where the contact is aimed at concluding or performing a contract – pursuant to Article 6(1)(b) GDPR;
- Sending the newsletter, if you decide to receive it – pursuant to Article 6(1)(a) GDPR, i.e. your consent;
- Carrying out marketing activities relating to ETL Polska’s services, including presenting our offer and informing you about services, events, publications, reports, training sessions and other initiatives organised or co-organised by ETL Polska – pursuant to Article 6(1)(a) GDPR, i.e. your consent, or Article 6(1)(f) GDPR, i.e. our legitimate interest in promoting ETL Polska’s services and building and developing relationships with clients and persons interested in our business – depending on the type of marketing activity and the manner 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 – pursuant to Article 6(1)(a) GDPR, i.e. your consent, Article 6(1)(b) GDPR, if the processing is necessary to take steps at your request or to perform a contract concluded with you, or Article 6(1)(f) 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 concerning your candidacy – pursuant to Article 6(1)(c) GDPR to the extent the processing is necessary to fulfil obligations arising from the law, in particular labour law, Article 6(1)(b) GDPR to the extent necessary to take steps at your request prior to concluding a contract, and Article 6(1)(a) GDPR, if the processing is based on consent given;
- Ensuring the proper functioning and security of the Website, including analysing how the Website is used, preventing abuse, detecting threats and fixing technical errors – pursuant to Article 6(1)(f) GDPR, i.e. our legitimate interest in ensuring the security, proper functioning and maintenance of the Website;
- Tailoring the content of the Website to users’ needs, including analysing how the Website is used in order to better understand the needs of its users and develop the Website in a way that meets their expectations – pursuant to Article 6(1)(f) GDPR, i.e. our legitimate interest consisting in developing the Website and improving the quality and usability of the content and functionalities offered on it, provided that the technologies used do not require the user’s prior consent;
- Establishing, pursuing or defending against claims by the Controller or by the data subject – pursuant to Article 6(1)(f) GDPR, i.e. our legitimate interest consisting in establishing, pursuing and defending against claims.
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How do we obtain personal data?
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We obtain personal data primarily directly from you – when you use the Website, contact us or otherwise provide us with your data.
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This may happen in particular when you use the contact form available on the Website, sign up for the newsletter, contact us directly by email, telephone, traditional correspondence or other available communication channels, register for or take part in an event, training session, webinar or other initiative organised or co-organised by ETL Polska, or take part in a recruitment process or otherwise provide us with information concerning your candidacy.
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Some information relating to your use of the Website may also be collected automatically, in particular technical data concerning your device, connection or the way you use the Website. You can find more information on this in the section on cookies and similar technologies.
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Are you required to provide us with your personal data?
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Providing personal data is generally voluntary. In some cases, however, it may be necessary to use certain functionalities of the Website, to receive a reply to your enquiry, to receive the newsletter, to take part in an event or recruitment process, or to conclude or perform a contract.
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Failure to provide the data necessary to achieve a given purpose may mean that we will not be able to take certain actions, e.g. respond to your enquiry, send the newsletter, register you for an event or take steps aimed at concluding a contract.
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If the obligation to provide certain data results from the law or a concluded contract, we will inform you of this in the relevant case.
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For how long do we process personal data?
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The period for which personal data is processed depends on the purpose for which it was collected. We do not store data for longer than is necessary to achieve the given purpose.
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Depending on the legal basis and purpose of processing, we may store personal data for the period necessary to perform a contract or take steps prior to concluding it, until consent is withdrawn (withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal) or an objection to the processing of personal data is raised, as well as for the period required by applicable law. If data may be needed to establish, pursue or defend against claims, we may store it until the relevant limitation periods have expired or until the final conclusion of proceedings relating to those claims.
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Who may your personal data be disclosed to?
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In connection with our business activities, we may disclose your personal data to entities that support the Controller in providing services, operating the Website and achieving the other purposes described in this privacy policy.
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Depending on the circumstances, these may include, in particular:
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- providers of IT and technology services, including entities providing hosting, maintenance of the Website and IT systems and their 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, audit, accounting or administrative services,
- subcontractors and other service providers that we use in connection with providing our services or conducting our business,
- postal operators, courier companies and other providers of services related to handling correspondence.
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Your data may also be disclosed to public authorities or other entities authorised to receive it under applicable law, if they make an appropriate request or if the obligation to disclose the data arises from the law.
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We disclose data to entities that process personal data on our behalf only to the extent necessary to perform the tasks entrusted to them.
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ETL Polska forms a nationwide network of law and advisory firms specialising in accounting, HR and payroll, legal and business advisory, audit, and tax. Information about the entities operating within ETL Polska can be found in the About Us tab.
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If the subject of your enquiry relates to services provided by one of the companies within the ETL Polska group, we may disclose your personal data and the content of your enquiry to that company to the extent necessary to handle it, in particular to provide a reply, prepare an offer or make contact regarding potential cooperation.
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What rights do you have in relation to your personal data?
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In connection with the processing of your personal data, you have the right to:
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- access your personal data, including obtaining information about its processing and receiving a first copy of the data free of charge,
- rectify your data, if it is inaccurate or incomplete,
- erase your data, if there are no circumstances justifying its further processing, in particular where applicable law requires its further storage,
- data portability, if it is processed in an automated manner on the basis of your consent or a contract,
- withdraw your consent to the processing of personal data – if the processing is based on your consent. Withdrawal of consent does not affect the lawfulness of processing carried out before its withdrawal,
- object to the processing of personal data – where we process it on the basis of our legitimate interest, as well as to restrict the processing of data in cases specified by law,
- not be subject to automated profiling, if the Controller were to make decisions based solely on automated profiling that produce legal effects concerning the data subject or similarly significantly affect them,
- obtain information about the processing of your data, in particular about the Controller, the purposes and manner of processing, the scope of the data processed, its source, and the recipients or categories of recipients to whom the data has been or may be disclosed.
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The data subject also has the right to lodge a complaint with the President of the Personal Data Protection Office (UODO) if the processing of data infringes the provisions of the GDPR.
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Transfer of personal data outside the European Economic Area (EEA)
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Personal data may be processed by providers whose registered offices or IT infrastructure, including servers, are located outside the European Economic Area (EEA), in particular in the United States of America (USA).
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Where data is transferred to third countries for which the European Commission has not issued an adequacy decision, the Controller ensures appropriate safeguards required under the GDPR, in particular by applying standard contractual clauses adopted by the European Commission or other mechanisms provided for in Chapter V of the GDPR.
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In the case of providers from the USA participating in the EU–US Data Privacy Framework, data is transferred on the basis of the European Commission’s decision of 10 July 2023 finding an adequate level of protection of personal data provided under the EU–US Data Privacy Framework.
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Social media
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ETL Polska maintains profiles on social media, in particular on Facebook and LinkedIn. In connection with the use of these profiles, we may process personal data that you make available by following our profiles, reacting to published content, posting comments or contacting us.
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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 the respective social media platforms. Detailed information on the rules of data processing by the operators of the respective platforms is available in their privacy policies.
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Cookies
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The Website uses cookies and similar technologies that make it possible to save or read information on the device you use to visit the Website.
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Cookies are pieces of computer data, most often in the form of text files, stored on the user’s end device, e.g. a computer, tablet or smartphone.
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The information collected through cookies may be used in particular to ensure the proper and secure functioning of the Website, to remember your selected settings and preferences, to analyse how the Website is used and – if you consent to this – to carry out marketing activities and tailor the content displayed to you.
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What cookies do we use?
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Cookies may be temporary, i.e. deleted when the browser is closed, or persistent. Persistent cookies are also stored after you finish using the Website and make it possible to remember the settings selected by the User and to personalise the user interface.
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The Website may use the following types of cookies:
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- necessary – enable the use of services available on the website,
- functional – allow the „remembering” of settings selected by the user and personalisation of the Website,
- analytical – enable monitoring of user activity on the website.
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Detailed information on the cookies used, including their purpose, provider and duration, is available in the cookie settings.
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The Website uses cookies for the following purposes:
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- tailoring the content of the Website’s pages to the individual preferences of the user and optimising the use of the website (display tailored to needs – functional cookies),
- carrying out analyses and statistics that provide information on how the user of the Website uses its pages, which makes it possible to improve their structure and content,
- marketing and/or remarketing purposes, including directing dedicated content, in particular to users who have visited the Controller’s website or fan page on the Facebook or LinkedIn social media platforms.
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Data contained in cookies is archived and used for statistical analysis purposes and to assess the overall traffic of Website users. Data contained in cookies is not combined with the personal data you provide when contacting the Controller.
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Consent to the use of cookies
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Upon entering the Website, you can accept the use of cookies for the above purposes, reject them, or consent only to selected cookies.
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We use the remaining cookies after obtaining your consent. On your first visit to the Website, you can accept all optional cookies, reject them, or select which types you consent to.
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You can change your decisions regarding cookies or withdraw your consent at any time using the cookie settings available on the Website.
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You can also manage cookies using your web browser settings, including deleting stored cookies or restricting the ability to save them. Restricting the use of certain cookies may affect the functioning of selected features of the Website.
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Contact with the Controller
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Contact with the Controller regarding the protection of personal data is possible via the data protection officer.
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The data protection officer supports the Controller in ensuring the proper processing of personal data and is the person you can contact with any questions concerning the processing of your personal data or the exercise of your rights relating to such processing. The data protection officer is Ms Hanna Rubaszewska, email: hanna.rubaszewska@etl.pl.
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Changes to the privacy and cookie policy
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The privacy and cookie policy may be updated periodically, in particular in the event of changes to the law, the way the Website operates, the technologies used, or the rules under which we process personal data.
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The current version of the privacy and cookie policy is always available on the Website. In the event of significant changes to the way personal data is processed, we will inform you of this in an appropriate manner.
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