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PRIVACY POLICY

1. Definitions

1.1 Co-Administrators:

1.1.1. PKF Consult Limited Partnership with its registered office in Warsaw, address: Orzycka 6/1B, 02-695 Warsaw, entered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Department of the National Court Register under the number 0000579479, NIP: 5210527710, REGON: 01014308000000, hereinafter also referred to as "PKF Consult"; and

1.1.2. PKF BPO Sadowska-Malczewska Limited Partnership with its registered office in Warsaw, address: Orzycka 6/1B, 02-695 Warsaw, entered in the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register under the number 0000593842, NIP: 7541013035, REGON: 00823260300000, hereinafter also referred to as "PKF BPO Sadowska-Malczewska"; and

1.1.3. PKF Tax&Legal Chamera Orczykowski Limited Partnership with its registered office in Warsaw, address: Orzycka 6/1B, 02-695 Warsaw, entered into the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, Commercial Department of the National Court Register under KRS number 0000832265, NIP: 5213892373, REGON: 38571507700000, hereinafter also referred to as "PKF Tax&Legal",

also separately as "Administrator" or "Administrators". For more information in this regard, please refer to Section 3 of this Policy.

1.2 Personal Data - information about a natural person identified or identifiable by one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, internet identifier and information collected through cookies and other similar technology.

1.3 Policy - this Privacy Policy.

1.4 GDPR - 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.

1.5 Service - the website operated by the Joint Administrators at https://www.pkfpolska.pl/.

1.6 User - any natural person visiting the Website or using one or more services or functionalities described in the Policy.

2 Processing of data in connection with the use of the Website

2.1 In connection with the User's use of the Website, the Joint Administrators (or each of the Administrators separately) collect data to the extent necessary to provide the individual services offered, as well as information about the User's activity on the Website. The detailed principles and purposes of processing of the Personal Data collected during the use of the Service by the User are described below.

3. Co-administration

3.1 In connection with the processing of Users' Personal Data within the scope of running the Service, the Administrators shall cooperate with each other in determining the purposes and means of such processing (co-management of natural persons' data).

3.2 The scope of co-management includes activities such as: running the Website, running social media as well as the use of cookies and similar technologies. For more information on co-management, please visit https://www.pkfpolska.pl/wspoladministrowanie-4889 .

3.3 Notwithstanding the foregoing, with respect to certain services provided on the Website, the Joint Controllers may act separately. In each such case, the content of the Policy will indicate the respective Data Controller responsible for the execution of the respective process.

4. Purposes and legal basis of data processing on the Website

USE OF THE SERVICE

4.1 Within the scope of using the Service the co-administrators of the Users' Personal Data are: PKF Consult Limited Partnership, PKF BPO Sadowska-Malczewska Limited Partnership and PKF Tax&Legal Chamera Orczykowski Limited Partnership, all based in Warsaw (02-695) at Orzycka 6/1B.

4.2 Personal Data of all persons using the Website (including IP address or other identifiers and information collected through cookies or other similar technologies), is processed by the Joint Administrators:

4.2.1. for the purpose of rendering electronic services in the scope of providing Users with access to the content collected on the Website - then the legal basis of the processing is the indispensability of the processing for the performance of the agreement (art. 6 par. 1 letter b GDPR);

4.2.2. for analytical and statistical purposes, in which case the legal basis for the processing is the Joint Administrators' legitimate interest (Article 6(1)(f) of the GDPR), consisting in analyzing Users' activities and preferences in order to improve the functionalities used and services provided;

4.2.3. for the purpose of possibly establishing and pursuing claims or defending against claims - the legal basis for the processing is the Joint Administrators' legitimate interest (Article 6(1)(f) of the GDPR) in protecting your rights;

4.3 Users' Personal Data may also be processed for marketing purposes of the Joint Administrators - the principles of processing of Personal Data for marketing purposes are described in the MARKETING section.

4.4 User activity in the Service, including his/her Personal Data, is recorded in system logs (a special computer program used for storing a chronological record containing information on events and actions that concern the IT system used for rendering services by the Administrator). The information collected in the logs is processed primarily for purposes related to the provision of services. The Joint Administrators also process them for technical, administrative purposes, for the purpose of ensuring the security of the IT system and managing this system, as well as for analytical and statistical purposes - in this regard, the legal basis for processing is the Joint Administrators' legitimate interest (Article 6(1)(f) of the GDPR).

CONTACT FORM

4.5 Within the scope of using the contact form in the Service, depending on the subject of the enquiry, the administrator of the Users' Personal Data will be PKF Consult Limited Partnership. or PKF BPO Sadowska-Malczewska Limited Partnership or PKF Tax&Legal Chamera Orczykowski Limited Partnership, all based in Warsaw (02-695) at Orzycka 6/1B.

4.6 Each of the separate Administrators provides a possibility to contact them using an electronic contact form. Using the form requires providing Personal Data necessary to make contact with the User and respond to the submitted enquiry. The User may also provide other data in order to facilitate the handling of the enquiry. Providing data marked as obligatory is required for accepting and servicing the enquiry, and its omission results in the impossibility of servicing. Providing other data is voluntary.

4.7 Personal Data is processed:

4.7.1. for the identification of the sender and the handling of his/her enquiry sent via the form provided - the legal basis for the processing is the necessity of the processing for the performance of the contract for the provision of the service (Article 6(1)(b) GDPR); with regard to the data provided optionally, the legal basis for the processing is consent (Article 6(1)(a) GDPR);

4.7.2. for analytical and statistical purposes - the legal basis of the processing is the Administrators' legitimate interest (Article 6.1.f GDPR), consisting in statistics on queries made by Users via the Service in order to improve its functionality.

5. Marketing

5.1 Within the scope of marketing activities, the Administrator of the User's Personal Data is PKF Consult Limited Partnership with its registered seat in Warsaw (02-695), at Orzycka 6/1B.

5.2 Personal Data of users who have agreed to receive communication from PKF Consult Limited Partnership via a selected communication channel (e-mail; telephone call) is processed in order to direct marketing communication about interesting offers or content promoting services offered by PKF Consult Limited Partnership, PKF BPO Sadowska-Malczewska Limited Partnership, and PKF Tax&Legal Chamera Orczykowski Limited Partnership, all based in Warsaw (02-695) at Orzycka 6/1B. Data processing takes place on the basis of the legitimate interest of the Administrator (Article 6(1)(f) GDPR). The legitimate interest of the Administrator consists in directing marketing content to the User via telephone or e-mail in connection with the User's consent to receive from PKF Consult Limited Partnership marketing communication promoting services offered by PKF Consult Limited Partnership, as well as other entities belonging to the PKF Consult Group i.e. PKF BPO Sadowska-Malczewska Limited Partnership, PKF Tax & Limited Partnership, to the contact data given by the User.

6. Social networks

6.1 Within the scope of operation of the social networking sites the co-administrators of the Users' Personal Data are: PKF Consult Limited Partnership, PKF BPO Sadowska-Malczewska Limited Partnership and PKF Tax&Legal Chamera Orczykowski Limited Partnership, all based in Warsaw (02-695) at Orzycka 6/1B.

6.2 The Joint Administrators process the Personal Data of Users who visit the Joint Administrators' profiles conducted in social media (Facebook, YouTube, LinkedIn). This Data is processed exclusively in connection with the running of the profile, including for the purpose of informing Users about the activities of the Joint Administrators and promoting various events, services and products. The legal basis for the processing of Personal Data by the Joint Administrators for this purpose is their legitimate interest (Article 6(1)(f) GDPR) in promoting their own brand.

7. Cookies and similar technology

7.1 Cookies are small text files installed on the User's device when browsing the Website. Cookies collect information making website use easier e.g. by remembering User's visits to the Website and actions performed by them.

7.2 Within the scope of managing cookies and similar technology in the Service, the co-administrators of the Users' Personal Data are: PKF Consult Limited Partnership, PKF BPO Sadowska-Malczewska Limited Partnership and PKF Tax&Legal Chamera Orczykowski Limited Partnership, all based in Warsaw (02-695) at Orzycka 6/1B. Detailed information in this respect is available in the Cookie Policy published at www.pkfpolska.pl/pl/cookie.  

8. Period of processing of Personal Data

8.1 The duration of data processing by the Joint Controllers or separate Controllers depends on the type of service provided and the purpose of processing. As a rule, the data is processed for the duration of the service provision or order processing, until the withdrawal of the consent given or until an effective objection to the data processing is raised in cases where the legal basis of the data processing is the legitimate interest of the Joint Administrators or of each of the separate Administrators.

8.2 The processing period may be extended if the processing is necessary for the establishment and assertion of possible claims or the defense against claims, and thereafter only if and to the extent that the law so requires. After the expiry of the processing period, the data shall be irreversibly deleted or anonymized.

9. User Privileges

9.1 The User has the right to access the content of the data and to request rectification, erasure, restriction of processing, the right to data portability and the right to object to the processing of the data, as well as the right to lodge a complaint to the supervisory authority in charge of the protection of Personal Data.

9.2 To the extent that the User's data is processed on the basis of consent (i.e. in the case of provision of optional data when filling in the contact form), this consent may be withdrawn at any time by contacting the Administrator responsible for processing the form (as stated in the "CONTACT FORM" section above).

9.3 The User has the right to object to the processing of data on grounds related to the User's particular situation - in cases where the legal basis of data processing is the legitimate interest of the Joint Controllers or of each of the Controllers separately (e.g. in connection with the performance of analytical and statistical purposes).

10. Data recipients

10.1 In connection with the provision of services, Personal Data will be disclosed to external entities, including in particular suppliers responsible for the operation of IT systems and entities related to the Joint Administrators or to each of the Administrators separately, including companies in their capital group.

10.2 Co-administrators, as well as each of the Administrators individually, reserve the right to disclose selected information concerning the User to the competent authorities or to third parties who make a request for such information on the basis of an appropriate legal basis and in accordance with the provisions of the applicable law.

11. Transfers of data outside the EEA

11.1 The level of protection of Personal Data outside the European Economic Area (EEA) differs from that provided by European law. For this reason, in principle, the Joint Administrators do not transfer Personal Data outside the EEA. Such transfer may only take place when necessary and with an adequate level of protection, primarily by:

11.1.1. cooperation with processors of Personal Data in countries for which a relevant decision of the European Commission has been issued regarding the finding of an adequate level of protection for Personal Data;

11.1.2. use of standard contractual clauses issued by the European Commission;

11.1.3. the application of binding corporate rules approved by the competent supervisory authority;

11.1.4. where data is transferred to the USA, cooperation with entities participating in the Privacy Shield program, approved by a decision of the European Commission.

11.2 The Joint Administrators and each of the Administrators individually shall always give notice of their intention to transfer Personal Data outside the EEA at the stage of collection.

12. Security of Personal Data

12.1 The Joint Controllers and each of the Controllers individually carry out a risk analysis on an ongoing basis to ensure that they process Personal Data in a secure manner - ensuring in particular that only authorized persons have access to the data and only to the extent necessary for the performance of their tasks.  The Joint Controllers and each of the Controllers individually ensure that all operations on Personal Data are recorded and performed only by authorized employees and associates.

12.2 The Joint Controllers and each of the Controllers individually shall take all necessary measures to ensure that also their subcontractors and other cooperating entities guarantee the application of appropriate security measures whenever they process Personal Data on their behalf.

13. Contact details

13.1 Contact with the Joint Administrators or each of the Administrators separately is possible by sending a message to the following correspondence address: Orzycka 6/1B, 02-695 Warsaw.

13.2 In addition, the following email addresses have been designated for contact with the selected Administrator:

13.2.1. PKF Consult - pkfconsult@pkfpolska.pl,

13.2.2. PKF BPO Sadowska-Malczewska - biurobpo@pkfpolska.pl,

13.2.3. PKF Tax&Legal - prawo@pkfpolska.pl.

13.3 The Joint Administrators and each of the Administrators individually have appointed a Data Protection Officer who can be contacted by emailing iod@pkfpolska.pl on any matter concerning the processing of Personal Data.

14. Amendments to the Privacy Policy

14.1 The policy shall be kept under review and updated as necessary.

14.2 The current version of the Policy has been adopted and is effective from 2020.