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INFORMATION ON THE PROCESSING OF PERSONAL DATA

In accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council, the so-called “GDPR”, we would like to provide you with some important information about the protection of your personal data.

Who is the controller of your data?

The controller of your personal data is Ortie Capital Investment S.A., Hubska 44 Street, 50-502 Wrocław (hereinafter referred to as “Administrator”).

How to contact us?

If you have any questions regarding the processing of your personal data or if you wish to exercise your rights, please contact us:

By email, via the email address: iod@rbo.pl

By post, to the following address:

Ortie Capital Investment S.A.

44 Hubska Street

50-502 Wrocław

with a note “Protection of personal data”.

For what purpose and on what basis do we process your data?

COLLECTION OF DATA IN CONNECTION WITH THE PROVISION OF SERVICES AND PERFORMANCE OF CONTRACTS

In the case of collection of personal data for the purposes related to the performance of a contract with the Administrator or taking action at your request prior to entering into a contract, the basis for the processing of personal data is:

  1. Article 6(b) of the GDPR, i.e. the data are processed for the purpose of performing a contract to which you are party or to take action at your request prior to entering into a contract. This also applies to data provided by you for this purpose through the means of communication made available by the Administrator, i.e. e-mail correspondence, traditional correspondence, telephone contact.

  2. Article 6(1)(f) of the GDPR, i.e. the Administrator’s legitimate interest in the establishment, investigation or defence against possible claims;

  3. Article 6(1)(c) of the GDPR, i.e. the processing is necessary for compliance with a legal obligation to which the Administrator is subject, in the form of, among others, tax laws and accounting regulations.

E-MAIL AND TRADITIONAL CORRESPONDENCE AS WELL AS TELEPHONE CONTACT

In the case of directing correspondence or telephone contact to the Administrator that is not related to contracts concluded or services provided by the Administrator, personal data provided in this way will be processed on the basis of Article 6(f) of the GDPR, i.e. the Administrator’s legitimate interest to conduct communication and resolve the matter to which the correspondence or telephone contact relates.

PROCESSING OF PERSONAL DATA OF CONTRACTORS / CUSTOMERS

In connection with the conclusion of agreements within the scope of its business activity, the Administrator acquires from contractors / customers data of persons involved in the performance of such agreements (e.g. persons authorized to contact, persons representing contractors / customers). The processing of such data is based on Article 6(b) GDPR, i.e. for the purposes related to the performance of the contract or taking action prior to entering into the contract, as well as on Article 6(1)(f) GDPR, i.e. the Administrator’s legitimate interest in determining, pursuing or defending against potential claims. The processing of such data also takes place on the basis of Article 6(1)(c) GDPR, i.e. the processing is necessary for the fulfilment of a legal obligation to which the Administrator is subject, in the form of, among others, tax laws and accounting regulations.

At the same time, we inform you that we received your data in this regard either directly from you or from the entity you represent.

DATA COLLECTION WITHIN THE SCOPE OF BUSINESS CONTACTS

In connection with its operations, the Administrator also collects personal data in other cases – e.g. during business meetings or by exchanging business cards – for the purposes of initiating and maintaining business contacts. The legal basis for the processing in this case is the legitimate interest of the Administrator (Article 6(1)(f) GDPR) consisting in creating a network of contacts in connection with the conducted business activity. At the same time, we inform you that we received your data in this regard either directly from you or from the entity you represent.

How long do we store your data?

We will store your personal data only for the time necessary for the purpose of its processing. Most often, they will be stored until the statute of limitations for claims under the contract concluded with us or until the expiration of the obligation to store personal data resulting from legal regulations. In the case of possible data processing for marketing purposes on the basis of a consent granted by you, your data will be processed until you withdraw it.

What rights do you have in relation to the processing of your data?

In connection with our processing of your personal data, you have:

  1. the right of access – the right to be informed of, among other things, what data are processed, for what purposes they are processed and to obtain a copy of the data;

  2. the right to rectification – you may inform us of changes to your personal data at any time should the need arise. As soon as we are so informed, we will correct the data held by us;

  3. the right to erasure of data (“the right to be forgotten”) – on this basis, you may request the erasure of data the processing of which is no longer necessary for any of the purposes for which they were collected. Please note that we will not be able to erase your data if there are legal grounds for further processing;

  4. right to the restriction of data processing – on this basis, the Administrator shall cease performing operations on personal data, with the exception of operations to which you have given your consent and their storage, in accordance with the adopted retention rules (data processing period) or until the reasons for the restriction of data processing cease to exist;

  5. right to data portability – insofar as your data are processed in connection with a contract concluded or consent given, you have the right to receive the data in a computer-readable format. It is also possible to request that this data be sent to another entity;

  6. right to object – at any time you have the right to object to the processing of data by automated means, including profiling, and also to object to the processing of data for marketing purposes;

In order to exercise the above rights, please contact us as indicated in the section “How to contact us?”.

If you believe that the processing of your personal data violates the law, you have the right to lodge a complaint to the supervisory authority competent for the protection of personal data. In Poland it is the President of the Office for Personal Data Protection, 2 Stawki Street, 00-193 Warsaw.

Providing data is voluntary, however, it is necessary to realize the purposes indicated above in the section “For what purpose and on what basis do we process your data?”.

Disclosure of personal data

Your data may be disclosed to other entities that provide services on our behalf, on the basis of contracts concluded with us and our instructions. These entities are not authorized by us to use or disclose this information other than as necessary to provide services on our behalf or to comply with legal requirements.

Primarily, these will be entities that provide IT services, accounting and human resources services, legal services, and postal carriers to us. We may also share your data with authorized entities if required to do so by law.

We do not transfer your data outside the European Economic Area.

Automated decision making and profiling

The Administrator will not make decisions about your person by automated means and your data will not be subject to profiling.

Updates of this Policy

This Policy is reviewed on an ongoing basis and may be updated.

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