Privacy policy

 
 
 

1. CONTROLLER

1.1.

The personal data controller is: Engagy Prosta Spółka Akcyjna with its registered seat in Poland, at Ostródzka 130, postal code 03-289 Warsaw, Poland (hereinafter referred to as: Engagy.

2. OUR CONTACT DATA

2.1.

Regarding the processing of your personal data by Engagy and the related requests you may contact us at: office@engagy360.com or at the following address: Engagy Prosta Spółka Akcyjna, at Ostródzka 130, 03-289 Warsaw

3. LEGAL GROUNDS

3.1.

Our Personal Data Processing Policy was developed in connection with 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 (General Data Protection Regulation) (hereinafter: GDPR).

4. SOURCE AND METHODS FOR DATA PROCESSING

4.1.

We collect your personal data directly or by electronic means, including by:


4.1.1.

sending queries through contact forms available at engagy360.com

The provision of data is necessary for entering into an agreement with us, using our services or obtaining information. Otherwise, providing the data is voluntary.

4.2.

We ensure that your personal data is processed legally, for legitimate purposes, transparently and reliably.

4.3.

Our websites use a safe web protocol – SSL Certificate, ensuring confidentiality of data transmission sent over the Internet. This means that your data provided through the contact form are sent through a safe encrypted connection.

Purpose of processing
Description of the Data Controller’s legitimate interests
GDPR legal basis

Handling contracts: concluding, performing and settling the agreement, including contacts in connection with its performance

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Article 6(1)(B) - processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract;

Handling complaints;

-

Article 6(1)(c) - processing is necessary for compliance with a legal obligation to which the controller is subject;

archiving documents, i.e. agreements and settling documents

-

Article 6(1)(c)

Exercise of legal claims in connection with the agreement

Enforcement of liabilities, conducting court proceedings and subsequent enforcement proceedings

Article 6(1)(f) - processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data;

Generating general statistics not identifying individuals (e.g. Google Analytics)

Statistics regarding our activities allow us to

improve the conduct of our business

Article 6(1)(f)

Handling queries or reports received through the contact form.

Providing information, responding to reports and queries received through the contact form or otherwise, including storage of reports and the responses given for accountability purposes

Article 6(1)(f)

Conducting marketing activities regarding own products or services (including profiling)

Promoting our activities, building and strengthening business relationships. In the case of using e-mail addresses and telephone numbers – solely based on the received consents.

Article 6(1)(f)

Conducting marketing activities regarding external products or services – solely based on the received consents.

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Article 6(1)(a)

5. DATA PROCESSING TIME

5.1.

If the basis for personal data processing is your consent (Article 6(1)(a) of GDPR) – the data will be used until the consent is withdrawn. We have the obligation to store your personal data for the time required under the law and when necessary for the functioning of Engagy and ensuring accountability.

Type of personal data
Duration of the processing

Data in documents, such as orders, reports, agreements, letters of authorization

The period of performing the obligations and the period of the statute of limitations resulting from the law; until the end of the time specified in a statute of limitations for contractual claims.

Data in settlement documents

The books and the related documents, until the end of the time specified in a statute of limitations for tax liability, unless the fiscal acts provide otherwise.

The data in the documents connected with statutory warranty and guarantee

The documents related to statutory warranty, guarantee and complaints will be processed for 1 year after termination of the statutory warranty, guarantee or settlement of a complaint.

Data for marketing purposes

Where processed based on consent – until such consent is withdrawn;

Where processed based on legitimate aim – until an objection is raised.

Contact form data

For two years, to make sure the accountability principle is followed.

6. DATA RECIPIENTS

6.1.

For technical reasons, your personal data may be shared with other entities for processing. These include:


6.1.1.

authorized employees and co-workers who use the data in order to do our business and the entities entrusted by us with supporting our business, including but not limited to specialists, advisors or providers of solutions supporting our business;


6.1.2.

state authorities or other authorities competent pursuant to the provisions of law (for the purposes of fulfilling legal obligations), such as: the Social Insurance Institution, Tax Office;

6.2.

Your personal data may be transferred outside the European Union only as a result of performing an agreement concluded with the Controller, if necessary to obtain a license from a third party with registered office outside the European Union.

7. AUTOMATED PROCESSING

7.1.

Personal data shall not be subject to automated decision-making, including profiling.

7.2.

Cookies – information not used for identification of users or for determining anyone’s identify in any manner. In doing our business we use cookies, which we use for analyzing the traffic on our pages and taking marketing activities; these activities, however, do not involve the processing of personal data as defined in GDPR. For more information about cookies, please see Cookies Policy.

8. RIGHTS

8.1.

Subject to the principles set forth under Article 15 – Article 20 of GDPR you have the right to access the content of your personal data and the right to rectify or erase them, restrict their processing, transfer them, object, withdraw consent at any time, without affecting the lawfulness of processing based on consent before its withdrawal (if the data are processed based on consent).

8.2.

You may submit a request regarding your data rights:


8.2.1.

in writing to the following address: Engagy Prosta Spółka Akcyjna, at Ostródzka 130, 03-289 Warsaw,


8.2.2.

by e-mail to the following address: office@engagy360.com,

8.3.

If our processing violates the GDPR provisions, you have the right to file a complaint to the supervisory authority, i.e. the President of Personal Data Protection Office.

The Policy is verified on an ongoing basis and updated as needed. The current version of the Policy is applicable as of 1 June 2022.