Privacy Policy - Twin Office

PRIVACY POLICY TWIN OFFICE S.A.

1. GENERAL INFORMATION

This document contains information that we are required to provide to you when we
obtaining your personal information through our website or from other sources.
We make every effort to ensure that your personal information is:

processed in accordance with the law (in particular, the RODO), fairly, in a manner that is transparent to you (“lawfulness, fairness and transparency”);
collected for specific, explicit and legitimate purposes and not further processed in a manner incompatible with those purposes (“purpose limitation”);
adequate, relevant and limited to what is necessary for the purposes for which they are processed (“data minimization”);
correct and updated as necessary (“correctness”);
kept in a form that identifies you, for no longer than is necessary for the purposes for which the data are processed (“retention restriction”);
processed in a manner that ensures adequate security of personal data, including protection against unauthorized or unlawful processing and accidental loss, destruction or damage, by means of appropriate technical or organizational measures (“integrity and confidentiality”).

2. DEFINITIONS

TWIN OFFICE, We – means Twin Office S.A., with its registered office in Gdynia, ul. Śląska 35/37, 81-310
Gdynia, registered in the Register of Entrepreneurs of the National Court Register under the number KRS
0000539114, NIP 5862208327, Regon 220523012

RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016.
on the protection of individuals with regard to the processing of personal data and on the
free flow of such data and repealing Directive 95/46/EC (General Data Protection Regulation).
Data Protection).

Website – TWIN OFFICE website.

You – A person who has provided TWIN OFFICE with his or her personal data for a specific purpose, using a contact form on the Website, by e-mail or in any other form.

3. WHO IS THE CONTROLLER OF YOUR DATA AND HOW YOU CAN CONTACT HIM/HER
CONTACT?

TWIN OFFICE is the administrator of your personal data.

If you need to contact us on matters related to the protection of your personal data, please
use the following forms of contact:

email to: [email protected].
In writing to the address:
Twin Office S.A.
35/37 Śląska Street
81-310 Gdynia

4. WHAT HAPPENS TO YOUR PERSONAL INFORMATION FROM COLLECTION TO DELETION?

A. WHEN YOU SEND US AN INQUIRY OR REQUEST A GENERAL
CONTACT IN COMMERCIAL MATTERS

What kind of your data do we collect? To respond to your inquiry, all we need is the email address you provided Your e-mail address. If you provide other data that proves to be necessary or useful for the realization of your inquiry, e.g. your identification data (name and surname), contact data (address
mailing address, telephone number) then we will also process them.

Why do we process them? So that you receive the commercial information you request from us.

On what legal basis do we process your data? We process your data to take action
at your request before entering into a contract to purchase a service from us, and otherwise on the
based on your consent.

How long will we process your data? Your data will be processed until you
resignation of your interest in our offer, after we have answered your questions.

Who do we share your data with? Apart from our employees and associates, we do not
We do not share your data with anyone, except when it is necessary for the purpose for which we collect the data.
for which we collect the data, such as entrusting your data to an email service provider.

B. WHEN YOU GIVE US PERMISSION TO CONTACT YOU FOR MARKETING PURPOSES

What kind of your data do we collect? For marketing purposes, we collect data the scope of which enables us to us to contact you through the various channels of communication that we consider most effective and appropriate for the type of marketing information we send. The scope of the data includes:
Your first and last name, the name of the company you represent, the position you hold in it, your telephone number and your business e-mail address.

Why do we process them? So that you can receive updated marketing information from us regarding the
TWIN OFICE.

On what legal basis do we process your data? We process your data on the basis of
Your explicit consent given by checking the appropriate box before
submitting your data to us.

How long will we process your data? Your data will be processed until you revoke
the consent you have given. However, such revocation does not affect the lawfulness of the processing,
which was performed on the basis of consent before its withdrawal.

With whom do we share your data? Apart from our employees and associates, we do not
we share your data with anyone, with the exception of the entity providing us with email
email and hosting services, but this access is limited to the storage of data on the server.

C. WHEN YOU CONTACT US IN CONNECTION WITH THE EXERCISE OF RIGHTS OR
OBLIGATIONS UNDER A CONTRACT TO WHICH YOU ARE A PARTY OR WHEN YOU ACT
ON BEHALF OF A PARTY TO SUCH A CONTRACT

What kind of your data do we collect? When you exercise rights or obligations under a contract with us
contract, we collect data that is necessary for the performance of the contract, such as: your name,
the name of the company you represent, the position you hold in it, your telephone number, your business email.

Why do we process them? In order to properly perform the contract (e.g., to perform warranty claims
warranty claims), to fulfill legal obligations under generally applicable
legal regulations, and for the purpose of realizing legitimate interests such as conducting
correspondence in writing, via e-mail and phone calls
telephone calls, the possibility of establishing or asserting claims and defending against claims
arising from the contract.

On what legal basis do we process your data? We process your data on the basis of
Article 6(1)(b) (for taking action at your request before entering into a contract for the purchase of goods or services service from us), (c) (legal obligation incumbent on us as an Administrator) and (f) (legally legitimate interest of us as an Administrator – protection against potential claims).

How long will we process your data? Your data will be processed for the duration of the
contract, as well as for the period of the statute of limitations for claims that may arise from the contract. After this period, Your data will be processed only to the extent and for the duration required by law.

Who do we share your data with? Your data may be shared with our employees,
employees, associates and subcontractors, as well as entities providing services related to day-to-day
operations.

D. WHEN YOU CONTACT US IN CONNECTION WITH APPLYING FOR A JOB AT TWIN
OFFICE IN CONNECTION WITH YOUR RESPONSE TO TWIN’S RECRUITMENT ACTIVITIES
OFFICE

What kind of your data do we collect? We collect data that is necessary for the recruitment process
recruitment process and those that we receive from you that you deem important for the recruitment process, such as such as: your name, date of birth, telephone number, e-mail address, history of
education/education, employment history, and other data whose collection is permitted by
by law, in particular the provisions of the Labor Code.

Why do we process them? In order to carry out the recruitment process and hire selected candidates
candidates, to fulfill legal obligations under generally applicable
provisions of the law, and for the purpose of realizing legitimate interests such as conducting
correspondence in writing, via e-mail and telephone conversations
telephone calls.

On what legal basis do we process your data? We process your data on the basis of
The following articles of the RODO: Article 6(1)(a) (your consent), (c) (legal obligation incumbent on us
as Administrator) and (f) (legitimate interest of us as Administrator).

How long will we process your data? Your data will be processed for the duration of the
recruitment, possibly for the purposes of subsequent recruitment in TWIN OFFICE, not longer than 24 months from the date of
the date of completion of the recruitment process, and in any case if you revoke your consent
for the processing of your personal data. After this period, your data will be processed only
to the extent and for the time required by law.

With whom do we share your data? Your data may be shared with our employees,
associates and subcontractors involved in the recruitment process, including those providing
us recruitment tools and providing services related to the day-to-day operations of the
TWIN OFFICE.

5. WHAT RIGHTS DO YOU HAVE IN RELATION TO OUR PROCESSING OF YOUR PERSONAL DATA?

The RODO gives you a number of rights related to the processing of your personal data. In brief
these are described below.

The right to request access to personal data concerning you

You have the right to confirm whether we are processing personal data concerning you, and if this is the case occurs, you have the right to access it and the following information:

purposes of processing;
categories of personal data concerned;
information about the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
where possible, the intended period of storage of the personal data, and where this is not possible, the criteria for determining this period;
information about the right to request us to rectify, erase or restrict the processing of personal data concerning your person, and to object to such processing;
information about the right to lodge a complaint with a supervisory authority;
if the personal data was not collected from the data subject, any available information about the source of the data;
information about automated decision-making, including profiling as referred to in Article 22 (1) and (4) of the RODO, and – at least in these cases – relevant information about the principles of such decision-making, as well as the significance and anticipated consequences of such processing for the data subject.

If you request access to personal data relating to you, we will provide you with one copy of the personal data being processed. For any subsequent copies you request, we may charge a reasonable fee based on administrative costs. If you request a copy electronically, and unless you indicate otherwise, we will provide the information by common electronic means.

Right to request rectification of personal data concerning you

You have the right to request that we promptly rectify personal data concerning you that is inaccurate. Taking into account the purposes of processing, you also have the right to request the completion of incomplete personal data, including by providing an additional statement.

The right to request erasure of personal data concerning you (the so-called “right to be forgotten”)

You have the right to immediately request the deletion of personal data concerning you, and we are obliged to delete personal data without undue delay if one of the following circumstances applies:

Your personal data are no longer necessary to us for the purposes for which they were collected or otherwise processed;
Your consent to process your personal data has been withdrawn and we have no other legal basis for processing;
Your personal data has been processed unlawfully.

Right to request restriction of processing

You have the right to request us to restrict processing in the following cases:

you question the accuracy of your personal data – for a period that allows us to verify the accuracy of the data;
the processing is unlawful, and you object to the deletion of your personal data, requesting instead a restriction on its use;
we no longer need the personal data for the purposes of the processing, but you need it to establish, assert or defend your claims;
we have received an objection from you under Article 21(1) of the RODO to the processing (see below) – until we determine whether the legitimate grounds on Our side override the grounds for your objection.

Right to object to processing

You have the right to object at any time, on grounds relating to your particular situation, to the processing of personal data concerning you based on the necessity of the processing for the purposes of the legitimate interests pursued by Us. If You raise such an objection, We will no longer be able to process Your personal data unless We demonstrate the existence of valid legitimate grounds for processing that override Your interests, rights and freedoms, or grounds for establishing, asserting or defending claims.

Right to data portability

You have the right to receive in a structured, commonly used, machine-readable format the personal data concerning you that we have received from you, and you have the right to send this personal data to another controller without hindrance from us, if:

processing is based on your consent or on the basis of a contract we have with you; and
the processing is carried out by automated means.

When exercising the right to data portability, you have the right to request that we send your personal data directly to another controller, as long as this is technically possible.

The right to data portability must not adversely affect the rights and freedoms of others.

6. PROFILING

We do not use profiling, and we do not make automated decisions about data subjects.

7. TRANSFER OF PERSONAL DATA OUTSIDE THE EOG

Personal data may be transferred outside the European Economic Area in connection with TWIN OFFICE’s use of ICT solutions from suppliers in the European Economic Area. In this case, Twin Office will provide a mechanism that, in accordance with European Union law, legalizes the transfer and provides adequate guarantees for the protection of personal data. In addition, personal data may be transferred to public authorities or entities (or those performing public tasks) authorized to obtain data under applicable laws.

8. WHERE CAN YOU COMPLAIN WHEN YOU THINK YOUR PERSONAL DATA IS BEING PROCESSED UNLAWFULLY?

If you believe that your rights related to personal data protection have been violated you have the right to file a complaint with the supervisory authority, which is the President of the Office for Personal Data Protection. Nevertheless, we encourage you to contact us in advance to clarify the situation.

9. INFORMATION ABOUT COOKIES

The Website uses cookies and similar technologies (collectively, “Cookies”), which, however, can be deactivated through your browser settings.

The Administrator uses two types of Cookies: (1) performance cookies (which collect information on how visitors use the Website, such as the most frequently visited pages or error messages, etc.), and (b) functional cookies (which record User settings, such as language, consents given, etc.).

In addition, the Website uses third-party services, such as Google Analytics (https://www.google.pl/intl/pl/analytics/), which use Cookies for the following purposes: monitoring traffic on the Website; collecting anonymous, aggregate statistics to understand how users use the Website and to enable its continuous improvement.

Cookies are not used to collect the User’s personal data. Cookies do not change the configuration of the User’s computer, do not serve to install or uninstall any computer program, do not interfere with the integrity of the system or the User’s data.

The Administrator reserves the right to use the services of third parties in compiling statistics on the use of the website. The Administrator declares that in such a case the entities will not be provided with any data identifying the User.

In accordance with the applicable provisions of the Act of July 16, 2004. Telecommunications Law (i.e. Journal of Laws of 2017, item.1907), the User has the right to decide on the access of Cookies to his/her computer by selecting them in advance in his/her browser window.

10. WHEN THE PRIVACY POLICY MAY CHANGE

We are entitled to change this Privacy Policy at any time, in particular if there is a change in data protection laws or guidelines. We will inform you of any change by email or by a notice on the Website.