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Data Privacy Policy

SUPERDEVS Sp. z o.o.

 

Below we present information about the rules and methods of processing your personal data in connection with our business. In the Policy you will find the most important information about how SUPERDEVS Sp. z o.o. with its registered office in Warsaw deals with your personal data.

Who is the controller of my data?

The administrator of your personal data is SUPERDEVS Sp. z o.o. with its registered office in Warsaw, Bukowińska 24D/7, 02-703 Warsaw, entered into the Register of Entrepreneurs by the District Court for the Capital City of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under KRS number: 0000673877, REGON: 36708499800000, NIP: 5272805163.

In matters regarding the protection of your personal data, you can always contact us by e-mail at [email protected], or by post to the address of our registered office, with the note "Personal data".

Where does the Administrator obtain my personal data from?

We obtain your personal data mainly from you. You provide us with your data to contact us by sending us an email, filling out a contact form, and even giving us your business card. We also obtain your data in connection with our  business activity and the implementation of transactions in the scope of services we provide.

Contractors and suppliers

If you are our client, contractor or supplier, run a  sole proprietorship or represent a company or organizational unit, we obtain your personal data mainly from you. You provide us with your data to contact us  in matters regarding the terms of cooperation by sending us an e-mail or filling out the contact form. We also obtain your data in connection with our business activity as part of the performance of the  contract for the provision of services or taking appropriate actions before the conclusion of the contract.

If you are an employee of a company or organizational unit, and the Administrator processes your personal data, although you have never directly provided them to us - it happens that your data may be provided to us by third parties, at your request or in connection with your official duties. Your data may be transferred to us by your employer to enable us to contact you in connection with the cooperation we undertake with the entity in which you are employed.

Workers and job applicants

If you are our employee or co-worker, we obtain your personal data mainly from you. You provide us with your personal data for purposes necessary from the perspective of employment – when concluding an employment contract, a civil law contract, or by completing a personal questionnaire. As your employer or client, we must process your personal data in order to be able to contact you and correctly settle all issues related to your employment, including for tax or social security purposes. It happens that some of your personal data will be transferred to us by third parties, e.g. state authorities, who will contact us as your employer or cooperating entity.

In some cases, we also process your personal data provided on social media (on the LinkedIn or Facebook platform). Then we act to verify the information provided in the course of recruitment or employment and to secure the legitimate economic interest of the Administrator, depending on the nature of the position held.

If you are just taking action to establish cooperation with us and want to send us your CV or cover letter, we collect your personal data from you in order to be able to contact you and include you in the recruitment process. It happens that we use the help of external entities – dedicated portals dealing with recruitment (e.g. www.pracuj.pl), or with the help of entities dealing with the recruitment of employees. In this case, your personal data is provided to us by these entities, with your consent and request.

Representatives of the authorities

The application of applicable legal regulations may sometimes involve the need to conduct correspondence with representatives of public administration bodies and public institutions. The data of persons whose data are included in letters delivered to us on behalf of an authority or institution are provided to us by the persons who drafted the letter or who signed it. Then we can process your data on the basis of contact with us.

For what purpose does the Administrator process my data?

Running a business

If we have obtained your personal data in connection with our business activity, your personal data will be used for the purposes of completing the order in the performance of the  contract for the provision of services or by taking appropriate actions before the conclusion of the above-mentioned agreement. This includes, in particular, receiving contact details from you, enabling us to establish and maintain contact with you in the course of cooperation.

We also use your address and registration data to deliver services to the place indicated by you, issue sales documents or settle our cooperation. We also need your personal data if you want to exercise your rights related to our cooperation – where applicable – protection of rights or pursuing claims.

If you run our client, contractor or supplier, run a sole proprietorship or represent a company or organizational unit that is our client, contractor or supplier  – we also process your personal data for tax, legal and accounting purposes. We need them to disclose relevant data on the contract or invoice, as well as to use them in keeping our tax records. However, the processing of your personal data will always be related to our business activity.

If you are our customer, contractor or supplier, run a sole proprietorship or represent a company or organizational unit that is our client, contractor or supplier, your personal data will be needed in particular to establish and maintain contact with the entity in which you work – again, only for purposes related to our business activity   a.

Your personal data that we use for business purposes will not be used by us for other purposes without your consent. An exception to this is the use of your data for marketing purposes, based on our legitimate interest. We want to maintain a relationship with you, so we want to be able to keep you informed about our new offers and promotions. If this does not suit you – you can object at any time, on the terms described below in the Policy.

Employment relationship service

If you are our employee or co-worker, we use your personal data for purposes related to your employment, including recording working time or supporting the improvement of qualifications by employees as part of training. As your employer or cooperating entity, we must fulfill a number of obligations – both in terms of the proper arrangement of our cooperation and in HR and payroll matters. As employers, we also have certain rights – we use your personal data, for example, to be able to contact you or control the effects of your work.

We also need your personal data to provide you with access to employee benefits and entitlements, as well as benefits and support in the event of your illness or maternity, as well as in the event of an accident at work. Again, the purpose of processing your personal data is then the proper handling of the employment or cooperation relationship between us and the protection of your vital interests.

It may happen that we will also use your personal data to provide information about you to third parties, e.g. to the bank where you apply for a loan, to the insurer, or to a public authority that will ask us. In these situations, your personal data will be disclosed for your benefit, at your request or in connection with our legal obligations.

Your personal data that we use for purposes related to the employment relationship or mandate will not be used by us for other purposes without your consent. In particular, we will not process your data for marketing purposes without your express consent.

Recruitment

If you apply for employment with us, we use your personal data only for the purpose of conducting the recruitment process. We use your data to get acquainted with your education and professional experience, to assess your suitability to work with us and to determine the fulfilment of the criteria required by us for employment, and  finally - to contact you and invite you for an interview.

If, after the recruitment process, we decide to employ you, the personal data provided in the recruitment process may be used for the purposes of future employment – so that you do not have to provide them again. Most often, the personal data provided by you in your CV and cover letter are stored in your employee file.

Your personal data that we use for recruitment purposes will not be used by us for marketing purposes without your consent.

Making contact

If you send us an e-mail or contact us in any other way, we use your personal data to correspond with you and answer your questions, in accordance with the content of your inquiry or message.

If you contact us for commercial purposes (e.g. to use our services), your personal data may then be used to address a commercial offer to you – but only to the extent that you request it and in relation to the inquiry addressed by you.

Notwithstanding the above, even if we make communication for commercial purposes, we will not use your personal data for marketing purposes in connection with offers other than the one you explicitly requested when making contact, without your consent.

Pursuing and defending claims

It happens that we will have to use your personal data to assert or defend our rights, including in court. We hope that this will not happen, but if any dispute arises between us - we may have to use your personal data in the course of court, arbitration or mediation proceedings.

In this case, we will use your personal data only to the extent necessary and in connection with the discussions or proceedings. It may happen that we use your personal data to call you as a witness in the case, or – if you are our contractor or supplier – in connection with the fact that you will be a party to the case.

Your personal data that we use for the purpose of pursuing or defending claims will not be used by us for other purposes without your consent. In particular, we will not process your data for marketing purposes without your express consent.

Marketing purposes

We process your personal data in connection with the functioning of our marketing database for our marketing purposes, i.e. as part of promoting our product and service offer. As part of our marketing, we want to be able to present you with our new range of products or services, as well as new commercial or business solutions used in our business.

For marketing purposes, we process your personal data with reference to the so-called legitimate interest of the personal data controller (Article 6(1)(f) of the GDPR). Constant information about our activities is necessary and desirable for us to maintain the network of customers. Thus, we have a legitimate interest in maintaining our marketing base and sending information to customers. Providing and processing your personal data in this respect is completely voluntary and does not result from a legal obligation. You have the right to object to the processing of your data in this respect at any time.

On what basis does the Administrator process my personal data?

The administrator ensures that your personal data will be processed only in a lawful manner. This means that we will always process your personal data on a specific basis that we will be able to demonstrate. The basis for processing personal data may vary depending on the purpose for which we process personal data.

Business

If we have obtained your personal data in connection with our business activity, we process your data in the first place in order to fulfill the cooperation agreement between us, and secondly also to enable you to exercise your rights related to our cooperation – where applicable – protection of rights or pursuing claims.

Therefore, the basis for processing will be the necessity to use your personal data to carry out the transaction of delivery of goods or provision of services. If the party to the Agreement is an entity other than you (e.g. we obtained your data from your employer, or in communication you act as a representative of a company or organizational unit), the basis for the processing of your personal data will be the use of your data for purposes resulting from the legitimate interests pursued by us and this entity (third party), e.g. to ensure the proper performance of the delivery or service.

Running a website

Cookies

Data regarding your use of the website, which we obtain via the so-called cookies, are processed on the basis of your consent, expressed in accordance with art. 173 of the Telecommunications Law.

Cookies (so-called "cookies") are IT data, in particular text files, which are stored in the Website User's end device (computers or mobile devices connected to the Internet) and are intended for using the Website's websites. Cookies usually contain the name of the website from which they originate, the time of their storage on the end device and a unique number.

Our website displays a banner asking for your consent to the placement of cookies on your computer. If you do not consent, activities carried out through your computer or Internet-connected device will not be monitored for marketing purposes. A second type of cookie, also known as session cookies, may be required to operate the feature you choose. These cookies are not blocked if you do not consent to their placement on your computer. Your choice will be stored in the cookie for a period of 90 days. If you want to change the option you have previously selected, you should delete cookies from your web browser.

Although most web browsers automatically allow cookies to be placed on your computer, you can opt out of this by making changes to your browser settings (in most cases, this option is located in the Tools or Preferences menu of your browser). You can also delete cookies from your device at any time. In this case, please note that if you do not consent to the placement of cookies, you will not be able to use all the functions of our website to their full extent.

The cookies we use are primarily used  to optimize the useof our website, to compile statistics on their visits and to maintain the user's session.

The processing of your personal data in this respect takes place with reference to our legitimate interest, i.e. on the basis referred to in art. 6 par. 1 lit. f GDPR and on the basis of your consent, expressed by you by accepting the collection and use of cookies by us in the web form.

Employment relationship service

All personal data that the Administrator processes in connection with already established cooperation on the basis of an employment contract or mandate contract are used in order to properly fulfill the role of the employer. The use of this data is necessary for us to fulfill the obligations imposed on us under the provisions of Polish law regulating a given form of employment or cooperation, as well as to enable us to exercise our rights as an employer.

Sometimes, your sensitive (health) data will also be used as necessary to fulfill the obligations imposed on the basis of social security regulations or regulations in the field of health prevention or occupational medicine.

The basis for the processing of your personal data is therefore the necessity of their use for the proper performance of the employment contract that connects you with us, as well as the fulfillment of the legal obligation incumbent on us under labor law or civil law. With regard to your health data, the basis for processing is the necessity of their use for the fulfilment of obligations and the exercise of specific rights by the controller or data subject in the field of labour law, social security and social protection, as well as for the purposes of preventive health or occupational medicine, for the assessment of the employee's fitness for work, medical diagnosis, provision of health care or social security.

Recruitment

In recruitment processes, we try, whenever possible, to obtain your consent to the processing of personal data for recruitment purposes, asking you to include the relevant consent in the CV or cover letter you provide to us. This avoids doubts as to whether we have the right to use all personal data disclosed by you in the documents you submit or in the course of the recruitment process.

However, even if you do not agree to the processing of your personal data for recruitment purposes (e.g. you send us your CV without the necessary consent), we will still be able to process your personal data to the extent necessary to carry out the recruitment process.

Therefore, the basis for the processing of your personal data will be your consent, and in the absence of it – the necessity to use your data to undertake recruitment activities aimed at concluding an employment contract or a mandate contract (i.e. to take action in accordance with your request, before concluding the Agreement).

If we process your personal data on the basis of consent, you have the right to withdraw your consent at any time, which, however, will not deprive the lawfulness of the processing of personal data during the period in which your consent was in force.

Your consent in this respect is voluntary, but necessary to carry out the recruitment process. Without consent to the processing of your data in this respect, we will not be able to contact you and carry out the recruitment process.

Making contact

If you contact us, for example by e-mail, the processing of your personal data is necessary for us to take action at your request, in accordance with the content of your inquiry or message.

In this case, the basis for the processing of your personal data will therefore be your consent or the necessity to use your personal data to take action in accordance with your request, before the conclusion of the Agreement. If we process your personal data on the basis of consent, you have the right to withdraw your consent at any time, which, however, will not deprive the lawfulness of the processing of personal data during the period in which your consent was in force.

Your consent in this respect is voluntary, but necessary to make contact. Without consent to the processing of your data in this respect, we will not be able to contact you.

Pursuing and defending claims

If we use your data in connection with the pursuit or defense of claims, the basis for the processing of your personal data will be the legitimate legal interest of the Administrator as the administrator of personal data. The use of your data will be necessary to protect our interests , e.g. in the field of debt collection, defense against unjustified allegations, etc.

Marketing purposes

We will process your personal data for marketing purposes with reference to the so-called legitimate interest of the personal data administrator (Article 6 (1) (f) of the GDPR), entitling us to send you commercial and marketing messages. As part of our marketing, we take care to present you with up-to-date information about our new range of products or services, as well as new commercial or business solutions used in our business.

Providing and processing your personal data in this respect is completely voluntary and does not result from a legal obligation. You have the right to object to the processing of your data in this respect at any time.

 

How long the Administrator stores my personal data

The period for which we process your personal data depends on the purpose of processing. And so respectively:

  1. if you are our customer,  contractor or supplier, or you act on their behalf – we process your personal data for the duration of the contract or the period of cooperation. After this period, we will process your data for purposes related to the accountability of our personal data protection activities, as well as for the period of limitation of claims related to cooperation arising from the applicable law, but not longer than for a period  of three (3) years from the date of issuing a final decision on discontinuation of proceedings due to the enforcement of the entire amount due;
  2. if you are our employee or contractor – we process your personal data for the entire period of cooperation or employment, as well as for the period required by law in the field of storage or archiving of documents and information regarding employment, but not longer than for a period of ten (10) years from the termination of employment – Article 125a paragraph 4a of the Act of 17 December 1998 on pensions from the Social Insurance Fund ( i.e. OJ of 2020, item 53). In the event of proceedings before a court or public authority, the documents may be kept for the entire duration of the proceedings until the final conclusion of the proceedings, but no longer than for a period  of three (3) years from the date of final termination of the enforcement proceedings in the event of recovery of the entire amount. Data related to the performance of OHS activities and training organized for employees are processed for the duration of the contract;
  3. if you disclose your personal data to us in connection with the recruitment process – we will store your personal data for the duration of the recruitment process, and if we are not recruiting – for a period  of three (3) months from the date of receipt of your CV or cover letter. Retaining your personal data for this period will allow us to contact you if we start employment activities at a later date;
  4. if you establish communication with us – we keep your personal data throughout the entire period of communication and correspondence, and when we settle a matter or provide you with a complete answer – we store this data for a period not longer than  five (5) years from the end of the communication, in order to allow you to return to previous conversations and issues if necessary, and to account for our personal data protection activities;
  5. obtained data about how you use our website – will be used by us throughout the entire period of cooperation and for a period of five (5) years from the moment you last visited our website;
  6. personal data used by us for marketing purposes – will be processed by us for the entire period when you are our customer and later for a period  of five (5) years from the time you stopped using our offer and did not make purchases of our products.

The administrator deletes personal data at the latest within one (1) from the end of the data processing period.

Who is the recipient of my personal data processed by the Administrator?

We make sure that your personal data is transferred only to those persons who need access to them for the proper performance of our cooperation, or in connection with our legal obligations. Your personal data will be shared:

  1. employees and associates of the Administrator involved in handling cooperation or issues – in each case, however, we will ensure that these persons have the authorization to process your personal data and undertake to maintain confidentiality in this respect;
  2. entities related to the Administrator and members of  the  SUPERDEVS Capital Group  – only to the extent necessary  resulting from the need for proper communication of the organization (if you are our employee or co-worker) or is necessary to ensure the correctnessand implementation of mutual obligations (regarding customers,contractor  or suppliers);
  3. entities providing IT  and hosting services  to the Administrator – we also process your personal data in electronic form, which means that entities servicing us from the IT side will have access to them, as well as hosting service providers on whose servers we store our data, including in the field of e-mail;
  4. transport or transport companies – in order to deliver goods or other things (e.g. documents) to the address you indicated in the course of cooperation;
  5. entities providinglegal, tax  advisory, accounting, HR and payroll services to the Administrator – to the  extent that disclosure of your data is necessary to ensure the correctness of tax settlements, in terms of human resources and payroll, or in connection with conducted proceedings. In the same scope, access to your personal data will be granted to entities servicing us from the legal side, involved, for example, in giving opinions on documents on which your personal data is contained;
  6. public authorities, courts and tribunals – to the extent that the transfer of your personal data will be necessary or required due to ongoing proceedings or in connection with the obligation to provide data to specific authorities on the basis of legal provisions (settlements with the Tax Office and the Social Insurance Institution, etc.).

Under no circumstances will the Administrator share your data with third parties for commercial purposes. We don't sell yours, so you don't have to worry about them going to anyone you didn't want to share your data with.

How is my personal data processed and protected?

Principles of personal data processing

Dmakes every effort to ensure that your personal data is processed in accordance with applicable law and with respect for the principles of their processing indicated in the GDPR. The basic principles and standards of personal data processing in our company are specified in the detailed Personal Data Protection Policy, which is obligatorily read by each of our employees and co-workers. Thanks to this, we ensure that all persons involved in our business are aware of the importance of ensuring the proper processing of your personal data.

The basic principles that guide us in the process of processing your personal data are:

  1. the principle of compliance of personal data processing with the law, fairly and in a transparent manner – we strive to ensure that the processing of your personal data by us always takes place on a legally permissible basis, and the processing processes of your personal data as well as the purposes of processing are clear and understandable to you;
  2. the principle of data minimization – we make every effort to process only those of your personal data that are adequate, relevant and limited to what is necessary for the purposes for which they are processed. We share your personal data only with such recipients for whom it is necessary to achieve the purpose for which we process your data. We share with these recipients only the scope of your data that is necessary to achieve this purpose;
  3. the principle of limiting the purpose of processing – we collect your data only for specific, explicit and legitimate purposes and we do not process them further in a manner incompatible with these purposes. We strive to provide you with proper and precise information as to why and for what purposes we will process your data;
  4. the principle of correctness – we make sure that the data we process is always true, correct, and if necessary – updated so that there are no mistakes, distortions or other irregularities. If you find that in any area your personal data has not been updated by us or is incorrect, please contact us at : [email protected].
  5. the principle of limiting the time of data storage – we will process and store your personal data only for such a period as is necessary to achieve the purpose for which we process your data. At the moment when we no longer need your data in any scope – we will delete all your data from our databases and systems;
  6. principle of integrity and confidentiality – we use the necessary measures to safeguard the confidentiality and integrity of your personal data. Our priority is to ensure full security and protection of your personal data by applying up-to-date and appropriate safeguards;
  7. The principle of accountability – in the field of personal data protection, we not only comply with the terms and conditions of their processing, but we also make every effort to be able to demonstrate compliance with these standards and regulations at all times. The rules for the processing of your personal data are written as part of the procedures, so that in the event of your inquiry, we can provide you with full and reliable information on what activities we have carried out on your data.

Security of personal data

As mentioned above, we use appropriate technical and organizational measures to ensure full security of your personal data against their (culpable or accidental) destruction, loss, modification, unauthorized disclosure or unauthorized access.

These measures consist of technical safeguards (proper protection of the premises and systems in which we process your personal data; safeguards preventing third parties from becoming acquainted with the content of documents containing personal data, making backups, etc.) and rules and procedures that we require all our employees and associates to follow.

Together, the measures we take allow us to adequately protect your personal data against loss or disclosure. In addition, we are constantly improving them, along with the changing environment and technological progress.

What rights do I have in relation to the processing of my personal data?

In connection with the processing of  your personal data by us, you have a number of rights that you can exercise at any time. The