Table of Contents
The website terms and conditions can be found at:
https://apersolution.pl/ogolna-klauzula-informacyjna/
1. General Description
We respect your right to privacy
In connection with the changes introduced at APER SOLUTION sp. z o.o. regarding personal data protection resulting from GDPR (i.e., 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)
Purposes of Personal Data Processing
Contact form
If you fill out a contact form, send us an email or letter, we process your data in order to contact you and conduct correspondence with you. Your contact data also serves us to send important communications, e.g., about changes in the functioning of the service, changes in terms and conditions. This data, together with the correspondence itself, will be archived by us. The legal basis for processing in this case is our legally justified purpose as the administrator consisting in conducting correspondence in connection with business activity and the right to archive this correspondence and inform about business activity (Article 6(1)(f)).
Personal data processed for the purpose of handling an inquiry submitted through the contact form is subject to the legal basis - Article 6(1)(a) GDPR, i.e., based on your consent.
This data may include: first name, last name, email address, phone number, and other data contained in the message content. Providing data is voluntary, however, failure to provide it may prevent us from responding to your inquiry.
This personal data will be processed for the period necessary to handle the inquiry, and after its completion for the period resulting from legal provisions or until consent is withdrawn.
You have the right:
– to access your personal data, rectify, delete or restrict processing, as well as to object to processing and the right to data portability
– to withdraw consent to personal data processing at any time, which will not affect the lawfulness of processing carried out based on consent before its withdrawal. To withdraw consent or exercise other rights, please contact us via email: rodo@apersolution.pl
More information at the link:
https://apersolution.pl/ogolna-klauzula-informacyjna/#formularz-kontaktowy
Ordering Goods or Services
If your data was provided in connection with ordering goods or services, we then process it for the purpose of concluding and performing the contract you are interested in. The legal basis for processing is then Article 6(1)(b) GDPR, i.e., the necessity of processing data to perform the contract or the necessity of processing it to take actions at your request before concluding the contract.
Phone Conversation
In the case of a phone conversation, we ask for personal data only when it is necessary to handle the matter you are calling us about and we process it only for that purpose. The legal basis for processing is then our legally justified purpose as the administrator consisting in the need to resolve matters related to our business activity (Article 6(1)(f)).
2. Personal Data Protection Declaration
Dear Sir/Madam,
below we provide you with information regarding the principles of processing personal data by our company, as well as information regarding the rights that you are entitled to in connection with personal data processing under the EU General Data Protection Regulation, known as GDPR. We are obligated to provide this information by law. At the same time, in meeting the requirements, we have tried to convey all information in a transparent and clear manner. However, in case of any doubts, questions or comments regarding this document or our processing of personal data, we invite you to contact us.
Below, in a clear and readable form based on a "question-answer" model, we present the most important information regarding the principles of processing your personal data by us: We indicate that this information clause is directed to our contractors and clients. If your personal data is to be processed by us for a purpose other than indicated below, you will be informed about it.
PART I
Information concerns cases when we obtain your personal data
directly from you
| 1 | Who is the administrator of my personal data? | The administrator, i.e., the entity that decides how and for what purpose the personal data received from you will be processed, is APER SOLUTION Sp. z o.o. with its registered office in Łódź, at ul. Łukasińskiego 4/234, (93-172 Łódź), registered in the District Court for Łódź-Śródmieście in Łódź, XX Commercial Division of the National Court Register under number KRS 0000745538, REGON 381 058 180, NIP 7262674364 |
| 2 | What are the possibilities of contacting the Administrator? | The Administrator directly supervises the process of processing your personal data. Therefore, we encourage you to contact the Administrator through one of the following channels: By email – rodo@apersolution.pl By correspondence – to the address indicated in point 1 |
| 3 | When is my personal data processed, what is the purpose and what is the basis for processing this data under GDPR? | Here we indicate to you what the personal data collected by us is used for, for what purpose we need it. We also indicate that personal data processing has its legal basis by referring to the editorial unit of the relevant provision. We will process your personal data for the purpose of preparing an offer for you, taking actions at the request of the data subject before concluding a contract, e.g., providing answers to inquiries (Article 6(1)(b) GDPR); Personal data processed for the needs of concluding a contract or performing specific services or benefits; We obtain personal data from you at the time of concluding a contract, placing an order for products or services (Article 6(1)(b) GDPR); We also process personal data for the purpose of performing, implementing a contract or providing a service, i.e., for example, sending or receiving goods or implementation (Article 6(1)(b) GDPR); In connection with the concluded contract or services provided on your behalf, a situation may arise where it will be necessary to consider, respond to notifications directed by you to us regarding the contract or provided service (Article 6(1)(b) GDPR) or consider complaints related to the concluded contract or provided services (Article 6(1)(c) GDPR); In connection with the concluded contract, it is necessary to process your personal data also for the purpose of fulfilling obligations incumbent on us, resulting from tax or accounting law provisions, which include in particular issuing invoices, bills, VAT settlement, sales settlement, maintaining accounting documentation (Article 6(1)(c) GDPR); In case of a dispute between us regarding the manner, quality and proper performance or non-performance of a contract or service, it may be necessary to process your data also for the purpose of pursuing claims or defending against claims; this also applies to cases when we will be making complaints about services or contacting you to report a complaint. In this case, we process your personal data in a legally justified interest which is pursuing our rights or protection against unauthorized claims or demands (Article 6(1)(f) GDPR); We will store and process your personal data also for the purpose of creating internal statistics, registers and customer databases, including for the needs of GDPR requirements and legal provisions, processing is therefore carried out due to our justified interest which is striving to accelerate procedures, improve operational efficiency, increase transparency of collected data (Article 6(1)(f) GDPR). In some cases, the obligation to create statistics, registers without data may result from legal provisions (Article 6(1)(c) GDPR). We may also process personal data for the purpose of contacting you and marketing our services. In such case, the basis is our legally justified purpose (Article 6(1)(f) GDPR). |
| 4 | Do I have an obligation to provide personal data? | We indicate that providing personal data by you is voluntary. However, providing this data is necessary to conclude a contract and properly provide our services. Sometimes the obligation to provide it results from legal provisions. |
| 5 | How long is my personal data stored? | We inform you that your personal data will be stored by us for the indicated period of time: for the entire period necessary for contract implementation, service provision or implementation of other activities on your behalf; for a period of 5 years, due to the obligation to store tax documentation for this period or for the archiving period resulting from other legal provisions; for the limitation period of potential claims related to concluded contracts or implemented services. |
| 6 | To whom is my personal data disclosed? | We inform you that your personal data may be transferred to so-called personal data recipients. Recipients of your personal data are entities cooperating with the Administrator in providing services on its behalf, in particular: accounting, payroll-tax, legal, insurance, audit, hosting, IT, debt collection services, courier companies, companies providing goods transport services, postal services, Administrator's contractors and clients, as well as other entities cooperating with the Administrator providing legal services independently deciding on the purposes and methods of personal data processing; On the basis of legal provisions, if required by applicable national or EU law, upon request or to the extent necessary to take specific actions, your personal data will also be transferred to public administration bodies, bodies of other EU member states, judicial bodies, law enforcement agencies, bailiffs. |
| 7 | Is my personal data subject to automated decision-making? | We inform you that we do not apply automated personal data processing, including profiling, to your personal data. |
| 8 | Do I have the right to file a complaint and when? | We inform you that if you consider that personal data processing violates legal provisions, you have the right to file a complaint with the competent supervisory authority – which is currently the President of the Personal Data Protection Office in Poland. |
| 9 | What other rights do I have and how | We indicate that in connection with our processing of your personal data, you have the following rights: the right to request access to personal data from the Administrator – i.e., obtaining confirmation from the Administrator whether your personal data is being processed. If data is being processed, you are entitled to access it and obtain the following information: about processing purposes, categories of personal data, recipients or categories of recipients to whom data has been or will be disclosed, about the data storage period or criteria for determining it, about the right to request rectification, deletion or restriction of personal data processing belonging to the data subject, and to object to such processing (Article 15 GDPR) the right to request rectification – requesting rectification of personal data that is incorrect, or completion of incomplete data (Article 16 GDPR); the right to request deletion of personal data – if the Administrator no longer has a legal basis for processing your personal data or the data is no longer necessary for processing purposes (Article 17 GDPR) the right to request restriction of personal data processing – requesting restriction of personal data processing (Article 18 GDPR), when the data subject contests the accuracy of personal data – for a period allowing the administrator to verify the accuracy of this data, processing is unlawful and the data subject opposes their deletion, requesting restriction of their use instead, the Administrator no longer needs this data, but it is needed by the data subject to establish, pursue or defend claims, the data subject has objected to processing – until it is determined whether the administrator's legally justified grounds are overriding compared to the objection grounds of the data subject; the right to data portability – receiving in a structured, commonly used, machine-readable format the personal data that you have provided to us. You may also request that we send your data to another administrator. However, we will do this when such transfer is technically possible. in case our processing of personal data is based on your consent to their processing, we inform you that you have the right to withdraw consent at any time; withdrawal of consent does not affect the lawfulness of processing carried out based on the expressed consent before its withdrawal. |
| 10. | What is an objection and when can it be filed? | You have the right to file a so-called objection to personal data processing for the Administrator's legally justified purposes, for reasons related to your particular situation, including profiling. Upon filing an objection, we assess the existence of important legally justified grounds for processing on our side (Article 6(1)(f) GDPR), overriding your interests, rights and freedoms, or grounds for establishing, pursuing or defending claims. If we determine that the interest you have demonstrated is more important than the Administrator's interests, then we are obligated to cease processing data for these purposes (Article 21 GDPR). |
| 11 | How is my personal data protected? | We indicate that in connection with personal data processing, we bear responsibility for the security of your personal data. To ensure this security, we apply appropriate and adequate technical and organizational measures aimed at ensuring appropriate confidentiality, including protection against unauthorized access to them and to equipment used for their processing, and against unauthorized use of this data and this equipment. When processing personal data and protecting it, we take into account the type of processed data, the purpose of their processing, context, risk of their disclosure, in particular through the use of data encryption procedures, application of technological and organizational solutions increasing the security of this data. |
| 11 | What else should I know about processing my personal data? | We inform you that processing personal data for purposes other than those indicated above may only take place based on your consent. The legal basis for processing your personal data remains in this case the provisions of Article 6(1)(a) GDPR. In case your personal data would be processed by us for a purpose other than those indicated in point 3 of this table and on a legal basis other than indicated there or above in point 1, we will inform you in advance about this fact, as well as about the rights you have in connection with this. We indicate that your personal data processed by us is not sensitive data and is classified as so-called ordinary personal data. We indicate that this includes the following personal data: first name, last name, residential address, correspondence address, NIP, email address, phone number, job position. We inform you that your personal data is not transferred to third countries or international organizations within the meaning of GDPR. This information clause relating to the principles of personal data processing will be updated by us in every case of change in this regard of generally applicable legal provisions. |
PART II
The following information concerns cases when we obtain your personal data
in a manner other than from the data subject.
| 1 | Who is the administrator of my personal data? | The data controller, i.e., the entity that decides how and for what purpose your personal data will be processed, is APER SOLUTION Sp. z o.o., based in Łódź, at ul. Łukasińskiego 4/234, (93-172 Łódź), registered in the District Court for Łódź-Śródmieście in Łódź, XX Commercial Division of the National Court Register under KRS number 0000745538, REGON 381 058 180, NIP 7262674364 |
| 2 | How can I contact the Data Controller? | The Data Controller directly supervises the processing of your personal data. Therefore, we encourage you to contact the Data Controller through one of the following channels: By email – rodo@apersolution.pl By mail – to the address indicated in point 1 |
| 3 | You have my personal data, when is my personal data processed, what is the purpose and what is the legal basis for processing this data under GDPR? | We indicate that we obtain your personal data from our contractors who are your employers, principals, partners, etc., and who provide us with your personal data. For simplification, we have used the term "employer" to refer to the entity from which we receive your personal data. Below, we indicate how we use the personal data we collect, what we need it for. We also indicate that the processing of personal data has its legal basis by referring to the appropriate section of the relevant provision. We will process your personal data to prepare an offer or respond to an offer to conclude a contract with your employer (Article 6(1)(b) GDPR); Personal data is processed for the purposes of concluding a contract or performing specific services or benefits for the employer; We obtain personal data from you when concluding a contract, placing an order for products or services (Article 6(1)(b) GDPR); We also process personal data to perform, execute a contract or provide a service concluded with your employer, for example, sending or receiving goods or performing, accepting a service (Article 6(1)(b) GDPR); In connection with the concluded contract or services provided to your employer, there may be a situation where it will be necessary to consider and respond to reports directed by the employer to us regarding the contract or service provided (Article 6(1)(b) GDPR) or to consider complaints related to the concluded contract or services provided (Article 6(1)(c) GDPR); In connection with the concluded contract, it is necessary to process your personal data also to fulfill the obligations incumbent on us and resulting from tax or accounting regulations, which include in particular issuing an invoice, bill, VAT settlement, sales settlement, keeping accounting documentation (Article 6(1)(c) GDPR); In the event of a dispute between us and the employer regarding the manner, quality and proper performance or non-performance of the contract or service, it may be necessary to process your data also for the purpose of pursuing claims or defending against claims; this also applies to cases where we will complain about services or contact you to file a complaint. In this case, we process your personal data in our legitimate interest, which is the pursuit of our rights or protection against unauthorized claims or demands, (Article 6(1)(f) GDPR); We will also store and process your personal data for the purpose of creating internal statistics, registers and databases of Customers, including for the requirements of GDPR and legal provisions, therefore processing is carried out due to our legitimate interest, which is striving to accelerate procedures, improve operational efficiency, increase transparency of collected data (Article 6(1)(f) GDPR). In some cases, the obligation to create statistics and registers without data may result from legal provisions (Article 6(1)(c) GDPR). |
| 4 | Am I obliged to provide personal data? | We indicate that providing your personal data is voluntary. However, providing this data is necessary to conclude a contract and properly provide our services. Sometimes the obligation to provide them results from legal provisions. |
| 5 | How long is my personal data stored? | We inform you that your personal data will be stored by us for the indicated period of time: for the entire period necessary for the implementation of the contract, provision of the service or performance of other activities on your behalf; for a period of 5 years, due to the obligation to store tax documentation for this period or for the archiving period resulting from other legal provisions; for the period of limitation of any claims related to concluded contracts or services provided. |
| 6 | Who is my personal data shared with? | We inform you that your personal data may be transferred to so-called recipients of personal data. The recipients of your personal data are entities cooperating with the Administrator in the provision of services, in particular: accounting, HR-tax, legal, insurance, audit, hosting, IT, IT industry, debt collection, courier companies, companies providing goods transport services, postal services, contractors and clients of the Administrator, as well as other entities cooperating with the Administrator providing legal services independently deciding on the purposes and methods of processing personal data; on the principles resulting from legal provisions, if required by applicable national or EU law, at the request or to the extent necessary to take specific actions, your personal data will also be transferred to public administration bodies, bodies of other EU Member States, judicial authorities, law enforcement agencies, bailiffs. |
| 7 | Is my personal data subject to automated decision-making? | We inform you that we do not apply automated processing of personal data, including profiling, in relation to your personal data. |
| 8 | Do I have the right to lodge a complaint and when? | We inform you that if you believe that the processing of personal data violates legal provisions, you have the right to lodge a complaint with the appropriate supervisory authority - which is currently the President of the Personal Data Protection Office in Poland. |
| 9 | What other rights do I have and how | We indicate that in connection with our processing of your personal data, you have the following rights: the right to request access to personal data from the Administrator - i.e., obtaining confirmation from the Administrator whether your personal data is being processed. If the data is processed, you are entitled to access it and obtain the following information: about the purposes of processing, categories of personal data, recipients or categories of recipients to whom the data has been or will be disclosed, about the period of data storage or the criteria for determining it, about the right to request rectification, deletion or restriction of processing of personal data to which the data subject is entitled, and to object to such processing (Article 15 GDPR); the right to request rectification - to request rectification of personal data that is incorrect, or to complete incomplete data (Article 16 GDPR); the right to request deletion of personal data - if the Administrator no longer has a legal basis for processing your personal data or the data is no longer necessary for the purposes of processing (Article 17 GDPR); the right to request restriction of personal data processing - to request restriction of personal data processing (Article 18 GDPR), when the data subject questions the accuracy of personal data - for a period allowing the administrator to verify the accuracy of this data, the processing is unlawful and the data subject opposes the erasure of the data, requesting the restriction of their use, the Administrator no longer needs this data, but it is needed by the data subject to establish, assert or defend claims, the data subject has objected to the processing - until it is determined whether the legitimate grounds on the part of the administrator override the grounds for the objection of the data subject; the right to data portability - to receive in a structured, commonly used machine-readable format the personal data that you have provided to us. in the case where our processing of personal data is based on your consent to their processing, we inform you that you have the right to withdraw consent at any time; withdrawal of consent does not affect the lawfulness of processing that was carried out on the basis of consent before its withdrawal. |
| 10. | What is objection and when can I raise it? | You have the right to raise a so-called objection to the processing of personal data for the Administrator's legally justified purposes, for reasons related to your particular situation, including profiling. At the time of raising an objection, we assess the existence on our part of these important legally justified grounds for processing (Article 6(1)(f) GDPR), overriding your interests, rights and freedoms, or grounds for establishing, pursuing or defending claims. If we determine that the interest you have demonstrated is more important than the interests of the Administrator, then we are obliged to cease processing data for these purposes (Article 21 GDPR). |
| 11 | How is my personal data protected? | We indicate that in connection with the processing of personal data, we are responsible for the security of your personal data. To ensure this security, we apply appropriate and adequate technical and organizational measures aimed at ensuring appropriate confidentiality, including protection against unauthorized access to them and to the equipment used for their processing, and against unauthorized use of this data and this equipment. When processing personal data and protecting it, we take into account the type of data processed, the purpose of their processing, the context, the risk of their disclosure, in particular through the use of data encryption procedures, the use of technological and organizational solutions that increase the security of this data. |
| 11 | What else should I know about the processing of my personal data? | We inform you that the processing of personal data for purposes other than those indicated above may take place only on the basis of your consent. The legal basis for the processing of your personal data in this case remains the provisions of Article 6(1)(a) GDPR. In the event that your personal data were to be processed by us for a purpose other than those indicated in point 3 of this table and on a legal basis other than that indicated there or above in point 1, we will inform you in advance about this fact, as well as about the rights you are entitled to in connection with this. We indicate that the personal data processed by us is not sensitive data and is classified as so-called ordinary personal data. We indicate that these include, among others, the following personal data: name, surname, residential address, correspondence address, NIP (tax identification number), email address, phone number, job position. We inform you that your personal data is not transferred to third countries or international organizations within the meaning of GDPR. This information clause regarding the principles of personal data processing will be updated by us in each case of changes in this regard to the provisions of generally applicable law. |