Privacy Policy of Nuctech Warsaw Company Limited sp. z o.o. [limited liability company] with its registered office in Warsaw
Information on Personal Data Processing

1. What does this policy describe?

This privacy policy (the “Policy”) contains information on the processing of personal data by Nuctech Warsaw Company Limited sp. z o.o. with its registered office in Warsaw and:

• specifies types of personal data that are collected;
• explains how and why your personal data are collected and used;
• explains when and why the personal data will be shared with other entities; and
• explains the rights and potential options that you have as far as your personal data are concerned.

We want you to clearly understand whether this Policy also includes principles of the processing of your personal data. The Policy applies, if:

• you are a Website User or an On-line Training Participant, i.e. you use the Internet service www.nuctechwarsaw.com (the “Website”);
• you are a Customer, i.e. you are interested in our products, and in particular you purchase our products;
• you a Customer’s Representative, i.e. you represent a Customer;
• you are a Service Provider, i.e. you provide us with products or services;
• you are a Service Provider’s Representative, i.e. you represent an entity that provides us with products or services;
• you are a Job Applicant, i.e. you are interested in our job offers.

We process your personal data in accordance with the EU General Data Protection Regulation (2016/679) (the “GDPR”) and other applicable regulations on personal data protection which supplement and/or implement the GDPR.

2. Who is the controller of your personal data?

he controller of your personal data is:

Nuctech Warsaw Company Limited sp. z o.o. with its registered office in Warsaw
ul. Emilii Plater 53
00-113 Warsaw
e-mail: rodo.pl@nuctech.com
(“we”)

In matters relating to personal data protection, we can be contacted by mail or at the above mentioned e-mail address or at the e-mail address of our Data Protection Officer: nuchtech.iod@discretia.pl.

3. What information and from what sources are collected?

If you are a User of our Website or an On-line Training Participant, we collect the information recorded during your use of the Website. These include, in particular, information that you provide in e-mails sent to us, IP address, information contained in cookie files as well as your username (login).

If you are a Customer or a Customer’s Representative, we collect information recorded when contact with us is established, including when you fill in a form, when orders are placed by you and then executed. These can include, in particular, first and last name, telephone number, e-mail address, bank account number, and the order-relating information contained in messages sent to us.

If you are a Service Provider, we collect information that we are provided with in documents that you send to us, during discussions, meetings, when we exchange e-mails, including, in particular, information necessary for agreement conclusion and performance. These can include, in particular, first and last name, business name, business activity address, personal identification number PESEL, tax identification Number (NIP), statistical number (REGON), bank account number. Your data may also originate from publicly available sources.

If you are a Service Provider’s Representative, we collect information that we are provided with in documents sent by you, during discussions, meetings, when we exchange e-mails. These can include, in particular, your first and last name, contact details, job title, data relating to the entity that you represent. Your data can be also provided to us by the entity that you represent, both before and during cooperation with us.

If you are a Job Applicant, we collect information that we are provided with in the submitted application documents, provided to us during discussions, meetings, when we exchange e-mails. These can include, in particular, your first and last name, other identification data, contact details as well as information on your education and experience.

4. For what purpose and under what basis do we process your data?

If you are a Website User or an On-line Training Participant, we process your data:

• for the purpose of organising an on-line training as part of performance of a concluded agreement if you are a participant thereof (Article 6(1)(f) of the GDPR);
• for the purpose of pursuing our legitimate interest (Article 6(1)(f) of the GDPR), consisting in administering the Website.

If you are a Customer or a Service Provider, we process your data:

• for the purpose of agreement conclusion and performance (Article 6(1)(b) of the GDPR);
• for the purpose of meeting legal obligations (Article 6(1)(c) of the GDPR), e.g. in respect of tax settlements or keeping financial documentation;
• for the purpose of pursuing our legitimate interests (Article 6(1)(f) of the GDPR) relating to maintaining business relations, on-going contact, conducting marketing activities as well as exercising and defending claims, and also as part of cooperation with Nuctech Group entities, i.e. Nuctech Company Limited with its registered office in Beijing.

If you are a Customer or Service Provider’s Representative, we process your data:

• for the purpose of pursuing our legitimate interests (Article 6(1)(f) of the GDPR) relating to the conclusion and performance of the agreement with the entity that you represent, maintaining business relations and on-going contact, conducting marketing activities as well as exercising and defending claims, and also as part of cooperation with Nuctech Group entities, i.e. Nuctech Company Limited with its registered office in Beijing.
  
  

If you are a Job Applicant, we process your data:

• for the purposes relating to the conducted recruitment process and for the purpose of including your application in the future recruitment processes (provided that you give additional consent thereto) (Article 6(1)(a) of the GDPR, Article 9(2)(a) of the GDPR);
• for the purpose of fulfilling our obligations as an employer, in respect of the collection of data, and your rights under the law, including labour law (Article 6(1)(c) of the GDPR);
• for the purpose of pursuing our legitimate interests (Article 6(1)(f) of the GDPR) in connection with administering the recruitment processes, and also as part of cooperation with Nuctech Group entities, i.e. Nuctech Company Limited with its registered office in Beijing.

5. Who are your data made available to?

When this is necessary for the purposes for which your data are processed, we can transfer them to:

1. entities entitled to obtain them under the law;
2. entities processing personal data on our behalf, i.e. companies that provide us with certain services, whose provision entails personal data processing, e.g. entities that service our IT systems or that make the ITC tools available to us, entities that provide us with advisory services as well as others (so called processors);
3. Nuctech Group entities, i.e. Nuctech Company Limited with its registered office in Beijing.
   
   

The Controller belongs to the group of companies whose member is Nuctech Company Limited with its registered office in Beijing, China. Therefore, in justified cases, your personal data can be transferred outside the territory of the European Economic Area (EEA). Cooperation with the said entity and the transfer of personal data are carried out on the basis of appropriate legal grounds and in compliance with appropriate personal data protection standards.

In each case when your data are made available, we will take care to transfer only minimum amount of information necessary to accomplish the purpose of data processing.

6. How long do we store your data?

If you are a Website User or an On-line Training Participant, we store your personal data for as long as it is necessary for the purposes of administering the Website or the purposes relating to undergoing the training.

If you are a Customer, Service Provider, or a Customer or Service Provider’s Representative, we store your data for the period of performance of the agreement concluded with you or the entity represented by you. After the lapse of this period, to the necessary extent, we store your data for a period resulting from legal requirements (e.g. the obligation to retain financial documentation for 5 years), regulations on limitation periods of claims (3 years for limitation period of claims resulting from business activity) or necessary to achieve other purposes of data processing indicated in this document.

If you are a Job Applicant, we store your data until the end of the recruitment process. If we have your consent to use your data for the purpose of future recruitment processes, they will be stored for a period during which they can be used for this purpose. If the processing of your data is carried out based on consent, your data will not be stored longer than until your consent is withdrawn.

7. What rights do you have?

In order to exercise your rights in respect of personal data processing, you can submit to us the following requests:

1. if we process your personal data on the basis of your consent, you can withdraw such consent at any time; withdrawing the consent shall not affect the lawfulness of processing carried out by us based on consent before its withdrawal;
2. you can demand access to your personal data and obtain a copy thereof;
3. you can exercise the right to data portability;
4. you can request that your personal data be rectified, if they are inaccurate or incomplete;
5. on grounds relating to your particular situation, you can object to the processing of your personal data if we process them citing our legitimate interest;
6. in cases defined by law – e.g. when your data are invalid, unnecessary, or processed in breach of the law, and also if you have withdrawn your consent to data processing (if your consent provided grounds for such processing) or if you have effectively objected to the processing of your personal data – you can request that your personal data be erased;
7. you can also request that the data processing be limited.
   
   

In order to exercise the above rights, please contact us by mail or at e-mail address rodo.pl@nuctech.com or at e-mail address of our Data Protection Officer: nuchtech.iod@discretia.pl.

Whenever you find that our processing of personal data violates the GDPR, you also have the right to lodge a complaint with the President of the Personal Data Protection Office.

8. Do you have to provide us with your data and where do we take them from if they are not provided by you?

In each case you provide your data on a voluntary basis, but please remember that refusal to provide them will prevent us from achieving the purposes for which they are collected, and in particular, will prevent or significantly hinder making contact with you, or will prevent conclusion of an agreement.

If you are a Customer or Service Provider’s Representative and you do not provide us with your data on your own, they originate from the entity that you represent or have been collected by us from publicly available sources (e.g. a website).