Privacy Policy

Privacy Policy

Updated 04.09.2024

Effective 04.09.2024

1. INTRODUCTION

• 1 We respect the right to privacy and take care of data security. Data protection is carried out in accordance with the requirements of generally applicable laws, in particular the RODO. Data storage takes place on secured servers, computers, mobile devices and in secured premises. We have implemented appropriate technical and organizational safeguards, introduced and apply appropriate procedures, policies and instructions to enable the proper functioning of the data processing processes we carry out, train our personnel in the field of data protection, and control and verify the data protection system in place.
• 2 For the purposes of this Privacy Policy of PHRONESIS PATH sp. z o.o., we use the following abbreviations:
  • “Policy” – means this Privacy Policy of PHRONESIS PATH sp. z o.o.;
  • “We” – means the Administrator referred to in Section 2;
  • “You” – means you, i.e. the natural person whose data is processed by us;
  • “Data” – means personal data;
  • “Customers” – means those purchasing goods and services included in our commercial offer;
  • “Contractors” – means those providing us with goods and services;
  • “RODO” – means 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.

2. ADMINISTRATOR

• The administrator of the data is PHRONESIS PATH Spółka z ograniczoną odpowiedzialnością, 10 Św. Jana St., 40-012 Katowice, registered in the Register of Entrepreneurs of the National Court Register kept by the District Court of Katowice – Wschód in Katowice, VIII Economic Department of the National Court Register under the number 0001097915, NIP: 634-30-37-520, REGON: 528260040.

3. PURPOSES, LEGAL BASIS FOR PROCESSING, STORAGE PERIOD, TRANSFER OF DATA TO THIRD COUNTRIES OR INTERNATIONAL ORGANIZATIONS

• 1 Parameters such as the purposes of data processing, legal basis for data processing, data retention period, transfer of data to third countries or international organizations – for individual categories of persons are indicated in the tabs referenced below.
• 2 Where data processing is carried out on the basis of a legitimate interest of the Data Controller, we try to analyze and balance our interest and the potential impact on the data subject (positive as well as negative) and the data subject’s rights under data protection laws. We do not process data where the impact on the data subject outweighs our interests (unless we have appropriate consent or are required or permitted to do so by law).
• 3 We have also prepared information for you about the parameters listed in 3.1. The list of categories is below.

4. PERSONS WHOSE DATA ARE TRANSFERRED

• Recipients of your personal data may be the relevant Tax Offices and other law enforcement authorities, regulatory and other governmental authorities or third parties, if required by applicable laws (the transfer of data will take place in accordance with these laws). In addition, your data will be transferred to entities to whom we outsource legal services, our auditors, entities that supply or operate our IT system or provide us with other IT services, entities responsible for controlling entrances and exits to our premises, as well as entities that perform destruction of data carriers, based on a contract with us, and those that provide us with other services or goods in support of our operations.

5. YOUR RIGHTS

• 1 You are entitled to:
  • The right to access your data and receive a copy of it.
  • The right to rectify (amend) your data.
  • The right to delete your data.
    • If, in your opinion, there are no grounds for us to process your data, you may request that we delete it. This right may not be exercised if our processing of your data is mandatory or we have a basis for processing other than your consent.
  • Restrictions on data processing
    • You can request that we restrict the processing of your personal data only to storing it or performing activities agreed with you, if in your opinion we have inaccurate data about you or are processing it unfoundedly; or you do not want us to delete it because you need it to establish, assert or defend a claim; or for the duration of your objection to the processing. This right may not be exercised if our processing of your data is mandatory (that is, required by law) or we have a basis for processing other than your consent.
  • The right to object to data processing.
    • Individuals have the right to restrict processing or object to the processing of their data at any time, based on their particular situation, unless the processing is required by law. In this case, we will no longer process the data or will restrict the processing as long as we can demonstrate a legitimate basis for the processing or for establishing, exercising or defending our rights.
  • Right to data portability:
    • You have the right to receive from us in a structured, commonly used machine-readable format (e.g., ,,csv” format) data concerning you that you have provided to us under a contract or your consent. You may also have us send this data directly to another entity. This right may not be exercised if our processing of your data is mandatory or we have a basis for processing other than your consent or contract, or if your data is processed only in paper form.
  • The right to lodge a complaint.
    • Protecting your data is a priority for us. However, if you believe that we are processing your data unlawfully, if you wish to file a complaint about our use of your data, please send an email with details of your complaint to the following email address: admin@phronesispath.com. Any complaints received will be investigated and we will respond to them. You may file a complaint with the President of the Office for Personal Data Protection (2 Stawki Street, 00-193 Warsaw).
  • The right to withdraw consent to data processing.
    • At any time you have the right to withdraw your consent to the processing of those data that we process based on your consent. Withdrawal of consent will not affect the lawfulness of the processing that was carried out on the basis of your consent before its withdrawal. This right may not be exercised if our processing of your data is mandatory or we have a basis for processing other than your consent.
  • 2 To exercise your rights, direct your request to the following email address: admin@phronesispath.com or report to the address indicated in Section 2.
  • 3 Please note that before exercising your rights we will need to make sure that you are you, i.e. identify you accordingly.

6. PROFILING

• Your data is not profiled by us. Profiling, according to the RODO, means a form of automated data processing that involves the use of data to evaluate certain personal factors of an individual, in particular to analyze or forecast aspects of that individual’s performance, economic situation, health, personal preferences, interests, reliability, behavior, location or movement.

7. COOKIES

• 1 This website, for your convenience, uses cookies. Cookies are small text files sent by the website you visit to your device.
• 2 This site uses:
  • functional cookies, which are used to “remember” your settings (e.g. language, font size).
  • functional cookies allowing the user to post questions or comments
  • necessary cookies monitoring interruptions in website access and protection against spam or abuse
• 3 By using our site, you consent to our use of cookies to provide you with convenience when browsing the Policy. You can change the settings of these cookies at any time via your browser settings.

CUSTOMERS AND CONTRACTORS

Purposes of data processing:

Your data is processed for the purpose of handling the relationship and settlements between you and us, including the conclusion and performance of the contract for the purchase and sale of goods or services, issuing accounting documents, managing contracts, orders, making and receiving deliveries, arranging transportation, handling complaints, confirming balances, monitoring payments, collecting receivables, managing disputes, as well as for analytical and statistical purposes, conducting quality of service surveys, and directing marketing content to you.

Legal bases for data processing:

• execution of the contract concluded between you and us or taking action prior to its conclusion – Article 6(1)(b) RODO,
• provisions of generally applicable law, i.e. tax and accounting regulations – Article 6(1)(c) RODO,
• our legitimate business interest – Article 6(1)(f) RODO – in the form of:
  • ensuring proper execution of cooperation with you,
  • establishing, asserting or defending claims,
  • direct marketing of our goods and services (by email to your address or by text message to your phone number – if you have given your consent),
  • to conduct analysis of the results of our business activities,
  • to learn about the level of satisfaction with the transaction carried out by us.

Transfer of data to third countries or international organizations

We do not transfer your data outside European Union or to international organizations.

Data storage period

We store your data contained in the records (paper and electronic) for no longer than 10 years, to the extent regulated by law – in accordance with applicable regulations. Data from video surveillance will be stored for a maximum of 3 months from the date of recording. In the event that the image recordings constitute evidence in proceedings under the law or we become aware that they may constitute evidence in the proceedings, the storage period shall be extended until the final conclusion of the proceedings. After the expiration of the periods referred to in the preceding sentences, the image recordings containing data obtained as a result of the monitoring shall be destroyed, unless otherwise specified in separate provisions.

INDIVIDUALS ASSOCIATED WITH OUR CLIENTS AND CUSTOMERS

Data collection:

We collect only the data necessary to fulfill the purposes specified below, and ask our Clients and Contractors to provide personal data only when necessary. Where we need to process personal data in order to carry out cooperation with our Customers and Contractors, we ask them to provide the data of persons participating on behalf of these Customers and Contractors in the performance of the cooperation, including persons to contact for the performance of the contract or order and auxiliary services related thereto (e.g., transportation). As a rule, we collect this personal data from our Customers and Contractors or from third parties acting in accordance with the instructions of the respective Customer or Contractor.  Personal data may include first and last name, name of employer or principal, position, telephone number, e-mail address, vehicle registration number and identification document designation (in terms of traffic records of vehicles and their drivers) and other business contact information.

Data processing purposes:

Your data is processed for the purpose of handling the relationship and settlements between us and our Customer or Contractor with whom you are associated, including the conclusion and performance of the contract for the purchase and sale of goods or services, the issuance of accounting documents, the management of contracts, orders, the execution and receipt of deliveries, the organization of transportation, the handling of complaints, the confirmation of balances, the monitoring of payments, the collection of receivables, the management of disputes, as well as for analytical and statistical purposes, the conduct of research on the quality of service, the targeting of marketing content.

Legal bases for data processing:

• provisions of generally applicable law, e.g. tax and accounting regulations – Article 6(1)(c) of the RODO,
• our legitimate business interest – Article 6(1)(f) RODO – in the form of:
  • ensuring proper execution of cooperation with the Client or Contractor with whom you are associated,
  • establishing, asserting or defending claims,
  • direct marketing of our goods and services to our Client or Contractor with whom you are associated,
  • to conduct analysis of the results of your business activities,
  • to learn about the level of satisfaction with the transaction carried out by us.
  • Consent, where we have requested such consent from the data subject – Article 6(1)(a) of the RODO.

Transfer of data to third countries or international organizations

We do not transfer your data outside the European Union or to international organizations.

Data retention period:

We keep your data contained in the records (paper and electronic) for no longer than 10 years, to the extent regulated by law – in accordance with the applicable regulations. Data from video surveillance will be stored for a maximum of 3 months from the date of recording. In the event that the image recordings constitute evidence in proceedings under the law or we become aware that they may constitute evidence in the proceedings, the storage period shall be extended until the final conclusion of the proceedings. After the expiration of the periods referred to in the preceding sentences, the image recordings containing data obtained as a result of the monitoring shall be destroyed, unless otherwise specified in separate provisions.

VISITORS TO OUR COMPANY

Collection and transfer of data:

We collect only the data necessary to fulfill the purposes specified below and request personal data only when necessary. When we need to process personal data in order to carry out cooperation with our Customers and Contractors, we ask them for the data of persons participating on behalf of these Customers and Contractors in the performance of the cooperation, including persons to contact for the performance of the contract or order and auxiliary services related thereto (e.g., transportation). As a rule, we collect this personal data from our Customers and Contractors or from third parties acting in accordance with the instructions of the respective Customer or Contractor. Personal data may include name, name of employer or principal, position, telephone number, e-mail address, vehicle model and registration number and identification document designation (in terms of vehicle traffic records and their drivers) and other business contact information.

Purposes of data processing:

Your data has been provided to us for the purpose of providing you with access to our Company’s premises and is processed for the purpose of ensuring the security of persons and property.

Legal bases for data processing:

• Our legitimate interest – Article 6(1)(f) RODO – in the form of:
  • the need to ensure traffic control on the site, including ensuring the presence of persons invited by us to the site,
  • the need to ensure the security of persons and property.

Transfer of data to third countries or international organizations

We do not transfer your data outside of European Union or to international organizations.

Data storage period:

Video surveillance data will be stored for a maximum of 3 months from the date of recording.  In the case where the image recordings constitute evidence in proceedings under the law, or we have become aware that they may constitute evidence in the proceedings, the storage period is extended until the proceedings are legally concluded.  After the expiration of the periods referred to in the preceding sentences, the image recordings containing data obtained as a result of the monitoring shall be destroyed, unless otherwise specified in separate provisions.

We keep records (paper and electronic) of visitor traffic for a period of three years after your last visit to us. These records are securely stored and can only be accessed in exceptional cases (e.g., to investigate an incident).

JOB CANDIDATES

Purposes of data processing:

Your data is processed for the purpose of recruitment and your application for employment with our company.

Legal bases for data processing:

• provisions of generally applicable law, i.e. in particular Article 22 of the Labor Code, Labor Code – Article 6(1)(c) RODO,
• our legitimate interest – Article 6(1)(f) RODO – in the form of:
  • ensuring the proper conduct of the recruitment process,
  • ensuring the appropriate level of employment, selection of personnel for the quality of work provided, as well as the proper operation of our business.
• Where a Job Candidate has consented to the processing of his/her data, the basis for processing is also the consent expressed – Article 6(1)(a) of the DPA.

Transfer of data to third countries or international organizations

We do not transfer your data outside European Union or to international organizations.

Data retention period

Your data contained in documentation (paper and electronic) is stored for a maximum of 6 months from the date of receipt. Data from video surveillance will be stored for a maximum of 3 months from the date of recording. In cases where the image recordings constitute evidence in proceedings under the law or we have become aware that they may constitute evidence in the proceedings, the storage period is extended until the proceedings are legally concluded. After the expiration of the periods referred to in the preceding sentences, the image recordings containing data obtained as a result of the monitoring shall be destroyed, unless otherwise stipulated by separate provisions.

PERSONS USING THE CONTACT FORM AVAILABLE AT www.phronesispath.com

Data processing purposes: 

We process your data contained in the contact form in order to enable you to contact us on a matter of interest to you, in particular with an inquiry regarding the goods and services we offer, and to provide you with feedback by e-mail to the e-mail address you provided, as well as for analytical and statistical purposes, to conduct quality of service research, to direct marketing content to you.

Legal grounds for data processing:

When you direct an e-mail message to us using the contact form, we do not know whether you belong to any of the categories of persons listed in another of the Privacy Policy’s tabs – for example, whether you are our customer. Therefore, the essential basis for processing your personal data is your consent – Article 6(1)(a) of the RODO.

Transfer of data to third countries or international organizations

We do not transfer your data outside European Union or to international organizations.

Data storage period

We store your data provided in the contact form for no longer than 10 years, and to the extent regulated by law, in accordance with applicable regulations.

VIDEOCONFERENCE PARTICIPANTS

Data collection:

We collect only the data necessary to fulfill the purpose specified below and request personal data only when necessary. If you are our Client or Contractor or a member of our Client’s or Contractor’s staff, and we need to process personal data in order to carry out cooperation with our Clients and Contractors, we ask Clients and Contractors or you directly to provide data of persons participating on behalf of these Clients and Contractors in the implementation of cooperation in the form of Videoconferencing. As a rule, we collect this personal data from our Customers and Contractors or you, or from third parties acting in accordance with the instructions of the respective Customer or Contractor.

Personal data subject to processing may include:

• Basic data, the scope of which depends on the use of the platform, in particular it is: name, surname, email, phone, login, password, organization name, avatar.
• Content: data contained in the conversation (image, sound, files, chats) – this is unstructured data.
• Technical/telemetric data: IP, location, hardware features, traffic volume.
• What specifically is recorded – the presenter’s speech (image and sound or sound alone), images and voice of all people participating in the meeting, presentation, content published in the chat, captions for images or publications of individuals (usual names of participants, name of employer or principal, position, phone number, email address, other business contact information).

Data processing purposes: 

Holding remote meetings, as part of the Administrator’s activities

Legal grounds for data processing:

• Conclusion or execution of a contract (including an order) – Article 6(1)(b) RODO
• Legitimate interests pursued by the Administrator (realization of the Administrator’s economic and legal interests in the form of: streamlining business processes – Art. 6(1)(f) RODO

Recipients of data:

Recipients of personal data will be entities authorized to obtain personal data under the law and entities providing services to the Administrator.

Rights of persons

8. Persons whose personal data is processed have the right to request from the Administrator access to personal data, the right to rectify, delete or restrict processing, and the right to lodge a complaint with the President of the Office for Personal Data Protection.

Transfer of data to third countries or international organizations

PHRONESIS PATH sp. z o.o. uses the business version of the Microsoft Teams tool for remote communication. We use the option to limit the processing of personal data to the territory of the European Union only. 

Data retention period

In accordance with applicable regulations, no longer than 6 years

Voluntariness of data submission

The provision of personal data by the user is voluntary, but participation in events conducted through platforms enabling meetings organized by the Administrator requires the provision of name, surname and e-mail address. Provision of the aforementioned data is necessary to obtain a hyperlink to a virtual meeting place and to verify the right to participate in meetings