Controller
This document (“Privacy Policy“) describes how Innsyte spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw (03-215) at Jagiellońska 77a/10, entered into the Register of Entrepreneurs of the National Court Register by the District Court for Warsaw in Warsaw, XIV Commercial Division of the National Court Register under KRS number 0001127374, VATID (Numer Identyfikacji Podatkowej, “NIP”): PL1133145784, Statistical number (Rejestr Gospodarki Narodowej, “REGON”): 529657130 (“We/Controller)” processes personal data (“Data“), individuals using the services we provide (“Client“), persons contacting us for various purposes, including as part of the website http://www.innsyte.com (“website“).
We care about your privacy
Therefore, whenever we access your Data, we make sure that it is processed in accordance with applicable law and with the highest standards of privacy and security. We process your Data in accordance with 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 (General Data Protection Regulation) (“GDPR”). We use high standard technical and organizational measures to secure all Data we process against loss, destruction or unauthorized access by third parties.
Source of Data acquisition
We may obtain Data directly from you or from one of our Clients in connection with the negotiation, conclusion or performance of a contract concluded with us or in connection with the process of its archiving.
We may also process Data that you have shared on social networking sites or that we have obtained from publicly available databases, e.g. Central Registration and Information on Business, National Court Register or Central Register of Beneficial Owners.
The data that we obtain depending on the purposes of their processing may be:
- basic identification data (name and surname),
- company name,
- contact details (phone number, e-mail address),
- address details (address of residence, place of stay),
- data on identification numbers (ID card series and number, PESEL, NIP),
- Information about the principal,
- data on citizenship,
- information on work experience.
Data we collect automatically
Our website collects some Data automatically when you visit it. We may obtain information by automated means, such as using browser cookies, pixels, web server logs, web beacons, and other technologies. The information we collect in this way may include:
- Data about your device, including MAC address, IP address, log information, device model, hardware model, IMEI number, serial number, subscription information, device settings, connections to other devices, mobile carrier, web browser characteristics, app usage information, sales code, access code, current software version, MNC, subscription information, and random, non-persistent, and reusable identifiers devices, such as a personalized service identifier (or PSID), and advertising identifiers, including the Google Ads ID;
- Data about your use of the Site, including Clickstream Data, your interactions with the Site (such as the web pages you visit, the search terms you use, and the apps and features you use), the pages that led or referred you to the website, the dates and times you use the website; and your use of third-party websites, apps, and features that are linked to our services;
- Data about your use of third-party websites, apps, and features that are linked to Our Services.
Purposes and legal bases of Data processing
- Provision of services. We use your Information to provide services to you, and to receive, make, or contact you about payments related to them. The legal basis for the processing is the necessity for the performance of a contract to which you are a party (Article 6(1)(b) of the GDPR). The retention period for such data processing lasts until the end of the contract between us.
- Providing services to our Client. We use your Data to enter or perform a contract between us and the entity with which you are affiliated or represent (e.g. a customer, contractor or other entity contacting us). The legal basis for the processing is the legitimate interest of the Controller in the form of performance of concluded contracts (Article 6(1)(f) of the GDPR). The retention period for such data processing lasts until the contract concluded with our Client is performed, terminated or expires.
- Recruitment. We process your Data sent to us as part of the recruitment processes. The legal basis for the processing is: (a) in the case of information specified in the Labour Code, Article 6(1)(c) of the GDPR (compliance with a legal obligation to which the controller is subject); (b) Article 6(1)(b) of the GDPR (performance of a contract) – the processing is necessary to enter into a contract with you; and (c) we process information not related to your qualifications or professional achievements (e.g. photo, interests) on the basis of Article 6(1)(a) of the GDPR (consent); and (d) we process the information that you have voluntarily provided to us that is special category data on the basis of Article 9(2)(a) of the GDPR (consent). We process the Data provided for the purpose of recruitment for the position indicated by us in the job advertisement in the period from the moment of receipt of the application to the end of the recruitment process, but no longer than for a year from its receipt. If you have consented to the processing of your Data as part of future recruitment processes, we will process your Data until you withdraw this consent, but no longer than within one year from the date of its consent. We process the Data processed based on consent until it is withdrawn or when the processing of other Data of a given person is terminated.
- Handling your requests. We will process your Data to respond to your requests or complaints. The legal basis for the processing is the legitimate interest of the controller (Article 6(1)(f) of the GDPR). This legitimate interest is to enable us to properly handle your complaint. The retention period for such processing lasts until the statute of limitations for claims arising from your requests or complaints.
- Compliance with obligations resulting from the law, industry norms and standards and internal regulations of the Controller, including the Privacy Notice. In some cases, we collect and use your Data to comply with legal regulations, for example, Payment Data is processed to comply with tax and accounting obligations. The legal basis for the processing of data is the necessity to comply with a legal obligation to which the Controller is subject (Article 6(1)(c) of the GDPR). The retention period of such data lasts until the relevant provisions of law authorize us to process them.
- Contact. We use your data to communicate with you through various channels. The legal basis for data processing is the legitimate interest of the controller (Article 6(1)(f) of the GDPR). This legitimate interest is to ensure proper communication with you. The retention period for such data processing lasts until the objection to the processing is raised, in any case no longer than 5 years.
- Exercise or defense of legal claims. We process your Data to exercise or defend our legal claims or interests. The legal basis for such processing is the legitimate interest of the Controller (Article 6(1)(f) of the GDPR). This legitimate interest is the exercise or defense of legal claims that we may have or that may be asserted against us. The data is stored for the duration of the legitimate interest pursued by us, but no longer than for the period of limitation of claims (the basic limitation period for claims is six years).
- Website analytics and personalization. We use your Data to personalize content and to analyze the website and web traffic. We use cookies for this purpose. The legal basis for the processing is the legitimate interest pursued by the Controller (Article 6(1)(f) of the GDPR), consisting in the analysis of the user’s activity to optimize the services provided. The period of storage of such data lasts until an effective objection to their processing is raised, but not longer than it is necessary for the purposes of such processing.
Voluntary provision of the Data
The provision of your Data is voluntary. However, without the necessary Data, we may not be able to carry out certain activities requested by you or our Clients; therefore, the provision of such Data is a condition for the conclusion of a contract with us or its performance by us.
Recipients of the Data
In some situations, we may need to share your Data with third parties, such as:
- Third-party service providers – we retain other companies and individuals to perform tasks on our behalf. This includes e.g. providing marketing support, providing legal and accounting services. These third-party service providers have access to your Data to the extent necessary to perform their functions but are not allowed to use it for other purposes. In addition, they must process Data in accordance with the provisions of data processing agreements and applicable data protection law;
- public authorities – in connection with the proceedings conducted by them based on the relevant provisions of law.
Transfer of data to countries outside the European Economic Area
We do not transfer, and do not plan to transfer, User Data from the European Economic Area to countries outside the European Economic Area.
If, in connection with the provision of a service to you or our Client, it is necessary to transfer the Data to service providers or other third parties outside the European Economic Area, we will only make such transfer to: (a) entities located in countries where the EU Commission has found an adequate level of protection within the meaning of Article 45(3) of the GDPR; (b) in the absence of such a decision, the legal basis for the transfer of Data is a contract based on standard contractual clauses constituting a set of principles adopted by the EU Commission, which, in accordance with Article 46 of the GDPR, ensure the security of the transfer of Data; (c) on the basis of your consent (Article 49(1)(a) of the GDPR). We will then inform you of such a transfer of Data.
Your rights
In connection with the processing of your Data by us, you have several rights, such as:
- the right to request access to your Data from us, the right to rectification or erasure of your Data (“the right to be forgotten”);
- the right to object on grounds related to your particular situation, if we process your Data on the basis of a legitimate interest. However, we will continue to process this Data to the extent necessary if there is a legitimate reason;
- the right to transfer or limit the Data processed in connection with the performance of a contract or on the basis of your consent;
- if the basis for the processing of the Data is your consent, you have the right to withdraw this consent at any time. However, the withdrawal of consent does not affect the lawfulness of our processing of Data, which we carried out based on consent before its withdrawal.
You can find more information about your rights in relation to your personal data on this website: https://uodo.gov.pl/pl/493 .
If you believe that our processing of your Data violates the law, you can lodge a complaint with the President of the Office for Personal Data Protection. You can find more information on how to file a complaint here: https://uodo.gov.pl/pl/83/155 .
Automated decision-making
We do not make decisions by automated means, including by means of profiling.
Contact Us
We take the processing of your Data seriously, if you have any questions, comments regarding the protection of your Data or if you would like to exercise your rights under the GDPR, please write to us at: contact@innsyte.com . When contacting us, please remember to provide your contact details and preferred form of contact. This will help us respond to your questions and requests more efficiently.
Current version of the Privacy Notice
The Privacy Notice is information current as of 24 July 2024 on the processing of your Data by us.