Privacy policy

I. Preliminary information and concepts used by us

In order to make the Privacy Policy clear, in places where it was only possible, we have departed from the use of formal, legal vocabulary. Therefore, when we write “You” we mean data subject and/or the service user.

II. Data controller and contact information

The data controller of your personal data is HRK.

HRK has appointed a Data Protection Officer, whose function is performed by Jakub Gałczyński.

In case you have any questions about this privacy policy or regarding the processing of your personal data, please contact the Data Protection Officer at:

HRK S.A.

Pl. Bankowy 2

00-095 Warsaw

Email: [email protected]

III. Legal basis and purposes of processing activities

Below, in the form of a table, we present for what purpose, on what basis, and for how long we process your personal data – depending on the relationship between us (Processing activity column).

Processing activity	Legal basis	Purpose of the processing	Retention period
Representatives and individuals associated with our clients or suppliers	art. 6 sec. 1 let. f) of the GDPR – legitimate interests pursued by HRK	Enabling the provision of professional services to clients; Ordering and receiving services from Suppliers; Clients and Suppliers relationship management; Exercising legal claims in particular by documenting completed services.	Until the end of cooperation with HRK and for the period indicated by statutory provisions of law as long as you or us may pursue legal claims towards each other.
Clients, Suppliers and Subcontractors who are natural persons	art. 6 sec. 1 let. b) of the GDPR – the performance of a contract or to take steps at the request of the data subject prior to entering into a contract	Establishing cooperation with a Client, Supplier or Subcontractor; Ordering and receiving services from Suppliers and Subcontractors.	Until the end of cooperation with HRK and for the period indicated by statutory provisions of law and as long as you or us may pursue legal claims towards each other.
Clients, Suppliers and Subcontractors who are natural persons	art. 6 sec. 1 let. c) of the GDPR – compliance with a legal obligation to which HRK is subject such as: Goods and Services Tax Act, Personal Income Tax Act or Corporate Income Tax Act	Fulfilling HRK’s tax obligations.	Until the end of cooperation with HRK and for the period indicated by statutory provisions of law and as long as you or us may pursue legal claims towards each other.
Clients, Suppliers and Subcontractors who are natural persons	art. 6 sec. 1 let. f) of the GDPR – legitimate interests pursued by HRK	Enabling the provision of professional services to clients; Ordering and receiving services from Suppliers; Clients and Suppliers relationship management; Exercising legal claims in particular by documenting completed services.	Until the end of cooperation with HRK and for the period indicated by statutory provisions of law and as long as you or us may pursue legal claims towards each other.
Job candidates	art. 6 sec. 1 let. a) of the GDPR – consent	Participation in a given recruitment project.	Until the recruitment project is completed.
Job candidates	art. 6 ust. 1 lit. a) RODO – zgoda	Entry to the HRK candidate database (unless separate consent has been granted in this regard).	Until you withdraw the consent.
Website users	art. 6 sec. 1 let. f) of the GDPR – legitimate interests pursued by HRK	Monitoring and enforcing compliance with our terms and conditions for use of our website; Aggregating data for website analytics and improvements;	Until the deletion of cookies files in accordance with information in Cookie section

IV. Do you have to provide your details?

Providing personal data is mandatory – in the scope of processing purposes pursued within the legal obligation. In the remaining scope, providing personal data is voluntary, however, without providing them we will not be able to provide our services or some services will be limited.

V. Who can we pass your data to?

Your personal data will not be disclosed to third parties except:

• Trusted partners and/ or service providers who process personal data on a HRK’s behalf. Service providers may include providers of IT services, including identity management, website hosting and management, data analysis, data back-up, security and storage services in so far as it refers to processing activities;
• Current and potential clients/suppliers of HRK, professional advisors (e.g. law firms), only to the extent necessary to contact you and enable proper performance of obligations arising from concluded contracts;
• Governmental or regulatory authorities, courts and law enforcement authorities or agencies as required by and/or in accordance with applicable law or regulation.

Your personal data may be transferred to countries outside the European Economic Area (EEA) – third countries, based on art. 45 sec. 1 of the GDPR – European Commission’s adequacy decision (applies for countries, which were subject of decision) or art. 46 sec. 2 let. c) of the GDPR – standard data protection clauses adopted by the European Commission.

VI. What are your rights?

The General Data Protection Regulation (GDPR) grants you a number of rights regarding the processing of your personal data. These include:

• the right to access your data, including obtaining a copy of the data;
• the right to request rectification of data;
• the right to erasure of data (in cases provided for in the GDPR);
• the right to restriction of processing of your personal data;
• the right to withdraw consent – to the extent that your data is processed based on your consent. Please note that withdrawing consent does not affect the lawfulness of processing based on consent before its withdrawal;
• the right to data portability;
• the right to lodge a complaint with the supervisory authority – President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych).

To exercise your rights, please contact us at the following email address: [email protected].

VII. Automated decision making

HRK will not make automated decisions regarding you based on your personal data, including profiling.

VIII. Cookie information

Cookies are small text files that are placed on your computer by the websites that you visit. They are widely used in order to make websites work, or work more efficiently, as well as to provide information to the owners of the site. The use of cookies is now standard for most websites. If you are uncomfortable with the use of cookies, you can manage and control them through your browser (see below), including removing cookies by deleting them from your ‘browser history’ (cache) when you leave the site. Please note that removing or blocking cookies can impact your user experience and some functionality may no longer be available.

Most browsers allow you to view, manage, delete and block cookies for a website. Be aware that if you delete all cookies then any preferences you have set will be lost, including the ability to opt-out from cookies as this function itself requires placement of an opt out cookie on your device. Guidance on how to control cookies for common browsers is linked below.

Google Chrome

Mozilla Firefox

MacOS Safari

Microsoft Internet Explorer

The following table explains the way in which we use cookies on this website

Name	Purpose	Type	Duration	Entity responsible
PHPSESSID	Stores the session identifier.	necessary	Until end of session	HRK
_ga _gat	This cookie is set to allow HRK to track individual visitors and their use of the site. It is set when you first visit the site and updated on subsequent visits. HRK does not use Google Analytics to collect personal information, other than IP address, from our visitors.	performance	2 years	Google Inc.
_gid	Used to distinguish users.	performance	24 hours	Google Inc.