Privacy Policy of the https://hrlaw.pl/en/ Website

1. What is the purpose of this document?

The use of the website https://hrlaw.pl/en/ (hereinafter “the Site”) involves the processing of personal data of individuals who use the Site.

This document provides information on the processing of personal data of users of the Site in relation to their use of the Site in accordance with the 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).

2. What can you learn from this document?

Among other things, this document will tell you:

• Who is responsible for processing your personal data in relation to your use of the Site (point 4);
• How to contact us (point 5);
• The purposes for which we process your personal data (point 6);
• The rights you have in relation to our processing of your personal data (point 11).

3. What do the terms used in this document mean?

The terms shown below have the following meaning in this document:

• “Data” - personal information about individuals who use the Site that is processed in connection with their use of the Site, including the elements and pages of the Site that they view, logs, information about the devices they use, IP address, browser settings, device information (e.g. IMEI), information about errors that occur when connecting to the Site;
• “Policy” - this Privacy Policy;
• “Cookie Policy” - a document containing information about the cookies used on the Site, available at: https://hrlaw.pl/en/cookies-policy
• “You” - the user of the Site.

4. Who is the controller of the personal data of the users of the Site processed in connection with the operation of the Site?

The controller of the personal data processed in connection with the use of the Site is WiW Services sp. z o.o. with its registered office in Warsaw, 00-478 Warsaw, Al. Ujazdowskie 10 (“the data Controller”, “we”).

As the data controller, we are responsible for processing your data in accordance with the law and have a number of related regulatory obligations - you should contact us on any matters relating to your data.

5. How can you contact us?

For any matters relating to the data, in particular matters relating to the exercise of your rights under the data protection legislation referred to in point 11 below, please contact us by writing to the Controller’s registered office address indicated in point 4 or by email to dane.osobowe@wardynski.com.pl.

6. What is the purpose and basis of our data processing and what are the possible consequences of providing the data?

Purpose of Data Processing	Legal Grounds of Data Processing	Consequences of Not Providing Data
To allow you to use the Site without interruption and correctly, in accordance with its functionalities and the conditions of use of the Site.	GDPR Article 6(1)(b)	Data collected automatically
In some cases, to comply with legal obligations, including those under tax and accounting legislation	GDPR Article 6(1)(c)	The right to request data derives from the law. Failure to provide data will prevent us from properly fulfilling our legal obligations and may have other legal consequences depending on the situation.
In some cases, to respond to requests and complaints.	GDPR Article 6(1)(f), i.e. our legitimate interest, including our right to respond to your requests.	Your provision of data is voluntary, but necessary to process your request.
To send you commercial and marketing information, to the extent that you have consented to the sending of such content.	GDPR Article 6(1)(f), i.e. our legitimate interest, which includes our right to direct commercial and marketing content to you to the extent resulting from your consent to receive such content based on separate regulations, in particular the provisions of the Act on Electronic Services.	The data you provide is voluntary, but necessary in order for you to receive our newsletter.
In some cases - the establishment and assertion of claims, or defence against claims.	GDPR Article 6(1)(f), i.e. our legitimate interest, which includes our right to establish or assert claims, or defend against claims.	Data collected automatically
Detecting possible threats or failures to ensure the secure and uninterrupted operation of the Site, in particular to detect, prevent and mitigate the effects of breakdowns, cyber attacks and similar incidents.	GDPR Article 6(1)(f), i.e. our legitimate interest, which includes our right to ensure the secure and uninterrupted operation of the Site.	Data collected automatically
Analytical and statistical purposes in order to improve the Website	GDPR Article 6(1)(f), i.e. our legitimate interest, which includes our right to conduct analytical research in order to improve the Site	Data collected automatically

7.  What are the sources of our data? What are the categories of this data?

Data Sources	Methods of Data Collection and Categories of Collected Data Collected
Data collected directly from you (e.g. when you send us an enquiry).	Data provided by you when you send us an enquiry or subscribe to our newsletter.
Data that we collect automatically (without our direct involvement) when you use the Site, including activity and other logs.	The data includes, for example, the pages and sub-pages you view, logs, information about your device (e.g. IMEI), IP address, browser settings, information about errors that occurred during your connection to the Site.

8.    Do we share the data with other recipients? Who may receive the data?

In some cases, we will transfer your data to other parties - if and to the extent permitted by data protection legislation, including upon compliance with any conditions provided for by such legislation.

Data may be transferred to companies that provide services to the Controller, including IT service and solution providers, marketing agencies, insurance companies, postal and courier service providers, audit service providers and companies that are part of the same group as the Controller.

In addition, data may be made available to courts and public authorities (e.g. tax authorities) if this is necessary in connection with the defence against or assertion of claims, or if required by law.

9.    Do we transfer your data outside of the European Economic Area?

We will not transfer your data outside the European Economic Area.

10.  How long will we keep your data?

We will keep your data for as long as is necessary for the purposes for which it was collected.

This means, among other things, that:

1. Data collected to respond to your enquiry/request will be processed until the enquiry/request has been handled and for the statutory limitation period for any claims;
2. Data collected for the purpose of sending you the newsletter will be processed only until our legitimate interest in doing so ceases to exist (in particular, only until you object to the processing of your data for this purpose or revoke your consent to receive commercial and marketing information on the basis of separate relevant legislation);
3. Data collected for analytical and statistical purposes will be processed for the time necessary to achieve the objectives of the proper functioning and development of the Site;
4. In the case of data processed on the basis of your consent, it will not be kept longer than until you withdraw your consent;
5. Data processed by us for the purpose of establishing and asserting clams or defending against claims will be processed for the period necessary for this purpose, but not beyond the expiry of the statutory limitation period;
6. Where the obligation to store data arises from legislation (e.g. tax or accounting law), we will store the applicable data for the period required by the relevant legislation.

11.  What are your rights in relation to our processing of your data?

In relation to our processing of your data, you have the following rights: to object to the processing of your data, to request access to your data, to rectify, erase or restrict the processing and the right to data portability. Your ability to exercise the above rights may depend on which category of data is processed.

In addition, where we process data on the basis of consent, you have the right to withdraw your consent at any time by contacting us in writing or by email (dane.osobowe@wardynski.com.pl). Withdrawal of your consent will not affect the lawfulness of any processing that took place before it.

If your personal data is processed for direct marketing purposes, you have the right to object at any time to the processing of the data for such marketing purposes, including profiling, to the extent that the processing is related to such direct marketing.

You also have the right to lodge a complaint with the supervisory authority, i.e. the President of the Data Protection Office.

12.  Will we use your data for automated decision making, including profiling?

We will not use your data for automated decision making, including profiling.

13.  Policy changes

This policy may change from time to time, particularly if the operation of the Site changes (e.g. new features are introduced) or if legislation changes. Please see below for the date of the last update.

Date of last policy update: 24 April 2024.