Notification obligation – social media

Notification obligation – social media

USERS OF FANPAGE, LINKEDIN PROFILE, YOUTUBE CHANNEL

I. Data of the controllers of personal data

We kindly inform you that the controllers of your personal data are the companies:

  • Aldesa Polska Services sp. z o.o. with its registered office at Wołoska 5, 02-675 Warsaw, entered in the National Court Register under number 0000287883, using NIP number 676-235-6224, e-mail address: biuro@aldesa.pl,
  • Aldesa Construcciones S.A. with its registered office in Madrid at c/Bahia de Pollensa 13 28042 Madrid, registered in the Madrid Commercial Register , first entry no: K.17.979,FILE 139 I N, T.2.676, BOOK 2.009, SECTION III, e-mail address: biuro@aldesa.pl,
  • Aldesa Construcciones Polska sp. z o.o. with its registered office at Wołoska 5, 02-675 Warsaw, entered in the National Court Register under number 0000288135, using NIP number 6762355756, e-mail address: biuro@aldesa.pl,
  • Aldesa Nowa Energia sp. z o.o. with its registered office at Wołoska 5, 02-675 Warsaw, entered in the National Court Register under number 0000287686, using NIP number 6762356201, e-mail address: biuro@aldesa.pl,
  • Aeronaval de Constructioness e Instalaciones S.A. with its registered office in Madrid at c/Bahia de Pollensa 13 28042 Madrid, registered with the Commercial Register of Madrid , first entry no: K.39.247, FILE 75 and NN, T.4.959, BOOK 4.121, SECTION III, e-mail address: biuro@aldesa.pl,

here in after referred to collectively as Joint Administrators or each individually as a Joint Administrator.

The main content of the arrangements between the joint administrators is annexed to this information obligation. The co-administrators maintain a fanpage, a profile on www.linkedin.com and a channel on www.youtube.com, which they manage.

II. Contact

As part of the implementation of a data protection system in our organisation, we have decided to appoint a Data Protection Officer, who is Ms Alicja Sytek. You can contact the Data Protection Officer on matters related to data protection and privacy in general at the e-mail address iod@aldesa.pl.

III. Purposes and grounds for processing personal data

In order to contact you about the matter you have described, we process personal data such as:

  • name,
  • data posted on your profile,
  • information about the matter you are contacting.

The legal basis for such processing is Article 6(1)(f) of the RODO, which allows us to pursue our legitimate interest, which in this case is communication with you.

For archival and evidential purposes, we process personal data such as:

  • name,
  • data posted on your profile,
  • information on the matter you are contacting

– for the purpose of safeguarding information that can be used to prove facts of legal significance. The legal basis for such processing is Article 6(1)(f) of the RODO, which allows the processing of personal data if, by doing so, the Joint Administrators pursue their legitimate interest (in this case, the Joint Administrators’ interest is to have personal data to prove certain facts relating to your contact with the Joint Administrators, e.g. the fulfilment of this information obligation);

In order to promote and present the Administrators, we process personal data such as:

  • name,
  • address details,
  • education data,
  • other data posted by you on your profile.

The legal basis for such processing is Article 6(1)(f) RODO, which allows us to pursue our legitimate interest, which in this case is direct marketing of our products or services, and Article 6(1)(a) (consent given by liking our fanpage).

For the purpose of advertising, market research and user behaviour and preferences, with the results of this research being used to improve the quality of the services provided by the Joint Administrators, we process personal data such as:

  • time spent on our profiles;
  • information about interest in particular content;
  • other data obtained through the use of cookies;
  • other data collected by social media, which are providers of analytical, promotional and advertising tools.

The legal basis for such processing is Article 6(1)(a) of the RODO, which allows personal data to be processed on the basis of freely given consent.

In order to establish a possible relationship with you, the Joint Administrators process personal data such as:

  • name,
  • e-mail address or telephone number,
  • position,
  • data about your workplace.

The legal basis for such processing is Article 6(1)(f) RODO, which allows us to pursue our legitimate interest, which in this case is to establish and develop a business relationship with you.

IV. Right of withdrawal of consent

  1. If the processing of your personal data is based on consent, you may withdraw this consent at any time – at your own discretion.
  2. if you would like to withdraw your consent to the processing of your data on our fanpage, simply tick “dislike” in relation to our fanpage.
  3. If the processing of your personal data was carried out on the basis of your consent, revocation of your consent does not render the processing of your personal data until then unlawful. In other words, we are entitled to process your personal data until you revoke your consent and revoking your consent does not affect the lawfulness of the previous processing.

V. Requirement to provide personal data

The provision of personal data is voluntary and at your discretion. However, the provision of certain personal data is necessary in order for us to be able to respond to you on the matter on which you are contacting us.

VI. Automated decision-making and profiling

We kindly inform you that we do not carry out automated decision-making, including on the basis of profiling.

VII. Recipients of personal data

  1. In connection with the Administrators’ use of social media: Facebook, Linkedin, Youtube your personal data may be transmitted to the owners of these portals, as well as to the marketing agencies serving us.
  2. In addition, it may happen, for example, that on the basis of a relevant legal provision or a decision of a competent authority, we will also have to pass on your personal data to other entities, whether public or private. It is therefore extremely difficult for us to predict who may come forward with a request for personal data. Nevertheless, for our part, we assure you that we analyse every request for personal data very carefully and very thoroughly so that we do not inadvertently pass on information to an unauthorised person.

VIII. Transfer of personal data to third countries

In connection with the Administrators’ use of social media: Facebook, Linkedin, Youtube your personal data may be transferred to a third country: United States. With regard to entities from this country, the European Commission has declared an adequate level of personal data protection by an implementing decision of 12 July 2016. (Data will only be transferred to those recipients who have joined the Privacy Shield programme).

IX. Period of processing of personal data

  1. In accordance with current legislation, we do not process your personal data “indefinitely”, but for the period of time that is necessary to achieve the stated purpose. After this period, your personal data will be irreversibly deleted or destroyed.
  2. Please be advised that we process your personal data until you successfully object or the purpose of the processing is achieved (including, for example, the expiry of limitation periods), unless you withdraw your consent earlier if your data is processed on the basis of your consent.

X. Entitlements of data subjects

  1. You are kindly informed that you are entitled to:
    • access to their personal data;
    • rectification of personal data;
    • deletion of personal data;
    • restrictions on the processing of personal data;
    • object to the processing of personal data;
    • portability of personal data.
  2.  We respect your rights under data protection legislation and strive to facilitate the exercise of these rights to the greatest extent possible.
  3. We point out that the enumerated rights are not absolute and therefore we may lawfully refuse you in certain situations. However, if we refuse to comply with a request, this is only after careful consideration and only if refusal of the request is necessary.
  4. Regarding your right to object, we explain that you have the right to object at any time to the processing of your personal data on the basis of the Controllers’ legitimate interest in relation to your particular situation. However, you must bear in mind that, according to the legislation, we may refuse to take your objection into account if we show that:
    • there are legitimate grounds for the processing which override your interests, rights and freedoms, or
    • there are grounds for the establishment, assertion or defence of claims
  5.  You can exercise your rights by sending an email directly to the Company at iod@aldesa.pl.

XI. Right of action

If you believe that your personal data is being processed in violation of applicable law, you may lodge a complaint with the President of the Data Protection Authority.

To download: MAIN CONTENT OF THE ARRANGEMENTS