Privacy and cookies policy

Good morning!

If you have arrived here, it is a reliable sign that you value your privacy. We understand this very well, which is why we are providing you with a document in which you can find in one place the principles for processing personal data and using cookies and other tracking technologies in connection with the operation of the aldesa.co.uk website.

Formal information to start with: the administrators of the site are equity companies of the ALDESA group:

Aldesa Polska Services Sp. z o.o.,
Aldesa Nowa Energia Sp. z o.o.,
Aldesa Construcciones Polska Sp. z o.o.,
Aldesa Construcciones Polska S.A. Branch in Poland,
Aeronaval De Construcciones e Instalaciones, S.A. Spółka Akcyjna Oddział w Polsce

Details of the administrators can be found in section 1.

This Privacy Policy has been structured in the form of questions and answers. The choice of this form was dictated by the concern for clarity and legibility of the information presented to you. Below, you will find a table of contents of the document corresponding to the questions we answer in turn.

Who is the controller of personal data?
Who can you contact about your personal data?
For what purposes do we process your personal data?
What information do we have on you?
What is ‘Anonymous Information’?
How do we have your personal data?
Is your data safe?
How long will we keep your personal data?
Who are the recipients of your personal data?
Do we transfer your data to third countries?
Do we use profiling? Do we make automated decisions based on your personal data?
What rights do you have in relation to the processing of your personal data?
Do we use cookies and what are they actually?
On what basis do we use cookies?
Can you disable cookies?
For what purposes do we use our own cookies?
What third-party cookies are used?
Do we track your behaviour undertaken within our website?
Are we targeting you with targeted advertising?
How can you manage your privacy?
Is there anything else you should know?
Is this Privacy Policy subject to change?
Annex: List of tools that use cookies

If you have any concerns about the Privacy Policy, you can contact us at any time by sending an email to biuro@aldesa.pl.

# 1: Who is the controller of your personal data?

The following ALDESA group companies may be the administrators of your personal data:

Aldesa Polska Services Sp. z o.o. with its registered office at Wołoska 5, 02-675 Warsaw, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS number 0000287883, NIP 6762356224,
Aldesa Nowa Energia Sp. z o.o. with its registered office at Wołoska 5, 02-675 Warsaw, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under number KRS 0000287686, NIP 6762356201,
Aldesa Construcciones Polska Sp. z o.o. with its registered office at Wołoska 5, 02-675 Warsaw, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under KRS number 0000288135, NIP 6762355756,
Aldesa Construcciones Polska S.A. Branch in Poland with its registered office at Wołoska 5, 02-675 Warsaw, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under number KRS 0000357163, NIP 1060002440,
Aeronaval De Construcciones e Instalaciones, S.A. Spółka Akcyjna Oddział w Polsce, with its registered office at Wołoska 5, 02-675 Warsaw, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 13th Commercial Division of the National Court Register, under number KRS 0000414882, NIP 1060003244.

# 2: Who can you contact regarding the processing of your personal data?

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. In matters related to personal data protection and privacy in general, you can contact the Data Protection Officer at the e-mail address iod@aldesa.pl.

# 3: For what purposes do we process your personal data?

There are more than one of these objectives. Below is a list of them, together with a more detailed discussion. We have also assigned the respective legal bases for processing to the various purposes:

Correspondence handling

When contacting us by e-mail, you naturally provide your personal data contained in the body of the correspondence, in particular your e-mail address and your name. The provision of data is voluntary, but necessary in order to make contact. In this case, we are relying on our legitimate interest in providing you with the opportunity to contact you. article 6(1)(f) RODO

Searching for job candidates

As part of the website belonging to the ALDESA Group, we advertise vacancies. If you would like to be considered for a position, you can submit your application via a dedicated form. In this form, you can provide details such as your name, contact details, CV, cover letter, your financial expectations and when you can start work. Some of this personal data is necessary to join the recruitment process – without it, you will not be able to participate in the recruitment.

We base the processing of personal data related to recruitment on different legal bases, depending on the type of data. Some of the information is required by the Labour Code and some you can provide voluntarily and with your consent. We also rely on our legitimate interest, which in this case remains the efficient and effective conduct of recruitment processes. article 6(1)(a) RODO, article 6(1)(c) RODO, article 6(1)(f) RODO, article 9(2)(a) RODO

Creation of an archive

We may create archives for the purposes of our business: both in traditional and digital form. The archives include any personal data that we have processed in connection with you, so the scope of the archives may vary depending on what data has come to us. In this case, we rely on our legitimate interest in organising and structuring the personal data media. article 6(1)(f) RODO

Defence, establishment or enforcement of claims

The use of our website, as well as the conclusion of a contract with us (e.g. an employment contract or a civil law contract), may give rise to certain claims on our part or yours in the future. Accordingly, we are entitled to process your personal data for the purpose of defending, establishing or asserting claims. As part of this purpose, we may process any personal data that is related to the claim in question, so the extent of the processing may vary depending on what the claim relates to. In this case, we are relying on our legitimate interest to protect our interests in this regard. article 6(1)(f) RODO

Social media handling

If you follow our social media profiles or interact with content that we publish on social media, we naturally see your data that is publicly available in your social media profile. We process this data only within the respective social network and only for the purpose of operating the respective social network, which is our legitimate interest. Your
use of social networks is subject to the rules and privacy policies of the administrators of those social networks, and those administrators provide electronic services to you, fully independently and autonomously of us. article 6(1)(f) RODO

Analysis and statistics using only Anonymous Information

We carry out analytical and statistical activities using tools provided by external providers. As part of the analytical tools, we only have access to Anonymous Information. We base the processing of Anonymous Information on our legitimate interest, which is to create, view and analyse statistics related to user activity on the website in order to draw conclusions for the subsequent optimisation of the website.
From the tools, we only have access to a set of statistics and information not attributed to specific individuals. For details on the tools of external providers, please see the section on the tools we use. article 6(1)(f) RODO

Own marketing using only Anonymous Information

We carry out marketing activities using tools provided by external providers. Within the marketing tools, we only have access to Anonymous Information. We base the processing of Anonymous Information on our legitimate interest, which is the creation of Custom Audience Groups based on Anonymous Information and the targeting of advertisements within external systems based on Anonymous Information, for the purpose of marketing our own products and services. From the tools, we only have access to a set of statistics and information not assigned to specific individuals. For details on the tools of external providers, please see the section on the tools we use. article 6(1)(f) RODO

# 4: What information do we have about you?

We have described the scope of the processing precisely for each processing purpose. Information in this regard can be found above in section 3 of the Privacy Policy.

# 5: What is “Anonymous Information”?

We use tools that collect a range of information about you related to your use of our website. This includes, in particular, the following information:

information about the operating system and web browser,
subpages viewed,
time spent on the site,
transitions between individual sub-pages,
clicks on individual links,
the source from which you go to the page,
the age range you are in,
Your gender,
Your approximate location limited to the village.
Your interests as determined by your online activity.

This information is referred to in this Privacy Policy as “Anonymous Information“.

Anonymous Information in itself does not, in our view, have the character of personal data, as it does not allow us to identify you and we do not collate it with the typical personal data we collect about you. Nevertheless, given the strict jurisprudence of the Court of Justice of the European Union and the divided opinions among lawyers, as a precaution, in case Anonymous Information is attributed the character of personal data, we have also included detailed explanations in the Privacy Policy regarding the processing of this information.

The processing of Anonymous Information allows us to provide you with the functionality available on the website. In addition, Anonymous Information is used for analytical and statistical purposes.

Anonymous information is also processed by tool providers under the terms of their terms of service and privacy policies. It may be used by these providers to provide and improve their services, to manage them, to develop new services, to protect against fraud and abuse, and to personalise the content and advertising displayed on individual services, websites and applications. Please see the section on the tools we use for more details in relation to this.

# 6: Where do we get your personal data from?

In most cases, you provide them to us yourself. For example, this is the case when you access our website, submit a completed form, contact us via email, and use features available on the website or external services (e.g. social media).

In addition, some information about you may be automatically collected by tools we use. Please see the section on the tools we use for details on the tools of third party providers.

Furthermore, in exceptional cases, we may also obtain your personal data from other sources, e.g. when the entity that employs you indicates your data to us as a contact person for contractual matters, or when you represent an entity that enters into a contract with us.

# 7: Is your data safe?

We care about the security of your personal data. We analyse the risks involved in the various processes of processing your data and then implement appropriate security and personal data protection measures. We monitor the state of the technical infrastructure on an ongoing basis, train our staff, look at the procedures in place and make the necessary improvements.

# 8: How long will we keep your personal data?

We process your personal data for as long as it is justified within the framework of a given purpose for processing your personal data, and therefore processing periods vary depending on the purpose. Please note that the termination of the processing of your data for one purpose does not necessarily lead to the complete erasure or destruction of your personal data, as the same set of data may be processed for another purpose, for the period of time indicated for that purpose. Complete erasure or destruction of data occurs when we have completed all purposes and in other cases indicated in the RODO.

Below you will find a description of the processing periods:

Correspondence handling – data relating to correspondence handling will be processed for the duration of the correspondence between us;
Job search – we process recruitment-related data for the duration of the current recruitment process and, if you agree to keep your CV for future recruitment, for a period of 2 years;
Archive – data related to the archive will be processed until the information contained in the archive is no longer relevant;
Determination, investigation and defence of claims – data related to claims will be processed until the statute of limitations for claims, whereby the period of limitation for claims may vary in light of applicable law;
Social media – data related to audience groups will be processed until you opt out of interacting with us on social media;
Analytics and statistics – data related to analytics and statistics will be processed until it is no longer relevant or you successfully object;
Self-marketing – data related to self-marketing will be processed until it is no longer relevant or you successfully object;
Data Protection Obligations – Data relating to personal data protection will be processed until it is no longer relevant, you have successfully lodged an objection or the expiry of the limitation period of our liability as data controller;
Transfer of personal data within the Controller’s group of companies – data related to groups of recipients will be processed until it is no longer relevant or you successfully object.

Where we process your personal data on the basis of consent you have given, you may withdraw such consent at any time: either by your action or by contacting us at the contact details provided. Please note that withdrawal of consent does not affect the lawfulness of the processing that was carried out on the basis of consent prior to its withdrawal.

# 9: Who are the recipients of your personal data?

We would venture to say that modern business cannot do without services provided by third parties. We also make use of such services. Some of these services involve the processing of your personal data. Third-party service providers that are involved in the processing of your personal data are:

Hosting provider that stores data on the server;
A cloud service provider that stores files that may contain your personal data;
A maintenance provider who accesses the data if the technical work carried out relates to areas where personal data is held;
Other subcontractors who gain access to the data if the scope of their activities requires such access.

In addition, due to our organisational structure, the recipients of your personal data may also be entities that have a personal or capital relationship with the controller. They form a so-called controller’s group of companies, within which internal administrative purposes may be pursued (e.g. for more efficient management).

If the need arises, your data may be shared with a legal adviser or lawyer bound by professional secrecy. The need may arise from a legal need requiring access to your personal data.

Your personal data may also be forwarded to the tax authorities to the extent necessary for the fulfilment of tax and accounting obligations. This includes, in particular, all declarations, reports, statements and other accounting documents containing your personal data.

In addition, if necessary, your personal data may be made available to entities, authorities or institutions entitled to access the data under the law, such as police, security services, courts, public prosecutors’ offices.

Furthermore, when it comes to Anonymous Information, the providers of the tools or plug-ins that collect Anonymous Information have access to it. The providers of these tools are their own controllers of the data collected in them and may share this data under the terms and conditions they set out in their own terms and conditions and privacy policies, over which we have no control.

# 10: Do we transfer your data to third countries or international organisations?

Yes, part of the processing of your personal data may involve transfers to third countries.

We transfer your personal data to third countries in connection with the use of tools that store personal data on servers located in third countries, in particular in the USA. The same may happen in the case of Anonymous Information. The providers of these tools guarantee an adequate level of protection of personal data through the relevant compliance mechanisms provided for by the RODO, in particular through the use of standard contractual clauses.

# 11: Do we use profiling? Do we make automated decisions based on your personal data?

We do not make decisions to you that are based solely on automated processing, including profiling, that produce legal effects on you or similarly materially affect you. Yes, we do use tools that may take certain actions depending on the information collected through tracking mechanisms, but we consider that these actions do not materially affect you as they do not differentiate your situation as a user, do not affect the terms of the contract you may enter into with us, etc.

# 12: What rights do you have in relation to the processing of your personal data?

The RODO grants you the following potential rights in relation to the processing of your personal data:

The right to access your data and to receive a copy of it;
The right to rectification (amendment) of your data;
The right to erasure (if, in your opinion, there are no grounds for us to process your data, you can request that we erase it);
The right to restrict processing (you can request that we restrict processing to only storing your data or carrying out activities agreed with you if, in your opinion, we have inaccurate data or are processing it unduly);
The right to object to processing (you have the right to object to processing on the basis of a legitimate interest; you should indicate the particular situation which you think justifies us stopping the processing covered by the objection; we will stop processing your data for these purposes unless we can demonstrate that the grounds for our processing override your rights or that your data is necessary for us to establish, assert or defend our claims);
The right to data portability (you have the right to receive from us in a structured, commonly used machine-readable format the personal data you have provided to us on the basis of a contract or your consent; you can have this data sent directly to another entity);
the right to withdraw your consent to the processing of your personal data if you have previously given such consent;
the right to lodge a complaint with a supervisory authority (if you find that we are processing your data unlawfully, you may lodge a complaint to the President of the Office for Personal Data Protection or any other competent supervisory authority).

The rules related to the exercise of the rights indicated above are described in detail in Articles 16-21 of the DPA. We encourage you to familiarise yourself with these provisions. For our part, we consider it necessary to explain to you that the rights indicated above are not absolute and you will not be entitled to them in relation to all processing activities of your personal data.

We emphasise that one of the rights indicated above is always available to you: if you consider that we have violated data protection regulations in the processing of your personal data, you have the possibility to lodge a complaint with a supervisory authority (the President of the Office for Personal Data Protection).

# 13: Do we use cookies and what are they?

Our website, like almost all other websites, uses cookies.

Cookies are small textual information stored on your terminal device (e.g. computer, tablet, smartphone) that can be read by our ICT system (our own cookies) or by third-party ICT systems (third-party cookies). In cookies, specific information can be recorded and stored, which ICT systems can then access for specific purposes.

Some of the cookies we use are deleted when your browser session ends, i.e. when you close your browser (so-called session cookies). Other cookies are stored on your terminal device and enable your browser to be recognised the next time you visit the website (persistent cookies).

If you would like to learn more about cookies as such, you can read, for example, this material.

# 14: On what basis do we use cookies?

We use cookies on the basis of your consent, except where cookies are necessary for the proper provision of an electronic service to you.

Cookies that are not necessary for the correct provision of the electronic service remain blocked until you have given your consent to the use of cookies. When you visit the website for the first time, we display a message asking for your consent together with the possibility to manage cookies, i.e. to decide which cookies you agree to and which you want to block.

# 15: Can you disable cookies?

Yes, you can manage your cookie settings within your web browser. You can block all or selected cookies. You can also block cookies for specific sites. You can also delete previously saved cookies and other site and plug-in data at any time.

Web browsers also offer the possibility to use incognito mode. You can use this if you do not want information about pages visited and files downloaded to be saved in your browsing and download history. Cookies created in incognito mode are deleted when you close all windows in this mode.

Browser plug-ins to control cookies are also available, such as. Ghostery. The option to control cookies may also be provided by additional software, in particular anti-virus packages, etc.

In addition, there are tools available on the internet to control certain types of cookies, in particular to collectively manage behavioural advertising settings.

We also give you the possibility to control your cookies directly from our website. We have implemented a special mechanism for managing cookies that allows you to block those cookies that you do not wish.

Please note that disabling or restricting cookies may prevent you from using some of the features available on our website and may cause difficulties in using the website, as well as many other websites that use cookies.

# 16: For what purposes do we use our own cookies?

Custom cookies are used to ensure the correct functioning of the various mechanisms of the website, such as the correct transmission of the form visible on the page, etc.

Own cookies also store information about the cookie settings you have defined via the cookie management mechanism.

# 17: What third-party cookies are used?

A list of tools that require the use of cookies and a description of the cookies used can be found in the Appendix to this Privacy Policy.

# 18: Do we track your behaviour undertaken on our website?

Yes, we use tools from third-party providers that involve the collection of information about your activities on our website. These tools are described in detail in the appendix to this Privacy Policy.

# 19: Are we targeting you with targeted advertising?

No, we do not target you with targeted advertising related to our business.

# 20: How can you manage your privacy?

The answer to this question can be found in many places in this Privacy Policy when describing individual tools, behavioural advertising, consent to cookies, etc. Nevertheless, we have once again gathered this information in one place for your convenience. Below you will find a list of options for managing your privacy.

the cookie settings within your internet browser;
Browser plug-ins supporting cookie management, e.g. Ghostery;
additional cookie management software;
incognito mode in the web browser;
behavioural advertising settings, e.g. youronlinechoices.com;
mechanism for managing cookies from our website;
Google Analytics Opt-out: https://tools.google.com/dlpage/gaoptout;
Google Ads Settings: https://adssettings.google.com/;

# 21: Is there anything else you should know?

As you can see, the topics of personal data processing, the use of cookies and the management of privacy in general are quite complex. We have done our best to ensure that this document provides you with the most far-reaching knowledge on the issues that are important to you. If anything is unclear to you, you would like to find out more, or you just want to talk about your privacy, please email us at biuro@aldesa.pl.

# 22: Is this Privacy Policy subject to change?

Yes, we may modify this Privacy Policy, in particular due to technological changes and changes in legislation. If you are a registered user, you will receive a message about any change to the Privacy Policy. In addition, all archived versions of the Privacy Policy are linked below.

# 23: Annex to the Privacy Policy

LIST OF TOOLS THAT USE COOKIES

Google Analytics

We use the Google Analytics tool provided by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. In order to use Google Analytics, we have implemented a special Google Analytics tracking code in the code of the website. The tracking code uses cookies from Google LLC concerning the Google Analytics service. You can block the Google Analytics tracking code at any time by installing a browser add-on provided by Google.
Google Analytics automatically collects information about your use of the website. The information collected in this way is usually transmitted to and stored on Google servers, which may be located around the world.

Due to the IP address anonymisation that we have activated, your IP address is shortened before being passed on. Only in exceptional cases is the full IP address transmitted to Google’s servers and only shortened there. The anonymised IP address transmitted by your browser within the scope of Google Analytics is generally not combined with other Google data.

I emphasise that within Google Analytics we only have access to Anonymous Information.
Google Analytics and Google Analytics 360 services have been certified to the independent security standard ISO 27001. ISO 27001 is one of the most widely recognised standards in the world and certifies that the systems operating Google Analytics and Google Analytics 360 meet the relevant requirements.

If you are interested in the details related to Google’s use of data from sites and applications that use Google services, I encourage you to read this information.

Google Ads

We use remarketing features available within the Google AdWords system operated by Google LLC, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA. When you visit our website, a remarketing cookie from Google is automatically left on your device, which collects information about your activity on our website. With the information collected in this way, we are able to display advertisements to you within the Google network depending on your behaviour on our website. For example, if you view a certain product, this information will be recorded by a remarketing cookie so that we can target you with an ad for that product or any other ad we deem appropriate. This advertising will be displayed to you within the Google network when you use the internet, browse other websites, etc.

We emphasise that when using with Google Ads, we only use Anonymous Information. When using with Google AdWords, we are only able to define the audience groups we would like our ads to reach. On this basis, Google decides when and how it will present our advertising to you.

Further processing of the information only takes place if you have consented to Google linking your browsing history to your account and using information from your Google account to personalise the advertisements that are displayed on the websites. In this case, Google will use your data to create and define target group lists for remarketing purposes on different devices. For this purpose, Google will temporarily combine the information collected with other data it has in order to create targeting groups.

If you do not wish to receive personalised adverts, you can manage your ad settings directly on the Google website: https://adssettings.google.com.

If you are interested in the details related to Google’s use of data from sites and applications that use Google services, we encourage you to read this information: https://policies.google.com/technologies/partner-sites.