§1 GENERAL PROVISIONS
- The policy specifies, among other things:
- the purposes, type, scope and method of the processing of your personal data by MANTA GROUP – in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council (the so-called GDPR);1
- The policy describes the rules for the processing of personal data, and also regulates these issues in terms of our interactions with you, in connection with the use of websites and social media belonging to MANTA GROUP.
- The controller of your data is the company GRUPA MANTA spółka z ograniczoną odpowiedzialnością spółka komandytowa [limited partnership] (hereinafter: MANTA GROUP), with its registered office in Kraków at ul. Ślusarska 9 (30-710 Kraków), entered into the Commercial Register of the National Court Register (KRS) maintained by the District Court for Kraków-Śródmieście in Kraków, 11th Commercial Division of the National Court Register, under the KRS number: 000076322, with the NIP number: 6772311921.
- If you have any additional questions regarding the protection of your privacy, please write to firstname.lastname@example.org or telephone +48 12 267 10 50.
§2 SCOPE AND METHOD OF OBTAINING PERSONAL DATA
- MANTA GROUP collects your personal data during your interactions with us, which occur when you use:
- the WEBSITE;
- the possibility to APPLY to become part of our team;
- the functionality of the Website in the form of the REPORTS DOWNLOAD FORMS;
- the available FORMS OF CONTACT with us (i.e. telephone or email correspondence);
- our SOCIAL MEDIA PROFILES, i.e. on Facebook, LinkedIn and Instagram;
- the SERVICES included in our offer;
- the marketing content we provide, e.g. our Newsletter.
- When you use our WEBSITE, we automatically collect data about your visit, such as the IP address assigned to your computer or the external IP address of the internet provider, domain name, browser type, access time, operating system type, source of visit, demographic data, approximate location and device data.
- If you want to initiate the possible recruitment process to join our team, please send your APPLICATION to the following address: email@example.com. In your application, please provide the data necessary for the position that you are applying for and the legal basis for potential cooperation. When you send your application to the email address provided, we will receive the data contained in the application documents and an email address enabling return contact. Please do not provide us with personal data other than that required by law or justified by the offer of cooperation.
- When using the REPORTS DOWNLOAD FORMS, you are asked to provide data in the form of your first name, surname, email address and the company on whose behalf you are acting, or which intends to use the information obtained through the form.
- When you CONTACT us, you are asked to provide the data necessary for us to answer your question. The scope of the data also depends on the form of contact with us that you choose. Please do not provide us with any other personal data than that which is necessary to answer your enquiry.
- In order to receive marketing content from us, at your request, it is necessary to provide your contact details and other information enabling an appropriate offer to be prepared. We only send marketing information with your consent and at your request.
- When using the SERVICES included in our offer, you are asked to provide us with the personal data necessary for the conclusion and execution of a cooperation agreement. The scope of the data depends on the type and scale of the project, and the number and professions of the people involved in the project, including the organisational structure of the entity you represent.
- MANTA GROUP is the co-controller of the personal data of people who are users of our profiles on social media, i.e. social networks such as Facebook, Instagram and LinkedIn. The other co-controllers are the providers of the services indicated. The scope of data to which we have access depends on the privacy settings you have selected to apply to each of the social media platforms used.
§3 PRINCIPLES OF DATA PROCESSING
- The provision of all personal data as indicated in §2 is voluntary, but necessary in order to:
- use the Website and view its content;
- send such data to the address firstname.lastname@example.org for us to consider your APPLICATION;
- download the "ONLINE EVENTS" REPORT;
- contact MANTA GROUP;
- use the services we provide;
- receive our marketing content;
- use the functionalities made available through our profiles on social media.
- The person providing us with the personal data is obliged to provide true and complete personal data that does not infringe the rights of third parties.
- Personal data is processed for the purpose and on the basis of (depending on the type and form of disclosure):
- keeping statistics (helpful for marketing purposes) and making it easier for you to use the services provided by us electronically, i.e. improving the functionality of the Website or our profiles on social media (legal basis: the legitimate interest of the administrator, which is to provide the possibility of providing services at the level expected by potential clients, in accordance with Art. 6 section 1 (f) of the GDPR) – when visiting the Website or using our profiles on social media;
- performance of the provisions of a contract concluded with you for the provision of our services, or taking action to conclude one at your request, its execution, the consideration of complaints or contact for purposes related to the provision of services (legal basis: contract concluded with the data subject, in accordance with Art. 6 section 1 (b) of the GDPR);
- settlements and the issuing of invoices (legal basis: legal obligation incumbent on the administrator in connection with the provisions of the tax ordinance and accounting, in accordance with Art. 6 section 1 (c) of the GDPR);
- considering your application and conducting the recruitment process (legal basis: data necessary for the recruitment process on the basis of the obligation resulting from the provisions of the Labour Code, in accordance with Art. 6 section 1 (c) of the GDPR; other data that will be provided at your initiative during recruitment are processed on the basis of consent; if you give your consent, your data may also be used for future recruitment processes, in accordance with Art. 6 section 1 (a) and Article 9 section 2 (b) of the GDPR);
- enabling contact (legal basis: our legitimate interest, which is the ability to carry out business contacts, in accordance with Art. 6 section 1 (f) of the GDPR) – when using the forms of contact provided, including email address, telephone number;
- advertising our services by running our profiles on social media (legal basis: the legitimate interest of the administrator, which is the marketing of own services, in accordance with Art. 6 section 1 (f) of the GDPR);
- transmission of electronic content of a marketing nature, sending the Newsletter, displaying advertisements and telephone contact. We enable the persons who agree to receive our newsletter to download for free the reports that we prepare (legal basis: voluntary consent, in accordance with Art. 6 section 1 (a) of the GDPR);
- enabling us to establish, investigate or defend against possible claims of third parties using our services or whose data we process on the principles set out in the Policy (legal basis: implementation of our legitimate interests in the form of establishing, investigating or defending against possible claims of third parties, e.g. resulting from negative consideration of an application or a complaint regarding the services provided, in accordance with Art. 6 section 1 (f) of the GDPR);
- ensuring the safety of users by implementing appropriate security measures to monitor the activities of users on the WEBSITE (legal basis: implementation of the legitimate interests of the administrator, which is to ensure the protection of users' information and data, in accordance with Art. 6 section 1 (f) of the GDPR).
- Principles related to the processing of personal data by:
- Facebook, Inc., based at 1601 Willow Road, Menlo Park, California 94025 (USA) and entities belonging to the same capital group, in particular Facebook Ireland Limited, with its registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2 (Ireland) – for all products of the Facebook group (including Instagram, Facebook, Messenger);
- LinkedIn Ireland Unlimited Company, based in Wilton Place, Dublin 2, (Ireland);
- are governed by the regulations available via the social networking sites indicated. MANTA GROUP has no influence on the privacy rules of these social networking sites, including whether the data provided by you in this regard is processed outside the European Union.
- The time of personal data processing by MANTA GROUP depends on the purpose for which they are made available, which means, in the case of:
- data collected automatically during a visit to the Website – a maximum of 3 years, but most of the data is deleted earlier, upon the expiry of the cookies through which they were collected (e.g. after 1 day or when the browser is closed);
- data collected when using social media – until the content to which you have added a reaction or comment is deleted; and for correspondence via the messenger – until it is automatically deleted in accordance with the provider's regulations. In the remaining scope (e.g. statistical data), the storage time does not depend on us and is regulated by the providers of these services and contained in the regulations on their websites, the acceptance of which determines their use;
- recruitment data – up to 3 months after the end of the recruitment process. With regard to consent to participate in future recruitment processes, this period is one year from the date consent is granted;
- contacting MANTA GROUP – the data will be stored 6 motnhs form the time when the correspondence is completed and additional explanations are provided. If the services are used, the storage time specified for this type of processing will apply. Should cooperation not be undertaken, the data will be deleted after 6 months from the expiry of the offer sent;
- provision of our services – up to 5 years after the year in which the provision of services ended;
- receiving marketing content – until the purpose of processing ceases to exist (e.g. termination of sending the Newsletter) or withdrawal of consent;
- Use of our profiles on social media (Facebook, Instagram or LinkedIn) – until the person stops being a user of a given social profile;
- establishing, investigating or defending any claims – we will store data until the time that the claims are time-barred.
- Withdrawal of consent – you can withdraw your consent to the processing of personal data at any time. Withdrawal of consent does not affect the compliance of processing before such withdrawal. Consent may be withdrawn by contacting us:
- in writing at the postal address: ul. Ślusarska 9 (30-710 Kraków);
- by email: email@example.com;
- regarding recruitment, you can also write directly to the following address: firstname.lastname@example.org.
§4 RIGHTS OF THE DATA SUBJECT
Every person whose data is processed by the controller has the right to request access to their personal data, as well as to rectify (correct) it. You also have the right to request the erasure of the data or the restriction of processing, as well as the right to object to the processing, but only if further processing is not necessary for the Controller to fulfil its legal obligation and there are no other overriding legal grounds for processing.
- The personal data processed by us may be viewed, corrected, erased and changed by the persons they relate to (data modification) at any time, subject to the provisions below.
- The data obtained during CONTACT may be modified, with the reservation that erasure of the data may prevent our possible future interaction.
- If the data obtained by us is related to an ongoing or recently completed recruitment process, downloading, processing complaints and erasing certain data is not possible until the specific activities are completed.
- We cannot change the data collected by us automatically as it is not generated by us, but is used only for statistical purposes.
- Any person whose personal data is processed by MANTA GROUP has the right to lodge a complaint with the supervisory authority.
- The complaint should be addressed to the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw.
- The complaint may also be submitted via the Office’s Electronic Inbox; in order to use this means of communication, follow the instructions on the website: https://uodo.gov.pl/pl/83/155
§5 DATA RECIPIENTS
- MANTA GROUP does not transfer the personal data made available to it to third parties, except for the recipients indicated below.
- Access to the personal data obtained by us (depending on the form and purpose of obtaining such data) is available to:
- entities cooperating with us in the scope of our business activities, to which these data have been entrusted in accordance with Art. 28 section 3 of the GDPR or made available under other legal provisions (e.g. IT service providers such as hosting, software and server space, IT specialists, advertising service subcontractors, CRM provider, public administration bodies, law firms, tax advisers);
- the co-controllers of the data processed as part of social media: Facebook and LinkedIn;
- in the case of cookies – Google LLC (USA).
- Information for users of Fanpages on Facebook and Instagram:
- When a User browses a Fanpage (regardless of whether they are logged in or not), their data is collected by the Facebook app in order to be able to provide him or her with ads from Facebook Inc. and its partners.
- Through the admin panel provided, the Fanpage owner can see statistical information about visits to the Fanpage, e.g. the age of the visitors, their reactions and activity. This is used to match the content to the preferences of Fanpage users, as well as to check the effectiveness of the displayed ads.
- Facebook decides whether the User will see a given advertisement. The Fanpage owner only sees statistical information about ad responses, as well as the reactions and comments about the ad.
- The Fanpage owner can see the comments and reactions of Users. As a Facebook user (the Fanpage administrator), they also have the option of viewing the User's public profile, or contacting them via the messenger available on Facebook.
- In connection with running the Fanpage on Facebook, Manta Group, together with Facebook Ireland Limited (4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland), are joint controllers of the User's data in the field of data processing for statistical and advertising purposes.
- Detailed information on mutual arrangements between controllers is available at: https://www.facebook.com/legal/terms/page_controller_addendum
- The rules for the processing of the User's personal data by Facebook Ireland
are available at: https://www.facebook.com/privacy/explanation
- Information on the rules for using data as part of Google tools:
- The Data Controller for the personal data of users in the European Economic Area and Switzerland is Google Ireland Limited, unless otherwise stated in the Service-specific Privacy Notice, which means that Google Ireland Limited is a Google affiliate responsible for processing personal data and complying with applicable privacy laws.
- Manta Group also uses the Tag Manager on the terms set out in the Google policy https://marketingplatform.google.com/about/analytics/tag-manager/use-policy/
- The data collected by the tool: location, source of visits, time spent on the website, website traffic, keywords that referred the user to the website, pages viewed by the user, anonymised IP address and demographic data.
- The analysis of statistical data is used to display the content
and make changes to the Website in order to increase User activity. Google allows you to exercise your rights under the GDPR. The rules for exercising these rights are set out here:
- In order to disable the option of tracking by Google tools, download and install the browser add-on available at: tools.google.com/dlpage/gaoptout
- Information for LinkedIn users
- At the same time, a visit to the Manta Group profile on LinkedIn, gives Manta Group access to the User's public data, comments and messages addressed to Manta Group. This data is processed in accordance with the LinkedIn Regulations, which Manta Group is obliged to apply as a LinkedIn User: https://www.linkedin.com/legal/user-agreement
- In terms of the data processed as part of LinkedIn, Manta Group has the option of exercising the User's right to have their data erased only in respect of deleting the message history. In all other regards, it is necessary to contact LinkedIn directly.
§6 SECURITY OF PERSONAL DATA
- MANTA GROUP hereby states that it never asks for any personal data, except for that which is necessary to achieve the indicated purposes, and does not transfer, sell or lend the collected personal data to third parties, except with your express consent, entrusting data in accordance with Art. 28 GDPR or at the request of public administration authorities authorised by law.
- We process the personal data that we obtain in a manner that ensures their appropriate security, including protection against unauthorised or unlawful processing, as well as accidental loss, destruction or damage.
- MANTA GROUP ensures that personal data is:
- processed in accordance with the law, fairly and transparently for the data subject;
- collected for specified, explicit and legitimate purposes and not processed further in a manner that is incompatible with those purposes;
- adequate, relevant and limited to what is necessary for the purposes for which they are processed;
- correct and, if necessary, updated;
- kept in a form which permits identification of the data subject for no longer than is necessary for the purposes for which the data are processed.
- Please inform us immediately about:
- any events that may be related to your use of the Website, our social media profiles, downloading a REPORT, and that may result in a breach of your personal data;
- any other breaches of security rules identified by you related to contact or cooperation with MANTA GROUP, including use of the Website or our profiles on social media.
- Cookies are small files, consisting of a sequence of letters and characters, saved on the User's computer.
- Cookies used by MANTA GROUP may serve the following purposes:
- optimising the use of the Website, including adapting to user preferences;
- accessing certain functions of the Website, e.g. Forms;
- subscription to the Newsletter;
- ensuring security;
- improving the performance of the Website.
- The information collected and generated by Cookies is not used to identify the Website user.
- Cookies used by MANTA GROUP are safe and have no harmful effect on the device through which you use the Website.
- The user may change the way that Cookies are used, including blocking or deleting those that come from MANTA GROUP, and which are not the so-called necessary cookies that enable the proper operation of the Website – using:
- the information banner available in the footer of the Website;
- tools provided by the browser you use.
- In order to choose the appropriate settings in the browser, MANTA GROUP recommends reading the user manual or the help topics of the Website you are using.
§8 USER STATEMENTS
- the registration data and contact details of MANTA GROUP;
- the categories and scope of personal data processed by MANTA GROUP;
- the purposes of processing personal data and the legal basis for the processing;
- the recipients of personal data or categories of recipients, if they exist;
- the period for which the personal data provided to us will be stored;
- the right to request from MANTA GROUP access to your personal data provided to us, rectification, erasure or restriction of processing, or the right to object to the processing;
- the right to data portability;
- the right to lodge a complaint to the supervisory authority;
- the (voluntary or obligatory) nature of providing the personal data to MANTA GROUP and the consequences of not providing them.
§9 FINAL PROVISIONS
- MANTA GROUP is entitled to introduce changes to the Policy by publishing the relevant information and new content of the Policy on the Website.
- On the Website, you can find redirects to other websites (i.e. agency profiles on social media: Facebook, Instagram, LinkedIn), which is aimed at enabling you to obtain faster the information you are interested in. These websites are administered by third parties, completely independent of MANTA GROUP. Before you start to actively use these websites, we recommend that you read the privacy policies and rules of operation applied by these entities.
- The disclosure or transfer of personal data processed by us may only take place after the applicant contacts MANTA GROUP and submits a request for the transfer or disclosure of certain personal data, and provided that it does not contradict applicable law.
- In case your data is processed outside the EEA, we ensure the application of appropriate security measures, in particular through careful analysis of the solutions used by our contractors, including compliance with the standards adopted by the European Commission. You have the right to access data that has been transferred to third countries and receive a copy of the security measures we use regarding data transfer to countries outside the EEA.