The EU Regulation n. 679/2016 (hereafter also GDPR) establishes rules concerning the protection of natural persons with regard to the processing of personal data, as well as rules concerning the free circulation of personal data. In order to protect the fundamental rights and freedoms of individuals, the Regulation therefore imposes on the data controllers the obligation to provide the interested parties with the information referred to in articles 12, 13 and 14, and the specific indication of the rights of the interested party, provided for in articles 15 to 22 of the GDPR.
Information pursuant to art. 13, par. 1
Data Controller and contacts
The data controller is Pentagon Trade One Spółka z ograniczoną odpowiedzialnością ul. Gliniana 14, 97-300 Piotrków Trybunalski +48 880 649 192 firstname.lastname@example.org NIP 9522132716
Pentagon Trade One Spółka z ograniczoną odpowiedzialnością informs you that your personal data will be processed:
– pursuant to arts. 12 and 13 of EU Regulation no. 679/2016 (General Data Protection Regulation, hereinafter referred to as “GDPR”), by specifically authorized subjects, limited to the purposes and with the methods that will be specified below with reference to the functionalities of the web portal www.pentagon-trade.pl
Object, purpose of treatment
The Data Controller, informs you that will treat your personal data, specifically, ie name, surname, e-mail address, telephone number and identifiers and IP addresses or domain names
Your data, as described above, will be processed in the ways and in the forms prescribed by the GDPR, for the performance of the functions of the Website, with particular – but not exhaustive – reference to the procedures described therein through data collection registration, ask for info direct phone contact by email or fax.
In particular, the personal data you have provided to the Data Controller will be processed for the following purposes:
– to follow up the specific requests made by you to the Owner through the Website and its communication tools (registration area and the like);
– for informative communications relating to the services of the same Owner, following your request for information by e-mail, ask for info and other communication tools such as by telephone or fax;
– for subscription to the newsletter and the consequent sending of commercial communications and various information concerning the sector in which the Data Controller operates, with the appropriate consent you have provided by selecting the relative box;
– for sending newsletters, commercial proposals, reporting of advertising events, sending promotional communications for a similar service, management of direct relationships and company / client-user contacts, through e-mail and then for direct marketing activities with special consent given by you by selecting the appropriate box;
– for other accessory purposes or connected to those indicated above and in any case falling within the scope of the Website activities;
The processing of data conferred on a generic basis will be carried out, even following automatic collection during navigation, for the sole purpose of verification and control of access to the Website. This also applies to technical cookies, to be intended as session, functional and analytics cookies that meet the requirements specified by the Guarantor. In particular, with regard to the latter, it is specified that they can be assimilated to technical cookies when they are created and used directly by the Website. In any case, for these analytics cookies, the Website, also in accordance with the clarifications of the Guarantor, has provided for the anonymization of IP addresses and the data processing amendment; the collection and use of these browsing data (without prejudice to the anonymization of the IP addresses) allow the monitoring of the Website’s performance and allow to improve the service offered, offering the User a better browsing experience. Please refer to the appropriate Cookie Information for further information.
This information is effective only with reference to the aforementioned web portal www.pentagon-trade.pl.
Legal basis of the processing
Apart from what specified for navigation data, the communication from you to the Data Controller of the personal data specified above, has as a basis for the lawfulness of the processing, the following legal bases:
• Article 6, par. 1, letter a) of the GDPR, concerning your express free consent, specific, informed and unequivocal, for this purpose we inform you that the aforementioned consent can be issued only if you have completed 16 (sixteen) years in default you cannot proceed but only and exclusively the holder of parental responsibility.
• Article 6, par. 1, letter b) of the GDPR, concerning the execution of a contract of which the interested party is a party, or the execution of pre-contractual measures adopted and requested by the interested party.
Both these legal bases have a purely optional and non-compulsory nature, as they have no other consequence other than the impossibility for the Owner to properly perform the aforesaid direct communication or contractual / pre-contractual execution services. And, in any case, the consent you may have provided may be revoked by you at any time, with immediate effect on the aforementioned business activities and services.
the treatment is not based on art. 6 par.1 let f)
recipients and categories of recipients of the collected data and data transfer
In particular, in relation to the purposes indicated above, the data may be disclosed to the following persons and / or categories of persons indicated below, or rather they may be disclosed to companies and / or persons, who provide services, including external, on behalf of the Owner of the Treatment. This shall include, but shall not be limited to, the following: subjects – internal or external to the company – that provide IT and telematic services for the management of the information system used by the Data Controller and the telecommunications networks (including e-mail and management of web portals and internet sites – hosting), subjects that in the eventuality the Owner reserves the right to appoint responsible of the treatment; financial administrations and other companies or public bodies in fulfillment of regulatory obligations; competent authorities and / or Supervisory Bodies for the fulfillment of legal obligations; companies and consulting firms; companies and law firms for the protection of contractual rights; subjects that carry out control, revision and certification of the activities carried out by the Owner who act as external data processing managers pursuant to art. 28 of the GDPR, or in total autonomy as separate Data Controllers.
The data will not be disclosed, with this term being intended to give it knowledge to indeterminate subjects in any way, including through their availability or consultation, unless a specific consent, free and informed, granted for each type of treatment.
Information pursuant to art. 13, par. 2
data retention period
– Right of Access and Correction
Pursuant to art. 15 of the GDPR, in your capacity as Interested Party you have the right to obtain from the Controller confirmation of the existence of processing of personal data concerning you, to obtain access to them and to all the information referred to in the same Article 15, paragraph 1, letters (a) to (h), by issuing a copy of the data processed in a structured format, in common use, readable by an automatic and interoperable device.
Pursuant to art. 16 of the GDPR, in your capacity as data subject you have the right to obtain from the Data Controller the correction and / or integration of the data being processed if they are not updated and / or inaccurate and / or incomplete.
– Right to cancel and Restriction Rights
Pursuant to art. 17 of the GDPR, in your capacity as Data Subject, you have the right to obtain, without undue delay, from the Data Controller, exclusively in the cases referred to in art. 17, paragraph 1, letters from (a) to (f), of the GDPR, the deletion of data concerning you – with the exception of the hypotheses specifically provided for by art. 17 paragraph 3.
Pursuant to art. 18 paragraph 1, letters from (a) to (d), of the GDPR, in your capacity as data subject you have the right to request and obtain from the Data Controller, the limitation of the processing of your personal data, or that such data are not subjected to further treatments and can no longer be modified. The Data Controller ensures that the limitation of the processing is implemented through appropriate technical devices that guarantee its inaccessibility and its non-modifiability.
– Right to Portability
Pursuant to art. 20 of the GDPR, in your quality of data subject, you have the right to receive from the Data Controller personal data concerning him which are processed by automated means, in a structured format, commonly used and readable by automatic device, and you have also the right to transmit such data to another data controller, or to obtain from the Data Controller, where technically feasible, the direct transmission of such data to another Data Controller specifically identified.
Right of Opposition
Pursuant to art. 21 of the GDPR, in your capacity as data subject you have the right to object at any time to the processing of personal data concerning you, for reasons connected with your particular situation, in cases where the processing of your data is necessary (1) the execution of a task of public interest and / or connected to the exercise of public authority vested in the Data Controller; (2) for the pursuit of a legitimate interest of the Data Controller or of a third party; (3) for the profiling activity, if performed by the Data Controller, on the basis of the previous points. You also have the right to object to the processing of your personal data for reasons related to your particular situation if they are processed for scientific or historical research purposes or for statistical purposes in accordance with Article 89 (1) of the GDPR, except in the case where the processing is necessary for the performance of a task of public interest.
You have the right to oppose the processing even if your personal data are processed by the Data Controller for the purposes of direct marketing and / or profiling activities linked to direct marketing. In such cases, Pentagon Trade Spółka z ograniczoną odpowiedzialnością Sp.k. ,the Data Controller, having received your communication in the manner indicated below, will refrain from further processing your personal data.
- how to exercise the rights mentioned above
You can exercise the rights listed above by request to be sent to the email address email@example.com at the c.a. of the Privacy Manager; or by registered post with the address above.
The Data Controller will confirm the receipt of your request and provide you with information on the action taken, with reference to the exercise of your rights under articles 15 to 22 of the GDPR, within 1 (one) month from receipt of the request. If necessary, and taking into account the complexity and the number of requests, the Data Controller may extend this term of 2 (two) months, upon substantiated notice to be sent within 1 (one) month from receipt of the request.
The Data Controller will communicate any correction, cancellation or restriction of opposition to all recipients, as identified by art. 4, paragraph 1, n. 9 of the GDPR, to whom such data have been transmitted, unless that proves impossible and / or it involves a disproportionate effort.
In the event that the Data Controller fails to comply with your request within the period of 1 (one) month from receipt of the request, the latter will inform you of the reasons for the non-compliance, informing you from now on your right to propose a complaint to the Authority of Control (Guarantor for the protection of personal data), as specified in accordance with art. 13, paragraph 2, letter (d) and governed by Articles 77 et seq. of the GDPR.
- revocation rights
Pursuant to art. 6 par 1 let. a) You have given consent to the processing of your data for the purposes specified above and therefore your express consent is purely optional and not mandatory, having no other consequence if not the impossibility for the Data Controller to properly perform the aforementioned direct communication services. And, in any case, the consent you may have provided may be revoked by you at any time, with immediate effect on the aforementioned business activities and services. It should be noted that this revocation will not affect the lawfulness of the processing based on the consent given prior to the revocation.
- right of complaint
Pursuant to art. 77 of the Gdpr, in your capacity as Interested Party you have the right to propose a complaint to a supervisory authority in the manner indicated in the article itself.
- consequences for non-disclosure of your data
The communication of your data is not a legal obligation. But as previously specified, it is based on the lawfulness of the processing, or your express consent, free, specific, informed and unequivocal or, possibly, the execution of a contract of which you are part or the execution of pre-contractual measures adopted by you.
Both the above legal bases therefore have a purely optional and non-compulsory nature, as they have no other consequence other than the impossibility for the Data Controller to properly perform the aforesaid direct communication or contractual / pre-contractual execution services. And, in any case, the consent you may have provided, as mentioned above, may be revoked by you at any time, with immediate interrupting effect of the aforementioned business activities and services.
- automated decision making and profiling
The Data Controller informs you that, for the purposes of processing your personal data, he does not make use of automated decision-making processes, i.e. those aimed at making decisions based solely on technological means according to predetermined criteria (i.e. without human involvement), he does not carry out profiling activities, that is, the one aimed at using your personal data to analyze or predict aspects of professional performance, economic situation, health, personal preferences, interests, reliability, behavior, location or travel etc..
Method of treatment
The processing of personal data communicated by you is carried out by means of the operations indicated in art. 4 n. 2) of the GDPR, namely: “collection, registration, organization, storage, consultation, processing, modification, selection, extraction, comparison, use, interconnection, communication, cancellation and destruction of data”.
The personal data you provide are processed automatically for the time strictly necessary to achieve the purposes for which they were collected, with technical and organizational methods, adopted to prevent the loss of data, illicit or incorrect use and unauthorized access, and such, therefore, to guarantee a level of security appropriate to the risk pursuant to art. 32 of the GDPR, by persons specifically authorized, in compliance with the provisions of art. 29 of the GDPR, by employees and / or collaborators of the Data Controller in their capacity as authorized subjects and / or system administrators, who can carry out operations of consultation, use, processing, comparison and any other appropriate operation in compliance with the necessary legal provisions to guarantee, inter alia, the confidentiality and security of data as well as the accuracy, updating and relevance of the data in accordance with the stated purposes and methods.
It should be noted, in particular, that the personal data you provide will be processed only at the registered office of the data controller, unless otherwise specified, and will not be disseminated, and, pursuant to art. 13, paragraph 1, lett. (e), they may be processed only by authorized parties and / or by external processors (in the case of individual professionals and / or complex professional associations), among which is explicitly the hosting company and / or by technical personnel in charge of the management and / or maintenance of the website, but only and exclusively for the purposes expressively and specifically indicated above.