ARIXO Advisory

Dear Sirs,

as Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (General Data Protection Regulation) applies from May 25, 2018, we provide you with information on personal data.

This document sets out the principles on which the personal data of persons using the ARIXO ADVISORY website (hereinafter: “the Site”) are protected.

The Privacy Policy describes the type of Service User's Personal Data collected, how it is collected, used, as well as stored and possibly shared, and describes what rights you have in connection with the processing of your Personal Data.

The Administrator is obliged to protect the privacy of Service Users. Acting to this end, the Administrator shall make every effort to ensure the protection of the personal data provided to the Service User in connection with the use of the Service.

Please be advised that the Administrator of your personal data is ARIXO ADVISORY Limited Liability Company with its registered office: Twarda 18, Warszawa 00-105.

PURPOSES AND GROUNDS FOR PROCESSING

1. Contract

If you are contacted for the purpose of entering into a contract, your data will be processed for the purpose of taking action at your request prior to entering into a contract, such as negotiating or presenting an offer (basis of Article 6(1)(b) RODO). The data will be processed for the period necessary to take action at your request. If a contract is not concluded after this period, the data will be deleted, while if a contract is concluded, they will continue to be processed until the execution of the contract and the statute of limitations for claims arising from the contract on the basis of the Administrator's legitimate interest, which is the defense and vindication of claims (Article 6(1)(b) and (f) RODO).

If a contract is concluded with you, the data will be processed:

(a) for the purpose of its execution (including contact in connection with its execution, confirmation of payment) and on its basis (the basis of Article 6(1)(b) RODO);

b) for the purpose of fulfilling the Administrator's legal obligations, including tax obligations, issuing VAT invoices, processing complaints, fulfilling information obligations (basis from Article 6(1)(c) of the DPA);

c) for archival (evidential) purposes to secure information in case of legal need to prove facts, for the purpose of possible establishment, investigation or defense against claims, on the basis of the Administrator's legitimate interest (the basis of Article 6(1)(f) RODO), which is then the investigation and defense of claims, archiving of documentation.

The scope of personal data necessary to conclude a contract depends on the subject of the contract. However, the administrator always requests only those data that are necessary to conclude a contract. Their provision is mandatory for the conclusion of the contract.

2. Conducting traditional correspondence and via e-mail

If you address the Administrator with e-mail or traditional correspondence, which is not related to the provision of services or performance of another contract, the personal data contained therein are processed for the purpose of handling the request or inquiry raised in the correspondence.

The basis for processing in such a case is the legitimate interest of the Administrator (Article 6(1)(f) of the RODO), which consists in conducting correspondence and handling requests and inquiries in connection with the business activity performed. Provision of personal data necessary to handle the request is mandatory.

3 Telephone contact

If you are contacted by telephone, on matters that are not related to the provision of services to you or the performance of any other contract, the personal data provided by you are processed for the purpose of handling the request or reported inquiry.

The basis for processing in such a case is the legitimate interest of the Administrator (Article 6(1)(f) of the RODO), which is to handle requests and inquiries in connection with the performance of business activities. The Administrator may request that you provide data necessary to handle the request, in which case the provision of such data is mandatory to handle the request.

4. Contact by employees of the contractor or customer

If you contact us by phone or email in connection with a contract concluded with your employer or actions taken at his request prior to the conclusion of the contract - we process the data thus obtained for the purpose of performing the contract concluded and taking actions at his request prior to the conclusion of the contract (the basis of Art. 6(1)(b) RODO), as well as for the purpose of investigating, defending against claims, which is the Administrator's legitimate interest in protecting your rights (the basis of Art. 6(1)(f) RODO).

5. Other grounds for processing

Your data may also be processed for the purpose of fulfilling the legal obligations of the Data Controller (the basis of Article 6(1)(c) of the RODO, including tax obligations, obligations under the Civil Code, RODO, issuance of VAT invoices, processing of complaints, fulfillment of information obligations).

RECIPIENTS OF DATA

1. Data processing entrustment and data sharing

We may share your personal data with the entities we use for data processing, e.g.: accounting, legal, IT, document shredding, document archiving, courier, transportation, email access providers, postal operators. The Administrator will also make your data available in a situation where it is necessary due to an obligation incumbent on him.

2. Transfer of data to third countries or international organizations

The Administrator may entrust the processing of personal data to a third country, i.e. outside the European Economic Area, and send it to external entities cooperating with the Administrator acting on behalf of the Administrator for the purposes described above.

The transfer of data outside the EEA, e.g. to the US, only takes place if the entity in question meets an adequate degree of security and data protection, e.g. based on the European Commission's decision of July 12, 2016, the so-called Privacy Shield. This means that your data can only be transferred to entities that comply with the rules set forth by the United States Department of Commerce under the EU-US Privacy Shield Framework programs governing the collection, use and storage of personal data from European Union member states, respectively. Such transfer shall only occur if a contract containing standard contractual clauses requiring a certain degree of personal data protection has been concluded with the entity receiving the data.

DATA RETENTION PERIOD

The length of time for which we may process your personal data depends on the legal basis for the processing of personal data by the Administrator. We will never process your personal data beyond the duration of the above-mentioned legal grounds. Accordingly, we inform you that:

1) where the Administrator processes personal data on the basis of consent, the processing period lasts until you withdraw that consent,

2) where the Administrator processes your personal data obtained on the basis of your request for the Administrator to take action before entering into a contract, the processing period lasts for the time necessary to take action on your request,

3) in case the Administrator processes personal data when it is necessary for the performance of a contract, the processing period lasts until the possibilitý of asserting claimś related to the contract by either party ceases,

4) where the Administrator processes personal data on the basis of a legitimate interest of the controller, the period of processing shall last until the aforementioned interest ceases to exist (e.g., the statute of limitations for civil law claims) or until the data subject objects to further such processing - in situations where such an objection is available under the law,

5) in the event that the Administrator processes personal data because it is necessary due to applicable laws, the processing periods for this purpose shall be determined by those laws.

YOUR RIGHTS

We inform you that you have the following rights:

(a) the right to access your data and receive a copy of it

b) the right to rectify (amend) your data

If, in your opinion, there are no grounds for us to process your data, you can request that we delete it.

(d) restriction of data processing

You may request that we restrict the processing of your personal data only to storing it or performing activities agreed with you, if in your opinion we have inaccurate data about you or are processing it unfoundedly; or you do not want us to delete it because you need it to establish, assert or defend your claims; or for the duration of your objection to the processing.

(e) The right to object to data processing:

Objection on grounds of special situation. You have the right to object to the processing of your data on the basis of legitimate interests for purposes other than direct marketing, and also when the processing is necessary for us to perform a task carried out in the public interest or for the exercise of public authority entrusted to us. You should then indicate to us your particular situation which, in your opinion, justifies our 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 of your data override your rights or that your data are necessary for us to establish, assert or defend claims.

(f) Right to data portability:

You have the right to receive from us in a structured, commonly used machine-readable format (e.g., “.csv” format) the personal data concerning you that you have provided to us pursuant to a contract or your consent. You may also have us send this data directly to another entity.

(g) The right to lodge a complaint with a supervisory authority

If you believe that we are processing your data unlawfully, you may file a complaint about it with the President of the Office for Personal Data Protection.

(h) The right to withdraw your consent to the processing of personal data

At any time you have the right to withdraw your consent to the processing of those personal data that we process on the basis of your consent. Withdrawal of consent will not affect the lawfulness of the processing that was carried out on the basis of your consent before its withdrawal.

At any time you have the right to withdraw your consent to the processing of those personal data that we process on the basis of your consent. Withdrawal of consent will not affect the lawfulness of processing that was carried out on the basis of your consent before its withdrawal.

If you believe that we are processing your data unlawfully, you may file a complaint about it with the President of the Office for Personal Data Protection.

If you wish to exercise the above rights, please contact us in person, via snail mail or e-mail using the following details:

ARIXO Advisory Spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, 18 Twarda Street, 00-105 Warsaw;

e-mail: office@arixo.pl

(Monday through Friday, 9:00 a.m. - 5:00 p.m.).

VOLUNTARINESS OF PROVIDING PERSONAL DATA

The provision of data in connection with the handling of the request and the reported inquiry, presented by telephone, traditional correspondence or e-mail correspondence, is necessary for the handling of the inquiry and the response to it and the resolution of the matter, and their failure to do so will result in the inability to send a response or resolve the matter.

When you contact us to ask a question or indicate a matter to be resolved, the provision of your data to enable return contact is voluntary, but necessary to answer the question or resolve the matter presented.

Providing the data indicated in the contact form as mandatory is necessary to handle the question and answer it, and failure to do so will result in the inability to send the inquiry.

Provision of data in connection with the conclusion, execution and performance of the contract is voluntary, but necessary for the proper implementation of the service and performance of the contract. The consequence of not providing this data will be the inability to conclude a contract with the Administrator.

We may also require you to provide data if it is necessary for the performance of our legal obligations. In that case, the provision of data is mandatory. Failure to provide them prevents sending commercial information on products and services, promotions and offers.

AUTOMATED DECISION-MAKING

Please be advised that we will not make automated decisions about you, including that you will not be subject to profiling.

COOKIES POLICY

The website uses cookies to provide the best possible experience of using it. If you do not change your browser settings on your side, you agree to their use.

A cookie is a small piece of text information sent by a server and stored on the device of a visitor to our Service (usually on the hard drive of a computer or mobile device). It stores information that the Service may need to adapt to the visitor's use of the Service and to collect statistical data about the Service.

When Users browse the content of the Service, information regarding the use of the Service by Users and their IP addresses is automatically collected based on analysis of access logs, such as browser type, operating system type, date and time of visit, number of connections, number of subpages of the Service opened, content viewed.

Installation of “cookies” is necessary for proper operation of functionality on the Website. The “cookies” files contain information necessary for the proper functioning of the website, especially those requiring authorization.

The website uses the following types of “cookies”: session, permanent, analytical. “Session” cookies are temporary files that are stored on the User's terminal device until the User logs out, leaves the website or shuts down the software (web browser). “Permanent” cookies are stored on the User's end device for the time specified in the parameters of the cookies or until they are deleted by the User. “Analytical” ‘cookies’ make it possible to better understand how the User interacts with the content of the website, to better organize its layout. “Analytical” ‘cookies’ collect information about the way Users use the website, the type of page from which the User was redirected, and the number of visits and the time of the User's visit to the website. This information does not record specific personal information about the User, but is used to compile statistics on the use of the website.

The user has the right to decide on the access of “cookies” to his/her computer by selecting them in advance in his/her browser window. Detailed information on how to change the settings for cookies and how to delete them yourself in the most popular web browsers is available in the help section of your web browser and on the following pages:

- in the Chrome browser

- in Firefox browser

- in the Internet Explorer browser

- in the Opera browser

- in the Safari browser

In addition to cookies, the Site may also collect data customarily collected by Internet system administrators as part of so-called logs or log files. Information contained in the logs may include: IP address, type of platform, type of web browser

Third-party cookies

By using our websites, you may receive cookies from third parties cooperating with the Administrator, such as Google, Facebook, Twitter, as well as from companies implementing advertising campaigns on our websites on behalf of advertisers. You can find more information about these cookies on the websites of individual third parties.

Contact

ARIXO advisory