Dear Sir/Madam,
We would like to inform you that as of May 25, 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016, on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as GDPR, is in effect. In connection with this, we inform you that you have certain rights related to the processing of your personal data by us. You will receive the full text of the information obligation, referred to in Articles 13 or 14 of the GDPR:
If you have any questions or concerns regarding the privacy policy, you can contact us at any time by sending a message to the email address: biuro@leadtrust.eu
By sending us an email, you provide us with your personal data, and we guarantee that the data provided will remain confidential, secure, and will not be shared with any third parties contrary to the regulations contained in this policy.
We may share your personal data with other entities within the LEADTRUST capital group for the purpose of fulfilling contracts and providing services as part of our collaboration with you, or with selected individuals/third parties cooperating with us in the execution of our projects
What data are we talking about?
Personal data refers to information relating to an identified or identifiable natural person. This primarily includes data that allows for your identification, such as your first and last name, numerical identification data such as PESEL, NIP, ID card number and series, address and contact details, e.g., phone number, email address.
Data Controller.
The Data Controller of your personal data is LEADTRUST GROUP LIMITED LIABILITY COMPANY, based in Warsaw (00-195), at Zygmunta Słomińskiego Street 5/174, registered in the Register of Entrepreneurs maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under KRS number: 0001053229, NIP: 5252969111, REGON: 526148422.
Why and on what basis do we process your personal data?
Your personal data may be processed by us on the basis of the legitimate interest pursued by the controller (Article 6(1)(f) GDPR) for the following purposes:
1. to take steps prior to entering into a contract or when necessary for the conclusion and performance of a contract entered into with you (Article 6(1)(b) GDPR);
2. to handle your requests and inquiries by receiving and responding to them (Article 6(1)(a) GDPR);
3. for marketing purposes, particularly to present you with a financial offer, provided that you have given us your voluntary consent; the legal basis for processing is therefore your consent (Article 6(1)(a) GDPR);
4. for the purpose of customer satisfaction surveys – the legal basis for data processing is the necessity of processing for the purposes of the legitimate interest pursued by the controller; the legitimate interest of the controller is to maintain a high quality of our service and the satisfaction level of our customers with our products and services (Article 6(1)(f) GDPR);
5. to store information for tax and accounting purposes, which is our legal obligation under applicable law (Article 6(1)(c) GDPR);
6. to handle your complaints, which is our legal obligation under applicable law (Article 6(1)(c) GDPR);
7. to fulfill our legal obligations under the regulations on anti-money laundering and counter-terrorism financing (Article 6(1)(c) GDPR);
8. to protect the rights of LEADTRUST GROUP LIMITED LIABILITY COMPANY in accordance with legal regulations;
9. Your personal data may be processed by us on the basis of the legitimate interest pursued by the controller (Article 6(1)(f) GDPR).
Email contact.
When contacting us via email, you provide us with your email address as the sender of the message. Additionally, you may include other personal data in the content of the message. The legal basis for processing personal data in this case is the consent resulting from initiating contact with us. Your personal data provided to us through email contact is processed solely for the purpose of handling the inquiry. The content of the correspondence may be subject to archiving
Marketing consents.
The legal basis for processing personal data in this case is the consent given by the person whose data is being processed, which can be withdrawn at any time. The data will be processed in an automated manner, including profiling and automated decision-making, and as a consequence of such processing, you will receive targeted marketing information. Providing personal data is voluntary; however, failure to provide data may result in the inability to receive marketing offers.
How do we protect your personal data?
We are aware that your personal data is confidential. The company maintains confidentiality, security, and protection of your personal data in accordance with applicable laws, including the GDPR, as well as the internal policies and procedures adopted by the company. The company has implemented technological and operational security measures to protect your personal data from loss, misuse, unauthorized modification, or destruction. Such measures include, among others, encryption, appropriate access management processes, and other technical and organizational measures ensuring proper protection of your personal data. These measures provide an appropriate level of security in relation to the risks inherent to the nature of the personal data being protected. However, please note that when transmitting information over the Internet, 100% security cannot be guaranteed. We ensure that all security and data protection measures required by data protection laws are taken. Personal data is collected with due diligence and appropriately protected against unauthorized access.
How long will we retain your personal data?
The period for which the Data Controller will process your personal data depends on the purpose of processing.
1. We process your data for the period necessary to fulfill the contract and for the expiration of any claims arising from it, or until the consent is withdrawn. For example, for marketing purposes of products and services, your personal data will be processed until the consent is withdrawn.
2. We retain user personal data for the duration required for archiving accounting documents in accordance with applicable laws, including tax and accounting obligations.
3. for the purpose of pursuing claims related to the performance of the contract,
4. to prevent abuse and violations of legal regulations,
5. for statistical purposes,
6. for a maximum period of 10 years from the end of the cooperation between the parties.
Who can we share your personal data with?
LEADTRUST GROUP LIMITED LIABILITY COMPANY, as the Data Controller, may share your personal data with other entities that have been authorized or required to receive such data under legal regulations, including those related to anti-money laundering and counter-terrorism financing, and in particular:
Do you have to provide us with your personal data?
Providing your personal data is voluntary. However, if the processing of your personal data is necessary for the conclusion and performance of a contract, failure to provide such data will result in the inability to conclude and execute the contract.
Profiling and automated decision-making in the processing of personal data.
We inform you that in the course of our activities, your data will be processed in an automated manner, including through profiling. Profiling means using your personal data to assess your preferences regarding the method and timing of contact with you.
Transfer of your personal data outside the European Economic Area (EEA). Your personal data is not transferred to third countries or international organizations.
Rights related to the processing of personal data:
In our operations, we guarantee the ability to exercise rights under GDPR. According to GDPR provisions, you have:
1. Right of access to data – You have the right to obtain confirmation from the Company as to whether your personal data is being processed by the Company, as well as certain other information (e.g., regarding the purposes of processing and the categories of personal data being processed about you). You also have the right to access your personal data by receiving a copy of the personal data concerning you. This is to ensure that you are aware of and can verify how the Company uses your personal data. The Company may refuse to provide a copy of personal data if it could potentially;
2. Right to rectification – You have the right to request the Company to promptly correct your personal data if it is inaccurate or incomplete (e.g., if the Company is processing your incorrect name or address); for this purpose, you may provide additional statements.
3. Right to erasure (also known as the “right to be forgotten”) – This allows you to request the deletion of your personal data when, for example, the data has been used unlawfully or if your consent has been withdrawn (in cases where consent was the sole basis for processing your data). However, the “right to be forgotten” is not an absolute right to the deletion of your personal data, as there are exceptions, such as when the Company still needs to use the data to establish, exercise, or defend legal claims or to fulfill a legal obligation.
4. Right to restriction of processing – You have the right to request the Company to stop using your personal data further if, for example, the Company is in the process of assessing a request to rectify your data. In the case of restriction of processing, the Company may still store your personal data but cannot actively use it further (e.g., for the performance of a contract).
5. Right to data portability – You have the right to receive and reuse certain personal data for your own purposes with other organizations (which are separate data controllers). This right applies only to your personal data that you have provided to us and that we process (in an automated manner) based on your consent or for the performance of a contract. In such cases, we will provide you with a copy of your personal data in a structured, commonly used, and machine-readable format, or (if technically feasible) we may transmit your data directly to another data controller. The Company may refuse to exercise this right if it could negatively impact the rights of another individual.
If the basis for processing your personal data is the pursuit of legitimate interests, you have the right to object to the processing of your data, particularly in relation to its processing for direct marketing purposes. However, the Company may continue to process personal data if it can demonstrate compelling and legally justified grounds for processing that override your interests, rights, and freedoms, or if it is necessary for the establishment, exercise, or defense of legal claims. If you object to the processing of your personal data for direct marketing purposes, we will cease to process your data for such purposes.
To the extent that the processing of your personal data is based on consent, you have the right to withdraw that consent at any time. The withdrawal of consent does not affect the legality of the processing that was carried out based on consent before its withdrawal.
You have the right to lodge a complaint with the supervisory authority responsible for overseeing compliance with data protection regulations (the General Inspector for Personal Data Protection or its successor, the President of the Personal Data Protection Office).
If you wish to exercise the above rights, you may submit your request via:
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