Newsletter

By clicking “I subscribe”, you express your wish to subscribe to the GWW electronic newsletter and provide your personal data in the form of your e-mail address. Giving your e-mail address is voluntary, but without it, GWW cannot register you in its mailing database and send you the information you are interested in.

Co-administrators (administrators who jointly determine the purposes and means of data processing) of your personal data are GWW Grynhoff i Partnerzy Radcowie Prawni i Doradcy Podatkowi spółka partnerska with its registered office in Warsaw, ul. Dobrej 40 (00-344), entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw, XII Economic Department of the National Court Register. Warszawy in Warsaw, XII Economic Division of the National Court Register, under the KRS number 0000541501, NIP 7792022623, REGON 631226810 (“GWW Legal“) and GWW Ladziński, Cmoch i Wspólnicy spółka komandytowa with its registered office in Warsaw at ul. Dobrej 40 (00-344), entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, XII Economic Division of the National Court Register, under KRS number 0000956566, NIP 7010313649, REGON 145496595 (“GWW Tax”).

Fulfilling the obligations imposed by Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in relation to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (“RODO”), the Joint Administrators provide the following information on the principles of processing of your personal data by the Joint Administrators, including the purposes of the processing, the legal basis for the processing, the storage period, the recipients of the personal data, as well as your rights in relation to the processing.

1.RESPONSIBILITIES OF THE JOINT CONTROLLERS

As part of the co-administration agreement between GWW Legal and GWW Tax, the co-administrators have agreed on the scope of their responsibility regarding the fulfilment of their obligations under RODO, including in particular that:

• with regard to the fulfilment of the obligation to provide information to personal data subjects, in accordance with the provisions of Articles 12-14 of RODO, the joint administrator who collects personal data or initiates the collection process is responsible;
• with regard to the exercise of the rights of the personal data subjects under Articles 7(3) and 15-22 RODO, i.e., withdrawal of consent, exercise of the right of access to personal data, rectification, erasure, restriction of processing, portability of personal data, objection to the processing of personal data, the co-controllers who received the request are responsible;
• with regard to the fulfilment by joint controllers of their obligations concerning the management of personal data breaches, their notification to the supervisory authority (Article 33 RODO) and to the person to whom the personal data refer (Article 34 RODO), the joint controller who first obtained information about the breach shall be competent; in case of simultaneous obtaining information about the breach, the joint controller on whose side the breach occurred shall be competent;
• if, on the basis of the above rules, it cannot be determined which co-administrator is responsible for the performance of the obligations set out in these paragraphs, GWW Legal is responsible.

Notwithstanding the above arrangements, the data subject may exercise rights under RODO against any of the joint controllers.

2.CONTACT DETAILS

The joint controllers have designated a single point of contact for all requests and enquiries concerning the personal data they process:

• In the case of contact by post by sending a letter to the personal data coordinator: 40 Dobra Street, 00-344 Warsaw, marked “personal data”.
• In case of contact by e-mail by sending an e-mail to: odo@gww.pl.

3.PURPOSE OF PERSONAL DATA PROCESSING AND LEGAL BASIS

In connection with the subscription to the GWW newsletter, your personal data will be processed by the co-administrators:

• for the purpose of implementing the GWW newsletter service terms and conditions, including the delivery of the GWW newsletter service (legal basis from Article 6(1)(b) RODO)
• for the purposes arising from the legitimate interests pursued by the joint controllers or third parties (legal basis from Article 6(1)(f) RODO), which are: to establish, assert or defend against claims; to implement internal procedures (e.g., concerning the protection of personal data, prevention of abuse)
• for other purposes, based on your separately granted consent (legal basis under Article 6(1)(a) RODO)

The provision of personal data is voluntary, however necessary for the purpose of providing the GWW newsletter.

4.RECIPIENTS OF PERSONAL DATA

The joint controllers only share personal data with other entities (recipients of personal data) if they have a legal basis for doing so. If the Joint Administrators transfer personal data to recipients located outside the European Union or the European Economic Area (EEA), this is only done if an adequate level of data protection has been confirmed for that third country by the European Commission or an adequate level of data protection has been agreed with the recipient (e.g., using so-called standard contractual clauses).

Your personal data may be disclosed to public authorities or other entities entitled to such access by law.

Recipients of your personal data may also be entities providing ICT services to the co-administrators, entities providing IT/technical/service support services, suppliers of software used by the co-administrators and other entities cooperating with the co-administrators in connection with the service provided to you.

The processing of personal data in ICT systems may result in the transfer of such data to the servers of software and IT service providers in connection with the co-administrators’ use of the services/software that the aforementioned providers provide. Some of these servers are in the United States. The transfer of data to the USA is carried out using the so-called standard contractual clauses referred to above. You are entitled to obtain a copy of this personal data.

5. RETENTION PERIOD OF PERSONAL DATA

The Joint Administrators do not keep personal data longer than necessary to achieve the purposes for which the data were collected.

Your personal data obtained in connection with the conclusion and execution of the agreement concerning the GWW newsletter subscription service (GWW newsletter service regulations) will be processed for the period of the GWW newsletter subscription, while your personal data processed for the purpose of realisation of legally justified interests realised by the co-administrators or third parties will be processed until the purpose of processing ceases or you raise an effective objection.

Personal data processed based on your consent will be processed until the purpose of the processing ceases or your consent is withdrawn (whichever comes first).

6.INFORMATION ON AUTOMATED DECISION-MAKING, INCLUDING PROFILING

Your personal data will not be processed in a purely automated manner (including profiling) which may produce legal effects on you or similarly significantly affect you.

7.RIGHTS OF PERSONAL DATA SUBJECTS

To the extent and in the cases stipulated by law, in particular RODO, you have the right to obtain from the joint controllers’ information about the processing of your personal data and to obtain a copy of the processed data (right of access to the data), the right to request the rectification (amendment) of your data, the right to request the erasure of your personal data, the right to restrict the processing of your personal data, the right to data portability, as well as the right to withdraw your consent (if the processing of your personal data is carried out on the basis of your consent).

You also have the right to object to the processing of your personal data based, inter alia, on the legitimate interests of the joint controllers, including profiling, in which case the joint controllers will cease processing your data for these purposes unless they demonstrate the existence of compelling legitimate grounds for the processing overriding your interests, rights and freedoms or grounds for establishing, asserting or defending claims.

If the joint controllers process your personal data for direct marketing purposes, you have the right to object to the processing of personal data concerning you for such marketing, including profiling, to the extent that the processing is related to such direct marketing. The exercise of this right means that the joint controllers will not process your personal data for such purposes.

The joint controllers will exercise the above rights in accordance with the provisions of RODO and other relevant legislation. To exercise your rights or to obtain further information regarding your rights, please contact the joint controllers (contact details are indicated in section 2).

8.RIGHT TO COMPLAIN

If you consider that the processing of your personal data by the joint controllers violates the provisions of RODO or other generally applicable data protection legislation, you may lodge a complaint with the President of the Data Protection Authority.