As of May 25 2018, the EU Data Protection Regulation – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of the data of individuals concerning the processing of personal data and on the free movement of such data and repealing Directive 94/46/EC (referred to as ‘GDPR’) and the Polish Data Protection Act of May 10, 2018 came into force.
PAULA Ingredients Sp. z o. o., with its registered office at Łódzka 145a, 62-800 Kalisz, as the Personal Data Controller, ensures that it responsibly approaches the security of personal data processed. To adapt our company to the requirements of the new legal regulations, we have introduced changes to the Personal Data Security Policy and IT systems in force. We carried out an audit of our resources and the methods used to process and protect personal data and a data security breach risk-analysis. We have improved organisational and technical safeguards – including the IT and telecommunications infrastructure. We have introduced the obligation to conduct internal audits of the compliance of personal data processing with personal data protection regulations implemented at PAULA Ingredients Sp. z o. o.
As a result, PAULA Ingredients Sp. z o. o. (as the Personal Data Controller) processes personal data in a manner that ensures its adequate security, integrity and confidentiality, on a legal basis and following the law reliably, fairly, transparently to the data subject, with care for the accuracy of the data, for specific purposes, not ‘in reserve’ and for no more or longer than necessary. The Controller has appointed a Data Protection Officer (DPO) to supervise data processing correctness. The DPO can be contacted at the following e-mail address: firstname.lastname@example.org
PAULA Ingredients Sp. z o. o.:
1. Processes personal data in connection with the sale of goods or provision of services and for commercial contacts carried out for these purposes in connection with the recruitment or employment of employees and the implementation of contracts with cooperating entities (Article 6 (1) b) and c) of the GDPR). The processing of personal data may also occur when necessary for the purposes of the legitimate interests pursued by PAULA Ingredients Sp. z o. o Sp. k. (such as plant monitoring with buildings, marketing of its own goods, including via social media – e.g., Facebook, fanpage, LinkedIn, Twitter) except where overriding the interests of PAULA Ingredients Sp. z o. o Sp. k. have the interests or fundamental rights and freedoms of the data subject which require the protection of personal data (Article 6 (1) f) of the GDPR). PAULA Ingredients Sp. z o. o. also processes personal data when the data subject has given their consent for a specific purpose, when the processing is necessary for the performance of a contract to which the data subject is a party, when the processing is necessary for the performance of a legal obligation imposed on PAULA Ingredients Sp. z o. o. as the Controller, or when processing is necessary to protect the vital interests of the data subject or another natural person (Article 6 (1) a), b), c) and d) of the GDPR). PAULA Ingredients Sp. z o. o. processes personal data only to the extent necessary due to the legal basis and purpose of processing.
2. It implements the statutory rights of data subjects in the field of the right to obtain information covered by the information obligation, the right to access data, the right to rectify data, the right to delete data (‘the right to be forgotten’), the right to limit processing, the right to data transfer, the right to object and the right not to be subject to a decision based solely on automated processing (including profiling). The implementation of the rights above requires contact with PAULA Ingredients Sp. z o. o Sp. k. at the following e-mail address: dane.osobowe@PAULAingredients.com
3. The processed personal data is obtained mainly from data subjects (clients, contractors, employees, job applicants) but the source of the data processed by PAULA Ingredients Sp. z o. o Sp. k. is also third parties or registers (public or with limited access). The obtained personal data is provided, in particular, to employees, associates, subcontractors supporting PAULA Ingredients Sp. z o. o Sp. k. in the implementation of legitimate interests and other authorised entities based on legal provisions or concluded contracts. The transfer of personal data is carried out based on authorisations or on contracts of entrustment of the processing of personal data. This is only to entities that provide guarantees of the possession or implementation of appropriate technical and organisational measures so that the processing meets the requirements of the law and protects the rights of data subjects.
4. PAULA Ingredients Sp. z o.o. processes personal data for the period necessary to realise the purposes of processing specified in Point 1, i.e., in the scope of performance of the agreement concluded with PAULA Ingredients Sp. z o. o., until the conclusion of the agreement and, after that time, for the period required by law or for the fulfilment of potential claims; in terms of fulfilling legal obligations binding on PAULA Ingredients Sp. z o. o. or in terms of protecting the vital interests of the data subject or another natural person until the fulfilment of these obligations or protection of vital interests; in terms of processing based on the data subject’s consent until the data is deleted on the basis of the data subject’s request (withdrawal of consent); in the case of processing based on the prerequisite of legally justified interests of PAULA Ingredients Sp. z o. o. until these interests are fulfilled (e.g., in the case of monitoring the plant with buildings for three months, in the case of recruitment for a period of up to one year) or until the data subject objects to such processing unless there are legally justified the basis for further processing of this data.
5. Transfers of personal data outside the European Economic Area are based on the principles and use of safeguards specified in applicable law.
6. Personal data may be transferred to a third country by the Controller; the Controller warrants that any such transfers will take place only to countries ensuring an adequate level of protection – compliant with the provisions of GDPR, and where the data is transferred to other countries – that the transfer will take place based on standard data protection clauses or the consent of data subjects or where the transfer of data is necessary for the performance of a contract between the data subject and the Controller. The Controller warrants that data subjects will be able to obtain a copy of their data. The Controller will transfer collected personal data only in order and to the extent necessary for a given purpose of the processing in accordance with this privacy notice.
If you have any questions, please contact us at the following e-mail address: dane.osobowe@PAULAingredients.com
If the processing of personal data performed by PAULA Ingredients Sp. z o. o. infringes the provisions on personal data protection, the data subject shall have the right to lodge a complaint to the supervisory authority, which is the President of the Office for Personal Data Protection.