Privacy Policy

INFORMATION CLAUSE

Hereby, out of concern for the integrity of your personal data and your rights, and in order to meet the requirements of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, repealing Directive 95/46/EC (the “GDPR”), I would like to update and supplement information regarding the processing of your personal data.

ADMINISTRATOR

The controller of personal data is:
Arkadiusz Waliczek, conducting business under the name HYDROTRADE Poland, Arkadiusz Waliczek, 43-200 Pszczyna, ul. Piwowarska 24/5, NIP: 638 116 23 39, REGON: 072319501, hereinafter referred to as the “Administrator.”

CATEGORIES OF ADDRESSEES

This clause is addressed to:

2.1. Recipients of the Administrator’s goods and services and suppliers of goods and services to the Administrator, regardless of their legal form (hereinafter also referred to as the “other party”).

2.2. Persons performing work/services on behalf of or for the benefit of the other party, within the scope of the legal relationship between the Administrator and the other party, in particular employees, contractors, subcontractors, service providers, attorneys or authorised representatives of the other party (hereinafter collectively referred to as the “involved persons”).
(UWAGA: w Twoim tekście brakowało nazwy w cudzysłowie – uzupełniłem ogólnym określeniem.)

DATA SOURCE AND CATEGORIES OF PERSONAL DATA

Personal data have been obtained directly from the data subject. Personal data of the involved persons have been obtained either directly from the data subject or from the other party or other involved persons.

If the data originate from the data subject, that person has full control over the scope of the disclosed data.
If the data originate from the other party or other involved persons, they include the data necessary for identification and verification (contact data), such as: name, surname, telephone number, professional licence number, vehicle registration number, function, position, e-mail address, company name.

BASIS OF PROCESSING, PURPOSES OF PROCESSING, STORAGE PERIOD

4.0.1. Basis – consent. Purpose – business contacts requiring separate consent.
Processing serves to acquire and maintain business contacts (marketing using telecommunications end devices). Data are processed until consent is withdrawn. Withdrawal does not affect the lawfulness of processing carried out prior to the withdrawal.

4.0.2. Purpose – responding to requests and resolving doubts.
Submitting a contact form or sending an inquiry (e-mail, phone, social media) constitutes consent to being contacted for the purpose of addressing the request. Data are processed until consent is withdrawn.

4.0.3. Purpose – newsletter.
Processing serves to provide current information on the Administrator’s offer and activities. Data are processed until consent is withdrawn.

4.0.4. Purpose – effective/convenient functioning of websites.
The Administrator owns active websites: hydrotrade.pl, wf-sedziszow.hydrotrade.pl, mahle.hydrotrade.pl, and cronne.pl.
These are business-card websites and do not enable account creation or submitting personal data via a contact form. The websites use cookies—small text files stored by the browser. Cookies allow recognition of the device used to reconnect with the websites.

4.2. Basis – performance of a contract. Purpose – conclusion and performance of a contract.

Processing is necessary for the performance and settlement of a contract, including complaints, debt recovery, and transferring data to courier or shipping companies.
Data include: name, surname, company name, telephone number, e-mail address, correspondence/home/delivery address, business address, tax identification number, bank account number, etc.
Data are processed for the term of the contract and after its termination—for the limitation period, fraud prevention, statistics, and archiving.

4.3. Basis – legal obligation. Purpose – compliance with statutory documentation requirements.

Invoicing and accounting documentation are processed to meet statutory obligations, in particular under tax and accounting law.

4.4. Basis – legitimate interest. Purpose – marketing not requiring separate consent.

Processing serves direct marketing, building business relationships, presenting offers (including online).
The data subject may object under Art. 21 GDPR.
Data are processed until the objection is upheld.

Purpose – performance of a contract through an involved person.

This applies when an involved person performs activities under a contract between the Administrator and the other party (e.g., signing handover protocols, identity verification of drivers, etc.).
Processing serves the protection of rights, settlement, contract performance, and pursuing claims.
The data subject may object under Art. 21 GDPR.
Data are processed for the term of the contract and after termination (limitation periods, fraud prevention, archiving) or until an objection is accepted.

Purpose – proving fulfilment of obligations and pursuing or defending claims.

Data may be processed for archiving documents confirming performance of obligations and pursuing or refusing claims, also for accountability.
Data are processed for the duration of obligations and thereafter for relevant periods (limitation, fraud prevention, archiving) or until the objection is accepted.

RECIPIENT CATEGORIES

Data may be shared with:

5.1. Persons authorised by the Administrator (e.g., sales representatives).
5.2. Processors under Art. 28 GDPR (e.g., accounting, IT administrators, legal services, forwarding companies, hosting providers, payment service providers, platforms such as Allegro).
5.3. Persons authorised by further delegation; public authorities combating fraud and abuse.
5.4. Public bodies (ZUS, NFZ, tax authorities) under legal obligations; entities acting as separate controllers (e.g., shipping companies).

RIGHTS OF THE DATA SUBJECT

Under the GDPR, the data subject has the right to:

6.1. Access to data.
6.2. Rectification.
6.3. Erasure.
6.4. Restriction of processing.
6.5. Data portability.
6.6. Objection (if processing is based on legitimate interest).
6.7. Withdrawal of consent (if consent is the basis).

The Administrator will justify any refusal based on GDPR provisions.

Notes on specific rights (corrected and clarified):
– The Administrator may refuse erasure when an exception applies (e.g., legal claims).
– Data portability applies only when processing is based on consent or contract and is automated.
– Objection may be rejected if overriding legitimate grounds exist, except in the case of direct marketing.
– Consent may be withdrawn at any time without affecting prior processing.
– Complaints may be lodged with the supervisory authority. In Poland:
President of the Personal Data Protection Office, ul. Stawki 2, 00-193 Warsaw.
(The former GIODO no longer exists—corrected.)

FAILURE TO PROVIDE PERSONAL DATA AND CONSEQUENCES

Providing data required for invoicing is mandatory under tax and accounting law.
Failure to provide data necessary for contract performance (e.g., contact details, addresses, payment information) may prevent contract conclusion or fulfillment.
Data used for business contact and communication are voluntary but absence of such data terminates commercial communication.

Data in the form of an image or signature required for safety on the premises are necessary—failure to provide them prevents performing a contract requiring presence at the facility.

AUTOMATED PROCESSING

Personal data are processed automatically only within cookies, without producing legal effects or similarly significant consequences. Profiling consists of analysing preferences and interests.

GOOD PRACTICES – PROVIDING THE INFORMATION CLAUSE TO INVOLVED PERSONS

As good practice, the other party should provide this clause to involved persons as part of its information obligation.

CONTACT DETAILS

For all matters related to this information clause, including exercising rights and submitting requests, please contact the Administrator’s data protection contact point at:
info@hydrotrade.pl