Data processing includes all activities that are carried out on them, starting with their collection, through recording, storage, modification, use, disclosure, transfer and removal.
We process personal data protecting it against unauthorized access by third parties and taking care of its integrity, using for this purpose organisational and technical security measures. Our policies and internal procedures related to data protection are monitored and updated as required. All our employees and associates are obliged to maintain confidentiality and take all precautions in the processes related to the processing of personal data.
Personal Data Administrator Data
The administrator of your personal data is SEQRED Sp. z o.o. with its registered office in Warsaw at Rybnicka street number 52, 02-432 Warsaw, entered into the Register of Entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, 14th Commercial Division of the National Court Register under the number KRS: 0000873841, holding NIP number 5223129294 and Regon number 380552914, hereinafter referred to as “SEQRED”. Contact with SEQRED regarding the protection of personal data is possible at the following email address: [email protected]
Purpose and basis of personal data processing
The term GDPR used in this document means 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, and repealing Directive 95/46 / EC.
SEQRED processes Your personal data in connection with the provision of services to You. Processing has different purposes, however it always takes place in accordance with applicable law.
In order to respond to the correspondence sent by you, we process the personal data contained therein and provided by you in the contact form, in particular:
- first and last name,
- email address,
- phone number,
- optional other data provided by you.
The legal basis for such data processing is art. 6 clause 1 lit. b) GDPR, which allows to process personal data if their processing is necessary to perform a contract to which the data subject is a party or to take action at the request of the data subject prior to entering into a contract.
Supplying of above data is not mandatory, however, failure to provide them will not allow us to respond to Your message or send You a reply to correspondence received.
In addition, for analytical and website administration purposes SEQRED may process data characterizing the way you use our website, such as:
- IP address,
- digital logs,
- information about using our website,
- browser type,
- type of operating system,
- time spent on the website,
- visited subpages.
The legal basis for such data processing is art. 6 clause 1 lit. f) GDPR, which allows to process personal data if it is necessary for purposes arising from legitimate interests pursued by SEQRED, such as learning about the activity of customers visiting our website or website administration.
If we process data for any other purpose not indicated above, it is completely anonymised, which makes it impossible to identify the user based on such data.
Cookies is IT data saved by a website on your device. Websites use them to record various information regarding visits to these sites.
Our website does not automatically collect any additional information, except for those contained in cookies.
Cookies perform many functions on the website, in particular they serve:
- matching the content of the website to the individual preferences of the user – cookies primarily recognize the user’s device to display the page in accordance with his preferences;
- affect the processes and efficiency of using the website – cookies are used to remember settings between subsequent visits to the website, which allows the website to operate efficiently and use the functions available on it;
- affect the display of the website – cookies, depending on the type of device you use, ensure proper display of the website;
- session state saving – cookies store information on how visitors use the website, e.g. which subpages are most often displayed. They also allow identifying errors displayed on some subpages. Cookies used to save so-called “Session state” thus help to improve services and increase the comfort of browsing the pages;
- session state maintenance – cookies allow you to maintain the session. This means that after switching to another subpage, you do not need to provide your data again each time, which promotes the comfort of using the website;
- statistics creation – cookies are used to analyze how users use the website, which allows continuous improvement of the website and adapting it to users’ preferences. The statistics created are completely anonymous, so user identification is disabled.
In a situation where you do not want to install cookies, you can change Your browser settings at any time. At the same time, we bring it to your attention that disabling cookies may lead to difficulties in using the website or even prevent such use. Most web browsers allow individual users to control cookie access in preferences. In order to familiarise yourself with the rules of using cookies within individual browsers, it is recommended that you familiarise yourself with the individual privacy policies of these browsers. You will find information on the cookie access management options on relevant websites, e.g.
In case of doubt or for more detailed information, use the “help” option of the web browser used.
The right to withdraw consent
If the processing of personal data is based on consent (cookies), you can withdraw this consent at any time. To do this, change your browser settings.
If the processing of your personal data was based on consent, its withdrawal does not mean that the processing of personal data up to this point was illegal, i.e. the cancellation does not affect the lawfulness of the current processing.
We reserve the right to process Your data after the termination of the Agreement or withdrawal of consent only for the purposes of pursuing any claims before the court or if national or EU regulations or international law oblige us to retain data.
Requirement to provide personal data
Providing personal data is in principle voluntary and depends on your decision. However, in some cases, providing certain personal data is necessary to meet your expectations regarding the use of services offered by SEQRED.
In order to correspond with SEQRED or send a message to SEQRED, it is necessary to provide your first and last name, email address and phone number, respectively – we are unable to respond to your message without this information.
Recipients of personal data
If necessary, we transfer your personal data to our business partners, including those dealing with accounting, legal, administrative, IT systems, hosting, payment services, and insurance services, only to the extent necessary to process the order.
It may happen that, based on the relevant law or decision of the competent authority, we will also have to transfer your personal data to other entities, including public, legislative, supervisory bodies, judicial authorities, as well as trustees, notaries or auditors. We ensure that every case of request for disclosure of personal data is analysed very diligently and very carefully so as not to provide any information to an unauthorized person.
Transfer of personal data to third countries
SEQRED S.A. does not transfer your personal data to any third countries.
The period of personal data processing
1. We do not process your personal data “indefinitely”, but for the time that is needed to achieve the set goal. After this period, your personal data will be irreversibly deleted or destroyed.
2. We process personal data for the period of:
- the duration of the contract or until the limitation of claims arising from the contract – in relation to personal data processed for the conclusion and performance of the contract;
- 3 years (entrepreneur’s data) or 6 years (natural person’s data) + 1 year from the date of termination of the relationship or termination of the court dispute – in relation to personal data processed in order to determine, assert or defend claims (the length of the period depends on whether both the parties are entrepreneurs or not) or other time defined by law;
- 5 years – in relation to personal data related to the fulfillment of obligations under tax law, or any other period specified by law;
- until the consent is withdrawn or the purpose of processing is achieved, but no longer than until the claims expire, or another period specified by law – in relation to personal data processed on the basis of consent;
- until the objection has been successfully lodged or the purpose of processing has been achieved, but not longer than 5 years, or another period specified by law – in relation to personal data processed on the basis of the legitimate interest of SEQRED or for marketing purposes;
3. Periods in years are counted from the end of the year in which we started processing personal data to improve the process of removing or destroying personal data. Counting the deadline separately for each event would involve significant organisational and technical difficulties as well as a significant financial outlay, so setting one date for deleting or destroying personal data allows us to manage this process more efficiently. Of course, if You exercise your right to forget, such situations are considered individually.
4. The additional year related to the processing of personal data collected for the purposes of performing the contract is dictated by the fact that you can hypothetically file a claim just before the expiry of the limitation period, the request may be served with a significant delay or you may incorrectly specify the expiration for your claim.
Data subjects’ rights
1. Please be advised that you have the right to:
- access to your personal data (you have the right to ask us which personal data of Yours we process. In response to your request, we will send you a summary of this data);
- rectification of personal data (you have the right to ask us to rectify Your incorrect personal data; If we submit such an application after we have transferred Your data to third parties, we will immediately inform these entities about the rectification of the data);
- deletion of personal data (in cases permitted by law, you can submit a request to SEQRED for the deletion of your personal data);
- restrictions on the processing of personal data (if you objected to the processing of personal data by SEQRED in connection with their processing on the basis of a legitimate interest, and this objection has been accepted, you believe that the information that SEQRED processes is incorrect, you believe that SEQRED processes personal data not in accordance with the law or you want SEQRED not to delete your data, you can submit a request to limit the processing of personal data);
- object to the processing of personal data (in the event of recognition that, due to our processing of your personal data on the basis of a legitimate interest, a negative influence is exerted on you, you can object to SEQRED against such use of personal data);
- object to automated decision-making (in the event where it is necessary to perform the concluded contract or if you have agreed to it, we can use the help of automatic decision-making systems. You have the right to object to automatic decision-making and request to take decisions by our authorized employee);
- transferring personal data (you can submit an application to SEQRED at any time to transfer your personal data to other entities You indicate).
2. We respect your rights arising from the provisions on the protection of personal data and we try to facilitate their implementation to the greatest possible extent. These rights are not absolute, so in certain situations we may lawfully refuse you to fulfill them. However, if we refuse to accept your request, then only after careful analysis and only if the refusal to accept the request is necessary.
3. You can exercise your rights by:
- sending an email directly to SEQRED to the address [email protected], or
- sending a written information directly to the address of the SEQRED office.
Right to lodge a complaint
If you think that your personal data is being processed contrary to applicable law, you can lodge a complaint with SEQRED, to which we are obliged to respond. In the event that you are not satisfied with our service related to the recognition of a complaint or our activities regarding the processing of personal data still cause your concern, you can submit a complaint to the President of the Office for Personal Data Protection or another body for personal data protection.
Providing personal data for marketing and analytical purposes is voluntary. If you do not agree to the processing of personal data You leave as part of using our website, including data stored in cookies, your personal data will not be processed for this purpose.
Providing personal data necessary to provide services by SEQRED is necessary. If these data are not provided, the services will not be able to be provided.
Providing personal data related to the justified purpose of the Administrator is necessary to ensure the high quality of our services. Lack of your data for this purpose may prevent the correct provision of services.