Privacy Policy
This document is effective from September 1, 2022.
PRIVACY POLICY
Terms
1.1. The purpose of the Pricer24 Privacy Policy (hereinafter – the Privacy Policy) is to provide the Data Subject with information about the purpose, legal basis, scope, conditions of processing, protection measures implemented by Pricer24 (hereinafter – Pricer24), as well as about the Data Subject’s rights regarding processing Personal data. Additional information on the processing of Personal Data may be included in contracts and other documents, as well as posted on the Pricer24 website.
1.2. This Privacy Policy applies to Pricer24 and is mandatory for employees and subcontractors of the company who have access to Personal Data and/or process Personal Data.
1.3. The privacy policy is developed in accordance with the legislation of Poland and the European Union, namely in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC; Convention on the Protection of Individuals in Connection with Automated Processing of Personal Data dated January 28, 1981, as well as in accordance with Art. 13 section 1 section 2 of Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the use of personal data and on free access to such data and the use of services 95/46 /EC (General Data Protection Regulation ) (Legislative Journal EU.L.2016.119.1).
1.4. Pricer24 takes care of the privacy of Data Subjects and the protection of Personal Data, respecting the rights of Data Subjects to the legality of the processing of Personal Data in accordance with current regulations.
1.5. Pricer24 takes appropriate technical and organizational measures to protect Personal Data from unauthorized access, unlawful disclosure, accidental loss, alteration, destruction or any other unlawful processing.
1.6. Personal data is obtained directly from the Data Subject and from the services used by the Data Subject (for example, in the System), as well as from external sources (for example, public registers or databases) or other persons (for example, a legal entity that represents the Data Subject, or an employee, official, beneficial owner of a legal entity). Pricer24 may record telephone conversations (subject to prior consent of the Data Subject), take video and/or audio, take photographs at any events organized and/or held by Pricer24 (subject to consent of the Data Subject), store messages email or otherwise document the Data Subject’s interaction and exchange of information with Pricer24.
2. Terms and abbreviations used in the Privacy Policy:
2.1. Processing is any action (set of actions) or set of operations performed with the help of information (automated) means, systems or without their use in relation to Personal Data or sets of Personal Data, such as collection, registration, accumulation, adaptation, change , organization, structuring, storage, adaptation or modification, recovery, revision, use, disclosure by distribution (sending, implementation, distribution, transmission) or otherwise providing access, coordination, combination, restriction, depersonalization (removal), erasure or destruction.
2.2. A person who processes personal data is a natural person, including an individual entrepreneur, enterprises, institutions and organizations of all forms of ownership, state authorities or local self-government bodies, or another state body that processes Personal Data on behalf of the Data Owner.
2.3. The data owner is Pricer24, which processes the Personal Data of the Data Subject in accordance with the stated purposes and means of processing Personal Data.
2.4. Data subject – potential, current, former Pricer24 client – natural person; an employee of Pricer24, a candidate for a position, a visitor, a visitor and user of the website (including the Systems), a participant in events organized by Pricer24, an employee of legal entities (for example, customers, business partners, landlords of Pricer24, etc.), an official, a contact person, authorized person, beneficial owner and any other identified or identifiable natural person whose personal data is processed by Pricer24.
2.5. The system is the Pricer24 system (https://my.pricer24.com/).
2.6. Pricer24 – PRICER24 SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (Poland)
2.7. Personal data – any information (data) relating to an identified or identifiable natural person (Data Subject).
2.8. General Data Protection Regulation – Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (GDPR).
2.9. Convention on the Protection of Individuals – Convention on the Protection of Individuals in Connection with Automated Processing of Personal Data dated January 28, 1981.
2.10. Law on Protection of Personal Data – the General Data Protection Regulation (Regulation (EU) 2016/679) (‘GDPR’) and the Act of 10 May 2018 on the Protection of Personal Data.
2.11. Standard procedure for processing personal data – Standard procedure for processing personal data, approved by the Act of 10 May 2018 on the Protection of Personal Data.
3. Information about the Data Owner
3.1. Pricer24 is the Data Owner according to the terminology of the current legislation of Poland. For the purposes of the General Data Protection Regulation (GDPR), Pricer24 is a data controller.
3.2. Pricer24 may be a Data Owner, Data Processor or Joint Owner when processing Personal Data of a Data Subject.
3.3. The Data Owner is Pricer24, which has obtained the Personal Data of the Data Subject, for example from an employee or contractor, on the basis of a contractual relationship or before the establishment of a contractual relationship, by submitting an application to the Data Subject or visiting the premises of Pricer24 or otherwise.
3.4. Pricer24 and its contact information and website address are available at: https://pricer24.com.
4. Purposes of personal data processing
4.1. The processing of Personal Data of Pricer24 employees and subcontractors is necessary for the fulfillment of a legal obligation as an employer and a party to a contract that uses the labor of hired personnel or individual economic entities. Personal data of counterparties and other entities are processed for the purpose of implementing contractual relations during Pricer24’s business activities.
Pricer24 processes Personal Data mainly for the following purposes:
4.1.1. compliance with legal requirements;
4.1.2. conclusion and execution of contracts;
4.1.3. registration of the client in the System, ensuring the operation of the System and improving its functioning;
4.1.4. preparation of invoices and payments;
4.1.5. identification of the client/Data Subject;
4.1.6. provision of information exchange;
4.1.7. implementation of activities, including provision of administrative, accounting and archival functions;
4.1.8. ensuring the process of personnel selection and ensuring the legitimate interests of Pricer24 in the part related to personnel selection;
4.1.9. management of personnel records;
4.1.10. carrying out marketing activities (for example, providing information and offers, organizing events for business partners/employees and their family members and their coverage in the media and social networks, promoting the recognition of Pricer24’s image);
4.1.11. consideration of applications/complaints and other documents;
4.1.12. implementation of labor relations, relations in the field of personnel management, military registration of conscripts, labor protection;
4.1.13. implementation of relations in the field of accounting and tax accounting;
4.1.14. preparation of statistical and other reporting defined by legislation;
4.1.15. documentation support, in particular, the rights and obligations of employees and employers in the field of labor;
4.1.16. for other purposes in legally justified cases.
4.2. Уin any of the cases specified in clause 4.1 of the Privacy Policy, Pricer24 processes Personal Data within the limits permitted by the specific purpose of processing Personal Data and in accordance with the procedures required and permitted by applicable laws and regulations. In particular, the processing of Personal Data is carried out in accordance with the requirements of the Law on the Protection of Personal Data and the Standard Procedure for the Processing of Personal Data. The processing of personal data of a Data Subject who is in the territory of the European Union or is a citizen of the European Union regardless of his location is regulated by the General Data Protection Regulation (GDPR) and the Convention for the Protection of Individuals. The legislation of the countries with whose residents Pricer24 is in partnership and business relations may establish additional requirements for the processing of Personal Data of the Data Subject.
4.3. In the event that Pricer24 changes the specified purpose of Personal Data processing to a new purpose that is incompatible with the previous one, Pricer24 obtains the Data Subject’s consent to process his data in accordance with the changed purpose for further data processing.
4.4. Pricer24 does not process Personal Data classified as confidential information by law or by the Data Subject without the Data Subject’s consent. Pricer24 has the right to process Personal Data without the Data Subject’s consent until such time as consent becomes possible if such processing is necessary to protect the vital interests of the Data Subject.
4.5. Pricer24, except for cases provided by law, informs the Data Subject at the request of the composition and content of the collected Personal Data; grounds for processing Personal Data; rights defined by current legislation; the purpose of collecting Personal Data; informs the Data Subject that the Data Owner takes all necessary measures to protect Personal Data.
4.6. Personal data must be accurate, reliable and updated as necessary, determined by the purpose of their processing. The Data Subject shall notify Pricer24 of a change in the Personal Data to be processed, providing the relevant documents or their copies.
4.7. If Pricer24 discovers, during the processing of Personal Data, information about the Data Subject that does not correspond to reality, such information is immediately changed or destroyed.
4.8. Personal data of the Data Subject, depending on the method of their storage (paper, electronic media), are processed by Pricer24 in such a way as to prevent access to them by third parties.
5. Legal basis for processing Personal Data
5.1. Pricer24 processes Personal Data on the following legal grounds:
5.1.1. For the conclusion and execution of the contract – processing of Personal data is carried out for the purpose of ensuring the conclusion of the contract, provision of services/sale of goods, settlement process or resolution of issues arising from the concluded contract, as well as for taking measures before the conclusion of the contract. The signature of the counterparty in the contract confirms the notification of the rights in the field of protection of Personal data, the Data Owner, the composition and content, the purpose of the collection of Personal data.
5.1.2. To prepare for the conclusion, conclusion and execution of an employment contract – processing of Personal data is carried out for the purpose of preparation for the conclusion, conclusion of an employment contract with candidates for the position, as well as execution of an employment contract with Pricer24 employees in accordance with the legislation of Poland. The correctness, accuracy and up-to-date information contained in the resume of the candidate for the position, the documents provided by Pricer24 for employment, as well as during the performance of his work duties are checked. Personal data is processed to the extent necessary for the implementation of employment relations.
5.1.3. To fulfill a legal obligation – the processing of Personal Data is necessary to fulfill the obligations specified in regulatory legal acts, for example, in relation to administrative, accounting, archival requirements, rules for preventing money laundering and terrorist financing and compliance with international sanctions, as well as to fulfill requests of law enforcement, supervisory and other institutions in the scope and in the order provided by regulatory and legal acts.
5.1.4. For the purpose of realization or protection of legitimate interests – on this basis, Personal Data is processed, for example, to prevent and detect criminal offenses related to the protection of property, as well as to obtain and preserve evidence in legal disputes (video surveillance), debt collection, loss prevention , protecting the rights and interests of customers, business partners, promoting the recognition of Pricer24’s image. Based on Pricer24’s legitimate interests, Personal Data is also processed within the scope of the recruitment process. In such cases, it is assessed that the Data Subject’s privacy is not compromised during processing.
5.1.5. Consent is the voluntary expression of the Data Subject’s will to grant permission to Pricer24 for the lease of his Personal Data in accordance with the formulated purpose of their processing. It is expressed in written form, in electronic form (by imposing an electronic digital signature by the Data Subject in accordance with the legislation on electronic documents, electronic document flow, as well as the legislation in the field of the use of electronic signatures) or in a form that makes it possible to conclude that consent has been given. Before processing Personal Data, Pricer24 obtains the Data Subject’s consent to process Personal Data. Such consent of the Data Subject is voluntary and informed. The data subject can withdraw consent at any time. In the field of e-commerce, the Data Subject’s consent is given during registration in the Pricer24 information and telecommunications system by marking the consent to the processing of their Personal Data or at the stage of signing a cooperation contract, where this information is indicated in a separate clause.
5.1.6. Public interest – in some cases, the Processing of personal data of Data Subjects may be carried out on the basis of general public interest. In most cases, these may be exceptional cases when the processing of Personal Data must be carried out in connection with unforeseen threats to the public or a specific Data Subject, for example, in connection with the spread of COVID-19.
6. Categories of Personal Data and their types
6.1. The scope and categories of Personal Data to be processed depend on the purpose of processing, which may differ in different situations, the specifics of Pricer24’s activities, the needs of management and economic activity, and the qualification requirements for the professions (positions) of employees. Personal data includes any information or set of information about a natural person by which he or she is identified or can be specifically identified. Pricer24 mainly processes the following categories and types of Personal Data:
6.1.1. identification data, for example, personal identification code (registration number of the taxpayer’s registration card), date and place of birth, data of documents certifying identity, including photo, surname, first name, patronymic, passport data;
6.1.2. contact information, for example, information about the place of registration and actual residence, phone number, personal e-mail address;
6.1.3. data about the use of the System, for example, data about accesses and user names and passwords fixed in the System, purchased goods, actions performed in the System environment, the nature of use;
6.1.4. financial data, for example, payment information related to Pricer24 services sold/purchased;
6.1.5. account details, for example, bank account number;
6.1.6. data on reliability and research, for example, data on the payment discipline of counterparties, data that allows Pricer24 to conduct customer research related to the prevention of money laundering and terrorist financing and to verify compliance with international sanctions, including the purpose of cooperation and affiliation of the business partner, his representative, real beneficiary to politically significant persons;
6.1.7. data received and/or created during the performance of duties provided for by regulations, for example, data that Pricer24 is obliged to provide to such government authorities as tax authorities, courts, law enforcement agencies, etc.;
6.1.8. communication data and device data, such as data contained in messages, emails, videos, photos and/or audio recordings, as well as other types of information exchange and interaction data collected during communication with the Subject (including including using permission granted by Pricer24) and organizing events or communications with the Data Subject, as well as data related to the Pricer24 website (including visits to the Systems);
6.1.9. professional data, in particular, data on education or professional activity, containing a work book, diploma on education; information on the availability of special knowledge or training (if necessary, depending on the qualification requirements for the position); information about the availability of a qualification category (rank, class, etc.);
6.1.10. personal data of a special category, for example, data on the suitability of a candidate for a vacant position; information about business and personal qualities, indicated in the resume submitted at the time of employment (in particular, regarding character traits, personal hobbies, habits); information about the state of health (processed to the extent necessary for the implementation of labor relations and to ensure the requirements of legislation in the field of labor protection).
6.2. Pricer24 does not process Personal Data on racial, ethnic and national origin, political, religious or worldview beliefs, membership in political parties and/or organizations, trade unions, religious organizations or public organizations of a worldview orientation, criminal convictions, as well as data , relating to health, sexual life, biometric or genetic data. Pricer24 is not deprived of the right to process such Personal data, if such processing is carried out on the condition that the Data Subject provides unequivocal consent to the processing of such data and in other cases provided for by law.
7. Personal data protection measures
7.1. To protect the Personal Data of the Data Subject, Pricer24 uses various technical and organizational security measures to protect the Personal Data from unauthorized disclosure, access, accidental loss, unlawful processing, erasure, unlawful destruction (for example, data encryption, anti-hacking equipment, security passwords, etc.).
7.2. Pricer24 takes measures to ensure the protection of Personal Data at all stages of its processing. Pricer24 independently determines the list and composition of measures aimed at the security of Personal Data processing.
7.3. Personal data is available to a limited number of Pricer24 employees and contractors – involved Persons who process personal data who need it for the performance of relevant official functions/tasks and who have mandatory confidentiality requirements.
7.3.1. Each of these persons has access to only those Personal Data (parts thereof) of the Data Subject that are necessary for them in connection with the performance of their professional or official or labor duties.
7.3.2. All other Pricer24 employees are entitled to full information only regarding their own Personal Data.
7.3.3. In the event of the dismissal of a Pricer24 employee who had access to Personal Data, or his transfer to another position that does not involve working with the Personal Data of the Data Subject, measures are taken to prevent such a person from accessing Personal Data, and documents and other media that contain Personal Data of the Data Subject, are transferred to another Pricer24 employee. The date of deprivation of the right to access and process Personal Data is the date of dismissal of the Pricer24 employee or the date of transfer to a position, the performance of duties of which is not related to the processing of Personal Data.
7.4. Pricer24 employees who process Personal Data are obliged to:
7.4.1. Use Personal Data only in accordance with professional or official or labor duties, prevent the loss of Personal Data or their improper use.
7.4.2. Not to allow the disclosure in any way of Personal data entrusted to them or which became known in connection with the performance of professional or official or labor duties, except for cases provided by law. At the same time, such an obligation is effective after they terminate their employment related to Personal Data, except for cases established at the legislative level.
8. Transfer/disclosure/distribution of Personal Data
8.1. Pricer24, as the Data Owner, may transfer Personal Data to persons to whom Pricer24 has the right to disclose them (for example, Personal Data Processors, legal service providers, etc.) or has obligations in accordance with regulatory acts or concluded agreements, subject to obtaining the consent of the Sub data object. Dissemination of Personal Data without the consent of the Data Subject or a person authorized by him is allowed in cases defined by law and only (if necessary) in the interests of national security, economic well-being and human rights.
8.2. Pricer24 may transfer Personal Data primarily to the following recipients:
8.2.1. PRICER24 SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (Poland), including all their representative offices and branches in any country of the world to their authorized persons and beneficial owners, if the relevant processes are related to the processing of the Personal Data of the Data Subject or in other cases where this is permitted by regulatory and legal acts;
8.2.2. institutions and officials, including, but not limited to, supervisory, tax and law enforcement authorities, persons who carry out enforcement of decisions, notaries, judicial authorities, institutions for out-of-court dispute resolution;
8.2.3. credit and financial institutions, insurance service providers, third parties involved in operations, calculations and reporting;
8.2.4. financial and legal consultants, auditors;
8.2.5. providers of information systems and databases;
8.2.6. debt collection service providers, assignees, bankruptcy managers;
8.2.7. other persons and suppliers related to the provision of Pricer24 services in the form of IT, telecommunications, archiving, postal service providers, etc.
8.3. Pricer24 does not transfer Personal Data to countries outside the European Union and the European Economic Area on a regular or systematic basis, but Personal Data may be processed by Personal Data Processors located in such countries (for example, developers of technical solutions or service providers). At the same time, during the transfer of Personal Data, Pricer24 provides procedures provided for by regulatory acts to ensure the level of processing and protection of Personal Data.
9. Storage/deletion/destruction of Personal Data
9.1. Pricer24’s storage of the Data Subject’s Personal Data involves actions to ensure their integrity and the appropriate mode of access to them.
9.2. Personal data of the Data Subject are stored for the period established by the regulatory acts or determined by the consent of the Data Subject to the processing of Personal Data.
9.3. Pricer24 does not retain Personal Data for a longer period than is necessary for the relevant purpose of processing the Personal Data or for a longer period than is specified in the regulatory acts.
9.4. The period of storage of Personal Data depends on the purpose for which the Personal Data was obtained and on whether such a period of storage is provided for in the regulatory legal acts.
9.5. Pricer24 determines the term of processing of Personal Data, taking into account, among other things, the date of termination of the business relationship, the withdrawal of the Data Subject’s consent to the processing of Personal Data and the statutory period during which Pricer24 or the Data Subject can exercise their legitimate interests (e.g. file an objection and complaints or file a lawsuit).
9.6. Pricer24 deletes/destroys Personal Data in the manner and in the cases defined by the current legislation. Personal data is destroyed in a way that excludes the further possibility of renewing such Personal data.
10. Profiling and automated decision making
10.1. Pricer24 does not perform profiling and automated decision-making on the Data Subject.
11. Cookies
11.1. Pricer24 uses cookies on its website.
12. Rights of the Data Subject
12.1. In accordance with the regulations in the field of personal data protection, the Data Subject has the following rights regarding the processing of his/her Personal Data:
12.1.1. receive confirmation of Pricer24 processing of the Personal Data of the Data Subject, as well as, in case of processing, to have access to them and receive the content of such Personal Data;
12.1.2. request correction (change) of the Personal Data of the Data Subject if they are inappropriate, incomplete, unreliable or incorrect (the Data Subject has no right to request correction or addition of video recordings, as this will be considered as falsification or distortion of information);
12.1.3. make a reasoned demand for the removal (destruction) of Personal Data by Pricer24 or the Persons who process personal data, if the Personal Data is processed illegally or is unreliable;
12.1.4. limit the processing of Personal Data of the Data Subject;
12.1.5. to object to the processing of the Personal Data of the Data Subject, if the processing takes place on the basis of legitimate interests PRICER24 SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ (Poland), including all their representative offices and branches in any country in the world;
12.1.6. receive the Personal Data provided by the Pricer24 Data Subject and processed on the basis of consent or performance of a contract in a structured form in one of the most commonly used electronic formats and, if possible, transfer such Personal Data to another service provider (data portability rights);
12.1.7. withdraw the Data Subject’s consent to the processing of Personal Data;
12.1.8. to know about the sources of collection, the location of your Personal data, to give the appropriate instructions for obtaining this information to authorized persons;
12.1.9. receive information about the conditions for providing access to Personal Data, in particular information about third parties to whom the Personal Data of the Data Subject is transferred;
12.1.10. apply legal remedies in case of violation of the legislation on the protection of personal data;
12.1.11. other rights defined by normative legal acts.
12.2. The Data Subject’s rights specified in Clause 12.1 of the Privacy Policy are exercised if the processing of Personal Data does not result from Pricer24’s obligations imposed on it by regulatory and legal acts.
12.3. In order to prevent unjustified disclosure of the Data Subject’s Personal Data to third parties, Pricer24 implements the Data Subject’s rights based on a written statement, having previously identified the Data Subject.
12.4. You can apply in one of the following ways (Pricer24’s contact information is available on its website):
12.4.1. by sending to Pricer24’s e-mail address;
12.4.2. by sending a written statement to the legal address of Pricer24, indicating the postal address to which a reply must be sent. The answer to such a statement will be provided only by registered letter to the specified postal address.
12.5. The response to the Data Subject’s request will be prepared no later than one month after receiving the request. If necessary for objective reasons, this term can be extended for another two months.
12.6. In some cases provided by regulations, Pricer24 is not entitled to provide the Data Subject with information about the processing of Personal Data.
12.7. Pricer24 has the right to refuse to comply with the requirements specified in the Data Subject’s application if the Data Subject unreasonably refuses to provide his or her identification information.
12.8. Pricer24 reserves the right not to release Personal Data, including Personal Data obtained during video surveillance, in cases where such release:
12.8.1. affects other Data Subjects, and there are no technical possibilities to release Personal Data without violating the rights of other Data Subjects;
12.8.2. because of their size or complexity, they require excessive time, personnel or financial resources.
12.9. The Data Subject may file a complaint regarding Pricer24’s processing of Personal Data to the General Data Protection Regulation (Regulation (EU) 2016/679) (‘GDPR’) and the Act of 10 May 2018 on the Protection of Personal Data.
13. Contact Information
13.1. In case of doubt or obtaining additional information regarding the processing of Pricer24 Personal Data, the Data Subject has the right to contact Pricer24 by sending an e-mail to:hello@pricer24.com.
14. Availability and changes to the Privacy Policy
14.1. Any provision of this Privacy Policy that is held to be illegal or unenforceable under law will not invalidate any other provision of this Privacy Policy.
14.2. Pricer24 has the right to unilaterally make changes and additions to the Privacy Policy at any time. This may include, but is not limited to, changes in legislation, or if Pricer24 changes its business profile or business practices.
14.3. The Privacy Policy, as amended, is available on the Pricer24 website: https://www.pricer24.com.
14.4. Pricer24 encourages Data Subjects to review the Privacy Policy from time to time.