Privacy Policy

This privacy policy is meant to describe how we process personal data, collected in connection with the use of our website available under the address: https://www.directpl.com/ ("Website") as well 

 

Personal data controller

The owner of the Website and the controller of the user’s personal data is Direct Communication sp. z o.o. with its registered office at ul. Sienna 39, 00-121 Warszawa, Poland, entered into the register of entrepreneurs kept by the National Court Register under the KRS number: 0000035843 (“Directpl”, “weorour”).

 

Categories of personal data 

While using the Website, you may be asked to provide some of their personal data, in particular by:

  1. subscribing to our newsletter: e-mail address (required);

  2. filling the general contact form: first name (optional), last name (optional), e-mail address (required);

  3. applying for the open job positions using the application form; 

  4. filing the contact form for candidates.

In the event that you are applying for the open job positions using the application form or filing the contact form for candidates in connection with current or future recruitment processes, please read carefully the privacy notice for the candidates which describes in detail how we process personal data of natural persons who would like to apply for a job position in Directpl and their rights associated therewith. 

We may also collect other personal data voluntarily provided by you when you contact us directly, including via e-mail.

In any case, remember to limit the personal data provided to a minimum. We reserve the right to delete personal data other than necessary to achieve the purpose of data processing.

Providing data is voluntary, but necessary to provide you with our newsletter and properly handle your inquiry, respectively.

We may use cookies or similar technologies that collect certain Website usage information when you access, view, and use the Website. To learn more about this subject, please go to the cookies section of this Privacy Policy.

 

Purpose and basis for the processing of personal data

Directpl processes personal data for the following purposes:

Purpose of the processing

The basis for the processing

sending you our newsletter

your consent (Article 6(1)(a) of the GDPR)

handling your inquiries and communicating with you in this regard, including preparation of the offer for our services

our legitimate interest (Article 6(1)(f) of the GDPR)

direct marketing of our services in connection with your inquiries

our legitimate interest (Article 6(1)(f) of the GDPR)

 

Period of personal data storage

The period of processing and storage of your personal data depends on the legal basis of the processing. 

If the basis for data processing is your consent your personal data will be processed until your consent is withdrawn. 

If the basis for data processing is our legitimate interest your personal data will be processed until you effectively object to the processing of your personal data.

The storage period can be extended by a limitation period in each case if the processing of your personal data is necessary to establish or exercise or defend of legal claims.

 

Recipients of personal data

Depending on a given case, your personal data me be disclosed with the following categories of recipients:

  1. Third-party service providers and advisors (including legal, financial and technical advisors, accountants, auditors, and IT support). We may share your personal data to the necessary extent with our service providers and advisors to obtain their advice or assistance or who perform business operations for us or render different services to us, for example by hosting it, enabling certain features or functionality of the Website, or by providing ancillary services such as data analytics, data storage, support, and maintenance or security technology. We require all our third-party service providers and advisors to respect the security of your personal data and to process it in accordance with the law. We do not allow our third-party service providers and advisors to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.  We enter with third-parties in relevant data processing agreements, if required by law.

  2. Entities authorized to obtain your personal data on the basis of applicable law, including law enforcement agencies, courts, regulators, government authorities. We may share your personal data with these parties where it is necessary to comply with a legal obligation.

We process your personal data within the European Economic Area. 

Your personal data may be transferred to a third country (e.g. within the IT services provided to us), if the conditions set out in the provisions of the law are fulfilled, including:

  • the country to which we transfer personal data ensures an adequate level of security in accordance with the decision of the European Commission;

  • the personal data shall be transferred to a recipient in the USA who is registered in the Privacy Shield;

  • personal data shall be transferred on the basis of standard contractual clauses adopted by the European Commission;

  • the transfer is necessary for the performance of an agreement between you and us or for the implementation of pre-contractual measures taken at your request;

  • the transfer is necessary for the establishment, exercise or defense of legal claims;

  • you have given a clear consent to the transfer of your personal data.

For more information on the transfer of personal data to third countries, including appropriate safeguards, please contact us.

 

Profiling. Automated decision making

We do not use profiling or automatic decision making in relation to your personal data.

 

Your rights

You have certain rights regarding your personal data. These include the right to:

Request access to your personal data

At any time you can find out what data we process and receive a copy of such data.

Request rectification of your personal data

You have the right to request your personal data is corrected if they are inaccurate or completed if they are incomplete. 

Request erasure of your personal data

You have the right to request that your personal data is deleted or removed if:

  1. they are no longer necessary in relation to the purposes for which they were collected or otherwise processed
  2. they have been unlawfully processed
  3. the erasure of your personal data is necessary for compliance with a legal obligation

Request restriction of our use of your personal data

You have the right to restrict the processing of your personal data if: 

  1. you contest the accuracy of your personal data, for a period enabling us to verify their accuracy
  2. the processing is unlawful and you oppose the erasure of your personal data and request the restriction of their use instead
  3. we no longer need your personal data for the purposes of the processing, but you require them for the establishment, exercise or defense of legal claims
  4. you have objected to the processing of your personal data pending the verification whether our legitimate grounds override yours

Object to the processing of your personal data 

You have the right to object to the processing of your personal data based on our legitimate interests.

We will no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms or we process your personal data for the establishment, exercise or defense of legal claims.

Where your personal data are processed for direct marketing purposes, i.e., to provide you with marketing communication from us, you have the right to object at any time to processing of your personal data for such purpose. In such a case we will no longer process your personal data for such purpose.

Data portability  (if the basis for data processing is your consent)

You have the right to receive your personal data, which you have provided to us, in a structured, commonly used, electronic format.

Moreover, you have the right to transmit those data to another controller or request to have the personal data transmitted directly from us to another controller, where technically feasible.

Withdraw your consent (if the basis for data processing is your consent)

You have the right to withdraw your consent for data processing at any time. 

The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

We will contact you if we need additional information from you in order to honor your requests. 

Please note that we may ask you to verify your identity before responding to such requests.

 

Right to lodge a complaint with the supervisory authority

If you believe that your personal data is being processed unlawfully you can lodge a complaint with a supervisory authority, in Poland: the President of the Personal Data Protection Office (Personal Data Protection Office - ul. Stawki 2, 00-193 Warsaw, Poland). 

Contact details for the supervisory authorities in the European Economic Area (EEA) are available here.

 

Cookies and similar technologies

Cookies are small pieces of data saved in files and stored on your device, which the browser sends to the server each time you connect to the Website from the given device - while you visit various websites on the Internet. More information about cookies can be found in the "Help" section of your browser.

In this Privacy Policy information on cookies also apply to other similar technologies used on the Website. For example, in order to ensure efficient use of the Website, we also use technologies other than cookies, e.g. Local Storage, which is used to store data saved when using the Website in a separate part of your browser's memory. Access to data in Local Storage can only be obtained by the given website from which the data was saved. Data in Local Storage is stored by the browser after closing it.

Within the Website, cookies are used for the following purposes:

  1. to ensure the correct functioning of the Website, including to adjust the content of the Website to your preferences and optimize the use of websites; in particular, these files allow you to recognize your device and appropriately display the Website, adapted to your individual needs;

  2. to ensure the security and reliability of the Website;

  3. to make anonymous statistics using analytical tools which help us understand how you use the Website in order to improve its structure and content;

  4. to use interactive functions in order to popularize the Website by means of social media sites.

There are two basic types of cookies used on the Website:

  1. session files - these are temporary files that are stored in your device until you close the Website or turn off the software (web browser); and

  2. permanent files - these are files stored in your device for a period of time specified in the parameters of these cookies or until they are deleted by you.

Please be informed that in addition to our own cookies, we also use third-party cookies uploaded by our partners through the Website, in particular for:

  1. statistical needs (Google Analytics [cookie controller: Google LLC with its registered office in the USA or Google Ireland Ltd with its registered office in Ireland], Facebook Pixel [cookie controller: Facebook, Inc. with its registered office in the USA or Facebook Ireland Ltd with its registered office in Ireland]), LinkedIn Insight Tag [cookie controller: LinkedIn Corporation with its registered office in the USA or LinkedIn Ireland Unlimited Company with its registered office in Ireland], Hubspot Analytics [cookies controller: Hubspot Inc. with its registered office in Cambridge, Massachusetts])

  2. use of interactive functions in order to popularize the site using social media sites Facebook.com [cookie controller: cookie controller: Facebook, Inc. with its registered office in the USA or Facebook Ireland Ltd with its registered office in Ireland], LinkedIn.com [cookie controller: LinkedIn Corporation with its registered office in the USA or LinkedIn Ireland Unlimited Company with its registered office in Ireland].

Please note that most web browsers are set to automatically accept cookies. However, you can independently and at any time change the settings for cookies by setting the conditions for their storage and access by cookies to your device. You can make changes by using browser settings. You can also delete cookies at any time by using the available functions in your web browser.

Restricting the use of cookies may affect some of the functions available on the Website. 

 

Links 

The Website may provide links to third party web sites or resources. We provide such links and references to you only as a convenience.  If you click a third party link, you will be directed to that third party's site. We strongly advise you to review the privacy policy of every site you visit.

We have no control over and assume no responsibility for the content, privacy policies or practices of any third party web sites or resources.

 

Changes to this Privacy Policy

We reserve the right to amend this Privacy Policy at any time at our sole discretion, for material reasons, including legal, security, technical or commercial reasons. 

If you continue to use the Website after the amendments to this Privacy Policy come into force, you thereby accept the new terms of this Privacy Policy.

 

Contact

All inquiries and decisions within the above-mentioned scope can be addressed to the Data Protection Officer in Directpl (Mr. Krzysztof Kunowski), in the following way:

1. via e-mail: direct@directpl.com;

or

2. in writing to the following address: Direct Communication sp. z o.o., ul. Sienna 39, 00-121 Warszawa, Poland.

DirectPL-BG-4

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