Protection of personal data – Privacy policy
This document describes how companies Pro Relocation s.r.o., with its registered address at Mliekárenská 7, 821 09 Bratislava, Slovak republic, company ID: 35 882 824, registered with Commercial register of te District court Bratislava I, section Sro, insert no. 31420/B (hereinafter as „Pro Relo Slovakia“) and Pro Relocation Sp. z o.o., with registered address at ul. Złota 3/10, 00-019 Warsaw, Poland, company IDs NIP: 521-30-92-939, REGON: 016218732, registered with the Polish Court Register (KRS )0000118701 (hereinafter as „Pro Relo Poland“) as a joint controllers (hereinafter as the “Controllers”, “ProRelocation” or “we”) process and protect personal data of the visitors (data subjects) visiting the webpage of the www.prorelo.com (hereinafter as “our web” or “ProRelocation web”).
Information regarding the processing of personal data in connection with the provision of ProRelocation services and other business activities, when the Controller acts independently as an individual controllers, will be in a respective situations provided to you by the Controllers in a required form.
In both countries we have implemented same program in both entities regarding data protection. Via this document we would like to inform you about how we handle the data and information you share with us by the means of our web and provide you with the essential parts of the agreement of the joint controllers, which have been concluded by the Controller according to the Art. 26 of the Regulation.
When processing your personal data via means of ProRelocation web, the Controllers of your personal data are both ProRelocation entities. Your personal data are always processed in accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council 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 (General Data Protection Regulation) (hereinafter as “Regulation“), respective national (Slovak and Polish) data protection legislation and other legislation in relation to personal data protection (hereinafter as “Personal data protection legislation“).
The Controllers have designated mutual responsibilities for fulfilling their obligations under the Regulation in an agreement of joint controllers concluded pursuant to Article 26 of the Regulation under which:
· the tasks of the contact point for data subjects in connection with the processing of personal data on our web are performed by Pro Relo Slovakia, by e-mail address dpo@prorelo.com or in writing at the address of its registered seat (however, in connection with the request you address Pro Relo Poland, you can contact directly Pro Relo Poland, via e-mail address dpo-pl@prorelo.com),
· the obligations to provide the information referred to in Articles 13 and 14 of the Regulation to data subjects shall be fulfilled by both Controllers through its publication on our web via this policy and at other appropriate locations,
· the obligations and tasks related to the exercise of the rights of data subjects are fulfilled by both Controllers in accordance with the procedure laid down below in this privacy policy, while the Joint Controllers shall provide all necessary assistance in the handling of the rights of data subjects.
Notwithstanding the above specified agreement, you may contact any of the Controllers at the following addresses in matters relating to the processing of your personal data on our web: Pro Relocation s.r.o., Mliekárenská 7, 821 09 Bratislava, Slovak republic, e-mail: dpo@prorelo.com or Pro Relocation Sp. z o.o., ul. Złota 3/10, 00-019 Warsaw, Poland, e-mail: dpo@prorelo.com.
In this document you will learn:
Why we collect and process personal data
What information/data we collect
Who are we sharing your information/data with?
How are we protecting your data?
Your rights, access to your data, right for deletion and to complain
Why we collect and process your personal data
Personal data that we obtain from you as a visitor of our web are only utilized in a manner that is appropriate to the purpose for which they were obtained. We only maintain these data for period necessary (in connection with the specified purposes of processing) and for which processing there is a relevant legal bases.
When processing your personal data via the means or our web, we process them for the following purposes:
Providing a reply to and handling of queries/requests delivered to us via messages delivered via the contact form on the website. Legal bases for this purpose is Art. 6 (1) f. of the Regulation – processing is necessary for the purposes of legitimate interest pursued by the Controllers, in particular interest in responding to the received messages for proper conduct of business communication, improvement of the quality of provided services and acquisition of a new clients for both entities. For this purpose of processing, your personal data are processed until your query or request is handled by the Controller (up to 3 months).
Direct marketing – newsletter (sending information about the Controller’s activities and its current offer. Legal bases for this purpose is Art. 6 (1) a. of the Regulation – processing is based on the consent granted by the data subject. For this purpose of processing, your personal data are processed 3 years from the date of the consent or until its revocation, whichever occurs first.
Carrying out the measurement of the website traffic on our web and ways how our web is used by the visitors (via analytical cookies provided by the third party). Legal bases for this purpose is Art. 6 (1) a. of the Regulation – processing is based on the consent granted by the data subject. For this purpose of processing, your personal data are processed depending on the type of cookie set into your devices (up to 2 years), according to the information you can find below, or until you withdraw your consent (change you cookies settings on our web, whichever occurs first).
What information/data we collect
The controller collect personal data always in accordance with the principle of minimisation. For the purpose of handling your queries or requests, we process your name, surname, phone number, e-mail address, a name of a company, on which behalf you act, country, in which you are interested to be provided with our services in and other data you provide us with in your query or message. For the purpose of direct marketing – newsletter, we process your e-mail address. For the purpose of measuring website traffic on our website, we collect information on the type of device or internet browser you use, time of your visit, subpages you visited on our website and in specific case also the IP address of the device you use.
Who are we sharing your information/data with and are they transferred to third countries?
In certain cases, the Controllers may be obliged to provide your personal data to public authorities that are authorized to process your personal data, e.g. to courts or law enforcement authorities (under respective legislation) and in some cases also to the competent supervisory authorities, in particular the competent data protection authorities with the Slovak Republic and Poland.
The Controllers also provide your personal data to their processors, i. e. external entities that process your personal data on behalf of the Controllers. Processors process personal data on the basis of a contract concluded with the Controllers in which they have undertaken to take appropriate technical and security measures for the purpose of the secure processing of your personal data. The controller’s processors regarding the processing of your personal data via our web include: a company providing hosting services and services connected to the adjustments of our web.
Among the recipients of your personal data may also be a company Google, LLC, which is a parent company of its European affiliate providing website analytical services, if you give the Operator permission to store cookies on your device when you visit the website. In this case, your personal data may be transferred to the United States, in accordance with the terms of use of the above stated services of Google, LLC and applicable US laws. The transfer of your personal data is secured by the usage of standard contractual clauses which are part of the above state terms of use of this service.
The Controller does not process your personal data by profiling or any form of automated individual decision-making, by which evaluation of your personal aspects would take place in the normal course of our business or when providing above stated services to you.
How are we protecting your data?
We make sure to keep the data safe. We have taken technical and organizational measures to ensure data security and adopted information and privacy security management system in both of our companies. The objective is to ensure protection and eliminate situation where data could be lost, or avoid situation of unlawful processing, access, transfer, copying or changes of your data. Data that you share with us, or vice versa we will share with you or third parties will be protected both when used electronically (password secured, encrypted, access limited) or physically (sealed document files, lockable containers, access only to authorized personnel).
We would like to confirm that access to the data is only provided to the authorized personnel (I .e. employees and suppliers) whose access is essential to secure the course of our business activities. That means, for example, that the queries address to the Pro Relo Slovakia will be delivered only to our Slovak entity and vice versa. The Controllers have also committed to follow the above specified security rules in their joint controllers agreement concluded according to the Art. 26 of the Regulation.
What are your rights in relation to personal data processing?
As the data subject, your rights regarding the processing of your personal data are as follows:
Right of access – You have the right to obtain a copy of the personal data which we hold about you, as well as the information on how we use your personal data. In most cases, your personal data will be provided to you by electronic means of communication, unless otherwise requested by you;
Right to rectification – We take reasonable measures in order to ensure that the data which we hold about you are accurate, complete and up-to-date. In case the personal data we hold are inaccurate, incomplete or outdated, we will modify, update or complete such personal data on basis of your request;
Right to erasure – under certain circumstances, you have the right to ask us to erase your personal data, for example, if the personal data we have obtained about you, are no longer necessary to fulfil the original purpose of processing or if you withdraw your consent to the personal data processing. We assess exercising your right to erasure (right to be forgotten) on the basis of individual circumstances of each particular case of processing;
Right to restriction of processing – You have also the right to ask us not to process your personal data. If you believe that the personal data we process about you are not accurate, that the processing is unlawful and you request the restriction of their processing, that we no longer need your personal data, but they are required by you as the Data subject for the exercise of legal claims or if you believe that we as the controller are not entitled to further process your personal data, we will not further process your personal data on the basis of your request;
Right to data portability – Under certain circumstances, you have right to transmit the personal data to another subject according to your choice. However, the right to portability applies only to personal data that we process under the contract to which you are one of the parties or on the basis of the consent which you have granted us;
Right to lodge a complaint or request – If you believe that we breach personal data protection legislation when processing your personal data or that we have not handled your request in accordance with such legislation, you can lodge a complaint with the respective supervisory authority which is in Slovak Republic – Úrad na ochranu osobných údajov Slovenskej republiky, Hraničná 12, 820 07 Bratislava 27; Slovak Republic, phone no. +421 2 3231 3214; e-mail: dozor@pdp.gov.sk and in Republic of Poland – Urzad Ochrony Danych Osobowych, Stawki 2, 00-193 Warsaw, Poland, phone no. +48 22 531 03 00, Fax +48 22 531 03 01, e-mail: kancelaria@uodo.gov.pl.
RIGHT TO WITHDRAW CONSENT – If we process your personal data on the basis of your consent, you have the right to withdraw such consent for further processing of your personal data. You may withdraw your consent at any time in writing, by e-mail or orally (in person).
RIGHT TO OBJECT – if we process your personal data based on our legitimate interest, you have the right to object to processing of your personal data, If you object to such personal data processing, we will not further process your personal data unless we demonstrate compelling legitimate grounds for such processing.
You may exercise your rights stated in the previous point of this Privacy policy via contact addresses stated in the beginning of this privacy policy. We will provide you with a response to a request regarding exercise of your rights within one month from the day of exercise of your rights. In certain cases, we are entitled to prolong the period for providing the response, i. e. in case of high number and complexity of the requests submitted by the data subjects, maximum by 2 months. We will always inform you in advance about prolongation of the period. Response to a request regarding exercise of your rights will be provided to you free-of-charge. In case of repeated, unreasonable or disproportionate request to exercise your rights, we are entitled to charge a reasonable fee for providing the information.
Validity of data protection rules
This updated privacy policy is valid and effective as of 21.8.2024. As it is possible that an update of the information on personal data processing contained in this Privacy policy may be necessary in the future, the Controller is entitled to update this Privacy policy at any time. In such case, the Controller will inform you about it in an adequate manner in advance.