I. INTRODUCTION

The protection of personal data and information security have always been treated as a priority in the operations of EMS PARTNER. Setting an example as a responsible and aware organization, we are committed to duly informing you about matters related to the processing of personal data, especially in light of the new regulations on personal data protection, including 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 (the “GDPR”). We are aware that information has a specific value that must be appropriately protected. With your data security in mind, this document presents key information regarding the legal basis for the processing of personal data, their use, and acquisition.

1. EMS PARTNER SP. Z O.O.
   EMS PARTNER SP. Z O.O. located at Szyperska 14, Poznań 61-754, hereinafter referred to as the ‘Company’, is a team of qualified salespeople and engineers providing implementation and maintenance services for the solutions delivered. We focus on issues in the field of IT security.
2. WHEN DOES THIS PRIVACY POLICY APPLY?
   This Privacy Policy applies in all cases where EMS PARTNER SP. Z O.O. is the data controller and processes personal data. This refers to both personal data obtained directly from the data subject and cases where we have obtained personal data from other sources. EMS PARTNER SP. Z O.O. fulfills its information obligations in both of the above situations, as specified respectively in Article 13 and Article 14 of the GDPR in accordance with these regulations. EMS PARTNER SP. Z O.O. is the administrator of marketing processes (including managing accounts on social media platforms), IT processes (including information systems where personal data is stored, e.g., of contractors), security incidents, and also coordinates the recruitment processes of employees. The company also operates the website www.emspartner.pl, and therefore coordinates the processing of personal data transmitted through forms on the website (e.g., via a contact form).
3. SCOPE, METHODS AND PURPOSES OF DATA PROCESSING
   We want all information regarding the methods and legal bases of personal data processing, as well as the purposes for which we process them, to be clear. We encourage you to familiarize yourself with the list of personal data processing operations presented below.

II. PROCESSING OF PERSONAL DATA OF INDIVIDUALS VISITING WEBSITES OPERATED BY EMS PARTNER SP. Z O.O. OR USING SERVICES PROVIDED ELECTRONICALLY

1. General Information

Every individual using our services electronically or visiting our website has control over the personal data they provide to us. We hereby inform you that the data we collect about users in this way is limited to the essential minimum necessary to provide services at the expected level.

2. Cookies

In a limited scope, we may collect personal data automatically through cookies present on our websites. Cookies are small computer data files that are saved and stored on a computer, tablet, or smartphone used to access websites. Cookies typically contain the name of the website they come from, the duration of their storage on the device, and a unique number.

On the website, visitors will be presented with information about cookies in accordance with legal regulations until the visitor accepts/closes this information. Data on the acceptance of this information will be stored in cookies on the visitor’s computer.

Our website and the services offered by it use cookies for the following purposes:

• for statistical purposes,
• for site and service configuration (allowing us to place features and services on the website),
• for authentication – they can inform users (including you) that they are logged in, enabling the site to display relevant information and features,
• for analyzing and researching your (as a user of the portal) behaviors – this allows us to read preferences related to the services we provide, thereby analyzing, improving, and developing the offered products and services,
• for advertising purposes – thanks to cookies, we are able to deliver more interesting and personalized ads to you, which after visiting our site may appear in remarketing campaigns within: Facebook ADS, LinkedIn ADS, Google ADS.

The collected information includes the IP address, type of browser used, language, type of operating system, internet service provider, information about the time and date of the location, and information sent to the site via the contact form.

The data we collect is monitored by us. For this purpose, we use tools related to profiling contacts using the Marketing Automation system. To analyze the usage of our site, we use Google Analytics tools, which record your activity on the site.

In the service, two types of cookies are used: ‘session’ cookies and ‘persistent’ cookies. ‘Session’ cookies are temporary files that are stored on the User’s end device until logging out, leaving the website, or turning off the software (web browser). ‘Persistent’ cookies are stored on the User’s end device for the time specified in the parameters of the cookies or until they are deleted by the User.

Within the service, the following types of cookies are used:

1. “necessary” cookies, enabling the use of services available within the service;
2. cookies used to ensure security;
3. “performance” cookies, allowing the collection of information about the use of websites;
4. “functional” cookies, enabling the “remembering” of settings chosen by the User and personalization of the User’s interface.

In many cases, software used for browsing websites (web browser) by default allows the storage of cookies on the User’s end device. Users of the Service can change the settings for cookies at any time. These settings can be changed in particular to block the automatic handling of cookies in the web browser settings or to inform about their placement on the Service User’s device each time. Detailed information about the possibilities and ways of handling cookies is available in the software settings (web browser). Deleting or blocking cookies is always possible. The service user can do this personally in the appropriate settings of their browser.

We inform you that restrictions on the use of cookies may affect some of the functionalities available on the website pages of the service.

Cookies placed in the end device of the Service User may also be used by advertisers and partners cooperating with us.

3. Notifications and online forms

Visitors to the EMS PARTNER SP. Z O.O. website have the opportunity to contact the company by filling out a contact form. When using these forms, it is necessary for you to provide us with your personal data. These data are processed only within the scope and for the purpose for which they were provided and with your explicit consent. Consent in the context of contact forms is expressed through your deliberate action (so-called implied consent), namely by sending the form and providing personal data.

4. Use of Social Plugins

On the website www.emspartner.pl, we use so-called Social Plugins (“Plugins”) of the social networks Facebook and LinkedIn, as well as Google. If a user interacts with a plugin, cookies will be used to identify the user and initiate the request.

Upon activation of the plugin, the user’s personal data is transferred to the respective plugin provider and stored on their servers. Since the plugin provider primarily collects this data through cookies, we recommend deleting all of them using the security settings option in your browser.

EMS PARTNER SP. Z O.O. has no influence over the data collected and data processing procedures, nor does it have knowledge about the full extent of their collection, the purpose of their processing, or the duration of their storage. We also do not have information about the deletion of the data collected by the plugin providers. Thanks to the plugin mechanism, users have the opportunity to integrate with social networks and other users, which allows us to improve our offer and make it more in line with user preferences.

The legal basis for using plugins is specified in Article 6(1)(f) of the GDPR.

Further information regarding the purpose and scope of data collection and its processing by Facebook, LinkedIn, or Google can be found in the privacy policies of the plugin providers:

Facebook http://www.facebook.com/about/privacy/

Linkedin https://pl.linkedin.com/legal/privacy-policy/

Google https://policies.google.com/privacy?hl=pl

There, you can also find information about user rights and settings enabling privacy protection.

5. Photos

The photos and icons presented on the website are the property of EMS PARTNER SP. Z O.O. or are sourced from image and icon banks, or have been purchased from agencies as materials for the website.

III. PROCESSING PERSONAL DATA OF INDIVIDUALS CONTACTING EMS PARTNER SP. Z O.O. TO REQUEST INFORMATION ABOUT SERVICES OR SHARE FEEDBACK REGARDING SERVICES, AS WELL AS THOSE CONTACTING FOR THE PURPOSE OF ENTERING INTO AN AGREEMENT

From individual persons contacting EMS PARTNER SP. Z O.O. with the intention of obtaining information about the offer, expressing their opinions, providing feedback, or contacting with the intent of entering into an agreement, we collect the following personal data: first and last name, email address, and telephone number.

We kindly request not to provide, through our websites, information containing special categories of personal data as defined in Article 9(1) of the GDPR (information about race or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information about physical or mental health, genetic data, biometric data, information about sexual life or sexual orientation, and criminal record history). In case such information is provided for any reason, it will be considered as explicit consent for us to collect and use such information in accordance with the terms specified in this document or as indicated where such information has been disclosed.

IV. PROCESSING PERSONAL DATA OF CUSTOMERS AND POTENTIAL CUSTOMERS

EMS PARTNER SP. Z O.O. processes personal data of its customers and potential customers, which may also include the contact details of customers and potential customers (their employees). Such personal data is processed in the computer systems used by EMS PARTNER SP. Z O.O., including in the CRM system. The personal data processed for these purposes may include, among others: first and last name, employer’s name, the position of the contact person, telephone number, email address, or other official contact information.

V. PROCESSING DATA OF INDIVIDUALS VISITING THE BUSINESS PROFILE OF EMS PARTNER SP. Z O.O.

The data of users who have liked the business profile of EMS PARTNER SP. Z O.O. on Facebook at https://facebook.com/EMS-Partner-111507761277672 or on LinkedIn at https://www.linkedin.com/company/ems-partner-sp-z-o-o-/ will be processed for the purpose of administering and managing the mentioned business profiles of EMS PARTNER SP. Z O.O., communicating with users, including responding to inquiries, engaging in interactions, informing about events, interesting information, services, and products offered by the Administrator, and building a community on Facebook. Consequently, EMS PARTNER SP. Z O.O., as the Administrator of the aforementioned business profiles, may generate anonymous statistical data regarding visitors to the pages using functions provided by Facebook or LinkedIn. The legal basis for data processing is consent. Users voluntarily decide to like/follow/interact with the profile/page/group on the respective social media platform. The rules governing the business profile of EMS PARTNER SP. Z O.O. on Facebook/LinkedIn are determined by the Administrator, but the rules of using the Facebook platform are subject to Facebook company regulations (co-administrator), and in the case of LinkedIn, they are subject to LinkedIn company regulations. At any time, you can stop following or even block the Administrator’s profile created on Facebook/LinkedIn. Due to the specific nature of the platforms used by the Administrator, using the “block user” option will result in you not seeing any content created by the Administrator. In all other respects, the content available on a given social media platform is of a general nature. Withdrawing consent does not affect the legality of processing based on consent before its withdrawal.

The Administrator processes publicly available personal data, such as names, surnames, or general information, which are placed on users’ profiles and are publicly accessible. The processing of other personal data is carried out by the Facebook/LinkedIn social media platform under the terms and conditions specified in its regulations. Under no circumstances will the data of individuals who have liked the business profile of EMS PARTNER SP. Z O.O. on Facebook/LinkedIn be used for any purpose other than the one for which they were provided. Personal data may be transferred outside of Poland, the European Union, and the European Economic Area in the context of the operation of these social media platforms.

– demographic data (including trends in age, gender, marital status, and professional status),

– information about lifestyle and interests,

– geographic data that enables determining where to conduct special promotions or organize events and how to best target your informational offerings.

Additional information regarding email correspondence

If you wish to send us an email message, please note that unencrypted email messages transmitted over the Internet are not sufficiently protected against unauthorized access by third parties.

VI. PROCESSING DATA OF JOB APPLICANTS

The data of job applicants is collected for the purpose of ongoing recruitment and taking action before concluding an employment contract. The company may also process data if the job candidate has given consent for their processing, including for future recruitment purposes.

The data of job candidates will be processed by us during the recruitment process and for a maximum of three years after its completion, i.e., until it is possible to make any claims.

In the case where processing is based on consent for participation in future recruitment processes, personal data will be processed until such consent is withdrawn.

VII. LEGAL BASIS FOR PROCESSING

1. The processing of data of individuals visiting the website operated by EMS PARTNER SP. Z O.O., using services provided electronically, or posting on the business profile of EMS PARTNER SP. Z O.O. on social media platforms is based on various legal grounds for processing depending on the category of personal data we process and the purpose of processing. We process personal data of individuals visiting our websites based on the legitimate interests of the data controller (art. 6 para. 1 lit. f GDPR) or based on consent if we have requested consent from the individual whose data is involved (art. 6 para. 1 lit. a GDPR). Data of individuals who fill out online/contact forms are processed because it is necessary for the purpose of performing a contract or taking steps prior to entering into such a contract, upon the request of the data subject (art. 6 para. 1 lit. b GDPR), based on consent (art. 6 para. 1 lit. a GDPR), or based on the legitimate interests of the data controller, which include responding to the questions asked (art. 6 para. 1 lit. f GDPR). Data of individuals visiting our fan page are processed in accordance with the rules of using the Facebook portal, based on the User’s consent (art. 6 para. 1 lit. a GDPR).
2. The processing of personal data of individuals contacting EMS PARTNER SP. Z O.O. to obtain information about the offer, share feedback on services, or contact for the purpose of entering into a contract is based on the consent expressed by the user making the request to EMS PARTNER SP. Z O.O. (art. 6 para. 1 lit. a GDPR) or for the purpose of performing a contract (fulfilling the request) submitted by the respective individual (art. 6 para. 1 lit. b GDPR). The provided data may also be processed based on the legitimate interests of the data controller (art. 6 para. 1 lit. f GDPR).
3. The processing of personal data of individuals who are potential customers is based on:
   1. The legitimate interest of EMS PARTNER SP. Z O.O. as the data controller (especially in terms of creating a database, direct marketing of own products); (Article 6(1)(f) of the GDPR);
   2. Consent (including consent for email marketing or telemarketing); (Article 6(1)(a) of the GDPR).

VIII. DATA PROCESSING PERIOD

EMS PARTNER SP. Z O.O. processes personal data and retains it for a duration dependent on the legal basis that constitutes a lawful ground for processing personal data. We would like to inform you that EMS PARTNER SP. Z O.O. processes personal data based on:

1. consent, the processing period lasts until the withdrawal of consent by the person to whom the data pertains or the completion of the processing purpose;
2. the legitimate interests of the data controller, the processing period lasts until the cessation of the aforementioned interest (e.g., the statute of limitations for civil claims) or until the objection of the data subject to such processing – in situations where such objection is provided for by applicable law;
3. the applicable legal provisions, the processing periods for this purpose are determined by those legal provisions.

In the absence of specific legal or contractual requirements, the basic data retention period for records and other evidential documentation prepared during the execution of the contract is a maximum of 6 years.

IX. DATA RECIPIENTS

We transfer personal data to other entities based on legal requirements or in connection with the fulfillment of the purpose for which they were provided to us. At the same time, we declare that we only use services of verified entities, well-known in the local market, and providing guarantees of data security. Agreements under which we entrust the processing of personal data contain provisions regarding the security measures required by us, ensuring the confidentiality, integrity, and availability of the transferred data.

We may transfer personal data to trustworthy companies or other business partners who provide services on behalf of the Company, as well as to entities with whom we cooperate. Additionally, data may be shared with providers of services such as debt collection, tax, legal, and accounting services. Personal data is only transferred to these entities and other third parties when necessary to perform the services requested or authorized by the individuals whose data is in question, to protect rights, property, or safety, or when the Company is required to do so by applicable laws, court orders, or regulations of other authorities, or when the disclosure of personal data is otherwise necessary to support legal or criminal investigations or legal proceedings.

Furthermore, authorized employees of the company will have access to personal data.

X. RIGHTS RELATED TO THE PROCESSING OF PERSONAL DATA

The rights of individuals with regard to the processing of personal data include:a) The right to access the content of one’s personal data;
b) The right to rectify data;
c) The right to restrict data processing;
d) The right to request the deletion of data;
e) The right to data portability to another data controller.

The aforementioned rights can be exercised by contacting us via email at rodo@emspartner.pl or by sending a letter to the address: EMS PARTNER SP. Z O.O., ul. Szyperska 14, Poznań 61-754.

Individuals have specific rights regarding their personal data, and EMS PARTNER SP. Z O.O., as their data controller, is responsible for upholding these rights in accordance with applicable legal regulations.

We would also like to inform you that every individual has the right to object to the processing of their personal data. In the case of personal data processed for legitimate purposes, an individual has the right to object for reasons related to their particular situation. If they exercise this right, the company will cease processing the data for that purpose, unless it can demonstrate compelling legitimate grounds for the processing that override the individual’s interests, rights, and freedoms, or for the establishment, exercise, or defense of legal claims.

The right to object can be exercised by sending an email to rodo@emspartner.pl or by sending a letter to EMS PARTNER SP. Z O.O., ul. Szyperska 14, Poznań 61-754.

XI. CHANGES TO THIS PRIVACY POLICY

We commit to regularly review this Privacy Policy and make changes as necessary or desirable due to: new legal regulations, new guidelines from authorities responsible for overseeing personal data protection processes, and best practices in the field of personal data protection.