PRIVACY POLICY

This privacy policy (the "Policy") sets out the rules for the processing of personal data by the Controller in connection with the operation of the website available at sprawdz-kierowce.pl (the "Service").

Capitalized terms not otherwise defined in this Policy have the meanings assigned to them in the Service's terms of use.

Who is the controller of your personal data?

1. The controller of Users' personal data is Bartosz Pawłowski, conducting business activity under the name "Grizzly Software Bartosz Pawłowski" with its registered office in Skierniewice (96-100), ul. Armii Krajowej 57/25 ("Grizzly Software", the "Controller" or "we").
2. In addition, Grizzly Software acts as a processor of personal data of its clients' employees, which it processes on behalf of its clients in order to provide them with the Credentials Verification Service.

What are the purposes and legal grounds for processing your data?

1. We process your personal data:
   • for the purpose of entering into and performing the Agreement - where you are a party to the Agreement, the legal basis for the processing of personal data is art. 6 ust. 1 lit. b) RODO (GDPR), and in other cases art. 6 ust. 1 lit. f) RODO, i.e. our legitimate interest in ensuring the proper conclusion and performance of the Agreement,
   • for the purpose of fulfilling the Controller's accounting and tax obligations, where the processing of your data for this purpose is necessary, e.g. you use paid Services and your data appears on an invoice; on the legal basis of art. 6 ust. 1 lit. c) RODO in conjunction with the provisions of the ustawa z dnia 29 września 1994 r. o rachunkowości (Polish Accounting Act of 29 September 1994) and applicable tax law;
   • in connection with contact, including for the purpose of responding to any inquiries or requests submitted to us and conducting further correspondence with you on the matter; on the legal basis of art. 6 ust. 1 lit. f) RODO;
   • for the purpose of handling complaints regarding the use of the Service or the Services; on the legal basis of art. 6 ust. 1 lit. b), c) and f) RODO;
   • where it is necessary to establish, pursue or defend claims, on the legal basis of art. 6 ust. 1 lit. f) RODO, i.e. as part of our legitimate interest in ensuring the ability to achieve these purposes.

Is providing personal data mandatory?

Providing personal data by our clients - natural persons conducting business activity - is a condition for entering into the Agreement covering the creation and maintenance of an Account and the provision of the Credentials Verification Service. Providing personal data by other persons, e.g. representatives or attorneys of a client that is a legal entity, is voluntary; however, failure to provide personal data in the registration form available in the Service will make it impossible to enter into the Agreement and to provide the Services to the client.

What data do we process and where did we obtain it?

1. We process the personal data of our clients to the following extent: first and last name, company name, registered company address, tax identification number (NIP).
2. The personal data we process as Controller is obtained directly from Users, including via the registration form available in the Service. If you did not provide your data to us directly, it was made available to us by our client, who is a party to the Agreement, in connection with entering into or performing that Agreement, or it was obtained from publicly available sources.
3. The personal data of our clients' employees who use the Credentials Verification Service is obtained from clients who enter it into the Service themselves using the available functionality.

How long will we process your personal data?

1. We process personal data for the term of the Agreement and, after its expiry, for the period resulting from applicable laws.
2. Personal data contained in accounting documents, including invoices, will be retained for the period prescribed by the ustawa z dnia 29 września 1994 r. o rachunkowości, i.e. for at least 5 years.
3. In cases justified by claims, we will process personal data for an additional period after the termination of the Agreement, but no longer than until the limitation period for claims expires.

How do we protect your personal data?

1. Protecting your personal data is our priority and we make every effort to ensure that it is processed securely.
2. Only authorized persons may access your data, and only to the extent necessary in connection with their assigned duties. We make sure that all operations on personal data are logged and performed only by authorized employees and associates.
3. We will take all necessary steps to ensure that subcontractors and other service providers we work with also guarantee the implementation of appropriate technical and organizational measures so that the processing of personal data by such entities meets the requirements of RODO whenever they process personal data on our behalf.
4. We do not transfer your data outside the European Economic Area. Your personal data is stored locally, on our server.

To whom may we disclose your personal data?

1. We may disclose your personal data to technical service providers we use in connection with operating the Service, as well as to entities providing us with legal services and accounting services.
2. We do not transfer, sell or lend personal data to other entities, persons or institutions, unless this is done with your explicit consent or at your request, or at the demand of authorized state authorities for the purposes of proceedings they conduct.
3. The personal data of employees referred to in ust. 7 will only be transferred to services offered by Ministerstwo Cyfryzacji (Ministry of Digital Affairs) for the purpose of obtaining information about the validity of driving entitlements.

What rights do you have in connection with the processing of your data?

1. You have the right to request access to your personal data, its rectification, erasure or restriction of processing, as well as to object to the processing of data and to request its portability.
2. Your request regarding our processing of your personal data should, as far as possible, precisely indicate what the request concerns, i.e. which of the rights listed in ust. 18 above you wish to exercise, and which processing operation or which processing purposes your request relates to.
3. We will send a response to your request to the e-mail address from which you sent the request, within 1 month of its receipt. In justified cases, due to the complex nature of the request or the number of requests, this period may be extended by a further two months.
4. A response to a request that was delivered to our registered office address will be sent to your postal address, unless the content of the request indicates a wish to receive a response electronically and you provide your e-mail address in the request.
5. Where you are an employee of our client whose data we process in connection with providing the Credentials Verification Service to that client, you should direct your requests regarding our processing of your personal data directly to your employer, who is the controller of your personal data processed for this purpose.
6. If you believe that we are processing your personal data in violation of applicable laws, you have the right to lodge a complaint with the supervisory authority.

How can you contact us?

For all matters concerning the processing of your personal data, including to exercise your rights, you can contact us at Grizzly Software, ul. Armii Krajowej 57/25, 96-100 Skierniewice or by sending an e-mail to: [email protected] or [email protected].