Privacy policy of ANWIS

PRIVACY POLICY OF ANWIS SP. Z O.O.

Introduction

At Anwis (hereinafter: ”Anwis” or ”we”) personal data protection is seen as a high priority. This declaration specifies the legal grounds for processing and the means of collection and use of personal data. It also presents information on rights of natural persons. We use obtained personal data for the purposes specified herein or for other purposes each time indicated at the time of their transfer to ANWIS.

Personal data mean information concerning an identified or identifiable natural person. ANWIS processes personal data for various purposes and, depending on the purpose, various means of collection, legal grounds for processing, use and disclosure and storage periods may be applied.

In the case of collection and use of personal data we wish to maintain transparency of the grounds for and means of personal data processing.

Security

For us, security of all data held by us is a matter of the utmost importance. We follow the recognized security standards and our personal data security management system is constantly developed.

We have implemented general policies, procedures and training relating to data protection, their confidentiality and security and we examine the implemented measures in terms of their suitability for the security of data held by us.

Processing operations

1. Business contacts

Collection of personal data
Anwis processes personal data of business contacts (present and potential Clients of Anwis and/or natural persons associated with them) by means of the ERP system, the B2B platform and the www.modniewoknie.pl IT system.

Collection of personal data of contacts and their introduction into the ERP System is initiated by an Anwis employee. Personal data include name and surname, name of the employer, position of the contact person, telephone number, e-mail address and other business contact information, or personal data of our “final” recipients including name, surname and address or e-mail address and contact number. It is also possible to obtain personal data of our business partners, received in an xml swap file generated by Clients’ service systems. The scope of data obtained does not exceed the above-referred data.

In the www.modniewoknie.pl IT system data are collected at the stage of registration or logging, during creation of designs and filling out contact forms: e-mail address, IP address, name, surname, assembly address and telephone number. A system user may allow the browser to download information about his/her location. This process helps us determine which of the data controller’s business Partners (the-so-called Dealer) should contact the User. If the User is logged in, he/she may edit data assigned to his/her account such as: e-mail address, name, surname and assembly address at any time.

Use of personal data
Personal data of business contacts may be disclosed to employees of Anwis and our business Partners during business operations. Personal data may be used for the following purposes:

Development of activity and services of Anwis and business Partners
Presentation of information about Anwis and the scope of our services and products offered
Disclosure of personal data to Anwis employees for the purposes of business operations and offering new products and services
Performance of orders for products and services
Identification of Clients with similar needs
Analyses of for example market trends, relationship maps and selling opportunities
Provision of personal data of the www.modniewoknie.pl system users to business Partners (dealers) of Anwis.

Legal grounds for processing
Personal data of our business contacts are processed on the basis of our legitimate interests of a data controller or consent in the case when a data subject was asked for such consent. Our legitimate interests of a data controller are connected with sale of products and services to our present and future recipients.

Storage of data
Personal data will be stored in the ERP system for a period necessary for the above-referred purposes (for example for the duration of our relations with a business contact or for a time necessary for documenting such relations, or for reasons defined by law). Personal data of the www.modniewoknie.pl system Users will be stored in professional and dedicated services like Amazon AWS S3, for a time necessary for the above-referred purposes.

2. Individual Clients

According to our policy we collect only personal data necessary for the accomplishment of specific purposes and we ask Clients for submission of personal data only if it is absolutely necessary.
Personal data of individual Clients are processed using the ERP system. Collection of personal data and their introduction into the ERP System is initiated by an Anwis employee. The data include name and surname, address of residence, or delivery address, e-mail address and telephone number.
Use of personal data
Personal data of individual Clients may be disclosed to Anwis employees and our business Partners in the course of business operations.
Personal data may be used for the following purposes:

Presentation of information about Anwis and the scope of our services and products offered
Disclosure of personal data to Anwis employees for the purposes of performing business operations and offering new products and services
Performance of orders for products and services

Legal grounds for processing
Personal data of our clients are processed on the basis of our legitimate interests of a data controller or consent in the case when a data subject was asked for such consent. Our legitimate interests of a data controller are connected with sale of products and services to our present and future recipients.

Storage of data
Personal data will be stored in the ERP system for a time necessary for the above-referred purposes (for example for duration of our relations with a client or for a time necessary for documenting these relations, or for reasons defined by law).

3. Candidates in the recruitment process

Collection of personal data
As part of our recruitment process we collect personal data of our candidates. Personal data are obtained in two manners, directly from the candidates or from third parties, i.e. recruitment agencies, depending on the requirements of the recruitment process.
The information we process includes necessary information specified in the regulations of law concerning education, professional experience and history of employment of the person applying for a job. We process information disclosed to us in CVs, cover letters or other forms necessary for the recruitment process.
We do not require our candidates to give us any information from the scope of special categories of data called "sensitive data" including information about racial or ethnic origin, political opinion, trade union membership, religion or beliefs, information about sexuality or sexual orientation, biomedical and genetic information and health status. In the case of applying for jobs where relevant regulations of law require submission of a certificate of clean criminal record, we may ask an applicant for submission of such data. We obtain this type of data only to the extent that is appropriate and compliant with the regulations of law.

Use of personal data
We use the obtained data on applicants in the following manner:

so that we can ensure an efficient procedure of recruitment for a given position
• if the applicant gives his/her consent, we may notify him/her of Anwis job offers, which we think he/she may find interesting. We can also inform the applicant on job-related events that are organized by/with the participation of Anwis.

Legal grounds for processing
Anwis collects and processes personal data according to the relevant regulations, i.e. the Labour Code, in the case of applying for an employment contract at Anwis. We can also process some of these data within our legitimate interests. If the applicant gives his/her consent to the use of data for other specific purposes, the data will be processed within the consent given.
In the case of unsuccessful recruitment data of applicants will be stored only on the basis of the consent given.

Storage of data
In the case of successful recruitment the personal data obtained in that manner are stored for the purposes of preparation of an employment contract, in line with the statutory regulations. The documents of rejected candidates are removed after six months from the completion of the recruitment process at the latest. If the applicant wishes to leave his/her documents in our candidate base for longer, his/her consent is required.

4. Suppliers (including subcontractors and natural persons associated with suppliers and subcontractors)

Collection of personal data
We collect and use personal data of our suppliers of goods and services (including subcontractors and natural persons associated with suppliers and subcontractors) in order to manage these relations, order and receive services from suppliers and provide professional services for Clients.

Use of personal data
Personal data are used for the following purposes:

purchase of goods and services:

We process personal data relating to our suppliers of goods and services and their employees to the extent necessary for business operations. For example if a supplier supplies goods to us or provides services of transport, assembly, management of equipment/facilities or other services commissioned to external entities, we process personal data of natural persons performing these services.

administering, managing and developing activities and services:

Personal data are processed for the purposes of running business, which includes:

management of our relations with suppliers;
development of trade and production activity and services (for example identification of needs of the Clients and improvement of provision of services);
maintenance and use of IT systems;
administration and management of our Internet site, servers, electronic mail, the ERP System and other systems and applications.
management of security, quality and risk:

We have security measures for protection of our own information and information of our Clients (including personal data), which includes detection of security threats, their examination and elimination. We can process personal data as part of security monitoring; for example through automatic scanning, which makes detection of malicious messages.
Supplies and services provided by our counterparties are examined in terms of quality, which may include processing of personal data. As part of procedures of selection and acceptance of suppliers we collect and store personal data.

Legal grounds for processing
In the case when data processing referred to in this section is necessary for performance of the agreement to which a data subject is a party (for example if processing is necessary for acting as a recipient or an ordering party), processing is carried out on the basis of the agreement.
In the case when data processing is necessary for fulfilment of an obligation arising from the law (for example tax regulations under which it is required to evidence or document business activity) data are processed on such legal grounds.
In the case of processing of personal data for other purposes specified above, we act on the basis of the legitimate interests of a data controller (for example purchase of goods, reception of services, provision of services, administration, management and development of activity and management of activity, security, quality or risk) or consent in the case when a data subject was asked for such consent.

Storage of data
Personal data processed by our company are stored for a time deemed necessary for the purpose they have been collected (and according to the requirements of the applicable provisions and regulations of law).
Personal data may be stored for longer if such a requirement is defined in provisions or regulations of law and to establish, exercise or defend our rights.

5. Visitors on the premises of our company

The premises and rooms of our company are protected by security measures, including the system of CCTV and building access control system. Proper signs in visible places inform us about the operation of the CCTV system.
Materials recorded thanks to the CCTV system are stored safely and access to them may be granted in exceptional situations only (for example to examine an incident). CCTV recordings are usually automatically overwritten after not more than 3 months (or sooner), unless the recording is necessary for examination of a specific event (for example theft or fire).
Persons entering the company premises are recorded at reception. Registered data include name and surname and/or company name and registration number of the vehicle. We store records of visitors for not more than a year. These records are stored safely and access to them may be granted in exceptional situations only (for example to examine an incident).
The legitimate interests of the data controller (ensuring security on the premises of Anwis) constitute the legal grounds for processing.

6. Persons visiting our Internet site

Collection of personal data
Persons visiting our Internet sites usually have personal data they disclose to us under control. We can collect personal data automatically via cookie files present on these sites to a limited extent.
We obtain the following personal data from persons visiting our Internet sites: name and surname or company name, company address and e-mail address which is also a login to our site. The visitors may also send us an e-mail via the Internet site. Such messages include the city and e-mail address and optionally: name, surname and telephone number as well as additional information the user wishes to include in the message.

Cookie files
Cookie files (the-so-called ”cookies”) are small text files that are placed on the user’s computer when he/she visits Internet sites. Thanks to them the user is provided with more customized service. The use of cookies is now a standard for most Internet sites. If a user does not want to receive cookie files, he/she may manage and control them via the browser.
Before registering on our site you must accept operation of cookies. In the case of deactivation of these files other functions of the site may operate incorrectly. After the end of your visit to the site you may remove cookies from the “browsing history”.

Use of personal data
In the case when a visitor gives us personal data, they are used for purposes specified at the time of their submission (or if they are obvious in the context of data submission). Personal data are usually collected for the following purposes:

registration on the Internet site;
subscription to a newsletter;
asking for details;
distribution of publications / materials;
monitoring and enforcing the observance of the conditions for using the Internet site;
administration and management of our site, including confirming and authenticating the identity and preventing unauthorized persons from accessing restricted parts, premium contents or other services available to registered users only;
aggregating data for the purposes of analyzing and improving the Internet site’s operation.
• unless provided for otherwise, we can also use data for contacting the user to submit information about Anwis operations, products and services and other information that the users may find interesting. The User may resign from obtaining the above information through contacting us at: odo@anwis.pl.

On our sites we do not collect or gather personal data in order to disclose or sell them to external entities for marketing purposes and we do not send messages in the name of third parties. In the case when such information may be disclosed to a different company than a counterparty of Anwis, the visitor must first consent to it.

Legal grounds for processing
We process personal data of persons visiting our sites on the basis of the legitimate interests of a data controller or consent in the case when a data subject is asked for such consent. For example, on the basis of the legitimate interests of a data controller we send marketing materials adapted to the preferences of a data subject.

Storage of data
We store personal data collected via Internet sites for as long as it is necessary (for example for duration of our relations with a given person).

7. Anwis Home users

This section describes the Privacy Policy for the Anwis Home mobile application provided by Anwis Sp. z o.o. (hereinafter the "Privacy Policy").
The Anwis Sp. z o.o. application (hereinafter the "Application") is installed on mobile devices, particularly on mobile phones and tablets, after downloading by the user via the Play Store (Android) or iTunes Store (iOS).
Use of the Application requires a mobile device with iOS or Android and an Internet connection with active data transmission package or an active Wi-Fi connection.
Use of the Application does not require to provide any personal data. Applications do not store any personal data that could allow a third party to identify the Application user.
If you do not accept the rules of the Privacy Policy rules, do not install the Application and remove it if it is installed on your device. Permanent removal of the Application from a mobile device is tantamount to termination of using the Application.
The Privacy Policy shall exclusively be complementary to the privacy policy of the Google Play Store and Apple App Store. Anwis Sp. z o.o. shall not be held liable for the privacy policy executed by entities managing the Google Play Store or Apple Appstore applications and for their compliance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 (OJ L 119 of 2016, p. 1-88), the Act of May 10, 2018 on the protection of personal data (OJ 2018,1000), and the Act of July 18, 2002 on the provision of electronic services (OJ 2017.1219) as part of the Google Play Store and Apple App Store.
For any questions or doubts, please contact us at anwis@anwis.pl.

Legal grounds for processing

The legal grounds for each processing operation are specified in the relevant section above. In the case when personal data are processed on the basis of legitimate interests of a data controller we try to analyze and balance our interests and the potential (positive and negative) influence on the data subject against the rights of this person resulting from the personal data protection regulations.
Our legitimate interests of a data controller do not automatically prevail over the rights of data subjects – we do not process personal data in the case when the influence on the data subject prevails over our interests (unless we have obtained proper consent or it is required or allowed by the regulations of law).

When and how we transfer personal data to third parties and processing sites

We transfer personal data to third parties only if it is permitted by the regulations.
If this is the case, we include in the agreement security provisions and mechanisms for the purposes of protecting data and maintaining our standards of data protection, their confidentiality and security.
Our company operates globally and we carry out our operations together with other suppliers of goods and services directly and via external entities based in other countries. As a result, personal data may be transferred beyond the territories of countries where our company or companies of our Clients is / are based.
Personal data stored by us may be transferred to:

External organizations providing applications/functionalities or providing services of data processing or IT services.
Thanks to the support of external entities we can carry out our business tasks, provide services as well as provide, operate and manage internal IT systems. These entities include among others providers of IT technology, the ERP system, the www.modniewoknie.pl system, cloud based software, as well as entities providing identity management services and services in the field of hosting and management of Internet sites, data analyses, back-ups, data security and storage. Servers operating and supporting the cloud infrastructure are situated in safe data centres all over the world and personal data may be stored in each of them.
External organizations that assist us in a different way in delivering goods, products or information or providing services.
Chartered accountants and other professional advisors.
Bodies supervising observation of the law, regulatory bodies and other government authorities or third parties if the binding regulations require so (pursuant to these regulations).
We may obtain requests from authorized third parties for disclosure of personal data, for example to check whether we observe the binding law and regulations, conduct an investigation into an alleged crime, establish, exercise or defend statutory rights. We comply with such requests only if regulations of the binding law or provisions allow us to do it.

Amendments to this document

We believe that transparency is a constant obligation and that is why we will regularly review and update this document.
This declaration was last updated on 26 June 2018.

Data controller and contact information

The data controller is ANWIS Sp. z o. o.

In the case of any questions relating to this document and means and purposes of processing personal data by our company please contact us at:

ANWIS Spółka z o.o.
ul. Smocza 16/18, 87-800 Włocławek, Polska
E-mail address: odo@anwis.pl
Phone: +48 54 412 88 00

Rights of natural persons and the manner of their exercise

Natural persons have specific rights concerning their personal data and data controllers are responsible for exercise of these rights. In the case when a decision about the means and purpose of personal data processing lies with us, we are a data controller and we provide further information about the rights of natural persons and the manner of their exercise below.
Access to personal data
Natural persons have the right to access data that we store as a data controller. This right may be exercised by sending an e-mail with a relevant request at odo@anwis.pl. or by mail.
Please send your requests to the Data Controller by e-mail or mail at the addresses indicated in the contact information above..

Amendment to personal data

You can update personal data transferred to us by sending a proper e-mail at: odo@anwis.pl or by mail or, if applicable, by contacting us via a proper registration site or amending personal data stored in proper applications in which registration has been carried out.
If practicable, after informing us that any personal data processed by us are no longer valid, we will amend them on the basis of updated information.

Withdrawal of the consent

In the case of processing personal data on the basis of consent, natural persons have the right to withdraw this consent at any time. You can withdraw consent to the processing of personal data by sending us a proper e-mail at odo@anwis.pl or by mail. If you do not want to receive marketing information any longer, click the resignation link in the proper e-mail sent by us.
Right to restrict the processing or to object to processing of personal data
Natural persons have the right to restrict processing or object to processing of their personal data at any time, due to their special situation, unless the processing is required by law.
If this is the case, we will discontinue processing of personal data or restrict their processing, provided that we are able to prove the legitimate grounds for processing or establishing, exercising or defending our rights.

Other rights of data subjects

This document presents information on what personal data we collect and how we use them. In addition to the right of accessing, amending and restricting processing or objecting to processing indicated above, natural persons have other rights relating to personal data stored by us, such as the right to demand deletion and the right to data portability. You can exercise these rights by sending an e-mail at odo@anwis.pl. or by mail.

Complaints

We hope it will not be necessary but if you want to lodge a complaint about using personal data by us, you can do it by sending an e-mail with detailed information about the complaint at odo@anwis.pl. or by mail. Any complaints will be examined and we will reply to them.
Natural persons have also the right to lodge a complaint to the President of the Personal Data Protection Office. You can obtain more information about rights of persons and the manner of lodging a complaint to the President of the Personal Data Protection Office at https://uodo.gov.pl/.