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Pursuant to Article 13(1)–(2) of 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 the free movement of such data, and repealing Directive 95/46/EC (Official Journal of the EU L 2016, No. 119) – hereinafter referred to as the GDPR – we inform you as follows:
1. The controller of your personal data is P.P.U. Comex Sp. z o.o., with its registered office at ul. Graniczna 21, 54-516 Wrocław, entered in the register of entrepreneurs of the National Court Register maintained by the District Court for Wrocław-Fabryczna, 6th Commercial Division of the National Court Register, under KRS number 0000023036, REGON number 008088365, and NIP number 8980016119, hereinafter referred to as the Controller.
2. The Controller has not appointed a Data Protection Officer. For matters concerning personal data protection and the exercise of your rights:
2.1. You may contact us regarding the protection of your personal data by email at sekretariat@comex.net.pl or in writing at the registered office address specified in point 1.
3. Your personal data will be processed for the following purposes:
3.1. where necessary for the performance or conclusion of a contract to which you are a party, pursuant to Article 6(1)(b) GDPR;
3.2. where necessary to conclude a contract on the basis of your interest in an offer, pursuant to Article 6(1)(b) GDPR;
3.3. to conduct customer satisfaction surveys in pursuit of the Controller's legitimate interest in assessing service quality and customer satisfaction with the products and services we provide, pursuant to Article 6(1)(f) GDPR;
3.4. to pursue or defend against potential claims in pursuit of our legitimate interests, pursuant to Article 6(1)(f) GDPR;
3.5. to offer you products and services in pursuit of our legitimate interest in direct marketing, including products and services supplied by entities cooperating with us (partners), and to tailor them to your needs, i.e. profiling, pursuant to Article 6(1)(f) GDPR, as well as for marketing purposes based on separate consent (Article 6(1)(a) GDPR).
4. Right to object.
You have the right to object to the processing of your personal data. Following such an objection, we will cease processing your data for the purposes specified in point 3, except where we demonstrate compelling legitimate grounds for processing that override your interests, rights, and freedoms, particularly in pursuit of our legitimate interests, or where the data are necessary for the establishment, exercise, or defence of legal claims.
5. Data retention period.
5.1. Where your data are processed as necessary for the performance of a contract to which you are a party, they will be processed for the period during which contractual claims may arise under the Civil Code and/or tax law, and also for five years calculated from the end of the calendar year in which the tax obligation arose.
5.2. Where the processing of your personal data is based on consent, the data will be processed until that consent is withdrawn. Following withdrawal, the personal data will be processed for a period corresponding to the limitation period for claims that the Controller may bring or that may be brought against the Controller.
6. Disclosure of personal data. Your personal data may be disclosed to the following recipients: entities within our corporate group; entities providing us with accounting (payroll and financial), legal, and auditing services; and our partners as part of their individual audits.
7. Transfers of personal data to third countries.
7.1. Your personal data may be transferred outside the European Economic Area (EEA) to third countries or international organisations in connection with the Controller's use of tools provided by external service providers (including Google LLC and Meta Platforms, Inc.).
7.2. Transfers of personal data to entities established in the United States are based on appropriate legal mechanisms, in particular:
(a) the European Commission's decision of 10 July 2023 recognising an adequate level of personal data protection under the EU–US Data Privacy Framework – in respect of entities listed as certified participants by the US Department of Commerce;
(b) Standard Contractual Clauses (SCCs) approved by the European Commission – where the adequacy decision does not apply or additional legal safeguards are required.
7.3. You may obtain a copy of personal data transferred to a third country by contacting the Controller.
8. As a data subject, you have the following rights:
8.1. the right to access your data and receive a copy of them;
8.2. the right to data portability;
8.3. the right to object to the processing of data;
8.4. the right to rectification (correction) of your data;
8.5. the right to erasure of data and restriction of processing;
8.6. the right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office.
9. Information concerning the voluntary provision of data:
The provision of your personal data is voluntary but necessary for:
9.1. the provision of services under concluded contracts and/or assignments, orders, or pro forma invoices;
9.2. the preparation of an offer and conclusion of a contract for the provision of other services by the Controller.
