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MSPO 2016
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INFORMATION ON PROCESSING OF PERSONAL DATA

Pursuant to Article 13 of the general data protection regulation of 27 April 2016 (OJ L 119 of 04 May 2016) we hereby inform that:

1. Controllers of personal data
The following entities shall be the Controllers of your data: Lubawa S.A. with its seat in Ostrów Wielkopolski, ul. Staroprzygodzka 117, 63-400 Ostrów Wielkopolski, entered into the Register of Entrepreneurs of the National Court Register (KRS) by the District Court in Poznań for Nowe Miasto i Wilda, IX Commercial Division of the National Court Register under the following number: 0000065741, tax identification number (NIP): 7440004276, and Lubawa Capital Group (hereinafter referred to as "Lubawa Group"), i.e. all the entities belonging to the capital group, as well as our trusted partners, i.e. entities not belonging to Lubawa Group but being our partners, with which we cooperate on a permanent basis (hereinafter referred to as "Trusted Partners"). Most often the said cooperation is aimed at providing you with the best service when performing contracts and handling your orders, better adjustment of offers to your needs and at performing different types of research and activities for better management of resources and their adaptation to the needs of our counterparties. Detailed information concerning the controllers can be found at https://www.lubawagroup.com/pl/polityka-prywatnosci.

2. Joint arrangements between the Controllers
In view of the fact that Lubawa Group and the Trusted Partners operate on the principle of co-controlling, pursuant to Article 26 of the general data protection regulation of 27 April 2016, we have concluded a relevant agreement. Each of the Controllers shall exercise due diligence to ensure the security of data processing and you may turn to each of them with any questions you might have. In particular we have agreed that:

1) the Controller obtaining personal data shall be responsible for fulfilling the information obligation towards you in accordance with Article 13 and 14 of the GDPR;
2) each of the Controllers shall be responsible for allowing you to exercise the rights referred to in item 6 through the point of contact established by us (see the data below). Notwithstanding the foregoing, you may exercise your rights by submitting your requests, applications or enquiries to each of the Controllers. In such a case, the Controller, to which you submit your request, shall forward it to other Controllers for the purpose of its execution and, subsequently, shall reply to your request in accordance with the rules and within the time limits laid down in Article 12 of the GDPR;
3) the Controller obtaining personal data from you shall be responsible for the accuracy of the data collected,
4) Litex Service Sp. z o.o. with its seat in Ostrów Wielkopolski shall also make every effort to ensure the external security of IT systems against unauthorised access as well as their internal organisation ensuring the best protection.

The content of the arrangements between the Controllers can be found on the website at https://www.lubawagroup.com/pl/polityka-prywatnosci.

3. Point of contact Together we have decided to establish a common point of contact that can be contacted in matters concerning the protection of personal data and the exercise of the rights associated with data processing. If you want to contact the Data Protection Officer, please use the contact details specified below.
- Mailing address: Litex Service Sp. z o.o., ul. Staroprzygodzka 117, 63-400 Ostrów Wielkopolski;
- E-mail address: iod@litexservice.pl

4. The purposes and bases of data processing
We have jointly defined the purposes of processing your personal data. We shall process the personal data:

a) on the basis of Article 6(1)(b) of the general data protection regulation of 27 April 2016 (hereinafter referred to as the "Regulation") your data shall be processed for the purpose of concluding and performing the contract concluded with you or executing an order as well as any and all activities preceding it,
b) on the basis of Article 6(1)(c) of the general data protection regulation of 27 April 2016 (hereinafter referred to as the "Regulation") your data shall be processed for the purpose of fulfilling the legal obligation related to the issuance and storage of documents and invoices for services rendered or contracted by the Controller of a particular service, and exercising your or Controller’s after-sales entitlements.
c) on the basis of Article 6(1)(f) of the general data protection regulation of 27 April 2016 (hereinafter referred to as the "Regulation") your data shall be processed for the purpose of carrying out direct marketing as well as defending against and in connection with asserting claims and performing other legal obligations before public institutions.
d) on the basis of Article 6(1)(a) of the general data protection regulation, on the basis of consent separately granted by you - if such consent is granted – your data shall be processed for the purpose of sending commercial information.
e) For the purpose of carrying out direct marketing we may do personal data profiling, i.e. an automated analysis of your personal data aimed at developing predictions on your preferences or future behaviours and receiving selected marketing information.

5. Data recipients
Your personal data shall be processed by other entities that provide services to the benefit of the Controller related to, among others, financial settlements, protection of property and persons, by accounting offices, legal firms, advisory and consulting agencies and archiving companies, companies servicing IT equipment and computer programs, in which the data are collected, and by any other companies providing services supporting activities undertaken by the Controller in the area of its business activity in connection with the performance of the contracts concluded with you or any third parties by the Controller.

6. The rights of the data subjects and the right to object

a) You have the right to request the Controller to provide access to personal data, the right to data rectification, deletion or processing limitation, the right to transfer data and if the processing of personal data by the Controller is conducted on the basis of your consent, you have the right to withdraw such consent at any time by sending a written notice to the address of the Controller or contact details given in item 3
b) notwithstanding the provisions indicated in item a) above, you have the right to object to: the processing of personal data that is conducted on a basis other than your consent, contract or a provision of law; to direct marketing carried out by the Controller, including profiling and data processed on another legal basis than the one indicated in the first sentence. You may send an objection notice to the Controller’s address or contact details of the Data Protection Officer indicated in item 3. In the event of submitting an objection notice, once your request have been complied to, it shall not be possible for the Controller to process the personal data covered by the objection notice, unless we prove that there are important legitimate grounds for data processing, which, according to the law, are deemed to take precedence over your interests, rights and freedoms or that there are grounds to determine, assert or defend any claims.
c) You have the right to submit a complaint to the supervisory authority, i.e. the President of the Office for Personal Data Protection, if you think that the processing of personal data by the Controller is in breach of the provisions of law.

7. Data storage period
Your personal data shall be stored for a period to be determined by the controller, i.e. 10 years, provided, however, that in the case of separately granted consent, the data shall be stored until the time such consent is withdrawn in the manner specified in item 6(a), and in the event of an objection to the processing of personal data, until an objection notice is submitted in the manner specified in item 6(b).

8. Information on a voluntary provision of data
The provision of personal data is voluntary. Nevertheless, your refusal to provide data allowing for the execution of a contract may result in our refusal to execute the respective order/contract.

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