Privacy policy and data protection

This privacy policy (Privacy Policy) applies only to the website www.subtenogroup.com (Website) provided by Subteno Group sp. z o.o. (hereinafter also referred to as we, us, our or the Company).

Please be advised that in accordance with Article 13 of 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/WE:

1. Providing personal data is voluntary, however, failure to provide data may result in the inability to subscribe to the newsletter, participate in competitions, receive marketing offers, or participate in surveys.
2. Your personal data will be processed for marketing purposes pursuant to Article 6(1)(a) of the General Data Protection Regulation of April 27, 2016, and will be stored until your consent is revoked.
3. You have the right to access and correct your data and the right to withdraw your consent at any time by contacting: subteno@subtenogroup.com
4. Withdrawal of consent does not affect the lawfulness of the processing of your personal data based on your consent prior to withdrawal.
5. The personal data you provide may only be made available to entities authorized under the aforementioned legal regulations.
6. You have the right to request from the administrator access to personal data, the right to rectify, delete or limit the processing of data, the right to withdraw consent and the right to transfer data.
7. You have the right to lodge a complaint with the supervisory authority, i.e. the President of the Personal Data Protection Office.

Data collected during a visit to www.subtenogroup.com

• We do not require registration to access www.subtenogroup.com, but if you wish to access any services offered by the Company through www.subtenogroup.com, we are required to collect the personal information we need to provide these services. Failure to provide us with the information necessary to complete the registration process may prevent or delay the provision of services. The categories of data collected include:
  • Contact details such as name, position, e-mail address, employer’s name and telephone number.
  • Information about the services we provide, such as details of your inquiries, requests or complaints.

Technical information

When you visit our website, we may collect technical information such as your Internet Protocol (IP) address, information about the pages you visit on www.subtenogroup.com, other websites you visit online, and the browser you use to view www.subtenogroup.com.

This website collects standard log and technical information to measure and improve the performance of the website, diagnose server problems, administer the website, find out where our traffic comes from and identify our users. We may also collect other information through www.subtenogroup.com, such as activity and usage preferences, also known as demographic or profile data. In this respect, we may use cookies to collect such information. For more information on our cookie policy, click here

When is personal data collected on www.subtenogroup.com

We collect your personal data in the following circumstances:

• When you register for any of our services
• When you register for any of our blogs
• When you register to participate in an event (e.g. training, conference or similar)
• When you participate in a discussion forum
• When you contact us to request more information (e.g. about our services, to submit an offer or similar)

We collect the minimum amount of data necessary to handle your request or provide our services. We will indicate when the provision of information is voluntary and when it is required. We usually request additional information only to provide the most appropriate response to your inquiry.

Use of personal data

Subteno Group sp. z o.o. uses personal data to:

• Identify you and create a profile for you when you register to use our services or request information from us.
• Verify your identity when you use our services or contact us.
• Communicate with you about the services we provide and the information we give you.
• To fulfill our contractual obligations in accordance with Komorniczak & Partners’ Global Terms of Use.
• To provide, improve, and personalize our services by analyzing information about how you use our website in order to understand how our website can be used more intuitively.
• To handle your inquiries and requests.
  To comply with our legal obligations and cooperate with regulatory and law enforcement
• authorities.
  To contact you for marketing purposes to offer you our services and products (unless you have opted out of marketing contacts or they are prohibited by law).
• Contacting you for marketing purposes to offer our events – conferences, training (unless you have opted out of such contacts).
• Personalize the marketing messages sent to you so that they become more relevant and interesting through a detailed analysis of the services and information provided and your transaction history, in order to suggest other information that may be of interest to you.
• Exercise our rights when necessary, for example to detect violations of the law.

We must have a legal basis for processing your data. In most cases the legal basis will be one of the following reasons:

• Provision of services in accordance with the Terms of Use of www.subtenogroup.com
• Compliance with our legal obligations, for example to enable us to comply with requirements regarding fraud prevention and money laundering.
• To satisfy our legitimate interests, for example, by understanding how our site and services are used, which helps us develop new services.
• When we process your data to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and we make sure that our legitimate interests do not override your interests or fundamental rights and freedoms or more information about the balancing test that we carry out for processing your personal data to meet our legitimate interests, please contact us using the details below.
• We may obtain your consent to collect and use certain types of personal data when required by law (for example, for direct marketing activities or the use of cookies and tracking technologies). If we ask for your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us using the contact details at the end of this Privacy Notice.

Your rights

You have certain rights regarding your personal data, subject to applicable legal provisions. These include the right to: request access to your personal data that we may process on www.subtenogroup.com, update or correct it, restrict its use, object to its processing, receive your personal data in a usable format and transfer it to a third party, or request that your personal data be deleted from our systems.

You can exercise these rights by sending an email to subteno@subtenogroup.com. We will process any requests in accordance with applicable law.

If you would like to opt out of receiving promotional or marketing emails from us on a going-forward basis, you may let us know by sending an email to subteno@subtenogroup.com and including the email address that should be removed from our mailing list. However, your withdrawal from receiving promotional and marketing messages will not prevent us from contacting you, via email or otherwise, in connection with the cooperation between us.

Transfer of data to third parties

We may contact other companies or individuals to help us deal with your enquiries or other matters relating to the operation of the website or our business (e.g. for marketing purposes, hosting our databases, mail and messaging services, and data analysis). We may give such companies access to your personal data in connection with the above purposes on our behalf. We may also share your personal data with other member companies of the BDO Network (e.g. for the purpose of analyzing or optimizing the service), provided that this is consistent with the basis on which we collected your personal data.

We may disclose personal data in response to a court order, subpoena, or government investigation, or as otherwise required or permitted by law.

We do not share data with third parties for their own marketing purposes and do not engage in third-party mailing.

We may, as a result of the sale, merger, consolidation, change in control, transfer of assets, reorganization or liquidation of our company (Reorganization Event), transfer, sell or assign your personal data to third parties involved in the Reorganization Event.

Data retention

We will retain your personal data for as long as we have an ongoing relationship with you. When our relationship with you ends, we will retain your personal data for a period of time that enables us to: maintain our business records for analysis/auditing purposes; comply with our legal record keeping requirements; defend or bring legal claims; deal with any complaints.

We will delete your personal data when it is no longer needed for the above purposes. If any data cannot be fully deleted from our systems for technical reasons, we will put in place appropriate safeguards to prevent any further processing or use of such data.

You have the right to revoke your consent to us at any time by sending an email to subteno@subtenogroup.com.

Data security

We have implemented generally accepted standards of technology and operational security in order to protect personal data from loss, misuse, unauthorized alteration, or destruction. All of our employees and contractors are obliged to respect the confidentiality of personal data, and only authorized persons are permitted to access it.

Cross-border transfers

In order to provide services through our website www.subtenogroup.com, it may be necessary to transfer your personal data outside the EEA to countries that may not provide a level of personal data protection considered to be equivalent to that provided in accordance with European data protection regulations. In cases where your personal data is transferred abroad, we will take appropriate steps to ensure its security and confidentiality in accordance with applicable law. For more information on how we protect your personal data, please contact us using the contact details in the “Contact” section of the Privacy Policy.

Updating the Privacy Notice

We may modify or update this Privacy Notice from time to time. You will be able to see when it was last updated because we will include the date of modification. Changes and additions to the Privacy Notice are effective as of the date they are posted.

Contact

If you have any concerns about how we process your personal data, you can contact the relevant data protection authority, i.e. the President of the Office for Personal Data Protection.

Please be advised that the Personal Data Controller is Subteno Group sp. z o.o., ul. Koszykowa 69 / 3, 00-667 Warsaw, tel.: +48 576 339 600; e-mail: subteno@subtenogroup.com, and the contact details of the Data Protection Officer are: iodo@subtenogroup.com