политика конфиденциальности

Privacy Policy of  GRUPA INCO S.A. Company

 

The following document describes the policy of processing personal data, especially personal data of users collected by webpages (www) and Internet websites, including the rules of cookie files usage. In cases of personal data security in GRUPA INCO S.A. Company you are requested to contact our personal data inspector available at an email address iod@inco.pl or send a letter to the Company’s business address with a note “IOD” on an envelope.

 

1. Glossary of terms

1.1. „GRUPA INCO” –  means the company operating as GRUPA INCO S.A. with its registered office located in Warsaw, address: Wspólna 25 St. 00-519 Warsaw, entered into the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, XIII Economic Division of the National Court Register under National Court Register (KRS) number 0000101255,  Tax Identification Number (NIP): 526-03-00-428, National Official Business Register (REGON): 000599764, registration number BDO: 000000026, share capital of the Company: 500.000,00 zł (400.000,00 PLN paid in cash, 100.000,00 PLN assets in kind).

1.2. „User” – means an Internet user visiting one of the webpages or profiles on social media websites (GRUPA INCO profile or other GRUPA INCO product profiles) belonging to GRUPA INCO. The User is also a person redirected to the Privacy Policy by, e.g. a footnote in an email of GRUPA INCO employee or a link included in an invoice issued by GRUPA INCO.

1.3. „Corporate client” – means a natural person conducting business activity, a person conducting agricultural activity, partners in a civil partnership, commercial law companies, public authorities (governmental and non-governmental), bodies under their authority, societies, foundations and organizational units.

1.4. „Consumer” or „Client” – means a natural person performing legal activity with GRUPA INCO or an entity related to GRUPA INCO, which is not directly associated with its business or professional activity.

1.5. „Agreement” – means a legal act consisting in two parties submitting a declaration of intent, which causes a direct legal effect on the formation, alteration or termination of their legal relation.

1.6. „Privacy Policy" – means the present document.

1.7.„Websites" – means websites available at following email addresses: www.inco.pl, www.inconieruchomosci.pl, www.osrodekmiedzywodzie.pl, www.osrodekgawra.pl, www.inco-inwestycje.pl, www.inco-opakowania.pl, www.florovit.pl, www.azofoska.pl, www.ludwik.pl, www.inco-chemia.pl, www.biofos.pl, www.nawozydotrawnikow.florovit.pl, www.mikroflora.florovit.pl, www.nawozeniejesienne.florovit.pl, and also webpages belonging to GRUPA INCO created for advertising and promotional purposes, such as landing pages of given products.

1.8. „Cookies” – IT data, particularly text files which are stored in user’s terminal equipment, facilitating the usage of websites. „Cookies” usually feature the name of the website they come from, their storage time on the terminal equipment and its unique identity.

1.9. „Personal data” – means data which independently or in conjunction with other pieces of data allow user’s identification, especially through the reference to such data as name and surname, ID number, location data and a web identifier.

1.10. „ GRUPA INCO Profile” – means websites, accounts and channels run by GRUPA INCO on social network services such as Facebook, YouTube.

1.11. „GDPR” – means 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 on the free movement of such data, and repealing Directive 95/46/EC. (General Data Protection Regulation).

 

2. Who is the administrator of personal data?

 

2.1. The administrator of data is  „GRUPA INCO” –  the company operating as GRUPA INCO S.A. with its registered office located in Warsaw, address: Wspólna 25 St. 00-519 Warsaw, entered into the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, XIII Economic Division of the National Court Register under National Court Register (KRS) number 0000101255,  Tax Identification Number (NIP): 526-03-00-428, National Official Business Register (REGON): 000599764, registration number BDO: 000000026, share capital of the Company: 500.000,00 PLN (400.000,00 PLN paid in cash, 100.000,00 PLN assets in kind). Email contact: kontakt@inco.pl.

2.2. For safety reasons GRUPA INCO has designated a data security inspector being available at an email address iod@inco.pl.     

2.3. Technical and organizational measures are being applied to secure the data GRUPA INCO is being provided with, according to requirements resulting from existing legislation.

2.4.  Each person GRUPA INCO employs or cooperates with is required to keep all personal data in confidence, before they are allowed to process them.

 

3.  What are the purposes of using personal data by GRUPA INCO and for how long are they being processed?

 

3.1. The purpose of data processing by GRUPA INCO is determined by the scope of services it provides towards the user. Aims of data processing along with the specification of situations it occurs are listed below. Simultaneously, the legal basis of data processing was given along with the data retention period.

 

Aim of processing	Explanation	Legal basis	Data processing period
The conclusion, and proper contract implementation, termination or other activities essential for the realization of the concluded contract.	All preparatory actions before concluding the contract, e.g. presentation of the offer , negotiations, etc. (regardless of its conclusion) as well as the execution of the contract.	Article 6(1) (b) of the GDPR.	Throughout the duration of the contract and after its termination or expiration until the end of the period of limitations arising from a given agreement.
Financial reporting	Record-keeping of bookkeeping vouchers, invoices and bills.	Article 6 (1)(c) of the GDPR, following the Accounting Act of 29 September 1994 and other regulations on objective  matters, i.e. The Tax Ordinance Act.	Data are stored throughout the period required by legislation which order GRUPA INCO to store the books (up to the end of tax limitations period, unless tax law constitutes otherwise) or accounting law (5 years counting from the beginning of the year following the turnover year which the data is concerning.
Considering claims under agreements concluded with a business customer	It shall mean possibilities of reacting to reported claims.	Article 6 (1)(b) and (f) of the GDPR.	Until claims relevant to the complaint are barred by limitation or expire.
The implementation of duties in the scope of monitoring the safety of medicinal products being used	It concerns personal data being collected by telephone contact or forms available at the website or distributed directly by a sales agent.	Article 6 (1)(c) and Article 9 (2) (i) of the GDPR.	Throughout the total period of the medicine admission to trading and for 10 years following the expiration of this admission.
Consideration of consumer claims	In some cases the complaint filed by a consumer is not sent to the shop the product was purchased in, but directly to the company GRUPA INCO, then such complaints are considered, which is connected with data processing.	Article 6 (1)(f) of the GDPR.	Until claims relevant to the complaint are barred by limitation or expire.
Protection against claims and its recovery	In cases of dispute the necessity of using measures permitted by law may occur, which is related to the evidentiary material protection. Analogically, such claims exist also in case of the lack of payment for ordered products.	Article 6 (1) (c) (following Article 118 of the Civil Code) and (f) of the GDPR.	Until it is barred by limitation or expires.
Dealing with correspondence (postal) sent to the contact addresses and emails shared by GRUPA INCO	Personal data made available in contact forms or directly via email or conventional correspondence (postal) addressed to GRUPA INCO. For example, it may be an offer from a potential supplier addressed to GRUPA INCO.	Article 6 (1)(f) of the GDPR.	Up to 3 years after an email was sent or a traditional letter delivered.
Ensuring safety of persons and property in the registered office, production facilities and holiday resorts of GRUPA INCO, including video surveillance of the facilities mentioned above	In properties owned by GRUPA INCO, such as its registered office, production facilities and holiday resorts, video surveillance is conducted, which is relevant to the image processing and thus may constitute personal data.	Article 6 (1)(f) of the GDPR.	Up to 3 months following the date of recording the video image and in cases where the video image constitutes an evidence in proceedings conducted on the legal basis or if GRUPA INCO was informed that it may occur, until the end of the proceedings.
Dealing with reports in the scope intended by Articles 15-22 GDPR (the principle of accountability implementation)	Dealing with demands, e.g. to delete personal data to enable GRUPA INCO service and archive it in order to prevent it from claims arising from the GDPR.	Article 6 (1)(c) (following Article 5 (2) of the GDPR) and (f) of the GDPR.	Up to 3 months following the date of receiving the claim and after this time, until the claim is barred by limitation and the ability to prove the implementation of the principle of accountability defined in Article 5 (2) GDPR.
Newsletter mailing	The User’s subscription to any GRUPA INCO information newsletters is connected with data processing by the company mentioned above.	Article 6(1)(a) of the GDPR.	Until the user unsubscribes the newsletter (withdraws a consent).
Dealing with correspondence via email within loyalty programs	Sending information connected with leading and accomplishment of promotional actions within loyalty programs, such as Florovit Premium Club, in which GRUPA INCO acts as the administrator of personal data, processing it directly or through an entity which is given the data on the basis of an entrustment contract	Article 6 (1) (b) and (f) of the GDPR.	For the duration of the loyalty program or until any objection against data processing or a demand of data deletion are risen.
Analyzing and assessment of suppliers production processes and the possibility of cooperation	Data obtained as a result of conducted processes audits and sent forms	Article 6 (1)(b) and (f) of the GDPR.	For the duration of the cooperation and after its end for 2 years following the year the cooperation was ended or until  until the expiry of limitation period for any claims.
Assessing possibilities of entering into a cooperation with suppliers	Data obtained by GRUPA INCO after it receives commercial offers or requests concerning the possibility potential cooperation	Article 6 (1) (b) and (f) of the GDPR.	For the duration of the contract and after its expiration or termination, until the expiry of limitation period for any claims emerging from the contract or after 3 years with no signs of further cooperation.
Authentication of a person authorized to receive merchandise on behalf of the contractor	It concerns personal data collected during implementation of contracts connected with carriage of goods	Article 6 (1) (f) of the GDPR.	Until the relevant tax obligations limitation period expires.

 

 

4. Personal data recipients

4.1. Personal data are disclosed to entities supporting GRUPA INCO on the basis of concluded entrustment agreements. Among these entities listed above there are:

• entities providing services in the field of legal services and counselling
• entities performing services within the scope of recovery of the claim
• entities providing archiving services and performing documentation removal
• entities providing IT services
• entities providing freight forwarding and courier service
  as well as:
• authorities entitled to data processing, e.g. enforcement agencies, law courts

 

5. User permissions in the scope of personal data

Each User is permitted to:

5.1. have access to their personal data (Article 15 of the GDPR), including receiving the copy of data (Article 15 (3) of the GDPR).

5.2. rectify (correct) or complete personal data which is incomplete (Article 16 of the GDPR).

5.3. claim personal data to be deleted in cases required by (Article 17 of the GDPR).

5.4. demand restrictions in data processing (Article 18 of the GDPR).

5.5. the right to obtain their data in a structured, commonly used format and its transition, when the processing occurs on the basis of permission or concluded agreement, also when it is automatized. (Article 20 of the GDPR).

5.6. the right to raise objection to personal data processing even in case of a legitimate action in the business of the administrator and for reasons related to its specific situation, including profiling (Article 21 of the GDPR)

5.7. In cases data processing is performed on the basis of the consent given, the User is entitled to withdraw their consent at any time, but this action cannot influence the legitimacy of processing before its withdrawal. The consent may be withdrawn by an email sent to the following email address: iod@inco.pl.  

5.8. In cases it is believed GRUPA INCO breaches the GDPR provisions by their data processing actions, the User shall be entitled to file a complaint to a supervisory authority, i.e. the President of the Personal Data Protection office with its registered office located in Warsaw, Stawki 2 St.

The Office may be contacted in following ways:

By letter by sending a letter to the following address: Stawki 2 St., 00-193 Warsaw

By an electronic email box available at https://www.uodo.gov.pl/pl/p/kontakt

By telephone: (22) 531 03 00

5.9. Providing personal data is voluntary, however in specific situations it is legally or contractually required. Consequently, the refusal of providing  them precludes the realization of a provision of the law or the conclusion and proper functioning of the agreement.

 

6. Social networks

6.1. GRUPA INCO runs several profiles on social networks:

6.1.1.  Facebook profiles:

1. GRUPA INCO holiday resort in Międzywodzie (Polish seaside) Facebook profile available at www.facebook.com/Ośrodek-Wypoczynkowy-INCO-Międzywodzie-1108698412495521
2. „GAWRA” GRUPA INCO holiday resort in Wikno (in Masuria region) Facebook profile available at www.facebook.com/Ośrodek-GAWRA-621481804597682
3. “Ludwik”  household chemistry products Facebook profile available at www.facebook.com/ludwikpl
4. “Florovit” fertilizer products profiles available at www.facebook.com/florovitSE and www.facebook.com/Nawozy-Florovit-Mikroflora-3w1-uzdrawiamy-glebę-385854618688397

6.1.2.  YouTube channels:  www.youtube.com/channel/UCOrF6-IXf8j4rzC4jcaZT4Q

This social media activity may be connected with User’s personal data processing by GRUPA INCO while they visit profiles, websites or channels mentioned above or interacts with them (giving likes, commenting or sending messages). If the User visits GRUPA INCO Facebook or You Tube profiles, these profiles collect data concerning User’s activity, including the data about likes given, messages sent to GRUPA INCO, comments or posts published on their social media profile. In this case it is vital to take into consideration that both the User and GRUPA INCO, as users of a given social media website, are bound by privacy policy and regulations agreed within this website. Data connected with User’s activity within social media profiles run by GRUPA INCO shall be saved until they are deleted by the User, GRUPA INCO or the administrator of a given social network website. The User of each social network website GRUPA INCO runs their profile on is also able to manage their accounts and published content, compliant with the regulations of a given social network website.

 

7.  Cookies

7.1. GRUPA INCO informs that cookies are used for the following purposes:

7.1.1. To adjust the content of the service to the User and to optimize using Internet websites. In particular, these files allow recognizing user’s device and display the website correctly, adjusted to their individual needs.

7.1.2. The maintenance of user’s session (if they are logged in) means that the User is not obliged to log in again on each subpage (only if the website of the service owned by GRUPA INCO allow user registration – if not, cookies do not occur).

7.1.3. Production of statistics which constitute the basis for further analysis of  Internet services usage.

7.1.4. Displaying GRUPA INCO advertisements on Internet websites other than these owned by GRUPA INCO.

7.2. There are two kinds of cookie files applied on GRUPA INCO Internet websites.

7.2.1. Session cookies, mean temporary files, which are stored in User’s terminal equipment until the moment of a log out, leaving the website or turning off the Internet browser.

7.2.2. Persistent cookies, stored in User’s terminal equipment for a period of time set out in cookies parameters or until they are deleted by the User.

7.3. Moreover, GRUPA INCO shall inform that within their websites and internet services, due to the purpose of usage, two types of cookie files are employed:

• Files enabling the use of the services available within an Internet website, e.g. authenticating cookie files required for authentication purposes.
• Files aiming at ensuring safety, e.g. used to detect misuse in authentication.
• Files allowing collecting information about the manner of usage of the Internet websites owned by  GRUPA INCO.
• Files allowing memorizing settings chosen by the User and personalization of User’s interface, e.g. by setting a given language or the region of the user’s origin.
• Files enabling Users to be provided with commercial content being well adjusted to their interests (advertising cookies).

7.4. GRUPA INCO states that the software designed for website browsing (an Internet browser) may allow cookie storage in User’s terminal equipment by default. Users shall change settings concerning cookies at any time, e.g. by blocking automatic cookies service in browser settings or informing the User about their location in the terminal equipment each time.

7.5. Detailed information about possibilities and ways of cookies management are available in manuals of cookies management, shared by following Internet browser producers:

Firefox, Internet Explorer, Chrome, Safari, Opera.

7.6. If any of the links does not work, e.g. because of the fact that the information about cookies was transferred to a different subpage by the browser producer, the User is requested to use the browser to find relevant information, e.g. by inserting phrase “Safari cleaning cookie”.

7.7. GRUPA INCO informs that cookie files restrictions applied by the User may influence some functionalities offered by GRUPA INCO Internet services.

 

8. Google Analytics

8.1. Websites owned by GRUPA INCO use Google Analytics, which is a Google device analyzing Internet services. Google Analytics uses cookie files, which are saved on the User’s computer and enable further analysis of websites being used. Data obtained by a cookie file concerning the manner of using Internet websites by the User are usually transferred to Google servers and saved.

8.2. The User may prevent saving cookie files by appropriate settings of browser settings (see: links above).  However, GRUPA INCO remarks that such an action may cause some limitations in the use of all the options of a given website it owns. Moreover, the User may prevent downloading data obtained by a cookie file, concerning the way of using the website (including an IP address) by Google and its data processing if the User downloads and installs the plug to the browser, available to download at: tools.google.com/dlpage/gaoptout.

8.3. GRUPA INCO uses Google Analytics for the purposes mentioned above. Obtained statistics make it possible to improve the offer for the User and design it in a more interesting way. In particular cases, where data is transferred to the US, Google complies with the EU-US Privacy Shield Agreement, available at: www.privacyshield.gov/EU-US-Framework. The legal basis for the use of Google Analytics constitutes in Article 6 (1)(f) of the GDPR.

8.4 The Privacy Policy of the Company can be found at https://policies.google.com/privacy?hl=pl: Due to ongoing changes in the Google Privacy Policy it is required to check the currently applicable version.