Privacy policy

PRIVACY POLICY WIEWIÓRSKI LEGAL

GENERAL INFORMATION

The purpose of this Privacy Policy (hereinafter referred to as “Policy”) is to provide data subjects (hereinafter referred to as “Data Subjects”) with information on the processing of their personal data by Wiewiórski Legal – Kancelaria Radcy Prawnego Marek Maciej Wiewiórski, 81 Świętego Mikołaja Street, 50- 126 Wrocław, NIP: 8941014116) (“Wiewiórski Legal”). All terms contained in the Policy, insofar as they are defined in Article 4 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 on the free movement of such data and repealing Directive 95/46/EC (“RODO”), shall have the meaning given to them in the RODO.

ADMINISTRATOR, CONTACT INFORMATION

Administrator: Wiewiórski Legal

Contact information: 81 Św. Mikołaja Street, 50-126 Wrocław

e-mail: daneosobowe@wiewiorski.pl

PERSONAL DATA PROCESSED BY WIEWIÓRSKI LEGAL

Representatives and employees of customers – business units (including potential customers)

CATEGORIES OF PERSONAL DATA THAT MAY BE PROCESSED: First and last name, position, e-mail address, telephone number, place of employment, signature and other personal data necessary to achieve the purpose of processing

PURPOSES: Wiewiórski Legal processes personal data of representatives and employees (in particular, management board members, proxies, attorneys, persons designated as contact persons, associates) of its clients as well as third parties (e.g., entities within the client’s capital group), in connection with the provision of legal assistance to clients or the conclusion and performance of a contract with a given client. In addition, Wiewiórski Legal processes personal data of client representatives in connection with marketing of its services (e.g. by sending product brochures, newsletters, etc.).

LEGAL BASES:

• The processing is necessary for the purposes arising from the legitimate interests pursued by Wiewiórski Legal (Article 6(1)(f) RODO), which interests include, for example, the conclusion and performance of a contract with a client, direct marketing of Wiewiórski Legal’s services, including, for example, sending marketing materials to client representatives, pursuing claims or defending against them;
• The processing is necessary for the fulfillment of legal obligations incumbent on Wiewiórski Legal (Article 6(1)(c) RODO), when legal provisions require us to take actions that involve the processing of personal data, e.g. actions arising from holding the status of an obliged institution under anti-money laundering and counter-terrorist financing regulations, or conducting verification activities to determine whether a given client is on the white list of VAT taxpayers;
• The data subject has given his or her consent (Article 6(1)(a) RODO);

DATA SOURCES: Personal data of representatives of clients – legal entities is obtained directly from clients by Wiewiórski Legal In other cases, the data may be obtained from publicly available sources (such as the Register of Entrepreneurs of the National Court Register, the Central Register of Beneficial Owners, or foreign registers of entrepreneurs). When personal data is obtained directly from the Data Subject, providing this information is voluntary, although necessary to achieve the purpose of processing. Failure to provide the data may result in the inability to achieve the intended objective (e.g., concluding a service agreement).

DATA RETENTION PERIOD: Personal data processed by Wiewiórski Legal in connection with providing services to its clients are retained for a period of 10 years from the end of the year in which the proceedings, during which the personal data was collected, concluded, pursuant on Article 5c(1)(2) of the Law on Legal Advisers.

DATA RECIPIENTS: Employees and associates of Wiewiórski Legal; Consultants / subcontractors of Wiewiórski Legal; Entities providing services to Wiewiórski Legal.

Contractors – organizational units (including potential contractors) and their representatives and employees

CATEGORIES OF PERSONAL DATA THAT MAY BE PROCESSED: First and last names, position, email address, telephone number, place of employment, signature and other personal data necessary to achieve the purpose of processing

PURPOSES: Wiewiórski Legal processes the personal data of contractors as well as their representatives and employees (in particular, management board members, commercial proxies, attorneys, designated contact persons, associates), in connection with the conclusion and performance of a contract with a respective contractor

LEGAL BASES: processing is necessary for the purposes arising from the legitimate interests pursued by Wiewiórski Legal (Article 6 (1)(f) RODO), which include, for example, concluding and performing a contract with a contractor

DATA SOURCES: Wiewiórski Legal obtains personal data of contractors (natural persons) directly from them. In the case of organizational units, Wiewiórski Legal obtains personal data of their representatives and employees directly from these entities or from other individuals within the contractor’s organization. In other cases, the data may be obtained from publicly available sources (such as the Register of Entrepreneurs of the National Court Register, the Central Register and Information on Economic Activity, the Central Register of Beneficial Owners, foreign entrepreneurs registers ). When personal data is obtained directly from the Data Subject, providing such data is voluntary, although necessary to achieve the purpose of personal data processing. Failure to provide personal data may make it impossible to achieve the intended purpose (e.g., concluding a service contract).

DATA RETENTION PERIOD: Wiewiórski Legal retains the personal data of contractors or their representatives for a period of 5 years, counting from the end of the year in which cooperation between the contractor and Wiewiórski Legal was concluded (particularly when the contract between the parties has been terminated).

DATA RECIPIENTS: Employees and associates of Wiewiórski Legal; Entities providing services to Wiewiórski Legal; consultants/subcontractors

Customers – individuals (including potential customers)

CATEGORIES OF PERSONAL DATA THAT MAY BE PROCESSED: First and last names, , PESEL number, Tax ID number (NIP), residential address, business address, bank account number, e-mail address, telephone number, signature and other personal data necessary to achieve the processing purpose

OBJECTIVES: Wiewiórski Legal processes personal data of its clients for the purpose of providing legal assistance to them, and personal data of contractors to conclude and perform contracts with the respective contractor.

LEGAL BASES:

• processing is necessary for the performance of a contract to which the data subject is party, or in order to take steps at the request of the data subject prior to entering into a contract (Article 6(1)(b) RODO), including activities aimed at concluding or executing a contract, such as the presenting offers, conducting negotiations, or maintaining ongoing communication during contract performance;
• processing is necessary for compliance with legal obligations imposed on Wiewiórski Legal (Article 6(1)(c) of the RODO), when applicable regulations require actions involving personal data processing, such as obligations arising from anti-money laundering and counter-terrorist financing laws, or verifying whether a client is included on the VAT taxpayers whitelist;
• processing is necessary for purposes arising from the legitimate interests pursued by Wiewiórski Legal (Article 6(1)(f) of the RODO), including sending offers, newsletters, or other informational or marketing materials related to Wiewiórski Legal’s activities, as well as pursuing or defending against claims;
• The data subject has provided consent to the processing (Article 6(1)(a) RODO)

DATA SOURCES: Wiewiórski Legal obtains clients’ personal data directly from them. In other cases, data may be acquired from publicly available sources (such as the Central Register and Information on Economic Activity, REGON register). When personal data is obtained directly from the Data Subject, providing such data is voluntary but necessary to achieve the processing purpose . Failure to provide personal data may result in the inability to achieve the intended purpose (e.g., entering into a service contract).

DATA PROCESSING PERIOD: Personal data processed by Wiewiórski Legal in connection with providing services to clients are retained for a period of 10 years from the end of the year in which the related proceedings concluded, pursuant to Article 5c(1)(2) of the Law on Legal Advisers.

DATA RECIPIENTS: Pracownicy i współpracownicy Wiewiórski Legal; Konsultanci / podwykonawcy Wiewiórski Legal; Podmioty świadczące usługi na rzecz Wiewiórski Legal.

Persons whose personal data are processed by Wiewiórski Legal in connection with the provision of legal assistance to clients

CATEGORIES OF PERSONAL DATA THAT MAY BE PROCESSED: First and last names, , PESEL number, Tax ID number, residential address, business address, bank account number, e-mail address, telephone number, signature and other personal data necessary to achieve the processing purpose.

OBJECTIVES: Wiewiórski Legal processes personal data of the designated Data Subjects in order to provide legal assistance to its clients.

LEGAL BASES: processing is necessary for the purposes arising from the legitimate interests pursued by Wiewiórski Legal (Article 6(1)(f) RODO), which include providing legal assistance to clients;

DATA SOURCES: Wiewiórski Legal generally obtains personal data from its clients. In other cases, data may be obtained from publicly available sources (such as the Register of Entrepreneurs of the National Court Register, the Central Register and Information on Economic Activity, the REGON register, the Central Register of Beneficial Owners).

DATA RETENTION PERIOD: Personal data processed by Wiewiórski Legal in connection with providing services to its clients are retained for a period of 10 years from the end of the year in which the related proceedings concluded, pursuant to Article 5c(1)(2) of the Law on Legal Advisers.

DATA RECIPIENTS: Employees and associates of Wiewiórski Legal; Consultants / subcontractors of Wiewiórski Legal; Entities providing services to Wiewiórski Legal; Clients.

Candidates in the recruitment process

CATEGORIES OF PERSONAL DATA THAT MAY BE PROCESSED: First and last names, date of birth, contact information provided by the Data Subject, education, professional qualifications, employment history and other personal data provided by candidates or necessary to achieve the purpose of processing.

OBJECTIVES: Conducting the recruitment process.

LEGAL BASES:

• processing is necessary for compliance with legal obligations imposed on Wiewiórski Legal (e.g. 221 § 1 of the Labor Code Act of June 26, 1974, in connection with e.g. 6(1)(c) of the DPA), arising from the labor law, if the parties intend to enter into an employment contract;
• processing is necessary for the performance of a contract to which the Data Subject is a party, or to take steps at the request of the Data Subject prior to entering into a contract (e.g. 6(1)(b) RODO), if the parties intend to enter into a contract other than an employment contract;
• consent of the Data Subject (e.g. 6(1)(a) of the DPA), where the Data Subject voluntarily provides Wiewiórski Legal with personal data beyond what is required by Wiewiórski Legal in the recruitment process;
• processing is necessary for purposes arising from the legitimate interests pursued by Wiewiórski Legal (e.g. 6(1)(f) RODO), related to the conducting the recruitment process, and pursuing or defending claims;
• consent of the Data Subject (e.g., 6(1)(a) RODO), if the Data Subject agrees to the processing of personal data for future recruitment purposes;

DATA SOURCES: Personal data of candidates in the recruitment process are obtained directly from the Data Subjects. Providing personal data is voluntary, but necessary to achieve the purpose of processing. Failure to provide personal data may make it impossible to achieve the intended purpose (e.g., concluding an employment contract).

DATA RETENTION PERIOD: Personal data of candidates in the recruitment process are retained for the duration of the recruitment process and for a period of 5 years from the date Wiewiórski Legal completes recruitment for a given position, for the purpose of defending against possible claims, and – if the candidate provides appropriate consent – for the future recruitment purposes

DATA RECIPIENTS: Employees and associates of Wiewiórski Legal; Entities providing services to Wiewiórski Legal; consultants/subcontractors.

Participants of trainings conducted by Wiewiórski Legal and recipients of marketing materials (including newsletters)

CATEGORIES OF PERSONAL DATA THAT MAY BE PROCESSED: First and last names, place of employment, position, email address and other personal data necessary for achieving the processing purpose.

OBJECTIVES: Conducting training sessions, direct marketing

LEGAL BASES:

• processing is necessary for the purposes arising from the legitimate interests pursued by Wiewiórski Legal (e.g. 6(1)(f) RODO), including activities essential for conducting training, such as the gathering participants data and contacting participants regarding the training
• consent provided by the Data Subject (e.g. 6(1)(a) RODO), where the Data Subject has agreed to receive marketing materials from Wiewiórski Legal;

DATA SOURCES: Wiewiórski Legal obtains personal data of training participants or recipients of marketing materials directly from them or from clients or other third parties interested in a particular training or receiving marketing materials. When personal data is obtained directly from the Data Subject, providing the data is voluntary, but necessary to achieve the intended purpose. Failure to provide personal data may prevent the achievement of this purpose (e.g., concluding a service contract).

DATA PROCESSING PERIOD: For training organization purposes, data is processed for up to 5 years following the completion of training or, in the case of recipients of marketing materials, until they opt out from receiving such materials

DATA RECIPIENTS: Employees and associates of Wiewiórski Legal; Consultants / subcontractors of Wiewiórski Legal; Entities providing services to Wiewiórski Legal.

Consultants or subcontractors, members of their staf

CATEGORIES OF PERSONAL DATA THAT MAY BE PROCESSED: First and last names, place of employment, position, e-mail address and other personal data necessary for achieving the processing purpose

OBJECTIVES: Cooperation in providing services by Wiewiórski Legal to its clients, such as document translations and legal or tax advice.

LEGAL BASES:

• processing is necessary for the performance of a contract to which the Data Subject is a party, or to take steps at the request of the Data Subject before entering into a contract (Article 6(1)(b) RODO), if the consultant/subcontractor is a natural person conducting business activity
• processing is necessary for purposes arising form legitimate interests pursued by Wiewiórski Legal (e.g., 6(1)(f) RODO), including cooperation in providing of services, when the consultant/subcontractor is a staff member of a legal entity or organizational unit with which Wiewiórski Legal cooperates;

DATA SOURCES: Wiewiórski Legal obtains personal data of consultants/subcontractors directly from them or from entities employing the respective consultant/subcontractor. When personal data are obtained directly from the Data Subject, providing such data is voluntary, but necessary to achieve the processing purpose . Failure to provide personal data may make it impossible to achieve the intended cooperation purpose )

DATA RETENTION PERIOD: Personal data processed by Wiewiórski Legal in connection with providing services to its clients are retained for 10 years from the end of the year in which the related proceedings concluded, pursuant to Article 5c(1)(2) of the Law on Legal Advisers.

DATA RECIPIENTS: Employees and associates of Wiewiórski Legal; Entities providing services to Wiewiórski Legal, consultants/subcontractors.

Social media users

CATEGORIES OF PERSONAL DATA THAT MAY BE PROCESSED: First and last names, email address, social media profile address, place of employment, other personal data provided by the Data Subject or necessary to achieve the purpose of processing.

OBJECTIVES: Maintaining Wiewiórski Legal’s social media profiles, establishing contacts with other users, responding to messages from other users’, direct marketing.

LEGAL BASES:

• processing is necessary for the purposes arising from legitimate interests pursued by Wiewiórski Legal (Article 6(1)(f) RODO), including maintaining a social media profiles and, for example, establishing andmaintaining relationships with other users, providing information about Wiewiórski Legal’s activities (including its services), and pursuing or defending against claims;
• consent provided by the Data Subject (e.g. 6(1)(a) RODO), when the Data Subject agrees to receive marketing materials from Wiewiórski Legal

DATA SOURCES: Wiewiórski Legal obtains personal data of social media users directly from them. In other cases, the data may be collected from other sources (e.g. other social media users, social media platform operators, public registers). When personal data is obtained directly from the Data Subject, providing this data is voluntary, but necessary to achieve the intended purpose. Failure to provide personal data may may make it impossible to achieve the intended objective (e.g., establishing a business relationship).

DATA RETENTION PERIOD: For the duration of Wiewiórski Legal’s social media profile on a given platform and for 6 months following the closure of that profile.

DATA RECIPIENTS: Employees and associates of Wiewiórski Legal; Entities providing services to Wiewiórski Legal; consultants/subcontractors

Persons contacting Wiewiórski Legal for other matters

CATEGORIES OF PERSONAL DATA THAT MAY BE PROCESSED: First and last names, , e-mail address, telephone number, residential address, business address, and other personal data provided by the Data Subject or necessary to achieve the purpose of processing.

OBJECTIVES: Responding to inquiries or contact initiated by the Data Subject, managing inquiries sent by a Data Subject, etc.,

LEGAL BASES: Processing is necessary for purposes arising from legitimate interests pursued by Wiewiórski Legal (Article 6(1)(f) of the DPA), which include managing contact with the Data Subject, and pursuing or defending against claims.

DATA SOURCES: Wiewiórski Legal obtains the personal data from individuals contacting the firm directly from them. In other cases, the data may be obtained from publicly available sources (e.g. Central Register and Information on Economic Activity, REGON register). When personal data is obtained directly from the Data Subject, providing this data is voluntary, but necessary to achieve the intended purpose. Failure to provide personal data may prevent achieving the intended objective (e.g., concluding a service contract).

DATA RETENTION PERIOD: 10 years from the end of contact, unless another legal relationship, defined in this Policy Is established which justifies a longer retention of personal data.

DATA RECIPIENTS: Employees and associates of Wiewiórski Legal; consultants/subcontractors, entities providing services to Wiewiórski Legal

RECIPIENTS OF PERSONAL DATA

Definitions of recipient groups are provided below. Information on categories of recipients to whom personal data may be transferred is included next to each category of personal data.

Employees and associates of Wiewiórski Legal: Legal advisors, attorneys, trainees and other employees and associates of Wiewiórski Legal may process personal data processed by Wiewiórski Legal if it necessary for performing their duties. All these persons are authorized to process personal data and are obligated to maintain confidentiality according to applicable law (e.g., legal advisors) or based on agreements concluded with Wiewiórski Legal.

Consultants / subcontractors Wiewiórski Legal: In providing services, Wiewiórski Legal may engage third parties, such as tax advisors or other lawyers, who do not permanently cooperate with Wiewiórski Legal. These recipients are obliged to maintain confidentiality according to applicable law (e.g., legal advisors) or agreements concluded with Wiewiórski Legal

Entities providing services to Wiewiórski Legal: Wiewiórski Legal may transfer personal data to entities providing services to Wiewiórski Legal, such as IT or marketing services. Additionally, Wiewiórski Legal collaborates with external partners and may transfer personal data to them, for example during recruitment process.

Clients: Some personal data collected by Wiewiórski Legal may be transferred to its Clients in the course of providing services to them. In this context, Clients also include other entities within the Client’s corporate group.

TRANSFER OF PERSONAL DATA TO THIRD COUNTRIES / INTERNATIONAL ORGANIZATIONS

Third countries and international organizations: Wiewiórski Legal generally does not transfer personal data to third countries or international organizations. If personal data is transferred to third countries, including those that do not ensure an adequate level of protection, such data is transferred to entities obliged to ensure an adequate level of personal data protection, e.g. by using standard contractual clauses approved by the European Commission. Due to the use of Microsoft products, Wiewiórski Legal may transfer personal data to third countries (e.g., when storing data on Microsoft cloud servers). Microsoft’s privacy policy including information on transfers to third countries is available at: https://privacy.microsoft.com/pl-pl/data-privacy-notice.

PERSONAL DATA RETENTION PERIODS

The information below supplements details about standard data retention periods provided alongside specific categories of personal data processed by Wiewiórski Legal.

Accounting documents: Accounting documents, and personal data recorded therein, are stored for the period required by applicable law, i.e. 5 years counting from the end of the year in which the the tax payment deadline related to the document occured.

Extended storage period: In special circumstances, particularly in case of a disputes or claims, the above-mentioned retention periods may be extended until the statute of limitations for claims expires.

RIGHTS OF DATA SUBJECTS

Entitlements: Data Subjects have the right to access their personal data, rectify, erase restrict processing, object to processing, and data portability. These rights may be subject to limitations specified by applicable laws, particularly the GDPR.

Contact: To exercise these rights, you can contact Wiewiórski Legal by sending a message to: 81 Św. Mikołaja Street, 50-126 Wrocław or by email: daneosobowe@wiewiorski.pl.

AUTOMATED DECISION-MAKING

Wiewiórski Legal does not make automated decisions regarding personal data processing.

COMPLAINT TO SUPERVISORY AUTHORITY

President of Personal Data Protection Office (PUODO): Data Subjects have the right to lodge a complaint with the supervisory authority – the President of the Personal Data Protection Office.

COOKIES

What are cookies? Cookies are text files composed of letters and numbers stored on your web browser, computer hard drive , or mobile device. There are three basic types of cookies:

1. session cookies: specific to a particular visit, limited to sending a so-called session ID (a random string of digits generated by the server). Session cookies are not permanently stored on the device and are deleted when the browser is closed;
2. permanent cookies: files that record information about your preferences, are stored in the cache memory of your browser or mobile device; and
3. Third-party cookies: placed by third parties to collect data from a number of different websites or sessions.

What kind of cookies do we use? We use the following cookies:

1. Strictly necessary cookies, i.e. cookies that enable the use of the website and its various functions. The information collected relates to how the website is used.
2. analytical cookies. These are cookies that collect information about how users use the website, such as which pages they visit most often, whether they receive error messages, and how they came to our website. The information collected by these types of cookies is used solely to improve the user experience of our website. Sometimes these types of cookies are placed by third parties that provide web traffic and analytics services. We use Google Analytics tools
3. functional cookies. Cookies that allow you to remember choices you have made, such as the language you have chosen and other parameters of individual web pages.
4. advertising cookies. The files record your visit to our website, the pages you visited. This information allows us to measure the effectiveness of marketing or information activities.We may share information with third parties for this specific purpose.

Types of cookies we use:

How do I block cookies? The default settings of most browsers assume that consent to cookies has been given. To block or delete cookies, please refer to your browser’s help tab for instructions on how to block or delete cookies. For more information on how to disable cookies, visit their websites and their cookie policies.