- During a visit to our Website, both data, for which reference to a specific person cannot be excluded, and Personal Data that you provide as a result of your activities, is obtained. We treat all this information as Personal Data.
- We respect the privacy of our Users, therefore we provide this document so that you know to what extent your Personal Data is processed, and you can independently, consciously and freely decide whether you wish to use our Website.
- Personal Data – all information about a natural person identified or identifiable by one or more specific factors determining the physical, physiological, genetic, mental, economic, cultural or social identity, including device IP, location data, internet identifier and information collected via Cookies and other similar technology.
- Cookies – small files stored on your computer or mobile device. They have unique identifiers assigned to the User’s device and allow the Website to remember your actions and preferences over time, such as: location, language, font size and others. This way, you do not have to re-enter information each time you return to our Website or browse page after page. Cookies can also help customize your browsing experience on our Website.
- Website – the website maintained by the Co-administrators at www.tlhub.pl.
- User, You – any natural person who uses the Website.
- GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals 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).
- TL HUB – the name includes the following companies (all with their registered office in Poznań): TL HUB sp. z o.o., TL HUB Chłosta Kołodziejczyk Matuszczak Doradcy Podatkowi sp.p., TL HUB Leśkiewicz Jarosiński Błaszyk sp. k., TL HUB Nieruchomości sp. z o.o., TL HUB Outsourcing sp. z o.o., running the Website – hereinafter jointly also referred to as the “Co-administrators” and each separately the “Administrator”.
3. [Principles of co-administration of Personal Data]
Please be advised that the Co-administrators have concluded an agreement on the co-administration of Personal Data.
As part of the agreement, the following responsibilities have been agreed regarding the fulfilment of obligations under the GDPR regarding the functioning of the Website:
- Each of the Administrators is responsible for handling the rights of the Personal Data subjects;
- A single point of contact has been established that can be used for the protection of Personal Data via e-mail: [email protected], telephone +48 61 898 73 00 or in writing to the correspondence address of the Co-administrators, i.e. ul. Szelągowska 24, 61-626 Poznań.
4. [Generalprinciplesfor the processing of Personal Data]
- TL HUB collects and processes Personal Data in accordance with applicable law, in particular in accordance with the provisions of the GDPR and the principles for the processing of Personal Data provided for therein in connection with their business activity.
- When collecting and processing Personal Data, we adhere to the following principles:
- We collect Personal Data only to the minimum extent necessary to achieve the purposes for which it is collected.
- The purposes of collecting Users’ Personal Data are clearly defined, based on legal provisions – we do not process Personal Data in a manner inconsistent with these purposes.
- We care about the validity and correctness of Users’ Personal Data and we immediately respond to requests for rectification or updating of Personal Data.
- We implement all Users’ rights provided for in the provisions of the GDPR.
- We limit the storage of Personal Data in accordance with the law, only to the period necessary to achieve the purposes for which it is collected, unless there are events that may extend the period of storage of Personal Data.
- We protect Users’ personal data against loss, unauthorized access, accidental loss or alteration and other unlawful forms of processing.
- If Personal Data is shared with other entities, it is done in a safe, contractually secured manner and in accordance with applicable law.
5 [Detailedprinciplesfor the processing of Personal Data]
When using the Website, we may process your Personal Data for various purposes, depending on the process of processing Personal Data:
1. Correspondence contact.
The processing of Personal Data takes place when you contact us by e-mail or correspondence. Handling your application requires us to process your Personal Data. We then process the following scope of Personal Data: name and surname, correspondence address, e-mail address, information contained in the correspondence and its headers.
Unless correspondence, including e-mail correspondence, is related to the conclusion or execution of a contract, then the basis for processing is your consent resulting from initiating contact, then also our legitimate interest in handling correspondence, including establishing contact with people in the future who contacted us and archiving correspondence for the purpose of showing its course in the future (art. 6 (1) (f) GDPR).
2. Contact form.
TL HUB provides the possibility of contact via the contact form on the Website. Using the form requires providing appropriate data enabling TL HUB to provide a reply.
The scope of Personal Data that we process: name, surname, email address, other data provided to contact TL HUB or to facilitate this contact.
In such a situation Personal Data is processed in order to identify the User and to reply to his/her message sent via the contact form. The legal basis for processing is consent given by the User via this form (art. 6 (1) (a) GDPR).
3. Sending an offer. Provision of services.
The Administrator sends information about their offer, and also provides services via the Website to people who have provided their e-mail address and consented to the provision of electronic services. Providing Personal Data in order to receive information regarding the Administrator’s offer or provision of a service is voluntary. The Administrator sends such information only if the User has given his/her consent, which he/she may withdraw at any time – without affecting the lawfulness of the processing carried out prior to its withdrawal. The consent to this form of contact is based on art. 10 sec. 2 of the Act of 18 July 2002 on the provision of electronic services (i.e. Journal of Laws 2020, item 344) and art. 172 sec. 1 of the Act of 16 July 2004 Telecommunications Law (i.e. Journal of Laws 2019, item 2460).
Personal Data is processed in order to send information about the offer, or as part of the provision of electronic services by TL HUB – the legal basis for processing is art. 6 (1) (b) GDPR and art. 6 (1) (f) GDPR.
4. Contact via LinkedIn.
TL HUB has profiles in public social media – i.e. on LinkedIn. TL HUB processes Personal Data that is left by visitors to these profiles in the form of comments, reactions and internet identifiers.
Scope of Personal Data that we process: comments, likes, online identifiers.
Legal basis: The legal basis for the processing of Personal Data is the legitimate interest of TL HUB consisting in enabling Users to be active on these profiles, effectively maintaining profiles by providing LinkedIn Users with information about the activities of TL HUB and promoting own services (art. 6 (1) (f) GDPR).
5. Recruitment process.
As part of the recruitment processes, we will process your Personal Data included in the application form available on our Website, such as: name, surname, telephone number, e-mail address, information for which position you are applying and documents attached by you, such as CV. We will process Personal Data to the extent necessary to assess your qualifications as a candidate for the position for which you are applying. We want to assess the ability and skills needed to work on the basis of the Personal Data sent by you. With separate consent, we will also process Personal Data that will be needed as part of future recruitment processes.
Scope of Personal Data that we process: data provided in the CV and in the application form.
If the planned form of employment is an employment contract – in order to perform the obligations related to the employment process and due to the necessity to take appropriate measures to conclude an employment contract, the legal basis is art. 6 (1) (b) GDPR and consent – in accordance with art. 6 (1) (a) GDPR.
However, if the planned form of employment is a civil law contract – in order to conduct the recruitment process for a given position, verify the qualifications and skills of the candidate and determine the terms of cooperation, the legal basis will be art. 6 (1) (a) GDPR.
If you consent to the processing of your Personal Data for the purposes of future recruitment processes, the legal basis is art. 6 (1) (a) GDPR.
6. Establishing, investigating or defending against claims.
TL HUB processes Users’ personal data in order to establish, investigate or defend against claims, such as: name, surname, e-mail address, information on consents or other data necessary to prove the existence of the claim or the extent of the damage suffered.
The legal basis for the processed Personal Data is the legitimate interest of TL HUB consisting in the establishment, investigation or defence of claims before competent courts and state authorities (art. 6 (1) (f) GDPR).
7. TL HUB processes Personal Data as part of Cookies, on the terms set out in § 6 below.
6. [Principles of processing cookies]
- There are two general categories of Cookies: Persistent and Session. Persistent Cookies remain on your device until they are deleted manually or automatically. Session Cookies remain on your device until you close your browser, when they are automatically deleted.
- enable Users to use services provided by TL HUB;
- improve TL HUB internet products and services;
- personalize and optimize Users’ use of our Website in terms of e.g. text size, language and screen resolution;
- provide additional services (e.g. Social Media Cookies).
4. Necessary Cookies are needed for us to offer a properly functioning Website, which enables the use of services provided by TL HUB. If cookies are blocked, you will not be able to use our Website.
5. Analytical and performance cookies help us measure the volume of traffic to determine which areas of our Website have been visited. We use this to research the habits of visitors to improve our online products and services. We may record IP addresses (i.e. electronic addresses of computers connected to the Internet) to analyse trends, administer the Website, track Users’ movements and collect general demographic information. These Cookies are not necessary to use the Website and we will always ask for your consent before placing them. You can withdraw your consent to our use of them at any time.
6. Our Portal may contain Cookies from third parties, such as social media (e.g. clicking on “Share on Linkedin” may result in placing LinkedIn Cookies in the User’s browser).
7. It is possible to restrict or block Cookies, and even delete them from your device. In this case, you may not be able to access certain areas of our Website and we may believe that you have never visited us before, therefore we will show you the Cookie Notice again and ask for your consent to the placement of these Cookies.
8. You can limit or block Cookies at any time by changing the settings of your browser. To determine how to manage your Cookie settings, please check the exact information in the help section of your browser.
9. If you have any questions, comments or complaints regarding Cookies, please contact us via the Contact Form or by e-mail: [email protected].
7. [Period of personal data processing]
- Personal Data will be stored for the time necessary to achieve the purposes for which the Personal Data was collected.
- In the case of Personal Data processing based on consent, Personal Data will be stored until its withdrawal.
- However, in any case, the storage period may change, i.e. Personal Data may be stored longer, if such an obligation results from legal provisions or it is necessary to establish, defend or pursue claims (e.g. until the claims are time-barred, we may keep evidence of the consent granted by the User), or shorter, e.g. in the case of fulfilling the request to delete Personal Data.
- The period of storage of Personal Data is determined in accordance with applicable law. The User has the right to obtain information from us about the planned and probable period of storage of Personal Data.
- Each of the Co-administrators may be involved in the processing of your Personal Data at various stages and to a varying degree, sometimes pursuing their own, individual, closely related purposes. Ultimately, the common purpose of all companies is to sell services.
- After the end of the processing period, Personal Data is irreversibly deleted or anonymized.
- Each of the Co-administrators will be responsible for the implementation of the rights of the Personal Data subjects on their own due to the fact that, apart from common systems or platforms, Personal Data of customers or potential customers may also be processed in independent IT processes or systems. Nevertheless, in any case, you can use the designated TL HUB Contact Point.
8. [Rights related to the processing of Personal Data]
- Depending on how you use the Website and on what basis and for what purpose we process your Personal Data, you may be entitled to all or selected rights listed below.
- You always have the right to:
- Access to your Personal Data and receive a copy thereof.
On this basis, TL HUB provides the natural person requesting access to Personal Data or receiving its copy, information on the processing of this Personal Data, including the purposes and legal bases for processing, the scope of the information held, entities to which the Personal Data is disclosed and the planned date of its deletion. In the event that the requested information is covered by professional secrecy (advocate or legal adviser), TL HUB will not be able to comply with the above request.
- Correct (rectify) your Personal Data.
TL HUB is obliged to remove any possible inconsistencies or errors regarding the processed Personal Data and to supplement it, when its scope requires supplementing.
- File a complaint to the President of the Personal Data Protection Office.
If it is found that the processing of Personal Data by TL HUB violates the provisions of the GDPR or other provisions on the protection of Personal Data, the User may submit a complaint to the body supervising the processing of Personal Data – i.e. to the President of the Personal Data Protection Office at the address of the Personal Data Protection Office, i.e. ul. Stawki 2, 00-193 Warsaw.
3. In certain cases, you have the right to:
4. Withdraw your consent to the processing of Personal Data, if the basis for their processing is consent. You can withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of the processing that TL HUB made based on your consent before its withdrawal.
5. Object to the processing of Personal Data.
6. You can object at any time to the processing of your Personal Data by us, if the basis for such processing is the legitimate interest of TL HUB.
7. Restrict the processing of Personal Data.
8. You have the right to restrict the processing of your Personal Data, which means that during the period of restriction of processing, we can only store your Personal Data.
You can request us to restrict the processing of your Personal Data if, for example, you question the accuracy of your Personal Data – for a period that allows us to check the correctness of this Personal Data; when the processing of your Personal Data is unlawful, and you oppose the deletion of Personal Data, requesting the restriction of its use instead; when we no longer need your Personal Data for processing purposes, but you need it to establish, assert or defend claims; when you have objected to the processing – until we determine whether the legitimate bases on our side override the bases of your objection.
9. Delete your Personal Data.
You have the right to request us to delete all or some of your Personal Data if, for example: Your Personal Data is no longer necessary for the purposes for which it was collected or otherwise processed; when you have withdrawn your consent to the processing of your Personal Data, and we have processed this Personal Data based on your consent; when you objected to the processing of your Personal Data on the basis of our legitimate interest and the objection was justified, your Personal Data was processed unlawfully.
10. Transfer your Personal Data.
You have the right to receive from us your Personal Data that you have provided to us and which we process on the basis of your consent or concluded contract. Moreover, you can indicate that we are to send this Personal Data, in a commonly used format, to another data administrator, if technically possible.
9. [Recipients of Personal Data]
- Personal Data may be disclosed to external entities, including in particular suppliers responsible for the operation of IT systems and equipment, entities providing postal and courier services or marketing agencies.
- Your Personal Data may be processed by third parties only if such an entity undertakes to provide appropriate technical and organizational measures to ensure the security of Personal Data processing, as well as to maintain the confidentiality of such Personal Data. We may also share your Personal Data with other recipients who are processors – providing services upon our commission and on our behalf, to whom we will commission activities requiring the processing of Personal Data in connection with the processing of Personal Data, transport data, archiving, handling correspondence, auditors, professional advisers. In some cases, external entities providing services upon our commission may act as independent administrators, e.g. the Polish Post Office or other postal operators, payment transaction operators.
10. [Children’s privacy]
- Forms collecting Personal Data on the Website, Cookies and similar technologies are intended for adults. Therefore, TL HUB does not knowingly process Personal Data of children under the age of 16. Consents expressed by Users are legally valid for persons over 16 years of age.
- If you are under the age of 16 you should not give us any information.
- If TL HUB becomes aware that a person under the age of 16 has provided us with Personal Data without verifiable parental consent, we will not process such Personal Data.
11. [Final provisions]
- If, as part of the processing, Users’ Personal Data is transferred to recipients in third countries (outside the EEA), such transfer of Personal Data will take place on the basis of the requirements specified by the European Commission or on the basis of your express consent.
- Co-administrators will not use automated decision making.
- Provision of Personal Data is voluntary, but necessary to enter and use the Website. Without providing your Personal Data, it is not possible to establish a connection and read the content of the Website.