One of the priorities of the Privacy Policy in force at Concession Europe Sp. z o.o. is respecting the privacy of people visiting the Company’s website.

1. Who is responsible for data processing and who can be contacted? The controller of your personal data is Concession Europe Sp. z o.o., with its registered office at (15-688) Białystok, ul. Gen. George Smitha Pattona 4, hereinafter referred to as the “Controller” or “Concession”, which can be contacted:
   
   • in writing, by sending correspondence to the following address: (15-688) Białystok, ul. Gen. George’a Smitha Pattona 4,
   • by phone, at +48 222903727
   • e-mail: info@concession.pl
2. Why, for what purpose and on what legal basis do we process your personal data? Concession Europe processes your personal data in connection with:
   – recruitment process,
   – concluding an employment contract,
   – signing civil law contracts,
   – signing a contract with other business entities.
   – your subscription to the newsletter.
   1. The processing of personal data of job candidates is carried out on the basis of Article 221 § 1 of the Labor Code and Article 6 paragraph 1 point a) of the GDPR and on the basis of your consent to the processing of data
   2. The processing of employees’ personal data is based on:
      
      • art. 22¹ §1 of the Labour Code and Article 6 paragraph 1 point b) of the GDPR – processing is necessary for the performance of a contract to which the data subject is a party,
      • art. 6 paragraph 1 point f) of the GDPR, processing is necessary for the purposes of the legitimate interests pursued by the Controller (protection of claims),
      • art. 22¹§ 4 of the Labor Code and Art. 6 paragraph 1 point c) of the GDPR, processing is necessary for the performance of a legal obligation incumbent on the Controller (this is related to the Controller’s obligations in the field of tax law and social security).
      • art. 22¹ § 5 Labor Code and Article 6, paragraph 1, point a) of the GDPR – consent expressed by the employee
   3. The processing of personal data of persons who are parties to a civil law contract is carried out on the basis of:
      
      • Article 6, paragraph 1, point b) of the GDPR – processing is necessary for the performance of a contract to which the data subject is a party,
      • Article 6(1)(f) of the GDPR – processing is necessary for the purposes of the legitimate interests pursued by the Controller (protection of claims),
      • art. 6 sec. 1 point c) – processing is necessary to fulfil a legal obligation incumbent on the Controller (this is related to the Controller’s obligations in the field of tax law and social security).
   4. In connection with signing an agreement with other business entities, the Administrator will process personal data of the following persons:
      
      • negotiating contracts on behalf of the contractor (pursuant to Article 6(1)(f) of the GDPR);
      • signing contracts on behalf of the contractor (pursuant to Article 6(1)(f) of the GDPR);
      • performing specific tasks in connection with the signing of a commercial agreement by Concession Europe (pursuant to Article 6(1)(f) of the GDPR);
      • representatives of contractors (pursuant to Article 6(1)(f) of the GDPR); The processing of personal data listed above pursuant to Article 6(1)(f) of the GDPR is carried out for the purpose of possible pursuit of claims or defence against claims and is related to the protection of the Controller’s rights.
   5. The processing of your data in connection with subscribing to the Newsletter is based on your consent (Article 6(1)(a) of the GDPR) and on the legitimate interest of the controller (Article 6(1)(f) of the GDPR) consisting in conducting marketing activities. Your data will be processed:
      
      • within the scope specified by the entity for which you provide services or work. The scope of the data provided includes: first name, surname, position, e-mail address, telephone number or other contact details necessary for electronic communication for the purpose of performing the contract signed with Concession.
      • for the purpose of settling accounts with the competent authorities and archiving documents, to the extent required by law, in particular by the provisions of the Tax Ordinance and the Accounting Act, as well as the Anti-Money Laundering Act. The legal basis for the processing of your data results from the obligations imposed on the Controller, pursuant to Article 6(1)(c) of the GDPR.
3. Who we may share your personal data with.
   
   1. The data of job applicants will be made available to the Management Board of Concession Europe Sp. z o. o. and to the Company’s employees involved in the recruitment process.
   2. The Company’s employee data will be available to authorised employees dealing with human resources and tax matters.
   3. The data of persons representing contractors will be made available to employees of Concession Europe Sp. z o.o. who are directly negotiating and/or signing a contract with you and/or performing a signed contract, as well as to employees providing accounting services.

   4. Your data may be disclosed to other recipients for the purpose of performing a contract with you and/or for the purpose of fulfilling a legal obligation incumbent on Concession Europe, based on your consent or for purposes arising from the legitimate interests of the Controller or a contractor of Concession Europe. The recipients of the data may include, in particular, relevant government agencies (including tax authorities and the National Insurance Institution).

4. Will your data be transferred to a third country (outside the European Union)?
   
   1. Your data will not be transferred to a third country.
   2. If Concession Europe intends to transfer data to a third country, it will ask you for your consent in accordance with Article 49(1)(a) and (b) of the GDPR.
5. How long your data will be processed (stored).
   
   1. Your data will be processed for the period necessary to achieve the purposes of processing specified in section 2 of this Privacy Policy, i.e.:
      
      • during the recruitment process, until the process is completed. If the candidate is not hired, the data they have sent will be destroyed immediately and the documents sent will be returned to the sender.
      • During the period of employment, employee data will be processed for the entire period of employment, and after its termination, for the period required by applicable regulations related to tax law and social security. In the event of legal proceedings related to the employee’s employment, their data will be stored until the final conclusion of the proceedings.
      • in relation to the performance of the agreement concluded with Concession Europe, until its completion, and thereafter for the period required by law or for the pursuit of any claims.
      • in terms of fulfilling the legal obligations incumbent on Concession Europe in connection with its business activities and the performance of concluded agreements, until such obligations are fulfilled by Concession Europe.
      • in the scope of processing carried out on the basis of consent, until you request the deletion of your data.
      • until the legitimate interests of Concession Europe, which form the basis for this processing, have been fulfilled, or until you object to such processing, unless there are legitimate grounds for further processing of the data.
   2. Your personal data, processed during contract negotiations with the entity representing you or your employer, will be stored until we receive information that the contract has not been signed.
   3. Your personal data processed in connection with the signing and/or performance of a commercial contract will be stored for the period during which claims related to commercial activities may be filed (i.e. for 3 years from the date of signing the contract), and in the event of claims being filed, your data will be stored until the court proceedings are concluded.

   4. Your personal data stored in connection with the performance of legal obligations imposed on Concession Europe Sp. z o.o. o. by the provisions of the Anti-Money Laundering Act, will be stored for a period of 5 years from the end of the year in which the business activity was terminated, unless the General Inspector of Financial Information, on the basis of these provisions, requests that this documentation be stored for a longer period.

   5. Your data will be stored for a period of 5 years for tax and accounting purposes, calculated from the end of the year in which the financial event took place.

   6. Your personal data will be stored for the duration of the contract and after its termination for the following purposes: pursuing claims in connection with the performance of the contract, fulfilling obligations arising from legal provisions, including in particular tax, accounting, statistical and archiving obligations, for the period specified in the relevant legal provisions.
6. What rights do you have to ensure that your data is properly protected?
   
   1. You have the right to obtain confirmation from the Controller as to whether your personal data are being processed and, if confirmation is obtained, to request information on the purpose of processing, the category of data being processed, the recipients of the data, the period of data processing, the right to request rectification, deletion or limitation of data processing, the right to transfer data and to object to their processing.
   2. You have the right to withdraw your previously granted consent to the processing of data to the extent covered by such consent at any time, provided that the withdrawal of consent will not affect the lawfulness of processing based on consent before its withdrawal;
   3. You have the right to obtain information about the source of access to your data.
   4. You have the right to lodge a complaint with the President of Personal Data Protection if you believe that the processing of your data violates the provisions of the GDPR.
   5. Furthermore, you have the right to object to data processing at any time:
      
      • for reasons related to your particular situation, unless the Controller demonstrates the existence of valid legitimate grounds for processing, overriding your rights, which concern the exercise or defense of claims (Article 21(1) of the GDPR),
      • for direct marketing purposes, including profiling for marketing purposes, to the extent that the data processing is related to direct marketing (Article 21(2) of the GDPR).
7. Are you obligated to provide data?
   
   1. ​​Providing your personal data is voluntary, however, it is necessary to start the recruitment process, conclude an employment contract, conduct negotiations related to the conclusion of a contract with a business contractor, and perform a contract with the entity you represent or which is your principal.
   2. If you do not provide your personal data, the conclusion and performance of the contract will be impossible and, in some cases, very difficult.
   3. If you do not provide your personal data for the purposes of obligations arising from the provisions of the Act on Combating Money Laundering and Terrorist Financing, Concession Europe will not be able to conclude an agreement with you or with the entity you represent.
8. Where do we obtain your data from and what are its categories?
   
   1. Most of the data processed by Concession Europe comes directly from you, in particular data obtained from you during the recruitment and employment process.
   2. We obtain personal data of entrepreneurs from them directly or from other public sources, i.e. from the National Court Register or the Central Register of Business Activity.
   3. In the case of data of persons representing entrepreneurs or acting in any other way on their behalf, we also obtain data from the above-mentioned sources and from the entrepreneurs themselves.
9. Information on automated decision-making regarding personal data processing, including profiling.
   
   1. Your personal data will not be used by Concession Europe for automatic decision-making regarding the processing of such data or for profiling.
10. Possibility of contact
    
    1. Concession Europe uses the email address provided above, as well as the work addresses and email addresses of its employees, to respond to requests for quotes, during contract negotiations, during contract execution, and in the recruitment process. To protect against unauthorized third-party access to email correspondence, Concession Europe uses appropriate security measures; however, encrypted correspondence is preferred.
    2. In addition, interested parties can contact Concession Europe Sp. z o.o. by submitting the form available on the website concession.pl/pl/kontakt. In the form, Concession Europe asks for the following information:
       
       • name and surname (not mandatory),
       • e-mail address (necessary to establish and continue contact),
       • message content (necessary to specify the query).
       • The completion of the mandatory data by the sender is a condition for establishing contact with the person concerned and clarifying all inquiries.
    3. The personal data provided in this way are processed:
       
       • in order to take the necessary steps before signing a contract or to perform a contract with the person indicated as the sender of the e-mail (Article 6(1)(b) of the GDPR);
       • for statistical purposes related to the scope of submitted inquiries (Article 6(1)(f) of the GDPR).
11. Data SecurityOnly authorized individuals have access to personal data at the Controller. The data is used only to the extent necessary to perform contracts. The Controller ensures that employees with access to personal data participate in personal data protection training. To minimize the risks associated with a breach or leak of personal data, Concession Europe Sp. z o.o. has appropriate procedures and technical safeguards in place.

12. Cookies: Cookies (commonly referred to as cookies) are computer data, most often text files, stored on the end device of a website user. Cookies are located on the Concession Europe website.

    Concession Europe uses cookies to collect statistics and ensure the proper functioning of the website. Anyone accessing the Concession Europe website can disable cookies without being logged out.

13. Changes to the Privacy Policy
    In the event of any changes to the Administrator’s data or other information listed in the Privacy Policy, the Administrator will immediately update this document.

This Privacy Policy is effective at Concession Europe Sp. z o.o. from August 1, 2022.