Information on the processing of Your personal data by emplo for marketing purposes 

 

Explanation of terms used in this information: 

GDPR - 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) (OJ L 119, 4.5.2016, p. 1-88)

emplo, we, our, ours, us - Emplo sp. z o.o., address: ul. Prosta 68, 00-838 Warsaw, email: contact@emplo.com

Your personal data

For the purpose of carrying out marketing activities and forwarding emplo’s marketing and commercial information to You, we are using the following information about You:

1) Data You provide directly to emplo as well as data collected by emplo from public sources, that is Your full name, email address, telephone number, company name, address, industry, number of people Your company employs, position in the company, Your newsletter preferences; and

2) Data we collect automatically through cookies and data resulting from Your browsing activity on emplo’s websites (emplo.com and emplo.pl), including in particular information concerning the pages you’ve visited.

Your data controller

Your personal data will be administered by emplo sp. z o.o. with its registered office in Warsaw, ul. Prosta 68, 00-838 Warsaw; email: abi@emplo.pl

The purpose and legal grounds for the processing of Your data

emplo’s marketing activities

To conduct marketing activities addressed to businesses, we are processing Your personal data based on the legitimate interests pursued by emplo (legal basis: Article 6(1)(f) of the GDPR). Our legitimate interests involve the use of Your professional data for the purpose of direct marketing of our products and services solely in B2B (business-to-business) relations, provided that you’ve expressed your consent to communication by email or phone in order to receive marketing and commercial materials from emplo or agreed to the use of cookies on our pages. Having considered our and Your interests, rights, and freedoms, we concluded that we would not intrude too far into Your privacy. Read more about profiling in the section below – Profiling Your preferences and interests.

Profiling Your preferences and interests 

In order to carry out marketing activities, we are profiling Your preferences and interest so as to best match emplo’s marketing communication to Your needs, which also includes tailoring our product and service offering. We evaluate Your preferences and needs based on data (1) collected via our systems supporting the correct performance of our services, e.g. the CRM system, system for registering applications, and online marketing systems; and (2) data collected automatically (registered and stored) by means of cookies and data resulting from Your browsing activity on emplo’s websites or similar pages owned by emplo. As a result of our profiling activities, we are able to provide marketing messages concerning emplo’s products and services by email, phone, or through our websites and ensure that our marketing communication is personalized. Our communication may also display on websites owned by entities that are in no way related to emplo but are providing advertising services to us, e.g., pages owned by Google or Facebook’s advertising networks.

Our profiling activities will not result in refusing Your access to our services. In exceptional cases, profiling may, however, lead to differentiating our offering addressed to different people who are in a comparable situation.

Profiling is carried out based on the legitimate interests pursued by emplo (legal basis: Article 6(1)(f) of the GDPR), which involve conducting marketing communication activities that will be attractive and tailored to Your needs and interests. Having considered our and Your interests, rights, and freedoms, we concluded that we would not intrude too far into Your privacy and that our activities will not cause any significant effects, including legal, for You, and their only objective will be to increase the attractiveness of our offering.

Our activities concern only professional relations. We are not collecting information that could enable us to access your private life. On the contrary, we are collecting only information related to your professional activity and to a very limited extent.

Read more about how emplo uses cookies in our Cookie Policy.

Recipients of Your data

We transfer Your personal data to the following categories of recipients: emplo’s employees and associates, hosting services providers, providers of customer service support tools (e.g. CRM, ticketing system, chat), providers of accounting systems, providers of online marketing systems, analytical services providers, providers of services to support emplo’s marketing activities (e.g. advertising agencies, training providers, and event organizers), as well as to public administration authorities (if it follows from any provision of law or an administrative or judicial decision).

Time limit for data storage 

We are storing Your personal data for marketing purposes until You opt out of receiving marketing and commercial information from emplo or associated companies (withdrawal of Your consent or objection), but for no longer than 3 years starting from the day of Your last activity and involvement in emplo’s online or offline marketing events and campaigns. Your activity and involvement means any kind of action which may indicate Your interest in emplo’s services or marketing event, e.g. participation in a marketing event (conference, training, satisfaction survey), opening an advertising mailing, entering emplo’s website or using emplo’s services. Within the period of 3 years since your last activity, Your personal data will no longer be actively processed – they will be only stored. Following this period, Your personal data will be deleted or anonymized.

Transferring Your personal data to countries outside the EU

Your personal data are transferred to our providers of CRM systems, analytical services, and online marketing systems who may process them outside the EU. We’ve made sure that our providers are ensuring an equally high level of protection of personal data as in the case of providers processing data in the EU. Such guarantees result in particular from:

- the location of providers in countries outside the EU which ensure an adequate level of protection for personal data in accordance with the Commission decisions;;

- the providers’ obligation to adhere to standard data protection clauses adopted by the European Commission (http://eur-lex.europa.eu/legal-content/En/TXT/HTML/?uri=CELEX:32016D1250&from=EN); 

- the providers’ participation in the Privacy Shield program established by the Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 pursuant to Directive 95/46/EC of the European Parliament and of the Council on the adequacy of the protection provided by the EU-U.S. Privacy Shield (http://eur-lex.europa.eu/legal-content/En/TXT/HTML/?uri=CELEX:32016D1250&from=EN)

Your rights

You have the right to:

1) opt out of receiving marketing and commercial information, which – depending on the circumstances – means You have the right to object or withdraw Your consent: (1) with regard to the processing of Your personal data for direct marketing purposes, including profiling by emplo; and, (2) to receiving marketing and commercial information by phone or email. You may object or opt out by email at abi@emplo.pl;

2) request access to Your personal data, their rectification, erasure, or restriction of their processing as well as their transfer to another data controller. Send Your requests to our email address: abi@emplo.pl;

3) lodge a complaint with the Inspector General for the Protection of Personal Data (future Director of the Office for the Protection of Personal Data) in matters related to the processing of Your personal data by emplo.

Contact us

Should you have any questions or need assistance please contact us at abi@emplo.pl or contact our Information Security Administrator (future Data Protection Supervisor) at iod@pracuj.pl.

Copyright © 2018 emplo sp. z o.o.