AUDYTORIUM PRIVACY POLICY

Please read this Audytorium Privacy Policy (“Policy”) carefully to acquaint yourself with relevant information about the purposes and methods of processing personal data in connection with responding to your inquiries, obtaining from – or presenting – you offers, or performing contracts, as well as about the rights you or (other) data subjects may have in relation to such processing.

This Policy also describes the rules for using the webpages available at: http://www.audytorium.eu (collectively, “Website”), so please read this document before you start using the Website and its functionalities. If you do not accept the terms of this Policy, please stop using the Website altogether.

General information

First of all, in compliance with the information obligations prescribed by the “GDPR”, that is (EU) General Data Protection Regulation 2016/679, we would like to inform you that Audytorium Biegli Rewidenci Grabowski, Pigoń Spółka Partnerska with its registered office in Gdańsk (address: ul. Marynarki Polskiej 163, 80-868 Gdańsk; registration: District Court Gdańsk-Północ in Gdańsk, VII Commercial Division of the National Court Register, KRS number: 0000335025; REGON number: 220849363; NIP/tax ID number: 5842681316; “Audytorium”, “we”, “us” , “Us”) is the controller (of your personal data).

In matters related to the protection of personal data, you can contact us by e-mail at: biuro@audytorium.eu; or in writing at the address of Audytorium: ul. Marynarki Polskiej 163, 80-868 Gdańsk, with the annotation: “GDPR – personal data”.

The provision of your data in connection with the use of the Website or correspondence with us – regarding offers or performance of contracts concluded with Audytorium – is always voluntary; however, provision of some information may be necessary to: (i) prepare a personalized offer for you; (ii) conclude and perform a contract with Audytorium; (iii) provide you with an answer; (iv) comply with legal obligations; or (v) achieve other purposes as further described in this Policy.

RULES FOR USING WEBSITE

All content on the Website – including, without limitation, trademarks and trade names, photos and descriptions of services and other materials – is protected by law and any use may only take place subject to prior written consent of Audytorium or other authorized entity.

Any use of the Website and its functionalities, such as a contact form, requires Internet access and an active and correctly configured e-mail account (e-mail), as well as a constantly updated web browser, e.g. Internet Explorer, Chrome, Firefox, Opera, Safari .

It is forbidden to (i) use the Website in a way that interferes with the use of it by Audytorium or its users, (ii) provide illegal content via the Website, including content that violates personal or other rights of third parties, and (iii) act so as to violate or circumvent law or contradict the principles of community life or principles of morality.

On the Website Audytorium makes available a contact form that allows you to submit an inquiry or send a message to Audytorium, and that may also allow you to order – via the Website or otherwise – free industry information and information relating to the current offer of Audytorium, provided in the form of mailing. The mailing will be sent only to those of you who have already (i) used our services, (ii) submitted an inquiry via the Website, by phone or otherwise, or (iii) otherwise expressed their willingness to cooperate – you will be able to withdraw your consent to receive it at any time, e.g. by unsubscribing (or objecting to the processing of your data for marketing purposes).

On the Website Audytorium has implemented certain technical measures to protect electronic messages and digital content sent via the Website, such as: SSL encryption, access passwords, anti-virus programs and devices against unwanted software. Nevertheless, we would like to point out that the use of the Internet or electronically supplied services always involves the risk of unauthorized access to transmitted data – therefore we recommend that you also apply appropriate security measures, e.g. anti-virus programs.

COOKIES

Audytorium may use cookies (small text files downloaded onto a user’s computer that can be employed to store information about the user and her/his preferences) and other similar technologies in order to fully exploit the Website’s functionality, display personalized advertisements, monitor traffic on the Website, and visit statistics. The Website may also contain the so-called social and marketing plugins, potentially employing cookies.

The cookies we use allow us primarily to assess the expectations and interests of the Website’s users, including through an analysis of your interest in a specific service. The data obtained during the analysis will be used only for marketing purposes, i.e. to display personalized advertising of Audytorium services on other websites and services operating as part of, for example, the AdSense network or in social networks.

You can change the settings of the web browser you use at any time, specifying the conditions for storing cookies by changing the web browser settings yourself, and also delete them yourself – however it may affect availability of the Website’s functions.

CEL PRZETWARZANIA ORAZ PODSTAWA PRAWNA PRZETWARZANIA DANYCH OSOBOWYCH PRZEZ AUDYTORIUM

  1. Performance of a contract concluded with Audytorium – your data will be processed in order to (enable us to) provide accounting or human resources (HR) services under a contract concluded between you and Audytorium. Processing may also be necessary to comply with legal obligations to which Audytorium is subject.

Depending on the nature of the services, legal obligations, and related information needs, we will minimize the processing of data and so Audytorium will not obtain or otherwise process more data than necessary to provide a specific service. In providing accounting or HR services to you, Audytorium may process such data as: first and last name, telephone number, e-mail address. Depending on the service provided, the scope of data may also include: place of residence, PESEL/personal ID number, NIP/tax ID number, telephone number, e-mail address, relevant tax office, amount of earnings, contractor and billing data, NFZ/National Health Fund, bank account number, contact persons, family, medical examinations, as well as training, education, employment and period of service information.

Audytorium makes every effort to maintain the highest level of professionalism with respect to the services offered. Therefore, with due regard to your legitimate interests, applicable requirements and complexity of the services offered, Audytorium reserves the right (to attempt) to obtain special categories of personal data (so-called, sensitive data) regarding, in particular, your or members’ of your personnel health – in order to make personnel settlements in accordance with applicable regulations.

In the cases described above, Audytorium will process your (data subject’s) personal data throughout the provision of services covered by a given contract and all related services or, where appropriate and to the necessary extent, beyond – at least until expiry of an applicable statute of limitations period and completion of pending proceedings or until expiry of a legally prescribed obligation to archive documents. Sensitive data will be processed until consent is withdrawn or the legal ground on which it was processed expires.

 

  1. Making an offer by, or conclusion or performance of a contract with, Audytorium – processing of your personal data as our partners, clients, contractors and service providers or data of persons indicated by you (including your employees and associates) as well as persons interested in Audytorium’s offer may take place for the purpose of making an offer or concluding or performing a contract or on the ground of the legitimate interests of Audytorium consisting in the pursuit of business activity – communication and contact with customers and potential customers, effective conclusion and performance of contracts (mainly) for accounting, HR and payroll services. In addition, personal data may then be processed in order to comply with our legal obligations, e.g. to issue an invoice.

We will therefore process your first and last name, e-mail address, company data, history of inquiries and offers made by Audytorium. The provision of your personal data is always voluntary but it may be necessary for the conclusion and proper performance of a contract. In the cases described above, Audytorium will process your data no longer than until the end of your business activity – but at least until the end or expiry of the last of (i) a contract concluded with you, (ii) an applicable statutory limitations period, (iii) related proceedings, and (iv) the year in which claims in connection with the contract cease to be enforceable, insofar as it is necessary that Audytorium processes personal data with respect to the claims – or for as long as it is necessary to pursue the legitimate interests of Audytorium or a third party.

 

III.          Persons making general inquiries to Audytorium – the processing of personal data takes place for the purpose of communicating with persons who approach Audytorium, in particular with potential clients and contractors of Audytorium. In this case the legal ground for the processing of personal data is the legitimate interest of Audytorium consisting in enabling (i) communication, (ii) establishment of a relationship with the approaching person, and (iii) provision of the sought information to such person. Alternatively, in such a case, the legal ground for processing may be consent of the approaching person expressed through her/his specific behavior.

Depending on the content of the correspondence, the processed data may include in particular: first and last name, e-mail address, position, telephone number, correspondence address and other information provided by the person approaching Audytorium. The provision of personal data is voluntary, however, in absence of personal data, the communication process (including answering your questions) may be difficult or impossible to carry out. As regards offer inquiries and inquiries concerning services, terms of cooperation or other information, Audytorium may store your data for as long as you pursue business activity or until we end our cooperation or you request to have your data and the content of inquiries removed from our database. Notwithstanding the foregoing, the collected data may be stored for as long as necessary to pursue the legitimate interests of Audytorium or a third party.

 

  1. Job candidates – conducting a recruitment process is, in this case, the main purpose of the processing of personal data. The processing of applicants’ personal data – such as: first and last name, parents’ names, date of birth, place of residence (correspondence address), education, course of previous employment – is based on provisions of law (Labor Code) or, as regards data in excess of the data mandated by law, on an applicant’s consent indicated by their voluntary inclusion of such additional data in a resume and like documents. As an exception to the rule, Audytorium may also process health data, including information about disabilities of job candidates obtained for reasons of occupational health and safety, possible PFRON/National Fund for the Rehabilitation of Disabled subsidies, limitations on working time and prevention of contact with hazardous substances. In this case, the legal ground for the processing of sensitive data is express consent to the processing of such data for the purpose of recruitment.

The provision of personal data, including – potentially – health data, is voluntary; however, failure to provide the mandated personal data, the list of which is set forth above, makes participation in the recruitment process impossible. As regards the data collected during a job interview and the results of the qualification tests, Audytorium will process them to check a candidate’s skills and abilities in order to assess the candidate and her/his suitability for the job. In this case, personal data will be stored until the end of the recruitment process. If an applicant agrees to the processing of personal data in further recruitment processes, the storage period will last a maximum of 24 months from the end of the calendar year in which such consent was granted.

 

  1. Other legitimate purposes of Audytorium. On the basis of the legitimate interests, Audytorium may use functionalities of the Website for:
  • conducting research and analysis of the activity of yours and other Website users in order to improve the efficiency of operation, assess the expectations and needs of users and improve the Website, introduce new products and services, as well as for statistical purposes,
  • providing you with commercial information and marketing content as well as technical information regarding products or services offered by us or our partners – to the extent permitted by law, including with your consent, using various available means of communication,
  • communicating with you on Audytorium’s account for purposes other than directly related to the possibility of concluding and performing a contract,
  • ensuring the safe use of the Website, counteracting fraud and abuse, and maintaining the correctness and continuity of the Website, including by creating backups,
  • establishing, investigating or defending the claims of Audytorium and demonstrating that Audytorium meets the obligations arising from the provisions of law, including by creating registers and records resulting from the provisions on the protection of personal data and their archiving.

If in any case the ground for data processing is your consent or our legitimate interests, we will process your data for the duration of our business activity or the duration of a given action – respectively – until consent is withdrawn or the right to object is effectively exercised.

PROFILING, NO AUTOMATED DECISION-MAKING, SAFETY MEASURES

While processing your data for the purposes described in point IV above, Audytorium may profile personal data in order to determine whether a job candidate applying for employment is suitable for a given position. At the same time, Audytorium may make attempts to predict your (future) job performance, for example by obtaining references or verifying publications and accounts on industry and social portals (e.g., LinkedIn, GoldenLine). Audytorium acknowledges that third-party references may be obtained through direct contact with such parties only subject to your prior consent.
In other cases described above, Audytorium will not profile you based on the personal data in our possession.
Audytorium never uses systems that enable automated decision-making towards you.
Audytorium uses technical and organizational measures to ensure the protection of personal data being processed, appropriate to the threats and categories of your data, and, in particular, it protects data through technical and organizational measures against unauthorized disclosure, removal by an unauthorized person or in an unlawful manner, and against alteration, loss, damage or destruction – using, among others, SSL certificates on the Website.

DATA RECIPIENTS

As a rule, only members of the staff and associates of Audytorium have direct access to personal data processed by Audytorium – authorized persons involved in the provision of services or maintenance of the Website who have been given appropriate authorizations. Access to such personal data may also be obtained – to a reasonable extent – by entities cooperating with us (or with us and you) during the provision of individual services.

The personal data provided by you may be made available to tax authorities – in the execution of a task assigned to Audytorium – as well as to other entities authorized to receive them under applicable law, in particular to competent judicial authorities.

In accordance with applicable law, we would like to inform you that your data may be transferred by Audytorium – to the extent necessary – to entities processing them at the request of Audytorium, i.e. in particular postal operators cooperating with Audytorium, entities handling and maintaining our IT systems and websites, professional advisors, banks and payment companies as well as accounting offices providing services to Audytorium. Such entities process data on the basis of an agreement concluded with Audytorium and only to the extent necessary to provide services in accordance with our instructions.

At the same time, we would like to inform you that if Audytorium collects your data in connection with the activities conducted in the European Economic Area, Audytorium does not intend to transfer your data to third countries – i.e., outside the European Economic Area – unless it is justified by the circumstances of the contract and brought to your attention by Audytorium in advance. In addition, if the transfer of data to a third country turns out to be necessary or justified, it will be carried out in accordance with applicable legal regulations, and the transfer will take place in accordance with applicable law.

RIGHTS RELATING TO THE PROCESSING OF YOUR PERSONAL DATA

According to the GDPR, you (data subjects) may have a number of rights resulting from the processing of your personal data, including:

  • the right of access to personal data, including the right to obtain a copy of the personal data,
  • the right to rectification of personal data – when you notice that the personal data is inaccurate or incomplete,
  • the right to erasure of personal data (the so-called “right to be forgotten”) – provided, however, that the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed or you object to the processing of data or you withdraw consent on which the processing is based and there is no other legal ground for the processing or the personal data have been unlawfully processed or have to be erased in order for compliance with a legal obligation,
  • the right to restriction of processing of personal data – if you contest the accuracy of your personal data, where the processing is unlawful but you do oppose the erasure of the personal data, when your data are no longer needed by us but you need them to establish, defend or pursuing legal claims, or when you object to the processing of data – pending the verification whether the legitimate grounds for our processing override the basis of your objection,
  • the right to data portability – if the processing takes place automatically on the basis of a contract concluded with you or on the basis of your consent.

You also have the right to object to processing of your personal data, including profiling – if we process them on the basis of a legitimate interest and the objection is justified by your particular situation. Where the processing of personal data takes place on the basis of your consent, you have the right to withdraw your consent at any time; the withdrawal will not affect the lawfulness of the processing based on consent before its withdrawal.

All requests regarding the exercise of the above rights can be submitted in writing or by e-mail to the addresses of Audytorium indicated above. We will do our best to respond to your requests promptly but no later than within one month of receipt of the request, unless they prove to be numerous or complicated. All requests are free of charge, but where they are manifestly unfounded or excessive, we may charge a reasonable fee, taking into account the costs of providing the information or communication or taking the action requested, or refuse to act on the request.

If you think that Audytorium has breach the law in processing your personal data, please contact us by utilizing the contact data provided above. Notwithstanding, you have the right to lodge a complaint with the supervisory authority, which in Poland is the President of the Office for Personal Data Protection.

LIABILITY DISCLAIMER

This Policy does not cover any information regarding products or services offered by entities other than Audytorium which may be posted on the Website for commercial purposes, as a favor to our guests, on a reciprocal basis or even without serving any direct or indirect commercial goals.

Audytorium is not responsible for the actions or omissions of users, as a result of which Audytorium processes the personal data provided by them in the manner specified in this Policy.

Audytorium reserves the right to change, withdraw or modify the fitness, form and function of the Website, as well as to cease operations, transfer the rights to the Website and to perform any legal action permitted by applicable law. Any activities performed by Audytorium may not infringe on the rights of the Website user.

Audytorium reserves the right to make changes to this Policy at any time, and both the current and previous versions of this Policy will be available on the Website.