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Privacy Notice

 

  1. Introduction

1.1    “BRINTONS AGNELLA” Limited, 42, Gen. Władysława Andersa St., 15-113 Białystok (“BRINTONS AGNELLA” ) takes data protection seriously.  The use of Brintons internet pages is not possible without the provision of some personal data; however if a Data Subject wishes to use certain services via our website, processing of further personal data could become necessary.  If the processing of personal data is necessary and there is no statutory basis for such processing, we will obtain consent from the Data Subject.

1.2    Personal Data processing shall always be in line with the General Data Protection Regulations 2016 (“GDPR”) and in accordance with the country specific legislation applicable to “BRINTONS AGNELLA”.  By means of this Privacy Notice we would like to inform the general public why we collect and process personal data and the Data Subject’s rights relating to the collection and processing of personal data.

  1. Definitions

2.1    The data protection notice of “BRINTONS AGNELLA” is based on the terms used by the European Union legislator for the adoption of the GDPR but to aid your understanding the definitions apply:

    • Controller: the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by the European Union or Member State law, the controller or the specific criteria for its nomination may be provided for by the European Union or Member State law.
    • Personal data: any information relating to an identified or identifiable natural person (“Data Subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as name, an identification number, location data an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
    • Data Subject: any identified or identifiable natural person, whose personal data is processed by the controller responsible for the processing.
    • Processor: a natural or legal person, public authority, agency or other body which processes personal data on behalf of the controller.
    • Recipient: a natural or legal person, public authority, agency or other body, to which the personal data is disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with European Union or Member State law shall not be regarded as recipients; the processing of that data by the Public Authority shall be in compliance with the applicable data protection rules according to the purposes of the processing.
    • Third party: a natural or legal person, public authority, agency or body other then the data subject, controller, processor, and persons who, under the direct authority or the controller or processor, are authorised to process personal data.
    • Restriction of processing: the marking of stored personal data with the aim of limiting their processing in the future.
    • Processing: any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
    • Profiling: any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyses or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, locations or movements.
    • Consent: consent of the data subject is any freely given, specific, informed, and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
  1. Name and address of the Controller

3.1    The Controller is:

          “BRINTONS AGNELLA” Limited, 42, Gen. Władysława Andersa St., 15-113 Białystok, phone:+48 85 67 52 551, e-mail: biuro@agnella.pl, the website: www.agnella.pl

  1. Name and address of the Lead Supervisory Authority

4.1    The Lead Supervisory Authority overseeing the Controller is:
Prezes Urzędu Ochrony Danych Osobowych /Prezes UODO/ , address: 2, Stawki St., 00-193 Warszawa

  1. Cookies

5.1    The internet pages of “BRINTONS AGNELLA” use cookies.  Cookies are text files that are stored on a computer system via an internet browser.  Many internet sites and servers use cookies.

5.2    Many cookies contain a so-called cookie ID, which is a unique identifier of the cookie.  It consists of a character string through which internet pages and servers can be assigned to the specific internet browser in which the cookie is stored.

5.3    This allows a visited internet site and servers to differentiate the individual browser of a Data Subject from other internet browsers that contain other cookies.  A specific internet browser can be recognised and identified using the unique cookie ID.

5.4    Through the use of cookies, “BRINTONS AGNELLA” can provide users of its website with a more user-friendly service that would not be possible without the use of cookies. By means of a cookie, the information on our website can be optimized with the user in mind.

5.5    The Data Subject may, at any time, prevent the setting of cookies by our website, either temporarily or permanently, by amending the settings of their internet browser.  Cookies already stored can be removed via their internet browser settings.

5.6    If the Data Subject deactivates the setting of cookies in their internet browser, not all functions of our website may be available or useable.

  1. Reasons and purposes for processing information

6.1    The following is a broad description of the way Brintons processes personal information.  To understand how your own personal information is processed you may also need to refer to any personal communications you have received.  We process personal information to enable us to promote our goods and services, to maintain our own accounts and records, and to manage and support our employees.

6.2    We collect information relating to the above purposes from the following sources:

    • the Data Subject directly (e.g. from information entered into forms)
    • the Data Subject indirectly (e.g. information collected when you browse our website, such as IP addresses)
    • Publicly available registers (e.g. the electoral roll, Companies House)
    • Social media (e.g. Twitter, LinkedIn, Facebook)
    • Research provided by third party providers (e.g. internet search engines)

6.3    We process information relating to the above purposes.  This information may include:

    • personal details
    • business activities of the person whose personal information we are processing
    • goods and services provided
    • financial details
    • education details
    • employment details

6.4    We process personal information about our:

    • customers
    • employees
    • complainants and enquirers
    • suppliers
    • advisers and other professional experts

6.5    We sometimes need to share the personal information we process with the individuals themselves and also with other organisations.  Where this is necessary, we are required to comply with all aspects of the Data Protection Act (“DPA”), Privacy and Electronic Communication Regulations (“PECR”) and the EU General Data Protection Act 2016 (“GDPR”) as it applies.  What follows is a description of the types of organisations we may need to share some of the personal information we process with for one or more reasons.

6.6    Where necessary or required we share information with:

    • business associates and other professional advisors
    • financial organisations
    • current, past or prospective employers
    • educators and examining bodies
    • suppliers and service providers
  1. Rights of the Data Subject

7.1    GDPR affords EU Data Subjects with rights, which are summarised below.  In order to assert any of these rights, the Data Subject may contact “BRINTONS AGNELLA” at any time.

7.2    The right of confirmation:  Each Data Subject shall have the right to obtain from the Controller the confirmation as to whether or not personal data concerning them is being processed.

7.3    The right of access:  Each Data Subject shall have the right to obtain from the Controller, free information about their personal data stored at any time and a copy of this information.  Furthermore, the Data Subject shall have a right to obtain information as to whether their personal data is transferred to a third country or to an international organisation.  Where this is the case, the Data Subject shall have the right to be informed of the appropriate safeguards relating to the transfer.

7.4    Right to rectification:  Each Data Subject shall have the right granted by the European Union to obtain from the Controller without undue delay the rectification of inaccurate personal data concerning them.  Taking into account the purposes of the processing, the Data Subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

7.5    Right to erasure (right to be forgotten):  Each Data Subject shall have the right to obtain from the Controller the erasure of personal data concerning them without undue delay, and the Controller shall have the obligation to erase personal data without undue delay where one of the statutory grounds applies, as long as the processing is not necessary.

7.6    Right of restriction of processing:  Each Data Subject shall have the right granted by the European Union to obtain from the Controller a restriction to the processing of their personal data where a statutory reason applies.

7.7    Right to data portability:  Each Data Subject shall have the right granted by the European Union to receive a copy of their personal data, held by the Controller, in a structured commonly used and machine-readable format.

7.8    Right to object:  Each Data Subject shall have the right to object, on grounds relating to their specific situation, at any time, to the processing of their personal data.

7.9    Automated individual decision-making, including profiling:  Each data subject shall have the right not to be subject to a decision based solely on automated processing, including profiling.

7.10  Right to withdraw consent:  Where consent forms the basis for processing, Data Subjects have the right to withdraw their consent at any time.  Data Subjects can withdraw consent by sending an email to dataprotection@brintons.co.uk.

7.11  Right to complain to the supervisory authority:  Should the Controller not react to a request from a Data Subject within a reasonable period, the Data Subject can contact the Supervisor Authority.  Their contact details can be found in clause 4 of this privacy notice.

  1. Legal basis for data processing

8.1    The legal basis for data processing shall be where:

    • the data subject has given consent to the processing of their personal data for one or more specific purposes.
    • 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.
    • processing is necessary for compliance with a legal obligation to which the controller is subject.
    • processing is necessary in order to protect the vital interests of the Data Subject or of another natural person.
    • processing is necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
    • processing is necessary for the purposes of the legitimate interests pursued by the Controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the Data Subject which require protection of personal data, in particular where the Data Subject is a child.
  1. The legitimate interests pursued by the Controller or by a third party

9.1    Where the processing of personal data is based on our legitimate interest, it is to carry out our business in favour of the well-being of all our employees and shareholders.

  1. Security of processing

10.1  As the Controller, “BRINTONS AGNELLA” has implemented technical and organisational measures to ensure personal data processed remains secure, however absolute security cannot be guaranteed.  Should a Data Subject have a particular concern about a particular method of data transmission, we shall take steps to provide an alternative method.

  1. Transfers

11.1  It may sometimes be necessary to transfer personal information overseas.  When transfers are needed, information may be transferred to countries or territories around the world.  Any transfers made will be in full compliance with all aspects of the General Data Protection Regulations and in accordance with the country-specific legislation applicable to “BRINTONS AGNELLA”.

  1. Personal data retention periods

12.1  The criteria used to determine the retention period of personal data is the respective statutory retention period within the EU Member State.  After the expiration of that period, the personal data shall be securely deleted, as long as it is no longer necessary for the fulfillment of a contract, the initiation of a contract, to meet the controller’s statutory obligations or in relation to other legal proceedings.

  1. Contractual obligation of the Data Subject to provide the personal data and the possible consequences of failure to provide such data

13.1  For clarity, the provision of personal data is partly required by law (e.g. tax legislation) or can also result from contractual provisions (e.g. a customer name and address).  Sometimes it may be necessary to conclude a contract that the Data Subject provides us with personal data, which must subsequently be processed by us.  The Data Subject is, for example, obliged to provide us with personal data when our company signs a contract with them.  The non-provision of the personal data would have the consequence that the contract with the data subject could not be concluded.

  1. Automated decision-making and profiling

14.1  We do not process personal data for automatic decision-making or profiling.

  1. Data protection for employment and recruitment procedures

15.1  The data Controller shall collect and process the personal data of applicants for the purpose of processing of the job application procedure.  The processing may also be carried out electronically.  In this case, in particular, if an applicant submits corresponding application documents by e-mail or by means of a web form on our website to the Controller.  If the data Controller concludes an employment contract with the applicant, the submitted data will be stored for the purpose of processing the employment relationship in compliance with legal requirements.  If no employment contract is concluded with the applicant by the Controller, the application documents will be automatically erased within two months following notification of the refusal decision, provided that no other legitimate interests of the controller are opposed to the erasure.  Other legitimate interests could be, for example, complying with country-specific legislation, such as the UK Equality Act 2010.

  1. General

16.1  You may not transfer your rights under this privacy notice to any other person.  We may transfer our rights under this Privacy Notice where we reasonably believe your rights will not be affected.

16.2  If any court or competent authority finds that any provision of this privacy notice (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy notice will not be affected.

16.3  Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.

16.4  This notice will be governed by and interpreted according to the law of England and Wales.  All disputes arising under the notice will be subject to the exclusive jurisdiction of the English and Welsh courts.

  1. Changes to this notice

17.1  This notice was last updated on 30 April 2018.  We may change this notice by updating this page to reflect changes in the law or our privacy practices.  However, we will not use your Personal Data in any new ways without your consent.