PRIVACY POLICY OF ENAF SPÓŁKA Z OGRANICZONĄ ODPOWIEDZIALNOŚCIĄ WITH ITS REGISTERED OFFICE IN WARSAW

 

In connection with the entry into force of the Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 eye on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46 / EC (general regulation on the protection of personal data) ("Regulation 106/679") on 25 May 2018 , as well as the obligation to provide information arising from these provisions, we would like to inform you in this document entitled "Privacy Policy of ENAF spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw" ("Privacy Policy") in a transparent way:

  • why, how and how long we collect, use and store (process) your personal data;
  • on what legal basis and for what purpose personal data is processed;
  • what are your rights and obligations related to the collection and use of such data.

 

WHO ARE WE?

The data controller of your personal data is ENAF spółka z ograniczoną odpowiedzialnością with its registered office in Warsaw, address: ul. Krakowiaków 16 , And 02-255 Warsaw, listed on the Register of Entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, XIII Commercial Division of the National Court Register under the KRS number: 0000142756, share capital: PLN 400.000,00, Tax ID number (NIP): 5342211228 ("Data Controller" or "ENAF").

 

HOW TO CONTACT US?

The Data Controller can be contacted in writing via traditional mail to the following address: ul. Krakowiaków 16, 02-255 Warsaw, by e-mail to the following e-mail address: rodo@enaf.pl or using the contact form available here: http://enaf.pl/pl/kontakt

 

TO WHOM IS THE PRIVACY POLICY ADDRESSED?

If:

  1. you visit our website: www.enaf.pl ("Website"), or Internet service: www.5x9.pl ("5x9 System"), which are operated by ENAF, also if you use the functional capabilities provided on the Website or 5x9 System, such as the possibility of ordering products offered by ENAF, using a company account in the 5x9 System activated by ENAF or contacting ENAF ("User")
  2. you are a natural person who is our (potential) customer, supplier, subcontractor, contractor, etc. ("Contractor"); 
  3. you are a natural person representing / acting on behalf / contact person of the Contractor ("Contact Person"); 
  4. you participate in workshops, trainings or events organized by ENAF, including participation of ENAF business partners ("Participant");

it is our privacy protection that concerns processing your personal information, meaning any information if it identifies you or allows to identify you directly or indirectly.

 

WHAT TYPES OF PERSONAL DATA DO WE COLLECT AND FOR WHAT PURPOSE?

In order to enable you to use a company account activated by ENAF in the 5x9 System and placing orders for products offered by ENAF on your own behalf or on behalf of other Contractors (if you are their Contact Person), we collect and process your personal data to the extent necessary as below:

  1. first name and last name;
  2. login;
  3. company or business name;
  4. address (street, house number, apartment number, zip code, city, country);
  5. delivery address (street, house number, apartment number, zip code, city, country);
  6. e-mail address;
  7. phone number;
  8. NIP (tax ID number) in case of invoice issue;
  9. REGON (statistical number).

The above personal data is voluntary, but it is necessary for the purpose of submitting an order to ENAF and concluding a contract with ENAF, also for the purpose of providing you service of the order. The consequence of not providing the above personal data is the inability for ENAF to perform the above actions (for example, lack of possibility to provide personal data may result in the fact that ENAF may not activate the company account in the 5x9 System, shipment of ordered products or issuance of invoices, etc.)

In order to enable you to use the contact form in the "Contact" tab available on the Website, we collect and process your personal data in the necessary below area:

  1. first name and last name;
  2. e-mail address;
  3. phone number;
  4. any personal data you provide voluntarily in the "Comment / Remarks" field.

In addition, in order to enable you to receive commercial information from us, including information, promotional or advertising materials and also to receive our Newsletter, we collect and process your personal data:

  1. first name and last name;
  2. e-mail address.

In order to enable you to leave your feedback or comments on the Website, we collect your personal data in the necessary below area:

  1. first name and last name;
  2. nick;
  3. e-mail address;
  4. any your personal information voluntarily provided by you as a part of your comment or opinion.

The above personal data is voluntary, but it is necessary for the implementation of the above-mentioned goals. The consequence of not providing the above personal data is the inability of ENAF to perform the above actions (for example, lack of possibility to provide personal data may result in the inability to submit a contact form, post your comment or opinions, or to send you commercial information or Newsletter).

In order to enable you to participate in the workshops, training or events organized by us, we collect and process your personal data:

a. first name and last name;
b. e-mail address;
c. phone number;
d. represented entrepreneur (data of the employer or principal, business name of the entrepreneur);
e.  image (in the case of workshops, training or events that are recorded by us);
f.   other personal data of the Participant appearing in his or her portfolio - only if you provide us with your portfolio, which is optional and if this portfolio contains your personal data.

Providing us with your personal data indicated in letters a - e above is voluntary, but necessary for us to achieve the above goals. The consequence of your failure to provide the above personal data is the inability to register and state your participation in events organized and conducted by us through workshops, trainings or events (for example, failure to provide personal data may result in the inability to submit your application form or send you some commercial information due to participation in workshops, trainings or events, lack of possibility to participate in workshops, training or events that are recorded by us, etc.) Providing us with your personal data indicated in letter f above is voluntary and optional.

In connection with the Website we also collect information about the User's activity on the Website, such as an IP address or other identifiers and information collected through cookies or other similar technologies, such as name, phone number, etc. The above does not refer to the 5x9 System.

With reference to the Contractors and Contact Persons, in particular potential Contractors, ENAF may obtain their personal information from the data subject as well as from other sources. In the latter case, ENAF acquires and processes the following categories of personal data: name, office, business address, address, correspondence address, phone number, e-mail, company (name) of the business, company address, NIP, REGON. The source of the above personal data are publicly available sources, including information made available on websites, as well as public accounts in professional social media like LinkedIn or commercial data bases acquired from our trusted suppliers.

 

ON WHAT LEGAL BASIS DO WE PROCESS YOUR PERSONAL DATA?

ENAF is the Data Controller of:

  1. personal information of the Website Users and the System 5x9 Users;
  2. the Contractors and the Contact Persons;
  3. Participants collected in the course of their registration for the workshops, trainings or events, as well as in relation to their images while the recording the workshops, trainings or events;

which means that ENAF determines the purposes in which your personal data is used and how it is processed.

Your personal data is processed by us for the following purposes and on the following legal basis:

  • in order to and to the extent necessary to execute orders placed by the Contractor for products offered by ENAF, as well as to deal with complaints made by the Contractor and provide post sale support by ENAF to the Contractor -

- then the legal basis is necessity of processing of your personal data for the performance of a contract concluded with you by ENAF (Article 6 paragraph 1 point b of the Regulation 2016/679);

  • for analytical and statistical purposes -

- then the legal basis is a legitimate interest pursued by the Data Controller (Article 6 paragraph 1 point f of the Regulation 2016/679) which is analyzing the Users' activity and preferences to improve functionalities of the Website;

  • in order to establish and bring claims or defend against them -

- then the legal basis is the legitimate interest pursued by the Data Controller (Article 6 paragraph 1 point b of the Regulation 2016/679) which is protecting his legal rights;

  • for organizing and conducting workshops, trainings or events -

- then the legal basis for the processing of your personal data in relation to registering Participants, running workshops, training or events, issuance of certificates confirming participation in workshops, training or events, etc. is the necessity of processing them for performance of a contract concluded with you by ENAF, including regulations of workshops, training or events accepted by you (Article 6 paragraph 1 point b of Regulation 2016/679);

  • in relation to your image recorded during participation in workshops, trainings or events - for information, promotional or marketing purposes of ENAF or ENAF business partners cooperating with us in organizing workshops, trainings or events, through its recording on photo, sound and film materials and their posting on the Internet, including social media (Facebook, LinkedIn, Google+, YouTube, etc.), including for the purpose of transfer of your image recorded in accordance with the above to the above mentioned ENAF business partners by ENAF -

- then the legal basis for the processing of your personal data is your consent (Article 6 paragraph 1 point a of the Regulation 2016/679);

  • for marketing purposes of the data Controller, including sending Newsletters information and offers of products offered by ENAF or sending commercial information to Participants, Contractors or Contact Persons (provided they have agreed to receive commercial information by electronic means and direct marketing using telecommunications terminal equipment);

- then the legal basis is a legitimate interest pursued by the Data Controller  (Article 6 paragraph 1 point f of the Regulation 2016/679) which is direct marketing undertaken by the Data Controller;

  • in order to transfer your personal data to ENAF business partners cooperating with us in organizing workshops, trainings or events, for their use by the above business partners for marketing purposes;

- then the legal basis for the processing of your personal data is your consent (Article 6 paragraph 1 point a of the Regulation 2016/679);

  • in order to contact, interact, follow us on social media -

- then the legal basis is a legitimate interest pursued by the Data Controller (Article 6 paragraph 1 point f of the Regulation 2016/679) which is necessity of contacting our Contractors and Contact Persons -

  • in order to fulfill statutory obligations of the Data Controller, resulting in particular from tax regulations and accounting regulations, including obligations related to issuing invoices and archiving obligations -

- then the legal basis is compliance with a legal obligation to which the Data Controller is subject (Article 6 paragraph 1 point c of the Regulation 2016/679).

The Data Controller processes personal data of the Users visiting his social media profile (Facebook and LinkedIn). These personal data is processed solely in connection with having such social media profile for the information and communication purposes, ie. it is a communication channel for the Users, within which they receive information about events and products presented on the Website. The legal basis for the processing of personal data by the Data Controller for this purpose is its legitimate interest pursued by the Data Controller (Article 6 paragraph 1 point f of the Regulation 2016/679), which is promoting its own brand and building and maintaining a brand-related society.

If the legal basis for the processing of your personal data is your consent, then we would like to inform you that your consent may be withdrawn at any time, and such withdrawal does not affect the legality of the processing carried out prior to this withdrawal.

 

HOW DO WE USE COOKIES?

The Website is also using cookies. The cookies are IT data, in particular text files, which are stored in the User's end devices and are intended for using the Websites. Cookies usually contain the name of the website from which they originate, their storage time on the User's end device and a unique number.

The entity placing cookies on the Users’ end devices and obtaining access to them is ENAF as the operator of the Website.

If you do not wish cookies on your end device, you should configure your browser settings or after each use of the Website delete saved cookies from the browser. However, you should consider that restrictions or blocking (disabling) the use of cookies necessary for authentication processes, security, maintaining the User's preferences, may affect (including negatively) some functionalities available on the Website, and in extreme cases may even prevent using the Website.

Cookies are used by ENAF as the operator of the Website for the following purposes:

  • collecting statistics (number of the Users, visited subpages of the Website, traffic paths between subpages of the Website, visiting time, etc.) which help to understand how the Users use the Website, which allows improving its structure and content, as well as to adjust the Website ad their functionalities to the individual needs of the Users, offer or provide better, more personalized services or products;
  • maintaining the Users’ session (after logging in) in order not to re-enter their login and password on every subpage of the Website;
  • analyzing the User’s profile in order to present you with the relevant marketing material, in particular the Google network and social media.

On the Website two basic types of cookies are used: session cookies and permanent cookies. Session cookies are temporary files that are stored on the Users’ end device until logging out, leaving the Website or disabling the software (web browser). Permanent cookies are stored on the Users’ end device for the time specified in the cookie parameters or until they are deleted by the User.

Software for browsing websites (web browser) usually by default allows storage of cookies in the User's end device. The Users can change settings in this area. The web browser allows you to delete cookies. It is also possible to automatically block cookies. Detailed information on this subject is provided in the help or documentation of the web browser.

Cookies placed in the Users’ end devices may also be used by third parties, advertisers and partners co-operating with ENAF. We recommend that Users read the privacy policy of these entities to learn about the rules of using cookies used in the statistics: Google Analytics privacy policy.

Cookies can be used by advertising networks, in particular the Google Network, to display advertisements adjust to the way the Users use the Website. For this purpose they can keep track navigation information or time the Users remain on the page.

The User can view and edit information about his / her preferences collected by the Google advertising network resulting from the cookies using the tool: https://www.google.com/ads/preferences/

As for the 5x9 System, it uses cookies to remember application settings for the User. Our cookies are used only for the correct operation of the 5x9 System, we do not collect data for advertising purposes. At any time you can change the way cookies are used in the settings of your web browser, however, changing these settings will limit the functionality of the 5x9 System. We recommend that you leave these settings unchanged, which will cause cookies to be saved in the memory of your device.

Privacy Policy regarding the use of cookies may change in the future by publishing by ENAF its new version on the Website and here. Then, information on the rules of using cookies via the Website and the 5x9 System will be again displayed to the Users.

 

TO WHOM ARE YOUR PERSONAL DATA PROVIDED?

Your Personal data may be transferred to the following recipients (including other controllers processing personal data on their own or in order to implement the processing of data by the Data Controller):

  • companies providing postal or delivery services;
  • companies providing payment services (banks, payment institutions);
  • entities and persons handling legal cases, consulting, accounting matters, marketing etc .;
  • entities and persons maintaining IT infrastructure (servers) and providing hosting services, Internet domain operator, IT and other similar for the benefit of the Data Controller;
  • ENAF business partners cooperating with us in organizing workshops, trainings or events;
  • entities that run social media;
  • trusted third parties, which ENAF uses to organize and run workshops, training or events, including entities providing services of recording such workshops, training or events and making photograps, sound or film materials;
  • trusted third parties with whom ENAF cooperates in order to perform orders placed by the Contractors.

ENAF may be required to provide personal information of the Users of the Website or the 5x9 System to authorized public authorities on the basis of lawful requests to the extent resulting from the request.

 

HOW LONG ARE YOUR PERSONAL DATA STORED?

We will process your personal data only for a period not longer than is necessary for the purposes in which your personal data is collected and the processed, which is for the period on which:

  1. the applicable law requires us to store your personal data, e.g. for accounting or tax purposes;
  2. we perform our obligations under contracts concluded with Contractors, including the period until the expiration of the time limits for claims arising from these contracts, and in the case of your company account in the 5x9 System for the period of keeping this company account which enable you to view the history of your orders carried out by ENAF;
  3. we perform our duties resulting from the workshops, trainings or events organized by us, including the period until the expiration of time limits for claims arising from contracts (regulations) for conduct of such workshops, training or events;
  4. we will disseminate photo, sound or film relations from workshops, trainings and events organized by us, via the Internet, including social media (Facebook, LinkedIn, Google+, YouTube, etc.) until our information and promotional goals are achieved;
  5. we implement or can implement the legitimate interests pursued by ENAF as a collector, such as:

*   redressing;

*   carrying out direct marketing of our products and services (we will cease to process your personal data for marketing purposes if you object to the processing of your personal data, and we will stop sending you commercial information by email and using your personal data for direct marketing using telecommunications end devices, in case of a withdrawal your consent to the above);

*   contacting persons representing / acting on behalf of the Contractor in relation to the necessity to implement the contract concluded by ENAF with that Contractor.

 

WHAT ARE YOUR RIGHTS IN CONNECTION WITH THE PROCESSING OF YOUR PERSONAL DATA?

As the Data Collector of your personal data, we ensure, that in connection with the processing of your personal data you have the right to:

  1. right of access to data – the ability to request access to your personal data, e.g. by obtaining confirmation as to whether / which your personal data (what categories of personal data) is processed by the Data Collector, by obtaining information including the purpose of the processing, recipients or categories of recipients of the data, the planned period of data storage or criteria for determining this period, etc., obtaining a copy of this personal data; 
  2. the right to rectify the data - the ability to request from the Data Collector to rectify (correct, supplement, update) your personal data that is incorrect, incomplete, including by means of providing a supplementary statement, however, this right does not apply to your personal data, such as image captured in photographs, sound or film materials from workshops, trainings and events organized by us; 
  3. the right to erasure the data - the ability to request from the Data Collector the removal of your personal data, but only under the Regulation 2016/679, e.g. when your personal data is not necessary for the purposes for which it was collected or otherwise processed, or when it was processed unlawfully; therefore, it will not be possible to delete your personal data in particular in the following circumstances:

*    the Contractor has an uncompleted complaint procedure regarding products ordered in ENAF;

*   the limitation period for claims resulting from contracts concluded by the Contractor with ENAF has not yet expired;

*    the Contractor has unsettled debt due to ENAF with respect to a contract concluded with ENAF;

*   the period of storage of your personal data relating to transactions for accounting or tax purposes has not yet expired;

  1. the right to restrict processing the data - the ability to request from the Data Controller to limit / restrict the processing of your personal data when:

*   you question the correctness of your personal data - reducing the processing can take place for a period allowing the Data Collector to check the correctness of the data;

*   the processing is unlawful and you oppose the deletion of data, requesting instead to limit their use;

*   the Data Collector no longer needs your personal data for processing purposes, and at the same time you need them to determine, pursue or defend your claims;

*   you have objected to the processing of your personal data - reducing the processing can be made until it is confirmed whether legitimate grounds on the side of the Data Collector precedence over your opposition;

  1. the right to data portability - the ability to request from the Data Controller to transfer of your personal data (in the case where the processing of your personal data is necessary for the contract to be executed by ENAF, which you are a contracting party or the processing of your personal data is based on your consent and in each case if such processing takes place in an automated manner), including receiving copy of your personal data in a structured, commonly used and readable format; this copy may be sent to another entity (another data controller), if it is technically possible;
  2. the right to object - the ability of bringing to the Data Collector object to the processing of your personal data by the Data Controller - in connection with your particular situation, to the processing of your personal data within the legitimate interests pursued by the Data Controller, as well as in processing persona data for direct marketing purposes;
  3. the right to bring a complaint to the supervisory authority (President of the Personal Data Protection Office / Prezes Urzędu Ochrony Danych Osobowych), if you consider that the processing of your personal data by ENAF violates the provisions of the Regulation 2016/679.

The rights indicated above can be used by:

*      e-mail contact at the following address: rodo@enaf.pl;

*      written contact via traditional mail to our following address: ENAF spółka z ograniczoną odpowiedzialnością spółka komandytowa, ul. Krakowiaków 16, 02-255 Warsaw, along with the note "personal data";

*      telephone contact at the following telephone number: 22 295 01 00 (during business hours, which is from Monday to Friday form 10.00 AM to 5.00 PM).

If you request a copy of the data, you may be required to pay the statutory fee, in case it is applicable.

If we store any personal data that is incorrect or if any changes have occurred in your data, please let us know so that we can keep correct and up-to-date records.

Your personal data is processed electronically and manually, in accordance with the methods and procedures related to the processing purposes mentioned above.

 

ON WHAT PRINCIPLES ARE YOUR PERSONAL DATA PROCESSED BY ENAF BUSINESS PARTNERS?

In the case of transfer of your personal data by ENAF to our business partners, which will be done only in the case of your separate consent for such transfer, the data controller of your personal data will be independently our business partner, who independently provides you with all the information required by law regarding the processing of your personal data in the range provided to him.

 

HOW ARE YOUR PERSONAL DATA SECURED?

The Data controller makes every effort to ensure all measures of physical, technical and organizational protection of your personal data   against their accidental or intentional destruction, accidental loss, change, unauthorized disclosure, use or access, in accordance with all existing legislation.

We use all necessary security of servers, connections and the Website itself in order to protect your personal data. All connections related to the making electronic connections by you, if you choose this option, will take place via a secure encrypted connection.

However, actions taken by us may prove to be insufficient, and if you do not follow safety rules yourself. In particular , keep your login and password in the confidentiality in order to log in to your company account within the 5x9 System and do not make them available to any third parties. Please remember that we will not ask you to provide them, except the situation in which you log in to your company account within the 5x9 System. In order to prevent you from using your company account within the 5x9 System by unauthorized and wrong persons, please log out immediately after using the 5x9 System.

 

HOW WILL WE MAKE CHANGES IN THE PRIVACY POLICY?

We reserve that in the future it may be necessary to amend or update our Privacy Policy. In particular, this may be necessary due to changes in the applicable legal provisions regarding the protection of personal data, guidelines regarding the protection of personal data issued by the supervisory body (President of the Personal Data Protection Office / Prezes Urzędu Ochrony Danych Osobowych), but also in connection with possible changes in this area by the ENAF or handling processes of the Contractors or the Participants.

We guarantee that any changes to the Privacy Policy that may possibly occur in the future will remain in full compliance with applicable law in the field of personal data protection, and will take into account the need to ensure the security of your personal data processed by us.

The latest version of our Privacy Policy is always available on our Website here.  

 

 

contact, address

Enaf Sp. z o.o.
Szarych Szeregów 2
05-820 Piastów