The GLC Personal Data Processing Policy has been prepared to provide you with the most important information regarding the rules related to processing and ensuring the protection of your data in the course of our business.
GLC is a group of Joint Controllers as referred to in Article 26 of the RODO, which includes the following entities:
The entities comprising GLC entered into on May 25, 2018. Data Joint Management Agreement, under which they jointly agreed to implement and maintain measures to ensure the security and confidentiality of your personal data. In matters related to personal data, the data protection company is GLC Legal Kubista, Szymik. Kancelaria Adwokatów i Doradców Podatkowych Spółka partnerska, based in Katowice. Regardless, you may exercise your rights under the RODO (and as indicated in the Policy) against each of the companies comprising GLC.
You may contact each of the Administrators at: 13 Uniwersytecka St., 40 – 007 Katowice or by sending an email to the following email address: kontakt@glc.pl with the reference “personal data”
and indicating which co-administrator the message concerns.
You may also contact Administrators whose registered office or place of business is other than 13 Uniwersytecka St., 40 – 007 Katowice, respectively:
The Joint Administrators have appointed Mariusz Jarosz as Data Protection Officer (DPO), who can be contacted by phone (+48502856288) or email (mjarosz@glc.pl).
We obtain your personal data mainly from you. You give us your data to get in touch with GLC by giving us your business card, making an appointment or expressing your desire to cooperate with us. We may also obtain data in the recruitment process when you submit application documents to us, obtaining it from our contractors within the framework of existing interdependencies between business partners. We may also obtain data from public authorities and institutions that contact us in connection with our business activities.
Clients and Contractors of GLC
We obtain personal data mainly in connection with our business activities. If you are our client and run a sole proprietorship or represent a company or an organizational unit, we obtain your personal data mainly from you. You provide us with your data to get in touch with GLC Companies, including by sending us an email or contacting us by phone or directly at our headquarters. We may also obtain your personal data from other business and economic partners who work with you (e.g., in the context of group services or business and personal affiliates), as well as from public authorities and institutions, e.g. within the framework of our provision of free legal assistance ex officio, or the exercise of the profession of auditor or trustee.
We may also obtain the data of Ordering Parties, Contractors and Subcontractors, as well as their employees and associates, as part of their participation in tender proceedings
If you are an employee or associate of a company, business entity, or entrepreneur conducting business, and GLC processes your personal data, although you never directly provided it to us – it happens that your data may be transferred to us by third parties, at your request or in connection with your business duties. Your data may be given to us by your employer or an entity working with you under a contract of mandate to enable us to contact you in connection with the cooperation we are undertaking with the entity where you are employed.
Applicants for employment with GLC Joint Ventures
If you are taking steps to cooperate with us and want to send your resume or cover letter or other application documents to any of our Companies, we obtain your personal data from you so that we can contact you and include you in the recruitment process.
Sometimes we use the help of entities that assist in the recruitment process of employees – for example, Internet portals that allow posting job advertisements. In this case, your personal data is provided to us by these entities, at your request and with your consent.
Representatives of public authorities and institutions
Due to the specific nature of the Joint Administrators’ business activities, we very often come into contact with public authorities and institutions, in the course of which we obtain personal data of representatives, employees and collaborators of such authorities and institutions. Then we process personal data in connection with the delivery to us of the letter on which the data are indicated or in connection with the in connection with telephone contact.
Data in case files
We obtain the data of individuals conducting and participating in inspection proceedings and audits, witnesses, experts, parties and participants in the proceedings, as well as the data of other individuals provided in connection with pending proceedings before public administration bodies and institutions, as part of the exchange of correspondence, authorizations to carry out certain activities or other letters related to the proceedings and attendance at meetings and hearings.
Conduct of business
If we have obtained your personal data in connection with the conduct of our business activities, they will be used for the performance of the services we offer in the fields of fintech, legal and tax consulting, financial, accounting and investigative auditing, auditing, accounting and accounting outsourcing, HR and payroll outsourcing, controlling and management accounting, business consulting and interim management, among others, depending on the area and specifics of the cooperation established between us. We may also use the data to perform our obligations and fulfill our contractual duties, process your claims and enable you to exercise your rights. This includes, in particular, receiving contact data from you, allowing GLC to establish and maintain contact with you in the course of cooperation.
Data provided to us by you or another entity may also be processed in connection with our performance of legal interests. On this ground, we may process your data, among other things, in pursuit of the right to perform a public task, as well as to ensure the proper functioning of the Joint Administrators and in connection with the exercise of rights relating to the assertion of claims and legal and organizational services.
If you are a sole proprietor or represent a company or business entity – we also process your personal data for tax, legal and accounting purposes. We need them to disclose the relevant data on a contract or invoice, as well as – to use them in maintaining our tax records. However, always the processing of your personal data will be related to our business activities.
If you are an employee of our client, we will specifically need your personal data in order to establish and maintain contact with the entity where you work – again, for business purposes only.
Running https://glc.pl
We process your personal data in order to provide the functionality of our website https://glc.pl. Accordingly, we use your personal data in particular to provide you with the opportunity to contact GLC using our contact form, which allows us to improve communication, and a recruitment form, through which you can easily send us application documents and apply for employment with one of the Joint Administrators.
Your personal information that we use for purposes related to the operation of the site will not be used by GLC for any other purpose without your consent. In particular, we will not process your data for marketing purposes without your express consent.
Recruitment
If you apply for employment with GLC, we use your personal data only for the purpose of conducting the recruitment process. We use your data to familiarize ourselves with your education
and work experience, to assess your suitability for a job at GLC, and finally – to get in touch with you and invite you for an interview.
If, after the recruitment process, we decide to hire you, the personal data provided during the recruitment process may be used for future employment – so that you do not have to provide it again. Most often, the personal information you provide in your resume and cover letter is stored in your employee file.
Your personal information that we use for recruitment purposes will not be used by GLC for marketing purposes without your consent.
Making contact
If you send us an email or get in touch with GLC via the contact form on the website https://glc.pl, we use your personal data to correspond with you and answer the questions you have asked, according to the content of your inquiry or message.
If you are contacting us for business purposes, your personal data may then be used to direct a business offer to you – but only to the extent that you request it and in relation to the inquiry you have made.
Notwithstanding the foregoing, even if we establish communication for business purposes, we will not, without your consent, use your personal data for marketing purposes in connection with offers other than the one you expressly requested when establishing contact.
Investigation and defense of claims
There are times when we will need to use your personal information to assert or defend our rights, including in court. We hope this will not happen, but if any dispute arises between us – we may have to use your personal information in the course of litigation, arbitration or mediation.
In that case, we will use your personal data only to the extent necessary and in connection with the discussions or proceedings. It may happen that we will use your personal data to call you as a witness in a case, or-if you are our Contractor or Customer-as a party to the case.
Marketing purposes
If you agree – your personal data may be processed by GLC also for marketing purposes, i.e. as part of promoting our range of products and services. As part of our marketing, we want to be able to present you with our new range of products or services, as well as new commercial or business solutions used in our business. We also want to inform you about our promotions or campaigns.
In addition, as long as you separately consent to commercial communication by e-mail or telephone in the course of our cooperation, we will use your e-mail address and telephone number to communicate our commercial offerings.
Operation of the https://glc.pl website and the GLC fanpage on facebook
We process your personal data in order to provide the functionality of our website https://glc.pl and the fanpage run on the facebook portal at: https://www.facebook.com/GLCPodatkiPrawoAudytKsiegowoscHR/, including to enable you to maintain contact with us via the portal and fanpage, as well as to access up-to-date information on our business.
Legal and organizational handling of GLC
We process personal data that we need in order to exercise our rights and enforce the obligations of others who enter into cooperation with us or against whom we have a claim, within the legal and organizational service of GLC. The purpose of the tasks carried out within this unit is to use personal data to perform activities in the preparation, legal instruments, contracts, procedural and extra-procedural pleadings, legal opinions, and to conduct legal analyses related to compliance with established legal norms.
Personal data that we use to write and conclude a contract are processed on the basis of necessity for the purposes of performing the contract, while data related to participation in proceedings before common courts, administrative courts, arbitration courts, public administration bodies and mediation proceedings are processed on the basis of our legitimate legal interest.
GLC ensures that your personal data will only be processed in a lawful manner. This means that we will always process your personal data on a specific basis that we can demonstrate. The basis for processing your personal data may vary depending on the purpose for which we process your personal data.
Conduct of business by GLC
We process personal data of Clients and Contractors mainly to the extent that its use is necessary for the performance of a contract concluded by us or to act on your request prior to its conclusion (Article 6(1)(b) RODO). If a party to the contract is an entity other than you (e.g. we obtained your data from your employer or cooperating entity, or in communication you act as a representative of a company or organizational unit), the basis for processing your personal data will be the use of your data for purposes arising from the legitimate interests pursued by GLC and this entity (third party), e.g. to maintain contact between us to the extent necessary to perform the service.
The realization of our legitimate interests may also involve the processing of data for the purpose of performing operations within the scope of mutual settlements (Article 6(1)(f) RODO). The basis for the processing of your personal data may also be the necessity of the processing for the performance of a task carried out in the public interest – in terms of the performance of a public task for the Ordering Party in accordance with a public purpose agreement (Article 6(1)(e) RODO).
We may also use the data on the basis of legal regulations imposing obligations on us that are inseparable from the need for us to process personal data – such as tax obligations. In that case, the basis for the data we process will be Article 6(1)(c) of the RODO.
For the rest, we may also process personal data on the basis of the consent you have given us.
Operation of the https://glc.pl website
We process data regarding your use of the website, which we obtain through so-called “cookies”, on the basis of your consent given in accordance with Article 173 of the Telecommunications Law.
Cookies are IT data, in particular text files, which are stored on the website user’s terminal device and are intended for use on the website. Cookies usually contain the name of the website from which they come the time of their storage on the end device and a unique number. The cookies we use are mainly used to optimize the use of our websites, to create statistics on their visits and to maintain the user’s session after logging in to certain pages (no need to re-enter the login and password during the specified session time). The processing of your personal data in this regard is done on the basis of our legitimate interest (Article 6(1)(f) of the RODO) and on the basis of your consent, expressed by you by accepting the collection and use of cookies by us in the web form.
Recruitment
In recruitment processes, we seek your consent whenever possible to process your personal data for recruitment purposes by asking you to include the appropriate consent in the resume or cover letter or other application document you submit to us. This avoids any doubt as to whether we have the right to use all the personal data you disclose in the documents you submit or during the recruitment process. If we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time, which will not, however, make the processing of your personal data unlawful during the period in which your consent was in effect (Article 6(1)(a) of the RODO).
Your granting of consent in this regard is voluntary, but necessary for the recruitment process. This is because without your consent to process your data in this area, we will not be able to contact you and carry out the recruitment process.
Making contact
If you contact us by e-mail, the processing of your personal data is necessary for us to take action on your request, according to the content of your inquiry or message (Article 6(1)(b)).
Thus, in this case, the basis for the processing of your personal data will be your consent, or the necessity to use your personal data to take action in accordance with your request, prior to the conclusion of the Agreement. If we process your personal data on the basis of your consent, you have the right to withdraw your consent at any time, which, however, will not deprive the compliance of the lawfulness of the processing of personal data during the period in which your consent was in effect.
Your granting of consent in this regard is voluntary, but necessary for us to make contact.
Indeed, without your consent to the processing of your data in this regard, we will not be able to contact you.
Investigation and defense of claims
If we use your data in connection with the investigation or defense of claims, the basis for the processing of your personal data will be the legitimate legal interest of GLC as a personal data controller. This is because the use of your data will be necessary to protect GLC’s interests, e.g. in the collection of claims, defense against unfounded allegations, etc. (Article 6(1)(f) RODO).
Data in case files
We process the data made available to us in the context of participating in proceedings before common courts, administrative courts, public administration bodies and institutions in connection with the realization of the legitimate interests of the controller related to the need to maintain the financial liquidity and operation of the Wsóadministrators in accordance with the law (Article 6(1)(f) of the RODO), to protect the vital interests of the data subject (Article 6(1)(d) of the RODO) or to fulfill a legal obligation incumbent upon us (Article 6(1)(c))
Marketing purposes
We will process your personal data for marketing purposes only on the basis of your consent, authorizing GLC to send you commercial and marketing messages. We make sure that when you consent to the processing of your data for marketing purposes, you are always aware of this and know that your data will also be used to present you with information about our products or promotions.
We never condition the possibility of establishing and maintaining cooperation with us on your consent to the processing of your data for marketing purposes. This is completely free and voluntary. You have the right to withdraw your consent at any time, which, however, will not make the processing of your personal data during the period in which your consent was in force unlawful.
Legal and organizational support of the Administrator
Personal data that we use to draw up and conclude a contract or use another legal instrument is processed on the basis that the processing is necessary for the performance of the contract (Article 6(1)(b) RODO), while data that we use in connection with enforcing your obligations and exercising our rights is processed on the basis of our legitimate legal interest (Article 6(1)(f) RODO).
The period for which we process your personal data depends on the purpose of the processing. Thus, respectively:
If you are our Client or Contractor, or acting on their behalf
We will process your personal data for the period of performance of the contract or the period of cooperation. After this period, we will process your data for the purposes of accountability of our activities within the framework of personal data protection, as well as for the period of the statute of limitations for claims related to cooperation under applicable laws. In connection with cooperation, we will process personal data no longer than until the end of the next calendar year after which the statute of limitations for claims has expired. Any data processed for accounting purposes and for tax reasons – we will process for five years calculated from the end of the calendar year in which the tax obligation arose. We may also process and store data for a period of time prescribed by separate regulations.
If you disclose your personal data to us in connection with a recruitment drive
We will keep your personal data for the duration of the recruitment process, and if we are not recruiting at the moment – for a period of six years from the date of receipt of your resume or cover letter for current and future recruitment. Keeping your personal data for this period will allow us to contact you if we initiate employment activities at a later date. If you deliver your application documents to us without an ongoing recruitment process, we will process your data for a period of one year from the date of delivery for ongoing and future recruitment efforts.
If you enter into communication with us
We keep your personal data for the entire period of communication and correspondence, and after settling the matter or providing you with a complete response – we keep the data for a period of no more than five (5) more years after the end of the communication, in order to enable you to return to earlier conversations and issues if necessary, and to account for our data protection activities. In any case, personal data shall be processed for a period of not less than the expiration of the statute of limitations for civil law claims related to the action, and, with respect to accounting or source documents, also not less than the statute of limitations for tax liabilities related to the action, due to the need to keep accounting or tax records for that period.
Data in case files
Data obtained in connection with ongoing inspections and audits, as well as accounting and bookkeeping as part of GLC’s accountability, may be kept for the entire period of the pending audit and for the period required by separate regulations in connection with the need to maintain GLC’s accounts and fulfill other obligations incumbent on the controller of personal data.
In any case, personal data shall be processed for a period not shorter than the expiration of the statute of limitations for civil law claims related to the activity, and with regard to accounting or source documents – also not shorter than the statute of limitations for tax liabilities related to the activity, due to the need to keep accounting or tax records for this period.
Data obtained for marketing purposes
Data that we process on the basis of consent given to us – including for marketing purposes we process from the time of consent until the date of its withdrawal, unless a shorter period of storage and processing of personal data is stipulated in the consent document. In any case, personal data shall be processed for a period no shorter than until the expiration of the statute of limitations for civil law claims related to the activity, and with regard to accounting or source documents – also no shorter than until the statute of limitations for tax liabilities related to the activity, due to the need to keep accounting or tax records for this period.
Data processed in the field of general administrative services of the Joint Administrators
Data are processed for the entire period of cooperation and validity of contracts related to the activities performed, and after this period – the period required by law for the maintenance of documentation related to the activities in question. Data in letters or documents are processed for a period of no more than 5 years from the moment of receipt of correspondence, unless a longer obligation arises from other processing activities. In any case, personal data are processed for a period of not less than the expiration of the statute of limitations for civil law claims related to the activity, and with regard to accounting or source documents – also not less than the statute of limitations for tax liabilities related to the activity, due to the need to keep accounting or tax records for this period.
We make sure that your personal data is shared only with those persons who need to have access to it in order for GLC to properly fulfill our cooperation, to carry out our statutory tasks or in connection with legal obligations incumbent on GLC. Your personal data will be shared with:
Under no circumstances will GLC share your data with third parties for commercial purposes.
We do not sell yours, so you do not have to fear that it will go to anyone to whom you did not want to share your data.
Principles of personal data processing
GLC makes every effort to ensure that your personal data are processed in accordance with applicable law and in compliance with the principles of their processing indicated in the RODO. The basic principles and standards for the processing of personal data in our company are set out in a detailed Personal Data Protection Policy, with which it is mandatory for each of our employees and associates to familiarize themselves. Thanks to this, we ensure, that all persons involved in our business are aware of the importance of ensuring the proper processing of your personal data.
The basic principles that guide us in the processing of your personal data are:
Security of personal data
As we mentioned above, we use appropriate technical and organizational measures aimed at ensuring full security of your personal data against their (culpable or accidental) destruction, loss, modification, unauthorized disclosure or unauthorized access.
These measures consist of technical safeguards (due protection of the premises and systems where we process your personal data; safeguards to prevent outsiders from reading the contents of documents containing personal data, back-ups, etc.) and rules and procedures that we require all our employees and associates to follow.
Together, the measures in place allow us to properly protect your personal data from loss or disclosure. In addition, we are improving them all the time, along with the changing environment and technological advances.
In connection with GLC’s processing of your personal data, you have a number of rights that you may exercise at any time. Exercising these rights is free of charge, and GLC makes every effort to ensure that it is also simple to exercise.
Rights related to the processing of personal data
In relation to our processing of your personal data, you have the following rights:
You can exercise the rights mentioned above by reporting them to our email address: kontakt@glc.pl with the note “Personal data”. You are also welcome to contact us at this address in all situations where you have concerns, questions or doubts about how GLC processes your personal data.
Right to object
Separately, we would like to inform you that you have the right to object to the processing of your data. If you consider that in a situation where we are processing your personal data based on the public interest or legal interest of GLC or any third party – we are processing your data too broadly (in an inadequate manner) – you can request that we restrict the processing of your data. You have the same right if at any time you decide that you do not want us to process your data for direct marketing purposes. Once you have objected – we will no longer process your data to that extent and for that purpose, unless it is necessary due to the existence of some valid legitimate basis for our processing of your data, overriding your interests, rights and freedoms; or to establish, assert or defend our claims.
You may exercise the rights referred to above by submitting them to our email address: kontakt@glc.pl with the subject line “Personal Data”. You are also welcome to contact us at this address in all situations where you have concerns, questions or doubts about how GLC processes your personal data.
The right to file a complaint
If you consider that we have in any way violated the rules of processing your personal data then you have the right to file a complaint directly to the supervisory authority, which is the President of the Office for Personal Data Protection.
In exercising this right, you should give a full description of the situation and indicate what action you consider to have violated your rights or freedoms. The complaint should be submitted directly to the supervisory authority.
