Due to the fact that the Lubawa Group and the Trusted Partners operate on the basis of joint controlling, pursuant to Article 26 of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (hereinafter referred to as “the GDPR”), on 24.05.2018 we concluded an Agreement on joint controlling of personal data.

Each of the Controllers makes every effort to ensure the security of the processing of your data and you may ask any of them any questions you may have.

As part of the Agreement concluded we have agreed that, in particular:

1. each Joint Controller shall be responsible on its own and within the scope of its own activities, for:
   1. examining the grounds for processing and the lawfulness of the personal data collected by it and entered into the Systems,
   2. the accuracy and validity of the personal data entered,
   3. providing data subjects with information in accordance with Articles 13 and 14 of the GDPR,
2. each Joint Controller is responsible for ensuring that you are able to exercise your rights referred to in point 6 below. If you want to exercise any of the rights, the Joint Controller to whom you sent your request will forward it to the other Joint Controllers for execution, and then respond to you in accordance with the rules and within the time limits set forth in Article 12 of the GDPR.
3. The Joint Controller Litex Service sp. z o.o. with its seat in Ostrów Wielkopolski also ensures the external security of IT systems against unauthorized access as well as their internal organization, providing the best protection possible, and is responsible for:
   1. introduction of appropriate technical measures for the functioning of IT systems allowing for their proper and faultless functioning and protection of personal data against threats, in particular against unauthorised access, unauthorised alteration, loss, damage or destruction.
   2. introducing methods and means of authentication of access to personal data and backing up data contained in databases,
   3. managing those systems and their users’ authorisations;
   4. anonymization of the data stored in computer systems after the expiry of the retention period.

We have jointly agreed on the following purposes of processing your data:

1. keeping sales records,
2. better adjustment of the offer to the contractors and customers’ needs,
3. more efficient service provided to potential and current customers,
4. improving the HR management systems,
5. improving recruitment processes and selection of job offers tailored to the required qualifications and requirements to be met by candidates,
6. introducing optimal solutions concerning HR & payroll as well as financial and accounting systems.

Your personal data will be processed by other entities providing services to the Controller, such as financial settlements, protection of property and persons; accounting, legal, advisory, consulting and archiving services; maintenance of IT equipment and computer programs in which the data are collected, any other services supporting the Controller’s activities in connection with the performance of contracts concluded by the Controller with third parties or you. 

Each of the Joint Controllers is responsible for ensuring that the data subjects are able to exercise their rights, that are:

1. the right to access their personal data and to receive a copy of them;
2. the right to rectify and correct their personal data;
3. the right to delete data;
4. the right to limit their processing;
5. the right to object to the processing of data;
6. the right to data portability;
7. the right to lodge a complaint with a supervisory authority;
8. the right to withdraw consent to the processing of personal data.

In order to exercise these rights, please contact the Controller or use the point of contact established by us (details below).

The Joint Controllers have established a single point of contact to allow you to exercise your rights and to protect your Personal Data. The point of contact is run by Litex Service, which accepts requests from data subjects sent by letter to: Litex Service sp. z o.o., ul. Staroprzygodzka 117, 63-400 Ostrów Wielkopolski or by e-mail to [email protected]

The Joint Controllers agree that they will not transfer the Personal Data to third countries unless the Joint Controllers should so decide due to special circumstances. Transfers to third countries may be carried out only in accordance with the rules laid down in Articles 44 to 50 of the GDRP.

We may amend and supplement this Privacy Policy as necessary. We will inform you of any changes or additions by posting relevant information on our website https://lubawagroup.com, and in the event of material changes we may also send you separate notices to the e-mail address indicated by you.