Privacy Policy
Privacy Policy at OT Port Świnoujście S.A.
I. INTRODUCTION
This policy describes how OT Port Świnoujście S.A. (dalej: „my”), (“We”), collects and uses personal data, defines the purposes and legal basis of the processing and provides information on the rights of data subjects.
This policy has been written on the basis of the applicable legislation on the processing of personal data, in particular the Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in relation to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC – (‘GDPR’).
We want to be transparent about the basis and manner in which we process personal data. We take special care to ensure the security of the personal data we process. We apply safeguards appropriate to the identified risks and derived from internationally recognised security standards, and our information security management system for our customers’ data complies with the requirements of ISO/IEC 27001.
II. DATA CONTROLLER AND CONTACT DETAILS
The controller of the personal data is OT Port Świnoujście S.A. Świnoujście, Bunkrowa street 1, 72-602 Świnoujście, registered in the Register of Entrepreneurs of the National Court Register kept by the District Court Szczecin-Centrum in Szczecin, XIII Economic Department of the National Court Register under the number 0000700026, using the National Business Registry Number 810515378 and the Tax Identification Number 8550003580.
If you have any questions about this privacy policy and the purposes and manner in which we process your personal data, you can contact us as follows:
- by post to the address: OT Port Świnoujście S.A., Bunkrowa street 1, 72-602 Świnoujście;
In order to guarantee transparent and lawful processing of personal data, we have appointed a Data Protection Officer in our company. You can contact him or her by e-mail, sent to: iod@otlogistics.pl.
III. TRANSFER OF DATA TO THIRD PARTIES
We transfer or disclose the personal data we collect to third party support service providers. We use providers of services such as technical support for IT functions, including management and maintenance of IT systems and their security, web hosting, data storage services, as well as information security and property protection services and legal and business advice.
It is our policy to only use third-party service providers who are committed to confidentiality (we have signed data processing trust agreements with them) and they provide an adequate level of data protection. External service providers are vetted before engaging with us to ensure that they provide an adequate level of personal data security and comply with applicable legal requirements.
In addition, we may provide personal data to public authorities if required to do so by applicable law.
IV. PLACE OF PROCESSING
We process all personal data of our stakeholders within the European Economic Area (EEA). We have to assume that in exceptional cases, in particular due to IT service providers, data may be processed outside the EEA, but this will always be done in accordance with applicable laws.
V. PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA AND THE DURATION OF DATA STORAGE
Below, in the thematic sections, we provide information on the purposes for which we collect and use personal data, the legal basis for the processing and the length of time for which we store them.
A. Contact with us
When you contact us through various communication channels, including telephone, email, traditional correspondence or social media, the personal data provided as part of that communication is processed for the sole purpose of resolving the matter to which the communication relates.
| Purpose of processing | Legal basis | Storage time |
| Contacting the data subject in order to resolve the matter in relation to which the communication to us has been initiated via email, traditional correspondence, telephone call, social media. | The legitimate legal interest of the controller (article 6(1)(f) of the GDPR), consisting of the need to resolve a reported matter related to our business. | Pending the final outcome of the case
or the lodging of an effective objection. |
The provision of personal data for the above purpose is voluntary, but without it we will not be able to contact you and respond to your case.
B. Social media (Facebook, LinkedIn)
We have public profiles on the social networks Facebook and LinkedIn. As such, we process personal data of users visiting these profiles (including comments, likes, web IDs).
| Purpose of processing | Legal basis | Storage time |
| Maintaining company profiles, publishing information about our services, initiatives and other activities.
Enabling visitors to be active on our profiles.
Analytical and statistical activities related to visitor activity on our profiles. Establishing, pursuing or defending against claims. |
The legitimate legal interest of the controller (article 6(1)(f) GDPR) to promote its own brand and improve the quality of its services and (if necessary) to pursue and defend against claims. | Until an effective objection has been lodged or until the case has been finally settled, including an administrative decision or court judgment becoming final. |
The above information does not apply to the processing of personal data by the administrators of individual social networks.
The provision of personal data for the above purposes is voluntary.
C. Participation in recruitment processes
This section applies to those involved in the recruitment processes we organise.
| Purpose of processing | Legal basis | Storage time |
| Carry out and resolve the recruitment process when the preferred form of employment is an employment contract. | Fulfilment of obligations, arising from the law, related to the employment process (Art. 6(1)(c) GDPR) in conjunction with Art. 221 § 1 para. 1 – 6 of the Labour Code Act. | Until the recruitment process is completed. |
| Verification of candidates’ qualifications and skills. | The legitimate legal interest of the controller (article 6(1)(f) of the GDPR) to verify that candidates meet the requirements for the position and to select a suitable candidate. | Until the recruitment process is completed. |
| Carrying out and resolving the recruitment process when the preferred form of
employment is a civil law contract. |
Necessity for the conclusion of the contract (article 6(1)(b) GDPR).
|
Until the recruitment process is completed. |
| Processing in the recruitment process of other categories of personal data than those required under the provisions of the Labour Code and special categories of personal data: data that relate to health status (if applicable). | Consent of the data subject [(article. 6(1)(a) and 9(2)(a) GDPR)]. | Until the end of the recruitment process or until you withdraw your consent, whichever comes first. |
| To contact you about job vacancies that we think may be of interest to you and for future recruitment processes. | Consent of the data subject [(article. 6(1)(a) and 9(2)(a) GDPR)]. | Up to 1 year or until you withdraw your consent, whichever comes first. |
| Establishing, pursuing or defending against claims, in connection with the recruitment processes carried out. | Legitimate legal interest of the controller (article 6(1)(f) of the GDPR) consisting of the possible assertion and defence of claims. | Up to 3 years or until the case is finally settled, including an administrative decision or court judgment becoming final. |
The provision of personal data for the above purposes is:
- a condition for participation in the recruitment process and possible conclusion of a contract – for the purposes of processing carried out on the basis of article 6(1)(b) and (f) GDPR,
- a statutory requirement – for the purposes of processing carried out on the basis of article 6(1)(c) GDPR,
- voluntary – for the purposes of processing carried out on the basis of article 6(1)(a) and article 9(2)(a) of the GDPR.
D. Representatives and contact persons nominated by our business partners
This section refers to the representatives and contact persons of the companies that are our business partners with whom we establish cooperation.
| Purpose of processing | Legal basis | Storage time |
| Business partner verification.
Establishing and maintaining cooperation. |
Necessity for the conclusion of a contract (article 6(1)(b) GDPR) (in the case of sole traders).
Legitimate legal interest of the controller (article 6(1)(f) GDPR) to enable the correct and effective performance of the contract, ongoing contact with our business partners i.e. their employees/co-workers (in the case of entities other than sole traders). |
For the duration of the cooperation and including the guarantee of the contract or service. |
| Confirmation by OT Logistics S.A. of the fulfilment of its obligations.
Establishing, asserting or defending against claims.
|
Legitimate legal interest of the controller (article 6(1)(f) of the GDPR) to ensure accountability and the possible assertion and defence of claims. | Up to 3 years or until a final settlement of the case, including an administrative decision or court judgment becoming final |
The provision of personal data for the above purposes is: a condition for entering into a contract and a contractual requirement – for the purposes of processing carried out pursuant to article 6(1)(b) and (f) GDPR.
VI. INFORMATION ON YOUR RIGHTS TO REQUEST FROM THE CONTROLLER
- Right of access to data
You have the right, at any time, to request information about what personal data we hold. To request such information, please contact us.
A. Right of portability
Where we process your personal data by automated means, based on the consent you have given us or the contract you have entered into, you have the right to receive a copy of your data in a structured, commonly used and readable format. This copy may be sent to you directly or to another entity designated by you and only relates to the personal data you have provided to us.
B. Right of rectification
You have the right to request the correction of your personal data at any time if it is incorrect, and to complete incomplete data.
C. Right of erasure
You have the right to delete the personal data we process at any time. Please note that this right is not absolute and, as a controller, we have the right to refuse to delete those data for which we have a basis for processing (e.g. in order to comply with a legal obligation or to assert or defend against claims that may be made against us).
D. Right to object to the processing of data
You have the right to object at any time to the processing of your personal data, to the extent that we process this data on the basis of a legitimate interest of the controller. We will then cease processing your personal data unless we can find a lawful justification for doing so that overrides your interest or rights. You will, of course, be informed of this.
E. Right to withdraw consent to data processing
For these purposes where the processing of personal data takes place on the basis of article 6(1)(a) or article 9(2)(a) – you have the right to withdraw your consent at any time without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal.
F. Right to limitation
You have the right at any time to request the restriction of the processing of your personal data under the terms of the GDPR.
In order to exercise the above rights, please send an e-mail to the address indicated in para. II above.
If, in your opinion, we process your personal data in an inappropriate manner, please contact us. You also have the right to lodge a complaint with the President of the Personal Data Protection Office.
VII. FINAL PROVISIONS
For all of the above processing purposes, we do not profile your personal data and we do not make any automated decisions.
If you are in any doubt about our processing policies or the identity of the controller responsible for processing your data, we encourage you to contact us at any time.
It may be necessary to update this Privacy Policy in the future. The latest version will always be available on our website.