Data Controller

Adlook Poland sp. z o.o.

seat: ul. Złota 61/101,00-819 Warszawa

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Purpose of the processing

• execution of contracts;
• negotiations;
• conducting other business operations;
• direct marketing activities,
• settlement issues.

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Categories of personal data

Personal data contained in emails sent to Adlook staff which may include:

• email address;
• names and surnames;
• mobile phone number;
• employer (or contractor) data;
• position in a company;
• business licenses numbers;
• social media information (usernames, links to profiles etc.);
• representation of a signature.

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Legal basis for the processing

The legal basis is dependent on the purpose of conversation conducted with Adlook staff. It might be either:

• necessity to enter into a contract with you or in order to take steps at your request prior to entering into a contract or;
• our legitimate interest based resulting from: conducting negotiations, performance of contracts, executing settlements.

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Sources of the personal data

We obtain your data either directly from you (upon receiving your email) or from your employers, contractors or colleagues who share it with us (e.g. by cc’ing you to a conversation thread).

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Recipients of the personal data

Your personal data may be disclosed to:

• members of Adlook staff and
• our subcontractors

only if it is necessary for the purposes set out above.

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Data subject’s rights

You have the following rights with respect to your personal data:

• the right to object to processing of the personal data for direct marketing purposes or, on grounds relating to your particular situation, whenever the legal basis for processing is controller’s legitimate interest;
• the right to access to the personal data;
• the right to obtain from the controller restriction of processing,
• the right to request that your personal data be corrected if it is found to be inaccurate or out of date;
• the right to request your personal data be erased where it is no longer necessary for the controller to retain such data;
• the right, where there is a dispute in relation to the accuracy or processing of your personal data, to request a restriction is placed on further processing;
• the right to request that the data controller provide you with your personal data and where possible, to transmit that data directly to another data controller.

You are entitled to request a copy of your personal data processed by the controller.

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Contact Information

In all issues related to processing of personal data and exercise of your rights concerning the processing of your personal data, you may contact us via the following means:

• by mail, to the following address: ul. Złota 61/101,00-819 Warszawa;
• by e-mail: dpo@adlook.com.

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Profiling

We do not conduct profiling of your personal data described herein.

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Retention period

Your personal data shall be retained for the period necessary to accomplish purposes indicated above.

Personal data processed for the purposes of the execution of contracts are processed until potential claims are time-barred.

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If cooperation is established, personal data contained in accounting documents are stored for the period of storage of accounting records and limitation period for claims claimed in civil proceedings or covered by criminal or tax proceedings.

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Personal data processed on the basis of legitimate interest of the controller can be processed until an objection is made or a period of data usefulness expires.

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Transfers to third country and safeguards

Adlook shall not transfer or permit any of your Personal Data to be transferred to a territory outside of the EEA unless it has taken such measures as are necessary to ensure the transfer is in compliance with Applicable Laws. Such measures may include transferring the Personal Data to a recipient in a country that provides adequate protection for Personal Data or pursuant to Standard Contractual Clauses or similar mechanism.

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If you wish to find the list of the countries which the European Commission recognised as providing adequate protection click here.

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Furthermore, you are entitled to obtain a copy of the security policy of transferring the data outside the EEA. In order to obtain such a copy, please contact us.

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Further Processing

If we wish to use your personal data for a new purpose, not covered by this notice, we will provide you with a new notice explaining this new use prior to commencing the processing and setting out the relevant purposes and processing conditions. Where and whenever necessary, we will seek your prior consent to the new processing.

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Contact details and lodging a complaint with supervisory authority

To exercise all relevant rights, queries of complaints please in the first instance contact Adlook via e-mail dpo@adlook.com.

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You are entitled to lodge a complaint with the competent supervisory authority, in particular in the Member State of your habitual residence, place of work or of an alleged infringement of the GDPR. Please find the contact details to supervisory authorities which have jurisdiction over our activity:

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POLAND

President of the Personal Data Protection Office

2 Stawki St.

00-193 Warszawa, Poland

T:  +48 606-950-000

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