.png)
GENERAL PROVISIONS:
VALUESHIPS Sp. z o.o. (hereinafter referred to as "VALUESHIPS" or "Controller") attaches particular importance to respecting the privacy of the Persons whose data it processes in the course of its activities, including the privacy of the Users visiting the website www.valueships.com administered by VALUESHIPS (hereinafter referred to as the "Site").
VALUESHIPS is responsible for controlling the personal data that is collected and processed as part of our cooperation with you. We respect your privacy and will protect the personal data we process. All personal data is processed in accordance with current data protection legislation.
The purpose of this privacy policy is to inform you of the types of personal information we collect when you enter into a particular relationship with us, use our Service or interact with us directly and the steps we take to protect and secure your personal information.
This Policy and its principles apply to personally identifiable information (personal data) that we may ask you for and use whether on the basis of your consent or other grounds that entitle us to process personal data. You will find more about this later in this Policy.
Personal Data Controller - within the meaning of Article 4(7) 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 (hereinafter: "RODO"), the Controller of personal data is VALUESHIPS Spółka z ograniczoną odpowiedzialnością with its registered office at ul. Wielka 67, 53-340 Wrocław, entered into the National Court Register - Register of Entrepreneurs by the District Court for Wrocław Fabryczna in Wrocław, VI Economic Division of the National Court Register, under KRS no. 0000870565, NIP 8943161057, REGON no. 38757217900000, share capital PLN 16,500.00.
2.1 In connection with its business activities, VALUESHIPS collects and processes personal data in accordance with the relevant legal provisions, including in particular the RODO, and the data processing rules provided for therein.
2.2 The controller ensures transparency in the processing of personal data, in particular always informs about the data processing at the time of collection, including the purpose and legal basis of the processing (e.g. when concluding a contract for the sale of goods or services). VALUESHIPS ensures that data are collected only to the extent necessary for the stated purpose and processed only for the period of time necessary.
2.3 When processing personal data, VALUESHIPS shall ensure its security and confidentiality and access to information about the processing to data subjects. If, despite the security measures in place, a breach of personal data protection (e.g. data "leakage" or data loss) were to occur, VALUESHIPS will inform the data subjects of such an event in a legally compliant manner.
3.1 Any demands, requests, notifications, enquiries concerning your personal data processed by the Controller, including with regard to access to their content, manner of updating or withdrawal of consent to their processing, may be sent by e-mail to dataprivacy@valueships.com or in writing to VALUESHIPS SP. z o.o., ul. Wielka 67, 53-340 Wrocław.
3.2 VALUESHIPS is not obliged to appoint a Data Protection Officer, nor has one been appointed by a voluntary decision of VALUESHIPS.
4.1 In order to ensure data integrity and confidentiality, VALUESHIPS has implemented procedures to ensure that personal data can only be accessed by authorised persons and only to the extent that this is necessary due to the tasks they perform. VALUESHIPS applies organisational and technical solutions to ensure that all operations on personal data are recorded and performed only by authorised persons.
4.2 VALUESHIPS furthermore takes all necessary measures to ensure that also its subcontractors and other cooperating entities guarantee the application of appropriate security measures whenever they process personal data on behalf of VALUESHIPS.
4.3 VALUESHIPS conducts an ongoing analysis of the risks involved in the processing of personal data and monitors the adequacy of the data security measures applied to the identified risks. Where necessary, VALUESHIPS implements additional measures to enhance data security.
5.1. APPLICATION FOR VACANT POSTS
a. PURPOSE OF PROCESSING : If you submit a job application to VALUESHIPS, your personal data will be processed for the following purposes:
In the event that the processing of your personal data should take place for a purpose other than those indicated above, each time this will take place after obtaining your prior consent to the processing of your personal data, to the extent and for the purpose indicated in this consent (basis under Article 6(1)(a) RODO).
b. LEGAL BASIS : The basis for the processing of the aforementioned personal data is the performance of an obligation imposed by law (Article 6(1)(c) RODO) or our legitimate interest (Article 6(1)(f) RODO), as well as, in the cases indicated above, consent.
c. DATA SOURCES : We collect your personal data directly from you when you apply for a position; through another person who recommends you for a job at VALUESHIPS, if you have given your prior consent; from publicly available sources such as LinkedIN or recruitment platforms; in cooperation with recruitment and other placement agencies.
d. SCOPE OF DATA : Among other things, we process the following types of personal data: first name(s) and surname, date of birth, contact details you have indicated, including telephone number, email address, nationality, education, date of birth, place of birth, professional qualifications, previous employment history, found in your curriculum vitae (CV) and cover letter, and provided in the course of a job interview or in connection with the conduct of qualification or screening tests.
e. PROCESSING TIME - DATA RETENTION : The duration of the processing of your personal data depends on the purpose for which the data are processed:
f. OBLIGATION TO PROVIDE DATA : The provision of data is voluntary, although necessary for the application to be considered in the recruitment process.
5.2. E-MAIL AND TRADITIONAL CORRESPONDENCE
a. PURPOSE OF PROCESSING: If you address VALUESHIPS via e-mail or traditional correspondence unrelated to the contract or otherwise unrelated to any relationship with VALUESHIPS, the personal data contained in this correspondence is processed solely for the purpose of communication and resolution of the matter to which the correspondence relates.
b. LEGAL BASIS: The legal basis for the processing is the legitimate interest of VALUESHIPS (Art. 6(1)(f) RODO), consisting of correspondence addressed to it in connection with its business activities.
c. SCOPE OF DATA: VALUESHIPS only processes personal data relevant to the matter to which the correspondence relates, e.g. e-mail address, name of sender/recipient, position, personal data included by the sender in the content of the correspondence. All correspondence is stored in such a way as to ensure the security of the personal data (and other information) contained therein and is only disclosed to authorised persons.
d. DURATION OF PROCESSING - DATA RETENTION: In the case of processing on the basis of a legitimate interest, the data shall be processed for a period of time allowing the fulfilment of that interest or until an effective objection to the processing is raised, up to a maximum of three years in the form of an email on the mail server. The processing period may be extended if the processing is necessary for the establishment or assertion of claims or the defence against claims, and thereafter only if and to the extent required by law.
e. OBLIGATION TO PROVIDE DATA: The provision of data is voluntary, although necessary for the handling of cases and the maintenance of the relationship carried out in correspondence.
5.3. TELEPHONE CONTACT
a. PURPOSE OF PROCESSING: When contacting VALUESHIPS by telephone, on matters not related to the contract or business relationship, VALUESHIPS may request personal data only if this is necessary to handle the matter to which the contact relates. Telephone calls may also be recorded, in which case the individual is informed at the beginning of the call. Calls are recorded to keep a record of the call and to generate a record of the agreement or conclusion reached and for statistical purposes. The recordings are only available to those directly involved in the implementation of the matters covered by the subject of the recorded conversations.
b. LEGAL BASIS: The legal basis in this case is the legitimate interest of VALUESHIPS (Article 6(1)(f) RODO), consisting of the need to resolve a reported case related to its business activities. Personal data in the form of a recording of the call is processed for the purpose of monitoring the call and documenting the requests, as well as for analytical and statistical purposes - the legal basis for the processing is the consent of the person being recorded (Article 6(1)(a) RODO).
c. SCOPE OF DATA: VALUESHIPS processes only personal data relevant to the matter to which the communication relates, i.e. the caller's telephone number, the caller's name, position, personal data contained by the caller relevant to the activities carried out covered by the consent to register. All correspondence is stored in a manner ensuring security of personal data contained therein (and other information) and disclosed only to authorised persons.
d. DURATION OF PROCESSING - DATA RETENTION: The duration of data processing by VALUESHIPS depends on the purpose of the processing. If processing is carried out on the basis of the legitimate interest of VALUESHIPS, data are processed for the period of time that enables the fulfilment of this interest or until an effective objection to the processing is raised. If processing is based on consent, data are processed until the consent is withdrawn.
e. OBLIGATION TO PROVIDE DATA: The provision of data is voluntary, although necessary for the handling of cases and the maintenance of the relationship carried out by telephone. If a recording of the call is made, you may withdraw your consent at any time.
5.4. HANDLING CONTRACTS WITH B2B COUNTERPARTIES (INCLUDING NEGOTIATION AND CONCLUSION OF CONTRACTS)
a. PURPOSE OF PROCESSING: In connection with the conclusion of commercial and service contracts in the course of its business activity, VALUESHIPS collects data of persons representing the Parties from the Contracting Parties in order to conclude the contract and to fulfil contractual obligations including financial obligations. Such data can be collected already at the stage of contractual negotiations at the stage of request for quotation, offer, contract with annexes and annexes amending contractual terms and conditions as well as in correspondence related to contract execution.
b. LEGAL BASIS: The processing of personal data is necessary for the performance of the contract with the Party you represent or upon request to act for the Party prior to the signing of such contract (Art. 6(1)(b) RODO) as well as necessary for the fulfilment of VALUESHIPS' legal obligations of keeping accounting and tax records (Art. 6(1)(c) RODO) as well as may be necessary for the purposes of the legitimate interests pursued by VALUESHIPS, i.e. pursuing and defending against claims Art. 6(1)(f) RODO).
c. SCOPE OF DATA: VALUESHIPS only processes data identifying the persons representing the contractual parties, data necessary for the settlement of contractual obligations.
d. DURATION OF PROCESSING - DATA RETENTION: When the basis for processing is necessity for the conclusion and performance of the contract, the data are processed until the contract is terminated. The processing period of the data contained in the accounting and tax documentation is based on the legal provisions. Due to possible claims of the Parties to the contract, personal data may be subject to processing for a further 3 years - for business-related claims, 6 years - for consumer claims, 10 years - for consumer claims established by a final decision of a court or authority, arising and not time-barred before 9 July 2018. (with the exception of accounting documents) or until you raise an effective objection to the processing.
e. OBLIGATION TO PROVIDE DATA: The provision of data is voluntary, although necessary for the signing of the contract.
5.5. PROCESSING OF PERSONAL DATA OF STAFF MEMBERS OF B2B CONTRACTORS WORKING WITH VALUESHIPS
a. PURPOSE OF PROCESSING: In connection with the conclusion of commercial and service contracts in the course of its business activities, VALUESHIPS obtains data from contractors on persons involved in the performance of such contracts (e.g. persons authorised to contact, placing orders, executing orders, etc.). The extent of the data provided is in each case limited to the extent necessary for the performance of the contract and does not normally include information other than name and business contact details.
b. LEGAL BASIS: Such personal data are processed in order to pursue the legitimate interest of VALUESHIPS and its contractor (Article 6(1)(f) RODO) in enabling the correct and effective performance of the contract. Such data may be disclosed to third parties involved in the performance of the contract, as well as to entities accessing the data on the basis of public information disclosure regulations and proceedings conducted on the basis of public procurement law, to the extent provided for by these regulations.
c. SCOPE OF DATA: VALUESHIPS only processes personal data relevant for the performance of the contractual relationship to which the communication relates, i.e. business telephone number, business e-mail address, name, position.
d. DURATION OF PROCESSING - DATA RETENTION: The duration of data processing by VALUESHIPS depends on the purpose of the processing. The duration of data processing may also be based on legislation, where they form the basis for processing. Where data are processed on the basis of the legitimate interest of VALUESHIPS (e.g. for security reasons), the data are processed for a period of time enabling the fulfilment of this interest, i.e. at least for the duration of the contract binding VALUESHIPS and the entity you represent or until you raise an effective objection to the processing.
e. OBLIGATION TO PROVIDE DATA: The provision of data is voluntary, although necessary for the establishment of a business relationship with your employer or principal. Without the provision of your data, it is not possible to establish any cooperation in the form envisaged by your employer in connection with your job description.
5.6. DATA COLLECTION IN OTHER CASES
a. PURPOSE OF PROCESSING: In connection with its business activities, VALUESHIPS also collects personal data in other cases - e.g. by building and using lasting mutual business contacts (networking) at business meetings, industry events or by exchanging business cards - for the purposes of initiating and maintaining business contacts.
b. LEGAL BASIS: The legal basis for the processing in this case is the legitimate interest of VALUESHIPS (Art. 6(1)(f) RODO), consisting of networking in connection with its activities.
c. SCOPE OF DATA: VALUESHIPS only processes personal data relevant for the purposes of communication in the business relationship, i.e. e.g. business telephone number, business e-mail address, name, position.
d. DURATION OF PROCESSING - DATA RETENTION: Where data are processed on the basis of a legitimate interest of VALUESHIPS (e.g. for security reasons), the data are processed for a period of time that enables the fulfilment of this interest or until an effective objection to the processing is raised.
e. OBLIGATION TO PROVIDE DATA: The provision of data is voluntary, although necessary to establish a business relationship. Without the provision of your data, it is impossible to establish any relationship.
5.7. WEBSITE ACTIVITY
a. PURPOSE OF PROCESSING: Your activity on the Website, including your personal data, is recorded using cookies and social plug-ins, which you can read more about in the Cookie Policy dedicated to them. We process the personal data provided in the form used to contact the Suppliers in order to maintain the business relationship and communicate on the services provided.
b. LEGAL BASIS: The legal basis for the processing of personal data is the legitimate interest of VALUESHIPS (Art. 6(1)(f) RODO), consisting of the need to guarantee the Service Users' access to the content of the Service and communication through the channels available through the Service, and to keep statistics through the Service in order to improve its functionality.
c. SCOPE OF DATA: VALUESHIPS only processes personal data recorded via cookies and data provided in connection with an enquiry sent via the Service's contact form.
d. DURATION OF PROCESSING - DATA RETENTION: Where data are processed on the basis of a legitimate interest of VALUESHIPS (e.g. for security reasons), data are processed for the period of time that enables the fulfilment of this interest or until an effective objection is raised against the processing. In the case of installed cookies, their processing is carried out until consent is withdrawn.
e. OBLIGATION TO PROVIDE DATA: The provision of data is voluntary, although necessary for the handling of cases and the maintenance of the relationship carried out in communication through the Service.
5.8 ONLINE EVENTS
a. PURPOSE OF PROCESSING: If you register for our online events and workshops (in particular webinars), your personal data will be processed for the following purposes: the conclusion of the contract, i.e. the fulfilment of your order to participate in the event, including acceptance of the registration, sending of the invitation to the event, fulfilment of the legal obligation to issue and post invoices (if you provide personal data for the invoice), as well as for financial reporting and, in addition, for the purpose of ongoing contact, processing of possible complaints, securing of claims.
b. LEGAL BASIS: The legal basis for the processing of personal data by VALUESHIPS is Article 6(1)(b) RODO, i.e. the performance of the event contract or the participant's request prior to its conclusion; Article 6(1)(c) RODO in conjunction with the Act of 29 September 1994. on Accounting, the Act of 29 August 1997 on the Tax Ordinance and the Act of 11 March 2004 on Value Added Tax - for paid events; Article 6(1)(f) RODO i.e. VALUESHIPS' legitimate interest for the purposes of pursuing claims or promoting the brand and services.
c. SCOPE OF DATA: VALUESHIPS processes basic identification data (first and last name, name of your profile, email address) to the extent provided by you for the purpose of registering for an event; other data provided, for example, for the purposes of maintaining contact, business communication or marketing communication.
d. DURATION OF PROCESSING - RETENTION OF DATA: data necessary for the performance of the contract / handling of a complaint are processed for the time necessary for its performance and thereafter until the statute of limitations for claims that may arise from the conclusion of the contract; data processed for contact purposes are stored for the time necessary for the performance of the contact / answering of queries and thereafter until the end of the calendar year following the year in which the case was resolved or the contact ended; data necessary for the performance of a paid event will be stored up to a maximum of 5 years calculated from the end of the financial year in which the accounting document was issued.
e. OBLIGATION TO PROVIDE DATA: The provision of data is voluntary, although necessary for the handling of online events and the maintenance of the relationship carried out in the communication through the event platforms.
5.9. SOCIAL NETWORKS
a. PURPOSE OF PROCESSING: VALUESHIPS processes the personal data of Users visiting VALUESHIPS profiles maintained on social media (LinkedIn). This data is processed exclusively in connection with the running of the profile, including to inform Users about VALUESHIPS activities and to promote various events, educational publications, services and products.
b. LEGAL BASIS: The legal basis for VALUESHIPS' processing of personal data for this purpose is its legitimate interest (Article 6(1)(f) RODO) in promoting its own brand.
c. SCOPE OF DATA: VALUESHIPS processes basic identification data (name, name of your profile) to the extent published by you on your own profile on the social network LinkedIn; other data made public by you on your LinkedIn profile.
d. TIME OF PROCESSING - DATA RETENTION: VALUESHIPS processes the data of the Users of the Services for the period of VALUESHIPS' legitimate interest, for the period when the User follows the VALUESHIPS profile and, in the case of communication via the Services, for the time necessary to close the conversation.
e. OBLIGATION TO PROVIDE DATA: We obtain all your data through social networking companies from your public profile and posts on the VALUESHIPS fanpage. The provision of data is voluntary, although, in the case of communication through social networks, it is necessary in order to handle matters and maintain the relationship carried out in the communication.
5.9. MARKETING ACTIVITIES, INCLUDING NEWSLETTERS. LEAD MAGNET
a. PURPOSE OF PROCESSING: VALUESHIPS processes personal data of Contractors, Users of services, participants of VALUESHIPS organised events for marketing purposes, which means in particular promotion of our offer of services in accessible forms accepted by recipients of communication.
As part of our marketing, we want to be able to present offers and promotions tailored to the interests of our audience on our website. For this purpose, we carry out profiling activities, which, however, will in no case affect your rights or freedoms or affect you in any other similar way.
In addition, provided that you have given your separate consent to commercial communication by e-mail or telephone, we will use your e-mail address and telephone number to communicate commercial offers for our products.
The Controller processes Users' personal data in order to carry out marketing activities, which may consist of:
b. LEGAL BASIS: The legal basis for VALUESHIPS' processing of personal data for this purpose is its legitimate interest (Art. 6(1)(f) RODO) in promoting its own brand and, as regards recipients who have not yet engaged in business communication, Art. 6(1)(a) RODO - consent of the recipient. The choice of communication channel, i.e. consent to communicate by e-mail or to provide marketing information by telephone, also requires consent from the recipient of the communication in accordance with Polish law to which VALUESHIPS is subject, i.e. in accordance with Article 172 of the Telecommunications Law and Article 10 of the Act on Rendering Electronic Services.
c. SCOPE OF DATA: VALUESHIPS processes basic identification data (first and last name, your profile name, e-mail address, business telephone number, details of the company you represent, your company's industry profile, other individually provided data concerning the assessment of our offer and needs).
d. TIME OF PROCESSING - DATA RETENTION: VALUESHIPS processes the data of the Users of the Services for the period of VALUESHIPS' legitimate interest, and in the case of processing personal data on the basis of consent. You may withdraw your consent at any time by sending an email to: [dataprivacy@valueships.com The withdrawal of consent will not affect the compatibility of processing carried out on the basis of consent before its withdrawal.
e. OBLIGATION TO PROVIDE DATA: The provision of data is voluntary, although necessary for VALUESHIPS to select a dedicated offer and update its own offers in relation to market needs.
6.1 In connection with the carrying out of activities requiring processing, personal data is disclosed to external entities, including in particular suppliers responsible for the operation of IT systems and equipment, a security agency carrying out monitoring tasks, entities providing legal or accounting services, couriers and transport companies.
6.2 The sharing of personal data is only permitted if one of the conditions referred to in either Article 6(1) or Article 9(2) of the RODO is met.
6.3 The entrustment of the processing of personal data to a third party shall take place on the basis of a data processing entrustment agreement.
6.4 VALUESHIPS reserves the right to disclose selected information concerning the data subject to the competent authorities or to third parties who request such information on the appropriate legal basis and in accordance with the provisions of the applicable law.
The level of protection of personal data outside the European Economic Area ("EEA") differs from that provided by European law. For this reason, VALUESHIPS transfers personal data outside the EEA only when necessary and with an adequate level of protection, primarily by:
In connection with the Controller's use of tools or services provided by third parties, your personal data may be transferred to a third country, in particular to:
1. Google LLC, 1600 Amphitheatre Parkway Mountain View, CA 94043, USA
2. LinkedIn Corporation, 1000 West Maude Avenue, Sunnyvale, CA 94085, USA.
3. Pipedrive, Inc., 490 1st Ave South, Suite 800 St. Petersburg, FL 33701, USA.
In the situation of these service providers, VALUESHIPS transfers personal data using the Standard Contractual Clauses, pending a decision of the European Commission on the adequate protection of personal data by the USA - in accordance with Article 45(3) RODO.
For more information on the transfer of your personal data to third countries, please contact us directly by sending:
by e-mail to: dataprivacy@valueships.com
8. PERIOD OF PROCESSING OF PERSONAL DATA
The duration of data processing by VALUESHIPS depends on the purpose of the processing. The duration of data processing may also be based on legislation where this is the basis for processing. If processing is carried out on the basis of the legitimate interest of VALUESHIPS (e.g. for security reasons), data are processed for the period of time that enables the fulfilment of this interest or until an effective objection to the processing is raised. When processing is based on consent, data is processed until the consent is withdrawn. When processing is based on the necessity to conclude and perform a contract, data are processed until the contract is terminated.
The processing period may be extended if the processing is necessary for the establishment or assertion of claims or the defence against claims, and thereafter only if and to the extent required by law.
9. RIGHTS RELATING TO THE PROCESSING OF PERSONAL DATA RIGHTS OF DATA SUBJECTS .
Data subjects have the following rights:
10. TO REQUEST THE EXERCISE OF RIGHTS
10.1 A request for the exercise of Data Subjects' rights can be made:
10.2 If VALUESHIPS is unable to identify the individual on the basis of the request made, it will ask the applicant for additional information. It is not mandatory to provide such data, but failure to do so will result in the request being refused.
10.3 The request may be made in person or through a proxy (e.g. a family member). For reasons of data security, VALUESHIPS encourages the use of a power of attorney in a form certified by a notary public or an authorised solicitor or barrister, which will significantly speed up the verification of the authenticity of the request.
10.4 The application should be responded to within one month of receipt. If it is necessary to extend this period, VALUESHIPS shall inform the applicant of the reasons for this action.
10.5 Where the request has been addressed to the Company electronically, a response shall be given in the same form, unless the requester has requested a response in another form. In other cases, the response shall be given in writing. Where the timing of the request makes it impossible to respond in writing and the extent of the applicant's data processed by VALUESHIPS makes it possible to be contacted electronically, a response shall be provided electronically.
10.6 The Company shall keep information regarding the request made and the person who made the request, in order to ensure that compliance can be demonstrated and for the purpose of establishing, defending or asserting possible claims by data subjects. The register of requests shall be stored in a manner that ensures the integrity and confidentiality of the data contained therein.
11. CHANGES TO THE PERSONAL DATA PROCESSING POLICY .
11.1 The policy is kept under review and updated as necessary.
11.2 Information on the current version of the Policy is included in the document header.
