This Privacy Policy, which is also a privacy statement, explains who and to what extent processes personal data as part of our website, and as part of the activities carried out by LSN spółka z ograniczoną odpowiedzialnością, with its registered office in Gdańsk, entered into the Register of Entrepreneurs kept by the District Court Gdańsk-North in Gdańsk, 8th Commercial Division of the National Court Register, under KRS number: 0000320716, REGON: 220726488; NIP: 5851445845 (hereinafter: LSN) and LSNH Monoprósopi Anónymi Etaireía, Athens, registered in the Greek commercial register G.E.M.I. under number 145254201000 and with the following tax number 800933594 (hereinafter: LSNH). LSNH and LSN are hereinafter also referred to together as the Company. At the same time, the Privacy Policy also contains within its scope a description of the applicable principles for the processing of personal data, including the rights to which data subjects are entitled, and generally defines the scope and purpose of the processing of personal data. The Privacy Policy applies only to those personal data processing processes that are exclusively carried out by the Company. Thus, the Privacy Policy does not apply to our business partners, contractors or social media applications, which have their own internal rules for processing personal data. The personal data processed by the Company is processed within the countries of the European Economic Area. If data is transferred outside the EEA, the transfer is based on the relevant legal regulations which secure the security of the processed personal data.

DATA ADMINISTRATOR

Due to the specific legal relationship, the main entity processing of your personal data may be LSN or LSNH. In principle, LSN and LSNH are the administrators of the website. The term of data administrator refers to the definition of data administrator in 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 "GDPR"). Each of the Administrators has appointed a Data Protection Officer (hereinafter: "DPO") who can be contacted in writing at LSN or electronically at: [email protected].

PROCESSING OF PERSONAL DATA

When using the website, you are under no obligation to provide your personal data. However, personal data voluntarily provided by you may be collected and processed through its use. At the same time, we process your personal data in accordance with the requirements of generally applicable data protection legislation, including the GDPR.

THE PERSONAL DATA WE PROCESS AND THE PURPOSES OF THE PROCESSING

As part of our processing of personal data collected via the website, it is only used for the following purposes: the establishment of cooperation of an economic nature related to the business purposes of LSN or LSNH. This applies in particular to personal data such as: name, surname, email address, physical address, telephone number, function and position. This personal data is processed in connection with contracts concluded between LSN and/or LSNH and cooperating entities or for the purpose of establishing cooperation / submitting offers of cooperation, for employment and recruitment purposes. In this respect, the personal data processed may be (but is not limited to) such as indicated and required by generally applicable laws, including the Labour Code, e.g.: name, surname, date of birth, contact details, education, professional qualifications, previous employment history. We process the provided personal data for the purposes indicated above, based on the legal grounds provided for in GDPR, included in Article 6(1) GDPR. Each time, the period for which the personal data may be stored is specified, after which it is deleted. As part of the personal data provided and entrusted to the Company, we do not use automated decision-making, including profiling. Detailed information related to the processing of personal data within the framework of the specific legal relationship created, where personal data is shared, is included in the specific and shared information clauses.

BASIC PRINCIPLES OF PERSONAL DATA PROCESSING

LSN and LSNH process personal data on the basis of the basic principles of processing. These are the following principles: lawfulness, fairness and transparency, purpose limitation, data minimalization, accuracy, storage limitation, integrity and confidentiality, accountability.

RIGHTS YOU HAVE

If Company process your personal data, you have the following rights: the right to be informed about the personal data we process, the right of access to your personal data, the right to rectification, erasure or restriction of the processing of your personal data to the extent that this is possible and is not prevented by other legislation or the legitimate interest of the controller, the right to object, the right to personal data portability, where personal data are processed on the basis of consent given, the possibility of withdrawing consent at any time without affecting the lawfulness of processing carried out on the basis of consent before its withdrawal, the possibility of filling a complaint to the competent supervisory authority.

TRANSFER OF PERSONAL DATA

We process data, including personal data to our business partners, for the proper operation and functioning of LSN and LSNH. We process personal data to, among others: entities that support Company with IT support, maintain the IT infrastructure and provide hosting, entities providing outsourcing services of all kinds, our business partners in connection with the fulfilment of our business purposes, in particular data concerning: persons representing our contractors, including proxies, board members, persons assisting in the performance of tasks related to our business purposes, tenants, collaborators, employees and any other persons where the transfer of such personal data is necessary and indispensable, to authorised co-workers and employees, entities carrying out marketing activities on our behalf, entities operating social media, entities authorised under generally applicable law, including entities to which LSN and/or LSNH are legally obliged to entrust and/or make available the personal data processed.

PROTECTION OF PERSONAL DATA

In order to ensure the security of the processed data, including personal data, the Administrator applies appropriate technical and organisational measures. For example, the office area is appropriately secured, access control has been introduced, and appropriate measures ensuring IT security are used. Necessary and legally required registers are also kept, such as: the register of processing activities, the register of processed data categories and others.

SOCIAL MEDIA

Our website may use applications connected to social media, through which you can share content with other users of these media. The personal data entered by the user in this way are processed not only by the Company, but also by the respective social network. The respective social network processes the personal data provided by you as an entity independent of us, over which we have no control or influence. Accordingly, we will not be liable for any infringement against you due to your data being made available on the respective social network. Generally, if Company has an account or fanpage on a particular social network, Company has joint control over the personal data you provide to Company. The social networks that may have access to personal data in connection with the use and tracking of Companies’ accounts on these networks is Linkedin.

COOKIES

Detailed rules relating to the Cookies Policy can be found here

CONTACT

For all matters relating to the processing of personal data, you can contact us by e-mail at the following e-mail address: [email protected] or in writing at the following address: LSN sp. z o.o., ul. Grunwaldzka 501, 80 320 Gdańsk.

CHANGES TO THE PRIVACY POLICY

Due to possible changes to the Privacy Policy, this Privacy Policy may be subject to updates. The updated Privacy Policy will be applicable from the date of the update.

IOD CONTACT

Paweł Foltman

[email protected]