GDPR | Privacy Policy | Trasko Invest

A. Information Clause
A.1. General Information Clause
Hereby, taking into account Article 13(1) and (2) of the General Data Protection Regulation of April 27, 2016 (Regulation/GDPR), Trasko Invest sp. z o.o. (Trasko Invest) with its registered office at al. Wolności 13, 63-500 Ostrzeszów, informs that your personal data will be processed by Trasko Invest for the purpose of: responding to your inquiry regarding (a) Invoices and payments; (b) Media inquiries; (c) Offers; (d) Employment; (e) Advertising and promotions; (f) Investor relations; (g) Internships and apprenticeships; (h) other areas specified in the content of the inquiry – depending on the consent provided by you.
Information regarding the contact details of the Data Protection Officer at Trasko Invest sp. z o.o. with its registered office at al. Wolności 13, 63-500 Ostrzeszów - email: dane.osobowe@trasko.pl.
The processing of your personal data will be based on consent (Article 6(1)(a) of the Regulation). Your personal data will be stored until the consent for processing is withdrawn.
You have the right to access the content of your data and the right to rectify, delete, limit processing, the right to data portability, the right to object, and the right to withdraw consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
You have the right to lodge a complaint with a supervisory authority if you believe that the processing of your personal data infringes applicable data protection laws.
Providing your personal data is a requirement for obtaining a response to your inquiry.
Information on how to submit any requests, inquiries, and notifications regarding personal data at Trasko Invest sp. z o.o. can be obtained by sending an individual inquiry to the Data Protection Officer at email: dane.osobowe@trasko.pl
Providing personal data is voluntary.
A.2. Information Obligation towards Clients/Contractors
How do we process your data? (Information Obligation)
1. Scope of data:
We process the following categories of your data: identification data (first and last name of persons representing the client/contractor, name of the business entity, NIP, REGON), contact data (phone number, email address), and correspondence data (registered office address of the business entity, correspondence address), data regarding concluded contracts, financial data, bank account number;
2. Administrator:
The administrator of your personal data is Trasko Invest sp. z o.o. with its registered office in Ostrzeszów, registered in the Entrepreneurs Register by the District Court in Poznań IX Economic Division KRS Poznań - Nowe Miasto and Wilda KRS 0000034789, NIP 5140120304, REGON 250794970;
3. Contact with the Company's Data Protection Specialist:
You can contact the Company's Data Protection Specialist by traditional mail at the Company’s registered office with the note "Data Protection Officer" or electronically at the email address: dane.osobowe@trasko.pl;
4. Purposes and basis of processing:
Since there is a contract binding you with the Company, your personal data is processed for the following purpose:
a) to fulfill the concluded contract (legal basis: Article 6(1)(b) of the Regulation of the European Parliament and Council (EU) 2016/679 of April 27, 2016, on the protection of natural persons in connection with the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation), "GDPR");
b) to document the concluded contract and its settlement, based on tax and accounting regulations (legal basis: Article 6(1)(c) GDPR);
c) for internal administrative purposes of the Company, including statistics and internal reporting of the Company as part of our legitimate interest (legal basis: Article 6(1)(f) GDPR);
d) archival (evidential) for the realization of our legitimate interest in securing information in the event of a legal need to demonstrate facts (legal basis: Article 6(1)(f) GDPR);
e) for the potential establishment, pursuit, or defense against claims, being the realization of our legitimate interest (legal basis: Article 6(1)(f) GDPR);
f) to handle complaints, in case they are submitted, regarding the execution of the contract connecting you with the Company (legal basis: Article 6(1)(b) GDPR);
g) to handle complaints, in case they are submitted, regarding the quality of the performance of obligations arising from the concluded contract and the service by the Company's employees (legal basis: Article 6(1)(f) GDPR).
5. Data recipients:
The recipient of your personal data will be Trasko Invest sp. z o.o.
6. Retention period:
In the case of processing personal data based on your voluntary consents, we may process the data until you withdraw your consent or we determine that it has become outdated. Data processed based on the legitimate interests of the data controller may be processed until the legitimate interests of the Company that form the basis for this processing are fulfilled or until you raise an objection to such processing. Data processed in other respects may be processed for a period not exceeding 6 years.
7. Information about rights:
You have the right to access the content of your data and the right to rectify, delete, limit processing, the right to data portability, the right to object to data processing, the right to withdraw consent at any time without giving a reason, without affecting the lawfulness of processing based on consent before its withdrawal;
8. Right to lodge a complaint:
You have the right to lodge a complaint with the President of the Personal Data Protection Office if you believe that the processing of your personal data violates the provisions of the GDPR;
9. Right to object:
You have the right to object at any time to the processing of your data based on the legitimate interest described above. We will cease processing your data for these purposes unless we can demonstrate that we have compelling legitimate grounds that override your interests, rights, and freedoms, or the data is necessary for the establishment, exercise, or defense of legal claims.
10. Your personal data is not subject to automated decision-making, including profiling related to automated decision-making;
11. Withdrawal of consent:
In the case of processing personal data based on consents, you have the right to withdraw your consent at any time by directly contacting the Company in writing at the Company's registered address with the note "Personal Data," without giving a reason, and without affecting the lawfulness of processing based on consent prior to its withdrawal. If you exercise this right, we will cease processing data for the purpose covered by the previously given consent;
12. Providing personal data is voluntary but necessary for the conclusion of the contract. Failure to provide data will result in the inability to conclude the contract.
A.3. Data protection in the recruitment process
Information regarding the processing of personal data in the recruitment process at Trasko Invest sp. z o.o. – employment based on an employment contract/civil law contract.
1. Data Controller
The personal data of the candidate applying for this position (Candidate) will be processed by "Trasko Invest sp. z o.o." in Ostrzeszów, correspondence address: al. Wolności 13, 63-500 Ostrzeszów.
2. Data Protection Officer
To ensure the security and confidentiality of Candidates' personal data at Trasko Invest sp. z o.o., we have appointed a Data Protection Officer, with whom Candidates can contact directly:
1) Email at the following email address: dane.osobowe@trasko.pl
2) By written correspondence to the registered address of Trasko Invest sp. z o.o. mentioned above with the note "Data Protection Officer"
3. Purposes and duration of processing Candidates' personal data
Candidates' personal data will be processed solely for recruitment purposes:
- solely for the position for which the Candidate is applying, for the period necessary to conduct the recruitment process and select a candidate, and then for a period of three months until the appropriate employment contract is signed;
- if the Candidate gives separate consent for their application to be included in the candidate database for employment at Trasko Invest sp. z o.o., also for other similar positions at Trasko Invest sp. z o.o. for a period of 1 year.
4. Legal bases for processing personal data
Trasko Invest sp. z o.o. requests to provide in recruitment applications only:
1) Information required by labor law, including information about held entitlements or special circumstances, if their possession/fulfillment is required by specific legal provisions to perform work at this position;
2) Contact information necessary to potentially invite Candidates to the next stage of recruitment (as a legitimate interest of Trasko Invest sp. z o.o. and the Candidates).
Providing the above personal data is voluntary; however, not providing it may prevent the Candidate from being invited to the further recruitment process or may affect the outcome of the Candidate's verification regarding meeting the formal requirements for the recruited position.
If the Candidate decides to include additional information in their application that exceeds the scope of the required information specified in the announcement, they are obliged to include in their application the following consent: "I consent to the processing of my personal data contained in this recruitment application for recruitment purposes by Trasko Invest sp. z o.o. based in Ostrzeszów."
If the Candidate does not include the above consent and does not supplement it at a later stage of the recruitment process, no later than before the first recruitment meeting, their application will be immediately deleted, and the Candidate will be required to submit a new application containing only the information indicated by Trasko Invest sp. z o.o. in the announcement.
5. Disclosure of Candidates' personal data
Trasko Invest sp. z o.o. does not disclose Candidates' personal data to other administrators, unless such an obligation has been imposed on Trasko Invest sp. z o.o. by law.
If the Candidate has consented to their personal data being placed in the job candidates database, the Candidate's recruitment application may be verified by Trasko Invest sp. z o.o. concerning recruitments conducted for the needs of other "Trasko" companies. However, before Trasko Invest sp. z o.o. shares the recruitment application with another "Trasko" company, it will contact selected Candidates and request their consent to transfer the application.
6. Rights of individuals whose personal data is being processed
The Candidate has the right to:
1) Withdraw their consent at any time and without giving a reason. Withdrawal of consent does not affect the lawfulness of the processing of the Candidate's personal data prior to its withdrawal, which means that the processing of personal data before the withdrawal of consent remains legal, but at the moment of withdrawal of consent, Trasko Invest sp. z o.o. is obliged to cease processing (art. 7 GDPR);
2) Request from Trasko Invest sp. z o.o. information about the processing of their personal data, i.e., confirmation of whether the Candidate's personal data is being processed. If the Candidate's data is being processed, they are entitled to access it, obtain a copy of it, and receive the following information: the purposes of processing, categories of personal data, information about recipients or categories of recipients to whom the data has been or will be disclosed, the period of data retention or the criteria for determining it, the rights of the Candidate related to the processing of their personal data, the possibility of lodging a complaint with a supervisory authority, the source of the personal data if it was not obtained directly from the Candidate, and information about profiling and automated decision-making (art. 15 GDPR);
3) Rectify personal data concerning that Candidate. If the Candidate learns that their personal data processed by Trasko Invest sp. z o.o. is incorrect, outdated, or incomplete, they have the right to request its immediate rectification or completion (art. 16 GDPR);
4) Request the deletion of the Candidate's personal data, provided that if the Candidate has consented to the processing of personal data, the request for deletion will have the same effect as the withdrawal of consent (art. 17 GDPR);
5) Request the restriction of processing of personal data (art. 18 GDPR), i.e., request to cease processing except for storage in situations where:
The Candidate contests the accuracy of the personal data for the period during which Trasko Invest sp. z o.o. will verify its accuracy;
The Candidate contests the lawfulness of the processing of personal data by Trasko Invest sp. z o.o.;
Trasko Invest sp. z o.o. no longer needs these data, but they are needed by the Candidate to establish, assert, or defend their claims;
The Candidate has lodged an objection to the processing until a decision is made by Trasko Invest sp. z o.o. regarding the legitimacy of the objection;
6) Raise an objection to the processing of the Candidate's personal data for legitimate purposes by Trasko Invest sp. z o.o.;
7) Transfer their personal data, i.e., receive in a structured, commonly used format suitable for machine reading the personal data they provided to Trasko Invest sp. z o.o., if its processing is based on the Candidate's consent, or request to send this data to another administrator specified by the Candidate (art. 20 GDPR).
To exercise the above rights, the Candidate should send a letter or email to the contact details provided in point 1, indicating which right they wish to exercise, to what extent, and how. Please include your contact details in the letter, which will enable quick communication with the Candidate during the exercise of their rights, especially if there is a need to verify the Candidate's identity or clarify which right or to what extent the Candidate wishes to exercise (it would be best if this were a phone number).
7. Supervisory Authority
The supervisory authority regarding personal data protection in Poland is the President of the Personal Data Protection Office based in Warsaw, ul. Stawki 2, email address: kancelaria@uodo.gov.pl. The Candidate has the right to lodge a complaint with the PUODO against Trasko Invest sp. z o.o. in any case, particularly if they believe that Trasko Invest sp. z o.o. is processing their personal data incorrectly or unjustifiably refusing to fulfill their rights.
Trasko Invest sp. z o.o. makes every effort to ensure high protection of Candidates' personal data and assistance in exercising their rights related to personal data processing. Therefore, if an incident concerning personal data processing occurs that concerns the Candidate, please contact the Data Protection Officer of Trasko Invest sp. z o.o., who will provide all necessary assistance and explanations, and will also take clarifying actions if needed.

B. Privacy Policy
Table of Contents:
I. Introduction
II. Collection of Personal Data
III. Legal Basis for Processing Personal Data
IV. Purposes of Processing Personal Data
V. Security of Personal Data
VI. Recipients of Personal Data
VII. Rights of the Data Subject
VIII.1. Acceptance of the Application
VIII.2. Processing of Personal Data in Connection with the Application Handling

I. Introduction
One of the essential aspects of business activity is the necessity of processing personal data. Data that allows for the identification of individuals is used in our daily work and concerns, among others: potential and current employees, clients, and contractors of Trasko Invest sp. z o.o. Due to the significant impact of breaches of the security of such data on the personal rights of individuals, their processing must be conducted with caution, in compliance with the law, and in accordance with the internal information security policy.
On May 25, 2018, the General Data Protection Regulation (GDPR) came into force.
The GDPR standardizes the approach to personal data protection across the European Union, increasing the insight and influence of every individual on what happens to their data and promoting principles such as:
• compliance with the law, fairness, and transparency,
• purpose limitation,
• data minimization,
• storage limitation,
• integrity and confidentiality,
• accountability for the processing of personal data.

Trasko Invest sp. z o.o. approaches the protection of personal data with due diligence and ensures a high level of security in the processes of their processing.
Below you can find basic information regarding the processing and protection of personal data of individuals used by Trasko Invest sp. z o.o. in its business activities.

II. Collection of Personal Data
Trasko Invest sp. z o.o. collects personal data of individuals by interacting with them in the course of providing its services and products. Most data is provided to the Company directly by the individuals to whom the data pertains. We also receive data about individuals from other companies, e.g., contact details of subcontractor employees, etc.
In any way that data comes into our possession, it must always be in accordance with the law.

III. Legal Basis for Processing Personal Data
At Trasko Invest sp. z o.o., personal data is collected and processed primarily based on the grounds arising from:
• voluntary consent,
• the performance of a contract,
• the necessity of fulfilling legal obligations,
• and the pursuit of legitimate interests of Trasko Invest sp. z o.o., such as pursuing claims or conducting marketing activities for its own products and services.

IV. Purposes of Processing Personal Data
The company Trasko Invest sp. z o.o. uses personal data to deliver products and services to its Clients. In particular, we process it for the realization of:
• construction investments;
• residential investments;
• services for the maintenance and modernization of buildings and industrial facilities, maintenance of road infrastructure.
We also use the data to protect the health and life of individuals involved in our projects, maintain investor relations, analyze the performance of companies in the Group, fulfill our legal obligations, and develop human resources.

V. Data Protection Measures
The company has decided to appoint a Data Protection Officer capable of directing and supervising the processes of personal data processing.
The basis on which personal data protection measures are built at Trasko Invest sp. z o.o. is the Information Security Policy of Trasko Invest sp. z o.o. established and accepted by authorized representatives of "Trasko Invest sp. z o.o."
As a result, our organization has a number of formal and technical regulations regarding access to and the ability to process personal data depending on the type of process being carried out. The discussed principles are uniform both internally and externally within our organization – they apply to employees of the Company as well as all individuals and entities that process information, including personal data, on behalf of and for the Company.
The compliance of the aforementioned regulations with international information security standards is confirmed by independent certification centers and audits.
The requirements of the standards mentioned in the above paragraph indicate the implementation of rigorous rules for responsible, supervised information processing, ensure effective and systematic improvement of the system, and demonstrate the maturity of the organization in the discussed area.

VI. Recipients of Personal Data
Trasko Invest sp. z o.o. uses the services of subcontractors, suppliers, and contractors to whom it may disclose processed personal data.
Disclosure of personal data may only occur if necessary to achieve the processing purpose indicated to the data subject, in accordance with applicable regulations and ensuring adequate protection of the processed personal data.

VII. Rights of the Data Subject
In the context of the processing of your personal data by Trasko Invest sp. z o.o., it should be noted that you have the right to request access to your personal data, their rectification, deletion, restriction of processing, or transfer.

VIII. Handling Requests, Inquiries, and Notifications Regarding Personal Data at Trasko Invest sp. z o.o.

VIII.1. Submission of a Request
All requests, inquiries, and notifications regarding personal data processed at Trasko Invest sp. z o.o. should be directed to the address:
data.osobowe@trasko.pl
The request should contain at least:
• A title containing the content: "Personal Data - Request - <phrase indicating the subject of the request>",
• The content of the request.

The department handling the request reserves the right to:
• directly contact the requester to verify and/or clarify the request;
• verify the identity of the requester;
• reject the request in justified cases compliant with regulations.
Verification of the identity of the requester may be done by having them perform one (or more) of the following actions before a designated employee responsible for handling the request:
• presenting an identity document at the administrator's office;
• providing the content of data that is in the data administrator's collection and which unequivocally confirms the identity of the verified person;
• sending to the administrator a request/electronic message signed with a valid qualified electronic signature of the requester.

VIII.2. Processing of Personal Data in the Context of Request Handling

By sending the request, you confirm that you have read the following information.
The administrator of your personal data is Trasko Invest sp. z o.o., al. Wolności 13, 63-500 Ostrzeszów, contact phone: 62 732 20 83.
Trasko Invest sp. z o.o. processes your personal data to fulfill a legal obligation of the administrator (art. 6 para. 1 lit. c GDPR).
The scope of data includes information provided in the request as well as data obtained during its handling.
Contact details of the Data Protection Officer: dane.osobowe@trasko.pl.
Recipients of personal data may include IT solution providers, entities from the Trasko Invest sp. z o.o. group, and other entities if necessary to achieve the above purposes.
Personal data will be stored for the time necessary to achieve the aforementioned purposes.
You have the right to request access to your personal data from Trasko Invest sp. z o.o., to rectify, delete, or limit the processing of your data, as well as the right to object to processing and the right to data portability. You have the right to lodge a complaint with a supervisory authority. Providing personal data is voluntary, and failure to provide data will prevent the processing of your request.