Globema Privacy Policy

In connection with the 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 (general data protection regulation) (“GDPR”), as well as the information obligation resulting from these provisions, we would like to inform you in this document in a transparent manner how we care for your personal data and how we process it.

We pay special attention to respecting the privacy of visitors to its websites. The data we collect are used only to manage the website and are not intended to identify users of our websites.

Please, find below detailed information on the personal data processing:

To whom our Privacy Policy is intended?

If:
you visit our websites operated by a given Controller, indicated below (“Websites”); including if you use the functional possibilities provided by the Services, such as the possibility of contacting us via the electronic contact form, or you subscribe to our Newsletter or visit our official social media accounts such as: LinkedIn, Twitter, YouTube, Facebook, Instagram run by a given Controller (“Social Media Accounts”) (“User”);

as a natural person you are a (potential) customer, supplier, subcontractor, contractor of the Controller, etc. (“Contractor”), or as a natural person you are a (potential) customer, supplier, subcontractor, contractor, etc. of the Contractor of a given Controller (“Contractor of Our Contractor”);
you are a natural person acting on behalf of the Contractor or the Contractor of our Contractor (“Representative”);
you contact the given Controller by phone or SMS, by e-mail, contact forms available on our Websites, or by traditional mail in any matter, or the given Controller contacts you and you are not the Contractor, the Contractor of our Contractor or the Representative at the same time (“Contacting Person”);

our privacy protection applies to the processing of your personal data, i.e. all information which identifies or enables you to be identified directly or indirectly.

Who processes your personal data?

The Controller of your personal data is:

How can you contact a given controller?

You can contact the given Controller:

Is giving your personal data voluntary?

Providing us your personal data is voluntary, but necessary for the purposes for which it is provided by you, and collected and further processed by the given Controller. It is necessary, respectively, to contact you, conclude an agreement with you or the entity you represent, or to perform the agreement concluded with you or the entity you represent.

The consequence of not providing your personal data is the inability to perform the above actions by the given Controller (for example, failure to provide personal data may result in the inability to contact you, the inability to conclude an agreement with you or the entity you represent, or the inability to implement our obligations arising from the agreement concluded with you or the entity you represent).

In connection with the User’s use of the Websites, the given Controller also collects information about the User’s activity on the Websites. The given Controller uses information identifying natural persons (their personal data), such as IP address or other identifiers and information collected via cookies or other similar technologies.

What source do we have your personal data from?

In most cases, we receive your personal data directly from you, i.e. directly from the data subject. This is the case, for example, when you voluntarily provide your personal data when sending us the contact form on our Websites, when you apply for a position in our team or even in the process of negotiating and concluding a contract with a given Controller.

With regard to the Contractors, the Contractors of our Contractors, the Representatives and the Contacting Persons, we may also obtain your personal data from other sources, such as:

your employers / principals / associates, entities you represent;
contractors of your employer / principal / associates, entities you represent;
publicly available sources, including information made available on websites or on public accounts in professional social media (i.e. LinkedIn), or in public electronic databases of entrepreneurs.

In the case of obtaining your personal data from sources other than directly from you, the given Controller (in accordance with the principle of minimizing the processing of personal data) may process the following categories of your personal data: name and surname, official position, business address, correspondence address, telephone number, e-mail, company (name) of business activity, company address, tax identification number, as well as information about what type of cases you deal with.

On what legal basis, for what purpose and for how long do we process your personal data?

Your personal data is processed by the given Controller for the following purposes, on the following legal basis and in the following period:

in order to send the Newsletter, including information about our products and services, as well as information from the IT world, about trends in the industry, our achievements and product news or interesting industry events – then the legal basis for the processing of your personal data is your consent (Article 6 paragraph 1 point (a) of the GDPR) – in this case, your personal data is processed until you resign from receiving the Newsletter or withdraw your consent;

in order to interact with you using the Social Media Accounts by a given Controller – then the legal basis for the processing of your personal data is the legitimate interest of the given Controller (Article 6 paragraph 1 point (f) of the GDPR) consisting in promoting the given Controller’s products and brand and building and maintaining a community related to the given Controller’s brand – in this case, your personal data is processed for the period of the given Controller’s keeping the given Social Media Account, but no longer than until you take appropriate action resulting in the removal of your personal data from the given Social Media Account (e.g. you will remove your comment or your like);

for the purpose and to the extent necessary to conclude and perform agreements between you as the Contractor and the given Controller – then the legal basis for the processing of your personal data, as one of the parties to the contract, is the necessity to process them for the Controller to perform the agreement concluded with you (Article 6 paragraph 1 point (b) of the GDPR) – in this case, your personal data is processed for the duration of such agreements;

in order to contact with the Representatives by the given Controller on current matters (e.g. arrangements for cooperation, answering questions, etc.) in connection with the conclusion or performance of agreements concluded by the given Controller with the Contractors or the Contractors of our Contractor – then the legal basis for the processing of your data personal data is the legitimate interest of the Controller (Article 6 paragraph 1 point (f) of the GDPR) consisting in the implementation of the agreement concluded by us – in this case, your personal data is processed for the duration of the agreement;

for the purpose of communication (e.g. by phone and e-mail) and answering questions and doubts related to the services and products of any of the Controllers and their activities – then the legal basis for the processing of your personal data is the legitimate interest of the given Controller (Article 6 paragraph 1 point (f) of the GDPR) consisting in conducting correspondence in connection with the conducted business activity – in this case, your personal data is processed for the period necessary to effectively achieve the purpose of contact chosen by the Contacting Person;

in order to fulfill the statutory obligations incumbent on the given Controller, resulting in particular from tax and accounting regulations, including obligations related to documenting economic events (issuing invoices) and archiving obligations – then the legal basis for the processing of your personal data is the legal obligation imposed on the given Controller (Article 6 paragraph 1 point (c) of the GDPR) – in this case, your personal data is processed for the period in which mandatory legal provisions require the given Controller to store your personal data, e.g. for accounting or tax purposes;

in order to possibly establish and pursue claims or defend against them by the given Controller – then the legal basis for the processing of your personal data is the legitimate interest of the given Controller (Article 6 paragraph 1 point (f) of the GDPR) consisting in the protection of its rights and interests – in this case your personal data is processed for the period of performance by the given Controller of the obligations arising from agreements concluded with the Contractors, including until the expiry of the limitation period for claims arising from these agreements;

for analytical and statistical purposes – then the legal basis for the processing of your personal data is the legitimate interest of the Controller (Article 6 paragraph 1 point (f) of the GDPR) consisting in conducting analyzes of Users’ activity, as well as their preferences in order to improve the functionalities of the Services used – in in this case, your personal data is processed for the period of analyzes and statistics conducted by the given Controller on the Websites.

Who do we share your personal data with?

In connection with conducting business that requires the processing of personal data, your personal data (to a reasonable extent) may be transferred to the following recipients:
entities related by capital to the given Controller;
postal operators or entities conducting courier activity;
entities conducting payment activity (banks, payment institutions, including those providing payment services, factoring services, etc.) and insurance;
entities cooperating with us that provide legal services, accounting and tax services to the given Controller, as well as statutory auditors, auditors, advisory and consulting companies, etc.;
entities maintaining servers and providing hosting services, internet domain operator, suppliers and entities maintaining IT systems and entities providing other similar services to the given Controller.

In addition, we would like to inform you that due to the transnational nature of data flow within social media portals (Facebook, LinkedIn, YouTube, Twitter, Instagram), if you visit Social Media Accounts, some of your personal data may also be processed by the owners of the above-mentioned social networks. Please be advised that, as tool providers, these owners are jointly responsible for the processing of your data, if you use Social Media Accounts. They may process your data for their own purposes based on other legal grounds on the terms specified by them (links below), including the transfer of your personal data to third countries (it is not dependent on any Controller):
Facebook (owned by Facebook Ireland Ltd.): link and link
Instagram (owned by Facebook Ireland Ltd.): link
LinkedIn (owned by LinkedIn Ireland Unlimited Company): link
YouTube (owned by Google Ireland Ltd.): link
Twitter (owned by Twitter, Inc.): link
The basis for such transfer are standard contractual clauses approved by the European Commission, used by the above-mentioned owners of social networks.

In addition, if you are a subscriber to our Newsletter, your personal data is transferred to entities providing, at the request of the given Controller, the activities of managing the collective mailing of the Newsletter to subscribers, including the entity providing the Mailchimp application. In this case, your personal data may be transferred to third countries, and the basis for such transfer are standard contractual clauses approved by the European Commission. More information in this regard can be found here.

What rights do you have in relation to the processing of your personal data?

Each Controller ensures that you have the right to:

the right to withdraw consent – your consent to the processing of your personal data may be withdrawn at any time, without giving any reason, and the withdrawal of such consent will not affect the lawfulness of processing based on consent before its withdrawal;

As part of the Newsletter, we try to provide the most interesting and accordant content to the interests of recipients. However, if you decide that you no longer want to receive the Newsletter from us, you can unsubscribe at any time and withdraw your consent, in accordance with the above. For this purpose, you should click the “unsubscribe” / “unsubscribe” link in the footer of our Newsletter or write to us directly at unsubscribe@globema.com.

the right to access data – the possibility of requesting access to your personal data from the given Controller, e.g. by obtaining confirmation whether / which your personal data (what categories) is processed by the given Controller, obtaining information, among others, about the purpose of processing, recipients or categories of recipients of data, the planned period of data storage or the criteria for determining this period, etc., obtaining a copy of this personal data;

the right to rectify data – the possibility of requesting the given Controller to rectify (correct, supplement, update) your personal data that is incorrect, incomplete, including by presenting an additional statement;

the right to erasure of data – the possibility of requesting the given Controller (only in certain situations) to delete your personal data, e.g. when your personal data is not necessary for the purposes for which it was collected or otherwise processed, or when it was processed inconsistently with the law;

the right to restrict of processing – the possibility of requesting the given Controller to limit the processing of your personal data when:
– you question the correctness of your personal data – then the processing may be limited for a period allowing the given Controller to check the correctness of this data;
the processing is unlawful and you oppose the erasure of the data and request the restriction of their processing instead;
– the given Controller no longer needs your personal data for processing purposes, and at the same time you need them to establish, assert or defend your claims;
– you have objected to the processing of your personal data – then the processing may be limited until it is determined whether the legitimate grounds on the part of the Controller override your objection;

the right to data portability – the possibility of requesting the given Controller to transfer your personal data (if the processing is necessary for the given Controller to perform an agreement to which you are a party, or is based on your consent and if such processing is carried out by automated means), including receiving a copy of your personal data in a structured, commonly used and readable format; this copy may be sent to you or to another entity (another Controller), as long as it is technically possible;

the right to object – the possibility of objecting to the given Controller to the processing of your personal data – on grounds relating to your particular situation, in the case of processing your personal data as part of the legitimate interest pursued by the given Controller, as well as in the case of their processing in direct marketing purposes.

You can exercise the rights indicated above by:

  In addition, you have the right to lodge a complaint with the supervisory authority for the protection of personal data if you believe that the processing of your personal data by the given Controller violates the provisions of the GDPR.

If you request a copy of your personal data, you may be liable to pay the statutory fee. If we store any of your personal data that is incorrect or if there have been any changes to your data, please notify us to enable us to keep accurate and up-to-date records.

How do we process personal data of job applicants?

If you apply for a position to our team, in particular if you send the given Controller your CV or other application documents containing your personal data, the data processing process of the given Controller is based not only on the GDPR, but also on the applicable labor law provisions, which also contain guidelines in the field of processing of personal data. Detailed information in this regard is provided by the given Controller in the recruitment process for a specific position.

How do we use cookies?

Our Websites use cookies. Cookie files (so-called cookies) are IT data, in particular text files, which are stored on your end device and are intended for the use of websites.
Cookies are used for the following purposes:
creating statistics that help to understand how users use websites, which allows improving their structure and content;
maintaining the user’s session (after logging in), thanks to which the user does not have to re-enter the login and password on each subpage of the Website;
determining the user’s profile in order to display him matched materials in advertising networks, in particular the Google network.
By using cookies in the manner described above, we never identify the identity of users on the basis of information stored in cookies.
Our websites use two basic types of cookies: session cookies and persistent cookies. Session cookies are temporary files that are stored on your end device until you log out, leave the website or turn off the software (web browser). Persistent cookies are stored on the end device for the time specified in the cookie file parameters or until they are deleted.
Cookies can be used by advertising networks, in particular the Google network, to display advertisements tailored to the way the user uses the website. For this purpose, they may keep information about the user’s navigation path or the time spent on a given page.
Most web browsers are initially set to automatically accept cookies. However, you can change your browser settings so that cookies are blocked – in whole or in part, e.g. only from third parties, or to receive a message each time cookies are sent to your device. Detailed information on the possibilities and methods of handling cookies is available in the settings of your web browser.
If you do not want to receive cookies, you can change your browser settings. We reserve that disabling cookies necessary for authentication processes, security, maintaining user preferences may make it difficult, and in extreme cases may prevent the use of websites.

Conclusions

We reserve the right to change or update our Privacy Policy by publishing a new Privacy Policy and its rules on the pages of our Services. In particular, it may be necessary due to changes in the applicable law on the protection of personal data, guidelines on the protection of personal data issued by the supervisory authority for the protection of personal data, but also in connection with any changes in the scope of running the Websites by the given Controller or processes of cooperation / service of contractors.

We guarantee that any changes to our Privacy Policy, which may occur in the future, will remain in full compliance with the applicable legal provisions on the protection of personal data, as well as take into account the need to ensure the security of your personal data processed by us.

Do you have additional questions? Write to us or call us on +48 22 848 73 13.