Privacy and cookies policy

The controller of your personal data is MILBOR spółka z ograniczoną odpowiedzialnością, a limited liabiity company, with its registered office in Warsaw, address: ul. Twarda 44, 00-831 Warsaw, entered in the Register of Entrepreneurs of the National Court Register under KRS No. 0000480839, with Tax Identification No. NIP 5671904547 and [National Business Registry No.] 146825291 (hereinafter: “we”, “Data Controller” or “MILBOR”).

We have not appointed a Data Protection Officer, but in all matters relating to the processing of personal data, we can be contacted:

• electronically via email: rodo@milbor.pl;
• in the form of traditional correspondence sent to our address: MILBOR spółka z ograniczoną odpowiedzialnością, ul. Twarda 44, 00-831 Warsaw.

In connection with your visit to our website or our profiles on social media, depending on the purpose of your visit, we may process the following personal data:

1. personal data – first name, surname,
2. contact data – telephone number, e-mail address,
3. data about your professional experience,
4. information about your activity on the website and social media as part of our profile,
5. information about your devices and connection information (including identification and location data),
6. data which you provide to us in the contact form in connection with your application for employment/co-operation (date of birth, education, professional qualifications, previous employment history, residential address, etc.).

We would like to point out that we do not knowingly collect data from persons under the age of 13 and request that persons under the age of 13 refrain from using our website and social media profiles. If we become aware of the processing of such persons’ data, we will take the necessary measures to delete such data.

We would also like to inform you that we do not need to process any specific personal data (sensitive data, e.g. on health, religion, racial origin) for our website and social network profiles, so please do not submit such data. If you include information in this regard, we will assume that you have implicitly consented to its processing. If we become aware of the processing of such data, we will take the necessary steps to delete it.

We collect data:

1. directly from you through contact carried out via our website, social media or means of remote communication;
2. from sources where you have provided the data in connection with your online activities (e.g. from social media);
3. thanks to technologies allowing automated tracking on the web (cookies, web tags).

We process your personal data for the following purposes, on the following grounds and for the following duration:

Legal basis: our legitimate interest, which is: to provide clarification in accordance with your request and to promote our own activities and our own products (Article 6(1)(f) GDPR) In doing so, we point out that we only process data on this basis if you can expect such processing and if we are sure that the impact of the processing on your interests does not outweigh our interests in processing your data.

Duration of processing: the time it takes to respond to you in relation to the matters identified in your request and, in relation to marketing activities, for the duration of such activities, but for no longer than until you raise an effective objection to the processing of your personal data.

Legal basis:

1. to take the necessary steps to conclude a contract at your request (Article 6(1)(b) GDPR) – if a contract is concluded in relation to an order placed, the legal basis for processing will change to that indicated within the information clause indicated in the concluded contract;
2. our legitimate interest of defending against or asserting claims in connection with an order (Article 6(1)(f) GDPR). In doing so, we point out that we only process data on this basis if you can expect such processing and if we are certain that the impact of the processing on your interests does not outweigh our interests in processing your data.

Duration for processing personal data:

1. the time needed to provide explanations about our products and the time needed to finalise your order and conclude the contract or until you cancel your order;
2. the time corresponding to the general limitation periods for claims that may arise in connection with the order in question, not longer than until you have raised an effective objection to the processing.

Legal basis:

1. the consent you have given by subscribing to the newsletter (Article 6(1)(a) of the GDPR)
2. the necessity of the processing for the conclusion and performance of the newsletter contract (Article 6(1)(b) GDPR)
3. our legitimate interest to promote our own goods and services and to assert and defend against claims arising from the provision of the newsletter service (Article 6(1)(f) GDPR). In doing so, we point out that we only process data on the basis of a legitimate interest if you can expect such processing.

Duration of the processing of personal data: the duration of the marketing activities in this regard, no longer than until you have successfully raised an objection or revoked your consent by opting out of the newsletter service. Further processing of personal data may take place until the statute of limitations for claims arising from the provision of the newsletter service.

Legal basis:

1. our legal obligations under Article 22¹ 1 of the Labour Code (Article 6(1)(c) GDPR) – with regard to the data of potential employees expressly referred to in this provision;
2. to take the necessary steps to conclude a contract at your request (Article 6(1)(b) GDPR) – with regard to the data of persons other than potential employees (for whom the basis of employment would be a civil law contract, or a contract concluded between entrepreneurs);
3. consent (Article 6(1)(a) GDPR) – with regard to data provided voluntarily by you, not required by the provisions indicated in point 1 above or not necessary for the conclusion of a civil law contract constituting the basis for possible cooperation.

Duration for processing personal data:

1. the time needed to complete the recruitment procedure or to consider the application and inform you of the results;
2. until the withdrawal of the consent – in the scope of data processed exclusively on the basis of the consent.

Legal basis:

1. Our legitimate interest in promoting our own goods and services via the profile/Fanpage that we run (Article 6(1)(f) GDPR) – with regard to the service user data provided as part of the profile and the data provided as part of the interaction. In doing so, we point out that we only process data on this basis if you can expect such processing and if we are certain that the impact of the processing on your interests does not outweigh our interests in processing your data.
2. Consent (Article 6(1)(a) of the GDPR) – to the extent of data provided voluntarily by you, not required by the provisions indicated in point 1 above or not necessary for the conclusion of a civil law contract forming the basis of a possible cooperation.

Duration for processing personal data:

1. until an objection is successfully raised
2. until the withdrawal of the consent – in the scope of data processed exclusively on the basis of the consent

Legal basis: our legitimate interest in promoting our own goods and services (Article 6(1)(f) GDPR) and your consent to the use of cookies (Article 6(1)(a) GDPR). In doing so, we point out that we only process data on this basis if you can expect such processing and if we are certain that the impact of the processing on your interests does not outweigh our interests in processing your data.

Duration of the processing of your personal data: the duration of our marketing activities in this regard, not longer than until you have successfully lodged an objection or withdrew your consent.

Our website uses cookie technology. We may also use other similar technologies such as e.g. tracking pixels, beacons, for our analytical and marketing purposes. We point out that these tools process anonymised personal data (they do not enable us to identify you and are not intended to serve this purpose), but due to doubts about their legal status they may be considered personal data.

What are cookies?

Cookies are small text files that are installed on your device when you browse our website. Cookies collect information that makes it easier for you to use the website – for example, by remembering your visits to the website and your actions such as choosing the language version of the website.

We use cookies based on your consent, except where cookies are necessary for the proper functioning of the website.

Some of these cookies come directly from our website and are used upon re-entry (first-party cookies, our own), others come from other parties whose services we use (third-party cookies, external).
The third-party services are described below.

As far as optional cookies are concerned, their use is subject to your consent to the respective group of cookies – the groups have been created by reference to the purpose of the cookies.
A distinction can be made between cookies:

1. Functional – to help perform certain functions, such as sharing website content on social media platforms, collecting feedback and other third-party functions.
2. Performance – used to understand and analyse the key performance indicators of the website, helping to ensure that the website performs better for the user.
3. Analytics – used to understand how visitors interact with the website.
   These cookies help provide information on visitor metrics, rejection rates, source of traffic, etc.
4. Advertising – used to deliver relevant advertising and marketing campaigns to visitors.
   These cookies track visitors across sites and collect information to deliver tailored advertising.
5. Essential – are absolutely necessary for the proper functioning of the website. These cookies ensure the anonymous operation of the site’s basic functions and security features and do not require your consent for their use.

Your consent to the use of cookies is given within the information bar that is displayed on our website. You can give your consent to the use of all cookies, some of them or none at all. Your choice in this regard can be changed at any time and you have the option of deleting cookies from the memory of your browser or device.

Data processed using the above cookies is processed for a period of 1 year.

In fulfilling our obligations in relation to the use of technologies to collect data from our website, we also inform you: that:

• if you have given your consent to our use of marketing cookies, third parties, including in particular Meta Platforms Ireland Limited (formerly Facebook Ireland Limited hereafter referred to as Facebook) and entities to which Facebook transfers data, as well as Google Limited Ireland and Google LLC, may use cookies, web beacons and similar technologies to collect or receive information from the website and other places on the internet and use them to provide measurement services and ad targeting regardless of our activity in this respect;
• each user of our website has the option to disable the collection and use of information collected through marketing cookies through the privacy settings provided to users on our websites and within the settings of the browsers the user is using;
• users also have the option to use mechanisms to select their preferences for receiving profiled marketing content online available at: http://www.aboutads.info/choices oraz http://www.youronlinechoices.eu.

MILBOR currently uses the following marketing cookies and technologies from third parties for the primary purpose of collecting information about the website and your activity within it:

1. Facebook Pixel – the Facebook Pixel tool provided by Meta Platforms Ireland Limited (formerly Facebook Ireland Limited), which may transfer the personal data of its users to the United States of America, based on the legal mechanisms provided by applicable law.
   The transfer of data in some cases may also be based on the consent that we collect within our websites.
   Please note that data protection law in the United States of America differs from European legislation and may not provide the same rights as those provided by Polish law, and in some cases may also involve the possibility of access to your data by authorities and services of a third country.

The tool uses a piece of code embedded in the website to measure, optimise and group audiences for advertising campaigns on Facebook.

The tool collects basic information stored in a cookie and information about the website and your activity.
The operation of this tool enables us to run more effective advertising campaigns and deliver content that is of genuine interest to you.

MILBOR complies with the current Facebook Business Tools Terms and Conditions, including the agreement on the rules for the co-management of personal data.

In order to comply with our obligation under data protection law, we would like to inform you that, with regard to the processing of information collected via the Facebook Pixel tool:

1. MILBOR and Meta Platforms Ireland Limited (formerly: Facebook Ireland Limited, hereafter referred to as Facebook), with registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland act as joint controllers (entities jointly deciding on the purposes and means of processing personal data).
2. MILBOR and Facebook are responsible for providing an adequate basis for the processing of personal data related to the collection of information through the Facebook Pixel. Accordingly, on the websites, MILBOR provides users with the opportunity to voluntarily consent to the collection and use of their data for marketing purposes, in particular for marketing campaigns on Facebook. Facebook provides an appropriate legal basis relating to the possibility of using the personal data of portal users for MILBOR’s marketing activities. At the same time, we would like to point out that we exclusively provide tools on our website which are fully managed and controlled by Facebook. We therefore have influence over the collection and transfer of data to Facebook. We are responsible to the users of the website for the correct functioning of the mechanisms for obtaining and withdrawing consents for the use of information collected via the Facebook Pixel tool. Upon receipt of the data collected via Facebook Pixel, Facebook is independently responsible for the rights set out in Articles 15 – 20 GDPR towards users of its social network.
3. Therefore, we point out that you will find information related to the principles of Facebook’s processing of personal data, the determination of the legal basis for such processing and the ways in which Facebook may exercise your rights, including information on Facebook’s relevant contact forms, in the Data Policy available at:https://www.facebook.com/about/privacy.
4. Both MILBOR and Facebook provide you with the opportunity to exercise your right to object. In the event of a request relating to an objection to the processing of personal data, MILBOR and Facebook will take appropriate action relating to the further processing of their users’ data.
5. MILBOR is responsible for the appropriate implementation and configuration of the Facebook Pixel tool. Facebook remains responsible for ensuring the security of the service offered to us and the personal data processed within the Facebook Pixel.
6. MILBOR and Facebook remain responsible for responding appropriately to all identified data protection violations. MILBOR’s responsibility in connection with the use of the Facebook Pixel service refers to all cases related to the provision of a properly implemented and configured tool to users. Facebook shall be liable for all data protection violations having to do with the processing operations carried out as part of the marketing service provided to us.

2. LinkedIn Insight Tag – the tool is a short code in Java Script technology that handles conversion tracking, site audience groups and site demographics for advertising campaigns on LinkedIn.
   The operation of this tool enables us to run more effective advertising campaigns and provide you with content that is of real interest to you. The LinkedIn Insight Tag tool is provided and operated by LinkedIn Ireland Unlimited Company.

You can find out more about the processing rules with LinkedIn’s processing of your personal data here:
https://www.linkedin.com/help/lms/answer/65513/add-the-linkedin-insight-tag-to-your-website?lang=pl

3. Google Ads – a tool that is one of the components of Google’s advertising system, allowing sponsored links to be displayed in Google’s search results and on the websites of Google’s affiliates.
   The Google Ads tool is provided and operated by Google Ireland Limited.

Google Analytics – Google Analytics is a Google tool provided by Google LLC which automatically collects information about the use of the website. The information collected in this way is mostly transmitted to Google servers. They may be located worldwide and are stored there. We point out that this data does not allow us to uniquely identify you and is not processed for this purpose.

YouTube (widgets) – a tool provided by Google LLC which causes videos to be embedded on the website in a privacy-protected mode, meaning that cookies are not saved on your device and Google does not collect any information about you until the video is played.

When a video is played, YouTube saves the cookies on your device and receives information about the playback from the specific website, even if you do not have a Google account or have not signed in to your account. Once logged in, Google will be able to directly associate your visit to our website with your account, so if you do not wish to provide such data, do not log into your Google account. The purpose and scope of data collection and the further processing and use of such data by Google, data are described in Google’s privacy policy. 

You can find more information about Google’s data processing principles here: Privacy Policy – Privacy and Terms and Conditions – Google

All data we process is provided by you on a voluntary basis. However, you must be aware that failure to provide data may mean that we are unable to achieve certain results directly related to the purposes of the data processing (e.g. contacting you, providing you with information, taking part in recruitment).

Your personal data may be disclosed and transferred to external entities that act on our behalf or for our benefit, including in particular suppliers responsible for the maintenance of our IT systems including the handling of the newsletter mailing, marketing agencies assisting us in our brand promotion activities and entities providing legal, accounting, training, maintenance, postal or analytical and advisory services. We have an entrustment agreement with these entities for the processing of personal data. We therefore require them to maintain the confidentiality and security of your information and verify that they provide adequate measures to protect your personal data.

Based on your consent to the use of marketing cookies, your data may be passed on to entities providing us with the relevant tools.

We would like to inform you that we use profiling for marketing purposes We do not, however, make any automated decisions (i.e. made without human intervention) with regard to you that would affect your legal situation or materially affect you.

In connection with the processing of your personal data, you have:

1. The right to access your data and to receive a copy of it;
2. The right to rectify (amend) your data;
3. The right to erasure – if there are no grounds for us to process your data, you can request that it be erased;
4. Right to request restriction of processing – you can request that we restrict the processing of your personal data in the following cases:
5. 1. you dispute the accuracy of the processing of your personal data – for a period of time to allow us to check the accuracy of the processing;
   2. the processing is unlawful and at the same time you do not consent to the erasure of the data;
   3. we no longer need the personal data for the established purposes of the processing, but you need the data to establish, assert or defend your claims.
6. The right to data portability – you have the right to receive from us in a structured, commonly used machine-readable format the personal data that concerns you, or to have us send the data to another party (provided that the legal basis for the processing is consent or contract, i.e. Article 6(1)(a) or (b) GDPR);
7. The right to object to the processing of your data on the basis of legitimate interests, for purposes other than direct marketing. In this situation, it is necessary to indicate the specific, particular situation that justifies the cessation of the processing of the objected data.
   We will stop processing your personal data for these purposes unless we can demonstrate that the grounds for our processing override your rights or that your data is necessary for us to establish, assert or defend our claims.
8. The right to object to processing on the basis of legitimate interests, for direct marketing purposes – if you object, we will stop processing your data for these purposes;
9. The right to withdraw your consent to the processing of personal data – you may withdraw your consent to the processing of those personal data that we process on the basis of your consent at any time. Withdrawal of consent will not affect the lawfulness of processing that was carried out on the basis of consent prior to its withdrawal. The withdrawal of consent is possible in each case by contacting us in accordance with the data indicated above or through specific tools dedicated to this purpose on the website or in the content of the messages addressed to you if this possibility is provided).

In addition, you have the right to lodge a complaint with a supervisory authority – if you believe that we are processing your data in an unlawful manner, you may lodge a complaint to this effect with the President of the Office for Personal Data Protection or any other competent supervisory authority;

Our processing of your personal data primarily takes place in countries in the European Economic Area (EEA), however, due to the analytics and marketing tools we use (including cookies), it is possible that data may be transferred outside the EEA To the extent that we are in a position to do so, we verify that those to whom we directly share data give guarantees of a high level of personal data protection.
These guarantees arise in particular from the obligation to apply the standard contractual clauses adopted by the Commission (EU) pursuant to the provisions of Article 46(2) GDPR.

MILBOR attaches great importance to the security of your personal data. To this end, we carry out risk analysis on an ongoing basis to ensure that your personal data is processed in a way that ensures that only authorised persons have access to the data and only to the extent that this is necessary for their tasks.
We also ensure that all operations on personal data are recorded and carried out only by authorised MILBOR employees and associates, and that the IT systems used to process the data ensure its availability, integrity and confidentiality.

We also take all necessary measures to ensure that all of our subcontractors and collaborators provide guarantees that appropriate security measures are in place whenever they process personal data on behalf of MILBOR.

The Privacy Policy is reviewed on an ongoing basis and updated as necessary. We will inform you of any changes to its content through the appropriate communication channels.