Privacy Policy

Privacy Policy of MILBOR

Introduction

MILBOR spółka z ograniczoną odpowiedzialnością is committed to protecting the privacy of all individuals whose data we process in connection with our business activities. 

By this document (“Privacy Policy”), we would like to provide you with the most important information related to the processing of personal data of:

  • people who visit our websites;
  • people who visit our premises;
  • our business partners and their representatives;
  • job applicants.

We strive to ensure that the information provided to you complies with the transparency requirements set out in the provisions 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 (General Data Protection Regulation) (“GDPR”). 

Personal data controller 

The controller of your personal data is MILBOR spółka z ograniczoną odpowiedzialnością , ul. Prosta 2/14/24, 00-850 Warsaw (hereinafter referred to as: “we”, “Data Controller” or “MILBOR”).

Contact 

You can contact us:

  • in electronic form via e-mail: sales(at)milbor.pl
  • in the form of traditional correspondence sent to our address: MILBOR spółka z ograniczoną odpowiedzialnością, ul. Twarda 44, 00-831 Warsaw (hereinafter referred to as “we”, the “ Data Controller” or the “MILBOR”).

What kinds of personal data do we process?

Website and social media

In the course of your use of our website, we collect data to the extent necessary to provide particular offered services, as well as information about your activity on the website. 

In particular, we collect following personal data:

  • If you browse our site, we collect information stored in cookies or system logs, as well as information about your IP address, time spent on the site, and interactions with the content posted on the site. 
  • As a part of the operation of our social media, we collect information regarding your activity on a particular website in connection with our website/company profile (e.g. clicks on “Like”, posts published, comments, messages sent via internal messengers).

Business collaboration 

Within the scope of business collaboration, we collect and process personal data of entrepreneurs being our business partners, as well as representatives or employees of our business partners operating  in the form of companies or entities interested in such collaboration. The scope of collected data depends on the type of established collaboration. Typically, we collect basic information such as contact details, information on the business activity conducted, information on the place of employment/represented entity, information relating to ongoing correspondence as well as the conclusion and performance of a contract. 

Visits to our premises, telephone or e-mail contact

In the course of visits to our premises and telephone or e-mail contact, we collect information relating to your name and surname and the details of your visit or contact. 

Purchase of MILBOR products or services

If you make use of range of our products or services, we process your data to the extent necessary to fulfil the concluded contract. In connection with the conclusion of the contract, we also process your data for the purposes justified by our legitimate interests, which include monitoring the quality of our customer service in the context of surveys regarding satisfaction with contract implementation. 

Recruitment

In connection with recruitment process, we process information necessary to conclude an employment contract or a civil law contract. During the recruitment process, we may require you to provide us with data required under current legislation (article 221 of the Labour Code) During the recruitment process you may decide to provide us with other information voluntarily. 

Cookies and similar technology

Our website uses cookie technology. We may also use other similar technologies such as tracking pixels or beacons (web beacons). 

What are cookies?

Cookies are small text files that are installed on your device when you visit our website. Cookies collect information intended to improve your experience from website, for example by remembering your visits to the site and actions you have taken, such as choosing the language version of the site.  

What cookies do we collect?

Service cookies. We use so-called service cookies primarily to provide you with electronic services and to improve quality of these services. In this regard, MILBOR and other entities providing analytical and statistical services to it use cookies to store information or access information already stored in the Data Terminal Equipment of users of the service  (computer, phone, tablet, etc.). Cookies used for this purpose include:

  • cookies with user input (session identifier) for the duration of the session (known as the “userinput cookie”);
  • authentication cookies used for services that require authentication for the duration of the session; 
  • security cookies, such as those used to detect authentication abuses (known as the “usercentricsecurity cookie”);
  • multimedia player session cookie (e.g. flash player cookie), for the duration of the session (known as the “multimedia playersession cookie”)
  • permanent cookies used to personalise the user interface for the duration of the session or slightly longer (known as the “userinterfacecustomisation cookie”)
  • cookies used to monitor website traffic, i.e. data analytics, including the Google Analytics cookie (these are cookies used by Google to analyse your use of the website, to generate statistics and reports on website activity). Google does not use the collected data to identify the User nor does it combine this information to enable identification. Detailed information on the scope and rules of data collection in connection with this service can be found under the link: https://www.google.com/intl/pl/policies/privacy/partners.

Marketing cookies. MILBOR and its trusted partners use cookies for marketing purposes, with regard to, for example, directing personalised adverts to the users of the service. In order to do so, the Data Controller and its trusted partners store information or access information already stored in the Data Terminal Equipment of users of the service (computer, phone, tablet, etc.). Usage of cookies and personal data gathered by them for marketing purposes, in particular within the scope of promotion of services and goods of third parties, requires your consent. In general, you give your consent via adequate settings of your browser or device. 

Given consent can be withdrawn at any time. You can delete cookies from memory of your browser or device. 

By implementing our obligations connected to the usage of technologies used to gather data from our website, we also inform you, that:

  • in the event that you give us your consent for usage of  the marketing cookies, third parties, including Facebook Ireland Limited, will be able to use your cookies, web beacons and other similar technologies used to gather or to receive information from the website or other sites in the internet and to use them to provide measurement and targeting services for advertising;
  • every user of our website is able to disable gathering and usage of information gathered through marketing cookies by privacy settings shared with the users on our websites;
  • users can also use mechanisms used to select preferences in the scope of receiving profiled marketing content in the internet under the links: http://www.aboutads.info/choices and http://www.youronlinechoices.eu.

Currently, MILBOR uses marketing cookies as follows: 

  • Facebook Pixel – Facebook Pixel tool is a fragment of code inserted on the website, which enables measurement, optimisation and creation of audience groups for advertising campaigns on Facebook. The operation of this tool enables us to run a more effective advertising campaign and to provide you with content that might interest you. Facebook Pixel tool is provided and maintained by Facebook Ireland Limited. Facebook Pixel gathers basic information saved in cookies as well as information about the website and your activity. Facebook Ireland Limited may transfer personal data of its users to United States of America, on the basis of legal instruments provided by governing law. In some cases, your consent, which we collect through our websites, can be considered a basis for a transfer of your data. In this regard, we want to draw your attention to the fact, that data protection law in the United States of America is different from European legislation and might not provide you with same privileges as those provided for by provisions of law binding in Poland, and in some cases can also be connected with a possibility of access to your data by bodies and authorities of a third country. In order to ensure the fullest protection of your rights and freedoms, mechanisms used by Facebook Pixel tool are disabling identification of your identification data and are subject to automatic processes of their disposal within short periods of time. 

We also want to notify you, that by using Facebook Pixel tool, MILBOR abides by the current Facebook Business Tools Terms and Conditions, including agreements concerning rules of co-management of personal data. In order to fulfil obligations arising from principles of data protection law, we want to notify you, that within the scope of processing information gathered by the Facebook Pixel tool:

  1. MILBOR and Facebook Ireland Limited, with its registered office at 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland are acting as co-managers (entities jointly deciding on the objectives and means of processing the personal data).
  2. MILBOR and Facebook Irealnd Limited have made joint agreement for the implementation of obligations resulting from provisions of GDPR.
  3. MILBOR and Facebook Ireland Limited are responsible for an adequate foundation for processing personal data connected with gathering of information through Facebook Pixel. In this regard, MILBOR provides a possibility to users of its websites to grant a voluntary consent for gathering and usage of their data for marketing purposes, in particular to run advertising campaigns on Facebook page. Facebook Ireland Limited provides adequate legal basis referring to the possibility of usage of personal data of users of the page for purposes of marketing activities of MILBOR.
  4. Under this Privacy Policy, MILBOR provides you with access to all information involving principles of processing of data as a part of our business activities. You can find information involving principles of processing of personal data by Facebook Ireland Limited describing legal basis for such processing and methods of exercising your rights by Facebook Ireland Limited, including information concerning relevant contact forms of Facebook, under the link https://www.facebook.com/about/privacy.
  5. MILBOR is responsible to users of the website for correct operation of mechanisms enabling ability to give or revoke consent for usage of information gathered through Facebook Pixel tool. After receipt of data gathered by Facebook Pixel, Facebook Ireland Limited is solely liable for rights set out in GDPR in Articles 14 – 20 to the users of its social networking site. 
  6. Both MILBOR and Facebook Ireland Limited provide a possibility to exercise a right to object. In the event of receipt of a motion concerning objection regarding processing of personal data, MILBOR and Facebook Ireland Limited will take adequate measures relating to further processing of data of their users. 
  7. MILBOR is responsible for proper implementation and configuration of Facebook Pixel tool. Facebook Ireland Limited remains responsible for ensuring security to the service offered to us and to personal data processed within the framework of Facebook Pixel. 
  8. MILBOR and Facebook Ireland Limited remain responsible for a correct response for all identified data breaches. Responsibility of MILBOR in connection with usage of Facebook Pixel service applies to all cases concerning providing users with a tool that is correctly implemented and configured. Facebook Ireland Limited is responsible for all cases of data breaches connected with processing operations pursed under marketing serviced shared with us. 
  • LinkedIn Insight Tag – this tool is a short code in Java Script technology which supports conversation tracking, groups of audience on the website and demographic data of the website for advertising campaigns on LinkedIn website. Operation of this tool enables us to run more efficient advertising campaigns and providing you with content that might really interest you. LinkedIn Insight Tag tool is distributed and maintained by LinkedIn Ireland Unlimited Company. More information concerning rules of processing of personal data can be found under the link: https://www.linkedin.com/help/lms/answer/65513/add-the-linkedin-insight-tag-to-your-website?lang=pl
  • Google Ads – tool constituting one of the elements of advertising system of Google company enabling display of sponsored links in search results of Google browser and on websites of entities collaborating with Google. Google Ads tools is delivered and maintained by Google Ireland Limited. More information concerning rules of processing of personal data can be found under the link: https://policies.google.com/privacy?hl=pl.

Sources of origin of the personal data  

In the event that we are not gathering personal data directly from you, we possess it from:

  • publicly accessible sources, such as: the Central Register and Information on Economic Activity websites, websites of other publicly accessible registers;
  • your employers or entities with which you collaborate.

Purposes and bases of the processing of personal data

We process your personal data for different purposes and on different legal bases which are as follows:

Processing of data within website 

  • Providing services on-line. We process your data in order to provide services through electronic means within sharing certain functionalities and contents featured on the website. The legal basis for such processing in this case is necessity of performance of a contract and providing services through electronic means (art. 6 par. 1 letter b of the GDPR)
  • Marketing. Your personal data is used for marketing purposes of MILBOR and other entities (trusted business partners). Within the scope of our website, we use behavioural advertisement technology which enables us to adjust contents to your preferences and expectations. By using such technology, we profile our users – so  we analyse and  evaluate the contents you might be interested and we display relevant advertisement to you. In the event that you give us a separate consent for marketing communication, we will also direct to you certain marketing contents concerning products and services of MILBOR and its trusted business partners (e.g. newsletter, information about new products, interesting bargains), including contents adjusted to your preferences. The legal basis for actions taken for marketing purposes  is your consent (art. 6 par. 1 letter a of the GDPR)
  • Analysis and statistic as well as service quality survey. Your personal data is used in analytical and statistical purposes that consist on conducting analysis of activity of people visiting the website and their preferences in terms of offered functionalities and contents. In order to survey the quality of services offered by MILBOR, we use your contact data  in an attempt to gather information about the level of your satisfaction from the quality of our services (e.g. through the way of displaying and sending you satisfaction surveys). By processing personal data in such purposes, we gain the possibility to constantly improve the quality of services offered and exercise our legitimate interest (art. 6 par. 1 letter f of the GDPR).
  • Protection from claims. In justified cases, we process your personal data in order to establish, enforce or protect from claims (e.g. claims resulting from inadequate execution of services available on the website). The legal basis for such processing of personal data in abovementioned purposes is our legitimate interest (art. 6 par. 1 letter f of the GDPR). 
  • Security and efficient operation of the website. User’s activity on the website is registered in system logs (computer program dedicated to store chronological record inclusive of information about events and activities concerning information system designed for providing services by MILBOR). Information gathered through the logs are processed in technical and administrative purposes connected with the need to ensure security of the website and information systems processing your personal data and in analytical and statistical purposes ensuring efficient operation of the website. The legal basis for processing of personal data is our legitimate interest connected with providing you with secured and efficient website (art. 6 par. 1 letter f of the GDPR). 

Processing of data within social media

  • Operation of social media. We also process personal data of users visiting our profiles on social media (e.g. Facebook, YouTube, Instagram, Twitter). Your personal data (e.g. name and surname or nickname in social media) is gathered and used only in connection with operation of a website of MILBOR or its profile and is used in order to inform the users about our activity and to promote variety of events, services or products. The legal basis of processing of your personal data is our legitimate interest consisting on promotion of our brand and conducting proper communication in social media (art. 6 par. 1 letter f of the GDPR)

Processing of data within business collaboration 

  • Conclusion or performance of a contract. Your personal data is processed by us in order to conclude respective cooperation agreement with MILBOR or to its proper performance. If you are a sole trader, your personal data is processed on the basis of its necessity for the conclusion or performance of the contract (art. 6 par. 1 letter b of the GDPR). In the event that you act as a representative, proxy or employee of an entity that is a party to a contract, the legal basis for processing of your personal data is our legitimate interest consisting on conclusion or correct performance of the contract (art. 6 par. 1 letter f of the GDPR).
  • Analytical and statistical purposes. Your personal data connected with established or ongoing economic collaboration is used in analytical and statistical purposes connected with, among others, profitability of collaboration, possibilities of its expansion or optimisation of business process. The legal basis for processing of personal data in abovementioned purpose is our legitimate interest consisting on conducting business analyses (art. 6 par. 1 letter f of the GDPR). 
  • Building a contact base. Your personal data is processed by us in order to build a contact base. In this regard we process data gathered during industry events or in a way of exchanging business cards. The legal basis for processing in this case is our legitimate interest consisting on building business contact base (art. 6 par. 1 letter f of the GDPR).
  • Conducting marketing activities. We use your personal data in order to conduct various types of marketing activities. For example: we gather and use contact data of people responsible for processes of sale and establishment of a business collaborations in order to reach potential business partners, we contact our business partners in order to present new possibilities of extension of the scope of collaboration or we send adequate advertising materials. The legal basis for processing of personal data in such purpose is our legitimate interest connected with marketing (art. 6 par. 1 letter f of the GDPR).
  • Organisation of trainings or events. Within the collaboration with MILBOR, you can submit yourselves or your employees to attend  in trainings or other types of events organised by us. The legal basis for processing of personal data of our business partners is necessity to perform a contract, subject to general terms and conditions of collaboration with MILBOR or contract concluded in order to collaborate with MILBOR (art. 6 par. 1 letter b of the GDPR). In the event that you are an employee or an affiliate of our business partner who has submitted you to attend in the training, we process your data on the legal basis of our legitimate interest consisting on necessity of such processing in order to perform a binding contract concluded with your employers or necessity of the processing in order to provide your employers with an access to services provided by MILBOR within business collaboration (art. 6 par. 1 letter f of the GDPR).  In the event that enrolment for trainings or events are held individually (i.e. you submit your entry directly on our websites or via email), we process your personal data on the basis of your consent (art. 6 par. 1 letter a of the GDPR). We provide you with the possibility to withdraw such consent at any time, in compliance with provisions of applicable law. 
  • Compliance with statutory obligations. Your personal data is processed in connection with the fulfilment of responsibilities resulting from provisions of applicable law, in particular tax law obligations and accounting provisions. The legal basis for processing of data in such event is the necessity to fulfil obligations imposed on the Data Controller (art. 6 par. 1 letter c of the GDPR).  
  • Establishment, enforcement or protection from the claims. In justified cases, your personal data is processed by us in order to establish, enforce or protect from the claim (e.g. claims resulting from lack or inadequate execution of a contract consisting on collaboration with MILBOR). The legal basis for processing personal data in abovementioned purpose is our legitimate interest (art. 6 par. 1 letter f of the GDPR).

Processing of data within conducted correspondence and telephone contact 

Correspondence and telephone calls. Your personal data sent within emails or traditional correspondence, as well as communicated during telephone conversations, is processed in order to conduct appropriate communication, placing orders, concluding contracts, answering questions or submitting information that you have asked for (e.g. information requested in the contact form). The legal basis for processing of personal data is our legitimate interest consisting on providing you with efficient way to contact MILBOR in all matters of interest to you (art. 6 par. 1 letter f of the GDPR) or the necessity to process personal data in order to conclude or perform a contract with MILBOR (art. 6 par. 1 letter b of the GDPR). 

Processing within ongoing recruitment process 

  • Undertaking measures with a view for conclusion of a contract. Your personal data is processed by us within measures undertaken before concluding a contract. In order to do so, we process information provided to us in correspondence consisting on recruitment process and agreement on terms of the collaboration on the basis of an employment contract or a civil law contract. The legal basis for processing of personal data is condition of necessity to conclude a contract (art. 6 par. 1 letter b of the GDPR).
  • Performing statutory duties. In the event that the basis for employment is an employment contract, we process your personal data to the extent required by the Labour Code, and by that fulfilling the obligations imposed on the employer. Your personal data might be also processed in order to fulfil other obligations resulting from different legislation. The legal basis for processing of data in those cases is fulfilling statutory obligations of the Data Controller (art. 6 par. 1 letter c of the GDPR)
  • Processing of other data during recruitment process. In order to conduct a recruitment, within the scope of data not required by provisions of law or beyond the data required by us for the conclusion of a contract or for purposes of future recruitments, we process your personal data on the basis of your consent which may be withdrawn at any time (art. 6 par. 1 letter a of the GDPR).

Necessity to provide data

Information provided in correspondence, required to conclude or perform a contract, connected with recruitment, attendance in a training/event or with entering monitored area. 

If you conduct correspondence, conclude a contract, attend in a training/event or in recruitment process, your provision of personal data is voluntary, but necessary to correspond, conclude an adequate contract or attend in a training/event or recruitment.

Consequences of not providing personal data

In the event that the provision of data is necessary to provide services, conclude or perform a contract, conduct appropriate correspondence, attend in a training/event or recruitment or enter monitored area, not providing required personal data might result in unavailability to provide such service, conclude or perform a contract, conduct a correspondence, attend in a training/event or recruitment or enter monitored area. 

Data retention periods 

Period for which we keep your personal data is dependent on the type of provided service and a purpose for its processing. 

As a rule, we process your personal data within the duration of a provision of services, term of a contract or fulfilment of an order, until you withdraw your consent or make an effective objection against processing of personal data when processing take place in connection with exercising our legitimate interests.  

Within MILBOR, we prepared and implemented adequate policies regarding processing of personal data which includes the necessity to store your personal data within certain period of time. Our policy for storing data includes periods of time for which we process data resulting from applicable tax and accounting regulations, limitation periods for claims or our legitimate interests resulting from the necessity to archive conducted correspondence. 

For further information connected with periods of time for which we process certain categories of personal data, please contact us as described in the CONTACT section. 

Recipients of the data

 Your personal data might be disclosed and transferred to third parties, including suppliers responsible for maintenance of information systems, marketing agencies supporting us in activities connected with promotion of our brand and entities providing legal, accounting, training, maintenance, postal or analytical and consulting services. 

Your personal data might also be transferred to entities connected with the Data Collector, including other companies in the MILBOR Group. 

Your Rights

In relation to processing of personal data by us, you are entitled to access such data and to request rectification, disposal, limitation of processing and transfer of it. 

In the event that we process your data in relation to fulfilment of our legitimate interest or in marketing purposes, you are also entitled to the right to object to such processing.

In the event that you have granted a separate consent for processing of personal data in certain purpose, you might withdraw such consent at any time. Withdrawal of consent will not affect the lawfulness of processing of data carried out on the basis of consent before its withdrawal. 

 In cases connected with possible suspicion of irregularities in processing of personal data, you are entitled to lodge a complaint with the supervisory authority dealing with personal data protection. Currently, such authority is the President of the Office of Personal Data Protection (you can find more information on a website of the Office under a link: https://uodo.gov.pl/).

Transfers of data outside the EEA

Level of security of personal data outside of the European Economic Area (EEA) differs from this provided by European Union law. Because of this, MILBOR transfers personal data outside the EEA only when necessary and ensuring adequate level of security, in particular by:

  • collaborating with entities processing personal data in countries to which relevant decision of the European Commission has been issued;
  • using standard contractual clauses issued by the European Commission; 
  • applying binding corporate rules, approved by the relevant supervisory authority;
  • invoking legally justified grounds for the transfer referred to in article 49 of the GDPR.

You are entitled to receive information and copy of adequate means of security used in relation to transfer of personal data outside the EEA at any time. In order to do so, please contact us as described in the CONTACT section.

Security of personal data 

MILBOR attaches great importance to safety of your personal data. In order to do so, we conduct a regular risk analysis to ensure that your data is processed in a way that ensures that only  authorized individuals have access to the data and only to the extent that is necessary due to tasks they perform. We also make sure that all personal data operations are registered and performed by authorised employees and affiliates of MILBOR and that information systems used to process the data ensure their availability, integrity and confidentiality. 

We also take all necessary actions to ensure that all of our contractors and entities collaborating with us guarantee the application of appropriate security measures in any case of processing personal data performing MILBOR’s request. 

Amendments to the Privacy Policy 

The Privacy Policy is regularly verified and updated when such need arises. We will inform you of any changes to its content through the appropriate communication channels.