Privacy Policy
We process
your personal data and are committed to protecting your rights and privacy.
Therefore, in
fulfilment of the information obligation arising from Regulation (EU) 2016/679
of the European Parliament and of the Council of 27 April 2016 (GDPR), ISTRAIL
Sp. z o.o., with its registered office in Golub-Dobrzyń, PTTK 56, 87-100
Golub-Dobrzyń, as the Data Controller, provides the following information
regarding the implemented data processing activities:
2. How do we
obtain data?
Your personal
data may be obtained:
1. Directly
from you – through:
a) contact forms on the website,
b) advertising forms used in campaigns on platforms such as Facebook/Meta,
Google, LinkedIn or other marketing tools,
c) e-mail messages, telephone contact, or visits to our office,
d) quotation requests, orders, contracts, or exchange of correspondence,
2. From other
companies within the ISTRAIL Group:
a) ISTRAIL AS (Norway)
b) ISTRAIL AB (Sweden)
– to the
extent necessary for the performance of services, customer support, or
forwarding an inquiry to the appropriate branch.
3. Purposes
and legal bases of data processing
Your personal
data will be processed for at least one of the following purposes:
3.1. Handling
inquiries and commercial contact
Responding to
an inquiry, presenting an offer, telephone or e-mail communication.
Legal basis: Article 6(1)(f) GDPR – legitimate interest of the controller (for
contact purposes, statistical analysis, pursuing or defending claims).
3.2. Execution
of concluded contracts or actions undertaken prior to concluding a contract
Where you act
as a contractor or customer – including placing and fulfilling orders and their
settlement, responding to questions about the offer, determining terms of
cooperation, sales/purchase support, or handling complaints.
Legal basis: Article 6(1)(b) GDPR.
3.3. Direct
marketing and advertising activities
a) telephone
and e-mail contact regarding the offer,
b) sending commercial materials,
c) conducting advertising campaigns,
d) handling advertising forms (lead ads).
Legal basis:
Article 6(1)(a) GDPR – consent (if granted), Article 6(1)(f) GDPR – legitimate
interest of the controller (B2B relationships).
3.4.
Analytics, statistics, CRM activities
a) evaluation of campaign performance,
b) segmentation of inquiries,
c) analysis of lead sources,
d) internal reporting.
Legal basis: Article 6(1)(f) GDPR – legitimate interest of the controller.
3.5.
Compliance with legal obligations
For example,
for tax settlements or obligations arising from decisions or rulings issued by
competent authorities or courts.
Legal basis: Article 6(1)(c) GDPR.
3.6. Purposes
related to your consent
(where
applicable, e.g., storing data in cookies).
Legal basis: Article 6(1)(a) GDPR, and for special categories of data – Article
9(2)(a) GDPR.
4. Processing
data in IT systems and profiling
We process
your data in paper form – e.g., information contained in forms you have
submitted, contracts we have concluded, and documents that support contract
settlements.
We also use IT
systems for processing (CRM, e-mail, advertising tools).
We do not make
automated decisions that produce legal effects.
We may perform
basic data analysis (segmentation, statistics), which:
a) does not result in decisions made about you,
b) serves solely to improve service quality and communication.
5. Transfer of
data within the ISTRAIL Group (Poland – Norway – Sweden)
Due to the
operations of the ISTRAIL Group, personal data may be transferred between:
a) ISTRAIL Sp. Z o.o. (Poland),
b) ISTRAIL AS (Norway – EEA country),
c) ISTRAIL AB (Sweden – EU).
Data are
transferred solely to:
a) handle inquiries,
b) prepare offers,
c) provide customer service,
d) carry out production,
e) forward leads to the proper branch serving a particular market.
Transfer of
data to Norway is not considered a transfer to a third country, as Norway is
part of the EEA and applies GDPR.
6. Data
recipients
Your data may
be transferred only to:
a) entities within the ISTRAIL Group,
b) companies operating IT systems, CRM, and e-mail services,
c) advertising campaign operators (Meta, Google, LinkedIn) – only if their
forms were used,
d) accounting, advisory, and legal service providers,
e) courier and logistics companies,
f) entities authorized under applicable law.
Each recipient
processes data exclusively under a data processing agreement or relevant
authorization.
7. Data
retention period
We process
data for the following periods:
- Quotation requests / contact via advertising
forms – up to 12 months from the last contact or until an objection is
submitted.
- Data processed on the basis of consent – until
consent is withdrawn.
- Client and contractor data – for the entire
duration of cooperation and for the period required by tax regulations and
limitation periods for claims.
- Data processed for direct marketing – until an
objection is submitted.
8. Rights of
data subjects
You have the
following rights:
a) the
right to access your data and obtain a copy,
b) the right to rectify (correct) your data if they are outdated or
incomplete,
c) the right to erase your data where processing is not required for legal
obligations or the establishment or defence of claims (“right to be
forgotten”),
d) the right to restrict processing in specific situations,
e) the right to data portability (where technically feasible) – to another
controller, if the processing is based on your consent,
f) the right to object to processing in specific situations, e.g., when
processing is based on the Company’s legitimate interest for direct marketing,
g) the right to withdraw consent at any time, if consent was required to begin
processing,
h) the right to lodge a complaint regarding the processing of your data with
the President of the Personal Data Protection Office (UODO), ul. Stawki 2,
00-193 Warsaw.
Withdrawal of
consent does not affect the lawfulness of processing performed before the
withdrawal.
9. Voluntary
provision of data
Providing
personal data is voluntary, but necessary to:
a) respond to an inquiry,
b) prepare an offer,
c) maintain commercial contact,
d) perform a contract.
Failure to
provide data may prevent us from carrying out these processes.
10. Contact
regarding personal data
To exercise
your rights or obtain additional information, you may contact us by e-mail at: rodo@istrail.pl