Your trust is very important to us. The document you are reading at this moment describes how we process your personal data. We are continually concerned to ensure the highest possible standard of privacy protection, so we are committed to complying with both this policy and all legal requirements relating to the protection of your personal data.
The policy is aimed at:
- clients and customers of “Incaso Group” sp. z o. o. as well as employees, associates and representatives of such entities engaged in the performance of the contract with “Incaso Group” sp. z o. o.
- visitors to our website.
1. Definitions
| Administrator, „we”, „us”, „ours”, „Incaso Group” | “Incaso Group” sp. z o.o. with registered office in Koszalin (75-452), ul. Jana Pawła II nr 20 lok. 70, Poland, whose registration files are held by the District Court in Koszalin, IX Economic Division of the National Court Register, KRS: 0000503873, NIP: 6692521160 |
| Personal data | in accordance with the GDPR, any information about an identified or identifiable natural person (‘data subject’); an identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of the natural person |
| Policy | this privacy and cookies policy |
| GDPR | 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) |
| Website | our website at: www.iaml.com.pl. |
2. Administrator
The administrator of your personal data is the “Incaso Group” sp. z o.o. with its registered office in Koszalin (75-452), ul. Jana Pawła II nr 20 lok. 70, Poland, KRS: 0000503873. Contact with us is possible:
- in writing to our address shown above
- via e-mail at: rodo@iaml.com.pl
- by telephone at (+48) 22 100 36 93.
3. Contact details of the Data Protection Officer
The administrator has appointed a Data Protection Officer. Contact with the Data Protection Officer is possible:
- in writing
- via e-mail at: rodo@iaml.com.pl
- by telephone at: (+48) 22 100 36 93.
4. Purposes and legal basis for processing personal data
Your personal data will be processed for the following purposes
If you are our customer, contractor or an employee, collaborator or representative of our customer or contractor appointed to perform a contract with us:
| Purpose of processing your personal data | Legal basis for processing your personal data |
if you are our customer or contractor:
| if you are our customer or contractor:
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if you are our customer or contractor:
| if you are our customer or contractor:
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if you are an employee, associate or representative of our client or contractor appointed to perform a contract with us:
| if you are an employee, associate or representative of our client or contractor appointed to perform a contract with us:
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If your personal data has been collected directly from you – your provision of personal data is voluntary, but failure to do so may prevent us from keeping in touch with you and from establishing or maintaining a business relationship.
Where marketing and promotional activities are carried out in relation to you
If we present our offer to you by telephone or email it means that you have given us prior consent to present it to you. We will never send you an offer by the above means unless we have the appropriate marketing consent.
| Purpose of processing your personal data | Legal basis for processing your personal data |
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If your personal data has been collected directly from you – your provision of personal data is voluntary, however, failure to do so may prevent you from receiving our offer.
If you are visiting our website:
| Cel przetwarzania Twoich danych osobowych | Podstawa prawna przetwarzania Twoich danych osobowych |
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Your provision of personal data is voluntary.
5. The scope of the personal data we process
If you are our customer, contractor or an employee, associate or representative of our customer or contractor appointed to perform a contract with us, the categories of personal data we process may include:
- identification data (including but not limited to first and last names)
- contact data (e.g. e-mail address, telephone number)
- data on the function performed (official position, designation of the function, place of performance/position, designation of the entity in which the person works)
- other data disclosed to the Data Controller for business contacts and relations.
Depending on which channel of marketing contact you have consented to and the extent of personal data you have provided to us for this purpose, when we carry out marketing and promotional activities towards you, the categories of personal data processed by us may include:
- identification data (including, but not limited to, first and last names)
- contact data (e.g. e-mail address, telephone number)
- data on the function performed (official position, designation of the function, place of performance/position, designation of the entity in which the person works)
- other data disclosed to the Data Controller for business contacts and relations.
If you visit our Website we may collect the following data about your activity:
- abbreviated IP address
- time zone settings
- the time and place of your visits to the Website
- type and version of the operating system you use
- type of Internet browser you use
- type and type of browser plug-ins
We collect the above data by automated means. You will find detailed information on this under cookies.
At the same time, we would like to point out that not all of the above personal data is always processed by us. There may also be situations in which you provide us with other personal data on a voluntary basis, e.g. when reporting a technical problem, communicating with us or making a possible complaint.
6. Recipients of personal data
Your personal data is processed by a limited number of people, including our employees and associates to the extent necessary for them to perform their work in connection with the provision of services to you. However, your personal data may be transferred to third parties, as discussed below.
Your personal data may be transferred to the following categories of recipients:
- service providers supplying the Data Controller with technical and organisational solutions to enable the management of the Data Controller’s organisation, including entities operating ICT systems or providing the Data Controller with ICT tools (in particular ICT service providers, courier and postal companies)
- to providers of legal and advisory services and to support the Controller in asserting due claims (in particular law firms)
- other entities and bodies to which the Controller is obliged or authorised to disclose personal data on the basis of generally applicable legal provisions.
Transfer of personal data to a third country (i.e. outside the European Economic Area) or an international organisation.
We do not transfer your personal data to third countries or international organisations.
7. Duration of storage of personal data
The length of time we keep your personal data depends on the type of service provided and the purpose of the processing. The duration of our retention of your personal data often follows directly from the law if we process your personal data on the basis of the law. If we process your personal data on the basis of our legitimate interest then your data is processed for the period of time that enables us to pursue that interest or until you raise an effective objection to the processing. On the other hand, if we process your data on the basis of your consent, then your data is held by us until you withdraw your consent. While the basis for the processing of your personal data is the necessity for the conclusion and performance of the contract, the data are processed until the contract expires. After this time, your personal data is retained by us for the time necessary to secure our claims or defend against claims. However, we may be obliged to keep your personal data longer for the time required by law, e.g. the Accounting Act.
8. Your data protection rights
If we process your personal data you have the following rights:
- the right to access your personal data and to receive a copy of it (Article 15 GDPR)
- the right to rectify (amend) your personal data (Article 16 GDPR)
- the right to request the erasure of your personal data (Article 17 GDPR)
- the right to restrict the processing of your personal data (Article 18 GDPR)
- the right to data portability, i.e. the right to receive your personal data in a structured, commonly used and machine-readable format (Article 20 GDPR)
- The right to withdraw your consent at any time without affecting the lawfulness of the processing carried out on the basis of your consent prior to its withdrawal (Article 7(3) of the DPA) – you can withdraw your consent to the processing of your personal data by contacting us:
- in writing – to our registered address (we have provided it above)
- via email – at: rodo@iaml.com.pl
- by telephone – at (+48) 22 100 36 93.
Right to lodge a complaint with a supervisory authority
If you consider that the Administrator processes your personal data unlawfully, you have the right to lodge a complaint to the President of the Office for Personal Data Protection (ul. Stawki 2, 00-193 Warsaw). Detailed information in this regard may be found on the Office’s website www.uodo.gov.pl.
Right to object
You have the right to object to the processing of personal data on grounds relating to your particular situation (Article 21(1), (4-5) GDPR). When lodging an objection, you should indicate the particular situation which, in your opinion, justifies the Administrator to stop processing the personal data covered by the objection. We will cease to process your personal data for the purposes set out above unless you demonstrate that there are valid legitimate grounds for the processing which override your rights and freedoms, or that your data are necessary for us to establish, assert or defend claims.
Remember, not all of the above rights are absolute, which means that you will not be entitled to all processing activities. The only right you will always have (regardless of the basis of processing) is the right to lodge a complaint with the relevant supervisory authority if you consider that our processing of your personal data breaches the law.
We encourage you to familiarise yourself with these powers
9. Information on automated decision-making, including profiling
The Data Controller does not make decisions about you based solely on automated processing, including profiling.
If you visit our Website, we may collect certain information about you as part of tracking mechanisms that allow us to target personalised advertising to you. The results obtained from such analysis are not used by us to make decisions about you. We also do not have data that allows us to identify you based on your actions on the Website.
10. Cookie files
Cookies are IT data, in particular in the form of small text files, which are stored on the user’s terminal equipment and can be read by our IT system or that of a third party.
You can manage your cookies
On your first visit to our Site, you are informed about the use of cookies and other technologies, including for profiling purposes (matching our offers to your preferences). Using a tool designed by us, you have the possibility to manage cookies (your consent) from the Webite. Furthermore, you have the possibility of changing the settings of cookies by changing the settings of your browser or deleting them.
However, we would like to warn you that if you block or delete cookies, your use of the Website, as well as other websites, may be impaired.
Cookies we use
Below we provide you with information about the cookies we collect as part of our Site.
Cookies related to the functionality of the Website (proprietary cookies)
These cookies are always enabled as they enable the basic operation of the Website. Among other things, these are cookies that allow you to be remembered per session. Their purpose is to ensure that the Website functions correctly.
Third-party cookies
As part of its marketing activities, the Administrator uses online tools that use cookies. For more information, we encourage you to read the privacy policies of the individual tools.
Google Analitics
Our Website uses the Google Analytics tool, which is provided by Google LLC.
Google Analytics, as a web analytics tool, uses its own cookies to track user interactions. Google Analytics collects information anonymously without identifying users. Google Analytics is used to analyse data that may be used by other Google tools, including Google Ads.
The advertising features used in Google Analytics as implemented for our Website include, but are not limited to, (I) remarketing in Google Analytics, (II) Google Ads network impression reports, (III) Google Analytics interest and demographic reports.
You can opt out of Google Analytics via your browser settings. For details on how to opt-out of tracking by Google Analytics on all websites used, please see: https://support.google.com/analytics/topic/2919631.
Google Ads
Our website uses the Google Ads tool, which is provided by Google Ireland Limited and Google LLC.
Google Ads is a tool that allows you to manage your advertising system. The advertising functions used in Google Ads implemented for our Website are (I) remarketing, (II) interest categories, (III) similar audiences, (IV) other types of interest-based advertising, (V) demographic and location targeting.
You can opt-out of Google Ads using the cookie management tool provided by us or through your browser settings. For details on how to opt-out of tracking by Google Ads, as indicated under: https://support.google.com/adwords/answer/2407785.
Current privacy policy and its changes
The latest version of the policy is effective from 17 October 2022.
The Policy was updated on 15 April 2020. The scope of the updates made relates to the introduction of new services and functionalities by the Data Controller and does not affect the legal position of data subjects reading this Policy prior to the date of the update.
The Policy was updated on 19 May 2021. The scope of the updates made relates to clarifying the transfer of personal data to third country recipients and does not affect the legal position of data subjects familiar with this policy prior to the date of the update.
The policy was updated on 11 October 2022. The scope of the updates made relates to the transfer of personal data to third country recipients and includes a change of layout and does not affect the legal position of data subjects reading this policy prior to the date of the update.
