Privacy Policy
Introductory information
Respecting the right to privacy of persons who have entrusted Premium Brands Spirits sp. z o.o. based in Reda (hereinafter the "Company") with their personal data, we would like to declare that we process the data obtained in accordance with national and European laws and under conditions that ensure its security. In order to ensure the transparency of the processing carried out by us, we present the personal data protection principles applicable to the Company, established on the basis of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons in relation to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter "RODO")
Data controller
The controller, i.e. the entity that decides on the purposes and means of the processing of personal data, is Premium Brands Spirits sp. z o.o. based in Reda (ul. Wejherowska 67, 84 - 240 Reda, pov. wejherowski, pomorskie voivodeship), entered in the register of entrepreneurs of the National Court Register kept by the District Court Gdańsk - North in Gdańsk, 8th Commercial Division of the National Court Register, under no. 0001005398, NIP: 5871701501, REGON: 222026430, BDO no.: 000514145, share capital: PLN 15,000.
The Company attaches great importance to the protection of personal data, therefore the controller encourages you to contact the Company at the Company's registered address indicated above or at the office address in Warsaw (00 - 728), ul. Dziekońskiego 3, with any concerns regarding the processing of your personal data.
Data acquisition and purpose of data processing
The company is a distributor of mainly alcoholic beverages. In carrying out our business functions, we process personal data for the following purposes:
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Purpose of processing |
Legal basis and data retention period |
Legitimate purpose, if any |
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Conclusion and performance of a contract with a contractor |
Article 6(1)(b) and (f) RODO For the duration of the contract and, upon termination, until the expiry of the time limits for claims arising therefrom (in the case of a business sales contract, 2 years). |
The administrator, in connection with activities undertaken for the purpose of concluding a contract or its performance, contacts employees/co-workers of contractors for a legitimate purpose. In addition, the controller may obtain basic data of the employee/co-worker (name, place of employment or co-operation, telephone number, e-mail address and, in certain situations, photo ID number) from the contracting party in connection with the performance of the contract, from the entity with which the person is employed or co-operates. |
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Conclusion and performance of a contract with a contractor who is a natural person |
Article 6(1)(a) RODO Data is provided by the person interested in entering into the contract; data is processed in this case on the basis of his or her consent. For the duration of the contract and, after termination of the contract, until the expiry of any claims arising therefrom. |
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Handling complaints |
Article 6(1)(b) and (f) RODO For 1 year after the warranty expires or the complaint is resolved. |
The administrator, in connection with the handling of complaints, contacts employees/co-workers of contractors for a legitimate purpose. |
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Redressing or defending against legal claims |
Article 6(1)(f) RODO For the duration of the proceedings in respect of the claims asserted, i.e. until their final conclusion and, in the case of enforcement proceedings, until final settlement of the claims asserted. |
The controller in connection with the assertion or defence of claims for a legitimate purpose may process the data of contractors, employees/co-workers of contractors. |
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Archiving of documents, i.e. contracts and billing documents |
Article 6(1)(c) RODO For the periods indicated by the law and, if no such periods are indicated for specific documents, for the time that their retention falls within the legitimate purpose of the controller regulated by the time of possible redress. |
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Statistics and analysis |
Article 6(1)(f) RODO Until such time as the other purpose of processing indicated in this table is fulfilled. We do not store personal data exclusively for statistical and analytical purposes. |
Keeping statistics and analysing activities allows the administrator to improve its operations. |
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Conducting marketing activities without the use of electronic communication means |
Article 6(1)(f) RODO Until you raise an objection, i.e. show us in any way that you do not wish to stay in contact with us and receive information about the activities we undertake. |
Conducting marketing activities to promote the business. |
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Conducting marketing activities using electronic communication means |
Article 6(1)(a) RODO These activities, due to other applicable laws, in particular the Telecommunications Act and the Electronic Services Act, are carried out on the basis of your consents. Until or unless you withdraw your consent, i.e. show us in any way that you do not wish to stay in contact with us and receive information about the activities undertaken by us, and after revocation, for the purpose of demonstrating the correctness of the fulfilment of legal obligations incumbent on the Company and related claims (up to 6 years after revocation of consent). |
Conduct marketing activities to promote the business using email addresses and telephone numbers. |
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Access control, including monitoring on the controller's premises for the purposes of enhancing employee security and protecting property and maintaining the confidentiality of information |
Article 6(1)(c) and (f) RODO Until an objection is lodged, not longer than one year. Image recordings shall be processed only for the purpose for which they were collected and shall be stored for a period not exceeding 3 months from the date of the recording, unless the recording constitutes evidence in proceedings, in which case until the proceedings have become final or until an objection is lodged. |
Conducting access control for persons on the administrator's premises is its legitimate purpose and, in the case of employees, stems from a legal provision (Art. 222 KP). The controller may obtain the basic data of the employee/co-worker (name, place of employment or co-operation, telephone number and, in certain situations, photo document number) prior to the arrival of the data subject from the entity with which the data subject is employed or co-operates. |
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Recruitment |
Article 6(1)(a), (b), (c) and (f) of the DPA Up to 3 months after the end of the recruitment process and, in the case of consent for further recruitment processes, no longer than 2 years. |
The controller, without the additional consent of the data subject, may keep the data of job applicants who have not yet been hired until 3 months after the recruitment process as a legitimate purpose of the controller due to the fact that the hired employee/co-worker may not perform well in the job or may resign. |
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Human resources management - employees and associates |
Article 6(1)(a), (b), (c) and (f) of the DPA Article 9(2)(b) RODO In accordance with the current legislation requiring the archiving of employment law documents, i.e. personal files for 50 years, in some cases for 10 years. A 10-year retention period for documentation on matters related to the employment relationship and the employee's personal file will apply for all employees hired after 1.01.2019. For employees hired after 31.12.1998 and before 1.01.2019, the documentation related to the employment relationship and the employee's personal file will be kept for a period of 50 years from the date of termination or expiry of the employment relationship, unless the employer submits a declaration of its intention to provide information reports for all employees and contractors hired during that period, and actually submits such reports. If the retention period for the selected documents is shorter, the administrator will respect this shorter period. In the case of civil law contracts, these contracts will be retained until the expiry of the limitation periods for claims arising from them. |
The administrator uses the image only on the basis of the employee's/co-worker's consent. |
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Running a contact form on the website |
Article 6(1)(f) RODO Until an objection is lodged, not more than 2 years. |
Responding to requests and enquiries made using the contact form or in any other form, including storing sensitive requests and responses in order to maintain accountability |
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Adaptation of website content to users' needs, optimisation of use of websites |
Article 6(1)(f) RODO Personal data will be processed for the periods indicated in the Information on the use of cookies or until you object to the data being processed. The objection can only be made by changing the end user's browser settings to prevent the collection of information using cookies. |
The controller's legitimate interest in the operation of the websites, user visits and analysis of website activity, as well as optimisation of website use |
If the relevant periods for the assertion of possible claims are shorter than the periods for the retention of accounting documents for tax purposes, we will retain these documents for the time necessary for tax and accounting purposes, i.e. for 5 years after the end of the year in which the tax obligation was incurred.
We obtain personal data from the following sources:
- publicly accessible registers,
- directly from the person concerned, who indicates his or her personal data, superiors, contractors, employees, co-workers.
Recipients of data
In connection with its operations, the Company may disclose personal data to the following entities:
- state and local government authorities, common or administrative courts, other entities authorised by law;
- entities supporting us in our operations on our behalf, in particular: suppliers of external ICT systems, transport entities and entities providing postal and courier services, entities auditing our operations, entities belonging to our capital group, entities cooperating with the Company within the framework of marketing campaigns, as well as those providing advisory, debt collection, legal and insurance services, whereby such entities will process data on the basis of a contract with the Company, granted authorisation and exclusively in accordance with the Company's instructions;
- banks, where settlement is required;
- manufacturers/importers of goods of which the Company is a distributor, or other entities from which the goods have been purchased by the Company.
Eligibility for data processing and voluntariness of data provision
Any person whose data is processed by the Company shall have the right to:
- access to their personal data;
- rectify your personal data;
- delete your personal data;
- to restrict the processing of your personal data;
- object to the processing of your personal data;
- portability of your personal data.
More information on data subjects' rights is available in Articles 12 - 23 of the RODO, the text of which can be found at:
https://eur-lex.europa.eu/legal-content/PL/TXT/?uri=CELEX%3A32016R0679
In addition, the person whose data is processed by the Company has the right to lodge a complaint with the supervisory authority, i.e. the President of the Office for the Protection of Personal Data; more information at: https://uodo.gov.pl
Do you have to provide your personal data?
The provision of data is necessary for the conclusion of contracts and the settlement of business operations and for the Company to comply with legal requirements. For the rest (in particular for the Company's processing of data for marketing or promotional purposes), the provision of data is voluntary.
Transfers of data to third countries
In certain exceptional situations, data may be transferred to third countries. The transfer of personal data always takes place on the basis of the law, including on the basis of a decision of the European Commission finding an adequate level of protection for that third country or with the application of the appropriate safeguards referred to in Article 46 RODO or in specific situations referred to in Article 49 RODO.
As a general rule, personal data is not transferred by us outside the European Union and the European Economic Area.
Processing of personal data by automated means
Personal data will not be processed by automated means (including profiling) in such a way that any decisions could be made as a result of such automated processing, that any other legal effects would be produced or that it would otherwise materially affect our employees or colleagues, contractors and employees/co-workers of contractors.
