In the course of using Social Networks, Users share a lot of information with “HERBAPOL – LUBLIN” S.A. They provide, inter alia, their identity and contact details, ask questions, lodge complaints, share their observations and take part in contests. All such information may constitute Personal Data and be subject to legal protection.
- Background information;
- Your personal data;
- The rights vested in you in connection with the processing of your personal data;
1. Background information.
a.) “HERBAPOL – LUBLIN” S.A. with its registered office in Lublin, ul. Diamentowa 25, 20-471 Lublin, registered by the District Court for Lublin-Wschód in Lublin, seated in Świdnik, 6th Commercial Division of the National Court Register, KRS No 0000027463, Tax ID No (NIP): 712-015-53-64 is the Controller of Personal Data collected in connection with Users’ use of Social Networks and is, therefore, obliged to protect the data.
d.) The terms used in this Policy shall be understood as follows:
Personal Data – any information relating to an identified or identifiable natural person.
Identifiable Person – a person whose identity can be determined directly or indirectly, e.g. by reference to an identification number or a factor specific to his/her physical, physiological, mental, economic, cultural or social characteristics.
User – a natural person using social networks, including persons who do not have a social network account.
Personal Data Controller – an entity which determines the purposes and means of personal data processing and is responsible for its processing in accordance with the law.
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), Official Journal of the European Union L 119, 4 May 2016, p. 1–88
2. Your personal data
a.) What data do we process?
“HERBAPOL – LUBLIN” S.A.” will process data uploaded by the User on a social network, including int al. the User’s name, surname (including profile name) and data to which “HERBAPOL – LUBLIN S.A. will obtain access after the User has granted consent, depending on his/her privacy settings, int. al.: e-mail address, telephone number, other contact details, interests, declared location, comments, likes, image. “HERBAPOL – LUBLIN” S.A. will also process Personal Data provided by the User in his/her comments posted on Social Networks.
Notwithstanding the foregoing, “HERBAPOL – LUBLIN” S.A. will process User information provided automatically by means of the so-called cookies. For details, please visit www.herbapol.com.pl
The User is obliged not to provide or make available on Social Networks any personal data of third parties, unless it has obtained consent of the data subject.
b.) For what purpose and on what basis do we process your data?
In connection with the activity on social networks, HERBAPOL – LUBLIN S.A., as the controller of Personal Data, uses personal data of the Users for the following purposes:
- responding to queries or handling of complaints – pursuant to Article 6(1)(f) of the GDPR (legitimate interest of the Controller) – for a period necessary to give a response;
- conduct of contests – the legal basis for the processing of data in connection with contests is Article 6 (1)(b) of the GDPR. If you submit a statement of consent in connection with a contest, the legal basis for the processing based on consent is Article 6(1)(a) of the GDPR (User’s consent) until the consent is withdrawn, however, such data may also be processed after that period on the basis of our legitimate interest described in the following items, but only if this is permitted or required under applicable law, e.g. processing for archival purposes or for ensuring accountability;
- archival (evidence) purposes, in order to protect information in the event of a legal need to demonstrate the facts – pursuant to Article 6(1)(f) of the GDPR (legitimate interest of the controller) – for a period in which the controller is obliged to retain data or documents containing data in order to demonstrate compliance with legal requirements and to enable controls of such of compliance by public authorities;
- establishment, exercise or defence of legal claims (if any) – pursuant to Article 6(1)(f) of the GDPR (legitimate interest of the controller) – until the lapse of a limitation period of potential claims resulting from the law;
c.) Who do we transfer your data to?
Personal data of Users may be transferred to processors at the request of “HERBAPOL – LUBLIN S.A.”, int. al. to subcontractors entrusted by us with the performance of promotional activities or to providers of IT services established in the European Economic Area – and such entities shall process data under an agreement with the controller and only in accordance with the instructions of “HERBAPOL – LUBLIN S.A.”
3. Your rights
Every User, insofar as his/her data is controlled by “HERBAPOL – LUBLIN S.A.”, has the right:
a.) of access to his/her Personal Data (Article 15 of the GDPR),
b.) to rectification of his/her Personal Data which is incorrect or incomplete (Article 16 of the GDPR),
c.) to erasure of all or some of his/her Personal Data (Article 17 of the GDPR),
d.) to restriction of use of Personal Data (Article 18 of the GDPR),
e.) to Personal Data portability to a User or other designated entity, in a commonly used, machine-readable format, if we are using the User's personal data on the basis of consent or for the purpose of performing an agreement (Article 20 of the GDPR),
f.) to withdraw consent to the use of Personal Data at any time – if the User’s Personal Data is processed on the basis of consent. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal (Article 7 of the GDPR),
g.) to submit an objection, on grounds relating to the User’s particular situation, to the processing of his/her Personal Data on the basis of legitimate interests of “HERBAPOL – LUBLIN” S.A. Following an objection, “HERBAPOL – LUBLIN S.A” will consider whether – on grounds of the User’s particular situation – the protection of his/her interests, rights and freedoms prevails over the interests that we implement using the User's Personal Data. If the User's objection proves to be reasonable and there is no other legal basis for the use of such data, Personal Data will be erased (Article 21(1) of the GDPR).