Privacy Policy Electrum Holding Sp. z o.o.
To ensure the lawful, transparent, and secure processing of your personal data, the Electrum Group has adopted this Privacy Policy. Committed to maintaining the highest standard of services and respecting the privacy rights of individuals whose data we process, including users of our services, our contractors, and their employees, we inform you that the data collected is processed in accordance with national and European laws and under conditions that guarantee its security.
To ensure the transparency of the processing activities carried out, we present the data protection principles in force at Electrum Holding Sp. z o.o., established based on 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, hereinafter referred to as “GDPR”).
This policy was last updated on 19.10.2022.
- Who is the controller of your personal data?
- by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok;
- by email, at: iod@electrum.pl;
- by phone, at: 85 664 73 73.
- How can you contact the Data Protection Officer?
- by email, at: iod@electrum.pl;
- by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok.
- For what purposes and on what basis do we process your data?
- to conduct recruitment activities leading to the conclusion of an employment contract (based on Article 6(1)(a) and (c) GDPR) or another type of cooperation agreement (based on Article 6(1)(a) and (b) GDPR);
- to conduct future recruitment processes, based on your consent to the processing of personal data provided in your CV, form, cover letter, and other documents. The basis for processing is this consent based on Article 6(1)(a) and (b) GDPR;
- to pursue the legitimate interest of the controller in processing data obtained from you during the recruitment process in connection with verifying your skills and qualifications needed for the position specified in the job advertisement – the basis for processing these data is our legitimate interest (based on Article 6(1)(f) GDPR);
- to ensure physical security and information security in connection with the use of video surveillance of the office premises and the area in front of the building, in the execution of our legitimate interest (based on Article 6(1)(f) GDPR);
- for potential establishment, exercise, or defense against claims and allegations in the execution of our legitimate interest (based on Article 6(1)(f) GDPR).
- What rights do you have in connection with the processing of data?
- the right to withdraw consent (where the legal basis for processing is consent) at any time. However, your withdrawal of consent will not affect the legality of the processing carried out before its withdrawal;
- the right to access your data and receive a copy of it;
- the right to rectify your data;
- the right to erase or restrict the processing of data;
- the right to object to the processing of data based on our legitimate interest;
- the right to data portability;
- the right to lodge a complaint with a supervisory authority (in Poland, this is the President of the Personal Data Protection Office).
- To whom do we disclose your data?
- How long will we store your data?
- for the purposes specified in point 3 items 1) – 2) for the period necessary to conduct this recruitment;
- for the purposes specified in point 3 items 3) – 4) for the period allowing the pursuit of the legitimate interest or until an effective objection to processing is raised;
- for the purpose specified in point 3 item 5) for the limitation period of claims.
- Is it mandatory to provide your data?
- Automated decision-making, including profiling of your data
- Who is the controller of your personal data?
- by mail, sending a letter to the address: Watykańska 13, 15-638 Białystok;
- by email, at: iod@electrum.pl;
- by phone, at: +48 85 664 73 73, tel. +48 85 664 73 72.
- How can you contact the Data Protection Officer?
- by email, at: iod@electrum.pl;
- by mail, sending a letter to the address: Watykańska 13, 15-638 Białystok.
- What data do we process and from what sources do we obtain it?
- identification data: first and last name, position, function, PESEL number, or date of birth;
- registration data: NIP, REGON;
- contact details: email address, phone number, correspondence address;
- financial data: bank account number.
- For what purposes and on what basis do we process your data?
- to conclude and perform a contract (based on Article 6(1)(b) GDPR – if you are a party to the contract) or to pursue our legitimate interest in the proper performance of the contract (for persons cooperating with us on behalf of a client/contractor, based on Article 6(1)(f) GDPR);
- to conduct settlements, accounting, and financial reporting (based on Article 6(1)(c) GDPR);
- for archival (evidential) purposes, as part of our legitimate interest in securing information in case of the need to demonstrate facts (based on Article 6(1)(f) GDPR);
- to verify the occurrence of conflicts of interest, as part of our legitimate interest in avoiding conflicts of interest (based on Article 6(1)(f) GDPR);
- for potential establishment, exercise, or defense against claims and allegations as part of our legitimate interest (based on Article 6(1)(f) GDPR).
- What rights do you have in connection with the processing of data?
- the right to withdraw consent (where the legal basis for processing is consent) at any time. However, your withdrawal of consent will not affect the legality of the processing carried out before its withdrawal;
- the right to access your data and receive a copy of it;
- the right to rectify your data;
- the right to erase or restrict the processing of data;
- the right to object to the processing of data based on our legitimate interest;
- the right to data portability;
- the right to lodge a complaint with a supervisory authority (in Poland, this is the President of the Personal Data Protection Office).
- To whom do we disclose your data?
- We disclose your personal data to other entities belonging to the Electrum capital group based on concluded contracts, as well as to our partners with whom we cooperate in the execution of processes, and subcontractors, such as IT service providers, our employees, and collaborators authorized to process personal data in connection with the performance of their duties.
- We also disclose your personal data to authorized bodies or institutions in accordance with applicable law.
- We do not transfer your personal data to recipients located outside the European Economic Area.
- How long will we store your data?
- Is it mandatory to provide your data?
- Automated decision-making, including profiling of your data
- Who is the controller of your personal data?
- by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok;
- by email, at: iod@electrum.pl;
- by phone, at: 85 664 73 73.
- How can you contact the Data Protection Officer?
- by email, at: iod@electrum.pl;
- by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok.
- For what purposes and on what basis do we process your data?
- to identify the person reporting a violation and to take appropriate action in response to the reported violation (based on Article 6(1)(c) GDPR) or to pursue our legitimate interest in ensuring the ability to take necessary action in connection with the reported violation (based on Article 6(1)(f) GDPR);
- for archival (evidential) purposes, as part of our legitimate interest in securing information in case of the need to demonstrate facts (based on Article 6(1)(f) GDPR);
- for potential establishment, exercise, or defense against claims and allegations as part of our legitimate interest (based on Article 6(1)(f) GDPR).
- What rights do you have in connection with the processing of data?
- the right to withdraw consent (where the legal basis for processing is consent) at any time. However, your withdrawal of consent will not affect the legality of the processing carried out before its withdrawal;
- the right to access your data and receive a copy of it;
- the right to rectify your data;
- the right to erase or restrict the processing of data;
- the right to object to the processing of data based on our legitimate interest;
- the right to data portability;
- the right to lodge a complaint with a supervisory authority (in Poland, this is the President of the Personal Data Protection Office).
- To whom do we disclose your data?
- We disclose your personal data to other entities belonging to the Electrum capital group in connection with the execution of contracts, as well as to our partners with whom we cooperate in matters related to personnel issues, such as law firms, IT companies, particularly Braf.tech Sp. z o.o., Staniątki 858, 32-005 Staniątki, in the scope of providing software that functions as an internal reporting channel within the Electrum Group.
- We also disclose your personal data to authorized bodies or institutions in accordance with applicable law.
- How long will we store your data?
- Is it mandatory to provide your data?
- Automated decision-making, including profiling of your data
- Who is the controller of your personal data?
- by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok;
- by email, at: iod@electrum.pl;
- by phone, at: 85 664 73 73.
- How can you contact the Data Protection Officer?
- by email, at: iod@electrum.pl;
- by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok.
- For what purposes and on what basis do we process your data?
- to execute the employment contract and fulfill the rights and obligations arising from it, including the payment of remuneration, granting of social benefits, maintaining documentation related to employment matters, and keeping employee personal files (based on Article 6(1)(c) GDPR and the Labor Code, and for data beyond that specified in the Labor Code, based on Article 6(1)(a) GDPR);
- to fulfill our legal obligations regarding social security and taxes (based on Article 6(1)(c) GDPR and Article 9(2)(b) GDPR);
- to provide and manage, including the settlement of costs, additional benefits offered by us or cooperating entities, which you may be a beneficiary of, particularly related to medical care, additional insurance, sports cards, and other benefits (based on Article 6(1)(b) GDPR);
- to use the results of your work for the improvement, verification, and presentation of our services, as part of our legitimate interest in improving the quality of services provided and fulfilling the provisions of contracts concluded with our contractors (based on Article 6(1)(f) GDPR);
- to publish your data, including your name, surname, business email address, business phone numbers, office, position, place in the organizational structure, and image—if you decide to upload your photo—in the internal portals and systems of the Electrum capital group, as well as in other IT tools used by us or other entities belonging to the Electrum capital group, as part of our legitimate interest and the legitimate interest of other entities belonging to the Electrum capital group, in facilitating communication and cooperation within the Electrum capital group (based on Article 6(1)(f) GDPR);
- to present you as our representative in relations with our contractors in the scope of your duties, as part of our legitimate interest in fulfilling the provisions of contracts concluded with our contractors (based on Article 6(1)(f) GDPR);
- to ensure physical security and information security through the use of video surveillance of the office building, the area in front of the building, and at our contracts/sites, as well as access control to rooms, as part of our legitimate interest (based on Article 6(1)(f) GDPR);
- for potential establishment, exercise, or defense against claims and allegations as part of our legitimate interest (based on Article 6(1)(f) GDPR).
- What rights do you have in connection with the processing of data?
- the right to withdraw consent (where the legal basis for processing is consent) at any time. However, your withdrawal of consent will not affect the legality of the processing carried out before its withdrawal;
- the right to access your data and receive a copy of it;
- the right to rectify your data;
- the right to erase or restrict the processing of data;
- the right to object to the processing of data based on our legitimate interest;
- the right to data portability;
- the right to lodge a complaint with a supervisory authority (in Poland, this is the President of the Personal Data Protection Office).
- To whom do we disclose your data?
- We disclose your personal data to other entities belonging to the Electrum capital group in connection with the execution of contracts, as well as to our partners with whom we cooperate in matters related to personnel issues, such as entities providing health care services, additional insurance, sports cards, and other benefits, training companies, archiving companies, law firms, IT companies.
- We also disclose your personal data to authorized bodies or institutions in accordance with applicable law.
- How long will we store your data?
- for the purposes specified in point 3 items 1) – 2) for the period of storing employee documentation specified in the Labor Code or other legal regulations, with the reservation that data processed based on consent will be stored no longer than until consent is withdrawn;
- for the purpose specified in point 3 item 3) for the duration of the employment relationship;
- for the purposes specified in point 3 items 4) – 7) for the period allowing the pursuit of a legitimate interest or until an effective objection to processing is raised;
- for the purpose specified in point 3 item 8) for the limitation period of claims.
- Is it mandatory to provide your data?
- Automated decision-making, including profiling of your data
- Who is the controller of your personal data?
- by mail, by sending a letter to the address: ul. Watykańska 13, 15-638 Białystok;
- by email, at: iod@electrum.pl;
- by phone, at: 85 664 73 73.
- How can you contact the Data Protection Officer?
- by email, at: iod@electrum.pl;
- by mail, by sending a letter to the address: ul. Watykańska 13, 15-638 Białystok.
- For what purposes and on what basis do we process your data?
- to execute the contract for services and fulfill the rights and obligations arising from it, including the payment of remuneration (based on Article 6(1)(b) GDPR);
- to fulfill our legal obligations regarding social security and taxes (based on Article 6(1)(c) GDPR and Article 9(2)(b) GDPR);
- to provide and manage, including the settlement of costs, additional benefits offered by us or cooperating entities, which you may be a beneficiary of, particularly related to medical care, additional insurance, sports cards, and other benefits (based on Article 6(1)(b) GDPR);
- to use the results of tasks completed by you for the improvement, verification, and presentation of our services, as part of our legitimate interest in improving the quality of services provided and fulfilling the provisions of contracts concluded with our contractors (based on Article 6(1)(f) GDPR);
- to publish your data, including your name, surname, business email address, business phone numbers, office, position, place in the organizational structure, and image—if you decide to upload your photo—in the Electrum Capital Group address book accessible to the personnel of entities belonging to the Electrum Capital Group, as well as in other IT tools used by us or other entities belonging to the Electrum Capital Group, as part of our legitimate interest and the legitimate interest of other entities belonging to the Electrum Capital Group, in facilitating communication and cooperation within the Electrum Capital Group (based on Article 6(1)(f) GDPR);
- to present you as our representative in relations with our contractors in the scope of your duties, as part of our legitimate interest in fulfilling the provisions of contracts concluded with our contractors (based on Article 6(1)(f) GDPR);
- to ensure physical security and information security through the use of video surveillance of office spaces, as well as access control to rooms and personal identification tags, as part of our legitimate interest (based on Article 6(1)(f) GDPR);
- for potential establishment, exercise, or defense against claims and allegations as part of our legitimate interest (based on Article 6(1)(f) GDPR).
- What rights do you have in connection with the processing of data?
- the right to withdraw consent (where the legal basis for processing is consent) at any time. However, your withdrawal of consent will not affect the legality of the processing carried out before its withdrawal;
- the right to access your data and receive a copy of it;
- the right to rectify your data;
- the right to erase or restrict the processing of data;
- the right to object to the processing of data based on our legitimate interest;
- the right to data portability;
- the right to lodge a complaint with a supervisory authority (in Poland, this is the President of the Personal Data Protection Office).
- To whom do we disclose your data?
- We disclose your personal data to other entities belonging to the Electrum Capital Group in connection with the execution of contracts, as well as to our partners with whom we cooperate in matters related to personnel issues, such as entities providing health care services, additional insurance, sports cards, and other benefits, training companies, archiving companies, law firms, IT companies.
- We also disclose your personal data to authorized bodies or institutions in accordance with applicable law.
- How long will we store your data?
- for the purposes specified in point 3 items 1) – 2) for the period of storing documentation specified by law;
- for the purpose specified in point 3 item 3) for the duration of the service contract;
- for the purposes specified in point 3 items 4) – 7) for the period allowing the pursuit of a legitimate interest or until an effective objection to processing is raised;
- for the purpose specified in point 3 item 8) for the limitation period of claims.
- Is it mandatory to provide your data?
- To the extent that we process personal data based on regulations governing obligations regarding social security and taxes, providing data is a statutory requirement necessary to conclude a service contract or to fulfill a legal obligation imposed on us. Failure to provide this data will prevent the conclusion of a service contract or the performance of our legal obligations.
- In other respects, providing personal data is voluntary. However, failure to provide personal data may prevent the conclusion of a service contract or the ability to benefit from additional benefits. If personal data is processed based on consent, you may withdraw consent at any time. Withdrawal of consent will not affect the legality of the processing carried out before its withdrawal.
- Automated decision-making, including profiling of your data
