Information regarding the processing of your personal data by emplo for marketing purposes

Terms used in this information

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, pp. 1-88).

emplo, we, our – Emplo Ltd., address: 60 Dzielna St., 01-029 Warsaw, email address: kontakt@emplo.com

Your personal data

For the purpose of conducting marketing activities and providing you with marketing and commercial information, emplo uses the following data about you:

1) provided directly by you to emplo, as well as obtained by emplo from publicly available sources, including: name, surname, email address, phone number, company name, address, industry, number of employees in your company, position in the company, your newsletter preferences and

2) data collected automatically by us using cookies and resulting from your activity on emplo websites (emplo.com and emplo.pl), including in particular information about the websites you have visited.

Your data administrator

The administrator of your personal data is: Emplo Ltd. with its registered office in Warsaw, 60 Dzielna St., 01-029 Warsaw; email address: iod@emplo.com

Purpose and legal basis for processing your data Emplo Marketing

For the purpose of conducting marketing activities targeted at entrepreneurs, we process your personal data based on emplo’s legitimate interest (legal basis: art. 6(1)(f) GDPR). Our legitimate interest consists of using your business-related personal data for direct marketing of our products and services only in professional relationships (so-called business-to-business), if you have consented to receiving marketing and commercial information from emplo via email or phone or consented to the cookies indicated on our websites. After weighing our interest against yours, we have concluded that we will not unduly intrude on your privacy. More information on profiling can be found below in the section Profiling Your Preferences and Interests.

Profiling Your Preferences and Interests

To conduct marketing activities, we profile your preferences and interests in order to tailor emplo’s marketing communication to your needs, including customizing specific product and service offers. We assess your preferences and interests based on data: (1) collected in our systems supporting the proper provision of our services e.g. CRM, registration system and online marketing systems, as well as (2) collected automatically (recorded and stored) through cookies and resulting from your activity on emplo websites or similar sites owned by emplo. The result of our profiling is providing you with marketing messages concerning emplo’s products and services, via email, phone or on our websites, as well as personalizing the marketing messages we send. Our messages may also be displayed to you on unrelated websites of entities providing us with advertising services e.g. websites of Google or Facebook advertising networks.

As a result of our profiling, there will be no denial of access to the services we provide. In exceptional cases, profiling may lead to differentiation of offers addressed to different individuals in similar situations.

Profiling is carried out on the basis of our legitimate interest in emplo (legal basis: art. 6(1)(f) GDPR), consisting of conducting marketing communication that will be attractive and tailored to your needs and interests. After balancing our interest against yours, we have concluded that we will not unduly intrude on your privacy and our actions will not have any significant effects, including legal ones, but will increase the attractiveness of our offer for you.

Our activities relate solely to professional relationships. We do not collect information that would allow us to gain insight into your private life. On the contrary, we only collect information related to your professional activity and only to a very limited extent.

You can find more information about the use of cookies by emplo in our Cookie Policy.

Recipients of your data

We disclose your personal data to the following categories of recipients: emplo employees and associates, hosting service providers, customer support tools providers (e.g. CRM, ticket monitoring system, chat), accounting system providers, online marketing system providers, analytical service providers, providers supporting marketing activities conducted by emplo (e.g. advertising agencies and training/event organizers), as well as to public authorities (if required by law, administrative decision, or judicial ruling).

Storage period for your data

We store your data for marketing purposes until you opt out of receiving marketing and commercial information from emplo or emplo-affiliated companies (withdrawal of consent or objection), but no longer than 3 years from the date of your last activity in online or offline marketing actions and events organized by emplo. Your activity includes any action that may indicate your interest in emplo’s services or marketing actions, such as participation in a marketing campaign (conference, training, satisfaction survey), opening advertising emails, visiting emplo’s website, or using emplo’s services. During the 3-year period from your last activity, your personal data will no longer be actively processed, just stored. After this period, your personal data will be deleted or anonymized.

Transfer of your data outside the EU

We transfer your personal data to our CRM service providers, analytical service providers, and online marketing system providers who may process them outside the European Union. We have ensured that our providers guarantee a level of data protection equivalent to that in the case of providers processing data within the European Union. These guarantees arise specifically from:

– the location of providers in countries outside the European Union that ensure an adequate level of personal data protection in accordance with decisions of the European Commission;

– providers’ commitment to comply with standard data protection clauses adopted by the European Commission (https://eur-lex.europa.eu/legal-content/PL/TXT/HTML/?uri=CELEX:32016D1250&from=EN);

– providers’ participation in the ‘Privacy Shield’ program, established by Commission Implementing Decision (EU) 2016/1250 of 12 July 2016 on the adequacy of the protection provided by the EU-US Privacy Shield (https://eur-lex.europa.eu/legal-content/PL/TXT/PDF/?uri=CELEX:32016D1250&from=PL)

Your rights

You have the right to:

1) opt-out of receiving marketing and commercial information which means, depending on the circumstances, objection or withdrawal of consent: (1) regarding the processing of your personal data for direct marketing purposes, including profiling by emplo, (2) to receive marketing and commercial information via phone or email. You can exercise objection or withdrawal of consent by emailing: iod@emplo.com;

2) request access to your personal data, their correction, deletion, or restriction of processing, and data portability to another data controller. You can make requests by emailing: iod@emplo.com;

3) lodge a complaint with the President of the Office for Personal Data Protection concerning the processing of your personal data by emplo in the future.

Contact us

If you have any questions regarding the processing of your personal data and your rights, please contact us:  iod@emplo.com.