SOKOŁÓW S.A. PRIVACY POLICY ON PROCESSING OF PERSONAL DATA OF USERS OF COMPANY’S WEBSITES

SOKOŁÓW S.A. Privacy Policy (hereinafter referred to as the “Policy”) is addressed to users of the "SOKOŁÓW" S.A. Company websites (listed below and referred to collectively as the “Website”). The Policy describes the principles governing the processing of personal data of website users by "SOKOŁÓW" S.A. with its registered office in Sokołów Podlaski.

1. Key terms used in this Policy

Data Controller – an entity that independently or jointly with others sets the purposes and means of processing personal data;

Personal Data – means any information about an identified or identifiable natural person through one or more factors specific to physical, physiological, genetic, mental, economic, cultural or social identity, including image, voice recording, location data, contact data, information contained in correspondence, information collected through recording equipment or other similar technology;

"SOKOŁÓW" - "SOKOŁÓW" S.A. with its registered office in Sokołów Podlaski;

GPDR – Regulation (EU) 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 – the Company's Websites listed in the table above;

User – a natural person using the Company websites.

2. Data controller

The administrator of the data collected in connection with the use of the Website is "SOKOŁÓW" S.A. located in Sokołów Podlaski, at: Aleja 550-lecia 1, 08-300 Sokołów Podlaski, entered into the register of entrepreneurs by the District Court for Lublin-Wschód in Lublin with registered office in Świdnik, VI Commercial Division of the National Court Register under KRS number 0000050909, NIP 823 000 14 44, share capital of PLN 101,467,444.00 paid in full (hereinafter referred to as "Sokołów"). In matters related to the processing of your data by the Controller, you can contact Sokołów or the Data Protection Team appointed by the Company via e-mail messages addressed to the e-mail address: odo@sokolow.pl

3. Data Source

1. If you have contacted the Controller, the data was provided to us directly from you.

2. In the case of creating an account on the Website, the data was provided to us directly from you.

3. If your data have been provided in connection with the processing of a case by the person who referred the case to the Controller, the source of the data is that person. In such a case, the Administrator shall receive identification, address and case-related data, such as a description of the case.

4. Purpose and legal basis of personal data processing

The scope and purpose of our data collection depends on your activity on the Website.

a) Contact Form applies to the Websites where such a contact form exists

(i.e.www.sokolowsa.pl, www.sokolow.pl, www.parowkistowki.pl, www.zgruntudobre.com, www.naturrino.pl, www.salami.pl, www.przekaskimiesne.pl)

If you wish to contact us, e.g., to ask questions regarding our offer, you will provide personal data marked as mandatory in the form. Provision of other data is optional.

Personal data is processed:

• for the purpose of identifying the User and answering the question included in the contact form, including complaints - the legal basis for processing is the consent given by the User;

• for the possible establishment, investigation or defence against claims - the legal basis of the processing is the legitimate interest to protect our rights;

• for analytical and statistical purposes - the legal basis of the processing is the legally justified interest consisting in conducting analyses and statistics on matters reported by Users, among others, in order to improve the functioning of the Website or improve our offer.  

b) Newsletter (operating on the following Websites: www.sokolow.pl)

For users who have provided us with their e-mail address for this purpose, we provide a newsletter service, i.e., the provision of commercial information on products or services offered by us.

Personal data is processed:

• in the case of directing marketing content to the user within the newsletter, the legal basis for processing is the consent given by the user;

• for the possible establishment, investigation or defence against claims - the legal basis of the processing is the legitimate interest to protect our rights;

c) Website account (operating on the following Websites: www.catalog.sokolowsa.com) 

For users who have created an account on the Website and have provided us with the personal data necessary to create an account, including their e-mail address, we provide commercial information on our products or services.

Personal data is processed:

• in case of provision of the service of maintaining an account on the Website - the legal basis of the processing shall be the performance of a contract to which the data subject is a party or to take steps at the request of the data subject prior to entering into a contract;

• for the possible establishment, investigation or defence against claims - the legal basis of the processing is the legitimate interest to protect our rights;

• for analytical and statistical purposes - the legal basis of the processing is the legally justified interest consisting in conducting analyses of Users' activity on the website in order to improve the applied functionalities and enhance our offer.

d) Redirecting to other external Websites (e.g., social media, external websites of other entities, the Company's brands websites)

The Websites (the Company's websites) contain links to other websites of the Company, including those relating to the Company's product brands as well as to the Company's social media and other external websites of entities, e.g., used by the Company in the recruitment process. The User may move from a given page of the Website he/she is viewing to another page as indicated in the previous sentence by clicking on the link provided on that page. Upon clicking the link, the User will be taken directly to the linked website without having to enter a separate web address in the browser.

5. The obligation or voluntary submission of personal data:

1. The provision of data by you for case-related purposes is voluntary but necessary. Failure to do so may make it difficult or impossible to process the case.

2. The provision of data by you for newsletter-related purposes is voluntary but necessary. Failure to do so will prevent the newsletter from being sent to you.

3. The provision of data by you for the purposes of creating an account on the Website is voluntary, but necessary for its creation. Failure to do so will prevent the creation of an account.

6. Rights resulting from the processing of personal data (rights of data subjects)

You have the following rights in relation to the processing of your personal data by the Company:

1. the right to obtain confirmation of the processing of your personal data by Sokołów, to obtain access to such data and a copy thereof,

2. The right to request from the Controller the rectification or correction of data - with regard to the request for data rectification, when you notice that the data is incorrect or incomplete,

3. the right to request the Controller to delete the data,

4. the right to request from the Controller the restriction of processing - e.g., if you notice that the data are incorrect, you may demand the restriction of the processing of your data for a period allowing us to check their correctness,

5. the right to transfer data if the processing takes place on the basis of consentor on the basis of a contract and the processing is carried out in an automated manner,

6. in the case of processing your data on the basis of Sokołów's legitimate interest - the right to object to the processing of your personal data in connection with your particular situation,

7. the right to withdraw consent to processing, where your consent forms the legal basis for processing - this will not affect the lawfulness of processing activities undertaken prior to withdrawal of consent,

8. the right to lodge a complaint with a local data protection authority in the EU or a data protection authority in Poland (the President of the Office for Personal Data Protection), ul. Stawki 2, 00 - 193 Warszawa), if you believe we are processing personal data unlawfully.

Should you wish to exercise your rights, please contact us in the first instance at  odo@sokolow.pl

7. Recipients of your personal data

Your personal data may be made available to the following categories of recipients:

• entities processing data on behalf of Sokołów S.A., e.g., IT service providers, marketing agencies, courier companies, other companies from the SOKOŁÓW Capital Group, etc., which process your personal data on the basis of an appropriate agreement with Sokołów S.A,

• public administration bodies, in situations defined by law.

• in other cases, personal data may be disclosed to entities authorised only on the basis of legal regulations.

If we transfer your personal data to recipients outside the European Union or the European Economic Area (EEA), this only takes place if, in relation to that third country, the European Commission has confirmed an adequate level of data protection, adequate safeguards are provided (e.g., by means of standard data protection clauses or binding corporate rules approved by the competent supervisory authority) or if we have obtained your consent to do so.

8. Personal data retention periods

Sokołów S.A. processes your personal data in connection with your use of the Company's websites (the Website) until there is a legal basis for the processing, i.e., in the case of the processing of your data on the basis of:

• consent - until it is withdrawn, whereby you may withdraw your consent at any time, but this does not affect the lawfulness of the processing carried out on the basis of your consent before its withdrawal;

• for the purpose of answering or investigating complaints and/or other enquiries, until they are answered or investigated;

• for the purpose of preserving evidence in order to defend against possible claims, until those claims expire;

• for statistical analyses of user activity, until you raise an objection;

• the relevant provisions of the law, for the period specified therein;

• until you have raised an effective objection to the processing of your personal data;

• until an effective request for deletion is made.

9. Profiling and automated processing

The only profiling that may take place on our Websites may occur when we monitor your activities via cookies from services such as Google and Facebook, e.g., Google Analytics and Facebook Pixel, which we use to embed content on our Websites. This data is not used or processed by us in any way and constitutes statistics on website visits or responses to sponsored content in Google search and online advertising. As we do not make any decisions or assess personal characteristics on this basis and you consent to the use of cookies separately, there is no profiling process that requires separate consent.

10. AMENDMENTS TO PRIVACY POLICY

The policy is verified on an ongoing basis and updated if necessary. The current version of the Policy has been adopted and is effective from 14 January 2021.