LPP SA Privacy Policy - GDPR

This privacy policy sets out the principles and scope of the processing of your personal data as well as your rights and our obligations as the Controller. With state-of-the-art technical and organisational measures, we seek to ensure a high level of protection for the personal data we process to safeguard them against unauthorised access.

 

The data controller is

LPP S.A. with its registered office in Gdańsk, ul. Łąkowa 39/44, entered in the National Court Register, kept by the Gdańsk-Północ District Court in Gdańsk, 7th Commercial Division of the National Court Register (KRS), under KRS no. 0000000778, with its share capital amounting to PLN 3,708,482 (paid up in full), REGON (National Business Registry Number) 190852164 and NIP (Tax ID)) 583-10-14-898 (hereinafter: “LPP”).

 

Contact with the Data Protection Inspector (hereinafter: DPI) and in matters concerning personal data:

You may report any reports or requests regarding your personal data to us in the manner of your choice:

  1. by e-mail to the following address: dataprivacy@lpp.com,
  2. by letter to the following address: LPP S.A. ul. Łąkowa 39/44, 80-769 Gdańsk.

 

Purpose of processing

We process your personal data for the purpose of:

  1. maintaining business relationships,
  2. ensuring the flow of information about the company’s operations,
  3. conducting communication related to the company’s operations on the company’s official channels on social media,
  4. carrying out activities to promote the company and brands associated with the company,
  5. responding to messages that you send to us to the e-mail addresses indicated for contact and via social networks,
  6. ensuring the correct display of the content on the website,
  7. website traffic control and analysis.

 

Legal basis for processing

We process your data on the basis of LPP’s legitimate interest in optimising its business operations, including the promotion of the company’s activities (direct marketing), which is necessary for the proper conduct of its business. The legal basis for the processing of your data results from Article 6(1)(f) of 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.

 

Data type

By visiting our website, we may process information about you, including:

  1. information about the device you are using,
  2. the country from which you visit our website,
  3. the time of your request,
  4. the URL of the website you previously visited if you came to us from another website,
  5. the IP address from which the request was made.
  6. your observed job offers if you mark a job offer as observed in the job search engine provided on the website.

 

If you communicate with us via email addresses or social networks, we may process the data you provide to us, including but not limited to:

  1. first and last name,
  2. e-mail address (e-mail),
  3. phone number,
  4. job position.

 

Information about your rights

Your rights in connection with the processing of your personal data are as follows:

  1. You may object to the processing of your personal data at any time – without giving reasons. The objection may relate to the purpose of processing which you submitted. The objection will not affect the activities performed to date.
  2. You may request that your data be erased, without giving reasons. The request to erase your data will not affect the activities performed to date.
  3. You may request that LPP restrict the processing of your personal data, either for a specific period or within a specific scope. This request will not affect the activities performed to date.
  4. You may request that your personal data be corrected or rectified.
  5. You may request that your personal data held by LPP be transferred to another entity. To this end, please contact us stating the name and address of the entity to which we are to transfer your data and their scope; that is, which of your data we are to transfer. The transfer will take place electronically once you have confirmed this request. The request has to be confirmed to keep your data secure and to ensure that the request comes from an authorised person.
  6. You may request information on the extent of our processing of your personal data if you wish.
  7. You have the right to lodge a complaint with the President of the Office for Personal Data Protection.

You will hear from us concerning the measures we have taken within a month of filing a request.

 

Duration of keeping personal data

We process personal data for the period:

  1. of your presence on the website and for the period of time of storing cookies used by the website you visit on your device – you can find the period of storage of cookies in the Cookie List,
  2. necessary for correspondence in case you contact us by e-mail,
  3. of conducting statistical research – until you lodge an effective objection,
  4. of pursuing claims or defending claims – until the expiry of the period related to a given claim resulting from legal provisions.

 

Entrusting data processing

We entrust your personal data, to the extent necessary for the fulfilment of the specified purposes, to entities cooperating with us and companies belonging to the LPP capital group. In order to ensure your comfort in using the website, we may also provide your data to companies which provide us with IT services, analytical services (e.g. related to the preparation of a personalised offer or user segmentation), cloud service providers (e.g. through the use of software located on the providers’ servers). You can find a list of our trusted partners to whom we transfer or entrust personal data HERE.

Your personal data, except for the purposes indicated in the Privacy Policy, will not be shared with third parties or other entities. You will therefore not receive promotional content other than ours. We do not provide promotional services to third parties.

We ensure the secure processing of your personal data by using effective and appropriately adapted technical and organisational measures.

 

Transferring data outside the EEA

As part of the Controller’s use of tools supporting its day-to-day operations provided, for example, by Google, your Personal Data may be transferred to a country outside the European Economic Area (EEA), in particular to the United States of America (USA) or another country in which an entity cooperating with it maintains tools for processing Personal Data in cooperation with the Controller. Adequate protection of the processed Personal Data outside the EEA is guaranteed by the use of external data processing agreements based on standard contractual clauses that meet the requirements of the GDPR.

 

Cookies

Cookies are small text files containing IT data that allow, among other things, the proper functioning of the Website. They are stored on your end devices. These cookies allow the Website to recognise your device and adjust its appearance according to your preferences. Cookies are needed in order for you to be able to use all functionalities without interruption. These files inform us about your activity on the Website but do not allow your full identification. Cookies may be used, inter alia, for the purpose of:

  1. adapting the content of the Website according to your preferences and optimising the use of the websites,
  2. creating statistics which help us understand how you use our Website,
  3. maintaining your session,
  4. conducting activities aimed at promoting the company and brands related to the company.

More about cookies HERE.

 

Information on LPP’s profile in social networks

We have profiles on social networks: Facebook, Instagram, YouTube, Linkedin (hereinafter “social networks”), where we publish news about our business. The administrators of the social networks record your behaviour on their own using cookies or similar technologies, including whenever you interact with our profiles. The full extent and purposes of the processing of personal data on social networks are determined by their administrators.

When you visit our profiles, we have access to general statistics on information relating to your interests and demographics (such as age, gender, region) generated by the social network administrators. As part of our operation of these profiles, we are fully responsible for the operation of these profiles, the content posted there, the information published by users themselves, including in private messages, and the communication on the indicated social networks.

Facebook and Instagram are administered by Meta Platforms, Inc. of California, USA and Meta Platforms Ireland Ltd.

YouTube is administered by Google Inc. YouTube is administered by Google Inc.

Linkedin is administered by LinkedIn Ireland Unlimited Company based in Ireland, Linkedin Corporation, based in California, USA.

If you have an account on a particular social network site, we have access to your information set as public, on the same basis as other users of that site.

When you visit our profile, the administrator of the social network uses cookies and other similar technologies to monitor your behaviour and actions. This information is collected, among other things, for the purpose of creating site statistics. The statistics contain only anonymised statistical data about users visiting the profile and it is not possible to link them to a specific person. We do not have access to the personal data used by social network sites for the purposes of preparing, inter alia, website statistics.

Thanks to the website statistics generated by the social network, we have information about how you use our profiles and which of the published contents are most popular. With this information, we improve our profiles by matching the published content more accurately to your interests and tastes. The entity responsible for processing your data for the purpose of generating website statistics is the administrator of each of the aforementioned social networks. Accordingly, each controller is obliged to inform you of any issues relating to the processing of your personal data for the purpose of generating site statistics and of the possibility of exercising your privacy rights under the applicable legislation.

You can find more information on data protection in relation to the production of website statistics and the possibility of using them directly in your interactions with social networks at:

  1. Facebook – https://www.facebook.com/legal/terms/information_about_page_insights_data
  2. Instagram – https://privacycenter.instagram.com/policy
  3. YouTube – https://policies.google.com/privacy
  4. Linkedin – https://pl.linkedin.com/legal/privacy-policy

 

Facebook pixel

Our sites include the Facebook Pixel, so that you are shown information, including videos, promoting our activities and services based on the content you are interested in when you visit the Facebook social network or other sites that also use this tool. The transfer of data also enables us to measure the effectiveness of personalized advertisements and to create reports on their content. The data collected is anonymous, we do not collect information about the user’s identity. The data is stored and processed by Facebook, so that a connection to the respective user profile is possible. Facebook uses this data for advertising purposes. More information on privacy protection can be found on Facebook: https://www.facebook.com/about/privacy/. You can deactivate the “Custom Audiences” remarketing function yourself in the ad settings area. You must be logged in to Facebook for this.

 

Google Analytics data protection declaration

Our websites use the web services analytics mechanisms of Google Inc. (“Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA”): Google Analytics and Google Tag Manager. Google Analytics and Google Tag Manager use cookies to analyse the use of websites. Information collected by cookies is transferred to Google servers located in the USA and archived.

If IP anonymisation is activated when using our website, your IP address is truncated by Google. This applies to member states of the European Union and other countries listed in the Agreement on the European Economic Area. Only in exceptional cases is the full IP address sent to a Google server in the USA and truncated there. In this way, the IP address anonymisation function is enabled on our website.

At the request of the website operator, Google uses the information collected to analyse website traffic, to prepare reports on website usage and other services related to website usage. The IP address provided by your browser as part of Google Analytics is not stored with other Google data.

We use Google Analytics to analyse the use of our website in order to optimise the content presented on the website.

 

Opting out of marketing tools

You can manage the cookie settings in your web browser. Your choice may affect the full use of all website features. You can block the storage of data collected by cookies on your use of the website (including your IP address) and the sending of such data to Google, as well as the transmission of such data by Google, by downloading and installing the plug-in available at: https://tools.google.com/dlpage/gaoptout?hl=en.

If you do not want to receive personalised messages about our company, you can apply the following solutions:

  1. make the appropriate settings in your browser by opting out of third-party cookies; for more information see the cookie policy,
  2. deactivate cookies for Conversion Tracking, i.e. set your browser to block cookies from the domain “www.googleadservices.com”, https://www.google.de/settings/ads, these settings will be deleted once the cookies are deleted;
  3. perform a permanent deactivation in your Firefox, Internet Explorer or Google Chrome browser at https://www.google.com/settings/ads/plugin. Please be advised, however, that this may limit the functionality of our website.
  4. perform deactivation of the Facebook remarketing function in the advertising settings area. To do this, you must be logged into Facebook.

More information on Google’s privacy policy is available here: https://policies.google.com/privacy?hl=en.

 

Changes to the Privacy Policy

The services and functions on the Website are subject to change, which means that we may make modifications to the Privacy Policy in the future. We will announce new versions of the document on the Website.

This document is for reference. We updated the above information on 29.06.2023.