Déclaration de confidentialité des données et cookies
1. GENERAL PROVISIONS
1.2. A user means a natural person using the Service, who is of legal age and has the relevant legal capacity;
1.3. The Service means the full range of services provided electronically by LeasingTeam International Sp. z o.o. Sp. K., a limited liability partnership under Polish law, or by other companies of the Leasingteam group of companies, via the website https://ltinternational.eu/, in accordance with section 2 below.
1.4. Personal data means any information relating to an identified or identifiable natural person. The data subject can be identified, for example, directly or indirectly, in particular by means of association with an identifier (a characteristic) such as first name and surname/name, identification number, location data, online identifier or one or more special characteristics that are an expression of the physical, physiological, genetic, mental, economic, cultural or social identity of this natural person.
1.5. Processing means any operation or set of operations which is performed on the personal data, whether or not by automatic means, such as collection, recording, organization, filing, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
1.6. Users’ personal data is processed in accordance with the applicable regulations, in particular Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data, on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation, hereinafter: GDPR) and the Polish Act of 10 May 2018 on the Protection of Personal Data.
2. LEASINGTEAM GROUP COMPANIES AS JOINT CONTROLLERS
2.1. In order to achieve the business objectives and, in particular, to improve the administrative procedures, as well as financial and accounting processes, and to ensure the highest security standards and quality of the services provided, including customer service and support for contractual partners, the Leasingteam Group companies, as data controllers, determine the purpose and means of processing personal data. For this reason, and considering the capital connections, as well as personnel and organizational connections between the Leasingteam Group companies, the model of joint responsibility for processing personal data, including, among others, user data, was introduced in the Leasingteam Group.
2.3. The Leasingteam Group includes the following companies:
2.3.1. “Leasingteam” sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.2. Leasingteam Professional sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.3. IT Leasingteam sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.4. Go West & Co sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.5. „Leasingteam Provider” sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.6. Finance B2B sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.7. Leasingteam Ousourcing sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.8. Ananke Business Comunication sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.9. BPO Team sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.10. Leasingteam Brand Management sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland))
2.3.11. Onca sp. z o.o. (limited liability company under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.12. LT International Group Sp. z o.o., Sp. K (limited liability partnership under Polish law) with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland),
2.3.13. LeasingTeam GmbH with its registered office at ul. Taśmowa 7, 02-677 Warsaw (Poland).
2.4. The parent company in the joint responsibility processing model is LeasingTeam sp. z o.o. (Joint Controller 1), which exercises control over the processing of personal data, determines the risks of personal data processing and sets appropriate security standards, ensuring appropriate protection of all personal data processed in the LeasingTeam group of companies.
2.5. In order to ensure the security of the users’ personal data, the joint controllers shall take appropriate technical and organizational measures concerning personal data processing security.
3. PURPOSE AND LEGAL BASIS OF THE PROCESSING OF USERS’ PERSONAL DATA
3.1. Personal data of the users is or may be processed:
a) in order to obtain feedback, i.e. to answer the questions asked by users through the contact form and to receive information about the offer of the joint controllers – In this case, the processing of the data by the joint controllers is carried out with the consent of the user (Article 6(1)(a) GDPR);
b) to safeguard the legitimate interests of the joint controllers related to the operation of the service, including for the purpose of analyzing the use of the website at https://ltinternational.eu/ by the users (Article 6(1)(f) GDPR);
c) to safeguard the legitimate interests of the joint controllers, which may include, but not be limited to the investigation, enforcement and defense of claims, counteracting criminal offences and the conduct of investigations related thereto, the conduct of business and the further development of activities, including risk management (Article 6(1)(f) of the GDPR);
d) for the purposes of direct marketing carried out by the joint controllers, including the targeting of services to match the needs of users (including profiling) based on cookies and other similar technologies referred to under item 9 – Processing of data by the joint controllers in this case is based on legitimate interest of the joint controllers (Article 6(1)(f) of the GDPR);
e) for marketing purposes of the joint controllers, implemented in particular through newsletters, based on consent given by the user (Article 6(1)(a) GDPR).
3.2. The provision of personal data in the Service is voluntary, but may be necessary for performing one or more of the services and for achieving the personal data processing purposes listed above under item 3.1, which cannot be achieved by the joint controllers if personal data is not provided.
4. SCOPE OF THE USERS’ PERSONAL DATA PROCESSED
4.1. information about the user provided voluntarily by them via the contact forms included in the service, such as: first name, last name, e-mail address, phone, position/company;
b) information about the user collected by the joint controllers through cookies and other similar technologies (see item 10).
5. RIGHTS AND DUTIES OF THE USER
5.1. The joint controllers have jointly determined that LeasingTeam sp. z o.o. is responsible for enforcing the rights and fulfilling the obligations arising from the GDPR (including, but not limited to, the information obligations referred to in Articles 13 and 14 of the GDPR) in dealings with individuals whose data is processed. Notwithstanding the foregoing, rights granted under the GDPR may be enforced against any of the joint controllers.
5.2. If personal data is processed on the basis of the user’s consent, this consent is voluntary and may be revoked at any time without affecting the lawfulness of the data processing prior to revocation of consent. A declaration of consent shall be revoked by e-mail sent to the e-mail address specified by the joint controllers and indicated under item 5.5.
5.3. The user also has the following rights:
a) right to erasure of their personal data;
b) right to restrict the processing of their personal data;
c) right to access the content of their data and its correction (rectification);
d) the right to receive a copy of their data and its transfer, provided that this right shall not adversely affect the rights and freedoms of other persons (including trade secrets and intellectual property rights) and is implemented to technically feasible extent;
e) the right to object to the processing of their personal data if the processing is based on a legitimate interest of the joint controller or a third party.
5.4. The joint controller, Leasingteam sp. z o.o., respects the rights of the user, subject to the exceptions specified in the provisions of the GDPR.
5.5. In order to exercise the rights referred to under items 5.1 and 5.2, an e-mail must be sent to the address established by the joint controllers, i.e.: firstname.lastname@example.org.
5.6. The user shall have the right to lodge a complaint with the supervisory authority responsible for the processing of personal data if they believe that previous data processing violates the provisions of the GDPR.
6. CUSTOMER’S PERSONAL DATA PROCESSING DURATION
6.1.The joint controllers shall process the user’s personal data in a manner and for the duration necessary to achieve the purposes for which the data was collected.
6.2. Where data is processed:
a) based on the user’s consent, the user’s data will be processed until consent is revoked;
b) in order to ensure compliance with the legal obligations of the joint controllers, the user’s data will be processed for the legally prescribed period;
c) for direct marketing purposes of the joint controllers, including matching services to the needs of users (including profiling), the user’s data will be processed until the user objects to the processing;
d) in order to safeguard other legitimate interests of the joint controllers, the data shall be processed until an objection is considered or the period of limitations for the claims expires.
6.3. Following the end of the processing period, the data is deleted or anonymized.
7. ACTORS AND ENTITIES RECEIVING TRANSFERS OF CUSTOMER’S PERSONAL DATA
7.1. The joint controllers shall provide personal data of the user if they have the relevant legal basis, including, but not limited to, where this is necessary to provide services to the users.
7.2. Users’ personal data may also be provided at the request of government authorities or other bodies and institutions that are authorized to access such data on the basis of applicable legislation, including, but not limited to where this is necessary to ensure the system security of the joint controllers.
7.3. Recipients of the users’ personal data may include, but not be limited to:
7.3.1. actors and entities authorized to receive the user’s data on the basis of the applicable legislation;
7.3.2. actors and entities whose services are used by joint controllers to provide services to users, including, but not limited to:
a) actors and entities providing communication and information systems to the joint controllers or ensuring the maintenance of these systems;
b) contractors who supply and maintain software necessary to provide the service;
c) law firms, consulting firms with which the joint controllers cooperate;
7.3.3. trusted marketing partners of the joint controllers:
a) Google LLC in connection with the use of Google Analytics.
8. TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA))
8.1. Joint controllers shall only transfer personal data outside the European Economic Area (EEA) if this is necessary and an adequate level of protection is ensured, in particular by:
a) cooperation with processors in the states for which a corresponding decision has been issued by the European Commission;
b) application of standard contractual clauses issued by the European Commission;
c) application of binding internal data protection rules adopted by the competent supervisory authority.
8.2. Where applicable, the controller shall inform of any intention to transfer personal data outside the European Economic Area at the moment of collecting such data. Upon the user’s request, the joint controller, Leasingteam sp. z o.o., shall provide the user with a copy of its data transferred outside the EEA.
9. COOKIES AND OTHER SIMILAR TECHNOLOGIES
9.1. In accordance with the common practice of most websites, personal data of the user may be automatically collected during the use of the service through cookies, the Google Analytics system and the HotJar analysis tool provided by Hotjar Ltd. through the system log files of the Service.
9.2. The cookies placed on the user’s terminal device are used to identify the users and to provide the joint controllers with statistical data on their use patterns, the users’ activity and the way in which the service is used. Among other things, they allow content and services to be tailored to user preferences.
9.3. The service uses session cookies, which are automatically deleted each time the browser window is closed, as well as permanent cookies, which are stored for a certain period of time (specified in the file parameters of the cookies or until they are deleted by the user) on the terminal devices through which the Customer uses the Website or the Online Shop.
9.4. The following types of cookies are placed on the user’s device:
a) security cookies;
b) cookies that can be used to collect information about the way in which the services are used;
c) cookies that allow saving the user’s settings and personalization of the user interface;
d) cookies that allow to provide content tailored to the user’s preferences and interests.
9.5. The joint controllers lawfully process data on the number (including the IP) and type of the user’s terminal device, as well as the duration of the user’s connection to the service and other operational data on the user’s activity on the website, including their preferences. The data described is processed for technical purposes to adapt the service to the needs of users, as well as to collect general statistical data on the functioning of the service and for the purpose of personalizing the content provided to the user.
9.6. The user can change the cookie settings themselves at any time and determine the conditions for storage and, via the browser settings, access the user’s terminal device by using cookies. These settings can be changed so that the automatic storage of cookies is blocked in the browser settings or the user is informed in each case about the placement of a cookie on their terminal device.
9.7. The user may delete cookies at any time using the available functions in their web browser. However, the controller expressly points out that this may result in limited availability of the functions provided in the service.
9.8. The joint controllers also use the Google Analytics system, a tracking tool that serves to analyze website traffic (web analytics) and provides insight into the movement of personal data and users’ location data. Google Analytics is used to compile statistics and reports on the functioning of the service and to personalize the content of the displayed advertisements. The detailed principles that govern the processing of data by Google LCC and rules for objecting to cookies placed by Google LCC are available at the address: www.google.com/policies/privacy/partners/.
9.9. The user’s activity in the service, including their personal data, is registered in system logs (log files in which all process events and actions are stored chronologically on the computer system used by the joint controllers to provide the services). The information collected in the log files is processed primarily for purposes related to the provision of the services. The joint controllers also process this information for technical and administrative purposes, to ensure the security of the information system and for the administration of this system, as well as for analysis and statistical purposes – within this scope, the legitimate interest of the controller forms the legal basis for the processing (Article 6(1)(f) GDPR).
9.10. The joint controllers also use the analysis tool HotJar (or a similar tool with identical functionality), which is used to analyze the user’s movements on the web pages (including sub-pages) of the service with the purpose to asses the user’s behavior when visiting the website and using the page functions. When using HotJar or a similar tool with identical functionality, no personal data of the user is collected.
10. FINAL PROVISIONS