How we process your personal data

Protecting the privacy of persons dealing with us is our top priority. To this end we take the necessary technical and organisational measures to ensure that the way we process personal data not only is in compliance with legal requirements but also reflects best personal data protection standards and practices.

Pursuant to 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) (OJ L 119, p. 1) (“GDPR”), we wish to inform you how personal data are processed by Sendero Kania, Lubaszka, Michalski i Wspólnicy sp.k. (“Sendero KLM”) or by Sendero sp. z o.o.

Clients of Sendero Kania, Lubaszka, Michalski i Wspólnicy sp.k.

The information below concerns the processing of personal data of:

a. our Clients who are natural persons or sole traders (“Individuals”), or
b. employees, associates and other people acting on behalf of our Clients, irrespective of the form of their economic activity (“Client Employees”).

1. You can contact Sendero KLM by phone at +48 (71) 717 80 20, by e-mail at biuro@sendero.pl or by snail mail at the following address: Sendero Kania, Lubaszka, Michalski i Wspólnicy sp.k., ul. Muchoborska 6, 54 – 424 Wrocław.

2. Below we list the purposes and legal grounds under which Sendero KLM processes personal data:
a. conclusion and performance of a contract – pursuant to Article 6(1)(b) GDPR with respect to Individuals, and pursuant to Article 6(1)(f) GDPR with respect to Client Employees, in pursuit of the legitimate interests that Sendero KLM has in concluding and performing contracts through authorised Client Employees;
b. compliance with obligations arising from legislation and decisions of competent authorities (such as the obligation to settle public levies) – pursuant to Article 6(1)(c) GDPR and to relevant laws ansd regulations (including tax regulations) that require Sendero KLM to settle public levies;
c. archiving for the purposes of safekeeping and retention of accounting documents – pursuant to Article 6(1)(c) GDPR and relevant provisions of the Accounting Act;
d. provision of commercial information, such as newsletters, using means of electronic communication, such as e-mail – pursuant to Article 6(1)(a) GDPR in conjunction with Article 10 of the Electronic Services Act [Ustawa o świadczeniu usług drogą elektroniczną] (based on data subjects’ consent);
e. direct marketing other than the provision of commercial information using electronic means or through the use of telecommunications terminal equipment and automated calling systems for direct marketing purposes – pursuant to Article 6(1)(f) GDPR, in pursuit of the legitimate interests that Sendero KLM has in promoting and offering its services;
f. exercise or defence of legal claims in pursuit of legitimate financial interests of Sendero KLM – pursuant to Article 6(1)(f) GDPR.

3. Sendero KLM processes the following types of personal data: first name and surname, telephone number, e-mail address, postal address, Individual’s business name, business name of the firms represented by the Client Employee, NIP.

4. The personal data processed by Sendero KLM are usually obtained directly from Individuals or Client Employees; however, it is sometimes the case that Sendero KLM obtains personal data from other parties with which Individuals or Client Employees cooperate (that is the case where, for example, we are given the contact details of an Individual or Client Employee, and we contact them first).

5. Data may be transmitted to other controllers (courts, offices and institutions), Sendero sp. z o.o., or external providers of business process support services for Sendero KLM (including law firms, ICT companies, accounting firms, courier companies, marketing companies, banks, financial advisors and other advisors).

6. Personal data may be transmitted to third countries, i.e. countries from outside the European Economic Area, or to international organisations. In each such case, if required by law, Sendero KLM shall ensure that appropriate or suitable safeguards are in place for the personal data so transmitted.

7. As a rule, personal data are retained for 3 years, counting from the day the contract is performed. Personal data processed for tax purposes are stored for a period necessary for Sendero KLM to comply with its public obligations (including tax compliance duties) and to submit relevant returns or filings and have them verified by tax authorities. Personal data archived for the purposes of safekeeping and retention of accounting documents are, as a rule, retained for 5 years, counting from the first day of the year following the financial year to which the personal data in question pertain. Where data are processed on grounds of legitimate interests of Sendero KLM, they will be retained at maximum until submission of an effective objection to their processing. Data processed on the basis of consent are processed until the consent is withdrawn. Personal data may be retained for a longer period where the processing thereof is necessary for establishment, exercise or defence of legal claims to the extent required by law.

8. Each data subject has the following rights:
a. right of access – right to obtain information on the data processed and to receive their copies;
b. right to rectification – right to have inaccurate data rectified or incomplete data completed;
c. right to erasure – right to obtain the erasure of data that are no longer necessary in relation to the purposes for which they were collected;
d. right to restriction of processing – right to demand the cessation of personal data processing except for those operations to which the data subject has consented and except for storage until the reasons for the restriction no longer apply;
e. right to data portability – right to demand delivery of data submitted by data subject, in a machine-readable format, to the extent the data are processed under a contract or upon consent;
f. right to lodge a complaint with the competent supervisory authority – right to complain against alleged breach of personal data protection regulations to Polish data protection authority Prezes Urzędu Ochrony Danych Osobowych, address: ul. Stawki 2, 00-193 Warszawa.

9. Data subjects also have the right to object to the processing of their personal data carried out in pursuit of the legitimate interests of Sendero KLM. Sendero KLM shall then no longer process the personal data on that ground unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Irrespective of the legitimate interests, Sendero KLM shall no longer process the personal data if the objection pertains to processing carried out for marketing purposes.

10. Where personal data are provided on the basis of consent, the data subject has the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

11. The provision of personal data is a requirement necessary to conclude a contract. If we are not provided with the personal data required, we will be unable to conclude or perform the contract.

12. Our decisions made in relation to data subjects are not based on automated processing or profiling of personal data.

13. To exercise your rights as a data subject, please call +48 (71) 717 80 20, send an email to dane.osobowe@sendero.pl or send a snail mail to: Dane Osobowe, Sendero Kania, Lubaszka, Michalski i Wspólnicy sp.k., ul. Muchoborska 6, 54 – 424 Wrocław.

Clients of Sendero sp. z o. o.

The information below concerns the processing of personal data of:

a. our Clients who are natural persons or sole traders (“Individuals”), or
b. employees, associates and other people acting on behalf of our Clients, irrespective of the form of their economic activity (“Client Employees”).

1. You can contact Sendero sp. z o. o. by phone at +48 (71) 717 80 20, by e-mail at biuro@sendero.pl or by regular mail at the following address: Sendero sp. z o. o., ul. Muchoborska 6, 54 – 424 Wrocław.

2. Below we list the purposes and legal grounds under which Sendero sp. z o. o. processes personal data:
a. conclusion and performance of a contract – pursuant to Article 6(1)(b) GDPR with respect to Individuals, and pursuant to Article 6(1)(f) GDPR with respect to Client Employees, in pursuit of the legitimate interests that Sendero sp. z o. o. has in concluding and performing contracts through authorised Client Employees;
b. compliance with obligations arising from legislation and decisions of competent authorities (such as the obligation to settle public levies) – pursuant to Article 6(1)(c) GDPR and to relevant laws and regulations (including tax regulations) that require Sendero sp. z o. o. to settle public levies;
c. archiving for the purposes of safekeeping and retention of accounting documents – pursuant to Article 6(1)(c) GDPR and relevant provisions of the Accounting Act;
d. provision of commercial information, such as newsletters, using means of electronic communication, such as e-mail – pursuant to Article 6(1)(a) GDPR in conjunction with Article 10 of the Electronic Services Act [Ustawa o świadczeniu usług drogą elektroniczną](based on data subjects’ consent);
e. direct marketing other than the provision of commercial information using electronic means or through the use of telecommunications terminal equipment and automated calling systems for direct marketing purposes – pursuant to Article 6(1)(f) GDPR, in pursuit of the legitimate interests that Sendero sp. z o. o. has in promoting and offering its services;
f. exercise or defence of legal claims in pursuit of legitimate financial interests of Sendero sp. z o. o. – pursuant to Article 6(1)(f) GDPR.

3. Sendero sp. z o. o. processes the following types of personal data: first name and surname, telephone number, e-mail address, postal address, Individual’s business name, business name of the firms represented by the Client Employee, NIP.

4. The personal data processed by Sendero sp. z o. o. are usually obtained directly from Individuals or Client Employees; however, it is sometimes the case that Sendero sp. z o. o. obtains personal data from other parties with which Individuals or Client Employees cooperate (that is the case where, for example, we are given the contact details of an Individual or Client Employee, and we contact them first).

5. Data may be transmitted to other controllers (courts, offices and institutions), Sendero Kania, Lubaszka, Michalski i Wspólnicy sp. k., or external providers of business process support services for Sendero sp. z o. o. (including law firms, ICT companies, accounting firms, courier companies, marketing companies, banks, financial advisors and other advisors).

6. Personal data may be transmitted to third countries, i.e. countries from outside the European Economic Area, or to international organisations. In each such case, if required by law, Sendero sp. z o. o. shall ensure that appropriate or suitable safeguards are in place for the personal data so transmitted.

7. As a rule, personal data are retained for 3 years, counting from the day the contract is performed. Personal data processed for tax purposes are stored for a period necessary for Sendero sp. z o. o. to comply with its public obligations (including tax compliance duties) and to submit relevant returns or filings and have them verified by tax authorities. Personal data archived for the purposes of safekeeping and retention of accounting documents are, as a rule, retained for 5 years, counting from the first day of the year following the financial year to which the personal data in question pertain. Where data are processed on grounds of legitimate interests of Sendero sp. z o. o., they will be retained at maximum until submission of an effective objection to their processing. Data processed on the basis of consent are processed until the consent is withdrawn. Personal data may be retained for a longer period where the processing thereof is necessary for establishment, exercise or defence of legal claims to the extent required by law.

8. Each data subject has the following rights:
a. right of access – right to obtain information on the data processed and to receive their copies;
b. right to rectification – right to have inaccurate data rectified or incomplete data completed;
c. right to erasure – right to obtain the erasure of data that are no longer necessary in relation to the purposes for which they were collected;
d. right to restriction of processing – right to demand the cessation of personal data processing except for those operations to which the data subject has consented and except for storage until the reasons for the restriction no longer apply;
e. right to data portability – right to demand delivery of data submitted by data subject, in a machine-readable format, to the extent the data are processed under a contract or upon consent;
f. right to lodge a complaint with the competent supervisory authority – right to complain against alleged breach of personal data protection regulations to Polish data protection authority Prezes Urzędu Ochrony Danych Osobowych, address: ul. Stawki 2, 00-193 Warszawa.

9. Data subjects also have the right to object to the processing of their personal data carried out in pursuit of the legitimate interests of Sendero sp. z o. o. Sendero sp. z o. o. shall then no longer process the personal data on that ground unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Irrespective of the legitimate interests, Sendero sp. z o. o. shall no longer process the personal data if the objection pertains to processing carried out for marketing purposes.

10. Where personal data are provided on the basis of consent, the data subject has the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

11. The provision of personal data is a requirement necessary to conclude a contract. If we are not provided with the personal data required, we will be unable to conclude or perform the contract.

12. Our decisions made in relation to data subjects are not based on automated processing or profiling of personal data.

13. To exercise your rights as a data subject, please call +48 (71) 717 80 20, send an email to dane.osobowe@sendero.pl or send a snail mail to: Dane Osobowe, Sendero sp. z o. o., ul. Muchoborska 6, 54 – 424 Wrocław.

Other people

When individuals contact Sendero KLM or Sendero sp. z o.o. (“we”, “us” or “Controllers”) in relation to the business of any of us, we process their personal data, such as in the case of individuals sending us inquiries by email or phone or in the case of candidates for employment (collectively “data subjects”).

Below we provide basic information in connection with the processing of data subjects’ personal data.

1. You can contact with Controllers by phone at +48 (71) 717 80 20, by e-mail at biuro@sendero.pl or by regular mail at the following address: Sendero Kania, Lubaszka, Michalski i Wspólnicy sp.k. or Sendero sp. z o. o., ul. Muchoborska 6, 54 – 424 Wroclaw.

2. The following are the purposes of and grounds for the processing of your personal data – for each of the Controllers:
a. email or regular mail correspondence – pursuant to Article 6(1)(f) GDPR in pursuit of the legitimate interests that each Controller has in managing correspondence addressed to it in connection with its business;
b. telephone contacts – pursuant to Article 6(1)(f) GDPR in pursuit of the interest that each Controller has in resolving the matter inquired about in connection with its business;
c. recruitment for proposed jobs – pursuant to Article 6(1)(c) GDPR or the Labour Code with respect to personal data of persons mentioned therein, and otherwise pursuant to Article 6(1)(a) GDPR, i.e. based on voluntary consent of the candidate;
d. exercise or defence of legal claims in pursuit of legitimate financial interests of each of the Controllers – pursuant to Article 6(1)(f) GDPR.

3. The following are the purposes of and grounds for the processing of your personal data – for both Controllers:
a. provision of commercial information, such as newsletters, using means of electronic communication, such as e-mail – pursuant to Article 6(1)(a) GDPR in conjunction with Article 10 of the Electronic Services Act (based on data subjects’ consent);
b. direct marketing other than the provision of commercial information using electronic means or through the use of telecommunications terminal equipment and automated calling systems for direct marketing purposes – pursuant to Article 6(1)(f) GDPR, in pursuit of the legitimate interests that the Controllers have in promoting and offering their services.

4. Where personal data are collected for the purpose of performing a specific contract or for other purposes related to various activities, each of the Controllers will provide the data subject with a separate personalised data processing notice.

5. Data may be transmitted to other controllers, external providers of recruitment support for the Controllers, ICT companies (for software and hardware), courier companies, and advisory firms, including providers of financial, accounting or marketing support.

6. The Controllers do not transmit personal data to third countries, i.e. countries from outside the European Economic Area, or to international organisations.

7. As a rule, personal data are retained until the purpose for which they have been collected is fulfilled. Where data are processed on grounds of legitimate interests of the Controllers, they will be retained at maximum until submission of an effective objection to their processing. Data processed on the basis of consent are processed until the consent is withdrawn. Personal data collected for recruitment purposes are stored for a maximum of 6 months from submission of application documents. Personal data may be retained for a longer period where the processing thereof is necessary for establishment, exercise or defence of legal claims to the extent required by law.

8. Each data subject has the following rights:
a. right of access – right to obtain information on the data processed and to receive their copies;
b. right to rectification – right to have inaccurate data rectified or incomplete data completed;
c. right to erasure – right to obtain the erasure of data that are no longer necessary in relation to the purposes for which they were collected;
d. right to restriction of processing – right to demand the cessation of personal data processing except for those operations to which the data subject has consented and except for storage until the reasons for the restriction no longer apply;
e. right to data portability – right to demand delivery of data submitted by data subject, in a machine-readable format, to the extent the data are processed under a contract or upon consent;
f. right to lodge a complaint with the competent supervisory authority – right to complain against alleged breach of personal data protection regulations to Polish data protection authority Prezes Urzędu Ochrony Danych Osobowych, address: ul. Stawki 2, 00-193 Warszawa.

9. Data subjects also have the right to object to the processing of their personal data carried out in pursuit of the legitimate interests of Controllers. Controllers shall then no longer process the personal data on that ground unless it demonstrates compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject or for the establishment, exercise or defence of legal claims. Irrespective of the legitimate interests, Controllers shall no longer process the personal data if the objection pertains to processing carried out for marketing purposes.

10. Where personal data are provided on the basis of consent, the data subject has the right to withdraw their consent at any time. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

11. Our decisions made in relation to data subjects are not based on automated processing or profiling of personal data.

12. To exercise your rights as a data subject, please call +48 (71) 717 80 20, send an email to dane.osobowe@sendero.pl or send a snail mail to: Dane Osobowe, Sendero Kania, Lubaszka, Michalski i Wspólnicy sp.k. or Sendero sp. z o.o., ul. Muchoborska 6, 54 – 424 Wrocław.

Informujemy, że nasza strona używa plików cookies w celu świadczenia Państwu usług na najwyższym poziomie. Dalsze korzystanie ze strony oznacza zgodę na ich użycie. Warunki przechowywania lub uzyskiwania dostępu do cookies można zmienić w ustawieniach przeglądarki. Polityka prywatności.