Privacy Policy

GDPR is the General Data Protection Regulation (Regulation of the European Parliament and of the Council (EU) of April 27, 2016, 2016/679), which regulates the protection of personal data of natural persons within the European Union.

The purpose of GDPR is to strengthen and unify the rules for the protection of personal data within the European Union.

Taking care of the personal data of the individuals we cooperate with, we have prepared this Privacy Policy. Its purpose is to provide information on what personal data we collect, for what purposes, how we use it, and who we are. It also aims to outline the rights you have regarding the processing of your personal data by us.

This Privacy Policy does not apply to the processing of personal data of employees and collaborators.

WHO IS THE DATA CONTROLLER?

We kindly inform you that the controller of your personal data is:
AIRPRESS POLAND Limited Liability Company
ul. Rynkowa 156, 62-081 Przeźmierowo, Poland
KRS 0000560350 | NIP 8522376978 | REGON 812551711
hereinafter referred to as the "Data Controller."

Contact regarding personal data protection is possible:

via email: info@airpress.mt or
by post: AIRPRESS POLAND Limited Liability Company | Customer Service Office | ul. Rynkowa 156, 62-081 Przeźmierowo, Poland

with the note "GDPR".

DATA PROTECTION OFFICER

We have not appointed a Data Protection Officer.

WHAT ARE THE PURPOSES AND LEGAL BASIS FOR PROCESSING PERSONAL DATA?

In order to provide services in accordance with the scope of our business, the Data Controller processes your personal data — for various purposes, but always in compliance with the law.

We process personal data of our:

clients, contractors;
representatives of clients/contractors;
partners – B2B Airpress, distributors;
persons corresponding with us;
users of the website and social media platforms such as Facebook, Instagram;
other individuals who contact us in any way.

To the extent that we receive personal data from you in connection with the use of the services we provide, but also during contact with us, your data will always be processed in accordance with the General Data Protection Regulation (Regulation of the European Parliament and the Council (EU) of April 27, 2016, 2016/679) and applicable national laws.

Below, you will find the specified purposes for processing personal data along with their legal bases:

A. In order to take actions at your request prior to entering into a contract for the provision of services in accordance with the scope of our business, as well as to establish business relationships — purchases, we process the following personal data:
Name and surname, company name, PESEL number, residential address, company headquarters, correspondence address, email address, phone number, NIP number, REGON number, website address, information contained in public registers, bank account number, IP address, and other information you provide to us, personal data of employees: first name, last name, contact details, position, and other personal data included in the documentation you provide to us;
the legal basis for such data processing is:

art. 6 sec. 1 letter b of the GDPR (necessary for the performance of a contract), which allows processing personal data if they are necessary to perform a contract or to take steps towards entering into a contract;
art. 6 sec. 1 letter f of the GDPR (legitimate interest of the data controller) when processing personal data of individuals other than the other party to the future contract, e.g. individuals acting on behalf of the contractor.

B. In order to conclude and perform the contract, i.e. to provide our services, we process the following personal data:
Name and surname, company name, PESEL number, date of birth, residential address, company headquarters, correspondence address, email address, phone number, NIP number, REGON number, website address, information contained in public registers, bank account number, IP address, and other information you provide to us; personal data of employees: first name, last name, contact details, position, and other personal data included in the documentation you provide to us;
The legal basis for such data processing is:

art. 6 sec. 1 letter b of the GDPR (necessary for the performance of the contract), which allows processing personal data if it is necessary to perform the contract or take actions aimed at entering into a contract between us.

C. In order to fulfill our legal obligations, e.g., issuing VAT invoices, accounting documents, and performing tax settlements, we process the following personal data:
Name and surname, company name, PESEL number, date of birth, residential address, company headquarters, correspondence address, email address, phone number, NIP number, REGON number, bank account number, REGON number, licenses, concessions, information contained in public registers, personal data of employees: first name, last name, contact details, position, and other information you provide to us;
The legal basis for such data processing is:

art. 6 sec. 1 letter c of the GDPR (legal obligation), which allows processing personal data if such processing is necessary to fulfill the Data Controller’s legal obligations.

D. In order to address matters submitted directly to the Data Controller, e.g., processing complaints, grievances, requests, we process the following personal data:
Name and surname, company name, PESEL number, date of birth, residential address, company headquarters, correspondence address, email address, phone number, NIP number, REGON number, bank account number, REGON number, website address, information contained in public registers, personal data of employees: first name, last name, contact details, position, and other information you provide to us;
The legal basis for such data processing is:

art. 6 sec. 1 letter a of the GDPR (voluntary consent), which allows processing personal data based on freely given consent;
art. 6 sec. 1 letter b of the GDPR (necessary for the performance of the contract), which allows processing personal data if it is necessary to perform the contract;
art. 6 sec. 1 letter f of the GDPR (legitimate interest of the data controller), which allows us to maintain the highest quality of our services.

E. In order to provide you with information related to the execution of the contract between us, e.g., when you complete our Service Form, we process the following personal data:
Name and surname, company name, PESEL number, date of birth, residential address, company headquarters, correspondence address, email address, phone number, NIP number, REGON number, bank account number, and other information you provide to us;
The legal basis for such data processing is:

art. 6 sec. 1 letter a of the GDPR (voluntary consent), which allows processing personal data based on freely given consent;
art. 6 sec. 1 letter b of the GDPR (necessary for the performance of the contract), which allows processing personal data if it is necessary to perform the contract or take actions aimed at entering into a contract or establishing cooperation between us;
art. 6 sec. 1 letter f of the GDPR (legitimate interest of the data controller), which allows us to maintain the highest quality of our services.

F. In order to establish, defend, and pursue claims, we process the following personal data:
Name and surname, company name, PESEL number, date of birth, residential address, company headquarters, correspondence address, email address, phone number, NIP number, REGON number, bank account number, and other information you provide to us;
The legal basis for such data processing is:

art. 6 sec. 1 letter f of the GDPR (legitimate interest), which allows processing personal data if the Data Controller pursues its legitimate interest - in this case, the Data Controller's interest is to have personal data that allows for the determination, pursuit, or defense against claims, including those of clients/contractors and third parties.

G. In order to store unanswered offers/requests, we process the following personal data:
Name and surname, company name, email address, phone number, or other data you provided to us;
It may happen that you decide to use our services after some time from receiving our offer,
The legal basis for such data processing is:

art. 6 sec. 1 letter f of the GDPR (legitimate interest), which allows processing personal data if the Data Controller pursues its legitimate interest - in this case, the Data Controller's interest is to allow you to take advantage of our services for a specified period without the need to repeat the offer.

H. For archival and evidential purposes, we process the following personal data:
First name(s) and surname, company name, PESEL number, date of birth, residential address, company headquarters, correspondence address, email address, phone number, NIP number, REGON number, bank account number;
The legal basis for such data processing is:

art. 6 sec. 1 letter f of the GDPR (legitimate interest), which allows processing personal data if the Data Controller pursues its legitimate interest - in this case, the Data Controller's interest is to have personal data that can prove certain facts related to the execution of the contract, e.g., when requested by a public authority;
art. 6 sec. 1 letter c of the GDPR (legal obligation), which allows processing personal data if such processing is necessary to fulfill the obligations resulting from the law.

I. For administering the website www.airpress.mt (automatically recording the following data in server logs each time you visit our site) and our online store, we may process personal data such as:
Shipping details: name and surname, company name, email, phone number, shipping address, NIP number
IP address, server date and time, information about the web browser, operating system information,
The legal basis for such data processing is:

art. 6 sec. 1 letter a of the GDPR (voluntary consent), which allows processing personal data based on freely given consent;
art. 6 sec. 1 letter c of the GDPR (legal obligation), which allows processing personal data if such processing is necessary to fulfill the Data Controller’s obligations resulting from the law;
art. 6 sec. 1 letter f of the GDPR (legitimate interest), which allows processing personal data if the Data Controller pursues its legitimate interest - in this case, the Data Controller’s interest is to have the ability to manage the website and the online store.

J. For direct marketing, we process the following data:
Name and surname, company name, email address, phone number, correspondence address, data contained in public registers, e.g., KRS, REGON, CEIDG, or other data you provided to us;
The legal basis for such data processing is:

art. 6 sec. 1 letter a of the GDPR (voluntary consent), which allows processing personal data based on freely given consent;
art. 6 sec. 1 letter f of the GDPR (legitimate interest), which allows processing personal data if the Data Controller pursues its legitimate interest, e.g., sending offers regarding current promotions, products, and services.

K. For analytical purposes, creating customer databases, and developing marketing strategies and company development purposes, we process the following data:
Name and surname, company name, email address, phone number, correspondence address, data contained in public registers such as KRS, REGON, CEIDG, or other data you provided to us;
The legal basis for such data processing is:

art. 6 sec. 1 letter a of the GDPR (voluntary consent), which allows processing personal data based on freely given consent;
art. 6 sec. 1 letter f of the GDPR (legitimate interest), which allows the provided information to be used also for analytical purposes, creating customer databases, developing marketing strategies, and company development purposes.

Google Privacy Policy
We inform you that data processing for the purpose of optimizing display and measuring the effectiveness of marketing actions is carried out in accordance with Google's privacy policy and using technologies employed by Google. You can read more on this topic here.

HOW TO EXERCISE YOUR RIGHT TO WITHDRAW CONSENT

1. If personal data processing is based on your consent, you can withdraw this consent at any time, at your discretion.

2. If you would like to withdraw your consent for the processing of personal data, you can do so by:

a) sending a letter directly to the Data Controller at the following address: AIRPRESS POLSKA Spółka z ograniczoną odpowiedzialnością | Customer Service Office | ul. Rynkowa 156, 62-081 Przeźmierowo
b) sending an email to: info@airpress.mt with the subject "RODO".
c) using the registration form: withdraw marketing consent

3. If the processing of your personal data was based on consent, its withdrawal does not affect the lawfulness of processing up until that moment. In other words, until the consent is withdrawn, we have the right to process your personal data, and its withdrawal does not affect the lawfulness of the processing that took place before.

REQUIREMENT TO PROVIDE PERSONAL DATA

1. Providing any personal data is voluntary and depends on your decision. However, in some cases, providing certain personal data is necessary to meet your expectations regarding the service provided by the Data Controller.

2. To receive a commercial offer, it is necessary to provide an email address — without it, we are unable to meet your expectations and maintain the highest quality of service, which is very important to us.

DO WE ENGAGE IN AUTOMATED DECISION-MAKING AND PROFILING?

We inform you that we do not engage in automated decision-making, including profiling.

WHOM CAN WE SHARE YOUR PERSONAL DATA WITH?

1. We may share your data with:

our employees and collaborators who need access to the data to fulfill our obligations or perform actions on your behalf;
our distributors and partners with whom we collaborate.

2. Like most businesses, we also rely on other entities to assist in our operations, which may require sharing personal data. Therefore, when necessary, we share your personal data with the following recipients:

entities providing marketing services for us, organizing training, events, fairs;
entities handling our IT and telecommunication systems;
entities supplying us with telecommunication systems that we use daily;
entities engaged in payment activities (banks, payment institutions);
entities engaged in credit activities (banks), leasing;
entities engaged in insurance activities;
entities engaged in postal, courier, and transport services;
research agencies/institutes acting on our behalf;
entities acquiring receivables;
entities providing advisory, consulting, audit, legal, and tax services for us.

3. Additionally, it may happen that, based on relevant legal provisions or decisions from competent authorities, we may be required to share your personal data with other entities, whether public or private, such as the Social Insurance Institution, the Tax Office, the National Revenue Administration, etc.

Therefore, it is very difficult for us to predict who may request access to your personal data. However, we ensure that each case of personal data request is thoroughly and carefully analyzed to avoid accidentally disclosing information to unauthorized individuals.

DO WE SHARE YOUR PERSONAL DATA WITH THIRD COUNTRIES?

We kindly inform you that your personal data is not transferred to Third Countries, that is, outside the European Economic Area.

HOW LONG CAN WE STORE YOUR PERSONAL DATA?

1. In accordance with applicable law, we process your personal data for the period necessary to achieve the intended purpose. After this period, your personal data will be irreversibly deleted or destroyed.

2. Regarding specific periods for the processing of personal data, we kindly inform you that we process personal data for the following periods:

For the duration of the contract, but also after its termination, not exceeding 6 years — for personal data processed for the purpose of concluding and performing the contract;
Up to 10 years — for personal data processed to establish, pursue, or defend claims, but no longer than required by applicable law;
3 years — for personal data collected in connection with offering a proposal, but where the contract was not immediately concluded;
5 years — for personal data related to fulfilling tax obligations, e.g., storing invoices, receipts;
Until consent is withdrawn or the processing purpose is achieved, but no longer than 3 years — for personal data processed based on consent;
Until an objection is effectively raised or the processing purpose is achieved, but no longer than 3 years — for personal data processed based on the legitimate interest of the Administrator or for marketing purposes;
Until outdated or no longer useful, but no longer than 5 years — for personal data processed primarily for the purposes of cookie use and website administration.

3. The periods in years are counted from the end of the year in which we began processing personal data to streamline the process of deleting or destroying personal data. Separate counting of the period for each event would involve significant organizational and technical difficulties, as well as substantial financial costs. Therefore, setting a single deletion or destruction date allows us to manage this process more efficiently.

4. Right to be forgotten:
Of course, if you exercise your right to be forgotten, such cases are considered individually.

WHAT RIGHTS DO YOU HAVE?

1. We kindly inform you that you have the right to:

Right to access the content of your personal data – that is, to obtain information about the purpose and manner of processing your personal data, as well as a copy of the data.
Right to rectification of data – that is, to correct data when they are incorrect, changed, or outdated.
Right to partial or full deletion of data ("Right to be forgotten") – that is, to delete data processed without a legal basis.
Right to restriction of processing – that is, to restrict processing to storage only.
Right to data portability – that is, to obtain your personal data that you provided to us or to indicate another administrator to whom we should transfer them, provided it is technically possible.
Right to object to the processing of personal data which is provided voluntarily – including for direct marketing purposes.
Right to withdraw consent – you can withdraw any consent you have given at any time. Please note that from the moment you submit your request, we will no longer process your data for the specified purpose, but we have the right to process your data until consent is withdrawn.

2. We respect your rights under data protection regulations and strive to facilitate their implementation to the greatest extent possible.

3. Please note that the rights listed are not absolute, and therefore, in some situations, we may lawfully refuse to fulfill your request. However, if we refuse to fulfill your request, it will be after a thorough analysis and only in cases where the refusal is necessary.

4. Regarding the right to object, we explain that you have the right to object at any time to the processing of personal data based on the legitimate interest of the Data Administrator (listed in point 3 of this Privacy Policy) due to your specific situation.
However, please note that according to regulations, we may refuse to acknowledge the objection if we can demonstrate that:

There are legally justified grounds for processing that override your interests, rights, and freedoms, or;
There are grounds to establish, pursue, or defend claims.

5. Additionally, at any time, you can object to the processing of your personal data for marketing purposes. In such a case, upon receiving the objection, we will cease processing for this purpose.

6. You can exercise your rights by:

a) Sending a letter directly to the Data Administrator at the address: AIRPRESS POLSKA Spółka z o.o. | Customer Service Office | ul. Rynkowa 156, 62-081 Przeźmierowo
b) Sending an email to: info@airpress.mt

with the note "RODO"

YOU HAVE THE RIGHT TO LODGE A COMPLAINT WITH THE PERSONAL DATA PROTECTION OFFICE

If you believe that your personal data is being processed unlawfully, you can lodge a complaint with:

Personal Data Protection Office
ul. Stawki 2, 00-193 Warsaw

FINAL PROVISIONS

1. In matters not regulated by this Privacy Policy, the provisions regarding the protection of personal data apply, including but not limited to:

GDPR: General Data Protection Regulation (Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016);
Act of May 10, 2018 on the Protection of Personal Data;
Act of February 21, 2019 on amending certain acts in connection with ensuring the application of Regulation (EU) 2016/679 of the European Parliament and the Council of April 27, 2016, on the protection of natural persons regarding the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

2. You will be notified by email or through a notification on our website about any changes made to this Privacy Policy: www.airpress.mt

3. This Privacy Policy is effective as of November 7, 2019, and supersedes the previous version.

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