1. Who are we and how to find us?
The Controller of personal data is Beso Lux spółka z ograniczoną odpowiedzialnością with its registered office in Łódź (address: ul. Łąkowa 7a/E, 90-562 Łódź, Poland), entered into the Register of Entrepreneurs of the National Court Register kept by the District Court for Łódź-Śródmieście in Łódź, 20th Commercial Division, with KRS number: 0000689756, identified by REGON number: and NIP number: 7292718480 (hereinafter: “Beso Lux”).
You can contact us by e-mail: GDPR@besolux.com or by phone at: +48 505 184 303.
2. Why do we process your personal data?
If you are our subcontractor or supplier, we process your personal data in order to implement the contract between us and you and to fulfil our tax obligations and accounting requirements.
Therefore, the legal basis for the processing of your personal data is Article 6(1)(b) of the GDPR (processing is necessary for the performance of a contract to which the data subject is party or in order to take steps at the request of the data subject prior to entering into a contract), and Article 6(1)(c) of the GDPR (processing is necessary for compliance with a legal obligation to which the controller is subject).
Additionally, the legal basis for our processing of your personal data is Article 6(1)(f) of the GDPR (processing is necessary for the purposes of the legitimate interests pursued by the controller or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data, in particular where the data subject is a child). In this case, the legitimate interest is to ensure that, in case of a dispute with you, we can prove the content of the contract between you and us and that we have implemented it duly.
If you are an employee or representative of our subcontractor or supplier, we process your personal data as otherwise we would not be able to implement the contract between us and your company (the purpose is therefore only to cooperate with your company).
Such processing is necessary for the purposes of the legitimate interests pursued by the controller (Article 6(1)(f) of the GDPR). We hope that you will not consider our actions as an infringement of your rights and freedoms. We are committed to processing only the personal data we need, preferably sent to us directly by you.
3. What kinds of personal data do we process?
We always endeavour to process only those personal data which are necessary and to the strict minimum, and we may process the following personal data concerning you:
if you are our supplier or subcontractor:
if you are our supplier or subcontractor:
4. Whom do we disclose your personal data to?
We disclose your personal data, to the extent required, to government authorities entitled to it by law (such as tax authorities).
Your data may also be disclosed to Luxobeslux Sarl with its registered office in Luxembourg (address 8 Rue de Beggen, L-1220 Luxembourg; VAT EU LU28279037) and to our other contractors (suppliers, subcontractors) to the extent necessary for the implementation of the contract between you and us.
Your personal data are processed in an IT system, parts of which are located in the so-called public cloud, for the purposes of storing data on a server and operating a mail server.
Also, you need to know that in our business we use the support of specialised third parties who may or need to access some of your data – namely those who provide the following services to us:
Some of the operations described above involve the transfer of your personal data to so-called third countries (outside the European Economic Area), where the GDPR does not apply. This is always done, however, on the basis of the legal instruments provided for in the GDPR, which guarantee adequate protection of your rights and freedoms.
5. For how long we will process your personal data?
We will process your personal data for at least as long as necessary for tax purposes.
If we cooperate with you on a permanent basis (e.g. under a framework contract), we will process some of your data necessary for this purpose for the entire period of our cooperation.
Also, if you (or your company) have any after-sales rights (e.g. under warranty or guarantee) under law provisions or the contract, we will need to process your personal data for the lifetime of those rights in order to be able to offer you (or your company) assistance in this regard, if necessary.
6. How do we make it possible for you to exercise your rights?
We are committed to ensuring that you are happy cooperating with us. However, you should be aware that you have a number of rights which will allow you to have your say on how we process your personal data, and in some cases to have such processing ceased. These rights are as follows:
− right of access (governed under Article 15 of the GDPR)
Article 15 - Right of access by the data subject
The data subject shall have the right to obtain from the controller confirmation as to whether or not personal data concerning him or her are being processed, and, where that is the case, access to the personal data and the following information:
2. Where personal data are transferred to a third country or to an international organisation, the data subject shall have the right to be informed of the appropriate safeguards pursuant to Article 46 relating to the transfer.
3. The controller shall provide a copy of the personal data undergoing processing. For any further copies requested by the data subject, the controller may charge a reasonable fee based on administrative costs. Where the data subject makes the request by electronic means, and unless otherwise requested by the data subject, the information shall be provided in a commonly used electronic form.
4. The right to obtain a copy referred to in paragraph 3 shall not adversely affect the rights and freedoms of others.
- right to rectification (governed under Article 16 of the GDPR)
Article 16 - Right to rectification
The data subject shall have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- right to erasure (governed under Article 17 of the GDPR)
Article 17 - Right to erasure (‘right to be forgotten’)
1. The data subject shall have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay and the controller shall have the obligation to erase personal data without undue delay where one of the following grounds applies:
Where the controller has made the personal data public and is obliged pursuant to paragraph 1 to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform controllers which are processing the personal data that the data subject has requested the erasure by such controllers of any links to, or copy or replication of, those personal data. Paragraphs 1 and 2 shall not apply to the extent that processing is necessary:
- right to restriction of processing (governed under Article 18 of the GDPR)
Article 18 - Right to restriction of processing
1. The data subject shall have the right to obtain from the controller restriction of processing where one of the following applies:
2. Where processing has been restricted under paragraph 1, such personal data shall, with the exception of storage, only be processed with the data subject's consent or for the establishment, exercise or defence of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest of the Union or of a Member State.
3. A data subject who has obtained restriction of processing pursuant to paragraph 1 shall be informed by the controller before the restriction of processing is lifted.
- right to object (governed under Article 21 of the GDPR)
Article 21 - Right to object
1. The data subject shall have the right to object, on grounds relating to his or her particular situation, at any time to processing of personal data concerning him or her which is based on point (e) or (f) of Article 6(1), including profiling based on those provisions. The controller shall no longer process the personal data unless the controller 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.
2. Where personal data are processed for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing, which includes profiling to the extent that it is related to such direct marketing.
3. Where the data subject objects to processing for direct marketing purposes, the personal data shall no longer be processed for such purposes.
4. At the latest at the time of the first communication with the data subject, the right referred to in paragraphs 1 and 2 shall be explicitly brought to the attention of the data subject and shall be presented clearly and separately from any other information.
5. In the context of the use of information society services, and notwithstanding Directive 2002/58/EC, the data subject may exercise his or her right to object by automated means using technical specifications.
6. Where personal data are processed for scientific or historical research purposes or statistical purposes pursuant to Article 89(1), the data subject, on grounds relating to his or her particular situation, shall have the right to object to processing of personal data concerning him or her, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- right to data portability (governed under Article 20 of the GDPR)
Article 20 - Right to data portability
1. The data subject shall have the right to receive the personal data concerning him or her, which he or she has provided to a controller, in a structured, commonly used and machine-readable format and have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, where:
2. In exercising his or her right to data portability pursuant to paragraph 1, the data subject shall have the right to have the personal data transmitted directly from one controller to another, where technically feasible.
3. The exercise of the right referred to in paragraph 1 of this Article shall be without prejudice to Article 17. That right shall not apply to processing necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
4. The right referred to in paragraph 1 shall not adversely affect the rights and freedoms of others.
To exercise any of the described rights, please contact us by e-mail to the address we use for contacting you, or to the following address: GDPR@besolux.com. You can also contact us by phone on +48 505 184 303.
7. Right to lodge a complaint with a supervisory authority
Pursuant to Article 77 of the GDPR, you have the right to lodge a complaint with a supervisory authority, in particular in the Member State of your habitual residence, place of work or place of the alleged infringement if you consider that the processing of personal data relating to you infringes the GDPR. In Poland, the supervisory authority is the President of the Personal Data Protection Office – you can lodge a complaint, for instance, by traditional mail to the address: ul. Stawki 2, 00-913 Warszawa, or by e-mail to email@example.com, or you can obtain more detailed information (including current telephone numbers) on the following website: https://uodo.gov.pl/.
If you wish to contact another supervisory authority responsible for the protection of personal data – go to the website of the European Data Protection Board: https://edpb.europa.eu/about-edpb/about-edpb/members_pl
8. Is it necessary for you to provide your data in order to enter into a contract with us?
We collect your personal data to the extent necessary for the conclusion and implementation of the contract. Some of the data are also required in order for us to fulfil our legal obligations (tax regulations, accounting regulations). If you choose not to provide personal data, this will unfortunately prevent the conclusion and implementation of the contract.
9. Where do we get your personal data from?
We only acquire your personal data from you, unless you are an employee or representative of our subcontractors or suppliers, in which case we acquire your data from your company or directly from you, if you contact us directly.
10. Automated processing and profiling
We do not process your data by automated means and we do not carry out profiling within the meaning adopted in the GDPR.