Protection of personal data of Suppliers

Administrator and Data Protection Officer

The Administrator of your personal data is Alupol Packaging Spółka Akcyjna (43-109 Tychy, ul. Strefowa 4, phone:  +48 32 324 57 00, mail: alupol@grupakety.com), hereinafter referred to as “Alupol”.

You can contact the Data Protection Officer at Alupol in matters concerning the protection of personal data via:

–    E-mail: IOD_AP@grupakety.com,

–    by letter to the following address: Alupol Packaging Spółka Akcyjna (43-109 Tychy, ul. Strefowa 4),

–    by phone: + 48 694 429 337.

Your rights

In connection with the processing of your personal data, you have the following rights:

a) The right to access your personal data;

b) The right to rectify your data;

c) The right to delete your data;

d) The right to limit the processing of your personal data;

e) The right to transfer your data;

f) The right to object. You have the right to object to the processing of your data based on legitimate interests at any time. We will cease processing your data for these purposes unless we can demonstrate that we have compelling legitimate grounds in relation to the data that override your interests, rights and freedoms, or the data is necessary for us to establish, pursue or defend any claims;

g)    The right to withdraw consent. In the case of processing personal data based on your consents, you have the right to withdraw your consent at any time without giving any reason, and without affecting the legality of the processing carried out on the basis of consent before its withdrawal. If you exercise this right, we will cease processing your data for the purpose covered by your prior consent. If you wish to withdraw your consent, please contact the Company directly using the contact details provided above.

If you wish to exercise your rights or obtain additional information, please contact us in writing or by telephone at the above-mentioned contact details of the Data Protection Officer.

If you consider that the processing of your personal data violates the provisions of GDPR you have the right to lodge a complaint to the President of the Office for Personal Data Protection (2 Stawki Street, 00-193 Warsaw).

Purposes, legal basis for collection and duration of personal data processing

1.    If you are an Alupol Contractor (an individual, including a sole proprietor, or a partner in a civil partnership)

If you did not provide us with your personal data directly, the data was collected using public and publicly available sources, such as websites, public records.

The scope of processed data includes:

a)    identification data (name and surname of the persons representing the Contractor, name of the business entity, NIP, REGON),

b)    contact details (e-mail address, telephone number, fax number) and correspondence details (registered office address of the business entity, address for correspondence),

c)     data regarding concluded contracts, financial data, bank account number,

d)    in the case of natural persons not conducting business activity – also the address of residence,

We will process your personal data for the following purposes:

a)    concluding an agreement with us or executing an order, including in connection with your participation in the process of collecting offers, as well as executing and monitoring the performance of the agreement/order that you have concluded with us (hereinafter jointly referred to as the Agreement) – for the period preceding the conclusion of the Agreement and for the period of performance of the Agreement (Article 6 paragraph 1 letter b of the GDPR – conclusion and performance of the Agreement);

b)    archiving to the extent necessary to comply with legal obligations, in particular tax regulations, accounting regulations – for the period resulting from these regulations (legal basis Art. 6 sec. 1 letter c of the GDPR – performance of an obligation imposed by law);

c)     possible establishment and pursuit of claims or defence against claims, including the transfer of rights to receivables – for the duration of the proceedings and the period of limitation of potential claims (legal basis Art. 6(1)(f) GDPR – implementation of the legitimate interest of the controller in the form of pursuing claims and defending against claims related to the Agreement);

d)    verification of the Contractor’s credibility – i.e. implementation of the necessary activities in the form of risk assessment before concluding the Agreement, after its conclusion, during the performance of the Agreement. In pursuing this objective, we may additionally obtain your data from business information registers, business intelligence agencies and other publicly available information sources. The personal data referred to in the previous sentence will relate to the settlement of your obligations and your business activities (legal basis Art. 6 sec. 1 let. f GDPR – implementation of the legitimate interest of the controller), for the period necessary to make such an assessment;

e)    preparing analyses of the results of our business activities for internal purposes – for a period not longer than that indicated in points b) and c) above (legal basis Art. 6 sec. 1 letter f) of the GDPR – implementation of the legitimate interest of the controller in the form of optimisation of the business operations).

2.    In case you are an employee or co-worker of Alupol Contractor

Your personal data have been made available to Alupol by your employer or the person (company) with whom you cooperate in connection with concluding an agreement with Alupol or executing an order, as well as in connection with the execution by Alupol’s Contractor of an agreement or order concluded with us (hereinafter referred to as the Agreement).

We will process the following categories of your personal data:

a)    identifying data (e.g. name, surname),

b)    contact details (e.g. e-mail address, telephone number, fax number),

c)     data regarding: employment with an Alupol Contractor or cooperation with an Alupol Contractor (e.g. company name, position), profession or business activity and participation in a civil partnership, held authorisations necessary to perform the Agreement.

We will process your personal data for the following purposes:

a)   conclusion and performance of the Contract with Alupol Contractor, in particular for purposes such as communication, performance of information obligations, interaction and other obligations under the Contract – for the period prior to the conclusion of the Contract and for the period of performance of the Contract (legal basis Article 6(1)(f) RODO – implementation of the legitimate interest of the administrator in the form of performance of the Agreement with the Contractor);

b)    archiving to the extent necessary to comply with legal obligations, in particular tax regulations, accounting regulations – for the period resulting from these regulations (legal basis Art. 6 sec. 1 letter c of the GDPR – performance of an obligation imposed by law);

c)     possible establishment and pursuit of claims or defence against claims, including the transfer of rights to receivables – for the duration of the proceedings and the period of limitation of potential claims (legal basis Art. 6(1)(f) GDPR – implementation of the legitimate interest of the controller in the form of pursuing claims and defending against claims related to the Agreement);

d)    preparing analyses of the results of our business activities for internal purposes – for a period not longer than that indicated in points b) and c) above (legal basis Art. 6 sec. 1 letter f) of the GDPR – implementation of the legitimate interest of the controller in the form of optimisation of the business operations).

Data recipients

In certain situations, we may transfer your data as it is often necessary to perform the Agreement, or to comply with  obligations arising from legal provisions.

We may transfer your personal data to the following categories of recipients:

a)    courier, transport or postal operators,

b)    banks and payment institutions,

c)     insurers,

d)    trade intelligence agencies, business information offices and credit information offices,

e)    purchasers of receivables,

f)     law firms,

g)    tax offices,

h)    entities acting on our behalf, i.e., subcontractors co-operating with Alupol (e.g., entities operating ICT systems and providing IT services, entities providing us with consulting, advisory, auditing, legal, tax, accounting assistance, document archiving, debt collection),

i)      entities that are part of the group of companies to which we belong (Grupa Kęty S.A. with its registered office in Kęty and companies controlled by it),

j)     state entities and other bodies authorized under the law (including courts, prosecutors, bailiffs, regulatory and supervisory bodies),

to the extent necessary to achieve the purposes for which personal data are processed.

Other information

We do not intend to transfer your data to so-called third countries (i.e. outside the European Economic Area). However, if such a need arises, we can do so, ensuring an adequate level of protection and applying appropriate legal provisions.

Providing personal data is a necessary condition for the execution of the Agreement or taking action before concluding the Agreement. If you do not provide your personal data, it will not be possible to execute the Agreement or take action before its conclusion.

Your personal data are not subject to automated decision-making, including profiling related to automated decision-making.

Joint controllers of personal data 

The joint controllers of your personal data are the companies belonging to the Flexible Packaging Segment of the Grupa Kęty S.A. Capital Group, namely: 

Alupol Packaging S.A. with its registered office in Tychy, ul. Strefowa 4, 43-109 Tychy, KRS 0000357912, phone:  +48 32 324 57 00, e-mail: alupol@grupakety.com;
Alupol Packaging Kęty Sp. z o.o. with its registered office in Kęty, ul. Kościuszki 111, 32-650 Kęty, KRS 0000331243, phone:  +48 33 844 64 33, e-mail: alupol@grupakety.com;
Alupol Films Sp. z o.o. with its registered office in Oświęcim, ul. Gospodarcza 18, 32-600 Oświęcim, KRS 0000535820, phone:  +48 32 324 57 41, e-mail: alupolfilms@grupakety.com.
Data Protection Officer 

In matters relating to the joint control of your personal data, you may contact the Data Protection Officer appointed by the Joint Controllers via: 

– E-mail: IOD_AP@grupakety.com, 

- by letter to the following address: Alupol Packaging Spółka Akcyjna (43-109 Tychy, ul. Strefowa 4), 

– by phone: + 48 694 429 337. 

Common purposes, legal basis for collection and duration of personal data processing 

The Joint Administrators process your personal data for the following purposes: 

1. a) ensuring and improving the work organization of the Joint Controllers as entities of the Flexible Packaging Segment of the Grupa KętyA. Capital Group, reporting and analytical – for the time necessary to perform the tasks of the Joint Controllers or until the person whose personal data is processed objects (legal basis: Article 6, paragraph 1, letter f) of the GDPR – implementation of the legitimate interest of the joint controllers of personal data),
2. b) commercial – for the period preceding the conclusion of the contract/order (hereinafter referred to as the Agreement) and for the period of performance of the Agreement (legal basis: Art. 6 sec. 1 letter b of the GDPR – conclusion and performance of the Agreement),
3. c) marketing – until the data subject objects or withdraws consent (legal basis: Article 6, paragraph 1, letter f) or letter a) of the GDPR – implementation of the legitimate interest of the joint controllers of personal data or consent of the data subject).

Data recipients 

In certain situations, we may transfer your data to the following categories of recipients: 

a)    courier, transport or postal operators, 

b)    banks and payment institutions, 

c)     insurers, 

d)    trade intelligence agencies, business information offices and credit information offices, 

e)    purchasers of receivables, 

f)     law firms, 

g)    tax offices, 

h)    entities acting on our behalf, i.e., subcontractors co-operating with Alupol (e.g., entities operating ICT systems and providing IT services, entities providing us with consulting, advisory, auditing, legal, tax, accounting assistance, document archiving, debt collection), 

i)      entities that are part of the group of companies to which we belong (Grupa Kęty S.A. with its registered office in Kęty and companies controlled by it), 

j)     state entities and other bodies authorized under the law (including courts, prosecutors, bailiffs, regulatory and supervisory bodies), 

to the extent necessary to achieve the purposes for which personal data are processed. 

Your rights 

In connection with the processing of your personal data, you have the following rights: 

1. a) The right to access your personal data,
2. b) The right to rectify your data,
3. c) The right to delete your data,
4. d) The right to limit the processing of your personal data,
5. e) The right to transfer your data,
6. f) The right to object. You have the right to object to the processing of your data based on legitimate interests at any time. We will cease processing your data for these purposes unless we can demonstrate that we have compelling legitimate grounds in relation to the data that override your interests, rights and freedoms, or the data is necessary for us to establish, pursue or defend any,

g)    The right to withdraw consent. In the case of processing personal data based on your consents, you have the right to withdraw your consent at any time without giving any reason, and without affecting the legality of the processing carried out on the basis of consent before its withdrawal. If you exercise this right, we will cease processing your data for the purpose covered by your prior consent. If you wish to withdraw your consent, please contact the Joint Administrator to whom the consent was granted directly using the contact details provided above. 

If you wish to exercise your rights or obtain additional information, please contact us in writing or by telephone at the above-mentioned contact details of the Data Protection Officer. 

If you consider that the processing of your personal data violates the provisions of GDPR you have the right to lodge a complaint to the President of the Office for Personal Data Protection (2 Stawki Street, 00-193 Warsaw). 

Other information 

We do not intend to transfer your data to so-called third countries (i.e. outside the European Economic Area). However, if such a need arises, we can do so, ensuring an adequate level of protection and applying appropriate legal provisions. 

Providing personal data is a necessary condition for taking action before concluding an Agreement with us. 

If you do not provide your personal data, it will not be possible to execute the Agreement or take action before its conclusion. 

Your personal data are not subject to automated decision-making, including profiling related to automated decision-making. 

The substantive content of the arrangements concerning the joint control of your personal data is made available at the request of the data subject sent to the above-mentioned contact details of the Data Protection Officer.