RODO in the company
Complying with the legal obligation regulated by the provision of art. 13 Regulation of the European Parliament and of the Council (EU) 2016/679 of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/WE (hereinafter referred to as "RODO"), COMTEL Group spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Brzesko (hereinafter referred to as the "Company") informs that in order to conduct its operations, the Company collects and uses personal data, including information about the Company's Business Partners.


Personal data administrator

The administrator of personal data (hereinafter: "Administrator") is COMTEL Group spółka z ograniczoną odpowiedzialnością sp.k. with its registered office in Brzesko, address: Plac Kupiecki 2, 32-800 Brzesko, a company entered into the Register of Entrepreneurs of the National Court Register under KRS number 0000564465, for which the register is kept by the District Court for Kraków-Śródmieście in Kraków, XII Commercial Division of the National Court Register, Tax Identification Number: 8691585325, REGON: 850515140.

Contact details

As an Administrator, we have not appointed a data protection officer. In all matters relating to the processing of personal data by the Company and the use of rights related to the processing of data, you can contact via email: or in writing to the Administrator's address with the inscription "Personal data".

The scope of information

The company informs that it processes personal data of persons who are:
  1. contractors of the Company, including potential contractors and / or
  2. partners, employees, statutory representatives, proxies or representatives of such contractors and / or
  3. other persons whose data is processed by the Company in order to perform the contract concluded between the Company and the Business Partners, including invoices and / or bills, and deliveries and / or orders under contracts with the contractors, hereinafter: "Contractors"

Types of personal data

In connection with cooperation between the Contractors and the Company, the Company processes personal data provided by them, such as:
  1. name and surname, company, business address and mailing address (es) and / or
  2. numbers held in the relevant registers (eg NIP or REGON number) and / or
  3. contact details, including e-mail address and / or telephone and / or fax number and / or
  4. position occupied as part of the Contractors' organization
Providing the data specified above is optional, but necessary for the purposes of implementing the contractual relationship and the implementation of cooperation between the Contractor and the Company. The refusal to disclose the data is tantamount to the inability to execute the provisions of the contract by the Company (for example, the refusal to provide data may be associated with the impossibility of implementing the invoice). Your personal data may be downloaded from publicly available sources, such as business registers of CEIDG or KRS, in order to verify the information provided by the Contractors. In this case, the scope of the data processed will be limited to data available publicly in these registers. We may also collect personal data from entities in which you are employed, or whom you represent, or cooperate on the basis of separate agreements. The scope of data processed in this case includes information necessary to perform the contract between the Company and such entity, e.g. information about the termination of the employment relationship of a given entity, change of contact details or change of the official position.

The purpose of processing

Undertaking the necessary actions before concluding the contract, entering into and performing the contract and providing services in accordance with the agreement. For the administrator's marketing purposes, including profiling for marketing and analytical purposes. For marketing purposes, including analytical purposes and profiling of third parties, including the administrator's partners. on the Administrator legal obligations arising from the relevant legal provisions. Alternatively, to claim claims related to the contract / services provided with you. The specific purpose and basis of processing are given in separate information to the data subjects.

The period during which data will be stored

Personal data will be stored until the claims for the contract / provision of services are time-barred or until the obligation to store data resulting from the law, in particular the obligation to keep accounting documents regarding the contract, expires. All data processed for accounting purposes and for tax purposes are processed for 5 years counted from the end of the calendar year in which the tax obligation arose. After the above-mentioned periods, your data is deleted or anonymized. Where we process personal data based on the legitimate interest of the Administrator, personal data will not be processed for a particular purpose if you object to such processing. If we process data based on consent, personal data will be processed until it is withdrawn.

Recipients of data

Personal data may be provided to recipients and other legal entities for the purposes listed in paragraph 6 to the extent to which they are necessary for them to perform the tasks ordered by the Company or if required by the applicable law.
Recipients of personal data can be:
  1. entities processing personal data at the request of the Company, such as IT systems suppliers, IT service providers, entities providing document archiving services and other entities performing tasks for the benefit of the Company related to the continuity of its operation. Processing by the above mentioned the personal data subjects take place only to the extent it is necessary for the Company's operations
  2. state & law enforcement authorities (Police, Prosecutor's Office, Court) or local self-government authorities in connection with the proceedings being conducted and / or
  3. clients, if on the basis of separate agreements it is necessary to provide them with appropriate certificates and conformity certificates;
  4. courier or postal service providers;

Transmission of data outside the European Economic Area

The collected personal data will not be transferred to recipients located in countries outside the European Economic Area (European Union countries and Iceland, Liechtenstein and Norway).

Measures protecting personal data

In order to protect personal data being processed in accordance with art. 32 RODO, the Company has implemented appropriate technical and organizational measures to secure personal data being processed against accidental or unlawful destruction, loss, modification of personal data, unauthorized disclosure of personal data and unauthorized access to personal data. The security measures referred to above have been implemented taking into account the state of the art, implementation costs, processing risks and the nature of personal data, with particular emphasis on sensitive data.

Automated decision-making processes in the field of personal data protection

The personal data processed will not be subject to automated decision-making processes by the Company, including profiling during the performance of the contract between the Company and the Contractor.

The rights of the data subject

You have the right to access your data and the right to demand rectification, deletion and processing restrictions. If the basis for the processing of personal data is the interest of the Administrator, you can object to the processing of personal data. In particular, you have the right to object to the processing for direct marketing purposes, including profiling and for analytical purposes.

To the extent that the basis for the processing of personal data is consent, you have the right to withdraw your consent. Withdrawal of consent does not affect the legality of the processing which was made on the basis of consent before its withdrawal.

To the extent that your data is processed for the purpose of concluding and performing the contract / provision of services or processed on the basis of consent - you also have the right to transfer your personal data. In this situation, you will receive your personal data from the Company in a structured, commonly used format that is machine-readable. You also have the right to lodge a complaint with the competent authority for the protection of personal data.

Providing personal data in connection with the contract / services provided on its basis is voluntary, but necessary for the conclusion and performance of the contract - without entering personal data it is not possible to conclude a contract / provision of services.

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