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This Privacy Policy defines the rules for User personal data processing in relation to the Users using the www.contrain.pl website.

The www.contrain.pl website is administered by the following Joint Controllers: Contrain Group Sp. z o.o. with its registered office in Łódź, ul. 3-go Maja 14, 93-408, Contrain Poland Sp. z o.o. ul. 3-go Maja 14, 93-408 Łódź, Contrain Global Sp. z o.o. ul. 3-go Maja 14, 93-408 Łódź and Contrain sp. z o.o., ul. 3-go Maja 14, 93-408 Łódź. Contact us at: kontakt@contrain.pl

The Joint Controllers have appointed the Personal Data Protection Officer, who can be contacted at: iod@contrain.pl

The Contrain Group companies treat protection of customers’ privacy and of their personal data as the fundamental value that contributes to building mutual trust. Therefore, we comply with all relevant personal data protection regulations, and we constantly strive to improve our operations in this respect. Your personal data is processed pursuant to applicable regulations, in particular the Regulation of the European Parliament and Council (EU) 2016/679 of 27 April 2016 on the protection of natural persons in connection with the processing of personal data and the free flow of such data and repealing the Directive 95/46/EC (the “GDPR”) and the Personal Data Protection Act of 10 May 2018 (“the Act”).

1. Personal data controller

The following companies are Joint Controllers of personal data: Contrain Group Sp. z o.o. with its registered office in Łódź, ul. 3-go Maja 14, 93-408, Contrain Poland Sp. z o.o. ul. 3-go Maja 14, 93-408 Łódź, Contrain Global Sp. z o.o. ul. 3-go Maja 14, 93-408 Łódź and Contrain sp. z o.o., ul. 3-go Maja 14, 93-408 Łódź.

The Joint Controllers will pursue the shared data processing goal consisting in conducting marketing activities and providing an opportunity for initial communication with the interested parties, via the company’s website. The entity that will conclude agreements and perform data processing operations that are necessary to meet the objective specified by the Joint Controllers is Contrain Group Sp. z o.o., with its registered office as specified above.

2. What is personal data?

Personal data include all information about a natural person (individual) identified or identifiable through one or more factors specific to their physical, physiological, genetic, mental, economic, cultural or social identity, including a device IP, location data, on-line identifier and information collected through cookies and other similar technology.

3. Personal data processing rules

All personal data are processed by Joint Controllers in line with the following rules:

Diligence and lawfulness, i.e. personal data are processed in good faith, pursuant to correctly identified legal bases under GDPR that are adequate to individual data processing-related operations. The Joint Controllers identify and specify a suitable legal basis for each individual data processing-related operation.
Transparency, i.e. data subjects are provided, in a transparent, approachable and understandable manner, with the following information: who, on which basis, for what purpose and how long will process their data. Moreover, data subjects are informed about: the recipients of their data, their rights and methods to exercise these rights, and also whether the data will be transferred to countries outside the EU, whether the data will be subjected to automated decision-making operations and, if so, what impact this will have on the data subject. The Joint Controllers ensure that their obligation to provide information will be fulfilled:

When data are collected from the data subject – at the time of data collection, at the latest;
When data are collected from a source different than the data subject – within 30 days from the date of data collection, at the latest.

Restricted data collection purpose, i.e. personal data are collected and processed for specific, explicit and legitimate purposes, and they are not further processed in a manner that would be incompatible with such purposes.
Data scope minimisation, i.e. the data are adequate and limited to the purposes that are necessary to achieve the goal for which the data are processed.
Data accuracy, i.e. the data processed are correct, legitimate and, if necessary, they are subject to

Data storage limitations, i.e. the data will be stored in a manner facilitating data subject identification for a period that is not longer than necessary for the data processing purposes.
Integrity and confidentiality, i.e. the data are processed in a manner ensuring adequate data security and, in particular, protection against: accidental or unauthorised loss, alterations, damage or destruction of data. The Personal Data Controller ensures data safety through the implementation of adequate technical and organisational measures. The Joint Controllers have elaborated a personal data protection system taking into account the risks defined in their organisation, to which the processed data are exposed (i.e. a risk-based approach).

4. How are your personal data processed?

4.1. Data entered by the User

If you conclude an agreement with us (by filling in the registration form fields) or you express your consent, you become a User of our website, and Joint Controllers process the personal data you have provided. All necessary detailed information regarding the personal data processing rules is provided in separate privacy clauses that are displayed when the data are being collected.

4.2. Cookies and automatically recorded data

The Joint Controllers employ cookies in order to make the website available to the Users and provide them with information regarding our commercial offering.

Cookies are small text files that may be used by websites in order to allow users to make a more efficient use of the website pages.

On the basis of generally applicable legislation, the Controller (in our case, the Joint Controllers) can store cookies on user’s device if this is necessary to ensure website performance. In order to store all other types of cookies, we need the User’s consent.

You will be asked to express your consent to using cookies other than those that are necessary for the use of the website via a banner displayed on this website. Your consent is not obligatory. You have the option to adjust your settings by specifying that only necessary cookies should be used. You can withdraw your consent at any time by changing your browser settings.

This website uses different types of cookies.

5. When is your personal data processed?

5.1. Filling in website forms (for candidates and other individuals interested in the Contrain Group companies’ services)

All your personal data are processed after you fill in the website forms, thanks to which you can subscribe to our database of candidates or obtain the information you require, before you start working with us. The legal bases for data processing are specified in the privacy clauses each time we collect your data, so that you can read them while filling in the forms.

5.2. Using the website

Your personal data are also processed to create the best possible product offering tailored to your personal needs. Our goal is also to make your visit to the www.contrain.pl website as transparent and enjoyable as possible. Therefore, we process your personal data collected in the form of your email address, cookies or information regarding frequency of your visits to the website and analysis of the services used. Art. 6(1f) of the GDPR constitutes the legal basis for data processing (processing is necessary for the purposes resulting from the legitimate interests pursued by the Controller or by a third party, consisting in providing you with the most attractive website experience possible), unless it is specified otherwise in the regulations mentioned below.

5.3. Providing Joint Controllers’ product offering information – newsletter

If you express your consent to receive information on our current commercial offering, we will be able to send our newsletter to you. In this case, data processing is based on your consent, which is optional and it is not a condition that you have to meet in order to use the website. In this case, your consent is based on Art. 10 of the Act on providing services by electronic means and Art. 6(1a) of the GDPR.

6. Data processing purposes

The purpose of processing your personal data is to make possible initial communication with the Contrain Group companies and run marketing operations addressed to website users, provided they express a separate consent in this respect. The initial communication consists in providing you with forms through which you supply the data we need to establish cooperation. For each form, we separately fulfil our obligations related to provide necessary information, so that you are fully and transparently informed of the applicable personal data processing rules.

7. Systems used to analyse the website and related applications

7.1. General conditions

We strive to design our www.contrain.pl website in the best possible manner. Therefore, to express our constant commitment to implementing quality improvements, we use state-of-the-art marketing tools that enable us to monitor our on-line effectiveness. The network monitoring tools are used to collect the following data:

When and how often you visit our website

Which services provided via apps are most commonly selected

Who uses our website and apps (age, sex, place of residence)

All the above information is aggregate data and we never use it to identify an individual.

Based on this information, we compile statistics that help us answer the following questions:

Which content is particularly attractive to our website users

Which services are of most interest to our users

Which services we should offer to our users

In particular, we utilise data collected via electronic means mentioned in section 4.2 above. They are the basis for creating anonymous user profiles designated with a pseudonym, in which we store data.

7.2. Google Analytics.

This website uses Google Analytics, an on-line analytic service provided by Google Inc. (“Google”), the USA. Google Analytics uses cookies to analyse your use of a website. The information generated by a cookie regarding your use of this website is transmitted to and stored on a Google server. This website uses the IP anonymisation feature which truncates, in advance, the IP addresses of Google users in the Member States of the European Union or in other states being party to the Agreement on the European Economic Area. A full IP address is transmitted to the Google server in the USA and truncated there only in exceptional cases. When commissioned by the owner of this website, Google will use this information to analyse the use of the website in order to develop reports on users’ activity while visiting the website and to provide the website owner with other services relating to the website and Internet use.

The IP address obtained from your browser via Google Analytics will not be merged with other Google data.

You can prevent the storage of cookies by changing your browser settings as required; however, we would like to point out that in this case you may not be able to fully use all the functions of this website. Additionally, you can prevent Google from collecting and processing the data generated by cookies and relating to your use of the website (including your IP address), which also applies to the processing of such data by Google. To this end, you should download and install the browser plug-in available at: https://tools.google.com/dlpage/gaoptout?hl=pl

Third party’s data: Google Dublin, Google Ireland Ltd, Gordon House, Barrow Street, Dublin 4, Ireland, Fax: +353 (1) 436 1001.

Terms and conditions of use: http://www.google.com/analytics/terms/pl.html

Objection against personal data processing:

At any time, you have a right to lodge an objection against collecting and processing your data related to Google site use (including your IP address). To this end, you should download and install the browser plug-in available at: https://tools.google.com/dlpage/gaoptout?hl=en

7.3. Google Ads / Re-marketing

Our website employs the Google Ads re-marketing feature, available from Google Inc, 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA ( “Google”).

The Google Ads re-marketing feature is a function which, after implementing a correct code on the website, enables users to create personalised messages for recipients who previously visited certain pages on the Google website, in order to create advertisements tailored to specified users’ needs. To this end, your browser stores cookies collected from individual sites visited by you via the Google browser. User visit information is collected using cookies which identify a browser installed on your device, however, your personal data are not stored. Obviously, you can also visit our website without saving cookies in your browser. You can restrict or deactivate the feature of cookie collection at any time by downloading and installing the plug-in available at: www.google.com/settings/ads/plugin. For more information on Google Ads and Google’s privacy policy, visit: www.google.com/privacy/ads

7.4. Google Ads / Conversion tracking

The Controller uses the Google Ads service provided by Google Inc. with its registered office in the USA (“Google”) to take advantage of its conversion tracking capability. If a user visits our site via a Google advertisement, Google Ads saves a cookie in the user’s browser to facilitate collecting statistics regarding activities conducted by this user on our site. These cookies cease to be active after 30 days and do not contain any personal data, so they are not used for personal identification purposes. If you visit an advertiser’s website while these cookies are active, Google and the advertiser receive information that the advertisement has been displayed. Each Google Ads client receives a unique cookie. Therefore, these cookies cannot be traced using Ads clients’ websites. The information collected via a conversion cookie is used to generate conversion statistics for Ads advertisers who have opted for using the conversion tracking feature. Customers will receive information on the total number of users who clicked on the advertisement and were redirected to the conversion tracking tag page. However, no information facilitating user identification is provided. You can restrict or deactivate the feature of cookie collection at any time by downloading and installing the plug-in available at: www.google.com/settings/ads/plugin. For more information on Google Ads and Google’s privacy policy, visit: www.google.com/privacy/ads

7.5. Hub Spot

The Controller uses the Hub Spot system provided by Businessweb, and takes advantage of all system capabilities, including the profiling feature. For full information on the system privacy policy, visit: Privacy policy – BusinessWeb

7.6. Facebook Pixel

The Controller uses the Facebook Pixel service to measure advertisement effectiveness based on the analysis of users’ actions taken on the website, as well as for profiling and re-marketing purposes. For detailed information on Faceboook Pixel cookies, visit: Facebook Pixel cookie settings

7.7. Linkedin Insight Tag

The Controller uses the LinkedIn Insight Tag service to run analyses, improve the website experience, and also for profiling and re-marketing purposes. More information on cookies used by LinedIn Insight Tag.

7.8. Call Page

The Controller uses the Call Page service provided by Call Page Sp. z o.o. For full information on the company’s privacy policy, visit: Privacy policy | CallPage

7.9. Chat Bot

The Controller uses the services provided by the Koda Bots company: Chatbots and voicebots | Communication automation system | KODA Bots. For full information on the privacy policy regarding this tool, visit: Privacy policy – Koda Bots

8. Data storage period

As per the applicable legislation, we process your personal data for the period of time that is necessary to achieve the set purposes. After this period, your personal data will be irreversibly deleted or destroyed. The maximum data storage time is 24 months. After this period, cookies are automatically deleted, and a return visit to the Contrain.pl website is the condition for automatic deletion.

Information on the length of the data storage period in relation to the data you provide directly while filling in job applications and contact forms is provided in the privacy clauses which you can consult when providing your data.

9. Privacy Policy amendments

In the case of all issues that are not regulated in this Privacy Policy, the provisions of the Act and the GDPR apply.

All amendments to this Privacy Policy will be communicated via email.

This Privacy Policy applies as of 29.03.2021.