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VECTOR | BE ABLE

PRIVACY POLICY OF VECTOR GROUP

 1. GENERAL INFORMATION

This policy contains information we are required to provide when collecting your personal data through the website of one of the entities belonging to VECTOR Group or in any other form.

We make every effort to ensure that your personal data is:

  • processed pursuant to the law (in particular to the GDPR), fairly and in a manner that is transparent for You (“lawfulness, fairness and transparency”);
  • collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (“purpose limitation”);
  • adequate, relevant and limited to what is necessary for the purposes for which they are processed (“data minimisation”);
  • accurate and, if necessary, kept up to date (“accuracy”);
  • kept in a form which permits your identification for no longer than it is necessary for the purposes for which the data is processed (“storage limitation”);
  • processed in a manner that ensures adequate security of personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (“integrity and confidentiality”).

2. DEFINITIONS

VECTOR Group, We – means the following entities jointly:

  • VECTOR sp. z o.o. with its registered office in Gdynia, ul. Krzemowa 6, entered in the Register of Entrepreneurs kept by the District Court Gdańsk-Północ in Gdańsk, 8th Commercial Division of the National Court Register, under KRS no. 0000077848, NIP [Tax Identification Number]: 5840152246 | Share capital: PLN 66,877,000
  • VECTOR TECH SOLUTIONS sp. z o.o. with its registered office in Gdynia, ul. Krzemowa 6, entered in the Register of Entrepreneurs kept by the District Court Gdańsk-Północ in Gdańsk, 8th Commercial Division of the National Court Register, under KRS no. 0000589935, NIP: 9581671366 | Share capital: PLN 2,480,000
  • VECTOR SMART DATA sp. z o.o. with its registered office in Gdynia, ul. Krzemowa 6, entered in the Register of Entrepreneurs kept by the District Court Gdańsk-Północ in Gdańsk, 8th Commercial Division of the National Court Register, under KRS no. 0000589997, NIP: 9581671343 | Share capital: PLN 2,480,000
  • VECTOR TECHNOLOGIES S.A. with its registered office in Gdynia, ul Krzemowa 6, entered in the Register of Entrepreneurs kept by the District Court Gdańsk-Północ in Gdańsk, 8th Commercial Division of the National Court Register, under KRS no. 0000591577, NIP: 9581671449 | Share capital: PLN 5,050,000 (fully paid up).
  • VECTOR BLUE HUB S.A. with its registered office in Gdynia, ul 6 Krzemowa, entered in the Register of Entrepreneurs kept by the District Court Gdańsk-Północ in Gdańsk, 7th Commercial Division of the National Court Register, under KRS no. 0000921553, NIP PL9581719009 l Shared capital PLN 1 100 000,00 (fully paid up).

 The GDPR – Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation).

The Website – the website of the entity belonging to VECTOR Group.

You – a person who has provided VECTOR Group with his or her personal data for a specified purpose, using the contact form available on the Website by e-mail or in any other form.

3. WHO IS THE CONTROLLER OF YOUR DATA AND HOW CAN YOU CONTACT US?

The Controllers of your personal data are the entities of VECTOR Group. In the case of providing personal data in accordance with point 4.D., the Controller of your personal data is the entity from the VECTOR Group with which the contract was concluded.

If You need to contact us in matters related to the protection of your personal data, please use one of the following forms:

1.by sending an e-mail to the following address: [email protected]
2. by sending a letter to the following address:

VECTOR Sp. z o.o.
Krzemowa 6
81-577 Gdynia, Poland

4. WHAT HAPPENS TO YOUR PERSONAL DATA FROM COLLECTION TO DELETION?

A. WHEN YOU REQUEST FOR A QUOTE OR ASK US TO CONTACT YOU IN COMMERCIAL MATTERS

What data do we collect? To replay to your request for a quote we only need the e-mail address You have provided us with. If You provide other data that might be necessary or useful to handle your request for a quote, e.g. your identification data (first and last name), contact details (correspondence address, telephone number), the data will also be process by us.

Why do we process the data? To provide You with the commercial information You requested from us.

What is the legal basis we process your data on? We process your data to take steps at your request prior to entering into a purchase agreement for goods or services.

How long will we process your data? Your data will be processed until You abandon interest in our offer, after we have replayed to your questions.

Who do we share your data with? Apart from our employees and associates, we do not make the data available to anyone, except where this is necessary for the purpose for which such data is collected, e.g. to entrust the data to the email provider.

 B. WHEN YOU GRANT YOUR CONSENT FOR MARKETING PURPOSES

What data do we collect? For marketing purposes we collect data which allow us to communicate with You through various channels of communication that we consider to be the most effective and adequate for the type of marketing information that we send. The data includes: your first name, family name, company You represent, your position, phone number and business e-mail address.

Why do we process it? In order to provide You with current marketing information regarding VECTOR Group.

What is the legal basis we process your data on? We process your data on the basis of your explicit consent granted by ticking the relevant box before providing us with the data.

How long will we process your data? Your data will be processed until You withdraw your consent. However, the withdrawal of consent does not affect the lawfulness of processing based on the consent before its withdrawal.

Who do we share your data with? Apart from our employees and associates, we do not make the data available to anyone, except for the entity providing us with electronic mail and hosting services, but such access is limited to the data storage on a server, or the entity performing marketing activities at our request, which has concluded a data processing agreement with us.

What forms of marketing do we use? The marketing forms we use include e.g. newsletters, free eBooks, free-of-charge industry events.

 C. WHEN YOU REGISTER FOR THE EVENT WE ORGANISE

What data do we collect? When You provide your personal data in order to participate in the event that we organise, this data includes: first name, family name, name of the company You represent, your position in the company, phone number and business e-mail address.

Why do we process the data? To contact You in any matters related to the event we organise, in particular with regard to organisational activities – creating a list of participants, sending materials before and after the event, informing about any changes to the agenda, creating individual signs (badges), etc.

What is the legal basis we process your data on? We process your data on the basis of your explicit consent granted by ticking the relevant box before providing us with your data, or in any other form accepted by rules of procedure for a given event. Refusal to give your consent or its withdrawal before the event will prevent You from participating in this event.

How long will we process your data? Your data will be processed for the purpose for which it was provided, i.e. until the event in which You participate has been completed, and any activities related to this event, conducted after the event, have been completed.

Who do we share your data with? Apart from our employees and associates, we do not make the data available to anyone, except for the entity providing us with electronic mail and hosting services, but such access is limited to the data storage on a server. If we organise an event in cooperation with third parties (e.g. hotels, conference rooms lessors, etc.), we may also transfer your personal data to them, but only for the purposes related to your participation in the event.

Can we process your data provided at registration for the event for other purposes? The rules of procedure for a given event (in particular the event that is free of charge) may provide that registration for the event is conditioned upon granting a separate explicit consent for contact for marketing purposes. In such the case, the rules described in point B above will also apply.

D. WHEN YOU CONTACT US IN CONNECTION WITH THE EXERCISING RIGHTS OR OBLIGATIONS ARISING FROM THE CONTRACT TO WHICH YOU ARE A PARTY OR WHEN YOU ARE ACTING ON BEHALF OF A PARTY OF SUCH CONTRACT

What data do we collect? When you exercising rights or obligations arising from the contract concluded with us, we collect data that is necessary for the performance of this contract, such as: first name, family name, name of the company You represent, your position in the company, phone number and business e-mail address.

Why do we process it? In order to properly perform the contract (e.g. fulfillment of warranty claims), comply with legal obligations resulting from generally applicable provisions of law and to execute of legitimate interests, such as correspondence in writing, by e-mail and telephone conversations, the possibility of establishing or to assert and defense against claims arising out of contract .

What is the legal basis we process your data on? We process your data on the basis of Article 6 (1) (b), c) and (f) of the GDPR.

How long will we process your data? Your data will be processed for the duration of the contract as well as for the period of limitation claims arising from it. After this period, the data will only be processed to the extent and for the time required by law.

Who do we share your data with? Your data can be transferred to our employees, co-workers, subcontractors and also to entities providing services relating to current activities.

5. WHAT ARE YOUR RIGHTS WITH REGARD TO THE PROCESSING OF YOUR PERSONAL DATA?

The GDPR gives You a number of rights with regard to the processing of your personal data. They have been briefly described below.

Right to request access to your personal data

You have the right to confirm that we process your personal data, and if so, You have the right to access the data and to obtain the following information:
a) the purposes of processing;
b) the categories of personal data concerned;
c) the information on recipients or categories of recipients to whom your personal data have been or will be disclosed, in particular the recipients in third countries or international organisations;
d) where possible, the envisaged period for storing your personal data and, if this is not possible, the criteria for determining that period;
e) the information about the right to request rectification, erasure or restriction of the processing of your personal data, and to object to such processing;
f) the information on the right to lodge a complaint with the supervisory authority;
g) if the personal data has not been obtained from the data subject – any information available about the date source;
h) the information on automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR, and – at least in these cases – the significant information on the principles of the decision-making, as well as on the significance and envisaged consequences of such processing for the data subject.

If You request access to your personal data, we will provide You with one copy of your personal data which is subject to the processing. For any subsequent copies You will request, we can charge a reasonable fee to cover administrative costs. If You submit a request for the copy by electronic means of communication, and if You do not indicate otherwise, we will provide You with the information via the commonly used electronic means of communication.

Right to request rectification of your personal data

You have the right to request us to immediately rectify your personal data that is incorrect. Taking into account the purposes of the processing, You also have the right to request your incomplete personal data to be completed, including by means of providing a supplementary statement.

The right to request erasure of your personal data (the so-called “right to be forgotten”)

You have the right to request erasure of your personal data without undue delay, and we have the obligation to erase the personal data without undue delay where one of the following grounds applies:
a) your personal data is no longer necessary in relation to the purposes for which it was collected or otherwise processed;
b) your consent for the processing of personal data has been withdrawn and we have no other legal ground for the processing;
c) your personal data has been unlawfully processed.

Right to request restriction of processing

You have the right to obtain from us restriction of processing in one of the following cases:
a) you contest the accuracy of your personal data – for a period that enables us to verify the accuracy of such data;
b) the processing is unlawful, and You oppose the erasure of your personal data, requesting the restriction of its use instead;
c) we no longer need your personal data for the purposes of the processing, but You require it for the establishment, exercise or defence of legal claims;
d) we have received your objection pursuant to Article 21(1) of the GDPR in respect of the processing (see below) – pending the verification whether the legitimate grounds we have override the grounds for your objection.

Right to object to the processing

At any time You have the right to object – on grounds related to your particular situation – to the processing of your personal data based on the necessity of the data processing for the purposes resulting from our legitimate interests. If You raise such objection, we can no longer process your personal data unless we demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or grounds for establishment, exercise or defence of legal claims.

Right to data portability

You have the right to receive your personal data, which You have provided us with, in a structured, commonly used and machine-readable format, and You have the right to transmit this data to another controller without any hindrance from us if:
a) the processing is based on your consent or on the contract we have concluded with You; and
b) the processing is carried out by automated means.

In exercising the right to data portability, You have the right to request that personal data is transmitted by us directly to another controller, if technically feasible.

The right to data portability cannot adversely affect the rights and freedoms of others.

6. WHERE CAN YOU LODGE A COMPLAINT IF YOU CONSIDER THAT YOUR PERSONAL DATA IS PROCESSED UNLAWFULLY?

If You consider that your rights related to the protection of personal data have been infringed, You have the right to lodge a complaint with the supervisory authority, which is the President of the Office of Competition and Consumer Protection. Nevertheless, we encourage You to a prior contact with us to clarify the situation.

7. INFORMATION ABOUT COOKIES

The websites of the companies from VECTOR Group may use cookies. Cookies do not gather information which could identify the user. The files are not used to process or store personal data. VECTOR Group stores cookies on your computer in particular to:
a) keep track of your session (after authentication) to avoid re-entering your user name and password on each website;
b) better adapt the website to your needs;
c) create viewer analytics reports for our partners who deliver content and advertisements.

8. WHEN THIS PRIVACY POLICY MAY BE AMENDED

We have the right to amend this Privacy Policy at any time, in particular in the event of any changes to the regulations or guidelines on the protection of personal data. In case of any amendment, we will send You an email or You will find the information on our Website.

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