1. What does this Policy describe?
This privacy policy ("Policy") governs the processing of personal data by StatXplorer sp. z o.o. (formerly: Nunatak Capital Advisors sp. z o.o.) ("Company", "StatXplorer", "we") when you interact with us and when you visit our website https://www.statxplorer.com/ (the "Website").
The Policy provides information about the Company's processing of personal data, and in particular:
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identifies the types of personal data we collect;
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explains how and why we collect and use your personal data;
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explains when and why we will share personal data with other parties;
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explains the rights and choices you have when it comes to your personal information.
We want it to be clear to you whether the Policy also applies to the processing of your personal data. The Policy applies if you are a:
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Visitor to the Website or contacting us, i.e. you make a visit to the Website or contact us, e.g. by email;
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Contractor, i.e. you provide any products or services to us, use our services or work with us on joint ventures;
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Contractor’s Representative, i.e. you represent an entity that provides any products or services to us, uses our services or joint ventures with us;
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Job Candidate, i.e. you participate in our recruitment process or send us your application documents for future recruitment processes.
We process your personal data in accordance with the European Union General Data Protection Regulation (2016/679) ("GDPR") and other applicable data protection legislation that supplements and/or implements the GDPR.
2. Who is the data controller of your personal data
The data controller of your personal data is StatXplorer sp. z o.o. (formerly: Nunatak Capital Advisors sp. z o.o.) with its registered office in Warsaw, address: Plac Trzech Krzyży 10/14, 00-449 Warsaw, entered in the register of entrepreneurs kept by the District Court in Warsaw, XII Economic Department of the National Court Register under KRS number 848073, having NIP number: 7010988778 and REGON number: 386443296.
In matters related to the processing of personal data, you can contact us by mail or at the e-mail address info@statxplorer.com.
3. What information do we collect and from what sources?
If you are a visitor to the Website or contacting us, we collect information collected when you use the Website, during conversations and e-mail exchanges. This may include, but is not limited to, your name, mailing address, email address, and telephone number.
If you are a Contractor, we collect information provided to us in the documents you send us, during conversations, meetings, and e-mail exchanges, including in particular information necessary to conclude and perform a contract. This may include in particular your name, surname, e-mail address, telephone number, company, business address, PESEL, NIP, REGON, bank account number. Your data may also come from publicly available sources.
If you are a Contractor's Representative, we collect information provided to us in the documents you send us, during conversations, meetings, e-mail exchanges. This may include, in particular, your name, contact details, position, details of the entity you represent. Your data may also be communicated to us by the entity you represent both before and during your cooperation with us.
If you are a Job Candidate, we collect information provided to us in your CV or other application documents as part of the recruitment process. This may include, in particular, your name, date of birth, contact details, education, professional qualifications and previous employment history, as well as other personal data which you provide to us on your own initiative. Please remember that providing your personal data to the extent stipulated by law, including Article 221 § 1 and 4 of the Labour Code, is necessary to participate in the recruitment procedure. Providing the remaining data is voluntary and their failure to provide will not result in any negative consequences towards you, in particular, it will not constitute a reason justifying the refusal to employ you.
4. For what purpose and on what basis do we process your data
If you are a visitor to the Website or contact us, we process your data for the purposes of the Company's legitimate interests, i.e:
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to contact you in response to your questions, requests, comments, for the handling of your request directed e.g. by email or other means, for the purposes of operating the Website, for reporting purposes, internal administrative and marketing purposes (Article 6(1)(f) GDPR);
If you are a Contractor, we process your data:
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for the conclusion and performance of the contract (Article 6(1)(b) GDPR);
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in order to comply with legal obligations (Article 6(1)(c) of the GDPR), in particular for the settlement of tax debts and the retention of financial records;
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in order to pursue our legitimate interests (Article 6(1)(f) of the GDPR) related to the operation of the business, the Website, the maintenance of business relations, ongoing contact, marketing activities, as well as the assertion and defence of claims.
If you are a Contractor Representative, we process your data:
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for the purposes of our legitimate interests (Article 6(1)(f) of the GDPR) related to entering into and performing a contract with the entity you represent, maintaining a business relationship and ongoing contact, conducting marketing activities, as well as pursuing and defending against claims.
If you are a Job Candidate, we process your personal data on the basis of your consent for the purposes of future recruitment processes (Article 6(1)(a) of the GDPR), and special category data if you have provided it to us on your own initiative (Article 9(2)(a) of the GDPR) or in order to fulfil the Company's legal obligations as an employer and the corresponding rights of a job applicant under the law, including the Labour Law (Article 6(1)(c) of the GDPR).
5. To whom we share your data
Where necessary for the purposes for which we process your data, we may share it with:
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entities entitled to receive it under the law;
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entities processing personal data on our behalf, i.e. companies providing certain services for us, the performance of which involves the processing of personal data. For example, entities operating our IT systems or providing us with ICT tools, entities providing us with consultancy services, etc. (so-called "processors");
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entities within the StatXplorer group.
Whenever we share your data, we will ensure that the transfer has a legal basis and includes only the minimum information necessary to fulfil the purpose of the processing for which the data is shared.
Where necessary for the purposes referred to in paragraph 4, data may be transferred outside the European Economic Area. Whenever we transfer your data outside the EEA we will ensure the highest level of security.
6. How long do we keep your data
If you are a visitor to the Website or contacting us, we will retain your personal data for as long as is necessary for the purposes of operating the Website or dealing with your enquiry.
If you are a Contractor or Contractor's Representative, we retain your data for the duration of the contract with you or the entity you represent. After this period, we will, to the extent necessary, keep your data for the period of time arising from legal requirements (e.g. the obligation to keep financial records for 5 years), statutes of limitation on claims (3 years for claims arising from business activities) or necessary for the fulfilment of the other purposes of data processing indicated in this Policy.
If you are a Job Candidate, we will keep your data until the end of the recruitment process, and longer only if you have consented to us processing it for future processes.
7. What rights do you have
In exercising your rights in relation to the processing of your personal data, you may address the following requests to us:
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where we process your personal data on the basis of your consent, you may withdraw that consent at any time; withdrawal of consent does not affect the lawfulness of the processing we have carried out on the basis of that consent up to the time of withdrawal;
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you can request access to and obtain a copy of your personal data;
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you can exercise your right to portability of your personal data;
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you can request the rectification of your personal data if it is incorrect or incomplete;
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in relation to your particular situation, you may object to the processing of your personal data where we process it on the basis of our legitimate legal interest;
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in cases provided for by law - e.g. if your data is outdated, redundant, processed unlawfully, and if you have withdrawn your consent to the processing of your personal data (where consent was the basis for such processing) or you have successfully lodged an objection to the processing of your personal data - you may request the erasure of your personal data;
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you can also request the restriction of data processing.
In order to exercise the above rights, please contact us by correspondence or at the e-mail address: info@statxplorer.com.
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In any case in which you consider that our processing of your personal data violates the provisions of the GDPR, you also have the right to lodge a complaint with the President of the Personal Data Protection Office.
8. Do you have to provide us with your data and where do we get it from if it does not come from you
Providing your data is, in any case, voluntary, but remember that refusal to provide it will prevent us from fulfilling the purposes for which the data are collected, in particular, it will prevent or significantly hinder contact with you, prevent the conclusion of a contract if you are a party to it, or prevent the provision of services to you.
If you are a Contractor's Representative and you do not provide us with your data yourself, they come from the entity you represent or have been collected by us from publicly available sources (e.g. the website of this entity).