Introduction
The protection of personal data in BROS. INVEST Ltd. with its registered office in London, Ground Floor, Craven House, 40-44 Uxbridge Road, W5 2BS London, entered in the Registrar of Companies of England and Wales under number 9157956 (hereinafter “BROS. INVEST”) is taken particularly seriously. This statement sets out the legal grounds for processing and the methods of collecting and using personal data as well as provides information on the rights of individuals. We use the provided personal data for the purposes specified in this document or for any other purpose indicated at the time of their transfer to BROS. INVEST.
Personal data shall mean information about an identified or identifiable natural person. BROS. INVEST processes personal data for different purposes, and depending on the purpose, different ways of collection, legal grounds for processing, use, disclosure and retention periods may apply.
In the case of the collection and use of personal data, we wish to maintain transparency regarding the basis and manner of personal data processing.
Legal basis for processing
The legal basis for each processing operation is set out in the relevant section above. Where the processing of personal data is based on the legitimate interest of the data controller, we try to analyze and balance our interest and potential impact on the data subject (positive and negative) and the rights of the data subject under the data protection legislation.
Our legitimate interest as a data controller do not automatically prevail over the rights of data subjects – we do not process personal data if the influence on the data subject outweighs our interests (unless we have the appropriate consent or it is required or permitted by law).
When and how we transfer your personal data to third parties and places of processing
We will only share your personal data with others if permitted by law. In such a case, the agreement provides for provisions and security mechanisms to protect data and to uphold our data protection, confidentiality and security standards.
Our company is part of a global network and together with other professional service providers we conduct our business through external entities based in other countries. As a result, personal data may be transferred outside the territory of the countries where our company is located or where our clients’ companies are located.
In the case of personal data subject to EU legislation, it should be noted that: cross-border transfers may involve countries outside the European Economic Area (“EEA”) and countries without specific data protection legislation in place. We have taken steps to ensure adequate protection of all personal data and the legality of the transfer of personal data outside the EEA.
In case of transfer of personal data outside the EEA to a country which according to the European Commission does not ensure an adequate level of personal data protection, the transfer will take place on the basis of an agreement taking into account the EU requirements for transfer of personal data outside the EEA, such as standard contractual clauses approved by the European Commission. These clauses are available here.
Personal data stored by us may be transferred to:
- Other member companies of BROS. INVEST, part of the BROS. INVEST network. We may pass on your personal data to other BROS. INVEST member companies where necessary for administrative purposes and in order to provide professional services to our clients (e.g. in the provision of consultancy services by other BROS. INVEST member companies in other countries). Our business contacts are disclosed to BROS. INVEST users from other BROS. INVEST member companies and used by them to obtain more information about the contact, client or opportunity they are interested in (see the business contacts section of this document for more information on how to process such data).
- External organizations providing applications/functions or providing data processing or IT services.
- Thanks to the support of external entities, we can provide our services as well as provide, operate and manage internal IT systems. These include, among others, providers of information technology, cloud-based software and entities providing identity management, hosting and website management services, data analysis, backup, security and data storage. Servers operating and supporting cloud infrastructure are located in secure data centers around the world and personal data can be stored in each of them.
- External organizations that otherwise assist us in providing goods, information or services.
- Auditors and other professional advisors.
- Law enforcement authorities, regulatory bodies and other government authorities or third parties if required by applicable law (in a manner consistent with such law).
- We occasionally receive requests from authorized third parties for disclosure of personal data, e.g. to check whether we comply with applicable laws and regulations, investigate alleged offences, establish, exercise or defend legal rights. We only meet such requests when we are permitted to do so by applicable laws or regulations. A list of our key suppliers to whom we entrust personal information is available here.
Data controller and contact details
The data controller is BROS. INVEST Ltd. with its registered office in London, Ground Floor, Craven House, 40-44 Uxbridge Road, W5 2BS London, entered in the Registrar of Companies of England and Wales under number 9157956
If you have any questions regarding this document or how and for what purposes we process your personal data, please contact us at:
BROS. INVEST Ltd
ul. Rakowicka 1
31-511 Kraków
Phone: +48 535 015 835
E-mail: [email protected]
Rights of natural persons and the way in which they are exercised
Natural persons have specific rights regarding their personal data and data controllers are responsible for the exercise of these rights. If the decision about the manner and purpose of the processing of personal data is up to us, we are the data controller and below we provide further information about the rights of natural persons and the way in which they are exercised.
Access to personal data
Natural persons have the right to access data that we store as a data controller. This right can be exercised by sending an e-mail to: [email protected].
Amendment of personal data
You can update your personal information by sending an email to [email protected] or, if applicable, contacting us via the relevant registration page or changing the personal information stored in the relevant applications for which you have registered.
Where reasonably practicable, we will correct any personal data processed by us on the basis of updated information after notifying us that any personal data we process is no longer up to date.
Withdrawal of consent
Where personal data are processed on the basis of consent, natural persons have the right to withdraw their consent at any time. In general, we do not process personal data on the basis of consent (as we usually operate under a different legal basis). To withdraw your consent to the processing of personal data, please send us an e-mail to [email protected] or if you do not want to receive further marketing information, please click on the unsubscribe link in the relevant e-mail sent by us.
Right to restrict or object to the processing of personal data
Natural persons shall have the right to restrict or object to the processing of their personal data at any time on grounds relating to their particular circumstances, unless processing is required by law.
In this case, we will not further process your personal data or we will restrict the processing insofar as we can demonstrate a legally valid basis for the processing or the establishment, exercise or defence of our rights.
Other data subjects’ rights
This document is intended to provide information about what personal data we collect and how they are used. In addition to the right of access, modification and restriction of the processing or objection to the processing indicated above, natural persons have other rights regarding the personal data stored by us, such as the right to demand deletion of data and the right to transfer data.
If you wish to exercise these rights, please send an e-mail to [email protected]
Complaints
We hope that this will not be necessary, but if you would like to complain about our use of your personal data, please send an e-mail with details of your complaint to [email protected] Any complaints we receive will be considered and responded to.
Natural persons also have the right to lodge a complaint with the President of the Office for the Protection of Personal Data. For more information on the rights of natural persons and how to lodge a complaint with the President of the Office for the Protection of Personal Data, please visit www.giodo.gov.pl
BUSINESS CONTACTS
BROS. INVEST Ltd. with its registered office in London, Ground Floor, Craven House, 40-44 Uxbridge Road, W5 2BS London, entered in the Registrar of Companies of England and Wales under number 9157956 processes personal data of business contacts (current and potential clients of BROS. INVEST and/or natural persons associated with them) when a natural person contacts us to make inquiries, complaints, comments or feedback (such as name, contact details and message content). In such a case, the person concerned has control over the data provided to us and we use such data only for the purpose of responding to the message and handling the matter.
Personal information includes name and surname, employer’s name, telephone number, e-mail address and other business contact information.
Use of personal data
Personal information about business contacts may be disclosed to BROS. INVEST users and used by them to obtain information about the client or services they may be interested in. Personal data may be used for the following purposes:
- Development of BROS. INVEST activities and services
- Presentation of information about BROS. INVEST and the scope of our services
- Sharing personal information with BROS. INVEST employees to provide services and offer new services
- Identifying clients with similar needs
- Analyses of e.g. market trends, relationship maps or sales opportunities.
Legal basis for processing
Processing of personal data of our business contacts is based on our legitimate interest of the data controller or consent where the data subject has been asked to give his or her consent. Our legitimate interest as a data controller is related to the direct marketing of our services or the provision of information that we believe will be of interest to our clients.
Storage of data
Personal data will be stored in the BROS. INVEST CRM system for the period necessary for the purposes set out above (e.g. for the duration of our relationship with a business contact or for a period that requires the documentation of such relationship).