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Privacy policy

Eurosteel sp. z o.o. Privacy Policy

I. General Information

This Privacy Policy explains how Eurosteel sp. z o.o. processes the personal data of website users, individuals who contact the Company, contractors who are natural persons, contractors’ representatives and contact persons, and job applicants.

This Policy does not replace separate privacy notices provided to employees or information concerning video surveillance. Where a separate privacy notice has been provided for a particular process, that notice takes precedence in relation to that process.

II. Data controller

The controller of personal data is Eurosteel sp. z o.o., with its registered office at ul. Chorzowska 22, 25-852 Kielce, Poland, entered in the register of entrepreneurs of the National Court Register under KRS number 0000438761, NIP (tax identification number) 959-194-95-21 and REGON (statistical identification number) 260631472, hereinafter “Eurosteel” or the “Controller”.

The Controller has not appointed a data protection officer.

III. Contact details for data protection matters

For matters concerning the processing of personal data or the exercise of rights, you may contact the Controller:

  • by post or in person: Eurosteel sp. z o.o., ul. Chorzowska 22, 25-852 Kielce, Poland;
  • by telephone: +48 41 346 81 90;
  • by email: js@eurosteel.pl.

IV. Purposes, legal bases and retention periods

Eurosteel processes personal data only to the extent necessary for the following purposes:

  1. Handling enquiries and correspondence – under Article 6(1)(f) of the GDPR, namely the Controller’s legitimate interest in communicating with people interested in the Company’s activities and responding to them. Where an enquiry concerns entering into a contract with a natural person, Article 6(1)(b) of the GDPR may also apply. Data is retained until the correspondence is concluded and then for as long as necessary to demonstrate its course or until the limitation period for any potential claims expires.
  2. Preparing quotations and entering into and performing contracts or orders:
    • where the data subject is a party to the contract – Article 6(1)(b) of the GDPR;
    • where the data relates to a contractor’s representative, employee or contact person – Article 6(1)(f) of the GDPR, namely the legitimate interest in establishing and carrying out cooperation and maintaining ongoing communication.
      Data is retained for the duration of the business relationship and then until the expiry of periods required by law or limitation periods for claims.
  3. Complying with accounting, tax and other legal obligations – under Article 6(1)(c) of the GDPR. Data is retained for the period required by the applicable law.
  4. Handling complaints and establishing, pursuing or defending claims – under Article 6(1)(f) of the GDPR. Data is retained until the matter is concluded and the applicable limitation period for claims has expired.
  5. Recruitment – for data required by employment law, under Article 6(1)(c) of the GDPR in conjunction with Article 22¹ of the Polish Labour Code; for additional data provided voluntarily, under Article 6(1)(a) of the GDPR. Data is processed until the particular recruitment process is concluded and then deleted, subject to the period necessary to establish, pursue or defend claims. Eurosteel does not retain CVs for future recruitment processes.

Eurosteel does not operate a newsletter or use website users’ data for profiling or for marketing based on analysis of their behaviour.

V. Sources and categories of data

Data may be obtained:

  • directly from the data subject, in particular through a contact form, email, telephone, application documents, or in connection with entering into or performing a contract;
  • from a contractor, the person’s employer, another employee, a Eurosteel Group company or publicly available registers, where necessary to make contact, verify authority to act or carry out cooperation.

Depending on the matter, Eurosteel may process: first and last name, business contact details, organisation name, position or role, information on authority to act, information contained in correspondence, quotations, orders, contracts and settlement documents, and, for recruitment, information provided in application documents.

Eurosteel does not expect special categories of personal data or data concerning criminal convictions and offences to be submitted through the website. Please do not include such information in forms or ordinary correspondence. Merely sending such data does not automatically constitute valid consent to its processing.

VI. Cookies and technical data

The website may use cookies and similar technologies necessary for its proper operation, security and remembering user settings. Necessary cookies are used to the extent required to provide the service and ensure that the website functions properly.

Analytics, functional or marketing cookies may be used only if they are actually deployed on the website and the user’s required consent has been obtained. Users should be able to refuse their use and subsequently change their decision as easily as they gave consent. Detailed information about the cookies currently used, their providers, purposes and lifetimes should be available in the cookie settings panel.

Users may also manage cookies through their browser settings. Blocking necessary cookies may impair the proper operation of the website.

When the website is used, technical data such as the IP address, device and browser type, date and time of connection, requested resource and error information may be processed automatically. This data is used to ensure the operation and security of the website under Article 6(1)(f) of the GDPR and is retained for the period necessary for those purposes.

VII. Automated decision-making

Personal data is not used to make decisions based solely on automated processing that produce legal effects concerning an individual or similarly significantly affect them. Eurosteel does not profile website users.

VIII. Whether providing data is voluntary

Providing data in the contact form or correspondence is voluntary, but failure to provide the data necessary to respond may prevent Eurosteel from handling the enquiry.

Where data is necessary to enter into or perform a contract or comply with a legal obligation, failure to provide it may prevent the contract from being entered into or performed. In recruitment, providing data required by employment law is necessary to participate in the process, while providing additional data is voluntary.

IX. Recipients of data

Data may be disclosed, only to the extent necessary, to:

  • providers of IT, support and hosting services, and entities maintaining the website and email systems;
  • Eurosteel Group companies, where necessary to handle an enquiry, prepare a quotation, carry out a project or contract, or perform administrative activities – acting, as appropriate, as separate controllers or processors;
  • providers of legal, accounting, audit, insurance or debt collection services;
  • banks, postal and courier operators, and other entities involved in performing a contract;
  • public authorities and other entities entitled to receive data under the law.

Entities processing data on Eurosteel’s behalf are granted access only to the extent necessary to perform the entrusted services and are required to provide appropriate protection for the data.

X. Transfers of data outside the European Economic Area

Eurosteel does not transfer personal data collected through the website to countries outside the European Economic Area or to international organisations.

XI. Rights of data subjects

Within the limits laid down in the GDPR, data subjects have the right to:

  • access their data and obtain a copy;
  • have their data rectified;
  • have their data erased;
  • restrict processing;
  • data portability, where processing is based on consent or a contract and is carried out by automated means;
  • object to processing based on Article 6(1)(f) of the GDPR on grounds relating to their particular situation;
  • withdraw consent at any time where processing is based on consent, without affecting the lawfulness of processing carried out before consent was withdrawn;
  • lodge a complaint with the President of the Personal Data Protection Office (Prezes Urzędu Ochrony Danych Osobowych), ul. Stanisława Moniuszki 1A, 00-014 Warsaw, Poland, www.uodo.gov.pl.

Requests may be submitted using the contact details in Section III. Where necessary to protect personal data, the Controller may request additional information to verify the identity of the person submitting a request.

XII. Data security

Eurosteel applies technical and organisational measures appropriate to the nature, scope and risks of personal data processing. Access to data is limited to authorised persons and entities that need it to perform the tasks entrusted to them.

XIII. Changes to the Privacy Policy

This Policy may be updated if the law, the operation of the website, the tools used or the processing activities change. The current version of the Policy, including its last updated date, is published on Eurosteel’s website.