The information contained in this document relates to the processing by Cabinethandle LTD (hereinafter: Cabinethandle LTD) personal data of Clients, Contractors, Co-workers and their employees (hereinafter: Data Subject) in relation to concluded contracts for the provision of services. Information is compliant with EU regulations regarding the processing of personal data (Regulation of the European Parliament and of the Council (EU) 2016/679 – the so-called RODO).

Data administrator and contact details

  1. The data administrator is: Cabinethandle LTD

  1. Contact details for Cabinethandle LTD ,

 Purposes of processing personal data

The personal data of the Data Subject is processed for the purposes of:

  1. perform the contract or take action before entering into the contract (eg accepting orders, providing services, handling orders and requests, dealing with complaints);

  1. fulfill legal obligations incumbent on the data controller and performance of tasks in the public interest (eg performance of tasks related to security and defense, storage of tax documentation);

  1. resulting from legitimate interests pursued byCabinethandle LTD  (eg direct marketing of own products, security and pursuing claims, security and protection against claims of the Subscriber or third parties);

  1. marketing, not resulting from legally justified interests pursued by Cabinethandle LTD(eg marketing of services and products of third parties, own marketing that is not direct marketing).

Legal basis for the processing of personal data

The legal basis for data processing is:

  1. Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46 / EC (general regulation on protection data), in particular art. 6 of this Regulation laying down general rules on the compatibility of data processing;

  1. consent – in situations where Cabinethandle LTD  is entitled or obliged to process data on the basis of express consent and this results from previously established legal acts.

  Legally legitimate interests

In the case of data processing pursuant to art. 6 par. 1 f) of the General Data Protection Regulation (where processing is necessary for purposes arising from legitimate interests pursued by Cabinethandle LTD or by a third party), Cabinethandle LTD informs that the legitimate interests pursued by the controller are:

  1. securing and pursuing their claims and securing and protecting against claims from the Data Subject.

Recipients of data

According to the definition of ‘recipient’, set out in the General Data Protection Regulation referred to in Article 4 point 9, Cabinethandle LTD informs the Data Subject that his personal data may be disclosed to the following categories of recipients when they are processed:

  1. Data Subject and persons authorized by the Data Subject;

  1. authorized persons employed by Cabinethandle LTD or in entities related to him in capital or in person;

  1. entities processing data on behalf of and on behalf of Cabinethandle LTD as well as authorized persons employed in these entities (eg marketing by external companies, debt collection and claims based on the services of external companies);

  1. third parties – in the case of consent of the Data Entity for the transfer of data (eg in the event of transfer of data for marketing purposes, if the credibility of the Data Subject is verified by the Economic Information Bureau, in the case of direct debit) or if Cabinethandle LTD rights (eg in the event of the assignment of claims together with the transfer of personal data related to the claim);

  1. public authorities that may receive data in cases other than as part of a specific proceeding conducted in accordance with Union law or Polish law.

Data processing in third countries

Cabinethandle LTD does not transfer personal data to third countries (outside the European Union) or international organizations. In the event that such intention arises,  Cabinethandle LTD will endeavor to provide the third country or international organization with a state or organization where the European Commission (in accordance with the General Data Protection Regulation) has found an adequate level of protection if necessary. Otherwise, Cabinethandle LTD may transfer personal data to a third country or international organization only if adequate safeguards are provided and the enforceable rights of data subjects and effective remedies referred to in the General Data Protection Regulation apply, and taking into account the Data Entity’s information on the possibilities of obtaining a copy of the data or on the place where the data is made available.

Data retention periods

Personal data is stored:

  1. in the case of collecting personal data for the purpose of the contract or the conclusion of the Agreement (legal basis: Article 6 paragraph 1 letter b): from the data collection before the conclusion of the contract to conclude it or from the collection of such data during the conclusion Contracts or from the moment the data are collected during the term of the contract (in the event of the data being supplemented or updated during the term of the Contract) until the contract is terminated or the contract is completed after its termination (eg processing of complaints);

  1. in the case of collecting personal data in order to fulfill obligations resulting from legal regulations or in connection with the performance of tasks in the public interest (legal basis: Article 6 paragraph 1 c and e) for the period of performing duties and tasks resulting from individual legal provisions;

  1. in the case of processing personal data for purposes deriving from legitimate interests  Cabinethandle LTD(legal basis: Article 6 (1) letter f) data will be stored no longer than ten years from the date of termination of the contract or until substantiated objection in the face of processing for that purpose;

  1. in the case of collection of personal data on the basis of consent (legal basis: Article 6 (1) a or f of the RODO): from the moment of consent to the processing of data covered by it (also during the contract) until the request for withdrawal consent in the event of its withdrawal, or until notice of objection;in addition to the situations mentioned above, the data may be stored during the period of limitation of data processing established at the request of the Subscriber, a request of the supervisory body – in situations provided for by the RODO in art. 18 and art. 58. If there are specific provisions specifying the time for which personal data should be stored, then such provisions may extend the processing time of personal data.

At any time, personal data processing Cabinethandle LTD is guided by the principles of purpose limitation, data minimization and limited processing periods.

Rights of the Data Subject related to the processing of personal data

The Data Subject has the right to request access to its personal data, rectification, deletion and processing restrictions. In addition, the Data Subject has the right to object to the processing of data and the right to transfer data. The implementation of the rights listed in this paragraph takes place in accordance with the provisions of the General Data Protection Regulation (GDPR) – based on the definitions and mechanisms described in this Regulation.

In the event that Cabinethandle LTD processes personal data based on the consent of the Data Subject, the Data Subject has the right to withdraw consent at any time, without affecting the legality of the processing, which was made on the basis of consent before its withdrawal.

The Data Subject has the right to lodge a complaint to the supervisory body under the terms of the general data protection regulation, in particular pursuant to art. 77 of this regulation. In Poland, the Supervisory Authority from May 25, 2018 is the Office for Personal Data Protection.

Data categories. Requirement to provide data. Consequences of not providing data.

Cabinethandle LTD informs that providing the following data is a contractual requirement and at the same time a condition for the conclusion of the Agreement: name, surname, tax identification number, PESEL, address data, email address. Providing other data, such as: contact telephone numbers is a contractual requirement, but it is not a condition of concluding or implementing the Agreement. Providing all data is voluntary. The consequence of not providing data that is a condition for the conclusion of the contract is the inability to conclude an agreement with Cabinethandle LTD . The consequence of not providing data that is not a condition for the conclusion of the contract is the inability to use these data for purposes related to their collection (ie, for example, contacting the Data Subject with the use of this data for the purpose of the contract, the possibility of presenting marketing offers).

Automated processing of personal data

Cabinethandle LTD does not carry out automated processing of personal data (eg profiling), which causes legal effects to you or similarly significantly affects you, but nevertheless we use cookies, other tools (eg conversion pixels, tag manager, etc.) and other systems registering traffic on our websites, e.g. chats (profiling for marketing purposes). Final information

The principles described in the document apply from May 25, 2018 –  from the date of application of the GDPR.

The full text of the European General Data Protection Regulation (GDPR) can be found at: