Social Media Policy

By using our social media accounts, you interact with us, e.g. by subscribing to a fanpage, leaving your reaction (likes, comments) or sending us a message. The information you provide about yourself may constitute personal data. The Social Media Policy describes how we process personal data collected through accounts on the following social media networks (hereinafter referred to as ‘Social Networks’):

We process your personal data in accordance with the 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 (hereinafter referred to as the General Data Protection Regulation).

I. Controller

The Controller of your personal data is Straal Sp. z o.o., with its registered office in Warsaw, address: Plac Europejski 1, 00-844 Warsaw, Poland (hereinafter referred to as the “Controller“). You may contact the Controller via e-mail: [email protected] or by correspondence at the above mentioned address of the Controller’s registered office. 

Please be advised that we have appointed a Data Protection Officer. You can contact our Data Protection Officer via e-mail: [email protected]

II. Categories of Data Subjects and Scope of Processing

FACEBOOK

We process the data of individuals who:

  • have subscribed to the account by clicking the ‘Like’ button or the ‘Follow’ button,
  • posted a comment, shared it or clicked the “Like” button under any of the posts in the account.

We process the following categories of personal data:

  • Account Identifier (usually including your name or a nickname),
  • profile picture,
  • other photographs (which may also depict an image),
  • the content of your comments,
  • statistical data on account visitors collected through cookies and available through the ‘Facebook Insights’ tool.

YOUTUBE

We process the data of individuals who:

  • have subscribed to the account by clicking on the ‘Subscribe’ button,
  • posted a comment under any of the videos posted in the account or responded to the posted videos.

We process the following categories of personal data:

  • account Identifier (typically including your name or nickname),
  • profile picture,
  • the content of your comments,
  • statistical data on the account visitors collected through cookies.

LINKEDIN

We process the data of individuals who:

• visited the Controller’s website,

• interact with the Controller,

• have published or sent data through the services offered by the Linkedin portal (eg filled out forms, answered surveys).

We process the following types of personal data:

• name, surname, image and other identification data published on the profile created on the Linkedin portal (including address and contact details, e.g. e-mail address, telephone number and data on education, work experience, professional qualifications and previous course employments),

• statistical data on the account visitors collected through cookies.

TWITTER

We process the data of individuals who:

• subscribed to the account by clicking the “Follow” icon,

• visited the Controller’s website,

• interact with the Controller.

We process the following categories of personal data:

• account identifier (usually containing your first and last name or nickname),

• profile picture,

• other photos (which can also show an image),

• the content of your comments,

• statistical data on account visitors, collected through cookies.

III. Purpose and Legal Basis 

We process your personal data:

  1. on the basis of a legitimate interest (Article 6 (1) (f) of the General Data Protection Regulation)  consisting in:

a) keeping an account on the social network, on the terms and conditions set out by the Network’s operator and informing about our activity, promoting events and brands, products and services, building and maintaining an online community (including supervision over content published by users) and for communication via the available functionalities of the Social Network (comments, messages),

b) keeping statistics (by analyzing data on the activity of our account users),

c) possible determination, investigation or defense against claims.

  1. on the basis of a separately granted consent to the extent and purpose specified in the consent and for the time until its withdrawal (Article 6 (1)(a) or Article 9(2)(a) of the General Data Protection Regulation),
  2. on the basis of statutory requirements to fulfill our legal obligations under the provisions of law (Art.6 (1) (c) GDPR).

In the event that we organize promotional campaigns using a Social Network, the rules for the processing of your personal data, including the purpose and legal basis for such processing, are described in the regulations of such action. Before participating in a promotional campaign, please read its regulations.

  1. Joint Controllers of Personal Data

With regard to the processing of personal data for statistical purposes, we act as Joint Controllers within the meaning of Article 26 (1) of the General Data Protection Regulation together with the operator of the Social Network that provides the statistics. We undertake such activities within the framework of our legitimate interest (Article 6 (1) (f) of the General Data Protection Regulation) as described above.

For more information on the processing of data for statistical purposes, please follow the link:

  1. Recipients of Personal Data

Access to your personal data will be granted to:

  • our authorized personnel and entities providing services to us (including marketing services, IT services and technical support) that must have access to data in order to perform their duties,
  • other users of the Social Network (due to the fact that information about account followers, likes, as well as the content of comments, posts and other data provided by users are public),
  • public authorities and entities performing public tasks or acting on behalf of public authorities, to the extent and for the purposes that result from the provisions of generally applicable law,
  • Controller of the Social Network on the terms described in the shared privacy policies.

Please note that Social Networks are separate entities responsible for processing  personal data using the Social Networking Sites, including personal data relating to you. These entities process your personal data for their own purposes based on the legal basis established by them. In particular, they may collect and process the information contained in the cookies of visitors to our accounts based on their own rules of operation of the Social Network. We have limited influence over the processing of data by the operators of the Social Network. For this reason, we ask you to read the terms and conditions of their operation and the privacy policies provided therein, which you can find here:

  1. Transfer of Data to Third Countries or International Organisations

Your personal data may be transferred outside EEA based on the agreements with our partners and based on the cooperation between the companies within our Group.

  1. Data Retention

The period of data processing is related to the purposes and grounds for their processing, therefore:

  • data processed on the basis of consent will be processed until the consent is withdrawn,
  • data processed on the basis of statutory requirements will be processed for the time specified by the provisions of law,
  • data processed on the basis of the legitimate interest of the Controller will be processed until positively considered objection or until the legitimate interest ceases to exist, i.e .:
  • we process your data by default until we delete the account on the Social Network,
  • personal data that we have obtained in the messages or correspondence for a duration of handling the message,
  • data processed in order to establish, investigate or defend against claims for a period equal to the period of limitation of these claims.
  1. Your Rights under the General Data Protection Regulation

You have the right to:

  1. request access to your personal data, rectification, erasure or limitation of processing, as well as data portability,
  2. if the grounds for the processing of personal data is consent – you have the right to withdraw it at any time. Withdrawal of consent does not affect the lawfulness of the processing which was carried out on the basis of consent before its withdrawal,
  3. if the grounds for the processing of personal data is a legitimate interest – you have the right to object at any time to the processing of personal data for reasons related to your particular situation,
  4. lodge a complaint with the supervisory authority, i.e. the President of the Personal Data Protection Office, 2 Stawki Street, 00-193 Warsaw.

To exercise your rights, please contact us.

  1. Data Source and Other Information
  • We receive your personal data directly from you through the interaction with our Social Media accounts and from your public profile.
  • The provision of data is voluntary. 
  • Personal data will not be subject to automated decision-making, including profiling. 
  1. Social Media Policy Changes

Social Media Policy is subject to change that we will inform you about 7 days in advance. Questions related to the Social Media Policy should be directed to: 

[email protected]

Last modified: 20.04.2022 r.

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