§ 1 Definitions

The terms used in this privacy policy have the following meanings:

  1. Administrator – the entity deciding on the nature, scope and purposes of personal data processing – Transition Technologies PSC S.A. with its registered office in registered in the Register of Entrepreneurs of the National Court Register kept by the District Court for Lodz Śródmieście in Lodz, XX Economic Department of the National Court Register under the KRS number 0000930989, having NIP 7292712388, Regon: 365249538, share capital in the amount of PLN 1,468,800.00, paid in full,
  2. „Cookies” – means IT data, in particular small text files, recorded and stored on devices through which the User uses the Services available on the Site. A detailed description of the Cookies used can be found in the Cookies Policy.
  3. RODO – Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 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 (General Data Protection Regulation),
  4. Website – the website managed and operated by the Service Provider, located at https://ttpsc.com/,
  5. User – an adult natural person using the Site.

§ 2 Data controller

  1. The administrator of the data collected during the use of the Site is Transition Technologies PSC S.A.
  2. Contact with the Administrator is possible through the following channels:
    1. Postal address: Transition Technologies PSC S.A.,
    2. E-mail address: contact@ttpsc.com
    3. phone number: +48 661 799 553
    4. Data Protection Officer: gdpr@ttpsc.com

§ 3 Purpose of the Privacy Policy

Please be advised that the principles contained in the Privacy Policy serve to ensure adequate protection of the data collected by the Administrator, including personal data, and apply whenever you use the Administrator’s Website as well as, in any other case, whenever you contact the Administrator. The Administrator declares that in its day-to-day operations it uses and selects the tools it uses with the utmost care, the latest technical knowledge and the principles of professionalism, with a view to protecting personal data and other information obtained from the User.

§ 4 Data collected

  1. The following data is collected during the use of the Site: IP addresses or other identifiers and information collected through Cookies or other similar technologies.
  2. When you fill out the forms available on our site or sign up for the Services we offer, we then collect the data that you provide to us, such as, for example:
    1. name
    2. name
    3. company name
    4. email address/service email address
    5. country
    6. phone number
    7. official position

The exact data needed for the use of specific Services or processed in connection with specific processes are described in the Terms and Conditions for Provision of Services by Electronic Means or in the relevant information clause.

  • Visitors to the Administrator’s Site may browse it without providing the personal information referred to in paragraph 2 above.
  • The rules of data collection in connection with the use of Cookies are described in detail in a separate document – Cookie Policy, which can be found at the link: Cookies Policy.

The collected data are used:

  1. to provide certain Services, where the basis for processing is the consent of the data subject, which he or she has given for one or more specified purposes (legal basis Article 6.1.a RODO);
  2. to provide certain Services, on the basis that the processing is necessary for the performance of the contract or to take action at the request of the data subject prior to entering into the contract (Article 6.1.b RODO);
  3. when the processing is necessary for the fulfillment of a legal obligation incumbent on the Administrator (Article 6.1.c RODO);
  4. when the processing is necessary for the purposes of legitimate interests pursued by the Administrator (Article 6.1.f RODO) such as, for example:
    1. for marketing purposes, including sending commercial information to an e-mail address based on the Administrator’s legitimate interest in marketing its own services and promoting the brand;
    2. for statistical, technical purposes, related to the administration of the Site on the basis of the Administrator’s legitimate interest, which is to ensure the proper operation of the Site, its updating and adaptation to the needs of Users:
    3. in order to maintain the Administrator’s profiles maintained in social media (e.g. Linkedin, Facebook) on the basis of the Administrator’s legitimate interest, which is to inform Users about the Administrator’s activities, promote events, services and products;
    4. for the purpose of establishing and investigating possible claims on the basis of the Administrator’s legitimate interest in protecting the Administrator’s rights.

Exact information on what data is needed to use specific Services or on what legal basis it is processed in connection with specific processes is described in the Terms and Conditions of Providing Services Electronically or in the relevant information clause. Provision of personal data is voluntary, however, it is necessary to perform the Services or fill out the Forms.

§ 6 Rights and Obligations of the User in relation to the processing of personal data

  1. The user, providing his data, is obliged to indicate complete, current and true data.
  2. The User should not provide the Administrator with personal data of third parties. Instead, if he/she provides such data, he/she shall each time declare that he/she has the appropriate consent of third parties to provide the data to the Administrator.
  3. Each User whose personal data is processed by the Administrator has the right:
    1. access to the content of his/her data,
    2. data their correction,
    3. removals,
    4. processing restrictions,
    5. To transfer data,
    6. object to the processing of data on the basis of the legitimate interest of the Administrator,
    7. if the processing is based on Article 6.1.a of the RODO or Article 9.2.a of the RODO. a RODO – the right to withdraw consent at any time, without affecting the lawfulness of the processing carried out on the basis of consent before its withdrawal.
  4. Exercise of the rights set forth in the paragraph above may be exercised by sending an appropriate request to the Administrator’s e-mail address: gdpr@ttpsc.com, along with the name and electronic mail (e-mail) address of the user.
  5. In addition, the User has the right to lodge a complaint to the supervisory authority – the President of the Office for Personal Data Protection (address: 2 Stawki Street, 00-193 Warsaw), in case he/she considers that the processing of his/her personal data violates the provisions of the RODO.

§ 7 Do we share personal data and to whom?

  1. Data may be made available to entities entitled to receive them under applicable law, including the relevant judicial authorities.
  2. Personal data may be transferred to entities processing them on behalf of the Administrator, i.e.: partners providing technical services (development and maintenance of IT systems and websites), entities providing accounting and bookkeeping services, group companies. Precise information on to whom specific data may be transferred is described in the relevant information clause.

§ 8 Transfer of data outside the European Economic Area

As the Administrator operates internationally, it may become necessary to transfer your personal data outside the European Economic Area, in particular to group companies. As entities located outside the European Economic Area do not always provide a level of personal data protection that meets European standards, in situations where the transfer of your data becomes necessary, the Administrator will implement appropriate solutions to protect your rights  and freedoms.

The transfer will take place based on the safeguards allowed under the RODO that is:

  1. to a country for which the European Commission has issued a decision on the adequacy of safeguards in the area of personal data protection (Article 45.1. of the RODO), or
  2. using the standard contractual clauses referred to in Article 46.2.c of the RODO.

§ 9 Security of data collected  by the Administrator

  1. The Administrator has applied all technical and organizational measures to ensure the protection of the processed personal data appropriate to the risks and categories of data under protection, and in particular has secured the data from being accessed by unauthorized persons, from being taken by an unauthorized person, from being processed in violation of the law, and from being altered, lost, damaged or destroyed in accordance with the provisions of the RODO.
  2. After the end of the processing period data are irreversibly deleted or anonymized.

§ 10 Automatic processing

  1. Automated decision-making, including profiling when using communication or marketing tools, may occur in connection with the processing of personal data. Collected data is automatically transferred to a customer relationship management (CRM) system, allowing TT PSC to use such data to analyze user behavior and preferences in order to create more personalized interactions and offers. Through profiling, TT PSC can tailor communications and offers to individual user needs and preferences.
  2. If, in connection with automated decision-making, you receive information that is not of interest to you, you may express your own position or challenge such decision at any time by contacting a representative of the Administrator who is an individual.
  3. If the User does not consent to automatic data processing then he/she can always contact the Administrator by sending an e – mail to: contact@ttpsc.com bypassing the forms available on the Site.

§ 11 Duration of storage of personal data

  1. The data will be kept only for the period necessary to fulfill the purpose for which they were collected, and after that for the period necessary to secure or assert possible claims or fulfill the Administrator’s legal obligation (e.g. under tax or accounting regulations). Details provided in the relevant information clauses.
  2. Personal data processed for the purpose of the Administrator’s legitimate interest in marketing its own products or services will be kept for the period until the User objects.

§ 12 Information Clauses

Information regarding the processing of personal data, depending on the nature of the relationship between the User and the Administrator, is presented in accordance with Article 13 or 14 of the RODO in the relevant information clauses, which are available at the link: GDPR clauses.

§ 13 Final provisions

  1. The site may contain links to the websites of other entities. The Administrator has no influence on the privacy policy of these entities’ websites and is not responsible for it. The user, when navigating to a third-party website, should familiarize himself/herself with the data protection rules applied by the administrator of the respective website.
  2. The privacy policy is continuously reviewed and updated.