Privacy Policy and Cookies

Objective processing

Discussion of the purpose of processing

Legal basis

Newsletter service

By subscribing to the newsletter, you provide your first and last name and email address. Providing this information is voluntary, but necessary to subscribe to the newsletter. 

In addition, the system used to operate the newsletter records your IP address, determines your approximate location, identifies the email client you use to handle your email, and tracks your actions in relation to the messages sent to you. As a result, we also have information about which messages you open, which links you click, etc. 

The data you provide in connection with your subscription to the newsletter is used to send you the newsletter, and the legal basis for its processing is our legitimate interest, which in this case is the pursuit of marketing objectives. 

When it comes to processing information that does not come from you but has been collected automatically by the mailing system, we rely on our legitimate interest in analyzing the behavior of newsletter subscribers in order to optimize our mailing activities. 

You can unsubscribe from the newsletter at any time by clicking on the dedicated link in each message sent as part of the newsletter or simply by contacting us. 

Data related to the newsletter will be processed for the period during which you use the newsletter. Even if you unsubscribe from the newsletter, your data may still be stored in the database for the purpose of identifying returning subscribers. In order to remove your personal data from the newsletter system, please send an email to: legal@materiality.pl.

Article 6(1)(f) of the GDPR

Marketing and remarketing activities

In addition to sending newsletters, we may also carry out other marketing and remarketing activities that will serve to promote our services among recipients and seek new customers. The type of data we will process depends on the nature of our marketing or remarketing activities. 

The basis for processing your personal data for marketing purposes will be either our legitimate interest or your consent, depending on the type of marketing activity we undertake. 

Article 6(1)(a) of the GDPR, Article 6(1)(f) of the GDPR

Sharing data with our partners

In conducting our business, we may establish business relationships with various industry organizations and commercial partners, e.g., to organize a promotional campaign, present you with an offer from our partner, carry out a joint venture, etc. 

The basis for processing your personal data in order to share it with our partners will be either our legitimate interest or your consent, depending on the type of data sharing and the situation in which it is to take place.  

Article 6(1)(a) of the GDPR, Article 6(1)(f) of the GDPR

Collecting and presenting opinions about our services

If you wish to express your opinion about our products or services, we will ask you to provide your first and last name, which will be assigned to your comment, as well as your position or role in the organization. Providing this information is voluntary, but necessary in order to post your review. 

The rating system may be operated by external providers. In such cases, use of the rating system is subject to the terms and conditions and privacy policy of the external provider. 

The opinion you provide, along with your details, may be displayed on our website as a recommendation of our business. 

The basis for processing your personal data for the purpose of posting reviews is our legitimate interest, which in this case is to build the credibility of our business.

Article 6(1)(f) of the GDPR

Correspondence handling

When you contact us via email, you naturally provide your personal data contained in the correspondence, in particular your email address and name. Providing this data is voluntary, but necessary to establish contact. In this case, we rely on our legitimate interest in ensuring that we can contact you. 

Article 6(1)(f) of the GDPR

Creating an archive

For the purposes of our business, we may create archives: both in traditional and digital form. All personal data that we have processed in connection with you is stored in the archives, so their scope may vary depending on the data we have received. In this case, we rely on our legitimate interest in organizing and structuring personal data carriers. 

Article 6(1)(f) of the GDPR

Defense, establishment, or pursuit of claims

Using our website, as well as entering into a contract with us, may give rise to certain claims on our or your part in the future. Therefore, we are entitled to process personal data for the purpose of defending, establishing, or enforcing claims. For this purpose, we may process any personal data that is related to the claim in question, so the scope of such processing may vary depending on the nature of the claim. In this case, we rely on our legitimate interest in protecting our interests. 

Article 6(1)(f) of the GDPR

Social media management

If you follow our profiles on social media or interact with content we publish on social media, we will naturally see your data that is publicly available on your social media profile. We process this data exclusively within the social media platform and solely for the purpose of operating the social media platform, which constitutes our legitimate interest. 

Your use of social networking sites is subject to the terms and conditions and privacy policies of the administrators of those sites, and those administrators provide services to you electronically, entirely independently of us. 

Article 6(1)(f) of the GDPR

Analysis and statistics using only Anonymous Information

We conduct analytical and statistical activities using tools provided by external suppliers. As part of our analytical tools, we only have access to Anonymous Information. We process Anonymous Information based on a legitimate interest, which consists of creating, reviewing, and analyzing statistics related to user activity on the website in order to draw conclusions that will allow us to optimize the website in the future. 

From the tools level, we only have access to statistics and information that is not assigned to specific individuals. 

For detailed information on third-party tools, please refer to the section on the tools we use. 

Article 6(1)(f) of the GDPR

Own marketing using only Anonymous Information

We conduct marketing activities using tools provided by external suppliers. As part of our marketing tools, we only have access to Anonymous Information. We process Anonymous Information based on a legitimate interest, which consists of targeting advertisements within external systems based on Anonymous Information for the purposes of marketing our own products and services. 

From the tools level, we only have access to statistics and information that is not assigned to specific individuals. 

For detailed information on third-party tools, please refer to the section on the tools we use. 

Article 6(1)(f) of the GDPR

Fulfillment of obligations related to personal data protection

As a personal data controller, we are required to fulfill our obligations regarding personal data protection. Therefore, we may process your personal data if it is necessary to fulfill these obligations (e.g., when processing your request regarding your personal data). The scope of data depends on what data we need to fulfill our obligations and prove compliance with the GDPR. 

In addition, we rely on our legitimate interest, which is to secure the data necessary to demonstrate accountability. 

Article 6(1)(c) of the GDPR, Article 6(1)(f) of the GDPR

Fulfillment of obligations related to ensuring digital accessibility

As a business entity, we make sure that our website is user-friendly for older people, people with disabilities, and other users who may need support when using digital resources. To this end, we have implemented appropriate digital accessibility mechanisms on our website.  

If you believe that our website does not provide digital accessibility, you can submit a complaint to legal@materiality.pl. In such a case, we will process your personal data (name and address) in order to consider such a complaint and respond to it.  

The legal basis for processing your personal data is the need to fulfill legal obligations related to ensuring digital accessibility. In addition, we rely on our legitimate interest, which is to secure the data necessary to demonstrate that we comply with digital accessibility requirements. 

Article 6(1)(c) of the GDPR in conjunction with the Polish Act on Accessibility, Article 6(1)(f) of the GDPR

Transfer of personal data within the Administrator's group of companies

The personal data administrator may create a group of companies, i.e., entities linked by personal or capital ties, where there is a controlling entity and controlled entities. Within a group of companies, there may be a need to pursue internal administrative objectives, e.g., in the form of managing available ICT systems. To this end, entities belonging to the group of companies may share your personal data with other entities within the group of companies. 

The legal basis for such processing of personal data is our legitimate interest related to the fulfillment of specific administrative purposes. 

Article 6(1)(f) of the GDPR

Preventing abuse on the website (in particular, anti-fraud mechanisms)

Due to growing cyber threats, including emerging attacks (e.g., bots), we may implement mechanisms to counteract these threats and adverse effects—both for us and our users. In such cases, we may process both Anonymous Information (data related to your activity on our website) and data assigned to you (e.g., your email address).  

The legal basis for such processing of personal data is our legitimate interest in protecting our financial and non-financial interests against unlawful activities. 

Article 6(1)(f) of the GDPR

Conducting ongoing recruitment processes

In connection with the recruitment process, you must provide us with certain personal data so that we can consider your application. If you are applying for employment, the scope of personal data required is specified in the Labor Code. For recruitment purposes, you must provide us with your first name(s) and surname; date of birth; contact details (e-mail address, telephone number), and, if necessary for the performance of a specific type of work or a specific position, also information about your education, qualifications, and employment history. Such personal data is processed for the purpose of fulfilling the legal obligations provided for in the Labor Code, as well as for the purpose of concluding an employment contract.   

If the recruitment process is aimed at establishing cooperation under a civil law relationship, the basic data will be processed for the purpose of conducting the current recruitment process and concluding a civil law contract (Article 6(1)(b) of the GDPR).  

In the case of data provided voluntarily by the candidate, it will be processed on the basis of consent (Article 6(1)(a) of the GDPR, Article 9(2)(a) of the GDPR).  

Providing your data is voluntary, but necessary to participate in the current recruitment process.  

Article 6(1)(c) of the GDPR in conjunction with the provisions of the Labor Code, Article 6(1)(b) of the GDPR

Storing data for future recruitment purposes

If you intend to participate not only in the current recruitment process, but also in future recruitment processes that we will conduct, you may consent to the storage of your personal data for the purpose of considering your application in future recruitment processes.  

If you give your consent, we will process the personal data you provided when applying to us. The legal basis for data processing is primarily your consent (Article 6(1)(a) of the GDPR). If we wish to consider your application in a future recruitment process, we will process your data in order to fulfill our obligations under the Labor Code (Article 6(1)(c) of the GDPR) or for the purposes of concluding a civil law contract (Article 6(1)(b) of the GDPR). 

Consent to participate in future recruitment processes is not mandatory.  

Article 6(1)(c) of the GDPR in conjunction with the provisions of the Labor Code, Article 6(1)(a) of the GDPR

Fulfillment of employment-related obligations

In connection with the search for employees and associates, we also perform various duties related to establishing employment, storing documentation, etc. Among other things, we must prepare a draft contract for you, as well as any other documents and statements that are required by law or our internal procedures. In addition, if you are a foreigner, Polish law may require us to report to the relevant state authorities and complete other formalities related to the employment of foreigners.  

The legal basis for the processing of your personal data is Article 6(1)(c) of the GDPR in conjunction with the relevant provisions of labor law, Article 6(1)(b) of the GDPR, as well as our legitimate interest, which in this case is the efficient and effective conduct of the recruitment process.   

Providing the data required by labor law is necessary for the performance of the specified duties.  

Article 6(1)(c) of the GDPR in conjunction with the relevant provisions of labor law, Article 6(1)(b) of the GDPR, Article 6(1)(f) of the GDPR