SECGEN fully understands that your privacy is important to you. We are committed to respecting your privacy and protecting your personal data, which is any information that is capable of identifying you as an individual person.

SECGEN collects the personal information that is provided voluntarily and necessary so that we can offer information and/or services to customers.

This privacy policy describes how we handle and protect your personal data in connection with SECGEN’s business activities.

1. Collection and use of personal information

1.1. What are the purposes of processing your personal data?

From our customers, suppliers or other third parties, as well as individuals representing them or co-operating with us on behalf of those entities, we process data which are necessary in order for us to provide advice and services. It includes but is not limited to: proper identification of contact persons and representatives of our clients or their employees, or co-workers, maintaining business contact, and in the event of potential dispute related to the service/co-operation we might process the personal information for the purpose of solving that dispute. As part of the particular matters and projects, we may process data such as your name, position, contact details or other relevant, necessary data as further defined and set out in the respective matters.

When you use our website, your personal data are collected and subsequently processed for purposes related to individual functionalities of our website:

• newsletter subscription,
• submission of a request for proposal,
• recruitment,
• registration for a specific event or publication,
• ordering marketing information.

When you submit personal information to SECGEN we will use this information in the manner outlined in this privacy policy. Your personal information is not used for other purposes, unless we obtain your permission, or unless otherwise required or permitted by law or professional standards.
In these instances, data is always submitted voluntarily. When you are the employee or co-worker of our clients and you are co-operating with us on its behalf, it might happen that we receive your contact information from our client when appointing its representing persons or persons contacting us on its behalf.

1.2. What are the legal grounds to process your personal data by SECGEN?

Depending on the purpose of the processing of your data, SECGEN proces your data based on the following legal grounds:

• when the processing is necessary to perform the agreement concluded with you or to take steps required by you before concluding the agreement – point (b) of Article 6(1) of 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 (GDPR),
• when you are asked to grant your consent to the processing of personal data for the specific purpose – point (a) of Article 6(1) of the GDPR,
• when we pursue our so-called legitimate interests, e.g. are accepting and answering your inquiry, solving the dispute, maintaining business contacts, identifying representatives, contacts persons or other employees or co-workers of our clients acting on behalf of our clients – point (f) of Article 6(1) of the GDPR,
• processing is necessary for compliance with a legal obligation to which we are subject, e.g. we are required to make available personal data to state authorities – point (c) of Article 6(1) of the GDPR.
  
  Other examples of the ‘legitimate interests’ referred to above are:
  
• to prevent fraud or criminal activity and to safeguard our IT systems,
• to customize individuals’ online experience and improve the performance, usability and effectiveness of SECGEN’s online presence,
• to conduct, and to analyze, our marketing activities (unless such activity requires by law a separate consent).
  

1.3. Are your “sensitive” personal data processed?

SECGEN does not intentionally collect “sensitive” personal data, unless such a duty arises from applicable legal regulations, e.g. for the purposes of recruitment. Sensitive information includes personal data revealing racial or ethnic origin, political opinions, trade union membership, religious or philosophical beliefs, data concerning health or data concerning a user’s sex life, sexual orientation, criminal record, as well as genetic and biometric data.

2. Automatic collection of personal information

In some instances, SECGEN and its service providers uses cookies, web beacons and other technologies to automatically collect certain types of information when you visit us online, as well as through emails that we may exchange. The collection of this information allows us to customize your online experience, improve the performance, usability and effectiveness of SECGEN’s online presence, and to measure the effectiveness of our marketing activities.

Information collected in such a way not always constitutes personal data, i.e. it does not enable us to identify the particular user, but it may happen that connecting an IP address or location information to the specific e-mail of the user will be possible.

2.1. IP addresses

An IP address is a number assigned to your computer whenever you access the internet. It allows computers and servers to recognise and communicate with one another. IP addresses from which visitors appear to originate will be recorded for IT security and system diagnostic purposes. This information will also typically be used in aggregate form to conduct website trend and performance analysis.

2.2. Cookies

Cookies may be placed on your computer or internet-enabled device whenever you visit us online. This allows the site to remember your computer or device and serves a number of purposes.

On some of our web sites, a notification banner will appear requiring your consent to collect cookies. If you do not provide consent, your computer or internet-enabled device will not be tracked for marketing-related activities. A secondary type of cookie referred to as „user-input“ cookies may still be required for necessary functionality. Such cookies will not be blocked through the use of this notification banner. Your selection will be saved in a cookie and is valid for a period of 90 days. If you wish to revoke your selection, you may do so by clearing your browser’s cookies.

Although most browsers automatically accept cookies, you can choose whether or not to accept cookies via your browser’s settings (often found in your browser’s Tools or Preferences menu). You may also delete cookies from your device at any time. However, please be aware that if you do not accept cookies, you may not be able to fully experience some of our web sites‘ features.

Further information about managing cookies can be found in your browser’s help file or through sites such as www.allaboutcookies.org

Below is a list of the types of cookies used on our web sites:

Purpose	Description
Performance (i.e., User’s Browser)	Our website is built using common internet platforms. These have built-in cookies which help compatibility issues (e.g., to identify your browser type) and improve performance (e.g., quicker loading of content). Cookies are deleted upon closing the browser.
Site Preferences	Our cookies may also remember your site preferences (e.g., language) or seek to enhance your experience (e.g., by personalizing a greeting or content). This will apply to areas where you have registered specifically for access or create an account. Cookies are deleted upon closing the browser.
Analytical	We use several third party analytics tools to help us understand how site visitors use our web site. This allows us to improve the quality and content on secgen.eu for our visitors. The aggregated statistical data cover items such as total visits or page views, and referrers to our web sites. Cookies will be automatically deleted after two years if you no longer visit secgen.eu.
Social sharing	We use third party social media widgets or buttons to provide you with additional functionality to share content from our web pages to social media websites and email. Use of these widgets or buttons may place a cookie on your device to make their service easier to use, ensure your interaction is displayed webpages (e.g. the social share count cache is updated) and log information about your activities across the Internet and on our web sites. We encourage you to review each provider’s privacy information before using any such service. Cookies will be automatically deleted after two years if you no longer visit secgen.eu.

Cookies by themselves do not tell us your email address or otherwise identify you personally. In our analytical reports, we may obtain other identifiers including IP addresses, but this is for the purpose of identifying the number of unique visitors to our website and geographic origin of visitor trends, and not to identify individual visitors.

BY NAVIGATING ON OUR WEB SITES OR ENTERING YOUR LOGIN DETAILS TO ACCESS AREAS RESERVED FOR REGISTERED USERS, YOU AGREE THAT WE CAN PLACE THESE COOKIES ON YOUR COMPUTER OR INTERNET ENABLED DEVICE.

2.3. Google Analytics

SECGEN uses Google Analytics. More information about how Google Analytics is used by SECGEN can be found here: http://www.google.com/analytics/learn/privacy.html

To provide website visitors with more choice on how their data is collected by Google Analytics, Google have developed the Google Analytics Opt-out Browser Add-on. The add-on communicates with the Google Analytics JavaScript (ga.js) to indicate that information about the website visit should not be sent to Google Analytics. The Google Analytics Opt-out Browser Add-on does not prevent information from being sent to the website itself or to other web analytics services.

2.4. Adobe Analytics

SECGEN uses Adobe Analytics tools. More information on using Adobe Analytics tools by SECGEN is available at: https://www.adobe.com/pl/privacy.html

2.5. Web beacons

A web beacon is a small image file on a web page that can be used to collect certain information from your computer, such as an IP address, the time the content was viewed, a browser type, and the existence of cookies previously set by the same server. SECGEN only uses web beacons in accordance with applicable laws.

SECGEN or its service providers will use web beacons to track the effectiveness of third party web sites that provide us with recruiting or marketing services or to gather aggregate visitor statistics and manage cookies.

You have the option to render some web beacons unusable by rejecting their associated cookies. The web beacon may still record an anonymous visit from your IP address but cookie information will not be recorded.

2.6. Location-based tools

SECGEN will collect and use the geographical location of your computer or mobile device. This location data is collected for the purpose of providing you with information regarding services which we believe may be of interest to you based on your geographic location, and to improve our location-based products and services.

3. Social media widgets and applications

SECGEN website will typically include functionality to enable sharing via third party social media applications, such as the Facebook Like button and Twitter widget. These social media applications will collect and use information regarding your use of SECGEN website (see details on ‚Social Sharing‘ cookies above). Any personal information that you provide via such social media applications will often be collected and used by other members of that social media application and such interactions are governed by the privacy policies of the companies that provide the application. We do not have control over, or responsibility for, those companies or their use of your information.

4. Children

SECGEN understands the importance of protecting children’s privacy, especially in an online environment. In particular, our sites are not intentionally designed for or directed at children under the age of 16. It is our policy never to knowingly collect or maintain information about anyone under the age of 16, except as part of an engagement to provide professional services.

5. Sharing and authorizing processing of PII

SECGEN does not disclose personal data to unrelated entities, except for situations, when it is necessary in relation to our activities, to carry out your requests, or in situations required or permitted by legal regulations or professional standards. As part of providing our business activities, we may transfer personal data to e.g. tax authorities, other public authorities and financial institutions and pension companies or other third parties. If necessary and based on proper legal grounds, SECGEN will disclose personal information in order to respond to requests of courts, tribunals, government or law enforcement agencies or where it is necessary or prudent to comply with applicable laws, court or tribunal orders or rules, or government or professional regulations.

In certain instances, SECGEN may disclose personal information to external firms, providers of services or sellers operating on our behalf in order to fulfil your requests or provide services for you. SECGEN will only transfer personal information to our third party service providers when they meet strict (GDPR-guaranteed) standards on the processing of data and security.

6. Choices

In general, you are not required to submit any personal information to SECGEN, but we will require you to provide certain personal information in order for you to receive additional information about our services and events. SECGEN will also ask for your permission for certain uses of your personal information, and you can agree to or decline those uses. If you opt-in for particular services or communications, such as an e-newsletter, you will be able to unsubscribe at any time by following the instructions included in each communication. If you decide to unsubscribe from a service or communication, we will try to remove your information promptly, although we may require additional information before we can process your request.

7. Access to data and rights

In a majority of instances, if you provide us with personal data, you have relevant access thereto, which enables you to modify these data and correct any errors in these data. You can also send a request for updating or erasing certain data to dpo@secgen.eu, as a result of which, SECGEN will take relevant steps aimed at fulfilling this request, provided it is consistent with applicable legal regulations.

The GDPR equips you with the following rights with regard to the processing of your personal data:

• right of access to his/her own personal data,
• right to rectification,
• right to erasure/right to be forgotten,
• right to restriction of processing, 
• right to object to processing of personal data,
• right to data portability,
• right to withdraw your consent,
• right to lodge a complaint with the President of the Office for the Protection of Personal Data (UODO).

8. Data security and integrity

SECGEN has reasonable security policies and procedures in place to protect personal information from unauthorized loss, misuse, alteration, or destruction. Despite SECGEN’s best efforts, however, security cannot be absolutely guaranteed against all threats. To the best of our ability, access to your personal information is limited to those who have a need to know. Those individuals who have access to the data are required to maintain the confidentiality of such information.

The period of personal data storage depends on the specific nature and circumstances (especially purpose) of collecting your personal data.

However, personal information processed on the basis of the consent will be anonymized or deleted after you withdraw your consent.

Personal data collected during business relationship, related to our customers or business partners (if physical persons), or their representatives (including appointed contact persons) will be processed for the period of such co-operation, and upon realization thereof there personal data might be stored, if:

• The provisions of law impose on SECGEN an obligation to keep the personal data, including in particular, in order to meet the regulatory requirements concerning SECGEN’s business activity
• The storage of personal data by SECGEN is necessary for the attainment of goals arising out of legitimate interests of SECGEN.

In case of contact persons’ personal data we might process contact details for the purpose and duration of our business relations, unless (if applicable by GDPR), such person files an objection to such processing.

9. Links to other sites

Please be aware that SECGEN website will typically contain links to other sites, including sites maintained by other firms that are not governed by this privacy policy but by other privacy policies that will often differ somewhat. We encourage users to review the privacy policy of each website visited before disclosing any personal information.

10. Changes to this policy

SECGEN may modify this privacy policy from time to time to reflect our current privacy practices. When we make changes to this statement, we will revise the „updated“ date at the top of this page.

11. Policy questions and enforcement

A Data Protection Officer (DPO) has been appointed in SECGEN who can be contacted by e-mail: dpo@secgen.eu or by correspondence to the post address: SECGEN Sp. z o.o. Data Protection Officer (DPO), ul. Aleje Jerozolimskie 53, 00-697 Warsaw. Data Protection Officer is your contact with respect to personal data matters who can also be addressed with any questions or comments concerning the personal data administration. You may also use this address to communicate any concerns you may have regarding compliance with our privacy policy.