Privacy policy (RODO)
Truly Nolen Poland
We strive to protect personal information we collect in accordance with national regulations and
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 (Journal of Laws UE No. L No. 119/1) - hereinafter "RODO".
We provide you with this privacy policy, in which we describe:
who is the administrator of personal data,
to what extent and for what purpose the data is processed,
to whom the data is shared and how it is protected.
1. The scope of the privacy policy. Who is affected?
The privacy policy contains information regarding personal data processing operations performed by
Przeniczka sp. z o.o.. operating under the Truly Nolen Polska brand (hereinafter: Truly Nolen) in
relation to current, former and potential:
a) Business customers,
b) people contacting us through our website trulynolen.pl,
c) service providers,
d) candidates for work and cooperation.
2. Administrator. A contact point.
Truly Nolen processes personal data as their administrator or recipient. Our headquarters is located in
Warsaw at ul. Floriańska 6, 03-707 Warsaw, office at ul. Piłsudskiego 116C, 05-270 Marki.
In matters related to the protection of your data, you can contact us at: biuro@trulynolen.pl
3. What personal data do we collect, for what purpose, how long do we keep the data?
We collect or receive all or part of the following categories of personal information for the following
purposes:
a) if you are our business customer, then in order to perform an order or fulfillment of the contract,
we need such data as: name and surname, business telephone number, company name, tax ID
number, Regon, or function / position. The data will be stored during the cooperation period, and after
its completion, min. for a period of 5 years from the end of the year in which the deadline for payment
of tax in connection with the service provided has expired. In order to get information about our offer,
arrange a phone call and a free inspection, we will need your name, e-mail address or telephone
number to contact you.
b) if you provide us with services based on the contract concluded or for the purpose of providing the
service, we process data such as: name and surname, telephone number, e-mail address, company
name, tax identification number, Regon, or function / position. In contracts, we place data in a
minimum scope, most often it is data available to the public from the National Court Register and
CEiDG. The data will be stored during the cooperation period, and after its completion, min. 5 years
from the end of the year in which the deadline for payment of tax due to the contract concluded or
the service provided has expired.
c) if you are interested in our job offers, we will process your data based on and within the scope
defined in art. 221 of the Labor Code in order to select the right person for a given position and carry
out activities related to the conclusion of the contract or employment. Your data will be stored until
the recruitment process is completed. In the case of the will to establish cooperation based on a civil
law contract, entering data by you is voluntary.
We process your data to the minimum extent that is necessary to achieve one or more goals.
From the data needed to fulfill legal obligations (legal basis: Article 6 (1) (c) of the GDPR) we will use:
a) for the duration of the duties,
b) for a period of time when laws require us to store data (appropriate provisions may provide for
different retention periods).
In our legally legitimate interest, we will process your data in cases (legal basis: Article 6 paragraph 1
point f) of the RODO):
a) correspondence,
b) defining, defending and pursuing claims, which includes sale of our debts to another entity - for the
period after which claims have expired,
c) establishing business cooperation,
d) promotion of our services - pending the objection.
4. Where are your data processed?
We take care that collection, receipt, use, sharing or other operations on your personal data are carried
out in accordance with applicable law, this privacy policy and our internal policies, regulations,
procedures and standards. Truly Nolen has rigorous standards for data access and processing.
Only a group of our authorized or authorized employees will have access to your data due to the need
to have such access. As a rule, we do not forward your personal information to anyone outside of our
company. However, we may share your personal information with trusted third parties (see point 7)
that perform business functions for us or provide us with other services. Such third parties will be
obliged to adequately protect your personal data on the basis of agreements that meet the
requirements of applicable law in this area or on the basis of relevant laws. Your personal data may
also be transferred to relevant public authorities when it results from the law (eg to avoid crime or
fraud or to comply with court order or other legal obligation of a Polish or EU body or court).
5. Who are the recipients of your data?
Sometimes we can share your data with other third parties (see point 7), which support us in
conducting our business. These may be entities that enable us to perform remote payment
transactions, banks, state authorities or other entities authorized under the law.
6. How do we protect your data?
Truly Nolen undertakes to properly protect your personal data in accordance with established internal
policies, regulations, procedures and standards so that personal data is protected against unauthorized
use or access, unlawful modification, loss or destruction. Your personal data will not be stored for
longer than is necessary for the purpose for which it was collected, including the need to comply with
legal obligations and to resolve disputes, assert or defend claims.
7. International transfer of personal data
As we are part of an international franchise network, your personal data may be transferred to a third
country such as the United States. This applies in particular to business processes conducted in
specialized or centralized databases (CRM) located in the United States. In such cases, the recipient of
your data will be Truly Nolen International 1800 33rd St, Orlando FL 32839, United States of America,
SIC 7389-001. The legal basis for the data transfer is an agreement with our company based on the
standard contractual clauses valid for the transfer of personal data after the entry of the RODO to data
processors established in third countries, in accordance with Decision 2010/87 / EU under Directive
95/46 / EC European Parliament and Council.
8. What rights do I have?
You have the right at any time:
a) access to personal data and obtaining copies thereof,
Upon your request, we will provide you with information as to whether we process your personal
information. We are also obliged, on a separate request, to provide more detailed information on:
processing purposes, categories of personal data, recipients or categories, personal data storage
period or criteria for determining personal data, automated data processing and the consequences of
such processing data for your person. In the case of transfer of personal data to a third country, we
will also inform you about the security used.
We will make a copy of your personal information upon your request. It will be made available to you
in the popular IT file format. The first copy will be made available free of charge. However, for each
subsequent payment, we can charge a fee, which we will determine based on the provisions of the
GDPR.
b) the possibility of rectifying, updating and changing it,
If it turns out that your personal details are incorrect, we will remove the irregularities. We will do it
on our own initiative - or, if you pay attention to it - at your request.
a) the right to delete data,
If you do not wish to process personal data and find no other legal grounds that allow us to process
your data - we will remove it from our databases. Remember, however, that deleting some data may
prevent us from providing services to you - this applies to those services in connection with which it is
necessary to process personal data for their implementation. Despite your request for deletion, we
will, however, be able to process certain personal data on the terms set out in the RODO.
b) restrictions on their processing,
In the cases provided by the RODO, we will limit the processing of your personal data at your request.
In the simplest terms, limiting the processing of personal data prevents them from being used outside
of storage. In this case, any other actions on the data subject to processing restrictions may only be
carried out with your consent.
c) transferring part of the data to other organizations,
Under the rules provided in the RODO, you may request the transfer of personal data stored in a
standard machine readable file format. If your goal is to transfer them to another administrator, we
will send you a file containing your personal details directly to him.
d) opposition to certain types of processing of personal data,
In some cases, even if we process personal data in accordance with the law,
without your consent, you can request that we stop processing personal data by filing an objection. It
will be justified if you prove that our lawful actions infringe your interests, rights or freedoms
nevertheless.
e) as well as in the case when we have asked you permission - to withdraw this consent at any time.
Once granted, consent to the processing of information is not granted forever. If for any reason you
change your mind, you can withdraw your consent to the processing of personal data. In this situation,
if we do not have a separate processing basis, we will cease using personal data for the purpose for
which consent has been given. Remember, however, that withdrawal of consent may sometimes result
in the lack of providing you with interesting content or information. You can withdraw your consent at
any time, e.g. via the link in the marketing material you received.
The aforementioned rights may be limited in certain situations, e.g. when we can prove that we are
legally obliged to process your data.
If you want to make use of your rights, all you have to do is send the appropriate request by contacting
us at: biuro@trulynolen.pl
You can also contact us for any questions, comments or complaints with respect to this privacy policy.
However, if you still have any doubts or believe that our activities related to the processing of personal
data have been violated, you can complain to the President of the Office for Personal Data Protection
(2 Stawki Street, 00-193 Warsaw).
9. How do we care about the Privacy Policy?
This privacy policy enters into force on 18/03/2019.
We have a policy of continuous updating and will inform you of any changes by posting the updated
policy on our site.