Informations sur le traitement des données personnelles par les sociétés du groupe Comarch

The joint controllers of your personal data are the Comarch Group companies. For an up-to-date list of the Comarch Group companies and theirs contact details, go to: 

The Comarch Capital Group structure>>and Worldwide Offices >>

Pursuant to Article 27 of GDPR, the Comarch Group companies established outside the EU have designated Comarch S.A., with its registered office at Al. Jana Pawła II 39 A, 31-864 Kraków, as their representative.

Any inquiries or requests related to the processing of personal data by the Comarch Group should be directed to us using the contact details provided below:

Comarch S.A.
Al. Jana Pawła II 39 A
31-864 Kraków
Poland

gdpr@comarch.com
telephone: +48 (12) 64 61 000

The Comarch Group companies may receive contact details directly from the data subject (for instance, via electronic forms or during conferences) or through other persons (e.g. from the employer, another employee or other entity with whom that person cooperates on a permanent basis).

In the case of direct contact, you will have full control over the scope of data made available to the Comarch Group companies.

In the case of data provided by another person, the Comarch Group companies usually collect only the main contact details connected with the data subject’s professional activity, including: the name, surname, email address, telephone number, job title or position, company and potentially other data in accordance with the contract or order under which the contact person’s personal data is being provided.

Personal data are processed by Comarch Group companies for the purposes specified below.
For each purpose, we have provided the relevant legal basis for data processing and criteria for determining the data processing period.

I.
PURPOSE: contract performance or order execution, LEGAL BASIS: Article 6.1.b) of GDPR
PROCESSING PERIOD: the period of performing the relevant obligations and the statutory period of limitation of claims

In the case of a contract or order between you and a Comarch Group company, the data provided by you will be processed for the purpose of performing that contract or executing that order and for settlement purposes.

In the case of electronic forms used to download/order a file (e.g. an e-book, demo, report, etc.), the provided data will be processed in order to deliver the ordered file and for related contact and settlement purposes.

In the case of electronic forms used to sign up for a conference, training or other event organised by a Comarch Group company, the provided data will be processed in order to organise the event and for related contact and settlement purposes.

II.
PURPOSE: business contacts, LEGAL BASIS: Article 6.1.f) of GDPR
PROCESSING PERIOD: until your objection submitted under Article 21 of GDPR is granted
    
Contact data entered into any electronic form, made available under a contract or order, or made accessible otherwise to Comarch Group company, may be processed for business contact purposes.

On this basis, representatives of the Comarch Group may contact you to present an offering of a Comarch Group company’s products or services, invite you to a meeting or event organised by a Comarch Group company or for other marketing purposes. You may occasionally receive information on the products, services or activities of the Comarch Group, as well as other information related to the Comarch Group’s business.

If you are a representative of a supplier or service provider, representatives of the Comarch Group companies may also contact you to request a business proposal, information or documents.

If this is the case, your data will be processed to pursue the legitimate interests of the controller, namely the marketing and sale of its products and services as well as building and maintaining of business relations.

You have the right to object to such processing of your personal data in accordance with the RIGHTS OF DATA SUBJECT section.

III.
PURPOSE: newsletter, LEGAL BASIS: Article 6.1.a) of GDPR
PROCESSING PERIOD: until you unsubscribe from the newsletter (withdraw consent)

If you give your consent to receiving a newsletter from the Comarch Group companies, your email address will be used to send you our newsletter. The newsletter will be sent to you with the frequency determined by the marketing department, so as to ensure you have access to up-to-date information on the offering and activities of the Comarch Group companies, and other information regarding the Comarch Group’s business.

Please note that, irrespective of your consent to receiving the newsletter, the controllers may have lawful basis to process your data for the purpose of business contacts in pursuance of their legitimate interests (in accordance with par. II).

IV.
PURPOSE: reply to your inquiry, LEGAL BASIS: Article 6.1.a) of GDPR
PROCESSING PERIOD: until you cancel your inquiry (withdraw consent)

If you fill out a contact form or submit an inquiry otherwise (for instance, by email, telephone or social networking site), then you consent to being contacted with regard to your request or inquiry. To withdraw consent, please use the contact details given in the CONTACT DETAILS FOR MATTERS RELATED TO PERSONAL DATA section. Your consent may be withdrawn at any time; its withdrawal will not, however, affect the lawfulness of data processing prior to the consent being withdrawn, but such withdrawal will result in a lack of reply to your inquiry.

V.
PURPOSE: organisation and promotion of events, LEGAL BASIS: Article 6.1.f) of GDPR
PROCESSING PERIOD: the period of performing the relevant obligations and the statutory period of limitation of claims, or until your objection submitted under Article 21 of GDPR is granted

In the case of signing up for a conference, training or any other event organised by a Comarch Group company, the data provided may be transferred to other participants, speakers, hotels and other entities involved in the organisation of that event. Information on the speakers may also be made publicly available on the website, in the event app, and in promotional and conference materials.

If this is the case, your data will be processed to pursue the controller’s legitimate interests, namely the performance of contracts and other obligations as well as event-based promotion.

You have the right to object to such processing of your personal data in accordance with the RIGHTS OF DATA SUBJECT section.

VI.
PURPOSE: performance of contracts or execution of orders between a Comarch Group company and a third party, LEGAL BASIS: Article 6.1.f) of GDPR
PROCESSING PERIOD: the period of performing the relevant obligations and the statutory period of limitation of claims, or until your objection submitted under Article 21 of GDPR is granted

If you are indicated by your employer or other entity as a contact person, your data may be processed for the purpose of performing and settling a contract (or order) between a Comarch Group company and your employer or such other entity. In this case, data processing will involve ongoing contacts related to the contract performance, preparation and retention of contract performance documents, as well as exercise and defence of any legal claims.

Your data will be processed to pursue the controller’s legitimate interests, namely the safeguarding of rights, performance of contracts and receiving due compensation.

You have the right to object to such processing of your personal data in accordance with the RIGHTS OF DATA SUBJECT section.

VII.
PURPOSE: cooperation with a partner of the Comarch Group, LEGAL BASIS: Article 6.1.f) of GDPR
PROCESSING PERIOD: the period of performing the relevant obligations and the statutory period of limitation of claims, or until your objection submitted under Article 21 of GDPR is granted

If you are interested in a product or service distributed through a network of the Comarch Group’s partners, your personal data will be made available to a dedicated partner. This applies if you are a potential or existing client of a Comarch Group company, and if your employer or business partner is/will be a party to a contract or order with a Comarch Group company.

If this is the case, your data will be processed to pursue the controller’s legitimate interests, namely the performance of contracts, business growth and development of a network of partners.

You have the right to object to such processing of your personal data in accordance with the RIGHTS OF DATA SUBJECT section.

VIII.
PURPOSE: contacts with the media and media promotion of the activities, products and services of the Comarch Group, LEGAL BASIS: Article 6.1.a) of GDPR
PROCESSING PERIOD: until you express a wish to discontinue contacts (withdraw consent)

In the case of journalists, editors, reporters and other persons involved in journalism, personal data will be processed for the purpose of maintaining contacts between representatives of the Comarch Group companies and the media, and to promote the activities, services and products of Comarch Group companies in the media. In particular, this may include informing the media of important events, activities, products and services, as well as achievements of the Comarch Group companies.

Contact with a representative of Comarch Group company will be treated as consent to such contacts. If you consent to such contacts, your consent is voluntary and may be withdrawn at any time. To that end, please use the contact details given in the CONTACT DETAILS FOR MATTERS RELATED TO PERSONAL DATA section. Withdrawal of your consent will not affect the lawfulness of data processing before its withdrawal.

IX.
PURPOSE: fulfilment of the legal obligation to prepare and retain documents,
LEGAL BASIS: Article 6.1.c) of GDPR
PROCESSING PERIOD: the retention period for invoices, accounting records and documents confirming the conclusion and performance of contracts, arising from the controller’s national laws.
    
If a contract is performed, order is executed or other service is provided to you, we will also process your personal data included in invoices, accounting records or other documents confirming the contract’s conclusion and performance in order to draw up and retain the necessary documents as required by applicable laws. This applies in a situation where you are a party to the contract or order, where your employer or business partner is a party to the contract or order, or where any service (for instance hotel booking) has been provided to you.

X.
PURPOSE: confirming the fulfilment of obligations, and exercise or defence of legal claims,
LEGAL BASIS: Art. 6.1.f) of GDPR
PROCESSING PERIOD: the period of performing the relevant obligations and the statutory period of limitation of claims

Data entered into any electronic form, made available under a contract or order, or made accessible otherwise to Comarch Group company may be processed for purposes related to retention of information or documents confirming the fulfilment of obligations by a Comarch Group company and for the purpose of exercising or defending any legal claims by a Comarch Group company. This applies in a situation where you are a party to the contract or order, where your employer or business partner is a party to the contract or order, or where a Comarch Group company was required, on whatever basis, to perform a service for you or to exercise your rights.

If this is the case, your data will be processed to pursue the controller’s legitimate interests, namely the safeguarding of rights, confirming the fulfilment of obligations and receiving due compensation.

You have the right to object to such processing of your personal data in accordance with the RIGHTS OF DATA SUBJECT section.

CONSEQUENCES OF FAILURE TO PROVIDE DATA

UNSUBSCRIBING FROM THE NEWSLETTER

RIGHTS OF DATA SUBJECT

RECIPIENTS, DATA TRANSFERS TO THIRD COUNTRIES

AUTOMATED DECISION-MAKING

LEGAL NOTE