PRIVACY POLICY
I. General Information
This Privacy Policy has been issued by the Personal Data Controller, MBH Sp. z o.o. S.K., with its registered office in Warsaw at al. Jana Pawła II 22, 00-133 Warsaw, entered into the Register of Entrepreneurs maintained by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under KRS number: 0000661808, NIP: 5252697173, REGON: 366489463.
This Policy is addressed to all users (hereinafter referred to as “Users”) of our website (hereinafter referred to as the “Website”). Definitions used in this Policy are explained in Section XII below.
The Data Controller is MBH Sp. z o.o. S.K., with its registered office in Warsaw. The Controller’s contact details are provided in Section XI below.
This Privacy Policy may be amended or updated to reflect changes in the Controller’s personal data processing practices or changes in applicable law. Users are encouraged to review this Policy carefully and to check this page regularly to verify any updates introduced by the Controller in accordance with this Policy.
II. Processing of Users’ Personal Data
Collection of Personal Data
The Controller may collect Users’ Personal Data such as first name, last name, address, and contact details, including email address and telephone number, as well as job title and company details. Personal Data may be collected, in particular, in the following cases:
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when Users provide Personal Data directly (e.g. via email, telephone, or other means of contact);
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as a result of conducting business relationships;
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from Users’ publicly available social media profiles (to the extent such information is publicly accessible);
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from third parties (e.g. contractors or business partners);
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when Users are asked to provide Personal Data during visits to the Controller’s websites or when using any features or resources available on or through the Website.
When Users visit the Website, their devices and browsers may automatically disclose certain information (such as device type, operating system, browser type and settings, IP address, language preferences, dates and times of connection, and other technical communication data), some of which may constitute Personal Data. During visits to the Website, no Personal Data will be stored by the Controller without the Users’ prior explicit consent. Temporary storage of log files and cookies facilitates the use of the Website; therefore, Users are requested to grant consent for such processing. Granting such consent is voluntary and does not affect the ability to use the Website; however, in some cases, failure to provide consent may limit certain functionalities of the Website.
Processed Personal Data
The categories of Personal Data processed by the Controller may include, in particular:
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Personal details: first name(s), last name(s), preferred name, gender, nationality, image/photo;
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Contact details: telephone number, email address, social media profile details;
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Communication content: all messages, inquiries, statements, opinions, and feedback submitted by Users or published on social media or via the Website.
Legal Bases for Processing
Depending on the circumstances, the Controller processes Personal Data on one or more of the following legal bases:
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the User has given prior, voluntary, specific, informed, and unambiguous consent;
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processing is necessary for the performance of a contract concluded or to be concluded with the User;
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processing is necessary to comply with a legal obligation incumbent on the Controller;
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processing is necessary to protect the vital interests of any natural person;
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processing is necessary for the purposes of managing, conducting, and promoting the Controller’s business activities and does not prejudice the interests or fundamental rights and freedoms of the User.
Purposes of Processing
The Controller may process Users’ Personal Data for the following purposes:
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Website operations: managing and administering the Website, presenting its content, publishing advertisements and promotional or marketing information;
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Provision of services: presenting the Website and other services offered by the Controller;
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Communication and IT operations: managing communication systems, ensuring IT security, and conducting IT security audits.
III. Disclosure of Personal Data to Third Parties
The Controller may disclose Users’ Personal Data to:
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administrative authorities or courts, upon request, in connection with actual or suspected violations of law;
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auditors, legal advisors, and PR agencies, subject to contractual or statutory confidentiality obligations;
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third-party data processors acting on behalf of the Controller, regardless of their place of establishment, in accordance with the requirements set out in this Policy;
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competent authorities for the purposes of preventing, investigating, detecting, or prosecuting criminal offenses or executing criminal penalties, including safeguarding and preventing threats to public security;
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any acquiring entity in the event of a sale or transfer of all or part of the Controller’s business or share capital (including reorganization, dissolution, or liquidation).
The Website may use plugins or content provided by third parties. If Users choose to use such plugins or content, their Personal Data may be disclosed to third parties or social media platforms. Users are therefore encouraged to review the privacy policies of such third parties before using their services.
Currently, the Website includes links to the following social media platforms:
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Facebook (https://www.facebook.com/ManagerBusinessHub/)
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LinkedIn (https://pl.linkedin.com/company/managerbusinesshub)
Where a third party is engaged to process Personal Data on behalf of the Controller under a data processing agreement, such processor will be obliged to:
(i) process Personal Data solely in accordance with the Controller’s documented instructions; and
(ii) implement appropriate measures to ensure confidentiality and security of Personal Data and compliance with applicable law.
IV. International Transfer of Personal Data
At present, the Controller does not transfer and does not intend to transfer Users’ Personal Data to third countries outside the European Union or to international organizations. Should such a transfer become necessary, this Policy will be amended accordingly, and Personal Data will be transferred only on the basis of standard contractual clauses implemented by the Controller prior to such transfer. In such cases, Users will be entitled to request a copy of the applicable standard contractual clauses using the contact details provided in Section XI.
V. Data Security
The Controller has implemented appropriate technical and organizational measures to protect Personal Data, including safeguards against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, unauthorized access, and other unlawful or unauthorized forms of processing, in accordance with applicable law.
The Controller is not responsible for actions or omissions of Users. Users are responsible for ensuring that Personal Data transmitted to the Controller is sent in a secure manner.
VI. Data Accuracy
The Controller takes all reasonable steps to ensure that:
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the Personal Data processed is accurate and, where necessary, kept up to date;
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any Personal Data that is inaccurate, having regard to the purposes for which it is processed, is erased or rectified without undue delay.
The Controller may request confirmation from Users regarding the accuracy of the processed Personal Data at any time.
VII. Data Minimization
The Controller takes all reasonable steps to ensure that the scope of Personal Data processed is limited to what is adequate and necessary for the purposes specified in this Policy.
VIII. Data Retention
The criteria for determining the retention period of Users’ Personal Data are as follows: Personal Data is retained in an identifiable form only for as long as necessary to achieve the purposes set out in this Policy, unless a longer retention period is required by applicable law. In particular, the Controller may retain Personal Data for the period necessary to establish, exercise, or defend legal claims.
IX. Users’ Rights
In accordance with the GDPR, Users whose Personal Data is processed by the Controller are entitled to the following rights:
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the right of access to Personal Data;
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the right to rectification;
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the right to erasure;
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the right to restriction of processing;
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the right to data portability;
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the right to object to processing;
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the right not to be subject to decisions based solely on automated processing.
Where processing is based on User consent, Users have the right to withdraw such consent at any time, without affecting the lawfulness of processing carried out prior to withdrawal.
In the event of unlawful processing of Personal Data, Users have the right to lodge a complaint with the competent supervisory authority, i.e. the President of the Personal Data Protection Office.
These rights do not affect any other rights available to Users under applicable law.
To exercise any of the above rights or to obtain further information regarding this Policy or the processing of Personal Data, Users may contact the Controller using the contact details provided in Section XI below.
X. Cookies
A cookie is a small file placed on a User’s device when visiting a website (including this Website). Cookies record information about the device, browser, and, in some cases, User preferences and browsing behavior. The Controller may process Personal Data using cookie technology in accordance with the Cookie Policy described in this Privacy Policy and the applicable information obligations.
XI. Contact Details
If you have any questions, concerns, or comments regarding this Privacy Policy or any matters related to the processing of Personal Data by the Controller, including the exercise of rights referred to in Section IX, please contact us at:
marketing@managerbusinesshub.pl
XII. Definitions
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Controller – the entity that determines the purposes and means of processing Personal Data and is responsible for compliance with applicable data protection laws.
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Personal Data – any information relating to an identified or identifiable natural person. Examples of Personal Data processed by the Controller are listed in Section II above.
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Processing – any operation or set of operations performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination, alignment or combination, restriction, erasure, or destruction.
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Processor – any person or entity that processes Personal Data on behalf of the Controller (other than an employee of the Controller).