In accordance with the principle of transparency and Regulation No. 679/2016 of BYTECOM Ltd. as a personal data controller, we provide you with information on how we use, share and store your personal data.

In certain cases, BYTECOM Ltd is the processor of personal data, in which case the processing is only for the purposes assigned to it, in the manner and by the means indicated to it by the controller and in compliance with the technical requirements set by the controller.

Who are we?

BYTECOM Ltd. is a legal entity, registered in the Commercial Register at the Registry Agency with UIC 104606886, registered office and registered address in the city of Warsaw. Veliko Tarnovo, ul. "Tsanko Tserkovski" No. 38, inc. „G“, floor 2.

How can you contact us?

You can contact us in your preferred and convenient way, namely: by email - office@bytecombg.com or by phone 062/606 206.

To whom does this Transparency Policy apply?

The Transparency Rules for the processing of personal data apply to:

- Our customers;

- Our contractors;

- Visitors to the website;

- Processing of personal data on the basis of consent.

 

CUSTOMERS

What data do we collect about our customers?

The data we collect about our customers is determined by the parameters of the specific enquiry or contract.

How do we collect our customers' personal data?

The way we collect your personal data is directly from you and the documents you provide to us. We may also receive your personal data from other parties, including municipal, state and/or other private entities, in the course of contract performance.

Purpose of the processing of customers' personal data?

If you are our customer, you should know that the purpose for which we process your personal data is the conclusion of a contract or the performance of an already concluded contract, as well as the performance of an existing legal obligation for BYTECOM Ltd.

Exceptionally, we process personal data of customers in order to protect the legitimate interest of BYTECOM Ltd. or a third party.

On what basis do we process our customers' personal data?

The basis on which we process customers' personal data is on the basis of an existing pre-contractual or contractual relationship respectively.

In certain cases, we process personal data of customers in fulfilment of a legal obligation or on the basis of a legitimate interest of BYTECOM Ltd or of a third party.

To whom do we provide the personal data of our customers?

BYTECOM Ltd provides the personal data of its customers to third parties only insofar as this is necessary for the performance of the contract or applicable law.

For the purposes of accounting document preparation, BYTECOM Ltd. provides personal data to an accounting firm.

It is possible to provide personal data of clients to third parties in connection with their statutory powers - state and/or municipal authorities, as well as private entities to which certain rights and/or obligations are attributed by virtue of the legislation (including the NRA, judicial or executive authorities, notaries, lawyers, bailiffs, etc.).

For how long do we keep our customers' personal data?

Customer data is stored for a period of 10 years from 1 January of the accounting period following the accounting period in which the debt became due. The storage is for financial accounting and tax reporting purposes.

All other personal data, the storage of which is not justified for the purpose of financial accounting and tax reporting, shall be stored for a period of 5 years from the end (termination/cancellation, etc.) of the contract.

After the expiry of these periods, the paper data shall be destroyed and the electronic data shall be deleted.

 

CONTRACTORS

What personal data do we collect?

The data we collect about our contractors is in the category of ordinary personal data and is only necessary for the purposes of performing the contract existing between us and complying with the requirements of applicable law.

 

How do we collect the personal data of our counterparties?

The personal data of BYTECOM Ltd's counterparties is collected directly from the counterparties.

 

For what purpose do we process the personal data of our counterparties?

If you are our counterparty, the purpose for which we process your personal data is to enter into a contract or to perform a contract already entered into and to fulfil an existing legal obligation for BYTECOM Ltd.

In certain cases, we may process your personal data in order to protect a particular legitimate interest.

 

On what basis do we process your personal data?

The basis for processing your personal data is the pre-contractual or contractual relationship existing between us or the performance of a legal obligation. Exceptionally, it is permissible to process your personal data on the basis of the legitimate interest of the Controller or of a third party.

 

To whom do we provide your personal data?

BYTECOM Ltd. provides the personal data of its contractors to third parties only if this is necessary for the conclusion or performance of an already concluded contract (e.g. bank, courier company, accounting firm, etc.), and if the latter is necessary for the performance of a legal obligation.

 

For how long do we keep the personal data of our contractors?

The data of counterparties is stored for financial and accounting purposes for a period of 10 years from 1 January of the accounting period following the accounting period in which the obligation became due. Data relating to the performance of the contract shall be destroyed after 5 years from the date of archiving.

After the expiry of those periods, the paper data shall be destroyed and the electronic data shall be deleted.

WEBSITE VISITORS

What personal data do we collect about website visitors?

BYTECOM Ltd does not collect personal data of visitors to the website. When someone visits the Administrator's website, the information that is collected is related to visitor behavior patterns. We do this to find out the number of visitors to different parts of the site. This information is only processed in a way that does not identify the subject. We do not attempt to find out the identity of visitors to our website.

In the event that you submit an enquiry via the contact form on the site, your personal data is transmitted via secure channels and received directly to the administrator's email. No one except the recipient of the email has access to your request and therefore the data provided with it.

We use cookies for the normal functioning of the site, more information about the cookies used can be obtained from the Cookie Policy.

In the event that you place an order, create an account or send an enquiry via the site, you should note that all data is processed via secure links and cannot be accessed by third parties, and the rules for processing personal data of customers, contractors, etc. will be followed according to the nature of the user activity.

 

PROCESSING OF PERSONAL DATA BASED ON CONSENT.

In the event that personal data of any of the aforementioned categories of persons is processed on the basis of consent, the latter must be obtained in advance, be in writing (or electronic) and be explicit /for specified purposes/. Consent for the processing of personal data of a person under 14 years of age shall be given by the data subject's custodial parent or guardian.

Consent may be withdrawn at any time by submitting a written request in accordance with the procedure described in the Exercise of Rights section of this policy.

Consent is not a prerequisite for entering into a contract or a reason for its termination. It is always the result of the free discretion of the data subject.

 

RIGHTS OF DATA SUBJECTS

In relation to the processing of your personal data, it is important for us to inform you that you have a set of rights which you are free to exercise whenever you deem it necessary by contacting BYTECOM Ltd as the data controller with the relevant request.

 

The right of access

What is the right of access to personal data?

On the basis of the right of access, we inform you whether we process your personal data, what categories of personal data we process and in what way, on what basis we do so, for how long we will process them, and whether we disclose them to others.

Are we always obliged to comply with your request?

Access may be refused if your request is manifestly unfounded.

Access may also be refused if your personal data contains the personal data of third parties, unless the third parties have expressly consented to us providing you with their data.

What will you receive in response to your request?

If we consider that your request is justified and that granting it would not affect the personal data of third parties (or there is their consent) you will receive a response that contains information on the criteria set out above.

If there is a reason for refusal, we will provide you with information about the reason for refusal.

 

Rectification of personal data

What is the right of rectification to personal data?

The right to rectification of personal data enables inaccurate or no longer relevant data to be rectified.

You may also exercise this right in cases where it is necessary to supplement your personal data in view of the purposes for which it was provided to us.

How can you exercise your right to rectification of personal data?

You can exercise your right to rectification of personal data processed by BYTECOM Ltd by submitting a request. You can use the form available on the Controller's website or submit a request in free text.

In the request for rectification or completion of data, you need to indicate which specific data you consider incorrect, how it should be rectified or completed, and attach relevant evidence, if any.

What will you receive in response to your request?

In the event that we consider that your request should be granted, we will take the necessary steps to correct your personal data in the manner in which you have stated that this should be done.

If there is a reason for refusal, we will provide you with information about the reason for refusal.

Erasure of personal data

What is the right to erasure of personal data?

The right to erasure of personal data, or more commonly known as the right to be forgotten, enables you to request the Administrator to erase your personal data once it is no longer necessary for the purposes for which BYTECOM Ltd. collects and processes it.

When can you ask for your personal data to be deleted?

You can exercise your right to have your personal data erased if:

- Your personal data is processed on the basis of your consent and you decide to withdraw it;

- you no longer wish your data to be processed for marketing purposes;

- you believe that the processing is unlawful.

Will your request always be granted?

The right to be forgotten is not absolute, so BYTECOM Ltd reserves the right to refuse your request if the processing is:

- on a lawful basis;

- for the establishment, exercise and defence of legal claims;

- for the purposes for which it was collected or otherwise processed;

- for scientific, research and statistical purposes, or if it is carried out in the public interest.

Also, if your request is manifestly unfounded, we reserve the right to refuse to delete your data.

What will you receive in response to your request?

If we refuse your request, you will receive our reasons for this decision.

If the conditions for granting your request are met, the same will be fulfilled.

 

Restriction of processing of personal data

What is the right to restrict the processing of personal data?

The right to restrict the processing of personal data enables the data subject to restrict the way in which their personal data is processed if they have doubts about the accuracy of the data or the way in which it is used.

Does the right of restriction prohibit the controller from processing the personal data?

The exercise of this right does not affect the Controller's right to process your personal data in any of the following ways:

- continue to store your personal data;

- use it for the establishment, exercise and defence of legal claims;

- to protect the rights of others;

- an important public interest so requires.

What constitutes restriction of processing?

A restriction on the processing of your personal data is usually temporary, for the following periods:

- If you contest the accuracy of your personal data - the processing of your personal data is restricted until it is clarified whether the request to correct is justified;

- If you object to the processing of your data on the grounds of public or legitimate interest - the processing of your personal data is restricted while the review is ongoing, which will assess whose interest is paramount.

The restriction may not be temporary but may be in relation to a particular type of processing.

If the restriction is temporary, the Controller is obliged to inform you before it is lifted.

Is the data controller always obliged to comply with your request?

The controller is obliged to comply with your request if:

- it no longer needs your data for the purposes of processing it, but you need it in order to establish, exercise or defend legal claims;

- you believe that we are processing your data unlawfully but you do not want it to be deleted;

- it has provided your data to third parties, it is obliged, as far as possible and would not cost us a disproportionate effort, to inform them of your request.

If we consider that your request for restriction is manifestly unfounded, we reserve the right to refuse to restrict the processing of your data and we will inform you of our refusal with reasons.

Portability of personal data

What is the right to data portability?

BYTECOM Ltd., as a personal data controller, provides you with the opportunity to exercise your right to data portability in cases where your personal data is processed in an automated manner based on your consent or the processing is necessary for the performance of a contractual obligation. On the basis of this right, you will be able to obtain your personal data or have them transferred directly to another data controller of your choice.

You have the right to request to receive your personal data in a structured and commonly used machine-readable format and to transfer it to another controller or, where technically feasible, to request that we directly transfer it to a controller of your choice.

Is the data controller always obliged to comply with your request?

The right to data portability is not absolute. The right to data portability applies where:

- the processing is based on consent or is necessary for the performance of a contractual obligation, and there is automated processing of personal data.

What happens to my personal data after the request for data portability is granted?

The controller does not delete your personal data, but stops processing them for the purposes for which they were provided to it.

 

Objection to processing of personal data

What is the right to object to the processing of personal data?

The right to object enables you to object to the processing of your personal data for certain purposes.

Can you always object to the processing of your personal data?

You can only object to processing where the Data Controller processes it:

- on the grounds of legitimate interest, whether that is the legitimate interest of the Data Controller or of a third party;

- for scientific or historical research purposes or statistical purposes;

- for direct marketing purposes (including profiling).

 

Exercise of rights

How can you exercise the rights listed?

You may exercise any of the rights listed by submitting a written request to the Data Controller.

How is the request made?

You can use the application form for the relevant right or submit a free text request.

Where is the application form located?

The form is available at the office of the Data Controller, at the address of the Data Controller in the city of Warsaw. Veliko Tarnovo, ul. "Tsanko Tserkovski" No. 38, entrance no. „G“, floor 2

What should the application in free text contain if you prefer to address the Administrator in this way?

In your request you need to provide your name and address, as well as other identifying data if you deem it necessary, a description of your request, your preferred form of communication, date and signature.

If you are acting as an authorized person, you will need to attach the appropriate authorization to your request.

Where should the request be submitted?

The request can be submitted on site at the office of BYTECOM Ltd. Veliko Tarnovo, ul. "Tsanko Tserkovski" No. 38, entrance no. „G“, floor 2, as well as submit by courier or by post to this address.

You can submit your completed application or request in free text and by email to: office@bytecombg.com. 

How will you know the outcome of your submission?

You will be contacted by the method you provide - email or address. In the event that you do not explicitly indicate a method of communication - email or address, the Administrator will contact you in the manner it deems most convenient for efficiency. If you have only provided an email, or only an address, we will contact you via the communication method you have provided.

Is it possible for me to request additional documents/data?

In order to protect the rights of the data subject, it is possible that you may be asked for additional documents or data to ensure that there is no abuse of a right. The additional data or documents requested will not be processed in a manner, by means and for purposes other than to identify the data subject and the person making the request for the exercise of rights.

How long will you wait for a response?

BYTECOM Ltd. is a data controller with a strong commitment to data protection, which is why we make every effort to respond to requests as quickly as possible. However, we would like to inform you that the statutory time limit is up to 1 month from the submission of the request.

REMEDIES

What should you do if you are not satisfied with the Administrator's response or if you believe your rights have been violated?

If you believe that your rights under Regulation 2016/679 and the Data Protection Act have been violated, you have the right to refer the matter to the Data Protection Commission.

The Commission will examine your case and inform you of the outcome.

Once it has issued a decision, the Commission will send you a copy of the decision, which you have the right to appeal against in court under the rules of the Administrative Procedure Code.

You also have the possibility to appeal to the relevant administrative court or the Supreme Administrative Court under the rules laid down in the Code of Administrative Procedure.

 

You may not appeal to the courts if there are proceedings pending before the Commission for the same infringement or if its decision on the same infringement has been appealed and there is no final court decision.