Privacy Policy

INFORMATION REGARDING THE PROCESSING OF YOUR PERSONAL DATA

Who is the controller of your personal data and who can you contact about it?

1. 1 The administrator of your personal data is EBS Spółka Akcyjna with its registered office in Warsaw ¹ [contact details: ul. Postępu 21, 02-676 Warsaw, Poland], hereinafter referred to as “EBS”.2 In matters of protection of your personal data and exercising your rights, you can contact us by e-mail: rodo@ebssa.pl ; telephone: 603 786 799; or in writing to our address indicated in Section 1.

For what purposes and on what grounds do we process your personal data?

3 We process your personal data for the following purposes:

purpose of processing	legal basis of processing
participation in the 5asec club
to establish a member’s status in Club 5asec (including having a regular customer status) entitled to discounts and special offers	our legitimate interest (Article 6(1)(f) of the RODO)
providing marketing and promotional information	our legitimate interest (Article 6(1)(f) RODO)
execution of services
performance of the contract concluded with us and handling of complaints regarding contracts concluded with us	our legitimate interest (art. 6(1)(f) RODO)
informing about the performance of the service	our legitimate interest (art. 6(1)(f) RODO)
The implementation of special services (including cleaning of leather or shoe assortments, mangle, carpet cleaning)	our legitimate interest (art. 6(1)(f) RODO)
inquiries addressed to us
responding to matters reported via our contact form, email or telephone	our legitimate interest (art. 6(1)(f) RODO)
general
for analytical purposes [e.g.: selection of services to meet the needs of our clients; optimization of our products/services based on your comments on them, optimization of service processes based on the course of sales and after-sales service processes, including complaints, surveying the satisfaction of our clients and determining the quality of our service].	our legitimate interest (Article 6(1)(f) RODO)
for possible establishment, investigation or defense against claims (i.e. evidentiary purposes)	Our legitimate interest (Article 6(1)(f) RODO)
retention of accounting records	Our obligation to keep accounting records under tax law (Article 6(1)(c) of the RODO in connection with Article 86 § 1 of the Tax Code)

Who has access to your personal information?

4 We may share your personal information with the following categories of entities:

1. employees and associates of – in particular to provide services and conduct our business;
2. to our group entities and our franchisees – for marketing and promotional purposes;
3. to subcontractors of the services we provide, as well as to entities that support our business, including in terms of legal, accounting, IT, logistics, marketing, etc. – in particular for the purpose of providing services and conducting our business.

How long is your personal data processed?

5. your personal data is processed:

1. in connection with the establishment of Club 5asec’s membership status (including its holding of the status of a regular customer) entitled to discounts and special offers – for the period of participation in this club,
2. in connection with a complaint made to us regarding a contract or the conclusion of a contract for the cleaning of a leather assortment or footwear – until the end of the statute of limitations for potential claims on this account (this period is determined by the provisions of the Civil Code), and in the case of their use in the context of public legal proceedings until, after their legal conclusion, extraordinary remedies are no longer available (this period is determined by the provisions of the Civil Procedure Code),
3. in connection with responding to matters reported via our contact form, email or phone – until you object to their processing for this purpose or we ourselves determine that they have become obsolete, for direct marketing of our products and services – until you object to their processing for this purpose or we ourselves determine that they have become obsolete,
4. for evidentiary purposes to establish the existence of claims, their investigation or defense against them – until the end of the statute of limitations for potential claims on this account (this period is determined by the provisions of the Civil Code), and in the case of their use in the framework of public legal proceedings until, after their final conclusion, extraordinary remedies are no longer available (this period is determined by the provisions of the Civil Procedure Code);
5. for analytical purposes – until you object to their processing for this purpose or we determine for ourselves that they have become obsolete, ;
6. in connection with the storage of accounting records – until the expiration of the statute of limitations on the tax liability for the related transaction (this period is determined by the provisions of the Tax Ordinance).

What rights do you have in relation to the processing of your personal data?

6 You are entitled to:

1. access to your data and receive a copy of it;
2. To rectify (amend) your data;
3. to erasure:
   if, in your opinion, there are no grounds for us to process your data, you can request that we erase it;
4. Restriction of data processing :
   you can request that we restrict the processing of your personal data only to storing it or performing an action agreed with you, if in your opinion we have inaccurate data about you or are processing it unfoundedly; or you do not want us to delete it because you need it to establish, assert or defend a claim; or for the duration of your objection to the processing;
5. To object to the processing of data:
   “marketing” objection – You have the right to object to the processing of your data for direct marketing purposes, if you exercise this right we will stop processing your data for this purpose,
   Objection on the grounds of special situation – you also have the right to object to the processing of your data on the basis of legitimate interests for purposes other than direct marketing, and when the processing is necessary for us to perform a task carried out in the public interest or for the exercise of public authority entrusted to us, you should then indicate to us your special situation, which in your opinion justifies the cessation of the processing covered by the objection, we will stop processing your data for these purposes, unless we demonstrate that the grounds for our processing of your data override your rights, or that your data are necessary for us to establish, assert or defend claims;
6. to data portability:
   you have the right to receive from us in a structured, commonly used machine-readable format (e.g., “xml.” or “.csv” format) the personal data concerning you that you have provided to us under a contract or your consent, or you may have us send the data directly to another entity;
7. to lodge a complaint with a supervisory authority:
   if you believe that we are processing your data unlawfully, you may lodge a complaint to this effect with the authority overseeing compliance with data protection laws (the Inspector General for Personal Data Protection or its successor – the President of the Office for Personal Data Protection);
8. to withdraw consent to the processing of personal data:
   at any time you have the right to withdraw your consent to the processing of those personal data that we process on the basis of your consent, withdrawal of consent will not affect the lawfulness of the processing carried out on the basis of your consent before its withdrawal.

How do you exercise your rights regarding your personal data?

7 To exercise your rights, direct your request to the following email address: rodo@ebssa.pl or call us at 603 786 799 . Remember, before exercising your rights, we will need to make sure that you are you, i.e. properly identify you.

Is it mandatory to provide personal information?

8. entering into a contract with us is voluntary. However, providing personal data in connection with the conclusion of a contract is a condition for its conclusion and subsequent performance – without providing personal data, it is not possible to conclude a contract with us.

Information about video monitoring of our laundries

(9) Our laundries are monitored during their opening hours to ensure reliable handling of complaints regarding the condition of donated and matched clothes, shoes, billing, persons authorized to collect, verification of employee work, etc. The recording from the cameras (without sound) covers the place where customers are served (i.e. no more than 2.5 m from the counter) and is kept on site at the given laundry for a period of 28 days, or for a longer period if such a legitimate need is reported by the customer or a public authority authorized to do so under the law, as well as if it is needed for the investigation or repudiation of a claim made within this period or due to our legitimate interest. After the indicated period it is deleted. We clarify that in the framework of this monitoring, we do not identify persons who have been recorded thanks to it, except when: (1) the recorded person requests it, indicating the data enabling him/her to be found on the recording (in which case he/she will be informed about the processing of his/her personal data and its purposes, and only the recording related to him/her will be made available to him/her at his/her request, (2) it will be necessary for us to handle a complaint filed by the recorded person, (3) it will be necessary to verify the performance of duties by our employees, (4) it will be requested by a public authority authorized to do so under the law.

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¹ EBS S.A., based in Warsaw, is a company entered in the Register of Entrepreneurs kept by the District Court for the City of Warsaw, XIII Economic Department of the National Court Register under the KRS number 0000347462, NIP 526-23-16-161, share capital of 4,081,632.00 paid in full.