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GDPR

From 25th May 2018 come into force the provisions of the Regulation (EU) 2016/679 of the European

Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the

processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC

(General Data Protection Regulation) (referred to hereinafter as “the Regulation”).

The Regulation introduces a number of amendments to obligations of entities processing personal

data. Its aim is to extend and harmonize the rights to the protection of personal data of citizens of the

European Union.

WHO IS THE ADMINISTRATOR OF DATA?

The Administrator of Your personal data is Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’ with its registered office in Warsaw, address: Żurawia 6/12/766, 00-503 Warszawa, entered into the register of entrepreneurs kept by the District Court for the capital city of Warsaw in Warsaw, 12th Commercial Division of the National Court Register under the KRS number 0000442857, TAX Identification Number (NIP): 5213641211, National Business Registry Number: 146433467, contact details: phone number: +48 797808730, +48 511973000, e-mail address: info@futurmedica.eu , contact@dentistinkrakow.co.uk , contact@affordabledentalcare.co.uk , contact@dentisteenpologne.fr , kontakt@tannlegekrakow.no , kontakt@tannbehandlingpolen.no , kontakt@tannklinikkkrakow.no , kontakt@zahnarztinpolen24.de, which is related to Futurmedica Group Ryło & Leśniewska business unit, being an organized part of Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’ (referred to hereinafter as “the Foundation”), operated by Anna Leśniewska and Małgorzata Ryło.

WHAT DATA IS COLLECTED

WE PROCESS YOUR DATA FOR THE FOLLOWING PURPOSES:

related to the performance of the contract that binds us, or in connection with the activities undertaken by You in connection with the conclusion of the contract (Article 6 paragraph 1 point b of the Regulation),

for the purpose of marketing and promotion of products offered by Fundacja Rozwoju Przedsiębiorczości “Twój StartUp” with headquarters in Warsaw and being our legitimate interest (Article 6 paragraph 1 point f of the Regulation),

to fulfill all legal obligations imposed on us in connection with the cooperation undertaken (Article 6 paragraph 1 point c of the Regulation), this aim is related to legal obligations to store specific documents for the time specified in the legal provisions, e.g.:

Article 74 paragraph 2 point 1-8 of the Accountancy Law dated 29 September 1994 (Official Journal from 2017, item 1858);

Article 34 paragraph 1 in conjunction with Article 49 of the Act on Counteracting Money Laundering and Financing of Terrorism dated 1 March 2018 (Official Journal from 2018, item 723);

Article 86 paragraph 1 and 2 of the Tax Ordinance Act dated 29 August 1997 (Official Journal from 1997, No. 137, item 926);

for archival purposes (evidence) to secure information in the event of a legal need to prove facts, which is our legitimate interest (Article 6 paragraph 1 point f of the Regulation);

in order to possible arrangement, investigation or defense against claims, which is our legitimate interest (Article 6 paragraph 1 point f of the Regulation);

for a specific purpose based on your consent to processing Your personal data in one or more purposes (Article 6 paragraph 1 point a of the Regulation) – if You consent to the use of your personal data, the content of this consent will specify in which specific purpose we will process this data.

Please be advised that in the above-mentioned purposes we will not perform profiling, ie automated analysis of Your data and prepare predictions about preferences or future behaviors (profiling means, for example in the case of marketing profiling, which offer may be the most interested based on your choices earlier). In case of a change of decision regarding profiling You will be informed about this by completing this information and sending it to the e-mail address provided by You.

WHAT DATA SHOULD BE PROVIDED TO US?:

To conclude a contract, we require to provide the data on the contract form (if You do not provide them, we will not conclude the contract). In addition, we can request optional data that does not affect the conclusion of the contract (if we do not receive it, we will not be able to, for example, call the contact number).

During the contract period, when we providing services, we enter into Your other data. The appearance of Your personal data with us is a consequence of our services that You use.

When concluding a contract, You can additionally for example, order services not previously covered by the contract. If it will require the use of Your data in a manner other than described in this

document, we will complete the missing information and provide it, if possible, before obtaining the data. In the remaining scope, the information on data processing contained in this document will remain valid.

WHO CAN WE MAKE YOUR DATA AVAILABLE TO:

Public authorities, to the extent that they do not receive data as part of a specific legal proceeding (depending on the competence basic);

Entities that process your personal data on behalf of the Foundation based on the contract for entrusting the processing of personal data concluded with the Foundation (the so-called data processor). These will include inter alia: IT specialists, archiving companies, service companies;

External data controllers (the so-called Parallel Administrator, to whom the data are made available, eg. attorneys-in-law and solicitors, entities conducting courier or postal activities, entities purchasing receivables – if You do not pay our invoices on time);

Recipient in the third country or international organization, if we make a decision, about such transfer.

FOR WHAT DURATION WE WILL STORE YOUR PERSONAL DATA?

Your personal data will be processed for the period necessary to implement the purposes of processing indicated in point 1, i.e .:

within the scope of the contract concluded by You with the Foundation, in connection with the activity of ZCP called Futurmedica Group Ryło & Leśniewska, for a period until its completion, and after that:

for a period required by law, e.g. for storing certain accounting records and specific data in accordance with tax regulations;

for a period resulting from the legitimate interests of the Foundation (i.e. a limitation period to secure any claims);

in the scope of fulfilling the legal obligations incumbent on the Foundation in connection with conducting legal activities and the implementation of concluded contracts, for a limited period of time until the Foundation fulfills these obligations;

in the internal administrative purposes, for a period of time before the legitimate interests of the Foundation forming the basis of this processing have been fulfilled or until You object to such processing;

in the scope of marketing and promotion of services offered by the Administrator – for a period of objection to data processing;

within the scope of expressed consent – until its withdrawal.

ENTRUSTING THE PROCESSING OF PERSONAL DATA TO THIRD COUNTRIES

We are not entitled to entrust your personal data outside Poland, the European Union and the European Economic Area (including the European Union, Norway, Liechtenstein and Iceland). For the duration of this Agreement, it may turn out that we decide to entrust your personal data outside the area of EEA – only in the extent permitted by law and providing that the third country guarantees its appropriate protection. In that case, you will be informed about such an entrustment via e-mail or telephone contact.

In case of entrustment your personal data to a third country that won’t be recognized as a state that provides an adequate level of protection in virtue of the European Commission’s proper decision, we will ask you for your explicit acceptance of such an entrustment while sending a notification about the potential risk connected with such a transmittal, on the basis of the Article 40 paragraph 1 letter a) as mentioned in the provisions of Regulation (EU) 2016/679 of the European Parliament and of the Council of 27th April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing directive 95/46/EC (General Data Protection Regulation), hereinafter referred to as ‘the Regulation’.

THE RIGHT TO ACCESS AND CORRECT PERSONAL DATA:

YOU ARE ENTITLED TO THE FOLLOWING RIGHTS:

the right to access to your personal data processed by us on the basis of Article 15 of the Regulation;

the right to refute the entrusted personal data, including its correction (Article 16 of the Regulation);

the right to remove your personal data from our systems, also known as ‘the right to be forgotten’ – if you think that there is no basis for us to process of your personal data, you are entitled to demand its removal on the basis of the Article 17 of the Regulation;

the right to limit the processing of the personal data – you can request us to limit the range of processing your personal data to storing or accomplishing agreed activities. If you think that we process your incorrect data or process them unjustifiably or you don’t want us to remove

them because of the need to establish, investigate or defend your claims or in time of your objection to personal data processing (Article 18 of the Regulation);

the right to data transfer – you have the right to receive from us your personal data, based on a contract or your consent, applicable in a structured, commonly used readable format (eg. ‘.CSV’ format). The basis of this right is to have your personal data in electric form. Otherwise (e.g. in case we operate on your data consolidated in the paper form) , you won’t be entitled use the right mentioned above. You are entitled to demand sending your personal data directly to other entities (Article 20 of the Regulation);

the right to withdraw your consent to processing your personal data (at any time you are entitled to withdraw your consent to processing your personal data processed on the basis of your approval) – Article 7 paragraph 3 of the Regulation. The withdrawal of the consent will not affect the prior personal data processing accomplished on this basis before its withdrawal. In order to withdraw your consent, send an email to the email address: info@futurmedica.eu, contact@dentistinkrakow.co.uk, contact@affordabledentalcare.co.uk, contact@dentisteenpologne.fr, kontakt@tannlegekrakow.no, kontakt@tannbehandlingpolen.no, kontakt@tannklinikkkrakow.no , kontakt@zahnarztinpolen24.de

In order to use the above rights, please send an application with appropriate content to the Fundacja’s address or submit it in person at the Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’ headquarters (address: Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’, 6/12/766 Żurawia Street, postal code: 00-503 Warsaw).

THE RIGHT TO VOICE THE OBJECTION

Notwithstanding the above-mentioned rights, at any time you are entitled to voice the objection to the processing of your personal data (including the profiling if provided) for the direct marketing purposes – Article 21 of the Regulation. After receiving the proper application on this matter, we are obliged to stop processing of your personal data for such a purpose.

In specific circumstances, at any time you are entitled to voice the objection to the processing of your personal data (including the profiling, if provided), if the basis for the processing of your personal data is our legitimate interest or public interest – Article 21 of the Regulation. In that case, after considering your application, we will not be entitled to process your personal data within the scope covered by the objection, unless we prove that they exist:

Important legally justified basis for the processing of personal data that are legally superior to your interests and rights;

or

Legal basis for establishing, investigating or defending claims.

YOU CAN FIND MORE INFORMATION ABOUT THE ISSUES MENTIONED ABOVE IN THE ARTICLE 21 OF THE REGULATION.

INFORMATION ABOUT THE VOLUNTARY ENTRUSTMENT OF THE DATA

As far as data processing is needed to conclude and implement a contract with Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’, the entrustment of your personal data is obligatory for its conclusion. The entrustment of your personal data shall be treated as voluntary, but the failure of providing such data will cause a lack of possibility to conclude and implement the contract.

INFORMATION ABO

INFORMATION ABOUT CHANGING THE DATA PROCESSING PURPOSES BY THE ADMINISTRATOR

If Fundacja Rozwoju Przedsiębiorczości ‘Twój Startup’ decided to process your personal data for a different purpose than the previous ones in which your data has been collected before, we will inform you about the new purpose, as well as provide other relevant information about your data processing.

THE CONSENT

If the use of your data is not necessary for the execution of the contract, fulfillment of any legal obligation or does not constitute our legitimate interest, we can ask you for your permission to specific purposes of using your data. Such consent can enable, for example, providing data to other entities for the purpose of their promotional campaigns or automatic decision-making based on your data and on your request or telephone / e-mail contact to provide information about the execution of the contract. You are entitled to withdraw your consent at any time (this will not affect the legality of using your personal data before your withdrawal of such a consent). The withdrawal of the consent takes place by relevant information, as mentioned in letter g point 1 of the chapter “Right to access and correct personal data.

If you voice your consent to our use of your data, its content will be determined by the purpose of such processing. Data processing consent will only be used for purposes where other processing conditions indicated in letter a)-e) mentioned above, would not be applicable.

THE RIGHT TO COMPLAINT

If the processing of personal data by Fundacja Rozwoju Przedsiębiorczości ‘Twój StartUp’ with its registered office in Warsaw, violates – in your opinion – the provisions of the Regulation, you are entitled to lodge a complaint to the higher level agency, the President of the Office for Personal Data Protection.

If you have any questions, please contact us at: rodo@twojstartup.pl.