This document “Privacy and Cookies Policy” (hereinafter: “Policy”) sets out the rules for processing personal data of users of the website www.global-assistance.pl (hereinafter: “Webite”).

The data controller is Global Assistance Polska Sp. z o. o (hereinafter: “Global Assistance”) with its registered office in Warsaw (02-342), Al. Jerozolimskie 162a, registered in the register of entrepreneurs kept by the District Court for the Capital City of Warsaw in Warsaw, XII Economic Department of the National Court Register under KRS number: 0000742736, NIP: 7010832349, REGON: 380696375.

To contact Global Assistance, you can:

1. send an email to: biuro@global-assistance.pl 
2. send a letter to the address of the registered office, i.e. Al. Jerozolimskie 162a, 02-342 Warsaw.

In matters of data protection, the Data Protection Officer, Ms. Daria Rychlik, can be contacted through:

1. send an email to: daria.rychlik@vig.pl 
2. Send a letter marked “Data Protection Officer” to Al. Jerozolimskie 162a, 02-342 Warsaw.

The principles of confidentiality, integrity and security of personal data in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of April 27, 2016 on the protection of individuals with regard to the processing of personal data and on the free flow of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (Official Journal of the EU L 119, p.1) (hereinafter: “GDPR”) shall apply to personal data processed through the Website.

Global Assistance processes personal data in accordance with the following principles:

• on a legal basis and in accordance with the law (principle of legalism),
• reliably and honestly (principle of integrity),
• in a transparent manner for the data subject (transparency principle),
• for specific purposes (the principle of minimization),
• with care for the accuracy of the data (principle of correctness),
• no longer than needed (time principle),
• with ensuring data security (security principle).

Depending on the purpose for which your data is processed, Global Assistance provides a legitimate legal basis for processing.

• realization of the so-called legitimate interest, e.g. accepting a question submitted in the contact form on our website and answering it – Article 6(1)(f) of the GDPR;
• processing necessary to fulfill a legal obligation incumbent on Global Assistance, e.g. if personal data must be made available to public authorities – Article 6(1)(c) of the GDPR;
• in the case of directing to Global Assistance via snail mail correspondence related to the services provided by Global Assistance – the legal basis for processing is the legitimate interest of Global Assistance (Article 6(1)(f) of the GDPR) consisting of correspondence addressed to it in connection with its business activities.
• processing of data in the recruitment process via the apply tab – legal basis consent to the processing of personal data (Article 6(1)(a) of the GDPR). 

A user who, with respect to the use of certain functionalities of the Website, may be asked to provide the following personal data: name, electronic mail address (e-mail address), telephone number and content of the contact message. Provision of the data indicated above is voluntary; however, without providing such data, it may not be possible to use the Website with respect to functionalities that require it (e.g., servicing a submitted request). Personal data collected through forms for which the user has given his/her consent are processed for the purpose and for the period necessary to properly handle the task.

The period of data processing depends on the type of service provided and the purpose of the processing, and may also result from regulations when they provide the basis for processing. If processing is carried out on the basis of legitimate interest, data are processed for the period of time that allows the fulfillment of this interest or until an effective objection to the processing is made. If processing is based on consent, data are processed until the consent is withdrawn. After the expiration of the processing period, the data are irreversibly deleted or animated.

In terms of the User’s use of the Website, Global Assistance stores http requests directed to the server. The resources viewed are identified by URLs and refer to:

• the public IP address of the terminal device (telecommunications device designed to connect directly or indirectly to the Internet, including but not limited to: smartphone, computer or tablet, hereinafter: “Device”) from which the request came;
• the name of the user’s workstation – identification implemented by the http protocol, if possible;
• the user name provided in the authorization process;
• the time of arrival of the query;
• the first line of the request and the http response code;
• the amount of data sent by the server;
• the URL of a page previously visited by the user, when the Website was accessed via an external link;
• information about the user’s browser;
• information about the errors that occurred in the implementation of the http connection.

The aforementioned data are not associated with specific individuals browsing the Website.

In addition, the Website is monitored through appropriate analytical tools and cookies are used for this purpose.

Cookies are used for:

• adapting the content of the Website to your preferences and optimize the use of the Website; in particular, these files allow you to recognize your Device and appropriately display the website, tailored to your individual needs;
• creating statistics that help us understand how you use the Website so that we can improve its content.

The following cookies are used on the Website:

• necessary for the operation of the Website – to enable the use of services available on the Website and to ensure security,
• Statistical – used to count statistics about websites and applications.

Cookies are classified as follows:

• session cookies, which are deleted from the Device’s memory when the session of a given browser ends or the User Device is switched off
• Persistent cookies, which are stored in the memory of your Device, remaining there until they are deleted or expire.

When you visit the site for the first time, you will see information about the use of cookies on our site . Agreeing to the use of cookies means that the user agrees to the use of cookies in the manner described in this Privacy Policy on the device used by the user. The user can voluntarily choose which type of cookies he or she agrees to use. To do so, click More options. The user will then be provided with detailed information about the types of cookies that the site uses and will be able to obtain more information about them in order to give informed consent to their use. This site uses cookies necessary for the operation of the site, which cannot be deactivated because they are necessary for the user to view the site. Other cookies such as statistical cookies can be enabled with the user’s consent.  In addition, the user can reject all cookies. 

You can always withdraw your consent by deleting cookies and changing the cookie settings in your browser on Internet Explore, Mozilla Firefox, Chrome, Opera and others so that only selected cookies are saved. If you deactivate the storage of cookies, some features of the Website may not work or will not function properly. Cookies are small files, containing a string of characters, in which certain information is stored in an open or encrypted manner. Cookies are sent by the server to the user’s Device and stored there to identify them. Each such file has an expiration date, after which it is not active. Using these files, it is possible to trace a user’s movement on the Website. Cookies usually contain the name of the website from which they come, the time they are stored on the Device and a unique number. The information is in no way combined with the personal data of the Website user and is not used to determine the user’s identity. The extent of information collected automatically depends on the user’s browser settings. The user should check their browser settings to find out what information is shared by the browser automatically or to change these settings. Cookies improve communication between the server and the Device, making the use of the Website more comfortable. 

Global Assistance uses external cookies for the following purposes: to collect general and anonymous statistical data via the Google Analytics analytics tool (controller fo external cookies: Google Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA). Google Analytics cookies are stored on the basis of Article 6(1)(f) of the DPA.  Global Assistance has a legitimate interest in analyzing user behavior to optimize the Website;

Global Assistance informs you that you have the following rights in connection with the processing of your personal data:

• The right to access your personal data;
• The right to rectify the processed data;
• The right to delete data – the so-called “right to be forgotten”;
• The right to restrict data processing;
• The right to data portability;
• The right to object to further data processing.

Exercise of each of the above rights is carried out at the request of the user, submitted to Global Assistance or the Data Protection Officer n given above. Global Assistance shall consider the submitted request and send a response within one month of receiving the request. Global Assistance stipulates that it has the functional right to respond to the user’s request later than the above (up to two months), where the criteria are the number of requests or the complicated nature of the request sent. By complicated nature is meant the need to compile data from multiple IT environments or the necessity to consult the content of the request with more than one person from the controller’s department or departments in order to obtain the information that is the subject of the user’s received request. In such situations, Global Assistance undertakes to inform the user of the occurrence of such a case, providing factual justification each time.

In exercising his or her rights, the user may also withdraw consent at any time to further processing of personal data for purposes that require consent, with the proviso that withdrawal of consent shall not affect the lawful use of personal data in activities undertaken on the basis of consent before its withdrawal. The user also has the right to lodge a complaint with the supervisory authority – the President of the Office for Personal Data Protection.

This Privacy Policy may be amended in whole or in part at any time and shall be effective in its new wording from the time it is published on the Website.