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Personal Data Controller

The Controller of your personal data is the Polish-American Freedom Foundation (PAFF). On behalf of PAFF, the duties of Controller are performed by the Polish-American Freedom Foundation Representative Office in Poland with its registered office in Warsaw, at ul. Królowej Marysieńki 48 (02-954 Warszawa).

Should you have any enquiries regarding personal data protection, please contact the Polish-American Freedom Foundation Representative Office in Poland by email at: paff@pafw.pl, phone at: 22 5502800 or mail sent to: Przedstawicielstwo w Polsce Polsko-Amerykańskiej Fundacji Wolności, ul. Królowej Marysieńki 48, 02-954 Warszawa.

The personal data processing purposes and the legal basis

Your personal data are processed in compliance with 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) (OJ L 119, p. 1 – 88) (GDPR).

PAFF processes personal data for the purposes of:

• (i) contacting you in connection with PAFF statutory activities, or corresponding with you, or settling things in response to messages, proposals and/or submissions addressed to us, following your consent (legal basis – Art 6 para.1 letter a of GDPR) or ii) concluding an agreement if you have expressed your interest in our offer (legal basis – Art 6 para.1 letter b of GDPR), or (iii) performing an agreement concluded by you with us (legal basis – Art 6 para.1 letter b of GDPR), or (iv) performing a grant agreement concluded by PAFF, which is the basis for awarding by PAFF a grant for performing an initiative of which you are beneficiary, contractor or service/goods provider, including in particular performing by PAFF its supervision and control rights and duties, among others such as fraud prevention, because processing is necessary for the purposes of the legitimate interests pursued by PAFF (legal basis – Art 6 para.1 letter f of GDPR);
• informing and popularizing by disclosing to public the names of individual persons – beneficiaries of programs funded or co-funded from grants awarded by PAFF, by means of posting them, without time and area limitations, on the PAFF website, or the Internet portals such as Facebook, Instagram, etc., and in printed materials relating to PAFF activities, because processing is necessary for the purposes of the legitimate interests pursued by PAFF that result from its statutory goals (legal basis – Art 6 para.1 letter f of GDPR);
• cooperation with PAFF or its partners, as well as PAFF services satisfaction surveys, because processing is necessary for the purposes of the legitimate interests pursued by PAFF and resulting from its statutory goals, such as PAFF services quality assessment and services recipient satisfaction surveys (legal basis – Art 6 para.1 letter f of GDPR);
• survey of preferences with regard to the demand for PAFF services, direct marketing of PAFF services, including profiling (using personal data for creating the beneficiaries’ profiles with a view to PAFF services that can be interesting to them in the future) and preparing dedicated offers, because processing is necessary for the purposes of the legitimate interests pursued by PAFF that result from its statutory goals (legal basis – Art 6 para.1 letter f of GDPR);
• archiving (evidencing), because processing is necessary for the purposes of the legitimate interests pursued by PAFF that result from its statutory goals, such as storing information in case of arising of legal need to document given facts (legal basis – Art 6 para.1 letter f of GDPR);
• determination, investigation or exercise of legal claims, if a need arises, because processing is necessary for the purposes of the legitimate interests pursued by PAFF that result from its statutory goals (legal basis – Art 6 para.1 letter f of GDPR);
• meeting the legal obligation of PAFF under Polish legislation, generally applicable EU regulations which may be applied directly, international agreements which the Republic of Poland is a party of, in particular connected with a duty to make certain data available to law enforcing authorities and to evidence business activities for tax and accounting purposes (legal basis – Art 6 para.1 letter c of GDPR);

Categories of your data that we process (applicable when collecting data not directly from a data subject)

If we have collected the data not from the subject person – the primary identification data (given name, family name, e-mail address, phone number) and potentially financial identification data (number of the bank account.)

Who to and where may PAFF transmit your data? Who can be a recipient of your data, apart from PAFF or the Polish-American Freedom Foundation Representative Office in Poland ? (Information on data recipients)

Apart from PAFF (and the Polish-American Freedom Foundation Representative Office in Poland) staff, proxies and management, your personal data will be available to persons and entities securing and maintaining IT systems and solutions used by PAFF.

Furthermore, depending on the nature of a case, PAFF may only make your personal data available to the following subjects:

• entities and persons cooperating with PAFF and performing services of mail and parcels delivery, printing, archiving, communication, analyzing (including organization of satisfaction and preferences surveys), and call centers on behalf of PAFF; or
• PAFF insurers; or
• entities providing PAFF with accounting, financial, legal and tax consulting, audit, and collection services; or
• public authorities, including courts, in complying with their justified request; or
• public authorities, including courts, PAFF attorneys, insurers and advisors if it is necessary to defend PAFF against claims lodged against PAFF or to pursue claims lodged by PAFF.

Transfers of data outside European Economic Area or to international organizations

Your personal data can be transferred to the PAFF registered office in the USA, where your personal data will be properly secured in compliance with corporate rules in force.

How long will PAFF store your personal data? (Information on the data storage period)

Your primary contact data will be stored for the needs of direct marketing of our services until you raise objection to your data processing for that purpose, withdraw your consent if we have processed them with your consent, or until we have established that your data got outdated.

If we obtain your data in order to conclude an agreement with you or a grant agreement which is the basis for awarding by PAFF a grant for performing an initiative of which you are beneficiary, contractor or service/goods provider, we will process your data until all potential claims of the Parties to the agreement are time-barred or the statutory period of such data storage expires, whichever date is later.

Information on your rights

The right to access your data

You have the right to access your personal data. Furthermore, you have the right to obtain a copy of your data, provided that you can obtain the first copy of your data free of charge, and for each next copy we may charge you a reasonable fee that covers administrative costs of preparing one.

The right to rectification your data

You have the right to rectify your data or complete them if they are incomplete, with a view to the purpose of processing them.

The right to erasure of your data (“to be forgotten”)

If you are of an opinion that there are no grounds for processing your data, you can require us to erase them.

The right to restriction of data processing

You can require us to restrict your data processing only to storage or activities agreed with you, if in your opinion the data we possess on you are incorrect or we process them without good grounds; if you don’t want us to erase them because you need them for the purpose of determination, exercise or defense of legal claims; or for the period covered by your objection to having your data processed.

The right to objection

Objection to marketing. You have the right to object to have your data processed for the direct marketing purposes. If you exercise your right, we shall stop processing your data for that purpose.

Objection due to particular situation. You have the right to object to processing your data, on grounds of legitimate interest, for the purposes other than direct marketing. In such a case, you should demonstrate that the particular situation which in your opinion justifies your request that we stop processing your data in the objected area. We shall then stop processing them for those purposes, unless we can demonstrate legitimate grounds for the processing which override your interests, rights and freedoms or that we need your data for the establishment, exercise or defense of legal claims.

The right to portability

You have the right to receive from us your personal data which you have provided to us in a structured, commonly used, machine-readable format, and to order us to transmit them directly to another controller.

The right to lodge a complaint with a supervisory authority

If you believe we process your data not in compliance with law in force, you may lodge a complaint to the President of the Personal Data Protection Office.

The right to withdraw the consent to process your personal data

If your personal data are processed on grounds of your consent, you have the right to withdraw your consent to have them processed. The withdrawal of consent shall not affect the lawfulness of processing based on consent before its withdrawal.

Information on requirement of providing data/ providing data voluntarily (applied when data is collected from the data subject)

You provide all your data voluntarily.

Depending on situation in which PAFF can obtain your data, providing some of them (determined by PAFF as required) may be a condition for concluding an agreement with PAFF, including the Polish-American Freedom Foundation Representative Office in Poland, or a condition for providing services, e.g. subscribing for the Polish-American Freedom Foundation newsletter.

Providing your full name, address and Tax Id Number (NIP) can be a statutory requirement and be necessary for preparing documentation for tax purposes.

If you send messages, proposals or requests to PAFF (e.g. to receive the PAFF offer), giving your address is not a statutory or contractual requirement and is not a condition for conclusion of an agreement, however providing required data is necessary for us to be able to reply.

Depending on situation, if you don’t provide us with certain information, it may be impossible for PAFF to conclude an agreement with you, or for you to use PAFF services, receive from PAFF proper tax documents or PAFF offer, or reply to a message addressed to PAFF by you, a complaint lodged to PAFF, intervention, or proposal.

Information on data source (applied when data are collected from a source other than the data subject)

We received your data from:

• an entity that is a Party to a grant agreement which is the basis for awarding by PAFF a grant for performing an initiative of which you are beneficiary, contractor or service/goods provider; or
• your public profile on LinkedIn; or
• your company website; or
• review of the National Court Register.