GDPR

CO-ADMINISTRATION OF PERSONAL DATA

On October 1, 2019, an agreement was concluded in Warsaw for the co-administration of:

  • Exorigo-Upos S.A.,registered office address: Warszawa (01-230), ul. Skierniewicka 10 A, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for m.st. Warsaw in Warsaw, XII Commercial Division of the National Court Register under the number KRS: 0000428347, Tax ID: 5252535950, REGON: 146251737;
  • FINTURE Ltd. , registered office address: Warsaw (01-230), ul. Skierniewicka 10 A, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for m.st. Warsaw in Warsaw, XII Commercial Division of the National Court Register under krs number: 0000635131, Tax ID: 5272778791, REGON: 365340724;
  • FINTURE. AI Ltd. , registered office address: Warsaw (01-230), ul. Skierniewicka 10 A, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for m.st. Warsaw in Warsaw, XII Commercial Division of the National Court Register under the number KRS: 0000785939, TAX ID: 5252789627, REGON: 383352469.

Co-administrators are capital and organizationally related entities and cooperate with each other in providing comprehensive IT solutions. The co-administrators belong to the Exorigo-Upos Group K.

The joint administrators shall endeavor to achieve a high level of protection of individuals with regard to the Joint Administration of Personal Data and to minimize the risk of infringement of their rights or freedoms.

The joint administrators, having regard to Article 26 of Regulation (EU) 2016/679 ofthe European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data and on the free movement of such data and the repeal of Directive 95/46/EC (General Data Protection Regulation, hereinafter referred to as the“GDPR”),have regulated the processes of joint administration of personal data.

OBLIGATIONS OF THE PARTIES

The joint controllers undertake to jointly administer the personal data of data subjects in accordancewith applicable laws, including in particular the provisions of the GDPR.

The joint controllers shall be required to ensure the security of the personal data processed and to implement appropriate organisational and technical measures to protect personal data and,where necessary, to update such measures.

The joint controllers are obliged to exercise control over the regularity of the processing of personal data by Third Parties.

RIGHTS RELATED TO THE PROCESSING OF PERSONAL DATA

During the Joint Administration of Personal Data, at each stage of their processing, the Joint Controllers shall ensure that the Data Subjects exercise their rights under the GDPR, that is to say:

  • the right to access and obtain a copy of the data in accordance with Article 15 of the GDPR,
  • the right to rectification and completion of data in accordance with Article 16 of the GDPR,
  • the right to erasure in accordance with Article 17 of the GDPR,
  • the right to restrict the processing of data in accordance with Article 18 of the GDPR,
  • the right to data portability in accordance with Article 20 of the GDPR,
  • the right to lodge a complaint with a supervisory authority in accordance with Article 77 of the GDPR.

JOINT ARRANGEMENTS BETWEEN ADMINISTRATORS

As part of the co-administration agreement, the Joint Administrators have agreed on the scope of their responsibility for fulfilling their obligations under the GDPR, in particular Exorigo-Upos S.A. is responsible for:

  • for fulfilling the information obligations under the GDPR with regard to the disclosure referred to in Articles 13 and 14;
  • carrying out activities aimed at promoting own products and services in order to attract new customers;
  • notifying Violat data subjects in accordance with Article 34 of the GDPR;
  • reporting personal data breaches to the supervisory authority in accordance with Article 33 of the GDPR;
  • Exorigo-Upos S.A. is responsible for fulfilling its obligations under the GDPR with regard to the exercise of their rights by data subjects.

CONTACT US ON MATTERS RELATED TO THE PROTECTION OF PERSONAL DATA

The joint controllers have appointed a joint Data Protection Officer who can be contacted by:

  1. e-mail ochronadanych@exorigo-upos.pl,
  2. by correspondence to Exorigo-Upos S.A. ul. Skierniewicka 10A, 01-230 Warszawa with the note “protection of personal data”.