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GDPR

Privacy Policy

Of Roseville Investments Sp. z o.o.

Warsaw, 2 July 2019

 

1       PRIVACY POLICY
2       WHEN AND WHY PERSONAL DATA ARE COLLECTED
3       THE KIND OF PERSONAL DATA COLLECTED
4       THE WAY IN WHICH PERSONAL DATA ARE COLLECTED AND USED
  4.1       Transaction of ABC Data S.A. and ABC Data Marketing Sp. z o.o. selling to Roseville Investment Sp. z o.o.
  4.2       Client registration
  4.3       Client’s employee registration
  4.4       Direct marketing
  4.5       Client profiling
  4.6       Establishing, pursuing and protecting against claims
  4.7       Drawing up internal statements, analyses and statistics
  4.8       Information on delivery points
  4.9       Data necessary to process orders for intangible goods
  4.10       Complaint management
  4.11       Correspondence
  4.12       Suppliers, subcontractors and collaborators
  4.13       Employee-related matters
5       TIME OF STORAGE OF PERSONAL DATA
6       METHOD OF DISCLOSING THE COLLECTED PERSONAL DATA
  6.1       General information
  6.2       Our subsidiaries
  6.3       Our service providers and strategic partners
  6.4       Enforcement of the provisions
7       THE MEANS OF PROTECTION OF PERSONAL DATA
8       SECURITY
9       HONESTY
10         RIGHTS OF THE DATA SUBJECT
  10.1         The right of access
  10.2         Right to rectification
  10.3         Right to erasure (‘right to be forgotten’)
  10.4         Right to restriction of processing
  10.5         Right to data portability
  10.6         Right to object
11         CHANGES IN THE PRIVACY POLICY


1 - PRIVACY POLICY

The terms “Roseville”, “us” and “our” used in this Privacy Policy shall mean and refer to Roseville Investments Sp. z o.o. This Privacy Policy shall apply to all personal data processed by Roseville in connection with its business activities. Personal data collected by Roseville are monitored by Roseville. Detailed information on the company can be found under the following link: http://www.roseville.eu/kontakt.

In this Privacy Policy, the term “personal data” shall apply to all information that helps us in identifying, verifying or locating a person, such as their surname, name, physical address, e-mail address, phone number, Internet identifier, date of birth, bank account number as well as other financial data, passport number or identity card number.

The Management of Roseville is fully aware of its responsibility to protect personal data, therefore this Privacy Policy shall regulate the following:

  • When and why personal data are collected.
  • The kind of personal data collected.
  • The way in which personal data are collected and used.
  • Time of storage of personal data.
  • To whom the collected personal data is disclosed.
  • The means of protection of personal data.
  • The rights of data subjects.

2 - WHEN AND WHY PERSONAL DATA ARE COLLECTED

Roseville may collect information on a person who engages in interaction with Roseville. Possible types of interaction include (among others):

  • Signing a dealership agreement, being a dealer’s employee, subsequent ordering of products or services from Roseville, establishing contacts for the purpose of customer service, providing support for a product or systems provided by Roseville;
  • Contacting us via e-mail, telephone, fax or other means;
  • Taking part in special deals offered by Roseville, including, among others, discounts, competitions, etc.;
  • Submitting inquiries to receive information about our services;
  • Face-to-face meetings or giving out business cards during trade fairs, presentations, events or conferences, training sessions, technological seminars or other events.

3 - THE KIND OF PERSONAL DATA COLLECTED

When it comes to our Clients, the type of personally identifying information we collect includes: name, surname, contact number, e-mail address, name and address of the company, position.

When it comes to entities engaged in a business activity, we collect additional information identifying the particular economic activity, such as: name under which the business activity is carried out, its address, Polish Tax Identification Number (NIP) and Polish National Business Registry Number (REGON).

For the purpose of granting a trade credit we can also collect data helping to verify the entity’s creditworthiness and providing adequate credit security, in particular copies of tax declarations or statements, promissory notes, etc.

In the case of persons submitting complaints we collect information helping us to contact with a given person and confirm the warranty/guarantee as well as data allowing for shipping back the goods being subject to complaint. This type of information includes, in particular: name, surname, contact number, e-mail address, name and address of the company, position and proof of purchase.

When it comes to competitions and persons collecting prizes, depending on particular circumstances, we may collect some additional information, such as: Polish Personal identification No. (PESEL), document numbers (including passport number for the purposes related with travelling abroad), identity card number, data necessary to enable correct tax settlement (issuance) or - if necessary - additional data.


4 - THE WAY IN WHICH PERSONAL DATA ARE COLLECTED AND USED

4.1 - Transaction of ABC Data S.A. and ABC Data Marketing Sp. z o.o. selling to Roseville Investment Sp. z o.o.

In connection with the sale of ABC Data S.A. and ABC Data Marketing Sp. z o.o. to Roseville Investment Sp. z o.o. (a company from the capital groups of ALSO Holding A.G.), Roseville obtained personal data from these companies from the ABC Data Group. The purposes of processing these personal data remain the same as they were in the ABC Data Group.

4.2 - Client registration

Reseller registration process requires entering name and surname, company data and billing data (this may include physical address, city, telephone number, e-mail address, bank account number or other Personal Data). The data are used to perform the contract in order to settle payments, deliveries, service complaints, make information on the sales of products available to particular manufacturers (e.g. data necessary to verify discount levels and for sales reporting), take common sales support activities and - if the permission was given - to carry out direct marketing activities.

4.3 - Client’s employee registration

During the registration process, resellers have a possibility to enter data of their employees, who can communicate with Roseville on their behalf. In such a situation, it may be required to provide the employee’s name and surname, position, e-mail address, phone number and system role. The data are used to perform the contract in order to settle payments, deliveries, service complaints, make information on the sales of products available to particular manufacturers (e.g. data necessary to verify discount levels and for sales reporting), take common sales support activities and - if the permission was given - to carry out direct marketing activities.

4.4 - Direct marketing

In relation to persons and entities who consented to receiving commercial communication, direct marketing activities are carried out. These persons and entities are provided with marketing and promotional content regarding products offered by Roseville and its partners. The said promotional content includes in particular commercial offers and information about promotional campaigns and events.

4.5 - Client profiling

As part of marketing communication carried out via Roseville’s proprietary systems (e.g. InterLink, BiznesLink or cloud solutions) or marketing mailing pertaining to promotions, events, webinars, bonus sales or contests, we analyze such data as purchase history and logging records, based on which we develop forecasts on future preferences and future behaviors of clients. Thus, we are able to determine which clients may be the most interested in a given type of marketing content.

4.6 - Establishing, pursuing and protecting against claims

The data are being processed until the beginning of the period of limitation for claims. This applies in particular, but is not limited, to customers using trade credit.

4.7 - Drawing up internal statements, analyses and statistics

We draw up reports, analyses and statistics, which are then used for our internal needs. This kind of processing is carried out, among others, in connection with the assessment and organization of the portfolio, quality and service suitability, services, product offer, development of our systems (e.g. InterLink or cloud solutions), etc.

4.8 - Information on delivery points

We use contact information of end users to manage goods deliveries, in cases where the delivery point is the end user's address and not the address of the reseller's office. Personal data of end users may be disclosed to our subcontractors (freight forwarding companies) taking part in the order delivery process.

4.9 - Data necessary to process orders for intangible goods

The data of end users are also used for the purposes related to processing of orders for intangible goods (such as licenses, subscriptions, or the so-called service packs or care packs). Personal data of end users may be also disclosed to companies providing the said goods or on behalf of which Roseville operates.

4.10 - Complaint management

In connection with complaint management, data of resellers and end users are processed. Personal data of end users may be disclosed to our subcontractors or partners (servicing companies and/or manufacturers) taking part in the complaint management and servicing process.

4.11 - Correspondence

If persons contact us to provide feedback, comments or for any other reason, we may keep records of such correspondence and collect Personal Data for the legitimate purpose of processing inquiries, responding to requests and improving our services.

4.12 - Suppliers, subcontractors and collaborators

Because of our extensive cooperation with various entities, we process personal data of contact persons. The processing takes place for the legitimate purpose of ensuring efficient cooperation and pertains in particular to such types of entities as: (1) freight forwarding companies, (2) suppliers, (3) manufacturers, (4) financial institutions, (5) shareholders, (6) journalists, (7) analysts, (8) administrative bodies, (9) IT sub-contractors, (10) companies carrying out equipment repairs, (11) companies organizing special events, promotional and marketing campaigns and (12) other subcontractors.

4.13 - Employee-related matters

Data of candidates are processed for the purposes of recruitment process.

In connection with: (1) matters related to employment under employment contract or other form of employment, (2) insurance-related matters (3) matters related with management of employee benefits, we process personal data of our employees and members of their families.


5 - TIME OF STORAGE OF PERSONAL DATA

We store personal data of a given data subject as long as it is needed to fulfill the purposes for which they were collected and to meet the legal, accounting and reporting requirements.

In order to determine the appropriate storage period for Personal Data, we take into account the amount, nature and sensitivity of Personal Data, the potential risk of harm resulting from unauthorized use or disclosure, purposes for which we process Personal Data and applicable legal requirements, and whether we can achieve these goals through other means. In certain circumstances, the data subject may ask us to delete their Personal Data. Further information related to this subject can be found in the section ”Rights of the data subject” below.


6 - METHOD OF DISCLOSING THE COLLECTED PERSONAL DATA

6.1 - General information

Personal data is collected by us for a specific purpose and are registered and used only for that purpose, unless the data subject allows us to use it for other purposes.

6.2 - Our subsidiaries

Depending on the applicable data protection regulations, we can disclose the personal data to entities we control. These entities may use the personal data only in accordance with this Privacy Policy and only for the specified purposes.

6.3 - Our service providers and strategic partners

We may disclose personal data to particular companies that render services to Roseville. For example, company data can be made available to insurance dealers, data related to the sales and timeliness of payments can be made available to market research entities and data related to the recovery of receivables can be made available to entities dealing with such issues. We report the sales volume for individual points of sale to selected key manufacturers. When it comes to product deliveries, we provide the freight forwarding companies with the name, surname and address of the ordering party. Such external service providers and partners have access to Personal Data necessary to perform the requested activities, but they have no right to use the data for any other purpose.

We may also disclose Personal Data to other companies so as to provide the data subject with information about products and services offered by Roseville that may be of interest to them, but only if they agree to such information provision by checking the appropriate box in the InterLink system.

6.4 - Enforcement of the provisions

We may disclose personal data or use such information in other ways to the extent that such disclosure or use may be required and to the extent necessary to meet the legal requirements imposed upon Roseville and to protect the legitimate legal and business interests of Roseville, as well as its rights, assets and employees.

We may also disclose personal data in response to legitimate requests by public authorities, e.g.to respond to inquires by law enforcement agencies, public administration or other relevant third parties made in connection with proceedings regarding fraud, IPR or other suspected illegal activity, or due to the requirements of applicable law or when a justification is necessary.


7 - THE MEANS OF PROTECTION OF PERSONAL DATA

Information collected from data subjects is processed in systems located in Roseville or by entities that have their registered office in the European Economic Area. Data pertaining to sole traders may be transmitted outside the EU (sales reporting).

Any questions or concerns regarding the use or disclosure of Personal Data should be directed to Roseville by writing to the following e-mail address rodo@roseville.eu.


8 - SECURITY

Roseville applies appropriate mechanisms protecting information about persons against unauthorized access, unauthorized changes, disclosure or deletion. Access to personal data is restricted to a specified group of employees who need such access to perform their official duties and to develop or improve products, services and websites. Our servers are equipped with appropriate safeguards and are situated in locations that provide an adequate level of physical protection.


9 - HONESTY

Users of our systems may view, rectify or delete the entered information, as long as this does not affect the integrity of the transaction and/or is consistent with the actual state of affairs. Our goal is to ensure the highest possible adequacy of the data being processed.


10 - RIGHTS OF THE DATA SUBJECT

The following rights are granted to the data subject.

10.1 - The right of access

The data subject has the right to obtain from Roseville confirmation that personal data relating to the data subject are being processed by the controller, and if so, they are entitled to access them. Upon the data subject’s request Roseville shall provide a copy of their Personal Data undergoing processing. For any further copies requested by the data subject, Roseville may charge a reasonable fee based on administrative costs.

10.2 - Right to rectification

The data subject has the right to rectify the inaccurate personal data that concern them. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.

10.3 - Right to erasure (‘right to be forgotten’)

The data subject has the right to obtain from Roseville the erasure of personal data that concern them without undue delay and Roseville shall have the obligation to erase personal data without undue delay, in circumstances foreseen by law. The circumstances foreseen by law include in particular: the need to process records related to tax law and accounting regulations, the need to process data necessary to defend against claims (e.g., deliveries made, purchases) or the processing of data in connection with other legal obligations.

10.4 - Right to restriction of processing

The data subject may indicate Data, the processing of which is to be limited only to specific, narrowed purposes.

10.5 - Right to data portability

Under certain circumstances the data subject shall be allowed to receive their personal data they provided to Roseville in a structured, commonly used, machine-readable and interoperable format, and to transmit them to another controller without hindrance from Roseville.

10.6 - Right to object

In certain circumstances the data subject shall have the right to object, on grounds relating to their particular situation, at any time to processing of personal data concerning the data subject and Roseville may be subject to the obligation to cease the processing of such Personal Data.


11 - CHANGES IN THE PRIVACY POLICY

The privacy policy can be updated. The latest version shall be published on our website. We encourage you to visit the website regularly so that you can get information about any changes to this Privacy Policy. In the event of an objection to the amendments made to the Privacy Policy, reservations must be submitted to Roseville in writing.