Of Roseville Investments Sp. z o.o.
Warsaw, 2 July 2019
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
4.12 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
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
- 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.
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.
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.
4.1 - 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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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 firstname.lastname@example.org.
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.
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.
The following rights are granted to the data subject.
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.
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.
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.
The data subject may indicate Data, the processing of which is to be limited only to specific, narrowed purposes.
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.
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.