Personal data protection and information security have always been prioritized in the activities of Raben Management Services Sp. zoo. and operational companies of Raben Group, as well as in the entire capital group (hereinafter referred to as: “Raben Group”). Being a responsible organisation aware that information has a specific value and it constitutes a resource which requires appropriate protection, it is important for us to keep you informed about matters related to personal data processing, particularly in the light of the new personal data protection regulation, including 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 (GDPR). For this reason, this document presents key information on the legal grounds for the processing of personal data, methods of their collection and use, as well as the rights of data subjects.
II. Raben Group
In the understanding of this Policy, Raben Group companies are:
- Raben Group N.V. with the registered office in Oss in the Netherlands, Raben Group Intelectual Properties B.V. with the registered office in Oss in the Netherlands, or Cougar Investments Holding B.V. with the registered office in Oss in the Netherlands, as well as
- each company - seated both in Poland and abroad - in relation to which Raben Group N.V., Raben Group Intelectual Properties B.V. or Cougar Investments Holding B.V. (separately or jointly) is the "dominant entity" in the understanding of the Polish Accounting Act dated September 29, 1994, (consolidated text Journal of Law 2009, No. 152, item 1223).
Raben Group companies in the understanding of this Policy are also companies which will be established in the future and which will meet at least one of the conditions stipulated in point 1) or point 2).
· Raben Management Services Sp. z o.o. z siedzibą w Robakowie, ul. Zbożowa 1, 62- 023 Robakowo
· Raben Logistics Polska Sp. z o.o. z siedzibą w Robakowie, ul. Zbożowa 1, 62-023 Robakowo
· Fresh Logistics Polska Sp. z o.o. z siedzibą w Robakowie, ul. Zbożowa 1, 62- 023 Robakowo
· Raben East Sp. z o.o. z siedzibą w Robakowie, ul. Zbożowa 1, 62- 023 Robakowo
· Raben Transport Sp. z o.o. z siedzibą w Gądkach, ul. Poznańska 71, 62-023 Gądki
· Raben Real Estate Poland Sp. z o.o. z siedzibą w Robakowie, ul. Zbożowa 1, 62- 023 Robakowo
IV. Contact point
We have appointed a data protection office. It is a person you can contact in all matters relating to the processing of personal data and exercising the rights related to data processing. Contact details of the Data Protection Officer are available on the website.
V. Scope, methods and purposes of data processing
We want to be transparent in terms of methods ways and legal grounds for personal data processing, as well as the purposes for which we process personal data. In order to make our explanation of these issues as clear as possible, we present the following list of personal data processing operations.
At the same time, we would like to assure you that whenever we process personal data based on the legitimate interest of the controller, we try to analyse and balance our interest and the potential impact on the data subject (positive and negative) as well as the rights of that person. We do not process personal data when we come to the conclusion that the impact on the data subject would prevail over our interests, unless we have a different legal ground, e.g. we have the appropriate consent or it is required and permitted by the provisions of law.
V.1. Processing of personal data of people who visit websites run by Raben Group or use services provided electronically
1. 1. General information
Natural persons who visit our websites or use the services we provide electronically have control over the personal data they provide to us, and we ensure that the collection and use of information about users is limited to the minimum necessary to provide services to them on the expected level.
2. 2. Log files
Each time the website is called, our system automatically collects data and information from the computer system of the computer which opens the page. The following data are collected:
1) information about the type and version of the used browser,
2) user's operating system,
3) user's IP address,
4) date and time of calling the page,
5) websites from which the user's system moved to our website (the so-called referrer),
6) websites which were called by the user's system through our website.
The data are also saved in the log files of our system. Recording of the data along with other personal data of the user does not take place. The data cannot be used to identify a specific person because the IP address is masked. The data are also recorded and processed in log files to analyse errors and for statistical purposes.
Temporary saving of the IP address by the system is necessary to make the website available to the user's computer. For this purpose, the user's IP address must be saved for the duration of the session. Saving in log files is intended to ensure the functionality of the website. In addition, the data are used to optimize the website and to ensure the security of our information systems.
Data analysis for marketing purposes therefore does not take place.
3. 3. Cookies
To a limited extent, we may collect personal data automatically via cookies located on our websites. A cookie is a small file containing information data recorded and stored on a computer, tablet or a smartphone, used for accessing websites. Cookies usually contain the name of the site where they originate from, duration of their storage on the device and their unique number.
Cookies are used for the following purposes:
- adjusting the website to the user preferences and optimising the use of websites;
- personalising the content displayed for the specific user of the service;
- building statistics which explain how Internet services are used by users, which allows for improving their structure and the content;
- sustaining the user's session (after logging in), which allows for bypassing the necessity of logging in on each sub-page of the service;
- optimising the advertising and marketing offer to the specific user of the website.
There are three major types of cookies: "session", "persistent" and "third party" cookies.
Session cookies are temporary files stored on the user's computer, tablet or smartphone until logging out, leaving the page or closing the web browser, and they are used to offer services which require verification within a particular website.
Persistent cookies are stored on the computer, tablet or smartphone for the duration defined in the parameters of the cookie, or until they are deleted by the user, and they are used to remember the settings selected by the user and to personalise the interface.
Third party cookies allow for gathering information about how websites are used and for delivering advertising content to the users, which is optimally adjusted to their interests.
Personal data collected via cookies are encrypted so as to prevent undesired and unauthorised persons from accessing them. They are collected for the sole purpose of performing specific functions for the user.
Using our website without using cookies is possible, however in individual cases certain limitations in functionalities may appear while browsing.
Detailed information about the possibilities and methods of supporting cookies is available in the settings of internet browsers.
In order to analyse the user behaviour, we use Google Analytics, a web analytics and reporting software by Google Inc. ("Google"). However, we have requested Google to make your IP address anonymous before analysing user behaviours in the web. We have introduced certain lines to the program code of Google Analytics.
As we have requested making IP addresses anonymous, your IP address is cut to the EU Member States or other European Economic Area states before it is sent to the Google server in the USA. Your full IP address may be sent to the Google server in the USA and abbreviated there only in some exceptional circumstances beyond our control. At our request Google will use the above information to evaluate how our website is used, generate site activity reports and provide us with other services connected with the use of the website and the Internet. Your IP address provided by your web browser to Google Analytics is in no way connected to other Google data.
We would like you to note that you can prevent Google from recording and processing the data from (Google) cookies concerning your website use (including your IP address) if you download and install a special browser plug-in available at tools.google.com/dlpage/gaoptout .
4. 4. Online applications and forms
Our website offers various possibilities of contacting us. Apart from contact forms, we also use application forms regarding employment and cooperation, as well as notification forms and subscriptions to our newsletter. The use of the aforementioned forms usually requires you to provide your personal data. The data which you provide in the online form are collected, processed and used solely within and for the purpose of processing your enquiry and their use occurs only after your express consent.
5. 5. Newsletter
If you consented to receiving our Newsletter to your e-mail address, you may revoke your consent at any time by signing out from the list of Newsletter subscribers. You can sign out of our Newsletter by clicking on the sign me out link which is located in every issue of our Newsletter.
6. 6. Using Social Plug-ins
On www.raben-group.com website, we use Social Plug-ins ("Plug-ins") of the Facebook social network, which is the property of Facebook Inc., 1601 S. California Ave, Palo Alto, CA 94304, the USA ("Facebook"). The Plug-ins are marked with the Facebook logo and the statement "Facebook Social Plug-in". The list of our Facebook plug-ins and their images are available here: developers.facebook.com/plugins. If you open one of our pages which contains the plug-in, your browser will automatically connect to the Facebook servers. At the same time personal data are sent to Facebook (currently they are: the IP, the date and time, viewed website/name of the viewed URL and cookie-ID). According to our knowledge, data processing takes place in the USA. Facebook may combine these data with other information they possess about your person. Being the administrator of the website, we do not have any knowledge about the exact course of processing your data by Facebook. For more information about processing of your personal data by Facebook, please read the provisions of Personal Information Policy of Facebook http://www.facebook.com/about/privacy/).
7. 7. Google +1 button
Thanks to the Google +1 button, clients receive personalised information from Google and the partners. Google stores information defined by the client as +1 content, as well as the information about the website the client visits using the +1 button. The +1 information may be displayed together with the name of the client's profile and their picture in Google services, e.g. in search results and in the Google profile, as well as in other locations on the web and in Internet announcements.
Google records information concerning +1 activities in order to improve Google services. In order to use the Google +1 button, the client must have the globally visible, public Google profile, which contains at least the name selected for this profile. This name is used by all Google services. In some cases, this name may replace another name used for co-sharing the content via Google account. Users who know the electronic mail address of a specific person, or who possess other information which allow for the identification, may obtain information concerning the identity of a specific Google profile.
8. 8.. Photographs
The photographs and icons presented on the website are the property of Raben Group or originate from photo banks such as Fotolia, Thinkphoto, Dreamstime, Getty Image, or they have been purchased from agencies as the content of the site. Detailed information is available here. Some icons used on the website originated from the website modernuiicons.com by Austin Andrews (http://templarian.com/).
Additional information about electronic correspondence
If you wish to write an electronic mail to us, please be advised that unencrypted e-mail messages which are sent via the Internet are not accurately protected against access of third parties.
If you have any questions concerning our information security statement, the Raben Group website, you may contact us by phone or by e-mail.
V.2. Processing of personal data of persons contacting Raben Group in order to obtain information about the offer or to share comments regarding services, as well as making contact for the purpose of concluding a contract
We collect the following personal data from natural persons who contact us in order to obtain information about the offer or share comments about our services, as well as those who contact us to conclude a contract: name and surname, position, e-mail address and telephone number. In particular, these persons can send us an e-mail via the website. Such messages contain the set user's name and e-mail address, as well as additional information that the user wishes to include in the message.
We ask you not to provide information on special categories of personal data listed in Article 9 paragraph 1 of the GDPR (information on racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, data concerning physical or mental health, genetic data, biometric data, data concerning a natural person's sex life or sexual orientation and the criminal past). If you provide such information for any reason, it will mean your express consent to collecting and using such data by us as set out herein or as set out in the location where the data were disclosed.
V.3. Processing personal data of customers and potential customers
Raben Group processes personal data of its customers and potential customers. These data may also include personal data of people associated with our customers who are not natural persons (e.g. contact persons). Personal data of this type are processed in IT systems used by Raben Group, including also the CRM system. Personal data processed for these purposes include, but are not limited to: name and surname, employer name, contact person's position, telephone number, e-mail address or other business contact details.
V.4.Processing personal data of end users of online tools
In a situation where we provide customers with specific products or services online (via the Internet), we process personal data of end users of such products and services. Please note that the information on cookies and access logs we have provided above is also applicable to the processing of natural persons who use products or services offered online.
V.5. Processing personal data of transport participants
Raben Group processes personal data of transport participants, the information clause for this group of people can be found here:
VI. Legal grounds for processing
1. Processing of personal data of people who visit websites run by Raben Group or use services provided electronically is based on different legal grounds of processing depending on the category of personal data which we process and the purpose of processing. We process personal data of persons who visit our websites on the basis of the legitimate interest of the data controller or on the basis of a consent if we have asked the data subject to provide such a consent. Personal data of persons who fill in an online / contact form are processed because it is necessary for the performance of the contract. Sometimes the law requires us to process certain personal data for tax and accounting purposes.
2. Processing of personal data of persons contacting Raben Group in order to obtain information about the offer or to share comments regarding services, as making contact for the purpose of concluding a contract is based on the consent expressed by the user addressing the above request to Raben Group or in order to perform the contract (complying with the request) submitted by a given person. The provided data may also be processed based on the legitimate purpose of the data controller.
3. Processing of personal data of natural persons who are our customers is based on:
a) legitimate interest of a Raben Group company as a data controller (e.g. in the area of database creation, analytical activities, including activities regarding product use analysis, direct marketing of own products, securing documentation for the purpose of defence against potential claims or for the purpose of exercising claims);
b) a consent (including, in particular, consent to e-mail marketing or telemarketing);
c) performance of the concluded contract
d) obligations arising from the law (e.g. tax law or accounting regulations).
4. Processing of personal data of natural persons who are potential customers is based on:
a) legitimate interest of a Raben Group company as a data controller (especially in the area of creating a database, direct marketing of own products);
b) a consent (including, in particular, consent to e-mail marketing or telemarketing).
5. If the end users are also customers of Raben Group, the legal grounds for processing their data are the same as for Raben Group customers described above. If, however, they are not customers, the legal grounds for processing their personal data depends on the situation and the type of personal data or the consent of a natural person (including in particular consent to e-mail marketing or telemarketing), or the legitimate interest of Raben Group as a data controller (e.g. in the scope of providing a service ordered by the customer, within the scope of analytical and profiling activities, including activities regarding the analysis of the use of products, direct marketing of own products, securing documentation for the purposes of defence against potential claims or for the purpose of exercising claims).
6. Legal grounds for processing personal data of transport participants are described here:
VII. Duration of data processing
The time during which we can process personal data depends on the legal grounds which constitutes a legal premise for personal data processing by Raben Group. Accordingly, please be advised that if Raben Group processes personal data based on:
1. a consent, the period of processing lasts until the data subject revokes the consent;
2. a legitimate interest of the controller, the period of processing lasts until the abovementioned interest (e.g. the period of limitation of civil claims) ceases to exist, or until the data subject objects to further such processing - in situations where such an objection is in accordance with the law;
3. applicable legal regulations, the periods of processing for this purpose are set out by these regulations.
In the absence of specific legal or contractual requirements, the basic period of data storage in the case of subscriptions and other documentary evidence drawn up during the performance of the contract is maximum 10 years.
VIII. Recipients of data
In connection with the above, we indicate that the recipients of personal data that Raben Group processes as a data controller may be:
- the aforesaid entities processing personal data under personal data processing contracts (the so-called processors),
- entities providing hosting services,
- subcontractors of Raben Group companies providing services of software provision, maintenance of software or hardware which we use, as well as providers of service we entities providing services in the field of questionnaire surveys,
- debt collection companies,
- auditors and statutory auditors, legal advisers, tax advisers,
- law enforcement authorities, regulatory authorities and other public administration bodies.
IX. Your rights connected with personal data processing
Natural persons have specific rights regarding their personal data, and Raben Group companies as data controllers are responsible for exercising these rights in accordance with the applicable law. In case of any questions or requests regarding the scope of and exercising the rights, as well as to contact us in order to exercise a specific right in the field of personal data protection, please contact our Data Protection Officer. We reserve the right to exercise the following rights after successfully verifying the identity of the person applying for the performance of a specific action.
You have the following rights connected with personal data processing:
1. right to revoke the consent to data processing, if we process your personal data on the basis of your consent,
2. right to access your personal data,
3. right to rectify your personal data,
4. right to demand erasure of your personal data,
5. right to restrict processing of your personal data,
6. right to object to processing of your data due to your special situation - in cases when we process your data based on our legitimate interest,
7. the right to portability of your personal data, i.e. the right to receive your personal data from us, in a structured, commonly used, machine readable format. You can send these data to another data controller or request use to transfer your data to another controller.
8. However, we will do this only if such a transfer is technically possible.
9. You have the right to personal data portability only with reference to the data which we process on the basis of a contract concluded with you or on the basis of your consent;
10. right to lodge a complaint with the supervisory authority responsible for personal data protection, i.e. the President of the Personal Data Protection Office.
The last update of the document was on May 25, 2018.