RSM Poland
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Privacy Policy

Updated 31 October 2022

 

Contents

INTRODUCTION
CONTACT WITH THE DATA CONTROLLER
SCOPE OF DATA
PURPOSE OF PERSONAL DATA PROCESSING
RIGHTS OF DATA SUBJECTS
TRANSFER OF PERSONAL DATA
SERVICE PROVIDERS
SECURITY
PROTECTING YOUR INFORMATION
LINKS TO THIRD PARTIES
PERIOD OF STORAGE OF PERSONAL DATA
MINORS
SOCIAL MEDIA
INTERNATIONAL SERVICES AND DATA TRANSFER
RELATED POLICIES
COMPLAINTS
CHANGES IN PRIVACY POLICY
COOKIES

 

Introduction

RSM Poland is a member of the RSM network and trades as RSM. RSM is the trading name used by the members of the RSM network. Each member of the RSM network is an independent accounting and consulting firm, each of which practices in its own right. The RSM network is not itself a separate legal entity of any description in any jurisdiction. The list of all members of the RSM network is available at: https://www.rsm.global/mena.

This Privacy Policy describes the rules for the collection and use of personal data by RSM Poland and the rights of data subjects regarding personal data. In addition, this Privacy Policy outlines the privacy protection practices for the www.rsmpoland.pl website and explains how information is collected and used by this website.

Privacy policies for local websites of RSM network members may differ from this Privacy Policy, contain additional information, or be subject to separate regulations and legal requirements.

If you have any questions or concerns as to the privacy notices on local RSM network member sites, please contact the executive office of RSM International Limited at 50 Cannon Street, London EC4N 6JJ. phone 0207 6011080.

RSM Poland's Privacy Policy has been developed and is updated on an ongoing basis by RSM Poland Audyt Sp. z o.o. with its registered office in Poznań, 61-555 Poznań, ul. Droga Dębińska 3B, entered into the business register of the National Court Register kept by the District Court for Poznań-Nowe Miasto and Wilda in Poznań, 8th Commercial Division of the National Court Register, under KRS number 0000970982, NIP: 7781428037, with a share capital of PLN 1,000,000.00.

 

Contact with the Data Controller

The data controller is RSM Poland operating in Poland under the name RSM Poland Audyt Sp. z o. o. with its registered office in Poznań, 61-555 Poznań, ul. Droga Dębińska 3B, entered into the business register of the National Court Register kept by the District Court for Poznań-Nowe Miasto and Wilda in Poznań, 8th Commercial Division of the National Court Register, under KRS number 0000970982, NIP: 7781428037, with a share capital of PLN 1,000,000.00.

You can contact us:

  • By sending a message to the e-mail address: office@rsmpoland.pl or gdpr@rsmpoland.pl. In matters related to recruitment, please contact us by e-mail: praca@rsmpoland.pl.
  • By sending a letter to RSM Poland: ul. Droga Dębińska 3B, 61-555 Poznań.
  • Via the contact form available on the website in the contact tab.

The preferred method of contacting us in matters related to the protection of personal data is e-mail.

In order to be correctly identified, please provide your name, surname, telephone number, and if you are authorised to representation, also the name of the entity on behalf of which you have acted or are acting. In case of doubts related to identification, we may ask you to provide additional data or information.

In particularly justified cases, resulting from applicable law or concluded contracts, the controller of your personal data may also be: 

RSM Poland Technology sp.z o.o. with its registered office in Warsaw, 00-189 Warsaw, ul. Inflancka 4, entered into the business register of the National Court Register kept by the District Court for the Capital City of Warsaw in Warsaw, 12th Commercial Division of the National Court Register, under KRS number 0000627716, NIP: 5252669099, with share capital of PLN 500,000.00

RSM Poland Fiscal Representations sp. z o.o. with its registered office in Poznań, 61-555 Poznań, ul. Droga Dębińska 3B, entered into the business register of the National Court Register under KRS number 0000415584, NIP: 7831687457, with a share capital of PLN 15,000.00

RSM Poland Legal sp. z o.o. with its registered office in Poznań, 61-555 Poznań, ul. Droga Dębińska 3B, entered into the business register of the National Court Register kept by the District Court for Poznań-Nowe Miasto and Wilda in Poznań, 8th Commercial Division of the National Court Register, under KRS number 0000464248, NIP: 5252556366, with a share capital of PLN 105,000.00

Scope of data

In this Privacy Policy, "personal data" shall mean information about a natural person who can be directly or indirectly identified, in particular based on an identifier such as name, identification number, location data or online identifier. Personal data also refer to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of a natural person.

RSM Poland may collect the following types of personal data:

Information provided by you

RSM Poland collects personal data received from you, which may include: (i) contact information, such as name and surname, company name, position, postal address, e-mail address and telephone number; (ii) additional personal information such as gender, age, date of birth, nationality, professional association membership and registration numbers; (iii) comments, questions and requests sent by the customer; (iv) login details, including, if applicable, social media account information; (v) information about customer preferences, e.g. preferred method of contact and scope of services.

Information collected automatically from your devices:

Device and browser information. RSM Poland may collect technical data of the customer's device, such as device type, type of web browser, IP address, operating system and device ID. RSM Poland collects this information automatically from the device and web browser using cookies and related technologies.

Information on how to communicate with us. RSM Poland may collect technical information on how users use the RSM Poland website. RSM Poland collects this information using cookies and related technologies.

Cookies and related technologies: A "cookie" is a file with information saved on your device when you visit a website. Cookies and related technologies enhance the user's experience by saving their preferences, customising the way they browse and sometimes enabling the delivery of advertisements that match their interests.

 

Purpose of personal data processing

RSM Poland processes personal data for various purposes. We collect personal data directly from, among others: clients who commission us to prepare their tax returns, from users visiting the www.rsmpoland.com website and from individuals applying for a job at RSM Poland who send us their applications using the "Apply" tab on the RSM Poland website. In addition, we process personal data in the context of providing professional services to the data subject's employer or service provider, for example when conducting an audit of a unit or department in the organisation where the data subject works. We also obtain personal information from publicly available sources such as LinkedIn.

The categories of persons whose data we may process include:

  • Visitors to the website www.rsmpoland.pl
  • Customers
  • Individual persons whose personal data we obtain in connection with the provision of services to our clients
  • Contact database in our customer relationship management systems (CRM)
  • Participants of meetings, conferences, events and webinars organised by RSM
  • Users of our apps
  • Visitors to our social media pages and users of social media plug-ins and tools (social media)
  • Persons conducting e-mail correspondence with RSM Poland
  • Job applicants - candidates for work at RSM Poland
  • Alumni
  • Suppliers
  • Persons subscribing to the RSM Poland Newsletter
  • Visitors to RSM Poland offices

 

Rights of data subjects

Based on the provisions of the GDPR, you can effectively manage your personal data, including the following rights:

  • Exercise your right to object to the processing of personal data or to request the deletion of personal data (in certain circumstances and in accordance with applicable law).
  • Exercise your right to correct information (the right to access data and the right to rectify data), i.e. edit your addresses, your personal data, and change your password.
  • Exercise your right to be forgotten, i.e. simply request the deletion of your data (in certain circumstances and in accordance with applicable regulations).
  • Exercise your right to be informed, by being able to read the basic information about the processing of personal data by RSM Poland.
  • Exercise your right to be notified, if a data breach occurs in our system, you should be notified within 72 hours. 
  • Exercise your right to restrict processing, if you want us to stop processing the personal data associated with your account.

 

The recommended and fastest way to exercise your rights is to send an e-mail to the address indicated by the Controller. Nevertheless, we will make every effort to fulfil your requests received in any other form, including in paper form.

If you submit a request in a different form, we reserve the right to verify your identity. Lack of effective verification of your identity for reasons for which you are responsible means that we will not accommodate the submitted request, of which you will be informed immediately.

Submission of the application in a form other than an e-mail may extend the response time to 30 days. In objectively complex cases, i.e. requiring a lot of work on our part, the above deadline may be extended to two months, of which you will be informed immediately.

 

Transfer of personal data

RSM Poland will not disclose your personal data except in the following cases:

  • RSM Poland may share your personal data with other entities, including entities based in other European Union countries. In such a case, entities that have received data will use it in a manner consistent with this Policy and any applicable privacy guidelines and laws regarding privacy and data protection.
  • RSM Poland may share personal data of customers with third parties with whom it cooperates in order to provide support services. Third parties are obliged to use the personal data received from us only to provide services on behalf of RSM Poland and to process this personal data in accordance with the applicable regulations on the protection of privacy and personal data.
  • In some cases, RSM Poland may share personal data with third parties cooperating with RSM Poland in the scope of supporting the delivery of RSM Poland services to customers. In such cases, we require business partners who receive this personal information from us to handle it in a manner consistent with this Privacy Policy and any applicable privacy guidelines and data protection laws.
  • RSM Poland may also share customer personal data with third parties if it believes in good faith that this is necessary: (i) to comply with laws, orders, court decisions and other legal requirements; (ii) to detect and prevent fraud, violations of intellectual property rights, violations of the provisions of agreements or contracts concluded with us, violations of the law or other improper uses of the RSM Poland website, RSM Poland services and to react in the event of their occurrence; (iii) to protect the property rights of RSM Poland and the health, safety, property and property rights of customers and others; (iv) in other such situations. If such an event occurs, we will take all steps necessary to protect your personal data.
  • RSM Poland may share personal data of its clients with third parties in connection with the sale, purchase, merger, restructuring, liquidation or dissolution of RSM Poland or RSM Poland business unit or in other circumstances of this type. If such an event occurs, we will take all steps necessary to protect your personal data.
  • RSM Poland may share personal data with the consent or at the request of the data subject.

 

RSM Poland may share anonymised or aggregated information internally and with third parties for any purpose. Such information does not allow for the identification of persons.

 

Service providers

We transfer or disclose the personal information we collect to third party support providers (and their subsidiaries and affiliates) that we engage to support our internal support processes. For example, we engage support service providers to provide (i) general office support, including printing, document creation and management, archiving and translation services; (ii) accounting, finance and invoicing support; (iii) IT functions, including systems management and security, data storage, analytics, business applications, voicemail and system replication for business continuity/disaster recovery; and (iv) conflict control, risk management and quality reviews.

It is our policy to only use third party support providers who are committed to maintaining an adequate level of data protection, security and confidentiality, and who comply with all applicable legal requirements for transferring personal information outside of the jurisdiction in which it was originally collected. In the case of data collected in the European Economic Area (EEA) or concerning data subjects in the EEA, RSM Poland requires an appropriate data transfer mechanism if it is necessary to comply with applicable law.

 

Security

Personal data will be stored mainly in RSM Poland databases or databases belonging to RSM Poland service providers. RSM Poland takes all appropriate steps, through contracts or otherwise, to ensure adequate protection of personal data disclosed to third parties or transferred to other countries.

RSM Poland takes appropriate measures to ensure the confidentiality, security and integrity of the personal data held. We do our best to protect your personal information from unauthorised disclosure, misuse or alteration, as with all computer networks connected to the Internet, we cannot guarantee the absolute security of information transmitted over the Internet and we are not responsible for security breaches that we had no reasonable influence on.

 

Protecting your information

Data sent to us using the forms on the Website are encrypted in transmission.

Unfortunately, the transmission of information over the Internet is not completely secure. Any email you send to us may not be secure. We recommend that you not send any confidential information to RSM Poland by e-mail. If you choose to send us any sensitive information by e-mail, you do so at your own risk, knowing that a third party may intercept that information. Instructions sent by you via e-mail and to the Website are processed solely at your risk.

 

Links to third parties

From time to time, we include links on the Site to third parties outside the RSM network. The provision of a link does not imply that we endorse or approve of this site's visitor privacy policy. Before using such a site or submitting any personal information to it, please review the privacy statement posted on that site.

 

Period of storage of personal data

The time of storing personal data depends on their purpose and how they are used. The storage time for certain types of data is regulated by the relevant provisions of law. We store other data for no longer than necessary to achieve the purpose for which it was collected.

 

Minors

The RSM Poland website is not inappropriate for children under the age of 13. RSM Poland does not knowingly solicit or collect information from or about children under the age of 13 or any other legal minimum age, except as permitted by applicable law.

 

Social media

This Privacy Policy also applies when you participate in blogs, forums and social media platforms operated by RSM Poland ("Social Media Platforms") that we make available to you. The main purpose of social media platforms is to facilitate and enable content sharing. However, RSM Poland is not responsible for the sharing of personal data on social media platforms that are then misused or otherwise appropriated by another user.

RSM Poland may also provide links to other social media platforms maintained on separate servers by individuals or organisations over which RSM Poland has no control. RSM Poland makes no representations or warranties regarding the accuracy or any other aspect of the information on such servers. A link to a third party website should not be construed as an endorsement by RSM Poland of a person or company, or its website, products and services. RSM Poland makes no representations or warranties regarding how user data is stored or used on third party servers. We recommend that you review the Privacy Policy of each third party website linked to this Site to determine how they use your personal information. We have also implemented social plugins from social media platforms on the website www.rsmpoland.pl. If a corresponding social plug-in appears on the Website, the browser visiting the Website will establish a direct connection to the servers of the social media platform. These servers recognise that you are visiting this Website. If you are a member of the relevant social media platform and are logged in when visiting this website, the information will be assigned by the social media platform to your personal social media account. By clicking on the relevant plug-in icon on the Site (e.g. the "Like" button), this information will be shared on your personal social media platform user account. Please visit the Privacy Notice of the relevant social media platform provider to learn more about your rights and choices.

 

International services and data transfer

With your consent or where permitted by applicable data protection laws, information provided through the Site will be stored and used by RSM Poland at the locations and systems of the relevant members of the RSM network in other jurisdictions around the world. It may also be stored and used by RSM Network service providers who process personal data on our behalf and who may be located anywhere around the world.

We may transfer your personal data outside the EEA for storage purposes, in connection with referring you to a local RSM member who can provide the goods or services you request in order to enter into or perform a contract concluded with you, or in connection with enabling a support service that is to be provided in our legitimate interest arising from our use of your personal information, as described in this Privacy Policy. We may otherwise transfer your personal data if we are legally obliged to do so or to facilitate the operation of the international RSM network, if it is in our legitimate interest, and we have concluded that it does not override your rights.

If such personal data is processed in another country, in some cases that country may have a lower level of data protection than the country of origin (for example, when personal data is collected and processed in the EU/EEA and used or stored in a country outside the EU/EEA, a country outside the EU/EEA may have a lower level of data protection than countries within the EU/EEA). In such cases, RSM Poland will strive to ensure an adequate level of data protection, e.g. based on the European Commission's statement of the adequacy of transfers to certain countries: https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en or by using a recognised legal adequacy mechanism, including transfers subject to valid Privacy Shield certification or transfers subject to standard contractual clauses regarding the transfer of  personal data between controllers and between controllers and processors https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/model-contracts-transfer-personal-data-third-countries_en.

 

Related policies

The following documents provide additional information on privacy practices at RSM and RSM Poland:

- https://www.rsmpoland.pl/pl/polityka-prywatnosci-chmury-rsm
- https://www.rsm.global/privacy-notice

 

Complaints

If you suspect that RSM Poland violates privacy laws or any other regulations, you can contact an employee of RSM Poland with whom you usually cooperate.

In justified cases, you can submit a complaint to the supervisory body - the Head of the Office for Personal Data Protection (to the address of the Office for Personal Data Protection, ul. Stawki 2, 00-193 Warsaw).

 

Changes in Privacy Policy

We will update this Privacy Policy from time to time to reflect changes to our practices and services. If we post changes to this Privacy Policy, we will change the "date of the last update" at the top of this document. If we make material changes to the way we collect, use and share your personal information, we will notify you by posting the information about the changes on our website. We recommend that you check the content of this page at regular intervals to find out about changes to the content of this Privacy Policy.

 

Cookies

1. What is a cookie?

A cookie is a small text file that often contains a unique identifier that is sent to your computer or device when you visit a website.

Each website can send its own cookie to your browser if your browser preferences allow it, but to protect your privacy your browser will only allow the website to access cookies it has already sent you, not cookies sent to you by other sites. Many sites do this every time a user visits their site to track online traffic flows.

We use cookies to improve the quality of the Site and services and to improve your browsing experience. Some of the cookies we use only last for the duration of your web session and expire when you close your web browser. Others are used when, for example, we save information that you have requested yourself (such as language preferences) and may be retained for longer periods of time. 

2. How does RSM Poland use cookies?

Cookies are only used to record aggregated data about your use of the Site, including visit details such as pages viewed and resources you access. Such information also includes traffic data, location data and other communication data, all of which are used by us to improve the Site and thus provide a better user experience. Some cookies are set by us and some by third parties providing services on our behalf.

We use the following types of cookies:

Necessary Cookies: Allows you to move around the Site, manage your login session so you can easily navigate from one page to another on the Site, and page requests are loaded smoothly and securely.

Analytics: they collect statistical information about how you use the Website so that we can improve the Website, they also remember that you have used the Website before; this means we can identify the number of unique visitors we receive on different parts of the Site. We use Google Analytics, which is based on cookies, to analyse how visitors use the Website and to generate statistical reports. This information will usually be transferred to and stored by Google on servers in the United States. See "How to control and delete cookies" below for information on how you can make choices about the collection and use of this data.

Functionality cookies remember information you have asked us for (such as language preferences) and will last for a longer period of time.

Retargeting cookies and website beacons: RSM Poland occasionally advertises on third party websites and uses services provided by Google, including AdSense and DoubleClick services to manage and place advertisements. Service providers place a cookie on your device and this enables us to track the success of our advertising campaigns from time to time using visitor identification technology such as "web beacons" or "action tags" that count visitors to the Site after viewing an RSM Poland banner ad on a third party site. We do not use this technology to access your personal information and it is only used to create aggregated statistics about visitors who visit the Site and to measure the effectiveness of our advertising.

This Site does not use cookies to provide users with any targeted behaviour or interest-based advertising through the Site. For more information about interest-based cookies and to control the use of these cookies, please visit www.youronlinechoices.com

3. How to control and delete cookies?

RSM Poland does not use cookies to collect information enabling the identification of the user.

You can prevent the collection of the analytics and retargeting data described above, which are generated by cookies by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at the following link [https://tools.google.com/dlpage/gapout].

Most web browsers automatically accept cookies, but if you prefer, you can set your browser to accept all new cookies, notify you when you receive a new cookie, or disable cookies altogether. If you wish to restrict or block cookies used on the Site or any other site, you can do so through your browser settings. To find out how to do this, please use the help function in your browser, as each device may have its own individual rules.

Please note that by blocking or deleting cookies on the Website, you may not be able to use the full functionality of the Website.

4. Cookies on third party websites

The site occasionally embeds photos and video content from websites such as YouTube. As a result, when you visit a site with embedded content, such as YouTube, you may receive cookies from those sites. RSM Poland does not control the dissemination of these cookies. More information on this can be found on the relevant third party website.

5. More information

If you have any questions about this Cookie Policy, please contact us via email: gdpr@rsmpoland.pl