Privacy Policy

1. Who is the administrator of your personal data?

We, Electrum Holding Sp. z o.o. based in Białystok, are the Administrator of your personal data. You can contact us:

• by mail, sending a letter to the address: Watykańska 13, 15-638 Białystok
• via email, at the email address: iod@electrum.pl
• by phone, at the number: +48 85 664 73 73, tel. +48 85 664 73 72

2. How can you contact the Data Protection Officer?

We have appointed a person who serves as the Data Protection Officer, with whom you can contact regarding all matters concerning the protection of your personal data:

• via email, at the email address: iod@electrum.pl
• by mail, sending a letter to the address: Watykańska 13, 15-638 Białystok

3. What data of yours do we process and from what sources do we obtain them?

In connection with the conclusion or performance of a contract, we may process the following categories of your personal data:

• identification data: name and surname, position, function performed, PESEL number or date of birth;
• registration data: NIP, REGON;
• contact data: email address, phone number, correspondence address;
• financial data: bank account number.

We obtain your personal data from the entity you represent or for which you act, as well as from publicly available sources (e.g., KRS and CEIDG).

4. For what purposes and on what basis do we process your data?

We process your personal data for the purpose of:

• concluding and performing a contract (basis from Art. 6(1)(b) of GDPR – if you are a party to the contract) or fulfilling our legitimate interest in properly performing the contract (for persons cooperating with us on behalf of the client/contractor, basis from Art. 6(1)(f) of GDPR);
• conducting settlements, accounting, and financial reporting (basis from Art. 6(1)(c) of GDPR);
• archiving (evidentiary), being the fulfillment of our legitimate interest in securing information in case it is necessary to demonstrate facts (basis from Art. 6(1)(f) of GDPR);
• verifying the occurrence of a conflict of interest, being the fulfillment of our legitimate interest in avoiding conflicts of interest (basis from Art. 6(1)(f) of GDPR);
• potentially establishing, pursuing, or defending against claims and allegations in the execution of our legitimate interest (basis from Art. 6(1)(f) of GDPR).

5. What rights do you have regarding data processing?

You have the following rights:

• the right to withdraw consent (where the legal basis for processing is consent) at any time. Your withdrawal of consent will not affect the lawfulness of the processing carried out before its withdrawal;
• the right to access your data and receive a copy of it;
• the right to rectify your data;
• the right to delete or limit the processing of data;
• the right to object to the processing of data, based on our legitimate interest;
• the right to data portability;
• the right to file a complaint with the supervisory authority (in Poland, this is the President of the Personal Data Protection Office).

6. To whom do we disclose your data?

• We disclose your personal data to other entities belonging to the Electrum capital group based on concluded contracts, as well as to our partners with whom we cooperate in the implementation of processes and subcontractors, e.g., IT service providers, our employees, and collaborators authorized to process personal data in connection with performing official duties.
• We also transfer your personal data to authorized bodies or institutions in accordance with applicable legal regulations.
• We do not transfer your personal data to recipients located outside the European Economic Area.

7. How long will we store your data?

We will process your personal data during the term of the contract and additionally for a period enabling the realization of our legitimate interest constituting the basis for processing or until an effective objection to processing is raised.

8. Is providing your data mandatory?

Providing your personal data is voluntary, but necessary for the purposes related to the conclusion and performance of the contract.

9. Automated decision-making, including profiling of your data

We do not process your personal data using automated decision-making, including profiling, as referred to in Art. 22(1) and (4) of GDPR.

1. Who is the administrator of your personal data?

As your Employer, Electrum Holding Sp. z o.o. is the administrator of your personal data. You can contact us:

• by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok;
• via email, at the email address: iod@electrum.pl;
• by phone, at the number: 85 664 73 73.

2. How can you contact the Data Protection Officer?

We have appointed a person responsible for the area of data protection, whom you can contact regarding all matters concerning the protection of your personal data:

• via email, at the email address: iod@electrum.pl;
• by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok.

3. For what purposes and on what basis do we process your data?

We process your personal data for the purpose of:

• performing the employment contract and fulfilling the rights and obligations arising from it, including the payment of wages, potential provision of social benefits, maintaining documentation related to the employment relationship, and personal files of employees (basis from Art. 6(1)(c) of GDPR and the Labor Code, and for data beyond what is specified in the Labor Code, the basis from Art. 6(1)(a) of GDPR);
• fulfilling our legal obligations in the area of social security and taxes (basis from Art. 6(1)(c) of GDPR and Art. 9(2)(b) of GDPR);
• providing and managing, including cost settlement, additional benefits offered by us or entities cooperating with us, of which you may be a beneficiary, particularly related to medical care, additional insurance, sports cards, and other benefits (basis from Art. 6(1)(b) of GDPR);
• using the results of your work to improve, verify, and present our services, being the fulfillment of our legitimate interest in enhancing the quality of services provided and fulfilling the provisions of agreements concluded with our contractors (basis from Art. 6(1)(f) of GDPR);
• publishing your data including name, surname, business email address, business phone numbers, office, position, place in the organizational structure, image – if you decide to include your photo, in portals and internal systems of the Electrum capital group, as well as in other IT tools used by us or other entities belonging to the Electrum capital group, being the fulfillment of our legitimate interest and the legitimate interest of other entities belonging to the Electrum capital group, in facilitating communication and cooperation within the Electrum capital group (basis from Art. 6(1)(f) of GDPR);
• presenting you as our representative in relations with our contractors within the scope of your official duties, being the fulfillment of our legitimate interest in fulfilling the provisions of agreements concluded with our contractors (basis from Art. 6(1)(f) of GDPR);
• ensuring physical security and information security in connection with the use of video surveillance of office building premises, the area in front of the building, and our contracts/construction sites, as well as using access control to rooms, being the fulfillment of our legitimate interest (basis from Art. 6(1)(f) of GDPR);
• potentially establishing, pursuing, or defending against claims and allegations in the execution of our legitimate interest (basis from Art. 6(1)(f) of GDPR).

4. What rights do you have regarding data processing?

You have the following rights:

• the right to withdraw consent (where the legal basis for processing is consent) at any time. Your withdrawal of consent will not affect the lawfulness of the processing carried out before its withdrawal;
• the right to access your data and receive a copy of it;
• the right to rectify your data;
• the right to delete or limit the processing of data;
• the right to object to the processing of data, based on our legitimate interest;
• the right to data portability;
• the right to file a complaint with the supervisory authority (in Poland, this is the President of the Personal Data Protection Office).

5. To whom do we disclose your data?

• We disclose your personal data to other entities belonging to the Electrum capital group in connection with the performance of contracts, as well as to our partners with whom we cooperate in the implementation of personnel matters, e.g., entities providing health services, additional insurance, sports cards, and other benefits, training companies, archiving companies, law firms, IT companies.
• We also transfer your personal data to authorized bodies or institutions in accordance with applicable legal regulations.

6. How long will we store your data?

We process your personal data for the following periods:

• for the purposes specified in section 3 points 1) – 2) for the period of storing employee documentation specified in the Labor Code or other legal regulations, subject to data processed based on consent, which will be stored no longer than until the consent is withdrawn;
• for the purpose specified in section 3 point 3) for the duration of the employment relationship;
• for the purposes specified in section 3 points 4) – 7) for the period enabling the realization of a legitimate interest or until an effective objection to the processing is raised;
• for the purpose specified in section 3 point 8) for the limitation period for claims.

7. Is providing your data mandatory?

To the extent that we process personal data based on the Labor Code or other legal regulations, providing data is a statutory requirement necessary to conclude an employment contract or fulfill a legal obligation imposed on us. Failure to provide this data will prevent the conclusion of the employment relationship or the fulfillment of our legal obligations. To the extent that we process personal data based on consent, providing personal data is voluntary. However, failure to provide personal data may prevent the employee from benefiting from additional benefits.

8. Automated decision-making, including profiling of your data

We do not process your personal data using automated decision-making, including profiling, as referred to in Art. 22(1) and (4) of GDPR.

1. Who is the administrator of your personal data?

We, Electrum Holding Sp. z o.o. are the administrator of your personal data. You can contact us:

• by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok;
• via email, at the email address: iod@electrum.pl;
• by phone, at the number: 85 664 73 73.

2. How can you contact the Data Protection Officer?

We have appointed a person responsible for the area of data protection, whom you can contact regarding all matters concerning the protection of your personal data:

• via email, at the email address: iod@electrum.pl;
• by mail, sending a letter to the address: ul. Watykańska 13, 15-638 Białystok.

3. For what purposes and on what basis do we process your data?

We process your personal data for the purpose of:

• performing the commission contract and fulfilling the rights and obligations arising from it, including the payment of wages (basis from Art. 6(1)(b) of GDPR);
• fulfilling our legal obligations in the area of social security and taxes (basis from Art. 6(1)(c) of GDPR and Art. 9(2)(b) of GDPR);
• providing and managing, including cost settlement, additional benefits offered by us or entities cooperating with us, of which you may be a beneficiary, particularly related to medical care, additional insurance, sports cards, and other benefits (basis from Art. 6(1)(b) of GDPR);
• using the results of the tasks you have completed to improve, verify, and present our services, being the fulfillment of our legitimate interest in enhancing the quality of services provided and fulfilling the provisions of agreements concluded with our contractors (basis from Art. 6(1)(f) of GDPR);
• publishing your data including name, surname, business email address, business phone numbers, office, position, place in the organizational structure, image – if you decide to include your photo, in the Electrum Capital Group address book available to the personnel of entities belonging to the Electrum Capital Group, as well as in other IT tools used by us or other entities belonging to the Electrum Capital Group, being the fulfillment of our legitimate interest and the legitimate interest of other entities belonging to the Electrum Capital Group, in facilitating communication and cooperation within the Electrum Capital Group (basis from Art. 6(1)(f) of GDPR);
• presenting you as our representative in relations with our contractors within the scope of your official duties, being the fulfillment of our legitimate interest in fulfilling the provisions of agreements concluded with our contractors (basis from Art. 6(1)(f) of GDPR);
• ensuring physical security and information security in connection with the use of video surveillance of office premises, as well as using access control to rooms and personalized badges, being the fulfillment of our legitimate interest (basis from Art. 6(1)(f) of GDPR);
• potentially establishing, pursuing, or defending against claims and allegations in the execution of our legitimate interest (basis from Art. 6(1)(f) of GDPR).

4. What rights do you have regarding data processing?

You have the following rights:

• the right to withdraw consent (where the legal basis for processing is consent) at any time. Your withdrawal of consent will not affect the lawfulness of the processing carried out before its withdrawal;
• the right to access your data and receive a copy of it;
• the right to rectify your data;
• the right to delete or limit the processing of data;
• the right to object to the processing of data, based on our legitimate interest;
• the right to data portability;
• the right to file a complaint with the supervisory authority (in Poland, this is the President of the Personal Data Protection Office).

5. To whom do we disclose your data?

• We disclose your personal data to other entities belonging to the Electrum capital group in connection with the performance of contracts, as well as to our partners with whom we cooperate in the implementation of personnel matters, e.g., entities providing health services, additional insurance, sports cards, and other benefits, training companies, archiving companies, law firms, IT companies.
• We also transfer your personal data to authorized bodies or institutions in accordance with applicable legal regulations.

6. How long will we store your data?

We process your personal data for the following periods:

• for the purposes specified in section 3 points 1) – 2) for the period of storing documentation specified by legal regulations;
• for the purpose specified in section 3 point 3) for the duration of the commission contract;
• for the purposes specified in section 3 points 4) – 7) for the period enabling the realization of a legitimate interest or until an effective objection to the processing is raised;
• for the purpose specified in section 3 point 8) for the limitation period for claims.

7. Is providing your data mandatory?

• To the extent that we process personal data based on regulations governing social security and tax obligations, providing data is a statutory requirement necessary to conclude a commission contract or fulfill a legal obligation imposed on us. Failure to provide this data will prevent the conclusion of a commission contract or the fulfillment of our legal obligations.
• In other respects, providing personal data is voluntary. However, failure to provide personal data may prevent the conclusion of a commission contract or the enjoyment of additional benefits. If personal data is processed based on consent, you may withdraw your consent at any time. Withdrawal of consent will not affect the lawfulness of the processing carried out before its withdrawal.

8. Automated decision-making, including profiling of your data

We do not process your personal data using automated decision-making, including profiling, as referred to in Art. 22(1) and (4) of GDPR.