General Data Protection Regulation

General Data Protection Regulation (GDPR)

Dear Customer,
In order to promote confidentiality of personal data and transparency of personal data processing, and in accordance with fair information practices and applicable provisions regarding the protection of personal data, we hereby inform you that the controller of your personal data is Cynk-Mal S.A. (hereinafter referred to as "the Company") with its registered office in Legnica at ul. Pątnowska 48, entered in the Register of Entrepreneurs of the National Court Register kept by the District Court for Wrocław-Fabryczna in Wrocław, 9th Commercial Division of the National Court Register, under the number 0000284987, NIP: 6911115171, REGON: 390406820, share capital of PLN 20,191,000.00 (paid up).

Scope of the document
This notice explains how the Company processes personal data of its contractors as part of its cooperation activities and keeping records, resulting from the applicable provisions of law.

Collection of personal data
We collect your personal data in several ways:
  1. You provide it yourself, for example when you conclude and sign a contract or when you provide us with information by phone or other available means of communication.
  2. Data can also be obtained from third parties, for example from your employers as well as from cooperating entities.
  3. Data can also be obtained from publicly available sources, such as registers or published websites
Use of personal data
We process the personal data of our contractors for the following purposes: 
  1. Preparation and signing of a contract (an offer or an order) and taking actions before the conclusion of a contract, including: 
    • Submitting an offer,
    • Negotiating the terms of cooperation,
    • Contact in matters related to a contract (an offer or an order),
    • Signing a contract,
    • Storage of a contract;
  2. Performance of a concluded contract (an offer or an order), including: 
    • Confirmation of an order or a job order,
    • Contact regarding the implementation of a contract or an order,
    • c.    Taking actions required to perform a contract or an order (e.g. transport, shipment);
  3. Providing after-sales service;
  4. Keeping financial and accounting documentation;
  5. Contractor verification and sales security;
  6. Monitoring of receivables and pursuing or defending claims in cooperation matters;
  7. Planning the delivery of services as well as management and internal reporting;
  8. Marketing of own products. 
Scope of data
For each process and purpose we collect different types of data, which may include: 
  1. name / surname, name of the company or activity,
  2. identification code (e.g. customer code),
  3. address and contact details (e.g. street, house number, zip code, e-mail address, telephone number),
  4. other identification data (NIP, REGON, business registration number, ID card or PESEL number),
  5. bank details (e.g. account number, name of bank),
  6. organizational data (e.g. position / function, superior),
  7. basic contract data (e.g. date of conclusion, number, subject matter, term, contractual price, terms of service, characteristics of goods),
  8. information about transports and shipments being carried out,
  9. numbers, dates, values and content of invoices and other financial and accounting documents.
Legal basis for the processing
Our use of personal data has different legal bases:  
  1. We use your personal data because their processing is necessary to:
    • perform a contract concluded between you and us or in order to take the necessary steps to conclude a contract (in accordance with Art. 6 (1) (b) of the GDPR).
    • comply or fulfil the legal obligation to which we are subject in accordance with Art. 6 (1) (c) of the GDPR; in particular, we are required to comply with the following acts:
      • Act of 11 March 2004 on the Tax on Goods and Services
      • Accounting Act of 29 September 1994.
    • ascertain, pursue or defend claims or in the course of administration of justice by the courts (in accordance with Art. 9(2)(f) of the GDPR).
    • for purposes arising from legitimate interests we or a third party may have in accordance with Article 6(1)(f) of the GDPR. Legitimate interests are mainly focused on:
      • Verification of contractors and sales security,
      • Monitoring of receivables and pursuing or defending claims in cooperation matters,
      • Planning the delivery of services,
      • Management and internal reporting,
      • Marketing of own products.
  2. If the collection and use of data is based on our legitimate interest, you have the right to object to the processing. In this case, we will cease further processing of your personal data, unless we demonstrate the existence of legally valid grounds for doing so.
  3. We may also process your personal data, if you have given us your consent (according to Art. 6 (1) (a) of the GDPR) – this applies mainly to marketing activities.
In this case, you may withdraw your consent to us processing your personal data, as a whole or for specific purposes - at your discretion, at any time. Withdrawal of consent will not affect the lawfulness of processing based on your consent prior to its withdrawal.

Disclosure of personal data
We may disclose your personal data for legitimate purposes to the following third parties: 
  • Entities with which we collaborate, where the disclosure is necessary for the performance of a contract,
  • Other entities, when we are required to do so, for example in accordance with the provisions of applicable law or a court order.
  • Other entities, if we acquire your consent
  • Suppliers of goods and services who process data at the exclusive request of the data controller and are contractually obliged to protect the data entrusted to them.
Personal data may be made available to entities in third countries after ensuring an adequate level of protection and in accordance with applicable law. Ensuring the adequate level of protection will take place through the use of technical means and signing standard contractual clauses issued by the European Commission or based on commitments undertaken under the Privacy Shield between the European Union and the USA.

Storage period
Data are stored for a period required by law or for a period necessary for the performance of a contract or for another processing purpose.

The obligation to transfer personal data
Personal data are provided voluntarily. However, they are required for the conclusion and performance of contracts and for keeping documentation required by law.

Your rights
You have the right to request access to your personal data. In many cases, you also have the right to request that your personal data be corrected, deleted, transferred, or that their processing be restricted.
You have the right to object to us processing your personal data if the collection and use thereof is based on our legitimate interest. Should you exercise your right to object, we will cease any further processing of the personal data to which you objected, unless we demonstrate that there are valid legitimate grounds for further processing.
Moreover, you are entitled to lodge a complaint with the national supervisory authority.
If your personal data are processed for other purposes, you will be informed about it.

If you wish to exercise your rights, please contact us at the following e-mail address: