Privacy Policy
Privacy Policy effective as of 24 May 2018
The Adam Mickiewicz University Foundation in Poznań attaches particular importance to respecting the privacy of persons whose personal data it processes, including in connection with the operation of its website and the provision of services as well as activities performed or initiated by electronic means. In order to protect personal data, the Adam Mickiewicz University Foundation in Poznań applies the principles set out in the applicable provisions of law, including the GDPR Regulation.
This Privacy Policy sets out how we take care of personal data and the rights of persons whose personal data we process.
1. Who is the controller of personal data and how can you contact it?
The controller of your personal data is the Adam Mickiewicz University Foundation in Poznań, with its registered office in Poznań (61-612), ul. Rubież 46, entered in the register of entrepreneurs as well as the register of associations, other social and professional organisations, foundations and public healthcare units of the National Court Register under KRS number 0000052045, whose registration files are kept by the District Court Poznań – Nowe Miasto and Wilda, identified by Tax Identification Number (NIP): 7810002075, hereinafter referred to in this Privacy Policy as “FUAM”.
If you have any questions concerning the processing of personal data or the exercise of your rights, please contact the Controller by e-mail sent to the Data Protection Officer – Natalia Wolska: iod@ppnt.poznan.pl.
2. Contact details of the Data Protection Officer
FUAM has appointed a Data Protection Officer who can be contacted by e-mail at: iod@ppnt.poznan.pl.
3. For what purpose and on what legal basis do we process Personal Data?
FUAM processes your personal data for various purposes, listed below:
On the basis of Article 6(1)(a) GDPR, i.e. on the basis of consent given by the data subject, FUAM processes personal data for the purpose of:
sending a Newsletter;
sending commercial information;
marketing FUAM’s own products or services;
making contact and handling submissions resulting from contact forms;
registering for trainings, workshops, conferences or other events organised by FUAM or in cooperation with FUAM;
recruitment of employees;
recruitment for the purposes of a scholarship programme or a support programme organised by FUAM or in cooperation with FUAM, as well as implementation of a scholarship programme or a support programme;
operating websites available after user registration.
Giving consent to the processing of personal data for each of the above purposes is voluntary; however, it is necessary for FUAM to undertake the activities referred to above.
On the basis of Article 6(1)(b) GDPR, i.e. where it is necessary for the performance of a contract to which the data subject is a party, or in order to take steps at the request of the data subject prior to entering into a contract, for the purpose of:
performing, concluding, shaping the content of, amending or terminating contracts between FUAM and the data subject;
taking steps at the request of the data subject prior to entering into a contract.
This point applies in particular to contracts concluded via e-mail or the Internet, as well as actions taken prior to the conclusion of a contract initiated by a party via the Internet or e-mail.
On the basis of Article 6(1)(c) GDPR, i.e. for the purposes of fulfilling a legal obligation incumbent on FUAM, for the purpose of:
performing contracts with third parties, in particular to organise study trips for participants and to insure participants;
issuing invoices and fulfilling other obligations arising from tax law provisions.
On the basis of Article 6(1)(f) GDPR, i.e. for purposes resulting from FUAM’s legitimate interests, for the purpose of:
statistical, informational, archival and analytical purposes – in this case FUAM’s legitimate interest is the analysis of activities and services already performed by FUAM in order to adapt them to the needs of interested parties in the future and to learn about customer activity;
performing, concluding, shaping the content of, amending or terminating contracts to which FUAM is a party, as well as taking steps prior to entering into a contract – where the contract is concluded with a person other than the person designated for contact regarding the contract (e.g. an employee, a collaborator of the party) – in this case FUAM’s legitimate interest is the performance of the contract or taking steps prior to entering into it;
organising study trips and insuring their participants – in this case FUAM’s legitimate interest is pursuing FUAM’s statutory objectives;
conducting satisfaction surveys regarding services offered by FUAM – in this case FUAM’s legitimate interest is to learn customers’ opinions on the services provided in order to adapt them to the needs and expectations of interested parties;
establishing, pursuing or defending against claims – in this case FUAM’s legitimate interest is to possess personal data enabling it to establish, pursue or defend against claims, including those of customers and third parties;
administering FUAM websites – in this case FUAM’s legitimate interest is the necessity to operate and administer FUAM websites;
sending commercial information by FUAM – in this case FUAM’s legitimate interest is direct marketing.
Database. FUAM informs that each set of collected personal data is secured against access by unauthorised persons in a manner adequate to the purposes of processing and the threats. The IT system processing personal data meets the requirements of a high level of personal data protection.
We do not make personal data available to third parties unless this occurs with their explicit consent or at the request of the data subject or on the basis of legal provisions (including at the request of state authorities authorised under the law for the purposes of proceedings conducted by them or activities related to security or defence, for specific tasks carried out for the public good as provided by law).
4. How do we use cookies?
FUAM uses cookies on its websites in order to adapt the services provided and the content posted on websites to the individual needs of their users. The user has the right to disable cookie acceptance on their computer. In such a case, however, the user may lose the ability to use some of the functionalities available on our website.
Detailed information on the purposes and methods of using cookies is contained in the Cookies Policy, to which the cookie notice provided on a given website refers.
5. Requirement to provide personal data
Providing any personal data is voluntary and depends on your decision. However, in some cases providing certain personal data is necessary for FUAM to take appropriate actions at your request or to deliver specific services.
On FUAM websites, the data required to carry out the action covered by a given contact form is marked next to each form. Failure to provide the required data will make it impossible to take the relevant actions.
6. To whom do we disclose the personal data received from you?
We disclose your personal data to the following categories of recipients:
Processors. We cooperate with entities that process your personal data solely on our instruction. Where necessary, we disclose your personal data to entities providing us with financial and HR services, legal services, insurance services, hosting services, supplying us with online marketing systems, handling e-mail distribution, analysing website traffic, and analysing the effectiveness of marketing campaigns.
State authorities. We disclose your personal data if authorised state authorities request it, in particular organisational units of the prosecutor’s office, the Police, the Inspector General for Personal Data Protection (as of 25 May 2018: the President of the Personal Data Protection Office), the President of the Office of Competition and Consumer Protection, or the President of the Office of Electronic Communications. Nevertheless, we ensure that each request for disclosure of personal data is analysed very carefully and thoroughly to prevent the transfer of information to an unauthorised person.
Third countries. Like most entrepreneurs, we use various popular services and technologies offered by entities such as Facebook, Microsoft and Google. These entities joined the Privacy Shield programme on the basis of the European Commission Implementing Decision of 12 July 2016. Entities that joined the Privacy Shield programme guarantee that they will comply with high standards of personal data protection applicable in the European Union; therefore, using their services and technologies in the personal data processing process is lawful.
7. How long is your personal data stored?
We store your personal data for the period necessary for the purposes for which it is processed, in particular, although not exclusively, for the period of:
performance of the service;
performance of the contract, if such a contract has been concluded;
until the consent is withdrawn by the authorised person – in relation to data processed on the basis of consent;
in the case of data stored in particular for analytical, statistical and informational purposes – until they become outdated or lose their usefulness.
Beyond the above periods, FUAM stores data for the time necessary to carry out the complaint procedure, the time necessary to secure or pursue possible claims, and to fulfil a legal obligation arising in particular, although not exclusively, from tax or accounting regulations.
After you resign from receiving commercial information, your data will be anonymised.
8. What rights do you have in connection with the processing of your personal data?
All correspondence concerning the processing of personal data and the exercise of rights related to the processing of your personal data should be sent to: iod@ppnt.poznan.pl or by post to: Fundacja UAM, ul. Rubież 46, 61-612 Poznań, with the note “Personal Data”.
Right to withdraw consent (Article 7(3) GDPR). Any person whose personal data is processed has the right to withdraw the consent granted to FUAM at the time of providing personal data. Withdrawal of consent does not affect the lawfulness of processing carried out on the basis of consent before its withdrawal. Withdrawal of consent does not entail any negative consequences. However, it will prevent further use of FUAM services which, under applicable law, we may provide only with your consent.
Right of access (Article 15 GDPR). Everyone has the right to obtain confirmation from FUAM as to whether personal data concerning them is being processed, and, where that is the case, the data subject has the right to:
obtain information about the purposes of processing, the categories of personal data processed, the recipients or categories of recipients of that data, the planned period for which the personal data will be stored or the criteria used to determine that period, the rights you have under the GDPR and the right to lodge a complaint with a supervisory authority, the source of the data, automated decision-making including profiling, and the safeguards applied in connection with the transfer of data outside the European Union;
obtain a copy of their data.
Right to rectification (Article 16 GDPR). Everyone has the right to have their personal data rectified and completed if it is inaccurate.
Right to erasure (“right to be forgotten”) (Article 17 GDPR). Each of you has the right to request the deletion of all or some personal data processed by FUAM. This right will be respected by FUAM without undue delay if:
the personal data are no longer necessary for the purposes for which they were collected or otherwise processed;
a specific consent has been withdrawn in so far as the personal data were processed and there is no other legal ground for processing;
you have objected to the use of personal data for purposes such as marketing or satisfaction surveys, and the objection has been found justified;
the personal data are processed unlawfully.
In connection with an objection or withdrawal of consent, FUAM may retain certain personal data to the extent necessary to establish, pursue or defend against claims. This applies in particular to personal data including: first and last name, e-mail address and application history, which we retain for the purposes of handling complaints and claims related to the use of our services.
Right to restriction of processing (Article 18 GDPR). Everyone has the right to request restriction of processing of their personal data in the following cases:
the accuracy of your personal data is contested – then its use is restricted for the time necessary to verify the accuracy of the data, but no longer than 30 days;
processing is unlawful and you oppose erasure and request restriction instead;
personal data are no longer needed by FUAM for the purposes for which they were collected or used, but are required by you to establish, pursue or defend claims;
an objection to processing has been lodged – in such a case, restriction applies for the time necessary to determine whether FUAM’s legitimate grounds override the grounds for the objection.
Right to data portability (Article 20 GDPR). Everyone has the right to receive their personal data provided to FUAM and then transmit them to another controller of their choice. You also have the right to request that personal data be transmitted by FUAM directly to such other controller, where technically feasible.
Right to object (Article 21 GDPR). At any time you may object to the use of your personal data where it is processed on the basis of FUAM’s legitimate interest, e.g. in connection with marketing of services or satisfaction surveys. When your objection is found justified and we have no other legal basis for processing your personal data, we will delete your personal data in accordance with the objection.
How quickly do we comply with your requests? If you submit a request to FUAM in the exercise of the above rights, the request will either be complied with or refused without delay, no later than within 1 (one) month of its receipt. If it turns out that, due to the complex nature of the request or the number of requests, FUAM will not be able to comply within 1 (one) month, it will be fulfilled within the next 2 (two) months, and you will be informed in advance about the intended extension.
Submitting complaints, inquiries and requests. Complaints, inquiries and requests concerning the processing of your personal data may be submitted to FUAM at any time. If, for any reason, you believe that the right to personal data protection or other rights granted to you under the GDPR have been infringed, you have the right to lodge a complaint with the Inspector General for Personal Data Protection (as of 25 May 2018: the President of the Personal Data Protection Office).
9. Automated decision-making and profiling
FUAM does not carry out automated decision-making, including profiling. The content of an inquiry sent via contact forms is not assessed by an IT system.
10. Changes to the Privacy Policy
Any person using our websites in any way is bound by the Privacy Policy current at the time of using them. Changes in legislation regarding personal data protection, as well as other factors, may affect changes to the privacy protection policy. FUAM declares compliance with the principles set out in this Privacy Policy, but reserves the right to make changes to the Privacy Policy.
