GFT Privacy Notice

This Information Describes

The nature, scope, and purpose of collecting, processing, and using personal data, which applies not only to our website but also to other services we offer.

• „Personal Data Controller and Data Protection Officer“  Section

In this section of the notification, you will find the name and address of the legal entity responsible for data processing, as well as the name of the Chief Privacy Officer of GFT appointed as the Data Protection Officer (DPO) and the Local Data Protection Officer. You will also find contact details for matters related to personal data processing.

• "Know your rights" Section

Here, you will find information about your rights concerning the processing of your personal data by us.

• "Data sharing and transfer" Section

This section provides information about the sharing, transfer, and distribution of collected personal data within the Group and with external partners.

• "Use of cookie files" Section

Here, you will find information about the use of cookies and similar technologies by our websites and services to collect information that may also be personal data.

To learn more about how GFT processes your personal data when using our services, please click on the name of the relevant activity, where you will find detailed information about the purpose, legal basis for processing, data retention period, and entities to whom the data is disclosed.

 

The Controller of the personal data (hereinafter: „Controller“):

GFT Poland Sp. z o.o.

with its seat at 66 Kilinskiego St. in Lódź, Poland

Company Register Number (KRS): 0000284121

Nr tel.: +48 42 663 08 60

Adress email: info@gft.com

Internet webpage: www.gft.com/pl

 

Data Protection Officer: Ernst O. Wilhelm, Chief Privacy Officer of GFT

Country Privacy Officer: Ilona Szmaj

Contact for personal data protection issues in marketing: marketing.subjectrequest@gft.com

Contact for personal data protection issues in HR: hr.subjectrequest@gft.com

Contact for filing complaints regarding our privacy practices: dataprotection.group@gft.com, dataprotection.poland@gft.com,

Contact for obtaining information to any other kind of subject: info@gft.com

Report a personal data incident connected with GFT: databreach@gft.com

Because we process your personal data you have the right to:

• Request access to personal data concerning you, including information on the processing of such data;
• Rectify or complete personal data if it is incorrect or incomplete;
• Request the erasure of personal data (right to be forgotten) if there is no longer any legal basis for processing or when your consent to process the data has been withdrawn;
• Object at any time to the processing of your personal data based on our legitimate interests. After objection, we will not process your personal data for these purposes unless there are compelling legal basis for such processing which override your interests, rights and freedoms or there are grounds for establishing, pursuing or defending claims.
  1. In particular, you have the right to object at any time to the processing of your personal data for direct marketing purposes, in which case we will not process your personal data for such purposes.
• Withdraw your consent to processing at any time. The withdrawal of consent does not affect on the lawfulness of the processing of your data that was carried out on the basis of the consent given before its withdrawal.
• Request the restriction of processing if it is inaccurate, unnecessary, processed without a legal basis or if an objection has been made to the processing on the basis of a legitimate interest of the Controller;
• Receive and transfer personal data in a structured, commonly used format, to reuse your personal data for your own purposes across different services, in the case of data provided to the Controller and processed on the basis of your consent.

 

If you wish to exercise your right, please contact the address given in „Personal Data Controller and Data Protection Officer“ paragraph.

You also have the right to lodge a complaint with a supervisory authority if you consider that the processing of your personal data violates the law.

The supervisory authority

UODO

Stawki St. 2

00-193 Warsaw, Poland

tel. +48 22 531-03-00

website: www.uodo.gov.pl

E-mail: kancelaria@uodo.gov.pl

 

 

GFT is an international organisation with operations and technical structures and systems in many countries and jurisdictions. We may therefore share personal data or relevant derivatives of personal data with GFT Group and transfer it to countries where we do business, for a specific purpose and in accordance with this notice. This includes countries outside the European Economic Area (the "EEA"). See list of GFT Group members.

This notice and our practices are designed to provide an adequate level of protection for personal data in each country in which we operate. This means that even in countries that offer less protection for your data, GFT will still handle your data in the manner described here. Our contractors and agents in third countries who help us provide services are also legally obliged to maintain an adequate level of data protection and information security including contractual, technical and organisational measures.

We will transfer or share your data with others for marketing purposes with your knowledge or consent and only on the basis and within the limits of applicable law.

Please also be aware that in certain circumstances personal data may be disclosed to public authorities for the purposes of legal proceedings, a court order or legal process.

Regardless of the purposes and means of transfer, the transfer will always be based on the grounds and within the limits set out by applicable law, using certain measures to ensure the security of the transferred data.

Cookies are small blocks of data created by a web server while a user is browsing a website and placed on the user's computer or other device by the user’s web browser.

Essential and non-essential cookies

Essential (necessary) cookies enable the correct use of the website, in particular enable transmission or ensure the security of the connection. Non-essential cookies can be used to save the user's preferences and use them during the next visit (e.g. language), for statistical purposes (e.g. to count the number of visitors) or for marketing purposes (e.g. collecting information on the materials downloaded from the GFT website to recognise the user's interests).

Session cookies and persistent cookies

Session cookies help you navigate through the website efficiently, keeping track of your progression from page to page so that you are not asked for information you have already provided during the current session. Session cookies are stored in the browser’s temporary storage and erased when the web browser is closed. The use of Session cookies does not require explicit consent.

Persistent cookies, on the other hand, store user preferences for current and successive visits. They are written on your device's non-volatile memory (typically the hard disk), and are still valid when you restart your browser. Persistent cookies are often used to track user behavior and to promote targeted advertising. The use of persistent cookies usually requires explicit consent.

First party and third party cookies

First Party cookies are set by the website owner responsible for notifying the website user about the purpose of data processing and for obtaining user consent. Third Party Cookies are set by some Third Party Plug-Ins, and both the website owner and the Third Party are jointly responsible for notifying the user of the purpose of data processing and for obtaining user consent.

First Party Cookies on GFT websites

GFT Website makes use of First Party Cookies by means of Session Cookies (namely for Login and Search purposes) to enable the correct use of the website and navigate through the website efficiently. These cookies will be deleted at end of the session.

Third Party Cookies on GFT websites and services

GFT website and services make use of Third Party Cookies for:

• Website optimization - gathering information about website traffic in order to customise the design, functionality and the selection of materials available on the website.
• Marketing purposes - gathering information about your activities in order to determine your interests, professional profile, materials and services of GFT that you are or may be interested in.
• Provide services - the use of cookies to enable the use of external tools (e.g. for online meetings, webinars) and to make use of content provided by third parties (e.g. links to profiles and material on other websites or platforms).

Before using this data, the GFT website asks for your explicit consent to collect, process, use and share this data within GFT Group and our suppliers. For more information, please refer to the section "Data sharing and data transfer".

Google Analytics

In order to optimize our website, we collect and use data from web-based tools that operate on information collected via cookies, such as Google Analytics, offered by Google Inc. ("Google"). Google Analytics uses "cookies", which are text files placed on your computer, to help the website analyze how users use the site. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information and analyze it in order to compile reports on website activity for website operators.

Our website also uses Google Optimize which is part of Google Analytics toolset. Google Optimize allows us to use so-called A/B tests to verify how different types of changes on a website (e.g. changes to input fields, design changes etc.) can affect visitor activity on it. It helps us to improve the usability of the website and improve the behavior of our users on the website.

Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You may refuse the use of cookies by selecting the appropriate settings on your browser. However please note that if you do this you may not be able to use the full functionality of this website. Please note that your device (tablet, cellphone, etc.) address (known as IP address) is forwarded in a truncated version to preclude any direct relation to persons.

Learn more about Google Analytics and privacy here: https://support.google.com/analytics/answer/6004245

Pardot

The GFT website uses the Pardot tool, provided by Pardot LLC, 950 E. Paces Ferry Rd. Suite 3300 Atlanta, GA 30326, USA., for marketing automation, which collects and analyses information about activity on the GFT website. This tool does not in any way link the user's activity to his/her personal data, unless the data subject provides his/her data voluntarily (e.g. as part of a request to send documents electronically).

Based on the data subject's activity on the GFT website, the Pardot tool assigns a numerical score to the user, which tells us how interested the user is in the GFT material. However, this score does not carry any consequences for the data subject. Based on the data subject's interests indicated on the GFT website and analyzed by Pardot, GFT may offer the data subject similar documents to those in which the data subject was interested. This does not deprive the data subject of the possibility of downloading these documents independently of Pardot's analysis.

Pardot uses persistent cookies for convenience: Based on previous form submissions we can pre-fill forms with information like name and email address. In addition the cookies help us to track user behavior in order to optimize our website for the needs of our visitors. A second persistent cookie saves your „do not track“ setting.

Using our site you can download additional information such as review articles and opinion pieces, as well as sign up for webinars and other online events providing exclusive and free access to our experts with financial expertise. When downloading or registering you are asked to provide personal data (name and surname, e-mail address, job title, company name, telephone number, company size, industry, country) and according to the information contained in the relevant forms, this data will be processed for marketing purposes, in particular to monitor interest in our activities and products and services. During these processes we use forms integrated with Pardot.

Pardot is used to get and stay in touch with GFT mailing list subscribers. It provides through emails information matching the area subscriber is interested in. Nevertheless, access to such information is not restricted by subscription and is possible without it.

Further information on how Pardot uses cookies can be found here: http://help.pardot.com/customer/portal/articles/2125776-pardot-cookies-overview.

GoToWebinar

The webinar tool GoToWebinar uses four different types of cookies. They will only be placed on your device in case you register for a GFT webinar and log in with the link provided to the GoToWebinar website. GoToWebinar uses persistent cookies to store your preferences across sessions, to remember your identity, to target advertising and for security reasons.

For further information on how GoToWebinar uses cookies please visit: https://www.logmeininc.com/de/legal/privacy [Chapter “3. Analytics, Cookies and Other Web Site Technologies“]

Delete Cookies

Browsers usually automatically permit cookies, but also give you the ability to control the majority of cookies, including whether or not to accept and how to remove them. You can also set your browser to turn off cookies altogether. However, this setting will affect persistent cookies as well as transient and as a consequence you may not be able to use the full functionality of this website.

If you want to delete cookies or change the rules for allowing the use of cookie files, see the settings of your web browser or your device.

Managing consent for the use of cookies

We only use the necessary cookies if you have consented to this, in particular by using Cookiebot on your first visit to one of the GFT websites.

If you want to know the detailed list of cookies used by GFT or change your decision concerning their use click here.

 

In order to enable our website to function properly, we process user information that is necessary to maintain and secure an ongoing session. We use essential cookies for this purpose and it does not require your consent.

We also use cookie files for website optimization, marketing purposes and provide services, but only if you have given your prior consent to such use.

You can find more information on how we use cookie files in the section „Use of cookie files“.

Third-party websites

The GFT website contains links to other websites. We are not responsible for the privacy policies of third party websites, including the collection and use of your personal data by the operators of such websites.

Social plug-ins

The GFT website contains sharing buttons that allow the user to share links from the GFT website via Facebook, Twitter, XING, LinkedIn or Viadeo. Without an explicit action (clicking the button of the social media), our site does not communicate with any social network.

Please be aware when commenting publicly on an article posted on GFT websites (e.g. GFT Blog), information you post (including your username and e-mail address) are available for all site visitors to see. As a consequence, they might be collected and used by them. We strongly recommend avoid contributing to discussion using information that may contain personal details or other data that can be considered sensitive.

Your personal data collected in connection with the commenting on published materials are processed for the purpose:

1. to maintain contact and respond to the question/enquiry/comment addressed – based on your consent expressed by providing data in the comment;

Your personal data may be entrusted for processing to or shared with:

1. our collaborators and external entities performing certain services for us (e.g. data storage, communication tools, legal support) - on the basis of respective authorizations or data processing agreements;
2. authorities entitled to request access to the data if, on the basis of a ruling or a decision of the entitled body or provisions of generally applicable law, we will be obliged to disclose them.

The period of time we will process your data (data retention period):

1. we will process data collected based on your consent until you withdraw it, which you can do at any time, especially by deleting a comment (for more information, see "Know your rights")

Your personal data collected in connection with the completion of an online contact form, a letter, an enquiry, a request addressed to us, whether orally, in writing or via email address, as well as data processed in connection with ongoing conversations, existing cooperation or other exchanges are processed for the purpose:

1. to maintain contact and respond to the letter/request/enquiry addressed – based on your consent expressed by providing data in the letter/request/enquiry;
2. archiving the conversations held and managing the contacts established – based on our legitimate interest in conducting efficient and transparent communication;

Your personal data may be entrusted for processing to or shared with:

1. our collaborators and external entities performing certain services for us (e.g. data storage, communication tools, legal support) - on the basis of respective authorizations or data processing agreements;
2. authorities entitled to request access to the data if, on the basis of a ruling or a decision of the entitled body or provisions of generally applicable law, we will be obliged to disclose them.

The period of time we will process your data (data retention period):

1. we will process data processed based on your consent until you withdraw it, which you can do at any time (for more information, see "Know your rights").
2. we will process your data based on our legitimate interest for a period of 3 years from the last contact or until you object to that processing (for more information, see " Know your rights").

Your personal data obtained in connection with subscribing to the newsletter or agreeing to receive commercial information electronically when attending an event or filling in a form is processed for the purpose:

1. to send you by e-mail a newsletter or other messages containing information about our activities and advertising content concerning our products – based on your consent 
2. to communicate by other electronic communication channels (e.g. phone, sms, mms, etc.) commercial information within the scope of your consent - based on your consent;
3. to analyze interest in our business, products and services in order to improve the quality of our offering and optimize our marketing campaigns - on the basis of our legitimate interest in analyzing feedback data obtained as a result of our marketing activities.

Your personal data may be entrusted for processing to or shared with:

1. our employees and to third parties who perform certain services for us (e.g. website hosting, support in data analysis and optimization of advertising campaigns, deliver of marketing tools) - on the basis of appropriate authorizations or processing agreements;
2. authorities entitled to request access to the data if, on the basis of a ruling or a decision of the entitled body or provisions of generally applicable law, we will be obliged to disclose them.

The period of time we will process your data (data retention period):

1. We will process data processed on the basis of your consent until you withdraw it, which you can do at any time (for more information, see the "Know your rights" section).

Data processed on the basis of our legitimate interest will be processed until this purpose is fulfilled, however, no longer than until you object (for more information, see "Know your rights") or for the period appropriate to the means with which they were collected (e.g. restrictions resulting from the use of specific cookies – more information you can find on our „Cookie declaration“).

When you follow, leave comments, engage in conversation in private messages, or otherwise interact with our profiles on various social media platforms, we become the Controller of your personal data visible to us in accordance with the terms and conditions of the relevant social media platform.

We process the personal data that you use in accordance with the privacy policy set forth by the platform on which you have an account. This may include, but is not limited to, your name, date of birth, image, information about where you live and work and other information associated with your account, as well as any personal data that you voluntarily make public on a particular social media platform or provide to us in a private message.  

Your personal data is processed:

1. To maintain our profile on a social media platform in accordance with the terms and conditions and privacy policy of the platform, including for the purpose of interacting with other users of the platform - on the basis of our legitimate interest to effectively maintain a social media profile and manage our network of contacts;
2. Defence against claims and assertion of your rights - on the basis of our legitimate interest in protecting against claims from entities and third parties.

Your personal data may be entrusted for processing to or shared with:

1. our employees and to third parties who perform certain services for us (e.g. legal support) on the basis of appropriate authorizations or processing agreements;
2. authorities entitled to request access to the data if, on the basis of a ruling or a decision of the entitled body or provisions of generally applicable law, we will be obliged to disclose them.

The period of time we will process your data (data retention period):

1. We will process your personal data until you object to further processing by clicking "dislike", revoking your liking of a post or deleting a comment on a post or by contacting us at dataprotection@gft.com.

 

Social media platforms have their own privacy policies, regulations and data processing rules, which are binding for their users and which we are obliged to comply with just like any other user. If you have an account on such a platform, the processing of your personal data is also subject to the regulations and policies set by the administrator of the platform, who may, among other things, decide how to exercise your rights under them.

Your personal data obtained in connection with your registration for an online event, webinar or conference, by filling in the form, will be processed for the following purposes:

1. organization of the event in accordance with the accepted terms & conditions - on the basis of the contract concluded upon acceptance of the terms & conditions;
2. current contact related to the event, possible correspondence regarding complaints, comments, requests and claims, also for the purpose of asserting or defending against claims - on the basis of the legitimate interest of the organizer(s) of the event consisting in the efficient organization of the event and protection against claims by entities and third parties;
3. to send you by e-mail a newsletter or other messages containing information about our activities and advertising content concerning our products – based on our legitimate interest in marketing our own services and products
4. to communicate by other electronic communication channels (e.g. phone, sms, mms, etc.) commercial information within the scope of your consent - on the basis of your consent.
5. to analyze interest in our business, products and services in order to improve the quality of our offering and optimize our marketing campaigns - on the basis of our legitimate interest in analyzing feedback data obtained as a result of our marketing activities.

Your personal data may be entrusted for processing to or shared with:

1. to our employees and to third parties who perform certain services for us (e.g. supplying a tool for the organization of an event) - on the basis of appropriate authorizations or processing agreements;
2. partners and co-organizers of the event on the basis and within the scope of the previously accepted event terms & conditions.
3. to authorities entitled to request access to the data if, on the basis of a ruling or a decision of the entitled body or provisions of generally applicable law, we will be obliged to disclose them.

The period of time we will process your data (data retention period):

1. we will process data collected based on your consent until you withdraw it, which you can do at any time (for more information, see "Know your rights").
2. data processed on the basis of contract will be processed until the end of the contract in accordance with the accepted terms & conditions.
3. we will process your data based on our legitimate interest until the purpose of that interest is fulfilled or until you object to that processing (for more information, see " Know your rights").

 

About GoToWebinar & MS Teams 

Webinars and other online events can be made available on:

• GoToWebinar platform, operated by LogMeIn, 320 Summer Street, Boston, MA 02210, USA. If you wish to access the seminars, you must first register directly on the GoToWebinar platform using the form.
• MS Teams platform, operated by Microsoft Inc., One Microsoft Way, Redmont, Washington 98052-6399.

For more details see „Use of cookie files“ on this page.

Any personal information provided via the registration form will be stored in the United States by LogMeIn Inc or Microsoft Inc., and GFT’s Pardot marketing automation software.

Both GoToWebinar and MS Teams installs various cookies. The associated privacy policies are available at:

• GoToWebinar - https://secure.logmein.com/home/en/policies/privacy.
• MS Teams - https://docs.microsoft.com/en-us/MicrosoftTeams/teams-privacy.

If you are our client or a representative of our client then the processing of your personal data will be carried out for purposes related to the conclusion, performance, and handling of the concluded contract.

1. The legal basis for the processing of your personal data are:

• if you are a Party of the contract:

- Article 6(1)(b) of the GDPR, i.e.: necessary for the performance of a contract of which you are a party, or to take action at your request before entering into a contract;

- Article 6(1)(c) of the GDPR, i.e.: a legal obligation on the Controller related to the maintenance of accounting and tax records, resulting from generally applicable laws;

- Article 6(1)(f) of the GDPR, i.e.: realization of the Controller's legitimate interests, consisting of, among other things, ensuring the continuous and uninterrupted operation and coordination of cooperation in the performance of the contract, internal administrative purposes (including management of services) and the assertion or defence against claims;

• if you are a natural person acting on behalf of a legal entity which is our client (including taking pre-contractual actions), as well as if you are an employee or associate of such legal person and participate in the conclusion or execution of the contract:

• Article 6(1)(f) of the GDPR, i.e.: the Controller's legitimate interest in enabling the proper and effective performance of the contract and activities related to establishing the terms of the contract.

2. Recipients of personal data:

Your personal data may be transferred to entities that support us in fulfilling our obligations and providing services, including entities that provide the following services: accounting, human resources, legal, archiving and destruction of documents, postal services, courier services, payment services, marketing services and also to providers of IT systems in which your data are processed.

3. Period of time for which we will keep your personal data is following:

We will process your personal data until the purpose for which the data was obtained has been fulfilled or until the expiration of the period of time indicated by law.

4. data obtained other than from the data subject:

If your personal data was not obtained directly from you but was provided by a legal entity of which you are an employee or collaborator - in accordance with Article 14(1)(d) and (2)(f) of the GDPR, we inform you that :

- Depending on the circumstances of the cooperation, we will process, among others, the following categories of your personal data: basic identification data (e.g. first and last name), contact data (e.g. telephone number, e-mail address), address data (address of the place of employment), other data related to employment (e.g. official position).

- The categories of data will be collected respecting the principle of adequacy, bearing in mind the purpose and nature of the cooperation, and will result primarily from applicable laws.

We reserve the right to amend this Privacy Notice by posting the new content on our website. Once changed, the Privacy Notice will appear on the website in a new version with a new date. 

In the event of a change to the Privacy Notice that requires users to be informed about under local data protection law, we will inform you directly of such change by means of postal or electronic correspondence or by displaying a notice at the entrance to the website or by any other means providing the easiest access to this information.

If the change requires us to collect the relevant consents from you again to process your personal data then we will ask you again to give such consent.

Current Privacy Notice: : version 4.0 published on 07.06.2024