Information on the processing of personal data of customers and suppliers pursuant to the Regulation (EU) 2016/679 (GDPR)

The company Flash-Butrym has adapted its Policy on the Processing of Personal Data of customers and suppliers, the points of which are described in this document in accordance with Regulation (EU) 2016/679.

1. Holder of the Processing of Personal Data

Holder of the processing is the company:

Flash-Butrym Sp.J.

Skarbimierzyce 18; 72002 Dołuje, Poland

Tel.: 00 48 668 155 555

email: sales@flash-butrym.pl

2. Definition of Simple or Particular Personal Data

Simple Personal Data means any personally identifiable or id entifiable information (known as "interested") that can be identified directly or indirectly through a name, an identification number, location data, an online identifier or one or more characteristic elements of its physical, physiological, genetic, psychic,  economic, cultural or social identity.

Particular Personal Data refers to data that reveal racial or ethnic origin, political opinions, religious or philosophical convictions, union membership, as well as genetic, biometric data intended to uniquely id entify a physical person, the relative ones to the health or sexual life or sexual orientation of the person.

3. Purposes of Data Processing, Methods and Legal Basis

The processing of Personal Data is carried out by the Data Management Manager for the purposes indicated below and takes place using manual and IT tools in compliance with the law and for the purposes indicated above, ensuring the security and adequacy of the Personal Data processed.

The processing of data is aimed at:

• to the correct and complete execution of the supply / sale contract. In particular, the processing of data consists in the collection, that is to say in the acquisition of data, recording, that is to say in the memorization of data, in organization, paper and data storage, consultation, ie reading of data, communication by transmission to the subjects better indicated in the following point, and use for instrumental purposes both for the execution of the contract and for the fulfillment of legal and regulatory obligations in general, including fiscal and accounting matters

The source of data processing is identified:

• in the laws and / or regulations that require the processing of personal data
• in the execution of the contract
• in the legitimate interest of Flash-Butrym to guarantee the

IT security of its system and the defense of its own interests in court.

Data processing is necessary:

• for the execution of the contract: in case of refusal by the interested party to provide Personal Data, the contract in which the data are processed can not be executed
• for the transmission of advertising material related to Flash-Butrym for promotional and commercial purposes upon the consent of the interested party.

4. Recipients of Personal Data

Recipients of Personal Data, that is to say the subjects to whom personal data may be communicated, are, in addition to the Head of Data Management:

•  all the employees and / or collaborators of Flash-Butrym
• members of the board of directors
• the data processors, identified in the IT service management company and in the tax / tax consultancy company
• auditors or other managers who may be appointed in writing and to whom specific written instructions will be given
• the Authorities  to  which  Flash-Butrym  is  obliged  to  send  personal  data  for  the  fulfillment  of  legal  or regulatory  obligations  in  general  (see  tax  /  tax  advisory  study),  or  the  judicial  authority  for  the protection of its own reasons, as well as to other subjects for the pursuit of the purposes indicated in the preceding par. 3

5. Possibility of Data Transfer to an Extra EU Country

Personal Data may be transferred to third countries outside the EU for:

• reasons connected with the performance of the contract that take place
• fulfillment of legal obligations

The transfer will however take place in compliance with the c

onditions established by the GDPR and, if necessary, subject to authorization by the interested party.

6. Data Retention

Personal  Data  is  kept  for  the  time  necessary  to  achieve  the  purposes  indicated  in  consideration  of  the purpose of the processing.

The  data are  considered  canceled  or  rendered  anonymous  after  the  deadline  and  following  the  legal requirements,  unless  their  further  conservation  is  necessary  to  fulfill  legal  obligations  or  to  comply  with public authority orders or to protect a legitimate interest of Flash-Butrym.

7. Rights of the Interested Party

The Interested Party has the right to:

• ask the Data Management Manager:
• access to Personal Data
• their rectification and / or integration if incomplete
• their cancellation

Any corrections or cancellations made at the request of the Interested Party will be communicated by the Data Management Manager to each of the Recipients.

•  ask the Data Management Manager to limit the processing that concerns him in cases where:
• the Interested  Party  contests  the  accuracy  of personal  data  during  the  period  necessary  for  the Data Management Manager to verify the accuracy
• the processing is unlawful and the Interested Party opposes the cancellation of the Personal Data and asks instead that its use is limited
• Personal Data  are  necessary  for  the  Interested  Party  to  ascertain,  exercise  or  defend  a  right  in court
• the Interested  Party  has  opposed  the  processing  in  the  waiting  period  of  the  verification  on  the possible prevalence of legitimate reasons of the Holder of Data Processing with respect to those of the interested party
• to request a copy of the Personal Data being processed
• to make Personal Data transferable through a structured file format commonly used and readable by common electronic devices
• to revoke the consent at any time, without prejudice to the lawfulness of the treatment up to that point in place. The  withdrawal  of  consent  can  not  cover  cases  in  which  the  processing  is  necessary  to comply with the law requirements to which Flash-Butrym is
• to propose a complaint to the Supervisory Authority, in the person of the Privacy Guarantor, when he considers that his rights have not been respected
• to know the purposes other than those indicated in art.2 above to be able to demonstrate, with respect to them, their consent

The Interested Party can send a written request to:

email: GDPR(at)flash-butrym.pl

8. Right of Opposition

Flash-Butrym declares:

• not to  use  automated  decision-making  processes,  including profiling,  to  evaluate  certain  personal aspects related to a natural person
• to undertake  not  to  use  data  of  Interested  parties  for  direct  marketing  urposes,  that  is  to  say  in activities and / or services to offer products and services and / or to transmit advertising messages to customers, when this has not been explicitly uthorized.

Flash-Butrym Sp.J.