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Privacy Policy

GTV Privacy Policy

GENERAL INFORMATION

The GTV Group (hereinafter also referred to as “GTV” or “we/us”) provides its services in many countries through entities that, in connection with their business activities, may process your personal data. In this GTV Privacy Policy (hereinafter referred to as the “Policy”), we present general information about the principles of processing your personal data by us and the rights you have in connection with this processing.

We emphasize that we take the protection of your personal data seriously and make every effort to process these data securely. To protect your personal data while increasing the value of our services and offering more options, we comply with the law, especially Regulation (EU) 2016/679 of the European Parliament and Council of April 27, 2016, on the protection of individuals with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ EU L 119 p. 1) (hereinafter referred to as the “GDPR”).

Whenever this document uses the term GTV Group (including the defined terms above), it means that the information may be universal for any entity within the GTV Group mentioned in this document and, as such, may process your personal data as a controller for the purposes and in the manner described in this Policy. The entities mentioned in the previous sentence are listed in the section “Entities responsible for applying the Policy.” If a specific issue indicated in the Policy relates exclusively to a given entity, you will be informed accordingly.

At the same time, we point out that the manner of processing your personal data may differ depending on your relationship with the entity, the country where the entity operates, and the specifics of the industry in which the entity operates, which may also own various brands with their own websites. In cases where a website owned by a GTV Group company has its dedicated privacy policy, this document does not apply.

If your personal data will be processed for purposes other than those indicated in this document, you will be informed accordingly by the entity processing your personal data as a controller through appropriate supplementary documentation.

ENTITIES RESPONSIBLE FOR APPLYING THE POLICY

This Policy applies generally to the processing of data by the following entities:

  • GTV Poland S.A. based in Poland
  • GTV Asset Management sp. z o.o. based in Poland
  • GTV Croatia d.o.o. based in Croatia
  • GTV España Herrajes e Iluminación S.L. based in Spain
  • GTV Czech Distribution s.r.o. based in the Czech Republic
  • GTV Stolmet sp. z o.o. based in Poland.

INFORMATION ABOUT DATA CONTROLLERS AND THEIR CONTACT DETAILS

As mentioned above, different data controllers may be responsible for processing your personal data, depending on which controller you are in a relationship with or which operates in the country where your personal data are collected.

Your data controller may be:

  • GTV Poland S.A. based in Poland, Pruszków (05-800) ul. Przejazdowa 21 (hereinafter referred to as “GTV Poland”)

GTV Poland will, as a rule, be the leading Company when it comes to processing your personal data. Therefore, most of the information regarding the processing of personal data indicated in the Policy may pertain to GTV Poland, about which we will inform you accordingly.

At the same time, we indicate that GTV Poland is responsible for the operation and maintenance of the websites: www.gtv.com.pl, www.hoegert.com, www.hoegertworkwear.com, www.gtvdecor.com, and www.enzeit.com.

 

The controller of your personal data may also be:

  • GTV Asset Management sp. z o.o. based in Poland, Pruszków (05-800) ul. Przejazdowa 21
    • Email: info@gtv.com.pl
  • GTV Croatia d.o.o. based in Croatia, Zagreb (10110) ul. Roberta Frangeša Mihanovica 9
    • Email: croatia@gtv.com.pl
  • GTV España Herrajes e Iluminación S.L. based in Spain, Valencia (46021) ul. Avenida Aragón 30 Planta 8
    • Email: gtv@gtv.es
  • GTV Czech Distribution s.r.o. based in the Czech Republic, Ostrava (720 00) ul. Na Rovince 879
    • Email: info.ostrava@gtv.com.pl
  • GTV Stolmet sp. z o.o. based in Poland, Szczytno (12-100) ul. Wincentego Pola 6
    • Email: stolmet@gtv.com.pl

You can contact the selected controller by:

  • Sending a message to the appropriate email address provided above;
  • Sending a message through our contact form;
  • Sending a letter to the company’s address provided above.

CONTACT WITH DATA PROTECTION OFFICERS

Please be informed that some of the controllers mentioned above have appointed Data Protection Officers with whom you can contact via:

  • GTV Poland – contact the Data Protection Officer by emailing: dpo@gtv.com.pl or sending a letter to the address of GTV Poland;
  • GTV Croatia – contact the Data Protection Officer by emailing: dpo.croatia@gtv.com.pl or sending a letter to the address of GTV Croatia;
  • GTV España – contact the Data Protection Officer by emailing: lopd@gtv.es or sending a letter to the address of GTV España.

WHAT DATA WE COLLECT

We usually receive your personal data directly from you. It may also happen that we receive your personal data from your employer or the entity you represent, e.g., when you sign a contract with us on behalf of your employer or contact us as your employer’s contact person. In such a case, we may obtain your identification and contact details, such as your name and email address.

The manner of collecting your personal data also depends on the circumstances under which we obtained your personal data. When you visit our websites, GTV Poland may collect certain personal data about you via cookies or other similar technologies (e.g., IP address). More information about cookies can be found in our Cookie Policy.

Your personal data may also be collected through forms available on the GTV websites, such as signing up for a newsletter, where you may provide your contact details (email address), filling out registration forms for access to catalogs or contact forms where you may provide your name and contact details (e.g., email address).

Apart from the above examples of obtaining your personal data, we indicate that they may also be collected when you use our services or enter into a contract with us, e.g., a sales contract through our online stores.

PURPOSES AND LEGAL BASES FOR DATA PROCESSING

Below we present the purposes and legal bases for processing your personal data most frequently. It may happen that your personal data will be processed for purposes other than those described below. In such a case, you will be informed in another way, e.g., when you want to participate in recruitment conducted by one of the GTV Group companies, we will present you with information about processing your personal data for recruitment purposes.

Please contact us through the above-mentioned contact channels if you do not see a processing purpose that matches the relationship we have with you.

Purpose of data processing:

  • Operation of our websites (e.g., www.hoegert.com), including enabling user registration and providing services within these websites by GTV Poland
    • Legal basis: Performance of a contract for the provision of electronic services in accordance with the terms specified on the website (Art. 6(1)(b) GDPR)
  • Access to the B2B platform (account creation)
    • Legal basis: Performance of a contract for the provision of electronic services in accordance with the terms specified on the website (Art. 6(1)(b) GDPR)
  • Handling your submitted issue (e.g., through a contact form or email)
    • Legal basis: Handling and responding to your inquiries, which constitutes our legitimate interest (Art. 6(1)(f) GDPR) or compliance with a legal obligation (Art. 6(1)(c) GDPR) if your message entails the fulfillment of such an obligation, e.g., you submit a request to exercise rights under GDPR
  • Entering into or seeking to enter into a contract at your request. Performance of a contract with the party (contractor, partner, or client)
    • Legal basis: Seeking to enter into a contract at your request or entering into and performing a contract (Art. 6(1)(b) GDPR)
  • Entering into or seeking to enter into a contract at your request on behalf of our client, partner, or contractor. Performance of a contract with the contact person
    • Legal basis: Seeking to enter into a contract at your request, proper entry into and performance of a contract with our client, partner, or contractor, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
  • Providing services or selling products, including order fulfillment through the online store owned by GTV Poland (e.g., purchasing products through the www.hoegert.com store)
    • Legal basis: Performance of a contract (Art. 6(1)(b) GDPR)
  • Handling complaints (e.g., for products purchased in our online store)
    • Legal basis: Compliance with a legal obligation (Art. 6(1)(c) GDPR) if the complaint results in the fulfillment of such an obligation, Performance of a contract (Art. 6(1)(b) GDPR) if the complaint results in the fulfillment of such an obligation, e.g., under a warranty agreement
  • Compliance with legal obligations
    • Legal basis: Legal provisions, including tax and accounting regulations (Art. 6(1)(c) GDPR)
  • Conducting correspondence
    • Legal basis: Possibility of conducting correspondence and ensuring the circulation and archiving of documents (Art. 6(1)(f) GDPR)
  • Conducting marketing by GTV Poland
    • Legal basis: Possibility of promoting our products and services, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
  • Sending marketing content by GTV Poland (newsletter, satisfaction surveys) regarding our products and services through your chosen communication channel (e.g., email)
    • Legal basis: Possibility of exercising the right to send marketing content resulting from your consent to receive such content through the chosen communication channel (e.g., GTV newsletter), which constitutes our legitimate interest (Art. 6(1)(f) GDPR) or your consent to the processing of personal data for direct marketing purposes (Art. 6(1)(a) GDPR) in connection with your consent to receive marketing content through the chosen communication channel
  • Displaying ads on behalf of GTV Poland on websites tailored to your interests (e.g., in collaboration with Google)
    • Legal basis: Possibility of presenting offers and advertisements on websites, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
  • Analyzing and statistics of websites managed by GTV Poland
    • Legal basis: Improving the quality and verifying the effectiveness of our marketing content, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
  • Conducting social media
    • Legal basis: Promoting GTV products and services, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)
  • Conducting contests
    • Legal basis: Performance of a contract in accordance with the rules (Art. 6(1)(b) GDPR) or organizing the contest, including selecting winners, notifying participants of winnings, awarding prizes, and handling any complaints. Our legitimate interest is to properly organize the contest as part of GTV’s promotion (Art. 6(1)(f) GDPR)
  • Establishing, pursuing, and defending claims
    • Legal basis: Establishing, pursuing, and defending claims, which constitutes our legitimate interest (Art. 6(1)(f) GDPR)

RECRUITMENT

Each controller has regulated recruitment matters separately (e.g., due to internal regulations in the respective country). Information on the processing of personal data of candidates is provided in the appropriate places when applying for a position.

SOCIAL MEDIA

We operate profiles on social media where we may process your personal data. In some activities, such as for statistical purposes, we may act as co-controllers with the social media platform operator. Information on how your personal data is processed on a given platform can be found below:

DATA RETENTION PERIOD

The retention period for your personal data depends on the legal basis for processing. Generally, we will process your personal data as follows:

  • If the legal basis for processing your personal data is consent, we will process your personal data until you withdraw your consent;
  • If we have a contract with you, we will process your personal data for the duration of the contract and then for the period specified by the statutes of limitations;
  • If the legal basis for processing your personal data is a legal obligation, we will process your personal data for the time required by law;
  • If the legal basis for processing your personal data is our legitimate interest, we will process your personal data for the time necessary to achieve our legitimate interest or until you object to the processing of your personal data.

RECIPIENTS OF PERSONAL DATA

Recipients of your personal data may include:

  • Service providers for GTV, such as IT, hosting, marketing, transport, courier services, document destruction services, social media platform operators, and debt collection service providers;
  • Professional advisors such as legal and tax advisors, auditing service providers, accounting service providers;
  • Entities within the GTV Group;
  • Government authorities in cases provided for by law.

NECESSITY OF PROVIDING PERSONAL DATA

Providing your personal data is voluntary but may be necessary to conclude a contract with us, provide you with services, resolve your issue, participate in a contest, or make a purchase in our stores. Where data provision in a form is required, we indicate it accordingly.

TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

Given the nature and scope of services offered by GTV Group entities, your personal data may, in justified cases, be transferred to entities outside the European Economic Area (EEA). In cases where these countries have not been recognized by the European Commission as providing an adequate level of personal data protection, the entity responsible for transferring the data outside the EEA implements appropriate safeguards to ensure an adequate level of protection for your personal data, particularly by using standard contractual clauses approved by the European Commission. These measures are designed to enforce your data protection rights and ensure effective legal protection. The controller responsible for processing your personal data will provide you with a copy of these safeguards upon request.

YOUR RIGHTS

We commit to respecting the confidentiality of your personal data and ensuring you can exercise your rights. Regardless of the purpose or legal basis for which we process your personal data, you have the following rights:

  • Access to the data we hold about you, including obtaining a copy;
  • Rectification or completion of data, including correcting and updating it;
  • Deletion of personal data (“right to be forgotten”), considering circumstances that allow or exclude the deletion of your personal data;
  • Restriction of processing your data, considering circumstances that allow for such a possibility;
  • Objection to the processing of personal data when we process your personal data based on our legitimate interest, and the objection is justified by your particular situation. You also have the right to object to the processing of personal data for direct marketing purposes;
  • Data portability, if we process your personal data based on consent or a contract. This means you have the right to receive the data you provided us in a structured, commonly used, machine-readable format, and to have it transferred directly to another entity where technically possible;
  • Withdrawal of consent for personal data processing at any time, without affecting the lawfulness of processing based on consent before its withdrawal.

You can exercise the above rights via the appropriate contact specified in the information about data controllers and their contact details mentioned above in the section “Information about data controllers and their contact details.”

You also have the right to lodge a complaint with the supervisory authority for personal data protection in your country of residence, which is a member state of the European Union where we are established.

CHANGES

We reserve the right to periodically review and modify this Policy in connection with possible changes in processing your personal data or legal regulations. The date of the last modification is at the end of this document. If we make changes to this Policy and the way we use your personal data, we will provide the updated version of this document.

Last update of the Privacy Policy: July 19, 2024.