I.Purpose of the Policy
The purpose of this Policy is to:
- Present the principles of personal data processing by the Data Controller within the B2B Portal, and through its publication to fulfill the information obligations resulting from Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016, the so-called GDPR («GDPR»);
- Explain your rights in connection with the processing of personal data and provide information on the security measures applied;
- Provide information on cookies and similar technologies used on the Website, including the rules for their acceptance and settings management.
II.General Information
Data Controller. The Data Controller of your personal data in connection with the use of the Website is ATC Group sp. z o.o. with its registered office in Warsaw, at the address: Aleje Jerozolimskie nr 109 lok. 70, 02-011 Warsaw, entered into the Register of Entrepreneurs of the National Court Register maintained by the District Court for the Capital City of Warsaw in Warsaw, XII Commercial Division of the National Court Register under KRS number: 0001021069, NIP: 8982289583, REGON: 524551510 (hereinafter: «Administrator» or «Controller»).
Contact. In case of any questions regarding the Policy, the rules of data processing, or in order to exercise your rights, you can contact the Controller by mail, directing correspondence to the address indicated above, or by email, directing correspondence to the address: contact@atcgroup.pl.
The Controller declares that it exercises special diligence to protect the interests of data subjects, and in particular ensures that it:
- Processes personal data lawfully, fairly and in a transparent manner in relation to the data subject;
- Collects personal data for specified, explicit and legitimate purposes and does not further process them in a manner incompatible with those purposes;
- Ensures personal data are adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed;
- Ensures personal data are accurate and, where necessary, kept up to date;
- Keeps personal data in a form which permits identification of data subjects for no longer than is necessary for the purposes for which the personal data are processed;
- Processes personal data in a manner that ensures appropriate security, including protection against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
III.Purposes and Legal Bases of Personal Data Processing
Your personal data may be processed for various purposes and based on various legal bases depending on which functionalities of the Portal you use, in particular to process wholesale inquiries (RFQs), conclude and perform B2B export contracts, conduct marketing, analytical or statistical activities, improve the quality of services, and fulfill relevant legal obligations incumbent on the Controller.
Use of the Website / Electronic Services
- Provision of services by electronic means, including ensuring the possibility to use the B2B Portal and its available inquiry forms (Electronic Services). The legal basis is Art. 6(1)(b) of the GDPR.
- Performance of legal obligations imposed on the Controller by law, e.g., tax and accounting regulations. The legal basis is Art. 6(1)(c) of the GDPR.
- Establishment, defense, or pursuit of potential claims. The legal basis is Art. 6(1)(f) of the GDPR.
Processing Inquiries & Performance of B2B Export Contracts
- Execution of trade inquiries, quotations, and B2B Contracts. The legal basis is Art. 6(1)(b) of the GDPR.
- Compliance with legal obligations (customs, tax, accounting). The legal basis is Art. 6(1)(c) of the GDPR.
- Defense or pursuit of trade claims. The legal basis is Art. 6(1)(f) of the GDPR.
B2B Marketing & Communication
- Sending commercial information and commodity offers (upon consent), e.g., product market availability and price lists. The legal basis is Art. 6(1)(a) of the GDPR.
- Direct marketing and personalization of offer presentations to corporate clients. The legal basis is Art. 6(1)(f) of the GDPR.
Business Contact
- Managing B2B trade communications, responding to submitted price inquiries, and establishing commercial partnerships. The legal basis is Art. 6(1)(f) of the GDPR or Art. 6(1)(b) of the GDPR.
Analytics & Platform Development
- Analyzing website usage to optimize B2B user experience and performance. The legal basis is Art. 6(1)(f) of the GDPR.
IV.Source of Data Obtainment
The Controller obtains personal data:
- Directly from you via forms on atcgroup.pl, trade inquiry forms, or e-mail correspondence;
- From corporate entities, clients, or B2B partners whom you represent;
- From publicly available business registers and commercial databases.
V.Data Retention Period
Data are processed for the duration necessary to execute trade agreements, manage commercial inquiries, or fulfill statutory accounting and tax retention periods.
Consent-based data processing continues until consent is withdrawn.
VI.Data Recipients
Data may be shared with hosting providers, IT infrastructure service providers (e.g. transaction notification services), logistics and freight forwarding partners, payment processing entities, as well as legal and tax advisors supporting ATC Group’s international export operations.
VII.Data Transfers Outside the EEA
In the context of international trade with buyers in Africa, Asia, and non-EEA regions, data transfers occur strictly in compliance with Chapter V of the GDPR, utilizing European Commission standard contractual clauses or adequacy decisions where required.
VIII.Automated Decision-Making & Profiling
Profiling may be used solely for personalizing trade offers and Website usability. No legally binding decisions are made based purely on automated processing.
IX.Rights of Data Subjects
Under the GDPR, you have the right to access, rectify, erase, restrict, object to processing, request data portability, and lodge a complaint with the President of the Personal Data Protection Office (UODO in Poland).
Questions about this Policy or your data? Write to contact@atcgroup.pl.