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 activities, may process your personal data. In this GTV Privacy Policy (hereinafter referred to as the “Policy“), we present general information regarding the principles of processing your personal data and the rights you are entitled to in connection with this processing.

We emphasize that we take the protection of your personal data very seriously and take due care to process this data securely. In order to protect your personal data while simultaneously increasing the value of the services we provide and offering more possibilities, we comply with the law, particularly Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons concerning the processing of personal data and the free movement of such data, and repealing Directive 95/46/EC (General Data Protection Regulation) (OJ L 119, p. 1) (hereinafter referred to as “GDPR“).

Wherever we use the term GTV Group in this document (also in the version of the defined terms above), it means that the given information may be universal for any entity within the GTV Group listed in this document, and thus may process your personal data as an administrator, for the purposes and in the manner described in this Policy. The entities mentioned in the preceding sentence are listed in the section Entities Responsible for Applying the Policy. If a specific issue mentioned in the Policy pertains solely to a particular entity, you will be informed accordingly.

We also indicate that the manner of processing your personal data may vary depending on the relationship you have with the given entity, the country in which the entity operates, and the specificity of the industry in which the entity operates, which may own different brands with their websites. In cases where a website owned by a GTV Group company has its dedicated privacy policy, this document does not apply.

In situations where 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 an administrator through appropriate supplementary documentation.

ENTITIES RESPONSIBLE FOR APPLYING THE POLICY

This Policy has general applicability for 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 indicated above, various data controllers may be responsible for processing your personal data, depending on the relationship you have with a particular controller or the country where your personal data is collected.

The controller of your personal data may be:

GTV Poland will generally be the leading company regarding the processing of your personal data; therefore, most information regarding the processing of personal data indicated in the Policy may concern GTV Poland, which we will inform you about accordingly.

We also indicate that GTV Poland is responsible for the operation and maintenance of the following websites: www.test.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:

or

or

or

or

You can contact the selected administrator in the following ways:

• by sending a message to the appropriate email address provided above;
• by sending a message through our contact form;
• by mail to the address of the respective company headquarters provided above.

CONTACT WITH DATA PROTECTION OFFICERS

We inform you that some of the above-mentioned administrators have appointed Data Protection Officers, who you can contact via:

GTV Poland – you can contact the Data Protection Officer by sending a message to the email address: dpo@test.gtv.com.pl or by mail to the address of GTV Poland headquarters;

GTV Croatia – you can contact the Data Protection Officer by sending a message to the email address: dpo.croatia@test.gtv.com.pl or by mail to the address of GTV Croatia headquarters;

GTV España – you can contact the Data Protection Officer by sending a message to the email address: lopd@gtv.es or by mail to the address of GTV España headquarters.

WHAT DATA DO WE COLLECT?

We most often 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, for example, when you sign a contract with us on behalf of your employer or contact us as the contact person of your employer. In such cases, we may obtain your identification and contact details, such as your name and email address.

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

Your personal data may also be collected through forms available on GTV websites, for example: by subscribing to a newsletter, where you may provide your contact details (email address), by filling out registration forms, access to catalogs, or contact forms, where you may provide, among other things, your name, surname, and contact details (e.g., email address).

In addition to 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, for example, a sales contract through our online stores.

PURPOSES AND LEGAL BASES FOR DATA PROCESSING

Below we present the purposes and legal bases for which your personal data is most often processed. It may happen that your personal data will also be processed for purposes other than those described below. In such cases, you will be informed in another way, e.g., if you wish to participate in recruitment conducted by one of the companies in the GTV Group, we will provide you with information about the processing of your personal data for recruitment purposes.

Please contact us through the contact channels indicated above if you do not see a purpose for processing that fits the relationship we have with you.

RECRUITMENT

Each administrator has separately regulated issues related to recruitment (including due to internal regulations in force in the given country). Information on the processing of candidates’ personal data is provided in the appropriate places when applying for a specific position.

SOCIAL MEDIA

We manage profiles on social media platforms where we may process your personal data. In some activities, for example, for statistical purposes together with the social media platform operator, we may act as joint controllers. Information about how your personal data is processed on each platform can be found below:

• Facebook and Instagram:

https://www.facebook.com/privacy/policy/?entry_point=data_policy_redirect&entry=0

• LinkedIN:

https://pl.linkedin.com/legal/privacy-policy

• Tik Tok:

https://www.tiktok.com/legal/page/eea/privacy-policy/pl

• YouTube:

https://policies.google.com/privacy?hl=pl

DATA PROCESSING PERIOD

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

1. In cases where the legal basis for processing your personal data is consent, we will process your personal data until you withdraw your consent;
   
2. If we are bound by a contract with you, we will process your personal data for the duration of the contract and then for the period required by regulations regarding the limitation of claims;
   
3. When the legal basis for processing your personal data is a legal obligation, we will process your personal data for the time required by law;
   
4. 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, and earlier if you object to the processing of your personal data.
   

RECIPIENTS OF PERSONAL DATA

The recipients of your personal data may be:

1. Service providers offering services to GTV, such as IT, hosting, marketing, transport, courier services, document destruction services, and social media operators, as well as debt collection services;
   
2. Professional advisors, such as legal and tax advisors, auditing service providers, and accounting service providers;
   
3. Entities within the GTV Group;
   
4. State authorities, in cases provided for by law.
   

NECESSITY OF PROVIDING PERSONAL DATA

Providing your personal data is voluntary, but it may be necessary to enter into a contract with us, provide you with services, handle your case, participate in a contest, or make a purchase in our stores. Where data provision is required in the form, we indicate this appropriately.

TRANSFER OF DATA OUTSIDE THE EUROPEAN ECONOMIC AREA (EEA)

Considering the nature and scope of services offered by entities within the GTV Group, your personal data may, in justified cases, be transferred to entities based 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 data to a country outside the EEA implements appropriate safeguards to ensure an adequate level of protection of your personal data, including the use of standard contractual clauses approved by the European Commission. These measures serve to exercise your personal data rights and ensure effective legal protection. The administrator responsible for processing your personal data will provide a copy of these safeguards upon your request.

YOUR RIGHTS

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

• Access to the data we hold about you, including obtaining a copy of it;
  
• Rectification or supplementation of data, including correction and updating;
• Deletion of personal data (“right to be forgotten”), considering circumstances that allow or exclude the possibility of deleting your personal data;
• Restriction of processing of your data, considering circumstances that allow such restriction;
  
• Objection to the processing of personal data when we process your data based on our legitimate interest, and the objection is justified by your particular situation. Additionally, you have the right to object to the processing of personal data for direct marketing purposes;
  
• Data portability in cases where we process your personal data based on consent or contract. This means you have the right to receive the data provided to us in a structured, commonly used, and machine-readable format to be transmitted directly to another entity, where technically feasible;
• Withdrawal of consent to the processing of personal data at any time, which does not affect the lawfulness of processing based on consent before its withdrawal.
  

You can exercise the above rights through the appropriate contact indicated in the information about the personal data controllers and their contact details, as mentioned above in the section on information about personal 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 based.

CHANGES

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

Last updated: July 19, 2024.