KGHM ZANAM S.A. PRIVACY POLICY

Personal Data Processing Policy

On 25 May 2018, Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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 entered into force (General Data Protection Regulation, hereinafter referred to as “the GDPR”). The Regulation imposes a number of new obligations on all entities which collect, process and use personal data.

In KGHM ZANAM S.A. we treat care for personal data as the highest priority. Below is the Personal Data Processing Policy, in which we provide you with information regarding the purpose for which we collect personal data, what obligations are imposed on the Controller and what are your rights in connection with the processing of personal data.

  1. DEFINITIONS

    Controller:
    KGHM ZANAM S.A. (the Company)

    Personal Data: wall information about an identified or identifiable individual through one or more factors specific to that person's physical, physiological, genetic, mental, economic, cultural or social identity, including the IP address of the device, location data, Internet identifier and information collected through cookies and other similar technological means.

    Policy: this Personal Data Protection Policy.

    GDPR: Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 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.

  2. PROCESSING OF DATA BY THE CONTROLLER

    The Controller collects and processes Personal Data in accordance with relevant legal provisions, including in particular the requirements of the GDPR and the principles of data processing provided for therein.

    The Controller shall ensure transparency in the processing of Personal Data, in particular it shall always inform about the processing of data at the time of collection, including the purpose and legal basis of the processing (e.g. when concluding a contract for the sale of goods or services). The Controller shall ensure that the data is collected only to the extent necessary to achieve the indicated purpose and processed only for the period in which it is necessary.

    When processing Personal Data, the Controller shall ensure its security and confidentiality and access to information on the processing for the Data Subjects. Should a personal data protection breach (e.g. data leakage or loss) occur despite the security measures applied, the Controller shall inform the Data Subjects about such an event in a manner consistent with the applicable provisions.

  3. THE PURPOSES, GROUNDS AND PRINCIPLES OF THE PROCESSING OF PERSONAL DATA
  1. PERSONAL DATA OBTAINED FROM VIDEO SURVEILLANCE

    Below we present information on the principles of functioning of the monitoring system at KGHM ZANAM S.A.

    In connection with the functioning of the monitoring system within the premises of KGHM ZANAM S.A., we wish to inform you that:
    • The Personal Data, Image, Controller is KGHM ZANAM S.A. with its registered office in Polkowice at ul. Kopalniana 7.
    • The Controller has appointed a Data Protection Officer, with whom you can contact by e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. or by post with a note: “to the Data Protection Officer”.
    • Monitoring is used to protect property, ensure security in the monitored area of the Company, control production and ensure secrecy of information, the disclosure of which could expose the Company to harm, which is the basis for processing data, which̨ is a legitimate interest of the Controller - Article 6(1)(f) of the GDPR.
    • Monitoring covers persons staying within the Company's premises or in its immediate vicinity. Monitoring cameras automatically record images without voice, and indicate the time and place of the recording.
    • Monitoring shall not include sanitary facilities, changing rooms, canteens, smoking rooms and rooms made available to trade unions' organisations.
    • There are plates with the camera pictogram on the buildings being monitored, at the entrance to the building or near the area covered by the system.
    • The monitoring system operates 24 hours a day.
    • Monitoring recordings will be stored until overwritten, for a maximum of 30 days or until the legally valid conclusion of legal proceedings - this applies to cases in which image recordings constitutę evidence in proceedings conducted pursuant to the provisions of law or when the Controller has obtained information that the monitoring recordings may be used as evidence in the proceedings.
    • The recipients of Personal Data will be companies providing services of property protection and maintenance of monitoring devices and, in justified cases, law enforcement and administrative bodies in accordance with applicable laws.
    • The following shall have access to images and monitoring recordings: The system administrator, authorised employees of the Controller and persons providing property protection and maintenance services for monitoring devices. These persons are obliged tǫ maintain confidentiality and to comply with the law on the protection of Personal Data and confidentiality of information.
    • The data from the monitoring recordings may be made available only in a justified case, to authorised bodies within the scope of conducted proceedings, after a written request has been submitted to the Controller. In this case, the data shall bę recorded on removable media (USB stick, DVD-ROM) and handed over to authorised bodies only upon signing for data receipt.
    • The recordings and data processed in the monitoring system shall be subject to appropriate security measures to ensure the processing of such data, in particular to prevent their loss or unlawful dissemination, as well as to prevent access to data by unauthorised persons.
    • A person recorded by the monitoring system has the right:
      • to access Personal Data,
      • to request their rectification,
      • to remove Personal Data,
      • to demand that the processing of your data be restricted,
      • to object to the processing of Personal Data.
    • The Data Protection Officer of KGHM ZANAM S.A. may be contacted in order to exercise the rights.
    • A person recorded by the monitoring system has the right to lodge a complaint with the supervisory authority - the President of the Data Protection Office - in the event of a breach of data protection.

  2. PROCESSING OF DATA OF PERSONS STAYING WITHIN THE COMPANY'S PREMISES / ENTERING THE COMPANY'S PREMISES IN POLKOWICE AND LEGNICA

    In connection with entering the premises of KGHM ZANAM S.A. we wish to inform you that:
    • The Personal Data Controller is KGHM ZANAM S.A. with its registered office in Polkowice at ul. Kopalniana 7.
    • The Controller has appointed a Data Protection Officer, with whom you can contact by e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. or by post with a note: “to the Data Protection Officer”.
    • Personal Data (first name and surname, identity card number and issuing authority) is processed in order to protect property and ensure security within the premises of the Company; which is the basis for the data processing, which is the legitimate interest of the Controller - Article 6(1)(f) of the GDPR.
    • Providing Personal Data is a condition for entering the premises of KGHM ZANAM S.A. in Polkowice and Legnica.
    • Personal Data will be processed for a period of 1 year from the date of collection.
    • The recipients of Personal Data will be companies providing services of property protection and, in justified cases, law enforcement and administrative bodies in accordance with applicable laws.
    • You have the following rights in relation to the processing of Personal Data:
      • to access Personal Data,
      • to request their rectification,
      • to remove Personal Data,
      • to demand that the processing of your data be restricted,
      • to object to the processing of Personal Data.
    • The Data Protection Officer of KGHM ZANAM S.A. may be contacted in order to exercise the rights.
    • You have the right to lodge a complaint with the President of the Personal Data Protection Office in the event that the Controller has violated the regulations on Personal Data protection.

  3. PROCESSING OF PERSONAL DATA OF PERSONS̨ IN CONTACT WITH EMPLOYEES OF THE COMPANY BY PHONE, ADDRESSING AN INQUIRY TO THE COMPANY BY POST OR E-MAIL

    In the case of sending inquiries to the Controller via e-mail or traditional correspondence not related to services provided to the sender, another agreement concluded with it or otherwise not related to any relationship with the Controller, Personal Data contained in this correspondence is processed exclusively for the purpose of communication and consideration of the case to which the correspondence relates. The Controller shall only process Personal Data relevant to the case to which the correspondence relates. All correspondence is stored in a manner ensuring the security of Personal Data (and other information) contained therein and disclosed only to authorised persons.

    In view of the above, we wish to inform you that:
    • The Personal Data Controller is KGHM ZANAM S.A. with its registered office in Polkowice at ul. Kopalniana 7.
    • The Controller has appointed a Data Protection Officer, with whom you can contact by e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. or by post with a note: “to the Data Protection Officer”.
    • Personal Data is processed in order to conduct correspondence addressed to the Controller in connection with their business activity, which constitutes the basis for̨ data processing, which is the legitimate interest of the Controller - Article 6(1)(f) of the GDPR.
    • Providing Personal Data is a condition for contacting the sender in order to examine the case and answer the inquiry.
    • Reservation in case of unsolicited correspondence: Please be advised that we will not respond to any correspondence (both paper and e-mail) which will be addressed to the Controller.
    • Personal Data processed for the time necessary to achieve the purpose of the processing, which was indicated above, and then stored for archival purposes for a period of 1 year.
    • The recipients of Personal Data will be companies providing IT and postal/courier services.
    • You have the following rights in relation to the processing of Personal Data:
      • to access Personal Data,
      • to request their rectification,
      • to remove Personal Data,
      • to demand that the processing of your data be restricted,
      • the right to object to the processing of your data; in this case, we will cease processing your data for the purpose described above unless we can demonstrate that there are legitimate grounds for us to process your data, which take precedence over your interests, rights and freedoms, or that the data is necessary for us to potentially establish or defend our claims.
    • The Data Protection Officer of KGHM ZANAM S.A. may be contacted in order to exercise the rights.
    • You have the right to lodge a complaint with the President of the Personal Data Protection Office in the event that the Controller has violated the regulations on Personal Data protection.
    In case of contacting the Controller by phone, in cases not related to the concluded agreement or execution of orders, the Controller may request Personal Data only if it is necessary to handle the case to which the contact relates. In such a case, the legal basis is the legally justified interest of the Controller (Article 6(1)(f) of the GDPR) consisting in the necessity to consider a submitted case related to its business activity.

  4. RECRUITMENT

    As part of recruitment processes, the Controller expects Personal Data to be transferred only within the scope specified in the provisions of the Labour Law (Article 6(1)(c) of the GDPR in connection with Article 221 § 1 of the Labour Code, i.e.:  first name(s) and surname, date of birth, contact details, education, professional qualifications, previous employment), therefore, the information should not be provided more widely. The basis for data processing in this respect is also the legitimate interest of the Controller, which is the verification of the qualifications and skills of candidates for work and the determination of the conditions for possible cooperation (Article 6(1)(f) of the GDPR).  In the event that the applications submitted contain additional data exceeding the scope of the provisions of the Labour Law, their processing will be based on the candidate's consent (Article 6(1)(a) of the GDPR), expressed in an unequivocal acknowledgement being the candidate's submission of the application documents. If the submitted applications contain information inadequate for the purpose of recruitment, they will not be used or taken into account in the recruitment process.

    In view of the above, we wish to inform you that:
    • The Personal Data Controller is KGHM ZANAM S.A. with its registered office in Polkowice at ul. Kopalniana 7.
    • The Controller has appointed a Data Protection Officer, with whom you can contact by e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. or by post with a note: “to the Data Protection Officer”.
    • Personal Data will be processed for the purpose of:
      • assessment of a candidate's qualifications for a specific position,
      • assessment of the ability and skills of a candidate for a specific position,
      • choosing the right person to be employed.
    • The provision of Personal Data results from Article 221 of the Labour Code. The consequence of not providing this data is that it is impossible to consider your candidacy in the recruitment process carried out by the Controller. Providing Personal Data in a broader scope than specified in the provisions of the Labour Law is voluntary.
    • Personal Data processed within the time necessary to complete the recruitment process, and, in the case of consent to process your Personal Data, for future recruitment for a period of 1 year determined by the Controller.
    • The recipients of Personal Data shall be companies providing the Controller's services - IT services.
    • You have the following rights in relation to the processing of Personal Data:
      • to access Personal Data,
      • to request their rectification,
      • to remove Personal Data
      • to demand that the processing of your data be restricted,
      • to object to the processing of data on the grounds of your specific situation - in cases where the data is processed on the basis of the legitimate interest of the Controller,
      • the right to data transfer, i.e. the right to receive Personal Data, in a structured, machine-readable and widely used computerised format. You may send this data to another controller or request that the Controller sends this data to another controller; however, the Controller will do so only if it is technically possible - the right to transfer the data is vested only in the data which is processed on the basis of consent,
      • the right to withdraw consent to the processing of Personal Data at any time without affecting the lawfulness of the processing carried out on the basis of the consent prior to its withdrawal.
    • The Data Protection Officer of KGHM ZANAM S.A. may be contacted in order to exercise the rights.
    • You have the right to lodge a complaint with the President of the Personal Data Protection Office in the event that the Controller has violated the regulations on Personal Data protection.

  5. PROCESSING PERSONAL DATA OF PROXIES OR REPRESENTATIVES, IN CONNECTION WITH PARTICIPATION IN THE TENDER PROCEDURE CARRIED OUT BY KGHM ZANAM S.A. OUTSIDE THE PROCUREMENT SUPPORT SYSTEM

    Within the framework of tender procedures conducted outside the Procurement Support System, the Controller will process the following categories of Personal Data: first name and surname, official position, professional qualifications, official contact details: e-mail, landline and mobile phone number, name of the entity and organisational unit, identity card number.

    In view of the above, we wish to inform you that:
    • The Personal Data Controller is KGHM ZANAM S.A. with its registered office in Polkowice at ul. Kopalniana 7.
    • The Controller has appointed a Data Protection Officer, with whom you can contact by e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. or by post with a note: “to the Data Protection Officer”.
    • Personal Data will be processed for the purpose of conducting a tender procedure.
    • The legal basis for the processing of Personal Data is the legitimate interest of the Controller, consisting in the selection of the most advantageous commercial bid (Article 6(1)(f) of the GDPR).
    • Personal data will be processed until the end of the tender/procurement procedure, and then stored for archival purposes for a period of 5 years, and in the event that an agreement is concluded as a result of selection of the bid - for a period of 5 years from the end of the tax year in which the completion of the agreement will take place, not earlier than the expiry of the statute of limitations for claims arising from it.
    • The provision of Personal Data is voluntary but is a condition for the participation in the tender procedure.
    • The recipient of Personal Data will be the Investor for whom the works are performed.
    • You have the following rights in relation to the processing of Personal Data:
      • to access Personal Data,
      • to request their rectification,
      • to remove Personal Data,
      • to restrict the processing of Data,
      • to object to the processing of Personal Data;
    • The Data Protection Officer of KGHM ZANAM S.A. may be contacted in order to exercise the rights.
    • You have the right to lodge a complaint with the President of the Personal Data Protection Office in the event that the Controller has violated the regulations on Personal Data protection.

  6. THE COLLECTION OF DATA IN CONNECTION WITH THE PERFORMANCE OF AGREEMENTS

    In the case of collecting data for purposes related to the performance of a specific agreement, the Controller shall provide the Data Subject with detailed information on the processing of their Personal Data at the time of concluding the agreement or at the time of acquiring Personal Data if the processing is necessary in order for the Controller to take action at the request of the Data Subject, prior to concluding the agreement.

  7. PROCESSING PERSONAL DATA OF THE STAFF OF CUSTOMERS OR CONTRACTORS COOPERATING WITH THE CONTROLLER

    In connection with the conclusion of commercial agreements in the course of business activity, the Controller obtains from contractors/customers data of persons involved in the implementation of such agreements (e.g. persons authorised to contact, placing orders, performing orders, etc.). The scope of the data transmitted is in any event limited to what is necessary for the performance of the agreement and normally does not include information other than the first name and surname and official contact details. In these cases, Personal Data is processed in order to meet the legitimate interest of the Controller and its business partner (Article 6(1)(f) of the GDPR), which consists in enabling the proper and effective performance of the agreement. Such data may be disclosed to third parties involved in the performance of the Agreement, as well as to entities gaining access to data under the provisions of public disclosure of public information and proceedings conducted under the public procurement law, to the extent provided for by those provisions. The data are processed for the period necessary to carry out the above mentioned interests and fulfil the obligations resulting from the binding regulations.

    In view of the above, we wish to inform you that:
    • The Personal Data Controller is KGHM ZANAM S.A. with its registered office in Polkowice at ul. Kopalniana 7.
    • The Controller has appointed a Data Protection Officer, with whom you can contact by e-mail: This email address is being protected from spambots. You need JavaScript enabled to view it. or by post with a note: “to the Data Protection Officer”.
    • Personal Data (first name and surname and name of the employing entity, contact phone number, e-mail account) is processed in order to identify the persons authorised to carry out the tasks specified in the Agreement, including those having access to the KGHM ZANAM S.A. Confidential Information
    • Thus, Personal Data is processed on the basis of legitimate interests of the Controller connected with the above mentioned purpose, which is to ensure the proper performance of the Agreement and ensure the security of confidential information (the business secret). – Article 6(1)(f) of the GDPR.
    • Disclosing Personal Data is voluntary, but the provision of Personal Data is a condition allowing a person to perform the tasks specified in the Agreement.
    • Personal Data will be processed for the period necessary for the performance and settlement of the Agreement, and then stored for the period resulting from the statute of limitations and the obligation to maintain confidentiality (if a separate statement is signed), as well as tax regulations.
    • Personal Data may be disclosed to legally authorised entities and to entities and their employees providing services to us which require access to your data, including legal, financial, accounting and IT data.
    • You have the following rights in relation to the processing of Personal Data:
      • to access Personal Data,
      • to request their rectification,
      • to remove Personal Data,
      • to restrict the processing of Data,
      • the right to object to the processing of data on the grounds of a specific situation - because we process data on the basis of our legitimate interest, as described above.
    • The Data Protection Officer of KGHM ZANAM S.A. may be contacted in order to exercise the rights.
    • You have the right to lodge a complaint with the President of the Personal Data Protection Office in the event that the Controller has violated the regulations on Personal Data protection.

  8. THE COLLECTION OF DATA IN OTHER CASES

    In connection with the activity conducted, the Controller collects Personal Data also in other cases - e.g. by building and using permanent business contacts during business meetings, industry events or by exchanging business cards - for the purposes of initiating and maintaining business contacts. The legal basis for the processing in this case is the legally justified interest of the Controller (Article 6(1)(f) of the GDPR) consisting in the creation of a network of contacts in connection with the conducted activity. Personal Data collected in such cases are processed only for the purpose for which they were collected, and the Controller ensures their proper protection.

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