Personal data protection and information security have always been a priority in Raben Group. Being a responsible organisation aware that information has a specific value and it constitutes a resource which requires appropriate protection, it is important for us to keep you informed about matters related to personal data processing, particularly in the light of the personal data protection regulations, including the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (GDPR). For this reason, this document presents key information on the legal grounds for the processing of personal data, methods of their collection and use, as well as the rights of data subjects.
- Raben Management Services Sp. z o.o. with its registered office in Robakowo, ul. Zbożowa 1, 62-023 Robakowo,
- Raben Logistics Polska Sp. z o.o. with its registered office in Robakowo, ul. Zbożowa 1, 62-023 Robakowo,
- Fresh Logistics Polska Sp. z o.o. with its registered office in Robakowo, ul. Zbożowa 1, 62-023 Robakowo,
- Raben East Sp. z o.o. with its registered office in Robakowo, ul. Zbożowa 1, 62-023 Robakowo,
- Raben Transport Sp. z o.o. with its registered office in Gądki, ul. Poznańska 71, 62-023 Gądki,
- Raben Real Estate Poland Sp. z o.o. with its registered office in Robakowo, ul. Zbożowa 1, 62-023 Robakowo,
- Raben Trans European Germany GmbH, Holländerstr. 11, 68219 Mannheim, Germany,
- Raben Group N.V., Vorstengrafdonk 81, 5342LW Oss, postal address Postbus 201, 5340AE Oss, the Netherlands,
- Raben Netherlands B.V., Vorstengrafdonk 81, 5342LW Oss, postal address Postbus 201, 5340AE Oss, the Netherlands,
- Raben Logistics Czech s.r.o., Komerční 535, Nupaky 251 01, Czechia,
- Raben Logistics Slovakia s.r.o., Diaľničná cesta 28, 903 01 Senec, Slovakia,
- Raben Trans European Hungary Kft., 2330 Dunaharaszti, Jedlik Ányos út 31., Hungary,
- Raben Ukraine T.z.o.w., 150, Brovarska Street, Velyka Dymerka, Brovarsky district, Kyiv region, 07442, Ukraine,
- Raben Lietuva UAB, Liepkalnio 85B, 02120 Vilnius, Lithuania,
- Raben Latvia SIA, Garā iela 2, Dreiliņi, Stopiņu nov., LV-2130, Latvia,
- Raben Eesti OÜ, Liivalao 11, Tallin 11216, Estonia,
- Raben Logistics Romania S.R.L., Strada Ithaca, Nr. 200, Comuna Bolintin-Deal, Județul Giurgiu, Postal Code 087015, Romania,
- Raben SITTAM Srl, via Monzoro 100 – 20007 Cornaredo, Italy*
- Raben Logistics Bulgaria EOOD, 8 Tsar Kaloyan Str., 2nd floor, Sofia 1000, Bulgaria.
II. Data Controller
The Controller of personal data and other information collected through the website www.raben90years.com is Raben Management Services sp. z o.o. with its registered office in Robakowo (62-023), ul. Zbożowa 1, (hereinafter referred to as: “RMS”) – Shared Services Centre of Raben Group companies, a company which manages i.a. marketing processes in Raben Group, including websites and company accounts in social media.
III. Contact point
We have appointed a Data Protection Officer. It is a person you can contact in all matters relating to the processing of personal data and exercising the rights related to data processing. Contact with our Data Protection Officer is possible at the e-mail address email@example.com or at +48 517 191 373.
IV. Scope, methods and purposes of processing of personal data of persons visiting the website www.raben90years.com and the Raben Group fanpage in social media
We want to be transparent in terms of methods and legal grounds for personal data processing, as well as the purposes for which we process personal data. In order to make our explanation of these issues as clear as possible, we present the following list of processing operations of personal data of persons visiting the website www.raben90years.com and the Raben Group fanpage in social media.
At the same time, we would like to assure you that when processing personal data based on the legitimate interest of the data controller, we try to analyse and balance our interest and the potential impact on the data subject (positive and negative) as well as the rights of that subject. We do not process personal data when we come to the conclusion that the impact on the data subject would override our interests, unless we have a different legal reason, e.g. we have the appropriate consent, or it is required and permitted by the provisions of law.
IV.1. Processing of personal data of persons visiting the website www.raben90years.com
- General information
Natural persons who visit the website www.raben90years.com have control over the personal data they provide to us, and we assure that the collection and use of information about users is limited to the minimum necessary to provide services to them on the expected level.
- Log files
Each time the website is called, our system automatically collects data and information from the computer system of the computer which opens the page. In that case, the following data are obtained:
- information about the type and version of the browser used;
- user’s operating system;
- user’s IP address;
- date and time of calling the page;
- websites from which the user’s system moved to our website (the so-called referrer);
- websites which were called by the user’s system through our website.
The data are also saved in the log files of our system. Recording of the data along with other personal data of the user does not take place. The data cannot be used to identify a specific person because the IP address is masked. The data are also recorded and processed in log files to analyse errors and for statistical purposes.
Temporary saving of the IP address by the system is necessary to make the website available to the user’s computer. For this purpose, the user’s IP address must be saved for the duration of the session. Saving in log files is intended to ensure the functionality of the website. In addition, the data are used to optimize the website and to ensure the security of our information systems. Data analysis for marketing purposes therefore does not take place.
To a limited extent, we may collect personal data automatically via cookies located on the website www.raben90years.com. A cookie is a small file containing information data recorded and stored on a computer, tablet or a smartphone, used for accessing websites. Cookies usually contain the name of the website where they originate from, duration of their storage on the device and their unique number.
Cookies are used for the following purposes:
- adjusting the website to the user preferences and optimising the use of website;
- building statistics which explain how Internet services are used by users, which allows for improving their structure and the content;
There are three major types of cookies: “session”, “persistent” and “third party” cookies.
Session cookies are temporary files stored on the user’s computer, tablet or smartphone until logging out, leaving the page or closing the web browser, and they are used to offer services which require verification within a particular website.
Persistent cookies are stored on the computer, tablet or smartphone for the duration defined in the parameters of the cookie, or until they are deleted by the user, and they are used to remember the settings selected by the user and to personalise the interface.
Third party cookies allow for gathering information about how websites are used and for delivering advertising content to the users, which is optimally adjusted to their interests.
Personal data collected via cookies are encrypted so as to prevent undesired and unauthorised persons from accessing them. They are collected for the sole purpose of performing specific functions for the user.
Using our website www.raben90years.com without using cookies is possible, however in individual cases certain limitations in functionalities of the website may appear while browsing.
Detailed information about the possibilities and methods of supporting cookies is available in the settings of internet browsers.
In order to analyse the user behaviour we use Google Analytics, a web analytics and reporting software by Google Inc. (“Google”). However, we have requested Google to make your IP address anonymous before analysing user behaviours in the web. We have introduced certain lines to the program code of Google Analytics. As part of the analysis service, we may also collect information such as page view statistics, links through which the page was opened, division into gender or age group, etc.
As we have requested making IP addresses anonymous, your IP address is cut to the EU Member States or other European Economic Area states before it is sent to the Google server in the USA. Your full IP address may be sent to the Google server in the USA and abbreviated there only in some exceptional circumstances beyond our control. At our request, Google will use the above-mentioned information to evaluate how our website is used, generate site activity reports and provide us with other services connected with the use of the website and the Internet. Your IP address provided by your web browser to Google Analytics is in no way connected to other Google data.
We would like you to note that you can prevent Google from recording and processing the data from (Google) cookies concerning your website use (including your IP address) as well as processing these data by Google, if you download and install a special browser plug-in available at tools.google.com/dlpage/gaoptout .
- Contact via e-mail
If you wish to write an e-mail to us, please be advised that unencrypted e-mail messages which are sent via the Internet are not accurately protected against access by third parties.
- Using Social Plug-ins
On the website www.raben90years.com, we use Social Plugins (‘Plugins’) of the social networks Facebook, Instagram and LinkedIn. The plugins are marked with the logos of the portals. If you open a page which contains a plugin, your browser will automatically make a direct connection with the servers of the social portal.
Information on the processing of your data by LinkedIn can found at https://pl.linkedin.com/legal/privacy-policy
The photographs and icons presented on the website are the property of Raben Group or originate from photo banks such as Fotolia, Freepik, Adobe Stock, they have been taken during photo shoots purchased from agencies as the content of the site.
IV.2. Processing data of persons visiting the Raben Group fanpage
RMS and Facebook are the joint controllers of data of the Users who have liked the Raben Group fanpage available at: https://www.facebook.com/RabenGroupOfficial/.
As the owner of the Instagram brand, Facebook also jointly controls the data of persons who follow Raben Group fanpage on Instagram located at https://www.instagram.com/raben_group/?hl=pl
RMS and LinkedIn are joint controllers of the data of Users who follow Raben Group fanpage at https://pl.linkedin.com/company/the-raben-group/
- Scope and manner of data processing
Due to the above, RMS, as Administrator of the fanpage/channel, may obtain anonymous statistical data on persons visiting the website. These data are collected thanks to cookie files, each of whom contains a unique user code (they are saved by the portal administrator on the computer hard drive or on any other data carrier of the persons visiting the fanpage). The user code which can be linked to the connection data of users registered in a particular portal is downloaded and processed when the fanpage/channel is opened. Although they are anonymous data, RMS may ask the portal Administrator to process them in the field of:
- demographic data (including trends in age, gender, marital status and professional status);
- information about lifestyle and interests;
- geographic data which allow for determining where to conduct special promotional actions or organize events, how to best target the information offer.
In the case of LinkedIn, the statistics on visitors to the site may include in particular:
- location of the user;
- function/type of position held;
- size of the company in which the user is employed;
- sector the users operates in.
At the same time, the data of persons who liked the fanpage/channel can be processed in a non-anonymised form in the case of:
- communication with Raben Group through a particular portal (this possibility does not apply to the LinkedIn portal),
- commenting posts shared on the fanpage/channel,
- participation in various promotional campaigns, contests – in this case, the processing will be carried out on the basis of the User’s explicit consent (this possibility does not apply to the LinkedIn portal).
Under no circumstances will the data of persons who like the Raben Group fanpage/channel be used for a purpose other than the one for which they were submitted. Their processing will be carried out exclusively on the particular portal and in accordance with the general terms and conditions of using the portal.
We want our fanpage to be a place for exchange of opinions and experience, where Users will be able to communicate while maintaining the principles of personal culture and mutual respect. Therefore, please respect the following rules:
- we do not tolerate hate speech or content of a racist, homophobic, sexist, pornographic, vulgar nature, insulting other religions, beliefs or nations;
- we do not tolerate breaking the law, acting in violation of applicable laws, infringing the rights of third parties, including copyrights and intellectual property rights;
- please pay special attention to information posted in the comments to posts;
- fanpage is a public space, therefore providing data by the Users, such as a PESEL number, ID card number, telephone number or authorization data (login, password) may involve negative consequences for the User who publicizes this type of information.
We reserve the right to delete or hide posts which break the aforesaid rules.
V. Legal grounds for the processing of personal data through the website and fanpages on social media
- Processing of personal data of persons who visit the website www.raben90years.com operated by Raben Group or publish content of the Raben Group fanpage in social media, is based on different legal grounds for processing depending on the category of personal data which we process and the purpose of processing.
- We process personal data of visitors to the website www.raben90years.com on the basis of a legitimate interest of the data controller.
- Data of persons who have sent us an enquiry to the e-mail address: firstname.lastname@example.org are processed in order to pursue the legitimate interest of the data controller, i.e. Responding to the message.
- The data of persons visiting our fanpage are processed in accordance with the rules of using the portal, based on the User’s consent.
- In the case of promotional campaigns carried out in social media, consisting in the User sending a photograph on a specific subject, the consent to the processing of their personal data in the form of the image recorded in the photo, name, surname and mailing address in the event of winning a prize (for the purpose of sending it) is expressed by them by providing/sharing this photo and providing the indicated data. In the case of sending a photograph which also displays the image of third parties, the User confirms at the same time that they have the right to use, including to share, the image of these persons.
- Legal bases for processing personal data of persons contacting Raben Group via the website www.raben90years.com for purposes other than those described herein are indicated in privacy policies of particular companies of Raben Group available on the website www.raben-group.com
VI. Period of processing of personal data obtained via the website and fanpages in social media
The time during which we can process personal data depends on the legal basis which constitutes a legitimate premise for personal data processing. Accordingly, please be advised that if we process personal data based on:
- a consent, the period of processing lasts until the data subject revokes the consent or the completion of the processing purpose;
- a legitimate interest of the data controller, the period of processing lasts until the above-mentioned interest (e.g. providing an answer to the question and possible period of limitation of civil law claims) ceases to exist, or until the data subject objects to further such processing – in situations where such an objection is in accordance with the law;
VII. Recipients of data processed through the website and fanpages in social media and data transfer outside the European Economic Area
We transfer your personal data to other entities based on the requirements of the law or in connection with pursuing the purpose for which they were provided to us. At the same time, we declare that we only use the services of verified entities which guarantee the security of your data. Contracts under which we entrust the processing of personal data contain provisions about the protection measures required by us, ensuring confidentiality, integrity and availability of the transferred data.
We may transfer your personal data to companies or other reliable business partners who provide services on our behalf, for example to provide technical support, to assess the suitability of the website for marketing purposes or other types of providing the service. Your personal data are only transferred to these entities and other third parties if this is necessary to achieve the purpose for which the data were collected.
In connection with the above, we point out that the recipients of personal data which we process as a data controller, may be:
- entities providing hosting services,
- subcontractors providing services of software provision, maintenance of software or hardware which we use, as well as providers of services we use
- entities providing services in the field of questionnaire surveys,
- law enforcement authorities, regulatory authorities and other public administration bodies.
Your personal data may also be transferred to data processors established outside the European Economic Area (EEA)
Countries outside the EEA may not offer the same level of personal data protection as the EEA countries. Before your personal data are transferred outside the EEA, we will make every effort to ensure that such transfer does not lead to a reduction in the level of protection guaranteed under the regulations in force in the EEA countries. In the case of transfer of your personal data outside the EEA, their transfer will be made under standard data protection contractual clauses adopted by the European Commission.
VIII. Rights related to the processing of personal data which can be exercised by users of the website and fanpages in social media
Natural persons have specific rights regarding their personal data, and we as data the data controller are responsible for exercising these rights in accordance with the applicable law. In case of any questions or requests regarding the scope of and exercising the rights, as well as in order to exercise a specific right in the field of personal data protection, please contact our Data Protection Officer. We reserve the right to exercise the following rights after successfully verifying the identity of the person applying for the performance of a specific action.
You have the following rights connected with personal data processing:
- right to revoke the consent to data processing at any moment if we process your personal data on the basis of your consent;
- right to access your personal data;
- right to rectify your personal data;
- right to demand erasure of your personal data;
- right to restrict processing your personal data;
- right to object to processing of your data due to your particular situation – in cases when we process your data based on our legitimate interest;
- the right to portability of your personal data, i.e. the right to receive your personal data from us, in a structured, commonly used, machine readable format. You can send these data to another data controller or request us to transfer your data to another controller on your behalf. However, we will do this only if such a transfer is technically possible. You have the right to personal data portability only with reference to the data which we process on the basis of a contract concluded with you or on the basis of your consent;
- right to lodge a complaint with the supervisory authority responsible for personal data protection, i.e. the President of the Personal Data Protection Office.